DERR-2024-011673

REVISED REMEDIAL ACTION PLAN
FOR
FACILITY RELATED ACTIVITIES
STATE OF UTAH VOLUATARY CLEANUP PROGRAM
LIBERTY CORNER
1229-1265 SOUTH 300 WEST
SALT LAKE CITY, UTAH 84101
UDEQ VOLUNTARY CLEANUP PROGRAM SITE #C125
Prepared by:
At las Technical Consultants
358 South 700 East, B518
Salt Lake City, Utah 84102
Prepared for
Utah Department of Environmental Quality
Division of Environmental Response and Remediation
Voluntary Cleanup Program
195 North 1950 West
Salt Lake City, Utah 84114
And
Liberty Corner Associates, LLC
6440 South Wasatch Boulevard, Suite 100
Salt Lake City, Utah 84121
September 26, 2024
Liberty Corner, Salt Lake City, Utah September 2024
VCP Site #C125 Version 3
Remedial Action Plan

Project No. 271EM00861 i Atlas Technical Consultants LLC
TABLE OF CONTENTS
1.0 INTRODUCTION AND SITE DESCRIPTION .............................................................................. 1
1.1 Current and Future Land Use ................................................................................................... 1
1.2 Objectives ................................................................................................................................. 2
1.3 Physical Setting ........................................................................................................................ 2
1.3.1 Topography .......................................................................................................................2
1.3.2 Geology .............................................................................................................................2
1.3.3 Hydrogeology ....................................................................................................................3
2.0 PREVIOUS SITE INVESTIGATIONS ........................................................................................... 3
3.0 PRIMARY CONTAMINANTS OF CONCERN ............................................................................. 6
4.0 CONCEPTUAL SITE MODEL ....................................................................................................... 6
4.1 Exposure Pathways ................................................................................................................... 6
5.0 REMEDIAL ACTION OBJECTIVES AND PROPOSED CLEANUP LEVELS ....................... 7
5.1 Remedial Action Objectives ..................................................................................................... 7
5.2 Proposed Cleanup Levels ......................................................................................................... 8
5.2.1 Soil.....................................................................................................................................8
5.2.2 Groundwater ......................................................................................................................8
6.0 REMEDIAL ACTION........................................................................................................................ 9
6.1 Soil Removal Procedures ......................................................................................................... 9
6.2 Post-Excavation Groundwater Sampling ............................................................................... 11
6.3 Waste Characterization Sampling .......................................................................................... 11
6.4 Groundwater Monitoring ........................................................................................................ 11
6.5 Installation of Chemical Vapor Barrier .................................................................................. 11
6.6 Site Remediation Summary Report ........................................................................................ 11
6.7 Site Preparation ..................................................................................................................... 11
6.7.1 Worker Projection ...........................................................................................................12
6.6.2 Dust Control ....................................................................................................................12
6.6.3 Anti-Tracking ..................................................................................................................13
6.6.4 Site Control/Security .......................................................................................................13
6.6.5 Stormwater Management.................................................................................................13
6.6.6 Public Notice ...................................................................................................................13
6.7 Environmental Covenants ...................................................................................................... 13
6.8 Site Management Plan ............................................................................................................ 13
7.0 SCHEDULE ..................................................................................................................................... 13
8.0 CONTINGENCY PLANS ............................................................................................................... 14
8.1 Inclement Weather.................................................................................................................. 14
8.2 Unexpected Discovery............................................................................................................ 14
8.2.1 Remedial Action ..............................................................................................................14
8.3 Deviation from Plan ............................................................................................................... 14
9.0 HEALTH AND SAFETY ................................................................................................................ 14
10.0 REFERENCES ............................................................................................................................... 15

FIGURES
Figure 1 – Site Vicinity Map
Figure 2 – Soil Boring Location Map
Liberty Corner, Salt Lake City, Utah September 2024
VCP Site #C125 Version 3
Remedial Action Plan

Project No. 271EM00861 ii Atlas Technical Consultants LLC
Figure 3 – Proposed Soil Excavation Map

APPENDICES
Appendix A – Proposed Site Redevelopment Plans
Appendix B – Arsenic Background Threshold Value Determination
Appendix C – Chemical Vapor Barrier Specifications
Appendix D – Fugitive Dust Mitigation Plan
Appendix E – Stormwater Pollution Prevention Plan
Appendix F – Draft Public Notice
Appendix G – UDEQ RAP Review Comments Dated July 16, 2024, and UDEQ Email August 29, 2024

Liberty Corner, Salt Lake City, Utah September 2024
VCP Site #C125 Version 3
Remedial Action Plan

Project No. 271EM00861 Page 1 Atlas Technical Consultants LLC
1.0 INTRODUCTION AND SITE DESCRIPTION

The property consists of four parcels of developed land located near the northeast corner of
300 West and 1300 South, Salt Lake City, Utah 84101. In total, the property comprises
approximately 2.042 acres in size. The property is developed with several office and warehouse
building structures formerly occupied mainly by Schmidt Auto Body & Paint, which were
originally constructed in the 1960s and then additions in the 1970s and 1980s were added. The
surrounding area primarily consists of commercial properties with some residential properties
present as well.

Previous subsurface investigations have documented contaminants of concern (COCs) in soils
and groundwater at the Site to be above the applicable regulatory screening criteria. In
February 2023, Liberty Corner Associates, LLC, (Applicant) submitted an application to enter
the Site into the Utah Voluntary Cleanup Program (VCP) administered by the Utah Department
of Environmental Quality (UDEQ), Division of Environmental Response and Remediation
(DERR). The Site was admitted to the VCP on March 10, 2024, and is identified as Liberty
Corner, Site #C125.

It is our understanding that the Site is being proposed for redevelopment as residential property
described as the Liberty Corner Apartments. To move forward with redevelopment and based
on conversations with the Site owner(s) and the UDEQ DERR VCP group, remedial actions are
required. The following sections of this Remedial Action Plan (RAP) describe the procedures
that will be used to remediate contaminated soil and groundwater at the Site.

The RAP is organized as follows:

• Section 1 provides an introduction of the project and the objectives of the
remedial action.
• Sections 2 and 3 provide the relevant background information, including a
summary of the previous investigatory work and site characterization that
identified remedial areas and primary COCs.
• Section 4 discusses the conceptual site model (CSM) which identifies completed
pathways for contaminants to receptors that require mitigation for the proposed
development.
• Section 5 provides the remedial action objectives (RAOs) and clean‐up goals.
• Section 6 provides the remedial action plans to address contaminated media on
the Site.
• Section 7 includes the contingency plans for the remedy.
• Section 8 includes health and safety.
• Section 9 is the list of references pertaining to this RAP.

The Site Vicinity Map is presented as Figure 1 and depicts the Site location and the surrounding
area. The Site Map, presented as Figure 2, shows the Site boundaries, identifies site features,
and identifies the sample locations completed to date on the Site.

1.1 Current and Future Land Use

The Site is currently occupied by several office and warehouse building structures which are
mainly occupied by Schmidt Auto Body & Paint. In January 2024 the building occupants
vacated the property and the Site is currently unoccupied. Proposed redevelopment of the Site
includes demolition of the current structures. Proposed site redevelopment plans for the Site
are provided in Appendix A.
Liberty Corner, Salt Lake City, Utah September 2024
VCP Site #C125 Version 3
Remedial Action Plan

Project No. 271EM00861 Page 2 Atlas Technical Consultants LLC
1.2 Objectives

The objectives of the RAP were developed to remediate petroleum contaminated soil and
groundwater at the Site to concentrations that are protective of human health and the
environment (i.e., future residents, the general public, wild life and biota) for the planned
development and land use.

The RAP will also include graphical and statistical evaluations for arsenic and lead in soil to
establish site-specific background concentrations of these naturally occurring elements. Data
to be utilized for the background concentration determination will include qualified laboratory
analytical results from previous site investigation activities. The results of the background
concentration evaluation will be used as the basis for determining if removal of soil containing
arsenic and/or lead at concentrations in excess of the site-specific background concentration
range is warranted.

In addition, upon removal of the buildings and surface cover material, further delineation of soil
impacts and removal of petroleum impacted soil will be completed as part of the RAP. As part
of the soil removal effort, soil and groundwater samples would be collected to document
residual impacts. Any remaining impacts will then be managed under a Site Management Plan
prepared for the Site.

1.3 Physical Setting

1.3.1 Topography
The Site is located in a highly urbanized setting with 100% of the Site covered in paved
surfaces or under a building footprint. The Site’s elevation is approximately 4,250 feet above
mean sea level and is relatively flat with a slight topographic gradient to the west. The Site
location and the surrounding area is included on a USGS topographic map presented as Figure
1.

1.3.2 Geology
The Site is regionally located in the Salt Lake Valley which is a north‐south trending valley
located southeast of Great Salt Lake. The Salt Lake Valley is a segment of the Wasatch Front
Valley section of the Great Basin physiographic province. The Salt Lake Valley is bounded on
the east and northeast by the central portion of the Wasatch Range, on the northwest by Great
Salt Lake, on the west by the Oquirrh Mountains, and on the south by the Traverse Mountains.
The Salt Lake Valley is a half‐graben that is bounded by faults on its east, west, and south
sides. Sediments have been filling this graben since the Tertiary. The Tertiary and Quaternary
basin fill is up to 4,000 feet thick in some areas of the valley and consists of unconsolidated to
semi‐consolidated clay, silt, sand, gravel, tuff, and lava. Quaternary sediments in the upper part
of the basin fill range from 0 to 2,000 feet thick (Wallace and Lowe, 2008). Based on soil
borings data collected during site characterization (Atlas, February 2024) at the Site, surface
soils are primarily composed of urban fill ranging from approximately 0 to 3 feet below ground
surface (bgs). Beneath the fill material, black to dark gray organic silt is encountered to the
depth of approximately 5 to 6-feet bgs. Beneath the organic silt, gray silt is primarily
encountered to the depth of soil borings at 15 feet bgs. Groundwater was encountered during
drilling at a depth of approximately 8-feet bgs.

Liberty Corner, Salt Lake City, Utah September 2024
VCP Site #C125 Version 3
Remedial Action Plan

Project No. 271EM00861 Page 3 Atlas Technical Consultants LLC
1.3.3 Hydrogeology
The Site is underlain by the Basin‐Fill Aquifer system in the Salt Lake Valley which includes a
shallow unconfined aquifer underlain by a confining layer, which is underlain by the “principal
aquifer.” Most of the groundwater from water wells in Salt Lake Valley is drawn from the
principal aquifer. The shallow unconfined aquifer has a maximum thickness of approximately 50
feet and yields little water (the water is generally of low quality), thus, is rarely used for water
supply (Wallace and Lowe, 2008).

Based on the monitoring well data collected during site characterization, shallow ground water
is encountered at depths ranging from approximately 4 feet bgs to 8 feet bgs. A State of Utah
registered land surveyor (McNeil Engineering, Inc.) was contracted to land survey the top-of-
casing elevations of the monitoring wells. The groundwater elevation data collected from the
monitoring wells indicates that the groundwater flow direction beneath the Site is to the
southeast.

2.0 PREVIOUS SITE INVESTIGATIONS

In July 2021, CMT Engineering Laboratories (CMT, July 2021) completed a Phase I
Environmental Site Assessment (ESA) of the Schmidt property (1265 South 300 West, 257
Lucy Avenue, Salt Lake City, UT). Based upon the findings of the Phase I ESA, two
Recognized Environmental Conditions (RECs) were identified:

• Drain in the floor of the flammable storage building of the subject property that showed
evidence (staining) of impact from leaking petroleum products and/or chemicals (Section
5.2.5)
• Sump drain in the south-central parking lot of the property that receives runoff from a
wash bay (Bay 7) on the property and from the surrounding parking lot (Section 5.2.8).

The CMT report provided no recommendations associated with the identified RECs.

In January 2022, RMEC (RMEC, January 2023), conducted a limited subsurface investigation
at the property, which consisted of eight soil borings. The analytical results confirmed the
presence of subsurface release of fuel products, predominantly diesel-range organics, at soil
boring location B-6; however, the impacts were below the DERR Initial Screening Levels (ISLs).
RMEC recommended further investigation and sampling closer to the potential source of the
contamination in order to provide confirmation on the extent and magnitude of the impact from
either a) the storm water inlet French drain and/or b) the sewer/floor drain located in the
flammable storage/thinner sheds. RMEC was unable to access the interior of Bays 8, 9, and 10
where discharges of paint product to floor drains was evident during the Phase I ESA site
reconnaissance. While no significant impacts were noted in the analysis of soil and
groundwater from soil borings collected outside of these bays, evidence of potential volatile
organic compound (VOC) impacts were noted in soils at the groundwater interface zone of each
boring. RMEC recommended that additional soil borings be advanced inside of these bays to
determine if soil impacts were present in the direct vicinity of the floor drain inlets.

Review of the groundwater data collected during the RMEC investigation indicated no detection
of impacts above the DERR ISLs. While groundwater impacts were not identified, RMEC
concluded that the presence of residual petroleum or VOC impacts in soils may present a
potential indoor air quality risk to future residential development of the property. As such, any
sources of impacted soils that are discovered prior to or during development, should be
characterized and, if necessary, removed and transported offsite to an appropriately licensed
Liberty Corner, Salt Lake City, Utah September 2024
VCP Site #C125 Version 3
Remedial Action Plan

Project No. 271EM00861 Page 4 Atlas Technical Consultants LLC
landfill for disposal. If impacted soil removal occurs, confirmation sampling should be performed
to verify and document that the full extent of impacted soils were adequately removed.

In August 2022 Atlas Technical Consultants (Atlas) completed a Phase I ESA
(Atlas, August 17, 2022), on a group of properties located at the northeast corner of State
Street and 1300 South Street (Schmidt Property at 1229 South and 1265 South 300 West, 257
West Lucy Avenue, and 246-252 West 1300 South) in Salt Lake City, Utah. These properties
included the same property as the 2021 CMT Phase I ESA (Schmidt Sign and Paint) with the
inclusion of the northern parcel (Schmidt Auto Body). Several RECs where identified at the
properties. The Phase I ESA recommended further environmental work to determine if the
following RECs represented an actual release into the soil or groundwater at the site.

• Atlas observed several floor drains inside the Paint Bays (two circular drains inside each
bay) which exhibited evidence of paint staining. Ms. Lisa Schmidt (with Schmidt Sign
and Paint) indicated the floor drains in each bay discharge to the oil/water separator to
the west of the building in the asphalt and were probably installed in the mid-1980s.
Based on the age of these floor drains and data collected during a previous investigation
conducted by RMEC in 2021 (RMEC, 2021); the drains were identified as a REC.

• Atlas observed one oil/water separator on the Schmidt Auto Body portion of the
property. Mr. Tracy Schmidt (with Schmidt Auto Body) indicated rinse water from
pressure washing flows into a drain line connected to the oil/water separator, which then
discharged to the city sewer. He also indicated it had not been used since the 1990s
and was probably installed in the late 1980s. Atlas was not able to access inside the
oil/water separator at the time of the Phase I ESA. Given that the structural integrity of
the oil/water separator could not be determined, the lack of subsurface data, and it’s
age, the oil/water separator and its associated flow drain was identified as a REC.

Due to this information, additional investigation was recommended by Atlas to confirm that
historical operations (Auto Body & Paint Shop) had not impacted the property.

In September 2022 Atlas conducted a limited subsurface investigation (Atlas, September 2023)
at the property. A total of five soil borings were advanced at the property. The results of the
limited subsurface investigation indicated the presence of naphthalene and xylenes in soil and
groundwater above the US EPA enforcement standards. In addition, Total Petroleum
Hydrocarbons as Gasoline (TPH-GRO), TPH as Diesel (TPH-DRO), and Oil & Grease impacts
were measured above the UDEQ enforcement standards. As a result of the impacts to soil and
groundwater and the proposed development of the property into a residential multi-family
facility, the Client entered into an agreement with the UDEQ VCP with the DERR to address the
impacts at the property. The first step towards addressing impacts at the property was to
prepare a Quality Assurance Project Plan (QAPP) that would provide the framework for the
data quality expectations for the environmental sampling and analysis that will be completed at
the property. On April 13, 2023, Atlas submitted the QAPP (Atlas, April 2023) to the UDEQ for
review, and in a correspondence dated June 20, 2023, the DERR approved the QAPP.

On April 14, 2023, Atlas attended an on-site meeting at the property with the UDEQ Project
Manager (Mr. Lincoln Grevengoed) and Cowboy Partners personnel. As part of the site
meeting, the soil and groundwater data results were reviewed and discussed. The data
collected in the direct vicinity of the Paint Bays (Atlas borings SB-3, SB-4, and SB-5) indicates
that minor groundwater impacts are present just above the EPA drinking water maximum
contaminant level (MCL) and that soil impacts are below the EPA Regional Screening Levels
(RSL). During the data discussion, Atlas stated that the groundwater laboratory results in this
Liberty Corner, Salt Lake City, Utah September 2024
VCP Site #C125 Version 3
Remedial Action Plan

Project No. 271EM00861 Page 5 Atlas Technical Consultants LLC
area are likely biased high because the groundwater samples were collected through the drill
rods at the soil/groundwater interface. Given that the groundwater impacts were only slightly
above the MCLs in this area, Atlas recommended that a monitoring well be installed in the direct
vicinity of SB-4 and SB-5 so that groundwater impacts could be more accurately evaluated.

On May 4, 2023, Atlas participated in a follow-up conference call with the UDEQ and Cowboy
Partners to discuss the next step in the VCP process for the property. The UDEQ VCP Program
Manager, Mr. Bill Rees, clarified their position and requested that a comprehensive subsurface
investigation be conducted at the site before recommendations for remedial actions be
implemented. Based upon the discussion with the UDEQ, Liberty Corner Associates requested
that Atlas prepare a Site Characterization Workplan for the property. The final work plan was
submitted to the UDEQ on September 11, 2023, and was approved by the UDEQ in a letter
correspondence dated September 25, 2023.

In November and December 2024, Atlas completed a Site Characterization of the property.
Eighteen soil borings were advanced to characterize subsurface conditions beneath the Site. In
addition, three of the soil borings were converted to monitoring wells. The soil boring and
monitoring well locations, along with sample locations from previous investigations, are present
in Figure 2.

Review of the soil VOC, TPH-GRO, TPH-DRO, and Oil & Grease analytical data indicated no
detection of constituents above their respective USEPA Residential RSLs or above the UDEQ
ISLs in any of the samples submitted for analysis. Review of the soil polycyclic aromatic
hydrocarbon (PAH) data indicated that benzo(a)pyrene (BaP) was detected in one soil sample
slightly above the USEPA Residential RSL of 0.11 mg/kg (SB-13 @ 2-3’). Review of the soil
metals data indicate the presence of arsenic above the USEPA Residential RSL in all of the
samples collected except for SB-9 at 2-3’. The arsenic concentrations measured above the
laboratory reporting limits ranged from 1.36 mg/kg to 18.1 mg/kg. Lead was also measured
above the USEPA Residential RSL in SB-17 (862 mg/kg @ 2-3’) and SB-19
(276 mg/kg @ 2-3’). No other constituents of concern were measured above their respective
USEPA RSLs or above their respective UDEQ ISLs in any of the other soil samples submitted
for analysis.

Review of the groundwater laboratory results indicated no detection of VOCs, PAHs, or
TPH-GRO or DRO above their respective MCLs or ISLs in any of the samples except for
benzene at a concentration of 5.41 µg/L in SB-19. Review of the Oil & Grease data indicated
an exceedence of the UDEQ ISL of 10,000 µg/L in SB-17 at a concentration of 13,500 µg/L.
Review of the groundwater metals data indicate the presence of arsenic above the USEPA
MCL of 10.0 µg/L in SB-9 (37.2 µg/L), SB-10 (50.4 µg/L), and SB-11 (48.3 µg/L). No other
metals were measured above their respective MCLs in any of the other groundwater samples
submitted for analysis.

Based upon review of the historical data (Atlas, September 2022) and data collected during this
investigation, it appears that petroleum impacted soil and groundwater are present above
enforcement standards in the direct vicinity of the Oil/Water Separator and hydraulic lift area
and near the paint bays and/or Painting and Storage Building. The soil data also indicate that
arsenic impacted soil above the USEPA Residential RSL is present throughout the property and
is present in the groundwater above its MCL at three sample locations.

Based upon review of the soil and groundwater data, Atlas recommended that a Remedial
Action Plan (RAP) be prepared to address the petroleum impacted soil and groundwater in the
vicinity of the oil/water separate and hydraulic lift and near the Painting and Storage Building. In
addition, Atlas recommended that the RAP include graphical and statistical evaluations f or
Liberty Corner, Salt Lake City, Utah September 2024
VCP Site #C125 Version 3
Remedial Action Plan

Project No. 271EM00861 Page 6 Atlas Technical Consultants LLC
arsenic and lead in soil to establish site-specific background concentrations of these naturally
occurring elements. Data to be utilized for the background concentration determination will
include qualified laboratory analytical results from the previous site characterization activities.

The results of the background concentration evaluation were to be used as the basis for
determining if removal of soil containing arsenic and/or lead at concentrations in excess of the
site-specific background concentration range is warranted. Atlas also recommended that upon
removal of the buildings and surface cover material, further delineation of soil impacts and
removal of petroleum impacted soil would be completed as part of the RAP. As part of the soil
removal effort, soil and groundwater samples would be collected to document residual impacts.
Atlas suggested that any remaining impacts would then be managed under a Site Management
Plan prepared for the site.

3.0 PRIMARY CONTAMINANTS OF CONCERN

Based on the results of previous environmental investigations, the associated primary
Contaminants Of Concern (COC) in the soil are benzo(a)pyrene, Oil & Grease, TPH-GRO,
TPH-DRO, arsenic, and lead. Review of the groundwater data indicate that Oil & Grease, TPH-
GRO, TPH-DRO, arsenic, and lead are the primary COCs.

4.0 CONCEPTUAL SITE MODEL

A conceptual site model (CSM) was developed for the Site by identifying COCs in the impacted
on‐site media and the pathways by which potential receptors (human and ecological) could be
exposed to potential COCs based on the intended future use as a mixed residential/commercial
development.

Exposures to contaminated soil and groundwater at the Site were assessed for potential human
and ecological receptors. Human receptors include construction workers and future residents.
Wildlife and biota (including sediment dwelling organisms) were also considered as potential
ecological receptors.

In the near future, the Site is intended to be redeveloped as a multi-family apartment complex.
The proposed redevelopment will include a multi-family apartment complex with a multi-level
parking structure and concrete and asphalt paved areas throughout the property. Limited areas
of landscaping will be installed around the Site perimeter. Based upon observations made at
the Site and surrounding properties, it does not appear that the Site would provide significant
viable habitat to support ecological populations. Consequently, current and anticipated future
site conditions do not represent a significant threat to onsite ecological receptors.

In addition, since a toxicity assessment is beyond the scope of this RAP, we have
conservatively assumed that all routes of exposure (inhalation, ingestion and dermal exposure)
are of concern for all contaminants. Although highly unlikely, the incidental ingestion of
groundwater is also included for both residents and construction workers.

4.1 Exposure Pathways

Based on current and anticipated future site conditions, potential exposure pathways are
generally limited to those involving human receptors. The human receptor category includes
construction workers engaged in the site redevelopment activities and future site residents
assuming occupancy after completion of the site redevelopment activities. The CSM considers
the following exposure pathways for the Site’s impacted media:
Liberty Corner, Salt Lake City, Utah September 2024
VCP Site #C125 Version 3
Remedial Action Plan

Project No. 271EM00861 Page 7 Atlas Technical Consultants LLC
• Surface Soil – Exposure pathways associated with surface soils (i.e., soil within the
upper 2 feet of land surface) include inhalation of fugitive dust, ingestion and dermal
contact. In addition to wind disturbance, surface soil may also be eroded and
transported offsite through the movement of surface water or storm water. The surface
soil matrix represents a potential matrix of concern for human receptors, including
construction workers and future site residents, through the inhalation, incidental
ingestion, and dermal contact routes of exposure. It should be noted that under the
post-development scenario, the surface soil exposure pathway is expected to be
incomplete, with the possible exception of relatively small landscaped areas around the
building perimeter.

• Subsurface Soil ‐ Exposure pathways associated with subsurface soil include ingestion
and dermal contact with subsurface soil (i.e., soil at depths of > 2 feet bgs). The
subsurface soil matrix represents a potential matrix of concern for construction workers
and potentially future site residents via the inhalation, incidental ingestion, and dermal
contact routes of exposure. The subsurface soil exposure pathway is expected to be
incomplete under the post-development scenario, with the possible exception of
occasional subsurface utility maintenance or replacement activities.

• Groundwater ‐ While the previous assessment data is not suggestive of vertical
migration of metals from overlying soil to shallow groundwater, certain
naturally-occurring metals (e.g., arsenic, lead, and selenium) were detected in
groundwater. Naturally-occurring metals, including arsenic, barium, and selenium were
detected in at least one site groundwater monitoring well. There is no evidence of
significant leaching of metals from subsurface soil to groundwater, based on
groundwater sampling results and TCLP analyses. Grab groundwater samples collected
from soil borings through drill rods at the soil/water interface contained trace
concentrations of other naturally-occurring metals including barium, cadmium,
chromium, lead, and mercury. Based on our experience with other similar
investigations, the grab-type groundwater samples tend to contain higher concentrations
of suspended solids which biases the laboratory analytical results to the high side. The
laboratory analytical results of groundwater samples collected from the on-site
monitoring wells support this interpretation and demonstrate that the concentrations of
naturally-occurring metals in groundwater are below applicable drinking water MCLs for
metals. Further, shallow groundwater at the Site and general vicinity is not utilized as a
potable water source. For these reasons, the ingestion pathway is considered an
incomplete exposure pathway.

5.0 REMEDIAL ACTION OBJECTIVES AND PROPOSED CLEANUP LEVELS

This section provides the remedial action objectives and proposed clean up levels for the Site
that will be protective of human health and the environment considering the contaminants
present and the proposed land use and exposure scenarios discussed in Section 5.0.

5.1 Remedial Action Objectives

As part of the RAP, petroleum impacted soil in the vicinity of the oil/water separator and the
hydraulic lift (SB-1 and SB-2), and in the vicinity of SB-13 will be removed. In addition, the area
in the direct vicinity of SB-17 will be excavated to further evaluate Oil & Grease impacts in this
area. Soils impacted above the BTV for arsenic and the RSL for lead in the direct vicinity of SB-
12, SB-17, SB-19, and SB-20 will also be removed. Upon completion of the soil removal effort,
post-excavation soil samples will be collected to confirm impacted soil in these areas has been
Liberty Corner, Salt Lake City, Utah September 2024
VCP Site #C125 Version 3
Remedial Action Plan

Project No. 271EM00861 Page 8 Atlas Technical Consultants LLC
removed to below UDEQ DERR ISLs and the BTV and RSL. The excavated soil will be profiled
and disposed a permitted landfill. Please refer to Section 6.0 for additional details associated
with the removal and disposal of the petroleum impacted soil.

The remedial objectives of this RAP are to address the following potential exposure scenarios:

• Metals and petroleum constituents in surface and subsurface soil that pose a potential
threat to residents and construction workers.

5.2 Proposed Cleanup Levels

RAP results will be compared to residential EPA RSLs, November 2023, for Target Cancer Risk
of 1E‐06 and a Target Hazard Quotient (THQ) of 1.0, UDEQ ISLs, and a site‐specific
background threshold value for arsenic.

5.2.1 Soil
Petroleum hydrocarbon constituents measured in soil will be compared to the UDEQ ISLs and
residential EPA RSLs for Target Cancer Risk of 1E‐06 and a Target Hazard Quotient (THQ)
of 1.0. Lead results will be compared to the updated residential EPA RSL of 200 mg/kg. For
arsenic, a site-specific Background Threshold Value (BTV) was established as the threshold
concentration. Additional details regarding the methodology utilized to establish the site-specific
arsenic BTV are provided in Appendix B.

COC Media
Cleanup
Objective
(mg/kg)
Cleanup Objective
Basis Analytical Method
Naphthalene Soil 2.0 EPA RSL SW846 8260
Xylenes Soil 142 UDEQ ISL SW846 8260
TPH-GRO Soil 150 UDEQ ISL SW846 8015
TPH-DRO Soil 500 UDEQ ISL SW846 8015
Oil & Grease Soil 1,000 UDEQ ISL SW846 1664
Benzo(a)Pyrene Soil 0.11 EPA RSL SW846 8270
Arsenic Soil 13.6 Site-Specific BTV SW846 6020
Lead Soil 200 EPA RSL SW846 6020

5.2.2 Groundwater
As stated above, soil removal will occur in the areas of metals and petroleum hydrocarbon
impacts and post-excavation groundwater sampling will be conducted. TPH-GRO, TPH-DRO,
and Oil & Grease results will be compared to the UDEQ DERR ISL, and arsenic and lead will be
compared to EPA drinking water Maximum Contaminant Levels (MCL) and/or Action Levels.

COC Media
Cleanup
Objective
(mg/L)
Cleanup Objective
Basis Analytical Method
Arsenic Groundwater 0.010 EPA MCL SW846 6020
Lead Groundwater 0.016 EPA Action Level SW846 6020
TPH-GRO Groundwater 1.0 UDEQ ISL SW846 8015
TPH-DRO Groundwater 1.0 UDEQ ISL SW846 8015
Oil & Grease Groundwater 10 UDEQ ISL SW846 1664

Liberty Corner, Salt Lake City, Utah September 2024
VCP Site #C125 Version 3
Remedial Action Plan

Project No. 271EM00861 Page 9 Atlas Technical Consultants LLC
6.0 REMEDIAL ACTION

This section describes the proposed remedies for impacted soil and groundwater that will meet
the remedial action objectives. Subsurface soil and groundwater (If encountered) exceeding
cleanup levels will be removed and disposed of at an appropriate permitted off‐site facility.
During removal of the building foundations an Environmental Professional (EP) will be present
on site in the event that previously unencountered signs of soil impacts are observed and the
EP will have the ability to collect opportunity samples if necessary.

6.1 Soil Removal Procedures

Atlas proposes excavating the soil contaminated with petroleum hydrocarbons, arsenic, and
lead at concentrations above the specified cleanup objective. The hierarchy for residential soil
cleanup objectives is as follows:

• Metals
o Arsenic - Site-specific BTV
o Lead – EPA Residential RSL
• Petroleum Hydrocarbons/Oil & Grease - UDEQ ISL or EPA Residential RSL
• BaP - EPA Residential RSL

Excavation efforts would be guided by recent laboratory analytical data, field screening with a
photoionization detector (PID), and field observations of staining and petroleum hydrocarbon
odors. The specific areas of excavation impacted with petroleum hydrocarbons will occur in the
vicinity of the hydraulic lift and oil/water separator (SB-1 and SB-2), and in the direct vicinity of
SB-13 and SB-17. Atlas anticipates excavating to a maximum depth of approximately 10 feet
bgs in the vicinity SB-1 and SB-2. In the vicinity of SB-13 Atlas anticipates the maximum depth
of the excavation will be approximately 5 feet bgs, and in the vicinity of SB-17 the maximum
depth is anticipated to be approximately 10 feet bgs.

Soils impacted above the BTV for arsenic and the RSL for lead in the direct vicinity of SB-12,
SB-19, and SB-20 will also be removed. In the area of SB-12, SB-19, and SB-20 soils will be
excavated to a minimum depth of 2-3’ bgs to address the metals impacts. The shallow (2-3’)
metals impacted soil in the area of SB-17 will also be removed. Upon completion of the soil
removal effort, post-excavation soil samples will be collected to confirm impacted soil in these
areas has been removed to below UDEQ DERR ISLs and the BTV and RSL. Atlas would
oversee the excavation contractor during the excavation and removal of impacted soils from the
Site.

Given that the area beneath the building located in the southeast corner of the Site was not
accessible during the site characterization effort, the area beneath the building will be
investigated after the building has been removed. Once the building has been removed three
test pits will be excavated within the building footprint. Historical information obtain for the Site
indicates that the building was used for commercial office purposes with no obvious historical
manufacturing or auto repair occurring at this location. Therefore, only the fill material beneath
the building will be investigated and one sample will be collected from each test pit at a depth of
approximately 2-3 feet below grade. The samples will be submitted a Utah Certified Testing
laboratory for analysis of VOCs analysis using EPA Method 8260, TPH GRO and DRO using
EPA Method 8015, PAHs with Selected Ion Monitoring (SIM) using EPA Method 8270, Oil &
Grease with Silica Gel Treatment (SGT) using EPA Method 9071, and RCRA 8 metals (arsenic,
barium, cadmium, chromium, lead, mercury, selenium, and silver) using EPA Method
6010/7471.
Liberty Corner, Salt Lake City, Utah September 2024
VCP Site #C125 Version 3
Remedial Action Plan

Project No. 271EM00861 Page 10 Atlas Technical Consultants LLC

Impacted soil would be removed and transported off-site for disposal at the E.T. Technologies
soil regeneration site. Atlas typically recommends that the lower portion of the excavation be
backfilled with clean 2-inch to 3-inch ballast rock, a geotextile filter fabric be placed over the
ballast rock if completed in the saturated zone, and that the remainder of the excavation be
backfilled with clean, 2-inch minus, engineered fill and compacted in loose lifts not exceeding
one foot in thickness. In this case, however, Atlas will defer to the Client and their excavation
contractor to determine the appropriate fill materials and compaction requirements that would
be appropriate for the proposed residential development. At this time it is not anticipated that
groundwater will need to be removed from the excavations. However, if groundwater present in
the excavations impedes the collection of soil confirmation samples, dewatering of the
excavations may be necessary. All appropriate procedures will be followed and a permit would
obtained from the UDEQ Division of Water Quality before dewatering commences. If
dewatering is required, contaminated groundwater would be temporally stored on-site in frac
tanks and then remediated to allowable levels before discharge to the stormwater system.

Atlas estimates that approximately 463 cubic yards (50x25x10 deep excavation ) of soil would
be removed in the vicinity of the oil/water separator and hydraulic lift, approximately 22 cubic
yards (10x10x6 ft. deep excavation) would be removed in the vicinity of SB-13 and
approximately 84 cubic yards (15x15x10 ft. deep excavation) would be removed in the vicinity of
SB-17. In the areas of SB-12, SB-19, and SB-20 it estimated that approximately 15 to 18 cubic
yards (10x10x4 ft.) of soil will be removed from each area. The proposed areas of excavation
are present in Figure 3.

Upon removal of the soil confirmation soil samples would be collected from the sidewalls and
floor of each excavation. All samples will be analyzed on a laboratory 48-hour turn-around time.
The laboratory metals digestion process take a minimum of 48-hours to run. A minimum of one
sidewall sample will be collected per 50 linear feet (with four minimum samples) and a minimum
of one floor sample will be collected per 1,000 square feet.

The confirmation soil samples collected in the vicinity of SB-13 will be analyzed PAHs using
EPA Method 8270 SIM and the RCRA 8 Metals using EPA Method 6020. Confirmation soil
samples collected in the vicinity of SB-17 will be analyzed for Oil and Grease using EPA
Method 1664 and the RCRA 8 Metals using EPA Method 6020. Confirmation samples collected
in the vicinity of the oil/water separator and the hydraulic lift (SB-1 and SB-2) will be analyzed
for TPH-GRO and TPH-DRO using EPA Method 8105, Oil & Grease using EPA Method 1664,
and the RCRA 8 Metals using EPA Method 6020. Confirmation soil samples collected in the
vicinity of SB-12 will be analyzed for arsenic and lead using EPA Method 6020. Confirmation
soil samples collected in the vicinity of SB-19 will be analyzed for lead only, and confirmation
soil samples collected in the vicinity of SB-20 will be analyzed for arsenic only. The confirmation
samples will be submitted to PACE Analytical Laboratory for analysis.

In addition to the sampling described above, confirmation samples for other analytes will be
included if other contaminants are suspected to be present based upon field observations or
other pertinent information.

Duplicate samples will be collected at the frequency specified in the QAPP. Split samples may
be collected by the UDEQ at their discretion. Spilt samples collected by the UDEQ would be
submitted to a separate state certified laboratory for analysis following the same method(s)
used for confirmation samples. All field procedures will follow the QAPP (Atlas, April 2023) and
Standard Operating Procedures (SOPs).

Liberty Corner, Salt Lake City, Utah September 2024
VCP Site #C125 Version 3
Remedial Action Plan

Project No. 271EM00861 Page 11 Atlas Technical Consultants LLC

6.2 Post-Excavation Groundwater Sampling

Upon successful completion of the COC impacted soil removal effort, a groundwater sample will
be collected using a new disposable bailer from each excavation to verify remaining impacts.
The same laboratory methods specified in Section 6.1 will be used. The samples submitted for
metals analysis will be field-filtered and then placed in laboratory provided containers. If the
post excavation groundwater sampling data indicate that residual petroleum impacts remain
above enforcement standards, an in-situ remediation product will be applied to the groundwater
within the excavations in an attempt to reduce the hydrocarbon impacts. If required, a
groundwater injection permit will also be obtained prior to implementation of the in-situ
treatment effort. Follow up groundwater samples will then be collected from the excavations to
determine if the application was successful at reducing the impacts to acceptable levels. If
groundwater impacts still remain above enforcement standards, a second application of the in-
situ product will be applied. Depending on the results, a third application may be required.

6.3 Waste Characterization Sampling

It is Atlas’s opinion that appropriate waste characterization sampling has already been collected
during the past investigations and are included in those reports. Based on the previous
sampling results, excavated soil would be classified as “non-hazardous” waste. However, if
required, Atlas will complete the appropriate waste profiles to be approved by the facility
receiving the waste based on the waste characterization sample results.

6.4 Groundwater Monitoring

At present there are three groundwater monitoring wells (i.e., MW -1, MW -2, and MW -3) located
at the Site. It is anticipated that the wells will need to be abandoned pursuant to UDEQ DERR
requirements prior to the property redevelopment. If upon completion of the remedial actions,
the UDEQ DERR requires the implementation of a long-term quarterly groundwater monitoring
program, new wells will be installed once the site redevelopment has been completed and
surface cover material (i.e. asphalt and concrete) has been placed.

6.5 Installation of Chemical Vapor Barrier

Atlas proposes the installation of chemical vapor barrier consisting of at least a 15-mil Drago®
Wrap (or equivalent) beneath all of the slab-on-grade occupied portions of the building. The
chemical vapor barrier would not be installed beneath the footprint of parking structure. The
vapor barrier would be installed by a qualified certified installer. All seams, edges, and
penetrations would be sealed in accordance with the manufacturer’s recommendations.
Specifications and installation instructions for the vapor barrier are provided in Appendix C.

6.6 Site Remediation Summary Report

A Site Remediation Report will be completed to document the remedial activities conducted at
the Site. The report will include sampling results, the locations and extents of excavated areas
and documentation of the disposition of impacted media disposed of off‐site.

6.7 Site Preparation

Work zones will be established around areas of contamination and tracking into and out of the
zones will be controlled to prevent spreading of contamination.
Liberty Corner, Salt Lake City, Utah September 2024
VCP Site #C125 Version 3
Remedial Action Plan

Project No. 271EM00861 Page 12 Atlas Technical Consultants LLC

6.7.1 Worker Projection
Prior to impacted soil removal activities, Atlas will prepare a site-specific health and safety plan
and all Atlas staff and subcontractors retained by Atlas will be informed of soil and groundwater
conditions. The on‐site construction workers that will directly or indirectly come into contact with
on‐site soil shall comply with any applicable state, city or local safety codes.

On‐site construction workers shall be responsible for evaluating the appropriate health and
safety work practices required, and for supplying and utilizing necessary equipment and
precautions required for the safety of employees, including adequate personal protective
equipment (PPE), monitoring and training requirements under Occupational Safety and Health
Administration (OSHA) standards.

The General Contractor retained by the property owner will be responsible for preparing their
own HASP. On-site works associated with construction of the apartment complex must be
informed of soil and groundwater conditions relating to construction and maintenance. On‐site
construction workers that will directly or indirectly come into contact with on‐site soil shall
comply with any applicable state, city or local safety codes. The General Contractor shall be
responsible for evaluating the appropriate health and safety work practices required, and for
supplying and utilizing necessary equipment and precautions required for the safety of
employees, including adequate PPE, monitoring and training requirements under OSHA
standards.

Level D PPE is considered adequate to conduct excavation activities. Level D is the lowest level
of PPE required by the U.S. Occupational Health & Safety Administration (OSHA) and is used
for nuisance contamination only. Other PPE is based upon the situation (types of gloves, etc.).It
is recommended that Dermal contact with soil or groundwater be avoided through the use of
gloves, and that in halation or ingestion of dust be minimized through site control practices.

Proper hygiene practice should be implemented to prevent dermal contact and/or ingestion of
contaminants. If potentially hazardous subsurface media is discovered during construction
activities, site safety personnel should be notified to assess if higher levels of protection are
warranted. Regardless, the construction contractor is responsible for the health and safety of
his their personnel and it is required that the construction contractor prepare, implement and
maintain a site‐specific Site Health and Safety Plan (HASP) for the protection and wellbeing of
its workers, subcontractors and authorized visitors to the site during the course of construction.
Atlas will prepare its own HASP for the remedial excavation activities.

6.6.2 Dust Control
During the soil removal effort and during construction of the apartment complex on site workers
shall minimize wind erosion and dust transport by ensuring that all necessary dust controls
(application of water, tarps, dust suppressants, etc.) are implemented and maintained at all
times during periods of operation.

Remedial actions will involve disturbance, excavation, and transportation of soils impacted with
metals and petroleum constituents. Fugitive dust maybe generated from activities with in the
work area. Although the area proposed for excavation does not exceed one‐quarter acre, as
referenced in the Utah Division of Air Quality (UDAQ) Administrative Rules under R307‐205
Emission Standards: Fugitive Emissions and Fugitive Dust, dust will be managed. The objective
during activities at the Site are to minimize fugitive dust and will utilize visual inspection. The
RAP fugitive Dust goal is zero visible dust when working with impacted materials. Atlas on‐site
personnel will periodically conduct visual monitoring of fugitive dust. If engineering controls are
Liberty Corner, Salt Lake City, Utah September 2024
VCP Site #C125 Version 3
Remedial Action Plan

Project No. 271EM00861 Page 13 Atlas Technical Consultants LLC
ineffective, work activities will be limited or stopped until conditions improve. Work stop may
also be required in high winds. A copy of the fugitive dust mitigation plan prepared by the
General Contractor developing the property is included in Appendix D.

6.6.3 Anti-Tracking
In general, excavation activities will take place in a manner designed to minimize equipment
contact with contaminated soils. Excavators and haul trucks will not enter the areas of
excavation. Vehicles and equipment will be decontaminated to prevent the spread of
contamination both within the site and off‐site. Construction workers shall employ anti‐tracking
measures (streets weepers, anti‐tracking pads, etc.) at the site ingress and egress areas to
ensure that vehicles do not track soil on to a public roadway at any time. All equipment that was
exposed to contamination will be decontaminated prior to leaving the site.

6.6.4 Site Control/Security
Site security will be the responsibility of the Applicant that will restrict access to the Site and
prohibit the general population and non‐site personnel from entering during construction
activities.

6.6.5 Stormwater Management
During construction, stormwater management should be conducted to reduce contact with
sediment and stormwater run‐off. Berms or temporary controls should be used to divert run‐off
around open excavations and to prevent run‐off from leaving the Site. Should stormwater come
in contact with potentially impacted media, it will be managed properly. A copy of the
stormwater pollution prevention plan (SWPPP) prepared by the General Contractor developing
the property is included in Appendix E.

6.6.6 Public Notice
Prior to remedial action, a notice informing the public of the proposed action, where the plan
may be viewed, and where comments can be submitted will be published in the local
newspaper and mailed or hand‐delivered to adjacent landowners. A copy of the Public Notice is
included Appendix F.

6.7 Environmental Covenants

Following completion of remedial activities, the Applicant will enter into an Environmental
Covenant with the DERR that outlines the activity and use limitations associated with any areas
if impacts remain above the proposed clean-up levels. One limitation will include the use of the
first two floors of the proposed structure as an open‐air parking garage to mitigate potential
vapor intrusion. In addition, a no groundwater use restriction will likely be placed on the
property.

6.8 Site Management Plan

Based on the use of environmental covenants at the Site, a Site Management Plan will be
prepared and submitted to DERR. The Site Management will define site management
requirements, groundwater performance monitoring, activity and use limitations, management
and maintenance of these limitations, site inspections and reporting requirements.

7.0 SCHEDULE

Upon DERR RAP approval and the public comment period, which is excepted within the next 60
days, soil excavation activities are likely to begin in July 2024. Soil excavation is expected to be
Liberty Corner, Salt Lake City, Utah September 2024
VCP Site #C125 Version 3
Remedial Action Plan

Project No. 271EM00861 Page 14 Atlas Technical Consultants LLC
completed within 1-2 weeks after commencement. All laboratory analytical will be on a 48-hour
turnaround timeframe.

The Applicant is currently conducting site activities in preparation of building demolition. It is
expected that site structures and surface cover material (i.e. asphalt and concrete) will be
removed within the next 3‐4 weeks. Once the buildings and surface cover material has been
removed, and approval of the RAP has been received, the soil removal effort can begin. Upon
completion, the Site Remediation Report will be prepared and submitted to DERR for review.

8.0 CONTINGENCY PLANS

8.1 Inclement Weather

In the event inclement weather creates unsafe work conditions, creates dust, or causes
significant construction concerns, work will stop until solutions can be devised to address the
concerns. The determination to stop work will be made by Atlas in conjunction with the
remediation contractor and the DERR.

8.2 Unexpected Discovery

If additional impacted media are discovered during remedial action activities, the following
procedures will be followed.

8.2.1 Remedial Action
If additional petroleum impacted soil is identified during remediation of an area, the removal
area will be enlarged to include it. Soil removal will be guided by field screening with the PID to
identify the boundaries and confirmation samples will be collected as described in Section 6.0.
Similarly, if petroleum impacted soil is found in areas not previously investigated during the site
characterization or prior environmental investigations/studies, these areas will be field
screened, and the soil removed consistent with approach discussed above. If impacted soil is
found, the DERR will be notified and, if needed, a response plan will be developed to address
the area.

If a fuel tank is discovered during excavation, excavation will stop, and the DERR’s petroleum
storage tanks branch will be notified, and a response plan will be developed in coordination with
the VCP section to address removal of the tank and proper off‐site disposal.

8.3 Deviation from Plan

To the extent that encountered field conditions differ from those planned and require deviations
from this RAP, they will be discussed with the DERR prior to implementation. In addition, the
applicant will coordinate with the DERR to address if concentrations increase that creates an
unacceptable risk. Any completed deviations from plan will be memorialized in the Site
Remediation Report.

9.0 HEALTH AND SAFETY

Atlas will prepare a site-specific HASP for this remedial project that meets the requirements of
the OSHA Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard
(29CFR1910.120), including addressing potential contact with contaminated media (soil,
groundwater). The subcontractor selected by Atlas to perform the remedial activities will be
comply with the HASP requirements. The DERR will be provided a copy of Atlas’s HASP a
Liberty Corner, Salt Lake City, Utah September 2024
VCP Site #C125 Version 3
Remedial Action Plan

Project No. 271EM00861 Page 15 Atlas Technical Consultants LLC
minimum of one week before field work begins. As part of the HASP, Atlas will be responsible
to ensure that all of its employees and subcontractors are informed of the on‐site hazards
related to contaminated media and the protective measures to mitigate those hazards as
required by OSHA’s Hazard Communication Standard (29CFR1910.1200).

10.0 REFERENCES

Atlas Technical Consultants, Phase I Environmental Site Assessment, 300 West Site – Schmidt
Property, 1229 South and 1265 South 300 West, 257 West Lucy Avenue, and 246-252 West
1300 South, Salt Lake City, Utah, August 17, 2022

Atlas Technical Consultants, Limited Subsurface Investigation Report, 300 West Site – Schmidt
Property, 1229 South and 1265 South 300 West, 257 West Lucy Avenue, and 246-252 West
1300 South, Salt Lake City, Utah, September 15, 2022.

Atlas Technical Consultants, Quality Assurance Project Plan For Facility Related Activities,
State of Utah Voluntary Cleanup Program, Liberty Corner – 1229-1265 South 300 West, Salt
Lake City, Utah. May 26, 2023.

Atlas Technical Consultants, Revised Site Characterization Work Plan For Facility Related
Activities, State of Utah Voluntary Cleanup Program, Liberty Corner – 1229-1265 South 300
West, Salt Lake City, Utah. September 11, 2023.

CMT Engineering Laboratories, Phase I Environmental Site Assessment, The Schmidt
Property, 1265 South 300 West, 257 West Lucy Avenue, and 246-252 West 1300 South, Salt
Lake City, Utah, July 5, 2021.

Gilbert, Richard O. 1987. Statistical Methods for Environmental Pollution Monitoring. Van
Nostrand Reinhold, New York.

Krishnamoorthy, K., and T. Mathew. 2009. Statistical Tolerance Regions: Theory, Applications,
and Computation. Hoboken, NJ: Wiley.

ProUCL Version 5.1 User Guide. Office of Research and Development, EPA/600/R-07/041.
Singh, A. and A.K. Singh. October 2015.

ProUCL Version 5.1 Technical Guide. Office of Research and Development, EPA/600/R-
07/041. Singh, A. and A.K. Singh. October 2015.

RMEC, DRAFT Limited Subsurface Investigation Report, The Schmidt Property, 1265 South
300 West, 257 West Lucy Avenue, 246-252 West 1300 South, Salt Lake City, Utah 84101,
January 3, 2022.

Singh, A. and J. Nocerino. 1997. Robust Intervals for Some Environmental Applications.
Chemometrics and Intelligent Laboratory Systems 37 (1997) 55-69. Singh, A., N. Armbya, and
A.K. Singh. 2010.

Scout 2008 Version 1.0 User Guide. Office of Research and Development, EPA/600/R-08/038.

U.S. Environmental Protection Agency (USEPA). 1999a. Record of Decision Amendment:
Keystone Sanitation Landfill, EPA ID: PAD054142781, OU 01, Union Township, PA.
EPA/AMD/R03-99/505. June 25.
Liberty Corner, Salt Lake City, Utah September 2024
VCP Site #C125 Version 3
Remedial Action Plan
Project No. 271EM00861 Page 16 Atlas Technical Consultants LLC
USEPA. 1999b. Robust Statistical Intervals for Performance Evaluation, USEPA Environmental
Sciences Division, Las Vegas, NV.
USEPA. 2002a. Guidance for Comparing Background and Chemical Concentrations in Soil for
CERCLA Sites. EPA/540/R-01/003. Office of Emergency and Remedial Response,
Washington, D.C.
USEPA. 2009. Statistical Analysis of Groundwater Monitoring Data at RCRA Facilities – Unified
Guidance. Office of Resource Conservation and Recovery. EPA 530-R-09-007.
USGS Water Resources of Salt Lake County, Utah, A.G. Hely, R.W. Mower, C. Albert Harr and
Ted Arnow, Technical Publication 31, 1971.
W allace, Janae and Lowe, Mike, Ground‐Water Quality Classification for the Principal Basin‐Fill
Aquifer, Salt Lake Valley, Salt Lake County, Utah. Utah Geologic Survey. August 25, 2008.

Project No. 271EM00861 Atlas Technical Consultants LLC

FIGURES

Remedial Action Plan
VCP Site #C125 Version 2
Liberty Corner, Salt Lake City, Utah July 2024
358 South 700 East, B518
Salt Lake City, Utah 84102
[phone]
PROJECT NO: 271EM00826
SOURCE: EDR
1229 South and 1265 South 300 West, 257 West
Lucy Avenue, and 246-252 West 1300 South
Salt Lake City, Utah 84101Figure 1
Site Vicinity Map

Project No. 271EM00861 Atlas Technical Consultants LLC

APPENDIX A

Proposed Site Redevelopment Plans

Remedial Action Plan
VCP Site #C125 Version 2
Liberty Corner, Salt Lake City, Utah July 2024
Ballpark Community Council 1
LIBERTY CORNER
Ballpark Community Council 2
6



:
:/8&<$9(
081,&,3$/=21(&*
6&23(
2):25.
081,&,3$/=21(&*
081,&,3$/=21(&*081,&,3$/=21(&*
081,&,3$/=21(&*
081,&,3$/=21(&*
081,&,3$/=21(50)
081,&,3$/=21(&*
081,&,3$/=21(&*
081,&,3$/=21(50)
081,&,3$/=21(&1
081,&,3$/
=21(5%
6725<&200(5&,$/
(;,67,1*%8,/',1*
'(02
6725<$1'6275<
&200(5&,$/
(;,67,1*%8,/',1*
'(02
AREA MAP
Ballpark Community Council 3
ROOF PLAN/SITE MAP
:
(%
Ballpark Community Council 4
6,7(6800$5<
=RQLQJ*HQHUDO&RPPHUFLDO&*
/HYHOV7\SH,,,$RYHU/HYHOV7\SH,$
'8
6)*URXQG/HYHO$PHQLW\
6)*URXQG/HYHO/HDVLQJ2IILFH
6)0XOWL8VH&RXUW
6)'D\FDUHZLWK6)3OD\JURXQG
6)/HYHO$PHQLW\

$OOEXLOGLQJDERYHJUDGH
SITE PLAN
6
6
:0
:0
6
:0
6
6
6'
(%
(%
:/8&<$9(
6



:
(%
83
83
83






















6)
'$<&$5(
6)
3/$<*5281'
6)
0$,/
6)
/2%%<
6)
/2%%<6)
08/7,86(
&2857
6)
$0(1,7<
6)
/($6,1*
6)
),5(5,6(5
6)
%,.(6725$*(
6)
(/(&
6)
75$6+
6)
6+257/2$',1*
6)
*$5$*(
6)
75$6+


















































/2$',1*
'(&.
*$7(
*$7(




































6)
0$,17(1$1&(
6725$*(
6)
/2%%<
6)
3$5.,1*&28573/$=$


 
 
 
 
 
 
 
 
 
 
 
 



















 



Ballpark Community Council 5
(%
(%
83
83
83

$$
%%
&&
''
((
))
**
++
--
..

 
 
 
 
 
 
 
 
 
 






















































































6)
'$<&$5(
6)
3/$<*5281'
6)
0$,/
6)
/2%%<
6)
/2%%<6)
08/7,86(
&2857
6)
$0(1,7<
6)
/($6,1*
6)
),5(5,6(5
6)
%,.(6725$*(
6)
(/(&
6)
75$6+
6)
6+257/2$',1*
6)
*$5$*(
6)
75$6+


















































/2$',1*
'(&.
*$7(
*$7(







































:
:/8&<$9(
6)
0$,17(1$1&(
6725$*(
6)
/2%%<
6)
3$5.,1*&28573/$=$











































































































 
 
 
 
 
 
 
 
 
 
 
 



















 



GROUND LEVEL
Ballpark Community Council 6
'183
'183
'1 83
6)
$0(1,7<
6)
'(&.

 
 
 
 
 
 

 
 
 














































































6)
$0(1,7<
%
%%
%
%
%
%
%
%
%%
%
%
%
%
%
%
% %
%
%
%
%
%
%
%
%
%
%
%
%
%
%







6)
75$6+
6)
(/(&
6)
75$6+
6)
(/(&
%
%
%
%

 
 
 
 
 
 







































































3rd LEVEL AMENITY DECK
Ballpark Community Council 7
'1
'1
'1
%
%%
%
%
%
%
%%
%%
%
%
%
%
%
%
% %
%
%
%
%
%
%
%
%
%%
%
%
%
%
6)
75$6+
6)
75$6+
6)
(/(&
6)
(/(&
RESIDENTIAL FLOORS 4-6
Ballpark Community Council 8
6)
75$6+
6)
(/(&
6)
(/(&
6)
75$6+
RESIDENTIAL FLOORS 7
Ballpark Community Council 9
/(9(/
 
/(9(/
 
/(9(/
 
/(9(/
 
/(9(/
 
/(9(/

 
/(9(/

 
522)
 
0$;%/'*+7)520
/2:(67*5$'(32,17
 
7K
H

I
L
Q
D
O

E
X
L
O
G
L
Q
J

K
H
L
J
K
W

L
V

G
H
W
H
U
P
L
Q
H
G

E
\

W
K
H

O
R
Z
H
V
W

J
U
D
G
H

S
R
L
QW

I
U
R
P

&
L
Y
L
O













%
8
,
/
'
,
1
*

+
(
,
*
+
7
7<
3
(

,
,
,
$












7<
3
(

,
$




































































/(9(/
 
/(9(/
 
/(9(/
 
/(9(/
 
/(9(/
 
/(9(/

 
/(9(/

 
522)
 
0$;%/'*+7)520
/2:(67*5$'(32,17
 




























































7<3(,,,$


7<3(,$


7KHILQDOEXLOGLQJKHLJKWLVGHWHUPLQHGE\WKHORZHVWJUDGHSRLQWIURP&LYLO

%8,/',1*+(,*+7

&21&5(7(
%5,&.&2/255$:+,'(
%5,&.&2/25781%5,'*(
%5,&.&2/25'81608,5',(6.,1
 %5,&.&2/25&80%(5/$1'
327(17,$/6,*1$*(/2&$7,21
&2558*$7('0(7$/
 0(7$//289(5
*/$666725()5217
 9,1</:,1'2:
678&&2&2/25720$7&+%5,&.
0(7$/5$,/,1*
&08:$//
 678&&2&2/25720$7&+&2558*$7('0(7$/
1RWH)LQDOPDWHULDOFRORURSHQLQJORFDWLRQVDQG
VSHFLILFDWLRQWREHLVVXHGXSRQ%XLOGLQJ3HUPLW6XEPLWWDO
 
6287+
 
:(67


PRIMARY ELEVATIONS
Ballpark Community Council 10
MODEL PERSPECTIVE
Ballpark Community Council 11
MODEL PERSPECTIVE
Ballpark Community Council 12
MODEL PERSPECTIVE
Ballpark Community Council 13
MODEL PERSPECTIVE
Ballpark Community Council 14
THANK YOU
Ballpark Community Council 15
352-(&7'$7$
&217$&7
2:1(56+,3 $5&+,7(&7
09(3$571(56
0$,1675((7
,59,1(&$
3+21(
&2:%2<3$571(56
6:$6$7&+%/9'68,7(
6$/7/$.(&,7<87$+
3KRQH
81,76800$5<
81,77<3( 81,71$0( 81,76,=( 81,7&2817
%('52206 % 6) 
%('52206 % 6) 
%('52206 % 6) 

%('52206'(1 % 6) 
%('52206'(1 % 6) 

%('52206 % 6) 
%('52206 % 6) 
%('52206 % 6) 
%('52206 % 6) 
%('52206 % 6) 
%('52206 % 6) 
%('52206 % 6) 

%('52206 % 6) 
%('52206 % 6) 

727$/
':(//,1*81,76352326('
%'%$  
%'%$'(1  
%'%$  
%'%$  
 
0DUNHW5HQWDEOH$9*$UHD 6)
7RWDO1HW5HQWDEOH 6)
5(6,'(17,$/'(0$1'67$7(*,(6
/(9(/ 67$//7<3( '(6&5,37,21 67$//'(37+ 67$//:,'7+ &2817
/(9(/ 67$1'$5' 67$1'$5' 
 
 
/(9(/ (9 (/(&75,&
9(+,&/(

 
 
/(9(/ $'$(9 $&&(66,%/((9 
 
 
/(9(/ $'$ $&&(66,%/( 
 
 
/(9(/ $'$9$1 $&&(66,%/(
9$1

 
 
/(9(/
/(9(/ 67$1'$5' 67$1'$5' 
 
 
/(9(/ $'$ $&&(66,%/( 
 
 
/(9(/ 7$1'(0 &203$&7 
 
 
/(9(/
727$/
*8(673$5.,1*352326('
352326('
352326('727$/*8(67 63$&(6
/(9(/ 67$//7<3( '(6&5,37,21 67$//'(37+ 67$//:,'7+ &2817
/(9(/ 67$1'$5' 67$1'$5' 
 
 
/(9(/ $'$9$1 $&&(66,%/(
9$1

 
 
/(9(/
727$/
352-(&7'(6&5,37,21
5(6,'(17$/
=RQH&*3HUWDEOH$$EHGURRPVVSDFHSHU'8
3HU$$WKHPD[LPXPSDUNLQJDOOFRQWH[WVEHGURRPVVSDFHVSHU'8
3HU$'3HUSDUNLQJVSDFHV$'$VWDOOVUHTXLUHG
3HU,%&9$1VWDOOVKDOOEHUHTXLUHGIRUHYHU\$'$VWDOOV
3HU$&(9VKDOOEHUHTXLUHGHYHU\VSDFHV
7DQGHPVWDOOVWREHDVVLJQHGWRDVLQJOHXQLW
3HU$$%6KDUHGSDUNLQJFDQEHUHGXFHGE\WKHSURYLGHGUHGXFWLRQIDFWRU
3HU$VKRUWORDGLQJ]RQHUHTXLUHGIRUWKHILUVW'ZHOOLQJXQLWVDQG
DGGLWLRQDOVKRUW
ORDGLQJ]RQHIRUDGGLWLRQDOXQLWVH[FHHGLQJXQLWVRI0XOWL)DPLO\5HVLGHQWLDO
'$<&$5(
=RQH&*3HUWDEOH$$VSDFHVSHUVTIW
3HUWDEOH$$QRPD[LPXPSDUNLQJOLPLW
3HUWDEOH$$VKRUWORDGLQJ]RQHUHTXLUHGIRUVIRI,QVWLWXWLRQV
0L[HGXVHSURMHFWFRQVLVWLQJRI7\SH,,,$RYHU7\SH,$FRQVWUXFWLRQZLWKDWRWDOXQLWFRXQWRI
XQLWV7KLVSURMHFWIHDWXUHVRYHUVIRIUHVLGHQWLDOVIRIGD\FDUHVIRISOD\
JURXQGVIRIDPHQLWLHVDQGVIRIDERYHJUDGHSDUNLQJ
$''5(666RXWK:HVW
6DOW/DNH&LW\8WDK
$31
=21(&*
'(6,*1$7,21
3XUSRVH6WDWHPHQW7KHSXUSRVHRIWKH&**HQHUDO&RPPHUFLDO'LVWULFWLVWRSURYLGHDQ
HQYLURQPHQWIRUDYDULHW\RIFRPPHUFLDOXVHVVRPHRIZKLFKLQYROYHWKHRXWGRRUGLVSOD\VWRUDJH
RIPHUFKDQGLVHRUPDWHULDOV7KLVGLVWULFWSURYLGHVHFRQRPLFGHYHORSPHQWRSSRUWXQLWLHVWKURXJK
DPL[RIODQGXVHVLQFOXGLQJUHWDLOVDOHVDQGVHUYLFHVHQWHUWDLQPHQWRIILFHUHVLGHQWLDOKHDY\
FRPPHUFLDODQGORZLQWHQVLWLHVRIPDQXIDFWXULQJDQGZDUHKRXVHXVHV7KLVGLVWULFWLV
DSSURSULDWHLQORFDWLRQVZKHUHVXSSRUWHGE\DSSOLFDEOHPDVWHUSODQVDQGDORQJPDMRUDUWHULDOV
6DIHFRQYHQLHQWDQGLQYLWLQJFRQQHFWLRQVWKDWSURYLGHDFFHVVWREXVLQHVVHVIURPSXEOLF
VLGHZDONVELNHSDWKVDQGVWUHHWVDUHQHFHVVDU\$FFHVVVKRXOGIROORZDKLHUDUFK\WKDWSODFHV
WKHSHGHVWULDQILUVWELF\FOHVHFRQGDQGDXWRPRELOHWKLUG7KHVWDQGDUGVDUHLQWHQGHGWRFUHDWHD
VDIHDQGDHVWKHWLFDOO\SOHDVLQJFRPPHUFLDOHQYLURQPHQWIRUDOOXVHUV
=21(
+(,*+7$//2:$%/(
1REXLOGLQJVKDOOH[FHHGVL[W\IHHW
%XLOGLQJVKLJKHUWKDQVL[W\IHHW
PD\EHDOORZHGLQ
DFFRUGDQFHZLWKWKHSURYLVLRQVRIVXEVHFWLRQV)DQG)RIWKLVVHFWLRQ$
)3URFHGXUH)RU0RGLILFDWLRQ$PRGLILFDWLRQWRWKHKHLJKWUHJXODWLRQVLQWKLVVXEVHFWLRQ)PD\
EHJUDQWHGWKURXJKWKHGHVLJQUHYLHZSURFHVVLQFRQIRUPDQFHZLWKWKHSURYLVLRQVRIFKDSWHU
$RIWKLVWLWOH,QHYDOXDWLQJDQDSSOLFDWLRQVXEPLWWHGSXUVXDQWWRWKLVVHFWLRQWKH3ODQQLQJ
&RPPLVVLRQRULQWKHFDVHRIDQDGPLQLVWUDWLYHDSSURYDOWKH3ODQQLQJ'LUHFWRURUGHVLJQHHVKDOO
ILQGWKDWWKHLQFUHDVHGKHLJKWZLOOUHVXOWLQLPSURYHGVLWHOD\RXWDQGDPHQLWLHV
)/DQGVFDSLQJ,IDGGLWLRQDOIORRUVDUHDSSURYHGLQFUHDVHGODQGVFDSLQJVKDOOEHSURYLGHGRYHU
DQGDERYHWKDWZKLFKLVQRUPDOO\UHTXLUHGIRUODQGVFDSH\DUGVODQGVFDSHEXIIHU\DUGVDQG
SDUNLQJORWSHULPHWHUDQGLQWHULRUODQGVFDSLQJ7KHDPRXQWRILQFUHDVHGODQGVFDSLQJVKDOOEH
HTXDOWRWHQSHUFHQWRIWKHDUHDRIWKHDGGLWLRQDOIORRUV
)0D[LPXP$GGLWLRQDO+HLJKW$GGLWLRQDOKHLJKWVKDOOEHOLPLWHGWRWKLUW\IHHW
2UG
2UG2UG2UG2UG†2UG†
2UG†2UG†
352326('
 7KHILQDOEXLOGLQJKHLJKWLVGHWHUPLQHGE\WKHORZHVWJUDGHSRLQWIURP
&LYLO
+(,*+7
5(48,5('
)URQW<DUG 7HQIHHW

&RUQHU6LGH<DUG 7HQIHHW

,QWHULRU6LGH<DUG 1RQHUHTXLUHG
5HDU<DUG 7HQIHHW

%XIIHU<DUG $OOORWVDEXWWLQJUHVLGHQWLDOSURSHUW\VKDOOFRQIRUPWRWKHEXIIHU\DUG
UHTXLUHPHQWVRIFKDSWHU$RIWKLVWLWOH
352326('
)URQW<DUG 7HQIHHWDQGIRXULQFKHV

&RUQHU6LGH<DUG 7HQIHHWDQGIRXULQFKHV

,QWHULRU6LGH<DUG 

5HDU<DUG 7HQIHHWDQGIRXULQFKHV

%XIIHU<DUG 
&,9,/
6(7%$&.
6,7($5($6)$&
%8,/',1*$5($
$//2:$%/()/225$5($/,0,7
81,76,1/27
'83(5$&5(

6((6,7(3/$1)25$31$1'/27&2162/,'$7,21
/27,1)250$7,21
5(6,'(17$/3$5.,1*5(48,5('
5(6,'(17,$/'85(48,5('
%' %' %'  
5(48,5('5(6,'(17,$/727$/ 63$&(6
67$1'$5'67$//65(48,5(' 63$&(6
$'$67$//65(48,5(' 63$&(6
$'$9$167$//65(48,5(' 63$&(6
(967$//65(48,5('63$&(63$&(6 63$&(6
5(48,5('727$/ 63$&(6
'$<&$5(3$5.,1*5(48,5('
5(48,5(''$<&$5(,1&/8'(3/$<*5281' 63$&(66)
6)6) 63$&(6
5(48,5(''$<&$5(727$/ 63$&(6
67$1'$5'67$//65(48,5(' 63$&(6
$'$67$//65(48,5(' 63$&(6
$'$9$167$//65(48,5(' 63$&(6
5(48,5('727$/ 63$&(6
5(48,5('727$/5(6,'(17,$/'$<&$5( 63$&(6
5(6,'(17$/3$5.,1*352326('
352326('

7DQGHP6SDFHZLOOEHDVVLJQHGWRVDPHXQLWV
352326('727$/5(6,'(17,$/ 63$&(6
%,&<&/(3$5.,1*
3HU7DEOH$&IRU5HVLGQHWLDO8VHVLQDOO]RQLQJGLVWULFWVQRWOLVWHGLQDQRWKHUFRQWH[W
DUHDELF\FOHSDUNLQJVKDOOEHSHUXQLWV3XEOLFXVHVLQDOO]RQLQJGLVWULFWVQRWOLVWHGLQDQRWKHU
FRQWH[WDUHDELF\FOHSDUNLQJVKDOOEHSHU6)
3HUD(6HFXUH(QFORVHG%LF\FOH3DUNLQJ(DFKRQHELF\FOHSDUNLQJVVSDFHWKDWLV
ZLWKLQDVHFXUHHQFORVHGELF\FOHSDUNLQJIDFLOLW\PD\EHXVHGWRVDWLVI\WKHUHTXLUHPHQWRIWZR
UHTXLUHGELF\FOHSDUNLQJVSDFHV
727$/%,&<&/(65(48,5(' 5(6,'(17,$/
'8 
727$/%,&<&/(65(48,5(' 38%/,&
/($6,1* 6)6) 
'$<&$5(,1&/8'(3/$<*5281' 6)6) 
727$/%,&<&/(65(48,5('
5(48,5('727$/5(6,'(17,$/38%/,& 63$&(6
352326('727$/5(6,'(17,$/38%/,& 63$&(6
727$/%,&<&/(63529,'('  5(6,'(17,$/
/(9(/ 
727$/ 
727$/%,&<&/(63529,'(' 38%/,&
/(9(/ 
727$/ 
5(48,5('727$/5(6,'(17,$/38%/,& 63$&(6
*5266%8,/',1*$5($
$0(1,7< 6)
%,.(6725$*( 6)
'$<&$5( 6)
(/(& 6)
),5(5,6(5 6)
*$5$*( 6)
/($6,1* 6)
/2%%< 6)
0$,/ 6)
0$,17(1$1&(6725$*( 6)
08/7,86(&2857 6)
3$5.,1*&2857 6)
3/$<*5281' 6)
6+257/2$',1* 6)
75$6+ 6)
9(57,&$/&,5&8/$7,21 6)
/(9(/ 6)
(/(& 6)
*$5$*( 6)
/2%%< 6)
0$,17(1$1&( 6)
0$,17(1$1&(6725$*( 6)
75$6+ 6)
9(57,&$/&,5&8/$7,21 6)
/(9(/ 6)
$0(1,7< 6)
&255,'25 6)
(/(& 6)
/2%%< 6)
5(6,'(17,$/81,76 6)
75$6+ 6)
9(57,&$/&,5&8/$7,21 6)
/(9(/ 6)
&255,'25 6)
(/(& 6)
/2%%< 6)
5(6,'(17,$/81,76 6)
75$6+ 6)
9(57,&$/&,5&8/$7,21 6)
/(9(/ 6)
&255,'25 6)
(/(& 6)
/2%%< 6)
5(6,'(17,$/81,76 6)
75$6+ 6)
9(57,&$/&,5&8/$7,21 6)
/(9(/ 6)
&255,'25 6)
(/(& 6)
/2%%< 6)
5(6,'(17,$/81,76 6)
75$6+ 6)
9(57,&$/&,5&8/$7,21 6)
/(9(/ 6)
&255,'25 6)
(/(& 6)
/2%%< 6)
5(6,'(17,$/81,76 6)
75$6+ 6)
9(57,&$/&,5&8/$7,21 6)
/(9(/ 6)
5(6,'(17,$/'(16,7<
6+((7,1'(;
$5&+,7(&785(
727$/ 6)
0F1(,/(1*,1((5,1*
6287+6$1'<3$5.:$<68,7(
6$1'<87$+
3KRQH
&29(56+((7 *(1
352-(&7'$7$ *(1
6,7(&217(;7 $
6,7(&217(;7,0$*(5< $
6,7(3/$1 $
),5($&&(663/$1 $
6+$'2:$1$/<6,6 $
/(9(/3/$1 $
/(9(/3/$1 $
/(9(/3/$1 $
/(9(/3/$1 $
/(9(/3/$1/(9(/6,0 $
/(9(/3/$1 $
522)3/$1 $
(;7(5,25(/(9$7,216 $
(;7(5,25(/(9$7,216 $
'3(563(&7,9( $
'3(563(&7,9( $
'3(563(&7,9( $
'3(563(&7,9( $
'3(563(&7,9( $
%8,/',1*6(&7,216 $
:$//6(&7,21 $
81,73/$1 $
81,73/$1 $
81,73/$1 $
81,73/$1 $
81,73/$1 $
81,73/$1 $
81,73/$1 $
81,73/$1 $
81,73/$1 $
81,73/$1 $
81,73/$1 $
81,73/$1 $
81,73/$1 $
/,*+7,1*3/$1 $
/,*+7,1*3/$1 $
/,*+7,1*3/$1 $
PROJECT DATA

Project No. 271EM00861 Atlas Technical Consultants LLC

APPENDIX B

Arsenic Background Threshold Value Determination

Remedial Action Plan
VCP Site #C125 Version 2
Liberty Corner, Salt Lake City, Utah July 2024

Project No. 271EM00861 Page B-0 Atlas Technical Consultants LLC

B.7 REFERENCES ...................................................................................................................................... 12
B.6 RECOMMENDED ARSENIC BACKGROUND THRESHOLD VALUE......................................................... 10
B.5 DATA VARIABILITY AND UNCERTAINTY.............................................................................................. 10
B.4 BTV STATISTICAL PROCESS................................................................................................................. 10
B.3.2 Recommended BTV Stascs....................................................................................................... 9
B.3.1 Overview of Candidate BTV Stascs .......................................................................................... 7
B.3 SELECTION OF BTV STATISTICS ............................................................................................................ 7
B.2.6 Descripve Stascal Summary................................................................................................... 5
B.2.5 Outlier Idenficaon.................................................................................................................... 3
B.2.4 Dataset Aggregaon..................................................................................................................... 3
B.2.3 Treatment of Duplicate Sample Results....................................................................................... 2
B.2.2 Treatment of Non-Detects and “J”-Flagged Data......................................................................... 2
B.2.1 Definion of Inial Dataset .......................................................................................................... 2
B.2 ESTABLISHED BACKGROUND DATA...................................................................................................... 2
B.1 STATISTICAL PROCESS OVERVIEW ....................................................................................................... 1
B.0 EVALUATION OF BACKGROUND ARSENIC CONCENTRATIONS ....................................................1
Table of Contents
ARSENIC BACKGROUND THRESHOLD VALUE DETERMINATION
APPENDIX B
Remedial Acon Plan
VCP Site #C125 Version 2
Liberty Corner, Salt Lake City, Utah July 2024

Project No. 271EM00861 Page B-1 Atlas Technical Consultants LLC

background dataset.
(see discussion on outliers below in Secon B.2.5). This resulted in idenfying an “established”
 Idenfy Outliers: Outliers contained within the inial dataset were idenfied and removed
performed.
duplicate samples, laboratory flagged data, or idenficaon or removal of outliers has been
(3, 9, and 15 feet bgs). Inial datasets are “raw” in the sense that no adjustments to account for
acvies, represenng validated laboratory analycal results for three different sample depths
 Inial Dataset: The inial dataset contains all sampling results from previous site invesgaon
to idenfy the stage of the dataset being discussed:
outliers. To beer describe the stascal process, the following descripve terms are used in this secon
steps to establish individual datasets that represent the same sample populaon devoid of confirmed
Descripon of Stascal Dataset: The validated analycal results went through a progression of stascal
The stascal evaluaon process included the major steps discussed below.
B.1 STATISTICAL PROCESS OVERVIEW
basis for confirming the adequacy of future arsenic-impacted soil removal acvies.
idenfy locaons where arsenic exceeds the established background concentraon and as the
 Secon B.6 summarizes the BTV esmaon results and presents the proposed BTV to be used to
 Secon B.5 provides general informaon regarding uncertaines and data variability.
arsenic BTVs.
 Secon B.4 discusses the use of the ProUCL model as the basis for esmang potenally applicable
 Secon B.3 provides an overview of potenally applicable stascal methods for esmang BTVs
treatment of outliers
non-detect values, “flagged” data, and duplicate samples; data merging; and idenficaon and
 Secon B.2 defines the inial datasets by subpopulaon; the methodologies ulized to address
 Secon B.1 idenfies key descripve terms ulized to describe and evaluate the datasets
as outlined below:
from previous site invesgaon acvies and to develop background threshold values (BTVs) for arsenic,
The following secons provide an overview of the processes employed to evaluate the soil data generated
arsenic in Utah rounely exceed the EPA RSL.
for residenal soil, arsenic is of primary interest given that ancipated background concentraons of
residenal soil. While both arsenic and lead were detected in soil at concentraons in excess of EPA RSLs
mercury, selenium, and silver were also detected in soil, but at concentraons below EPA RSLs for
EPA RSL for residenal soil (200 mg/kg). Addional metals, including barium, cadmium, chromium,
analyzed. Lead was detected in three (3) soil samples at a concentraons in excess of the recently revised
excess of the EPA RSL for residenal soil (0.68 mg/kg) in 37 of 53 primary and duplicate soil samples
duplicate samples were obtained during these invesgaons. Arsenic was detected at concentraons in
samples collected at depths ranging from approximately 2 to 15 feet bgs. In addion, three (3) field
conducted between 2022 and 2023 involved the collecon and analysis of fiy-three (53) discrete soil
The laboratory analycal results of soil samples obtained during previous site invesgaon acvies
B.0 EVALUATION OF BACKGROUND ARSENIC CONCENTRATIONS
Remedial Acon Plan
VCP Site #C125 Version 2
Liberty Corner, Salt Lake City, Utah July 2024

Project No. 271EM00861 Page B-2 Atlas Technical Consultants LLC

and would result in assessing unjusfied greater precision for the stascs derived from such data. The
Treang such duplicate samples as independent data points would falsely increase the overall sample size
spaal proximity and, therefore, provide overlapping informaon (i.e., the results are not independent).
its associated duplicate sample result. Duplicate samples are expected to be correlated because of their
Discrete duplicate-sample results were replaced with a simple average of the primary sample result and
evaluaon. An unbiased esmate of the concentraon at the locaon is the average of the two values.
are valid concentraon values at a given sampling locaon and neither should be ignored in any stascal
Although duplicates are collected primarily for QA/QC purposes, both the primary and duplicate results
B.2.3 Treatment of Duplicate Sample Results
of stascal parameters.
informaon. The “J”-flagged values were used collecvely with other values to derive unbiased esmates
MDL and the RL). Censoring at the RL would lose this disncon with a consequent loss of some
the MDL) and a value that is a confirmed detect, although not fully or precisely quanfied (between the
were used for BTV esmaon. This method accounts for the disncon between a true non-detect (below
considered present in the sample, but of an esmated concentraon, their reported “esmated” values
MDL). For “J”-flagged data, which are values falling between the MDL and the Reporng Limit (RL) and
non-detect and “censored” at the MDL (i.e., the results were considered to be less than or equal to the
Laboratory analycal results reported as being less than a Method Detecon Limit (MDL) were treated as
B.2.2 Treatment of Non-Detects and “J”-Flagged Data
significantly influence the BTV esmaon method or result.
applicable, data were also evaluated by sample depth to determine whether sample depth would
9 and 15 feet bgs. Collecvely, these sample depths represent the background sample populaon. As
of this evaluaon, the three different sampling depths are referred to by the terminal sample depths of 3,
depths ranging from approximately 2 to 3 feet bgs; 7 to 9 feet bgs, and 13 to 15 feet bgs. For the purpose
Historical soil samples were collected during previous site invesgaon acvies at relavely uniform
B.2.1 Definion of Inial Dataset
B.2 ESTABLISHED BACKGROUND DATA
secons.
Each of the above steps in the stascal process is also described herein in more detail in subsequent
accounted for both the populaon distribuon and the presence of non-detects.
and upper stascal limits (represenng BTVs) were computed using applicable stascal methods that
Compute Stascal Parameters: Basic stascal parameters (e.g., mean, range, and standard deviaon)
parameters were selected for BTV computaon (see Secon B.3).
potenal stascal parameters that could represent BTVs were evaluated and the most appropriate
Select Appropriate BTV Stascal Parameter(s): In accordance with the expected use of the data,
stascal analyses were performed.
outliers, it is considered representave of the populaon of “background” samples from which
outliers from the inial background dataset. Since the established dataset is free of known
 Established Dataset: Derived from the disnct dataset, reflecng the removal of confirmed
Remedial Acon Plan
VCP Site #C125 Version 2
Liberty Corner, Salt Lake City, Utah July 2024

Project No. 271EM00861 Page B-3 Atlas Technical Consultants LLC

example of a Q-Q Plot of the Site dataset prior to outlier removal is provided below:
whisker plots, and probability plots); and confirming outliers using stascal tests (e.g., Rosner's Test). An
validaon reports, etc.), visually examining graphical data representaons (e.g., histograms, box-and-
Lines of evidence pursued included ensuring that data are valid (e.g., reviewing field and lab reports, data
Methods for Environmental Polluon Monitoring (Gilbert, 1987).
al., 2015), Data Quality Assessment: Stascal Methods for Praconers (USEPA, 2006b), and Stascal
The details of the graphical methods and outlier test are provided in ProUCL 5.1 Technical Guide (Singh et
errors were idenfied.
idenfied as potenal outliers were checked for field or laboratory errors. However, no field or laboratory
appeared to be separated by large gaps from all the remaining data. Data values that were visually
the ProUCL soware. These displays were examined visually to idenfy any isolated data values that
displays of the data (box-and-whisker plots, histograms, and normal probability plots) were prepared using
refining the dataset to idenfy and ulmately remove outliers. To idenfy potenal outliers, graphical
In addion to making adjustments to the dataset discussed in the previous secons, the EDA resulted in
For the background study, exploratory data analysis (EDA) was ulized, followed by a formal stascal test.
B.2.5 Outlier Idenficaon
normal, gamma, and/or lognormal distribuons).
use of parametric methods for stascal evaluaon (i.e., data were determined to be consistent with
stascal analysis. The characteriscs of inial dataset each analyte exhibited characteriscs favoring the
single populaon whose data could be merged together to form a more robust overall disnct dataset for
step was to idenfy whether the data from the three depth profiles could be recognized as represenng a
The inial arsenic datasets were compared across the three sample depth profiles. The purpose of this
B.2.4 Dataset Aggregaon
concentraon of the parent and duplicate sample) was used in this stascal analysis.
samples collected during each invesgaon. Duplicate averaging (i.e., using the arithmec mean
stascal analysis, the number of duplicate samples was approximately 10% of the total number of
variability should be negligible and duplicate averaging is a reasonable opon. For the data used in this
total number of samples is small (e.g., no more than 10%), the impact of duplicate averaging on the data
However, as asserted by USEPA (2009) guidance, when the percentage of duplicate samples relave to the
than the variability of the single measurements.
sample values. One concern about duplicate averaging is that the variability of the averaged values is less
point, for which the best esmate of the concentraon is taken to be the average of the duplicate-primary
A common pracce, repeated for this Study, is to replace each duplicate sample result with a single data
merges the results from both samples.
data from both the primary and duplicate sample results represent valid data and the averaging process
Remedial Acon Plan
VCP Site #C125 Version 2
Liberty Corner, Salt Lake City, Utah July 2024

Project No. 271EM00861 Page B-4 Atlas Technical Consultants LLC

The Q-Q plot above suggests as many as three outliers on the upper-end of the quanle range. The fact
that a background concentraon value exists in an inial, properly-collected set of data and that it is later
determined to be an outlier does not, in any way, indicate that the reported concentraon is not valid, is
not naturally occurring, or does not reflect the condions that exist at the locaon where the associated
sample was collected. However, retaining the outliers in subsequent stascal analyses would skew the
stascal results and reduce the inherent conservasm of the BTV esmate.
All potenal outliers were subjected to a formal stascal test using the ProUCL soware. To test for
outliers, the Rosner’s test was used since the sample size was greater than 25. At a crical value of 5%
(= 0.05), three stascally-confirmed outliers were idenfied (i.e., SB-12 [32.6 mg/kg], SB-17
[18.1 mg/kg], and SB-20 [16.4 mg/kg]). All of the outliers were associated with soil samples collected at
depths of approximately 3 feet bgs. It should also be noted that lead concentraons in excess of the EPA
Residenal Soil RSL were observed in outlier samples SB-17 and SB-12. This observaon suggests that
elevated concentraons of arsenic and lead may be co-located.
The confirmed arsenic outlier samples were excluded from subsequent stascal analyses and BTV
evaluaons. The retained sample populaon is considered to represent an established background
dataset, free of outliers. A revised version of the Q-Q Plot and a box plot represenng the Site data
following removal of the three outliers are presented below:

Q-Q Plot All Data Prior to Outlier Removal
Remedial Acon Plan
VCP Site #C125 Version 2
Liberty Corner, Salt Lake City, Utah July 2024

Project No. 271EM00861 Page B-5 Atlas Technical Consultants LLC

Box Plot Following Removal of Outliers

While these plots illustrate some differences arsenic concentraons by sample depth, the maximum
arsenic concentraons detected in each sample depth show reasonable agreement, ranging from 9.68
(9 g) to 9.82 mg/kg (15 g). Addional discussion of descripve stascs associated with the sample
populaon is provided in the following secon.
B.2.6 Descripve Stascal Summary
Descripve stascs provide metrics applicable to a given data set which can therefore be representave
of the enre populaon or a sub-sample of the populaon (e.g., depth-specific intervals). In general,
descripve stascs provide measures of sample count, central tendency (e.g., mean, median, and mode),
Q-Q Plot Following Removal of Outliers
Remedial Acon Plan
VCP Site #C125 Version 2
Liberty Corner, Salt Lake City, Utah July 2024

Project No. 271EM00861 Page B-6 Atlas Technical Consultants LLC

Parameter Arsenic
After Outlier Removal
Sample Depth (fbg) 3 9 15 All Depths
Number of Samples 15 18 17 50
Number of Detections 15 17 17 49
Detection Frequency 100% 94.4% 100% 98%
Minimum Concentration 0.618 1.36 1.37 0.618
Maximum Concentration 9.77 9.68 9.82 9.82
Mean Concentration 6.76 4.58 4.85 5.34
Median Concentration 7.58 3.39 4.31 5.21
Variance 8.01 7.86 6.03 7.90
Standard Deviation 2.83 2.80 2.46 2.81
Skewness -1.04 0.71 0.67 0.16
Coefficient of Variation 0.42 0.61 0.51 0.53
# of Samples >EPA RSL 14 17 17 48
% of Samples > EPA RSL 93.3% 94.4% 100.0% 96.0%
Notes:
fbg – Feet below grade
Where applicable, the average concentration of parent and field duplicate samples
was used to establish the sample concentration
All data, including "J" flagged values were retained for evaluation
Mean, Median, and Standard Deviation values based on detections only
RSL – Regional Screening Level, Residential (EPA, November 2023)

It should be noted that the descripve stascs indicate that the 3 g sample depth exhibits slightly higher
mean and median concentraons that the deeper sample depths. While the differences between the
sample populaons by depth are significant, these differences do not preclude the aggregaon of all site
data across these depth intervals for the purpose of determining a defensible BTV. The arsenic
concentraon ranges between the different sampling depths are approximately equal, suggesng a similar
degree of heterogeneity within the sample subpopulaon. The higher mean and median arsenic
concentraons in shallow soil may simply be suggesve of aerial deposion as a factor influencing arsenic
concentraons in soil.

Theorecal opons for addressing the differences in arsenic concentraons by depth include calculang
BTV esmates based on 1) depth-specific data (i.e., three different data subsets), 2) shallow data only (i.e.,
3 feet bgs data only), 3) deep data only (i.e., 9 and/or 15 feet bgs), or 4) combined shallow and deep soil
data. For the purpose of this analysis, Atlas elected to ulize the combined shallow and deep soil data as
the basis for determining BTV esmates. Addional details regarding the potenal implicaons and
raonale for this decision are provided below:

General Descripve Stascal Summary of Arsenic in Sample Populaon
collecvely for all samples regardless of depth.
summary provides an overview of the descripve stascs for the samples by depth interval and
variability or spread (e.g., standard deviaon, variance, range, and skewness). The following tabular
Remedial Acon Plan
VCP Site #C125 Version 2
Liberty Corner, Salt Lake City, Utah July 2024

Project No. 271EM00861 Page B-7 Atlas Technical Consultants LLC

 Upper Simultaneous Limit at 95% confidence (USL95)
 Upper Tolerance Limit with 95% coverage and 95% or 99% confidence (UTL95-95 , UTL95-99), and
 Upper Predicon Limit at 95% confidence (UPL95)
 95% Upper Percenle (x0.95)
stascal methods to establish a site-specific arsenic BTV:
For the purpose of this evaluaon, Atlas evaluated four different stascal limits as potenally applicable
B.3.1 Overview of Candidate BTV Stascs
considered for the Site.
mulple future observaons. The following secon provides an overview of candidate BTV stascs
confidence and whether the resulng esmate is intended to apply to a single future observaon or to
of non-detect observaons. In addion, the BTV esmang method should also consider the desired
the size of the background sample populaon, data distribuon, data variability, and presence or absence
for all sites. Selecon of an appropriate BTV esmang method is influenced by various factors, including
It should be noted that there is no single, universally accepted BTV esmang method that is appropriate
the false negave error rate, increasing the likelihood of leaving contaminaon in place
result in higher project costs. Conversely, BTV esmates that are higher than the true background increase
background increase the false posive error rate, resulng in unnecessary removal acons that would
concentraon is below the background level). In general, BTV esmates that are lower than the true
level) and false negave (Type II) error rates (i.e., erroneously concluding that the constuent
I) error rates (i.e., erroneously concluding that the constuent concentraon is above the background
such, the BTV esmate should be designed to provide a reasonable balance between false posive (Type
and to confirm that arsenic concentraons that remain are consistent with the “true” background. As
The BTV will be used to both idenfy locaons where arsenic concentraons exceed the remedial objecve
B.3 SELECTION OF BTV STATISTICS
and considers the full range of available data to support the BTV determinaon.
outlier analysis, stascal evaluaon, and BTV esmang balances the potenal for future decision errors
For the reasons outlined above, the selected alternave of ulizing all soil as the basis for subsequent
source, reliance on deep soil data would increase the potenal for Type I error.
distribuon of arsenic in soil. If, as suspected, arsenic is associated with an aerial deposion
 Reliance on deep soil data only would neglect characteriscs relang to the occurrence and
intervals.
consequence, this would increase the potenal for Type II error, parcularly within the deeper soil
and deep soil were considered to represent the background sample populaon. As a
 Reliance on shallow soil data only would tend to result in higher BTV esmates than if the shallow
relave basis, BTV esmates would generally be higher for shallow soil and lower for deeper soil.
value is scienfically-defensible and preferred as a simplifying approach. In general and on a
different BTV esmates applicable to the three soil sampling depths. Adopon of a single BTV
complexies to future site decision-making. If applied, this approach would result in three
 While BTV esmates could be established by sample depth, this would introduce addional
Remedial Acon Plan
VCP Site #C125 Version 2
Liberty Corner, Salt Lake City, Utah July 2024

Project No. 271EM00861 Page B-8 Atlas Technical Consultants LLC

95% of the observaons from the background populaon will be less than or equal to that upper-limit
level of confidence. The UTL95-95 is a value that represents the upper limit of a tolerance interval such that
A tolerance interval establishes liming values that include a fixed proporon of a populaon with a stated
B.3.1.3 Upper Tolerance Limit (UTL95-95)
UPL95 is not appropriate as a BTV for this Site.
an unknown number of future confirmaon samples, the high false posive error rate associated with the
Since the proposed site development acvies and subsequent removal acons will involve collecon of
compared to the UPL95 is known, the UPL95 can be computed accordingly.
of the samples would exceed the UPL95. If the total number of future samples to be collected and
one-hundred future samples are drawn from this populaon, there is a 95% probability that at least one
value is approximately 5% for any single future sample drawn from the same populaon. If, for example,
comparisons. By way of a generalized illustraon, the false posive error rate associated with a UPL95
posives. This is because the probability of Type I error (false posive) increases with the number of future
However, using UPL95 to compare many future observaons may result in a relavely high number of false
compared against the UPL value.
UPLs are more appropriate for use when only a few known number of future observaons are to be
CC provides a good compromise between false posives and false negaves (USEPA, 2011b). In general,
populaon with a confidence coefficient (CC) of 95%. In most praccal applicaons, the choice of the 95%
that would classify future observaons at or below this limit as being taken from the background
probability or level of confidence, based on what has already been observed. The UPL95 establishes a limit
A predicon interval is an esmate of an interval in which future observaons will fall, with a certain
B.3.1.2 Upper Predicon Limit (UPL95)
percenle approach is not appropriate as a BTV for this Site.
significant number of confirmaon samples and result in a high false posive error rate, the upper
The proposed site development acvies and subsequent removal acons will involve collecon of a
exceed the x0.95 value from 5% to 50%.
extended to include ten future samples, increases the likelihood that at least one future sample would
high number of false posives. By way of illustraon, a 5% error rate for a single future sample when
of site observaons are to be compared to a BTV, the use of x0.95 as the BTV may lead to an unreasonably
variability or total number of future observaons to be compared to the x0.95 value. When a large number
approximately 5% of background values would exceed x0.95, this stasc does not take into account the
locaon, such as a confirmaon soil sample obtained from a remedial excavaon area. While by definion,
to x0.95. An “observaon” in this context is a measurement of chemical concentraon at a parcular
background populaon, there is a 95% probability that a random observaon would be less than or equal
the background populaon would be less than or equal to x0.95. If a populaon is comparable to the
(Singh et al., 2015; USEPA, 2011b). Under this approach, it is expected that 95% of the values coming from
The Upper Percenle (x0.95) represents an esmate of the 95th percenle of background populaon
B.3.1.1 Upper Percenle (x0.95)
project objecves is included in the following secons.
sample size increases. A brief descripon of each of these stascs and suitability with regard to the
variability in all sampled and unsampled locaons, crical values associated with a USL95 increase as the
(e.g., USL95 and UTL95-95) may exceed the largest value in the background dataset. To account for data
It should be noted that depending upon the variability of the background data, certain stascal methods
Remedial Acon Plan
VCP Site #C125 Version 2
Liberty Corner, Salt Lake City, Utah July 2024

Project No. 271EM00861 Page B-9 Atlas Technical Consultants LLC

as decision points during the remedial process.
represent a BTV for use as a both a numeric cleanup goal and for conducng point-by-point comparisons
USL95 based on an established background dataset is recommended as the most appropriate basis to
In summary, a populaon stasc that represents a stascally-based upper tolerance limit, such as the
approximately 52.6% and comparable to the target objecve of 50%.
represent impacted locaons. In the case of the subject Site, the RSD for the enre sample populaon is
(i.e., the relave standard deviaon [RSD] is less than 50%) and there are no potenal outliers that may
esmate BTVs when the variability in the background dataset used to derive USL95 is relavely small
consequently increases the potenal for Type II error. In general, the USL95 is an appropriate approach to
coverage for all future observaons, this metric results in a higher BTV esmate than the UTL95-95 and
(with 95% confidence) for all present and future background observaons. Since the USL95 provides 100%
USL95 provides 100% coverage (with 95% confidence), while the UTL95-95 provides 95% coverage
Measures that are applicable to all present and future observaons include the UTL95-95 and USL95. The
follows: x0.95, UPL95, UTL95-95, and USL95.
represenng background). In a ranked order, the stascs with decreasing chance of false posives are as
exceeding background) and Type II or false negave errors (i.e., samples falsely characterized as
with varying balances between Type I or false posive errors (i.e., samples falsely characterized as
In a real-world context, the candidate BTV stascs [discussed above] represent a spectrum of stascs
B.3.2 Recommended BTV Stascs
represents the preferred alternave for establishing the Site BTV for arsenic.
values are believed to represent observaons representave of clean, unimpacted locaons, the USL95
posive and false negave errors. Since outliers were removed from the Site dataset and the retained
account the variability of current and future observaons and tends to provide a balance between false
is meant to perform many comparisons simultaneously (USEPA, 2011b). A parametric USL95 also takes into
Under the USL95, the false-posive error rate does not change with the number of comparisons since USL95
background populaon will be less than or equal to USL95 with a 95% CC.
Consequently, It is expected that all potenal observaons (present and future) coming from the
from the established background dataset will be less than or equal to USL95 with a CC of 95%.
1999b). A USL95 represents the upper limit such that all observaons, not some proporon or percenle,
populaon will be less than or equal to USL95 with 95% confidence (Singh and Nocerino, 1997; USEPA,
The USL95 is the stasc such that all potenal observaons (present and future) from the background
B.3.1.4 95% Upper Simultaneous Limit (USL95)
the UTL95-95 approach is not recommended as method for establishing the Site BTV esmate.
number of false posives can increase as the number of future samples also increases. For this reason,
While a parametric UTL95-95 takes into account the variability of current and future observaons, the
than 5% of the me by future samples originang from the background populaon, with a CC of 95%.
95th percenle (x0.95). From an exceedance perspecve, a UTL95-95 is the value that will be exceeded less
populaon with a probability of 95%. The UTL95-95 also represents a 95% upper confidence limit for the
observaons actually derived from a background populaon as not coming from the background
upper-limit value with a CC of 95%. In other words, a UTL95-95 can declare simply by chance that 5% of the
such that 99% of the observaons from the background populaon will be less than or equal to that
value with a CC of 95%. Similarly, a UTL95-99 is a value that represents the upper limit of a tolerance interval
Remedial Acon Plan
VCP Site #C125 Version 2
Liberty Corner, Salt Lake City, Utah July 2024

Project No. 271EM00861 Page B-10 Atlas Technical Consultants LLC

presented for all three distribuon types.
be parametric, with distribuons classified as both normal, gamma, and lognormal, BTV esmates are
applicable arsenic BTVs for both shallow and deep soil at the Site. Since the site data were determined to
Based on the evaluaon methodologies discussed above, the following table summarizes the potenally
ProUCL evaluaon output are presented as an aachment.
the data validaon process for the intended purpose of esmang the arsenic BTV. The results of the
The stascal evaluaon process discussed in Secon B.4 ulized all analycal results judged usable by
B.6 RECOMMENDED ARSENIC BACKGROUND THRESHOLD VALUE
for both Type I and Type II errors.
Adherence to appropriate field and laboratory QA/QC procedures is expected to minimize the potenal
in the sampling data, which may be introduced through field or laboratory equipment or procedures.
However, it should be noted that stascal methods do not protect against systemac variaons or bias
constrains the probability of the false-negave error to an acceptable level.
and the observed relavely small random variability of the background data (RSD of approximately 53%)
error may be large. However, for this evaluaon, the nominal background sample size of 50 (or greater)
in the background data is large and the background sample size is small, the probability of a false-negave
esmates that are influenced by the number of future samples to be obtained. If the random variability
current and future observaons from the background populaon. However, certain methods provide BTV
Formal stascal methods such as those discussed above explicitly account for random variability in the
B.5 DATA VARIABILITY AND UNCERTAINTY
(Singh et al, 2015). Supporng documentaon include ProUCL output files are included in the aachment.
technical details regarding the ProUCL applicaon are provided in the ProUCL Technical Guide
Results derived using the ProUCL soware were used to determine parametric USL95 BTVs. Addional
the established background dataset, following the removal of confirmed outliers.
acceptable measures. This secon summarizes the individual steps used to compute BTV esmates for
BTV esmates is intended to provide addional insight regarding the possible range of potenally
BTV esmates were calculated and are presented in this documentaon. Presentaon of these alternave
remedial goal for arsenic in soil under the proposed future remediaon acvies. However, alternave
As discussed in the previous secon, the USL95 is recommended for establishing a BTV to be used as the
B.4 BTV STATISTICAL PROCESS
Remedial Acon Plan
VCP Site #C125 Version 2
Liberty Corner, Salt Lake City, Utah July 2024

Project No. 271EM00861 Page B-11 Atlas Technical Consultants LLC

Data
Distribution
Statistical
Metric
Arsenic BTV
(mg/kg)
Normal
UTL95-95 11.04
UTL95-99 13.27
UPL95 10.01
USL95 13.56
x0.95 9.88
x0.99 11.79
Gamma
UTL95-95 13.42
UTL95-99 14.69
UPL95 11.42
USL95 19.31
x0.95 10.73
x0.99 14.18
Lognormal
UTL95-95 17.07
UTL95-99 28.85
UPL95 13.40
USL95 30.87
x0.95 13.00
x0.99 20.37
Notes:
Statistics presented for normal, gamma, and
lognormal distributions for comparison purposes.

Proposed BTV based on USL95 for normal
distribution.

Based on the results of this evaluaon, the proposed arsenic BTV for site soils at all depths is 13.6 mg/kg,
for the normal distribuon USL95. USL95 values based on other supported distribuon types range from
19.31 mg/kg (gamma) to 30.87 mg/kg (lognormal). While USL95 values for other data distribuons are
greater than the normal USL95, they are within the range of the original sample populaon before outliers
were idenfied and removed. Although arguments can be made to defend the applicaon of USL95 BTVs
based on gamma or lognormal distribuons, the normal USL95 BTV represents a reasonably conservave
and appropriate metric for its intended applicaon.
The BTV is proposed as the target remediaon goal and as a numeric threshold for use in confirming the
adequacy of soil removal in the three areas where arsenic was detected in shallow soil at concentraons
in excess of the proposed BTV (i.e., SB-12, SB-17, and SB-20).

Remedial Acon Plan
VCP Site #C125 Version 2
Liberty Corner, Salt Lake City, Utah July 2024

Project No. 271EM00861 Page B-12 Atlas Technical Consultants LLC

Office of Resource Conservaon and Recovery. EPA 530-R-09-007.
USEPA. 2009. Stascal Analysis of Groundwater Monitoring Data at RCRA Facilies – Unified Guidance.
EPA/540/R-01/003. Office of Emergency and Remedial Response, Washington, D.C.
USEPA. 2002a. Guidance for Comparing Background and Chemical Concentraons in Soil for CERCLA Sites.
Division, Las Vegas, NV.
USEPA. 1999b. Robust Stascal Intervals for Performance Evaluaon, USEPA Environmental Sciences
Sanitaon Landfill, EPA ID: PAD054142781, OU 01, Union Township, PA. EPA/AMD/R03-99/505. June 25.
U.S. Environmental Protecon Agency (USEPA). 1999a. Record of Decision Amendment: Keystone
Scout 2008 Version 1.0 User Guide. Office of Research and Development, EPA/600/R-08/038.
and A.K. Singh. October 2015.
ProUCL Version 5.1 Technical Guide. Office of Research and Development, EPA/600/R-07/041. Singh, A.
A.K. Singh. October 2015.
ProUCL Version 5.1 User Guide. Office of Research and Development, EPA/600/R-07/041. Singh, A. and
Intelligent Laboratory Systems 37 (1997) 55-69.
Singh, A. and J. Nocerino. 1997. Robust Intervals for Some Environmental Applicaons. Chemometrics and
Computaon. Hoboken, NJ: Wiley.
Krishnamoorthy, K., and T. Mathew. 2009. Stascal Tolerance Regions: Theory, Applicaons, and
Reinhold, New York.
Gilbert, Richard O. 1987. Stascal Methods for Environmental Polluon Monitoring. Van Nostrand
B.7 REFERENCES
Remedial Acon Plan
VCP Site #C125 Version 2
Liberty Corner, Salt Lake City, Utah July 2024

Project No. 271EM00861 Atlas Technical Consultants LLC

ATTACHMENTS
ARSENIC BACKGROUND THRESHOLD VALUE DETERMINATION

Rosner’s Outlier Test
ProUCL Input File (Outliers Removed)
Goodness of Fit Tests
General Descriptive Statistics
BTV Calculations (95-95)
BTV Calculations (95-99)

Remedial Acon Plan
VCP Site #C125 Version 2
Liberty Corner, Salt Lake City, Utah July 2024
User Selected Options Arsenic at all sample depths
Date/Time of Computation ProUCL 5.14/3/2024 6:04:26 PM
Outlier Tests for Selected Variables replacing nondetects with 1/2 the Detection Limit
Rosner's Outlier Test for 1 Outliers in As_All
Total N 53
From File WorkSheet_e.xls
Full Precision OFF
SD with NDs=DL/2 5.161
Number of data 53
Number of suspected outliers 1
Number NDs 1
Number Detects 53
Mean with NDs=DL/2 6.222
NDs replaced with half value.
Potential Obs.Test Critical Critical
#Mean sd outlier Number value value (5%)value (1%)
5.16 3.151 3.504
For 5% Significance Level, there is 1 Potential Outlier
1 6.222 5.112 32.6 53
Rosner's Outlier Test for 1 Outliers in As_All_OL1
Total N 52
Therefore, Observation 32.6 is a Potential Statistical Outlier
For 1% Significance Level, there is 1 Potential Outlier
SD with NDs=DL/2 3.64
Number of data 52
Number of suspected outliers 1
Number NDs 1
Number Detects 52
Mean with NDs=DL/2 5.714
NDs replaced with half value.
Potential Obs.Test Critical Critical
#Mean sd outlier Number value value (5%)value (1%)
3.436 3.144 3.496
For 5% Significance Level, there is 1 Potential Outlier
1 5.714 3.605 18.1 52
Rosner's Outlier Test for 1 Outliers in As_All_OL2
Total N 51
Therefore, Observation 18.1 is a Potential Statistical Outlier
For 1% Significance Level, there is no Potential Outlier
SD with NDs=DL/2 3.223
Number of data 51
Number of suspected outliers 1
Number NDs 1
Number Detects 51
Mean with NDs=DL/2 5.472
NDs replaced with half value.
Potential Obs.Test Critical Critical
#Mean sd outlier Number value value (5%)value (1%)
3.425 3.137 3.488
For 5% Significance Level, there is 1 Potential Outlier
1 5.472 3.191 16.4 51
Rosner's Outlier Test for 1 Outliers in As_All_OL3
Total N 50
Therefore, Observation 16.4 is a Potential Statistical Outlier
For 1% Significance Level, there is no Potential Outlier
SD with NDs=DL/2 2.848
Number of data 50
Number of suspected outliers 1
Number NDs 1
Number Detects 50
Mean with NDs=DL/2 5.253
NDs replaced with half value.
Potential Obs.Test Critical Critical
#Mean sd outlier Number value value (5%)value (1%)
For 1% Significance Level, there is no Potential Outlier
1.644 3.13 3.48
For 5% Significance Level, there is no Potential Outlier
1 5.253 2.819 0.618 1
Liberty Corner Apartments
1229 -1265 South 300 West
Salt Lake City, Utah
ProUCL Input Data - Post Outlier Removal
As_AllDepths D_As_AllDepths As_3fbg D_As_3fbg As_9fbg D_As_9fbg As_15fbg D_As_15fbg
0.618 1 0.618 1 1.36 1 1.37 1
1.36 1 2.19 1 1.7 1 1.825 1
1.37 1 3.66 1 1.89 1 2.56 1
1.7 1 4.19 1 2 0 2.58 1
1.825 1 6.46 1 2.19 1 3.03 1
1.89 1 6.78 1 2.41 1 3.46 1
2 0 6.99 1 2.61 1 3.86 1
2.19 1 7.58 1 2.66 1 4.28 1
2.19 1 8.55 1 3.24 1 4.31 1
2.41 1 8.57 1 3.39 1 5.11 1
2.56 1 8.59 1 3.96 1 5.24 1
2.58 1 8.79 1 5.21 1 5.32 1
2.61 1 9.15 1 6.01 1 5.66 1
2.66 1 9.56 1 6.04 1 6.85 1
3.03 1 9.77 1 7.63 1 7.86 1
3.235 1 8.38 1 9.23 1
3.39 1 9.48 1 9.82 1
3.46 1 9.68 1
3.66 1
3.86 1
3.96 1
4.19 1
4.28 1
4.31 1
5.11 1
5.21 1
5.24 1
5.32 1
5.66 1
6.01 1
6.04 1
6.46 1
6.78 1
6.85 1
6.99 1
7.58 1
7.63 1
7.86 1
8.38 1
8.55 1
8.57 1
8.59 1
8.79 1
9.15 1
9.23 1
9.48 1
9.56 1
9.68 1
9.77 1
9.82 1
Notes:
Values based on the average of the parent sample and field duplicate sample
J Flagged results presented at estimated values
Identified outliers removed from background sample dataset include 16,4, 18.1, and 32.6 mg/kg
Note: Substitution methods such as DL or DL/2 are not recommended.
Lilliefors (NDs = DL/2) 0.111 0.125 Data Appear Lognormal
Lilliefors (Lognormal ROS Estimates) 0.108 0.125 Data Appear Lognormal
Lilliefors (Detects Only) 0.107 0.126 Data Appear Lognormal
Lilliefors (NDs = DL) 0.106 0.125 Data Appear Lognormal
Shapiro-Wilk (NDs = DL/2) 0.935 0.947 Data Not Lognormal
Shapiro-Wilk (Lognormal ROS Estimates) 0.938 0.947 Data Not Lognormal
Shapiro-Wilk (Detects Only) 0.936 0.947 Data Not Lognormal
Shapiro-Wilk (NDs = DL) 0.938 0.947 Data Not Lognormal
Test value Crit. (0.05)Conclusion with Alpha(0.05)
Correlation Coefficient R 0.97 0.972 0.971 0.971
Lognormal GOF Test Results
No NDs NDs = DL NDs = DL/2 Log ROS
Anderson-Darling (Gamma ROS Estimates) 0.664 0.758
Kolmogorov-Smirnov (Gamma ROS Est.) 0.0976 0.126 Data Appear Gamma Distributed
Anderson-Darling (NDs = DL/2) 0.623 0.758
Kolmogorov-Smirnov (NDs = DL/2) 0.0965 0.126 Data Appear Gamma Distributed
Anderson-Darling (NDs = DL) 0.662 0.758
Kolmogorov-Smirnov (NDs = DL) 0.0976 0.126 Data Appear Gamma Distributed
Anderson-Darling (Detects Only) 0.631 0.757
Kolmogorov-Smirnov (Detects Only) 0.0981 0.128 Detected Data Appear Gamma Distributed
Test value Crit. (0.05)Conclusion with Alpha(0.05)
Correlation Coefficient R 0.964 0.964 0.963 0.964
Gamma GOF Test Results
No NDs NDs = DL NDs = DL/2Gamma ROS
Lilliefors (NDs = DL/2) 0.112 0.125 Data Appear Normal
Lilliefors (Normal ROS Estimates) 0.111 0.125 Data Appear Normal
Lilliefors (Detects Only) 0.114 0.126 Data Appear Normal
Lilliefors (NDs = DL) 0.115 0.125 Data Appear Normal
Shapiro-Wilk (NDs = DL/2) 0.94 0.947 Data Not Normal
Shapiro-Wilk (Normal ROS Estimates) 0.941 0.947 Data Not Normal
Shapiro-Wilk (Detects Only) 0.942 0.947 Data Not Normal
Shapiro-Wilk (NDs = DL) 0.937 0.947 Data Not Normal
Test value Crit. (0.05)Conclusion with Alpha(0.05)
Correlation Coefficient R 0.979 0.977 0.979 0.979
No NDs NDs = DL NDs = DL/2 Normal ROS
0.665 0.448
Normal GOF Test Results
Statistics (Lognormal ROS Estimates) ------ 1.484
0.683 0.463
Statistics (Gamma ROS Estimates) 2.872 2.713 1.849 1.486 0.663 0.446
Statistics (NDs = DL/2) 2.753 2.601 1.923 1.474
0.656 0.436
Statistics (NDs = DL) 2.898 2.737 1.834 1.488 0.659 0.443
Statistics (Non-Detects Only) 2.953 2.785 1.823 1.504
5.16 2.914
K hat K Star Theta hat Log Mean Log Stdv Log CV
Statistics (Lognormal ROS Imputed Data) 50 0.618 11.9 5.308
5.16 2.937
Statistics (Gamma ROS Imputed Data) 50 0.618 11.9 5.311 5.16 2.911
Statistics (Normal ROS Imputed Data) 50 0.618 11.9 5.292
5.16 2.905
Statistics (All: NDs treated as DL/2 value) 50 0.618 11.9 5.296 5.16 2.932
Statistics (All: NDs treated as DL value) 50 0.618 11.9 5.316
2 N/A
Statistics (Non-Detects Only) 49 0.618 11.9 5.383 5.21 2.895
Statistics (Non-Detects Only) 1 2 2 2
1 2.00%
Number Minimum Maximum Mean Median SD
Raw Statistics 50 0 50 49
As_AllDepths
Num Obs Num Miss Num Valid Detects NDs % NDs
From File Liberty_ProUCL Input_All.xls
Full Precision OFF
Confidence Coefficient 0.95
Goodness-of-Fit Test Statistics for Data Sets with Non-Detects
User Selected Options
Date/Time of Computation ProUCL 5.15/1/2024 12:46:46 PM
GOF_Stats w NDs_All and depth Page 1 of 4
Lilliefors Critical (0.05) Value 0.22
Data not Lognormal at (0.05) Significance Level
Shapiro Wilk Critical (0.05) Value 0.881
Approximate Shapiro Wilk P Value 1.6377E-4
Lilliefors Test Statistic 0.298
Correlation Coefficient R 0.832
Shapiro Wilk Test Statistic 0.707
K-S Critical(0.05) Value 0.223
Data not Gamma Distributed at (0.05) Significance Level
Lognormal GOF Test Results
A-D Test Statistic 1.346
A-D Critical (0.05) Value 0.744
K-S Test Statistic 0.277
Data appear Approximate Normal at (0.05) Significance Level
Gamma GOF Test Results
Correlation Coefficient R 0.838
Approximate Shapiro Wilk P Value 0.0427
Lilliefors Test Statistic 0.203
Lilliefors Critical (0.05) Value 0.22
Correlation Coefficient R 0.939
Shapiro Wilk Test Statistic 0.873
Shapiro Wilk Critical (0.05) Value 0.881
Standard Deviation of Log Transformed Data 0.745
Normal GOF Test Results
Kstar 2.55
Theta star 2.652
Mean of Log Transformed Data 1.743
Standard Deviation of Raw Data 2.831
Khat 3.132
Theta hat 2.16
Minimum 0.618
Maximum 9.77
Mean of Raw Data 6.763
Raw Statistics
Number of Valid Observations 15
Number of Distinct Observations 15
As_3fbg
GOF_Stats w NDs_All and depth Page 2 of 4
Note: Substitution methods such as DL or DL/2 are not recommended.
Lilliefors (NDs = DL/2) 0.112 0.202 Data Appear Lognormal
Lilliefors (Lognormal ROS Estimates) 0.129 0.202 Data Appear Lognormal
Lilliefors (Detects Only) 0.128 0.207 Data Appear Lognormal
Lilliefors (NDs = DL) 0.141 0.202 Data Appear Lognormal
Shapiro-Wilk (NDs = DL/2) 0.96 0.897 Data Appear Lognormal
Shapiro-Wilk (Lognormal ROS Estimates) 0.94 0.897 Data Appear Lognormal
Shapiro-Wilk (Detects Only) 0.946 0.892 Data Appear Lognormal
Shapiro-Wilk (NDs = DL) 0.94 0.897 Data Appear Lognormal
Test value Crit. (0.05)Conclusion with Alpha(0.05)
Correlation Coefficient R 0.982 0.978 0.987 0.979
Lognormal GOF Test Results
No NDs NDs = DL NDs = DL/2 Log ROS
Anderson-Darling (Gamma ROS Estimates) 0.405 0.749
Kolmogorov-Smirnov (Gamma ROS Est.) 0.145 0.206 Data Appear Gamma Distributed
Anderson-Darling (NDs = DL/2) 0.365 0.749
Kolmogorov-Smirnov (NDs = DL/2) 0.14 0.206 Data Appear Gamma Distributed
Anderson-Darling (NDs = DL) 0.549 0.747
Kolmogorov-Smirnov (NDs = DL) 0.166 0.205 Data Appear Gamma Distributed
Anderson-Darling (Detects Only) 0.446 0.746
Kolmogorov-Smirnov (Detects Only) 0.152 0.211 Detected Data Appear Gamma Distributed
Test value Crit. (0.05)Conclusion with Alpha(0.05)
Correlation Coefficient R 0.971 0.97 0.972 0.972
Gamma GOF Test Results
No NDs NDs = DL NDs = DL/2Gamma ROS
Lilliefors (NDs = DL/2) 0.191 0.202 Data Appear Normal
Lilliefors (Normal ROS Estimates) 0.188 0.202 Data Appear Normal
Lilliefors (Detects Only) 0.194 0.207 Data Appear Normal
Lilliefors (NDs = DL) 0.202 0.202 Data Appear Normal
Shapiro-Wilk (NDs = DL/2) 0.89 0.897 Data Not Normal
Shapiro-Wilk (Normal ROS Estimates) 0.899 0.897 Data Appear Normal
Shapiro-Wilk (Detects Only) 0.885 0.892 Data Not Normal
Shapiro-Wilk (NDs = DL) 0.87 0.897 Data Not Normal
Test value Crit. (0.05)Conclusion with Alpha(0.05)
Correlation Coefficient R 0.95 0.941 0.952 0.956
No NDs NDs = DL NDs = DL/2 Normal ROS
0.648 0.502
Normal GOF Test Results
Statistics (Lognormal ROS Estimates) ------ 1.289
0.688 0.544
Statistics (Gamma ROS Estimates) 2.577 2.185 1.703 1.273 0.674 0.53
Statistics (NDs = DL/2) 2.511 2.129 1.744 1.265
0.63 0.471
Statistics (NDs = DL) 2.84 2.404 1.562 1.303 0.63 0.483
Statistics (Non-Detects Only) 2.901 2.428 1.578 1.339
3.315 2.813
K hat K Star Theta hat Log Mean Log Stdv Log CV
Statistics (Lognormal ROS Imputed Data) 18 1.36 9.68 4.41
3.315 2.869
Statistics (Gamma ROS Imputed Data) 18 1.147 9.68 4.388 3.315 2.838
Statistics (Normal ROS Imputed Data) 18 0.707 9.68 4.364
3.315 2.788
Statistics (All: NDs treated as DL/2 value) 18 1 9.68 4.38 3.315 2.848
Statistics (All: NDs treated as DL value) 18 1.36 9.68 4.436
2 N/A
Statistics (Non-Detects Only) 17 1.36 9.68 4.579 3.39 2.804
Statistics (Non-Detects Only) 1 2 2 2
1 5.56%
Number Minimum Maximum Mean Median SD
Raw Statistics 18 0 18 17
Num Obs Num Miss Num Valid Detects NDs % NDs
As_9fbg
GOF_Stats w NDs_All and depth Page 3 of 4
Lilliefors Critical (0.05) Value 0.207
Data appear Lognormal at (0.05) Significance Level
Shapiro Wilk Critical (0.05) Value 0.892
Approximate Shapiro Wilk P Value 0.887
Lilliefors Test Statistic 0.102
Correlation Coefficient R 0.99
Shapiro Wilk Test Statistic 0.974
K-S Critical(0.05) Value 0.21
Data appear Gamma Distributed at (0.05) Significance Level
Lognormal GOF Test Results
A-D Test Statistic 0.141
A-D Critical (0.05) Value 0.743
K-S Test Statistic 0.0788
Data appear Normal at (0.05) Significance Level
Gamma GOF Test Results
Correlation Coefficient R 0.99
Approximate Shapiro Wilk P Value 0.422
Lilliefors Test Statistic 0.135
Lilliefors Critical (0.05) Value 0.207
Correlation Coefficient R 0.976
Shapiro Wilk Test Statistic 0.945
Shapiro Wilk Critical (0.05) Value 0.892
Standard Deviation of Log Transformed Data 0.547
Normal GOF Test Results
Kstar 3.323
Theta star 1.458
Mean of Log Transformed Data 1.447
Standard Deviation of Raw Data 2.456
Khat 3.988
Theta hat 1.215
Minimum 1.37
Maximum 9.82
Mean of Raw Data 4.845
Raw Statistics
Number of Valid Observations 17
Number of Distinct Observations 17
As_15fbg
GOF_Stats w NDs_All and depth Page 4 of 4
9.51 9.646
As_15fbg 17 0 2.266 2.67 3.03 4.31 5.66 6.612 8.408 9.348 9.726
2.245 3.315 6.033 6.994 8.71As_9fbg 18 0 1.833 2.076
9.626 9.796
As_3fbg 15 0 2.778 4.084 5.325 7.58 8.69 8.862 9.396 9.623 9.741
2.623 5.16 7.803 8.554 9.255As_AllDepths 50 0 1.884 2.53
Percentiles using all Detects (Ds) and Non-Detects (NDs)
Variable NumObs # Missing 10%ile 20%ile 25%ile(Q1)50%ile(Q2)75%ile(Q3)80%ile 90%ile 95%ile 99%ile
0.709 0.612
As_15fbg 17 0 1.37 9.82 4.845 4.31 6.034 2.456 2.001 0.672 0.507
4.579 3.39 7.864 2.804 2.506As_9fbg 17 0 1.36 9.68
0.155 0.526
As_3fbg 15 0 0.618 9.77 6.763 7.58 8.014 2.831 1.794 -1.037 0.419
5.34 5.21 7.895 2.81 3.855As_AllDepths 49 0 0.618 9.82
General Statistics for Raw Data Sets using Detected Data Only
Variable NumObs # Missing Minimum Maximum Mean Median Var SD MAD/0.675 Skewness CV
2.728 0.618
As_15fbg 17 0 17 0 0.00% N/A N/A 4.845 6.034 2.456 0.507
5.56% 2 2 4.416 7.443As_9fbg 18 0 17 1
2.807 0.533
As_3fbg 15 0 15 0 0.00% N/A N/A 6.763 8.014 2.831 0.419
2.00% 2 2 5.262 7.878As_AllDepths 50 0 49 1
From File: Liberty_ProUCL Input_All.xls
General Statistics for Censored Data Set (with NDs) using Kaplan Meier Method
Variable NumObs # Missing Num Ds NumNDs % NDs Min ND Max ND KM Mean KM Var KM SD KM CV
From File Liberty_ProUCL Input_All.xls
Full Precision OFF
General Statistics on Uncensored Data
Date/Time of Computation ProUCL 5.15/2/2024 11:13:48 AM
User Selected Options
Variance (KM) 7.878 SE of Mean (KM) 0.401
Estimates of Gamma Parameters using KM Estimates
Mean (KM) 5.262 SD (KM) 2.807
11.79
95% Gamma USL 19.34 21
95% Approx. Gamma UTL with 95% Coverage 13.45 14.05 95% Approx. Gamma UPL 11.44
The following statistics are computed using Gamma ROS Statistics on Imputed Data
Upper Limits using Wilson Hilferty (WH) and Hawkins Wixley (HW) Methods
WH HW WH HW
95% Percentile of Chisquare (2kstar) 11.94 90% Percentile 9.505
95% Percentile 11.3 99% Percentile 15.22
nu hat (MLE) 294.7 nu star (bias corrected) 278.3
MLE Mean (bias corrected) 5.27 MLE Sd (bias corrected) 3.159
k hat (MLE) 2.947 k star (bias corrected MLE) 2.783
Theta hat (MLE) 1.789 Theta star (bias corrected MLE) 1.894
Maximum 9.82 Median 5.16
SD 2.824 CV 0.536
This is especially true when the sample size is small.
For gamma distributed detected data, BTVs and UCLs may be computed using gamma distribution on KM estimates
Minimum 0.618 Mean 5.27
Gamma ROS Statistics using Imputed Non-Detects
GROS may not be used when data set has > 50% NDs with many tied observations at multiple DLs
GROS may not be used when kstar of detects is small such as <1.0, especially when the sample size is small (e.g., <15-20)
For such situations, GROS method may yield incorrect values of UCLs and BTVs
MLE Mean (bias corrected) 5.34
MLE Sd (bias corrected) 3.165 95% Percentile of Chisquare (2kstar) 12.13
Theta hat (MLE) 1.769 Theta star (bias corrected MLE) 1.876
nu hat (MLE) 295.8 nu star (bias corrected) 279
Gamma Statistics on Detected Data Only
k hat (MLE) 3.018 k star (bias corrected MLE) 2.847
5% K-S Critical Value 0.127Detected data appear Gamma Distributed at 5% Significance Level
Detected data follow Appr. Gamma Distribution at 5% Significance Level
5% A-D Critical Value 0.757 Data Not Gamma Distributed at 5% Significance Level
K-S Test Statistic 0.104 Kolmogorov-Smirnov GOF
Gamma GOF Tests on Detected Observations Only
A-D Test Statistic 0.778 Anderson-Darling GOF Test
99% Percentile (z) 11.88 95% USL 13.67
DL/2 is not a recommended method. DL/2 provided for comparisons and historical reasons
95% UTL95% Coverage 11.12 95% UPL (t) 10.08
90% Percentile (z) 8.903 95% Percentile (z) 9.937
DL/2 Substitution Background Statistics Assuming Normal Distribution
Mean 5.253 SD 2.848
99% KM Percentile (z) 11.79 95% KM USL 13.56
95% UTL95% Coverage 11.04 95% KM UPL (t) 10.01
90% KM Percentile (z) 8.859 95% KM Percentile (z) 9.879
Kaplan Meier (KM) Background Statistics Assuming Normal Distribution
KM Mean 5.262 KM SD 2.807
5% Lilliefors Critical Value 0.126 Detected Data appear Normal at 5% Significance Level
Detected Data appear Approximate Normal at 5% Significance Level
5% Shapiro Wilk Critical Value 0.947 Data Not Normal at 5% Significance Level
Lilliefors Test Statistic 0.112 Lilliefors GOF Test
Normal GOF Test on Detects Only
Shapiro Wilk Test Statistic 0.919 Shapiro Wilk GOF Test
Critical Values for Background Threshold Values (BTVs)
Tolerance Factor K (For UTL) 2.058 d2max (for USL) 2.957
Mean Detected 5.34 SD Detected 2.81
Mean of Detected Logged Data 1.5 SD of Detected Logged Data 0.65
Maximum Detect 9.82 Maximum Non-Detect 2
Variance Detected 7.895 Percent Non-Detects 2%
Number of Distinct Detects 48 Number of Distinct Non-Detects 1
Minimum Detect 0.618 Minimum Non-Detect 2
Number of Distinct Observations 49
Number of Detects 49 Number of Non-Detects 1
As_AllDepths
General Statistics
Total Number of Observations 50 Number of Missing Observations 0
Coverage 95%
Different or Future K Observations 1
Number of Bootstrap Operations 2000
From File Liberty_ProUCL Input_All.xls
Full Precision OFF
Confidence Coefficient 95%
Background Statistics for Data Sets with Non-Detects
User Selected Options All Site Data (3 Outliers Removed)
Date/Time of Computation ProUCL 5.15/7/2024 7:04:15 PM
BTVwND_All 95_95 Page 1 of 6
Note: The use of USL tends to yield a conservative estimate of BTV, especially when the sample size starts exceeding 20.
Therefore, one may use USL to estimate a BTV only when the data set represents a background data set free of outliers
and consists of observations collected from clean unimpacted locations.
The use of USL tends to provide a balance between false positives and false negatives provided the data
represents a background data set and when many onsite observations need to be compared with the BTV.
95% USL 9.82 95% KM Chebyshev UPL 17.62
Approx, f used to compute achieved CC 1.289Approximate Actual Confidence Coefficient achieved by UTL 0.721
Approximate Sample Size needed to achieve specified CC 93 95% UPL 9.721
Nonparametric Upper Limits for BTVs(no distinction made between detects and nondetects)
Order of Statistic, r 49 95% UTL with95% Coverage 9.77
DL/2 is not a Recommended Method. DL/2 provided for comparisons and historical reasons.
Nonparametric Distribution Free Background Statistics
Data appear to follow a Discernible Distribution at 5% Significance Level
90% Percentile (z) 10.37 95% Percentile (z) 13.27
99% Percentile (z) 21.05 95% USL 32.28
SD in Original Scale 2.848 SD in Log Scale 0.678
95% UTL95% Coverage 17.56 95% UPL (t) 13.71
Background DL/2 Statistics Assuming Lognormal Distribution
Mean in Original Scale 5.253 Mean in Log Scale 1.47
KM SD of Logged Data 0.66 95% KM UPL (Lognormal) 13.4
95% KM Percentile Lognormal (z) 12.98 95% KM USL (Lognormal) 30.87
Statistics using KM estimates on Logged Data and Assuming Lognormal Distribution
KM Mean of Logged Data 1.477 95% KM UTL (Lognormal)95% Coverage 17.05
99% Percentile (z) 20.37 95% USL 30.87
95% Bootstrap (%) UTL95% Coverage 9.798 95% UPL (t) 13.42
90% Percentile (z) 10.23 95% Percentile (z) 13
SD in Original Scale 2.83 SD in Log Scale 0.659
95% UTL95% Coverage 17.07 95% BCA UTL95% Coverage 9.798
Background Lognormal ROS Statistics Assuming Lognormal Distribution Using Imputed Non-Detects
Mean in Original Scale 5.266 Mean in Log Scale 1.48
5% Lilliefors Critical Value 0.126 Detected Data appear Lognormal at 5% Significance Level
Detected Data appear Approximate Lognormal at 5% Significance Level
5% Shapiro Wilk Critical Value 0.947 Data Not Lognormal at 5% Significance Level
Lilliefors Test Statistic 0.114 Lilliefors GOF Test
Lognormal GOF Test on Detected Observations Only
Shapiro Wilk Test Statistic 0.921 Shapiro Wilk GOF Test
11.77
95% KM Gamma Percentile 11.17 11.49 95% Gamma USL 19.31 21
95% Approx. Gamma UTL with 95% Coverage 13.42 14.03 95% Approx. Gamma UPL 11.42
The following statistics are computed using gamma distribution and KM estimates
Upper Limits using Wilson Hilferty (WH) and Hawkins Wixley (HW) Methods
WH HW WH HW
80% gamma percentile (KM) 7.416 90% gamma percentile (KM) 9.136
95% gamma percentile (KM) 10.73 99% gamma percentile (KM) 14.18
nu hat (KM) 351.5 nu star (KM) 331.7
theta hat (KM) 1.497 theta star (KM) 1.586
k hat (KM) 3.515 k star (KM) 3.317
BTVwND_All 95_95 Page 2 of 6
represents a background data set and when many onsite observations need to be compared with the BTV.
Note: The use of USL tends to yield a conservative estimate of BTV, especially when the sample size starts exceeding 20.
Therefore, one may use USL to estimate a BTV only when the data set represents a background data set free of outliers
and consists of observations collected from clean unimpacted locations.
The use of USL tends to provide a balance between false positives and false negatives provided the data
95% Chebyshev UPL 19.51 99% Percentile 9.741
95% USL 9.77
95% UPL 9.77 90% Percentile 9.396
90% Chebyshev UPL 15.53 95% Percentile 9.623
Approximate Sample Size needed to achieve specified CC 59
95% Percentile Bootstrap UTL with 95% Coverage 9.77 95% BCA Bootstrap UTL with 95% Coverage 9.77
Order of Statistic, r 15 95% UTL with 95% Coverage 9.77
Approx, f used to compute achieved CC 0.789Approximate Actual Confidence Coefficient achieved by UTL 0.537
Nonparametric Distribution Free Background Statistics
Data appear Approximate Normal at 5% Significance Level
Nonparametric Upper Limits for Background Threshold Values
95% UPL (t) 22.18 95% Percentile (z) 19.48
95% USL 34.44 99% Percentile (z) 32.38
Background Statistics assuming Lognormal Distribution
95% UTL with 95% Coverage 38.71 90% Percentile (z) 14.86
5% Lilliefors Critical Value 0.22 Data Not Lognormal at 5% Significance Level
Data Not Lognormal at 5% Significance Level
5% Shapiro Wilk Critical Value 0.881 Data Not Lognormal at 5% Significance Level
Lilliefors Test Statistic 0.298 Lilliefors Lognormal GOF Test
Lognormal GOF Test
Shapiro Wilk Test Statistic 0.707 Shapiro Wilk Lognormal GOF Test
95% HW Approx. Gamma UTL with 95% Coverage 23.4
95% WH USL 19.83 95% HW USL 21.8
95% Hawkins Wixley (HW) Approx. Gamma UPL 16.51 95% Percentile 14.89
95% WH Approx. Gamma UTL with 95% Coverage 21.11 99% Percentile 20.24
Background Statistics Assuming Gamma Distribution
95% Wilson Hilferty (WH) Approx. Gamma UPL 15.49 90% Percentile 12.44
MLE Mean (bias corrected) 6.763 MLE Sd (bias corrected) 4.235
Theta hat (MLE) 2.16 Theta star (bias corrected MLE) 2.652
nu hat (MLE) 93.95 nu star (bias corrected) 76.5
Gamma Statistics
k hat (MLE) 3.132 k star (bias corrected MLE) 2.55
5% K-S Critical Value 0.223 Data Not Gamma Distributed at 5% Significance Level
Data Not Gamma Distributed at 5% Significance Level
5% A-D Critical Value 0.744 Data Not Gamma Distributed at 5% Significance Level
K-S Test Statistic 0.277 Kolmogorov-Smirnov Gamma GOF Test
Gamma GOF Test
A-D Test Statistic 1.346 Anderson-Darling Gamma GOF Test
95% UPL (t) 11.91 95% Percentile (z) 11.42
95% USL 13.58 99% Percentile (z) 13.35
Background Statistics Assuming Normal Distribution
95% UTL with 95% Coverage 14.03 90% Percentile (z) 10.39
5% Lilliefors Critical Value 0.22 Data appear Normal at 5% Significance Level
Data appear Approximate Normal at 5% Significance Level
5% Shapiro Wilk Critical Value 0.881 Data Not Normal at 5% Significance Level
Lilliefors Test Statistic 0.203 Lilliefors GOF Test
Normal GOF Test
Shapiro Wilk Test Statistic 0.873 Shapiro Wilk GOF Test
Critical Values for Background Threshold Values (BTVs)
Tolerance Factor K (For UTL) 2.566 d2max (for USL) 2.409
Coefficient of Variation 0.419 Skewness -1.037
Mean of logged Data 1.743 SD of logged Data 0.745
Maximum 9.77 Third Quartile 8.69
Mean 6.763 SD 2.831
Minimum 0.618 First Quartile 5.325
Second Largest 9.56 Median 7.58
As_3fbg
General Statistics
Total Number of Observations 15 Number of Distinct Observations 15
BTVwND_All 95_95 Page 3 of 6
10.32
95% KM Gamma Percentile 9.48 9.617 95% Gamma USL 13.83 14.47
95% Approx. Gamma UTL with 95% Coverage 13.54 14.14 95% Approx. Gamma UPL 10.13
The following statistics are computed using gamma distribution and KM estimates
Upper Limits using Wilson Hilferty (WH) and Hawkins Wixley (HW) Methods
WH HW WH HW
80% gamma percentile (KM) 6.53 90% gamma percentile (KM) 8.382
95% gamma percentile (KM) 10.14 99% gamma percentile (KM) 14.01
nu hat (KM) 94.33 nu star (KM) 79.94
theta hat (KM) 1.685 theta star (KM) 1.989
Variance (KM) 7.443 SE of Mean (KM) 0.663
k hat (KM) 2.62 k star (KM) 2.221
Estimates of Gamma Parameters using KM Estimates
Mean (KM) 4.416 SD (KM) 2.728
10.78
95% Gamma USL 14.57 15.36
95% Approx. Gamma UTL with 95% Coverage 14.25 15 95% Approx. Gamma UPL 10.52
The following statistics are computed using Gamma ROS Statistics on Imputed Data
Upper Limits using Wilson Hilferty (WH) and Hawkins Wixley (HW) Methods
WH HW WH HW
95% Percentile of Chisquare (2kstar) 10.08 90% Percentile 8.36
95% Percentile 10.12 99% Percentile 14.02
nu hat (MLE) 92.78 nu star (bias corrected) 78.65
MLE Mean (bias corrected) 4.388 MLE Sd (bias corrected) 2.969
k hat (MLE) 2.577 k star (bias corrected MLE) 2.185
Theta hat (MLE) 1.703 Theta star (bias corrected MLE) 2.009
Maximum 9.68 Median 3.315
SD 2.838 CV 0.647
This is especially true when the sample size is small.
For gamma distributed detected data, BTVs and UCLs may be computed using gamma distribution on KM estimates
Minimum 1.147 Mean 4.388
Gamma ROS Statistics using Imputed Non-Detects
GROS may not be used when data set has > 50% NDs with many tied observations at multiple DLs
GROS may not be used when kstar of detects is small such as <1.0, especially when the sample size is small (e.g., <15-20)
For such situations, GROS method may yield incorrect values of UCLs and BTVs
MLE Mean (bias corrected) 4.579
MLE Sd (bias corrected) 2.938 95% Percentile of Chisquare (2kstar) 10.85
Theta hat (MLE) 1.578 Theta star (bias corrected MLE) 1.886
nu hat (MLE) 98.64 nu star (bias corrected) 82.56
Gamma Statistics on Detected Data Only
k hat (MLE) 2.901 k star (bias corrected MLE) 2.428
5% K-S Critical Value 0.211Detected data appear Gamma Distributed at 5% Significance Level
Detected data appear Gamma Distributed at 5% Significance Level
5% A-D Critical Value 0.746Detected data appear Gamma Distributed at 5% Significance Level
K-S Test Statistic 0.152 Kolmogorov-Smirnov GOF
Gamma GOF Tests on Detected Observations Only
A-D Test Statistic 0.446 Anderson-Darling GOF Test
99% Percentile (z) 11.01 95% USL 11.51
DL/2 is not a recommended method. DL/2 provided for comparisons and historical reasons
95% UTL95% Coverage 11.37 95% UPL (t) 9.471
90% Percentile (z) 8.03 95% Percentile (z) 9.065
DL/2 Substitution Background Statistics Assuming Normal Distribution
Mean 4.38 SD 2.848
99% KM Percentile (z) 10.76 95% KM USL 11.25
95% UTL95% Coverage 11.11 95% KM UPL (t) 9.292
90% KM Percentile (z) 7.912 95% KM Percentile (z) 8.903
Kaplan Meier (KM) Background Statistics Assuming Normal Distribution
KM Mean 4.416 KM SD 2.728
5% Lilliefors Critical Value 0.207 Detected Data appear Normal at 5% Significance Level
Detected Data appear Approximate Normal at 5% Significance Level
5% Shapiro Wilk Critical Value 0.892 Data Not Normal at 5% Significance Level
Lilliefors Test Statistic 0.194 Lilliefors GOF Test
Normal GOF Test on Detects Only
Shapiro Wilk Test Statistic 0.885 Shapiro Wilk GOF Test
Critical Values for Background Threshold Values (BTVs)
Tolerance Factor K (For UTL) 2.453 d2max (for USL) 2.504
Mean of Detected Logged Data 1.339 SD of Detected Logged Data 0.63
Variance Detected 7.864 Percent Non-Detects 5.556%
Mean Detected 4.579 SD Detected 2.804
Minimum Detect 1.36 Minimum Non-Detect 2
Maximum Detect 9.68 Maximum Non-Detect 2
Number of Detects 17 Number of Non-Detects 1
Number of Distinct Detects 17 Number of Distinct Non-Detects 1
Total Number of Observations 18 Number of Missing Observations 0
Number of Distinct Observations 18
As_9fbg
General Statistics
BTVwND_All 95_95 Page 4 of 6
Note: The use of USL tends to yield a conservative estimate of BTV, especially when the sample size starts exceeding 20.
Therefore, one may use USL to estimate a BTV only when the data set represents a background data set free of outliers
and consists of observations collected from clean unimpacted locations.
The use of USL tends to provide a balance between false positives and false negatives provided the data
represents a background data set and when many onsite observations need to be compared with the BTV.
95% USL 9.68 95% KM Chebyshev UPL 16.63
Approx, f used to compute achieved CC 0.947Approximate Actual Confidence Coefficient achieved by UTL 0.603
Approximate Sample Size needed to achieve specified CC 59 95% UPL 9.68
Nonparametric Upper Limits for BTVs(no distinction made between detects and nondetects)
Order of Statistic, r 18 95% UTL with95% Coverage 9.68
DL/2 is not a Recommended Method. DL/2 provided for comparisons and historical reasons.
Nonparametric Distribution Free Background Statistics
Data appear to follow a Discernible Distribution at 5% Significance Level
90% Percentile (z) 8.557 95% Percentile (z) 10.99
99% Percentile (z) 17.56 95% USL 19.85
SD in Original Scale 2.848 SD in Log Scale 0.688
95% UTL95% Coverage 19.16 95% UPL (t) 12.12
Background DL/2 Statistics Assuming Lognormal Distribution
Mean in Original Scale 4.38 Mean in Log Scale 1.265
KM SD of Logged Data 0.626 95% KM UPL (Lognormal) 11.15
95% KM Percentile Lognormal (z) 10.19 95% KM USL (Lognormal) 17.46
Statistics using KM estimates on Logged Data and Assuming Lognormal Distribution
KM Mean of Logged Data 1.292 95% KM UTL (Lognormal)95% Coverage 16.91
99% Percentile (z) 16.37 95% USL 18.37
95% Bootstrap (%) UTL95% Coverage 9.68 95% UPL (t) 11.55
90% Percentile (z) 8.323 95% Percentile (z) 10.53
SD in Original Scale 2.813 SD in Log Scale 0.648
95% UTL95% Coverage 17.77 95% BCA UTL95% Coverage 9.68
Background Lognormal ROS Statistics Assuming Lognormal Distribution Using Imputed Non-Detects
Mean in Original Scale 4.41 Mean in Log Scale 1.289
5% Lilliefors Critical Value 0.207 Detected Data appear Lognormal at 5% Significance Level
Detected Data appear Lognormal at 5% Significance Level
5% Shapiro Wilk Critical Value 0.892 Detected Data appear Lognormal at 5% Significance Level
Lilliefors Test Statistic 0.128 Lilliefors GOF Test
Lognormal GOF Test on Detected Observations Only
Shapiro Wilk Test Statistic 0.946 Shapiro Wilk GOF Test
BTVwND_All 95_95 Page 5 of 6
represents a background data set and when many onsite observations need to be compared with the BTV.
Note: The use of USL tends to yield a conservative estimate of BTV, especially when the sample size starts exceeding 20.
Therefore, one may use USL to estimate a BTV only when the data set represents a background data set free of outliers
and consists of observations collected from clean unimpacted locations.
The use of USL tends to provide a balance between false positives and false negatives provided the data
95% Chebyshev UPL 15.86 99% Percentile 9.726
95% USL 9.82
95% UPL 9.82 90% Percentile 8.408
90% Chebyshev UPL 12.43 95% Percentile 9.348
Approximate Sample Size needed to achieve specified CC 59
95% Percentile Bootstrap UTL with 95% Coverage 9.82 95% BCA Bootstrap UTL with 95% Coverage 9.82
Order of Statistic, r 17 95% UTL with 95% Coverage 9.82
Approx, f used to compute achieved CC 0.895Approximate Actual Confidence Coefficient achieved by UTL 0.582
Nonparametric Distribution Free Background Statistics
Data appear Normal at 5% Significance Level
Nonparametric Upper Limits for Background Threshold Values
95% UPL (t) 11.36 95% Percentile (z) 10.46
95% USL 16.46 99% Percentile (z) 15.18
Background Statistics assuming Lognormal Distribution
95% UTL with 95% Coverage 16.56 90% Percentile (z) 8.571
5% Lilliefors Critical Value 0.207 Data appear Lognormal at 5% Significance Level
Data appear Lognormal at 5% Significance Level
5% Shapiro Wilk Critical Value 0.892 Data appear Lognormal at 5% Significance Level
Lilliefors Test Statistic 0.102 Lilliefors Lognormal GOF Test
Lognormal GOF Test
Shapiro Wilk Test Statistic 0.974 Shapiro Wilk Lognormal GOF Test
95% HW Approx. Gamma UTL with 95% Coverage 13.87
95% WH USL 13.24 95% HW USL 13.81
95% Hawkins Wixley (HW) Approx. Gamma UPL 10.41 95% Percentile 9.877
95% WH Approx. Gamma UTL with 95% Coverage 13.29 99% Percentile 13.04
Background Statistics Assuming Gamma Distribution
95% Wilson Hilferty (WH) Approx. Gamma UPL 10.19 90% Percentile 8.409
MLE Mean (bias corrected) 4.845 MLE Sd (bias corrected) 2.658
Theta hat (MLE) 1.215 Theta star (bias corrected MLE) 1.458
nu hat (MLE) 135.6 nu star (bias corrected) 113
Gamma Statistics
k hat (MLE) 3.988 k star (bias corrected MLE) 3.323
5% K-S Critical Value 0.21Detected data appear Gamma Distributed at 5% Significance Level
Detected data appear Gamma Distributed at 5% Significance Level
5% A-D Critical Value 0.743Detected data appear Gamma Distributed at 5% Significance Level
K-S Test Statistic 0.0788 Kolmogorov-Smirnov Gamma GOF Test
Gamma GOF Test
A-D Test Statistic 0.141 Anderson-Darling Gamma GOF Test
95% UPL (t) 9.258 95% Percentile (z) 8.885
95% USL 10.92 99% Percentile (z) 10.56
Background Statistics Assuming Normal Distribution
95% UTL with 95% Coverage 10.95 90% Percentile (z) 7.993
5% Lilliefors Critical Value 0.207 Data appear Normal at 5% Significance Level
Data appear Normal at 5% Significance Level
5% Shapiro Wilk Critical Value 0.892 Data appear Normal at 5% Significance Level
Lilliefors Test Statistic 0.135 Lilliefors GOF Test
Normal GOF Test
Shapiro Wilk Test Statistic 0.945 Shapiro Wilk GOF Test
Critical Values for Background Threshold Values (BTVs)
Tolerance Factor K (For UTL) 2.486 d2max (for USL) 2.475
Coefficient of Variation 0.507 Skewness 0.672
Mean of logged Data 1.447 SD of logged Data 0.547
Maximum 9.82 Third Quartile 5.66
Mean 4.845 SD 2.456
Minimum 1.37 First Quartile 3.03
Second Largest 9.23 Median 4.31
As_15fbg
General Statistics
Total Number of Observations 17 Number of Distinct Observations 17
BTVwND_All 95_95 Page 6 of 6
Variance (KM) 7.878 SE of Mean (KM) 0.401
Estimates of Gamma Parameters using KM Estimates
Mean (KM) 5.262 SD (KM) 2.807
11.79
95% Gamma USL 19.34 21
95% Approx. Gamma UTL with 99% Coverage 18.6 20.1 95% Approx. Gamma UPL 11.44
The following statistics are computed using Gamma ROS Statistics on Imputed Data
Upper Limits using Wilson Hilferty (WH) and Hawkins Wixley (HW) Methods
WH HW WH HW
95% Percentile of Chisquare (2kstar) 11.94 90% Percentile 9.505
95% Percentile 11.3 99% Percentile 15.22
nu hat (MLE) 294.7 nu star (bias corrected) 278.3
MLE Mean (bias corrected) 5.27 MLE Sd (bias corrected) 3.159
k hat (MLE) 2.947 k star (bias corrected MLE) 2.783
Theta hat (MLE) 1.789 Theta star (bias corrected MLE) 1.894
Maximum 9.82 Median 5.16
SD 2.824 CV 0.536
This is especially true when the sample size is small.
For gamma distributed detected data, BTVs and UCLs may be computed using gamma distribution on KM estimates
Minimum 0.618 Mean 5.27
Gamma ROS Statistics using Imputed Non-Detects
GROS may not be used when data set has > 50% NDs with many tied observations at multiple DLs
GROS may not be used when kstar of detects is small such as <1.0, especially when the sample size is small (e.g., <15-20)
For such situations, GROS method may yield incorrect values of UCLs and BTVs
MLE Mean (bias corrected) 5.34
MLE Sd (bias corrected) 3.165 95% Percentile of Chisquare (2kstar) 12.13
Theta hat (MLE) 1.769 Theta star (bias corrected MLE) 1.876
nu hat (MLE) 295.8 nu star (bias corrected) 279
Gamma Statistics on Detected Data Only
k hat (MLE) 3.018 k star (bias corrected MLE) 2.847
5% K-S Critical Value 0.127 Detected data appear Gamma Distributed at 5% Significance Level
Detected data follow Appr. Gamma Distribution at 5% Significance Level
5% A-D Critical Value 0.757 Data Not Gamma Distributed at 5% Significance Level
K-S Test Statistic 0.104 Kolmogorov-Smirnov GOF
Gamma GOF Tests on Detected Observations Only
A-D Test Statistic 0.778 Anderson-Darling GOF Test
99% Percentile (z) 11.88 95% USL 13.67
DL/2 is not a recommended method. DL/2 provided for comparisons and historical reasons
95% UTL99% Coverage 13.38 95% UPL (t) 10.08
90% Percentile (z) 8.903 95% Percentile (z) 9.937
DL/2 Substitution Background Statistics Assuming Normal Distribution
Mean 5.253 SD 2.848
99% KM Percentile (z) 11.79 95% KM USL 13.56
95% UTL99% Coverage 13.27 95% KM UPL (t) 10.01
90% KM Percentile (z) 8.859 95% KM Percentile (z) 9.879
Kaplan Meier (KM) Background Statistics Assuming Normal Distribution
KM Mean 5.262 KM SD 2.807
5% Lilliefors Critical Value 0.126 Detected Data appear Normal at 5% Significance Level
Detected Data appear Approximate Normal at 5% Significance Level
5% Shapiro Wilk Critical Value 0.947 Data Not Normal at 5% Significance Level
Lilliefors Test Statistic 0.112 Lilliefors GOF Test
Normal GOF Test on Detects Only
Shapiro Wilk Test Statistic 0.919 Shapiro Wilk GOF Test
Critical Values for Background Threshold Values (BTVs)
Tolerance Factor K (For UTL) 2.855 d2max (for USL) 2.957
Mean Detected 5.34 SD Detected 2.81
Mean of Detected Logged Data 1.5 SD of Detected Logged Data 0.65
Maximum Detect 9.82 Maximum Non-Detect 2
Variance Detected 7.895 Percent Non-Detects 2%
Number of Distinct Detects 48 Number of Distinct Non-Detects 1
Minimum Detect 0.618 Minimum Non-Detect 2
Number of Distinct Observations 49
Number of Detects 49 Number of Non-Detects 1
As_AllDepths
General Statistics
Total Number of Observations 50 Number of Missing Observations 0
Coverage 99%
Different or Future K Observations 1
Number of Bootstrap Operations 2000
From File Liberty_ProUCL Input_All.xls
Full Precision OFF
Confidence Coefficient 95%
Background Statistics for Data Sets with Non-Detects
User Selected Options
Date/Time of Computation ProUCL 5.15/7/2024 7:07:34 PM
BTVwND_All 95_99 Page 1 of 5
5% K-S Critical Value 0.223 Data Not Gamma Distributed at 5% Significance Level
5% A-D Critical Value 0.744 Data Not Gamma Distributed at 5% Significance Level
K-S Test Statistic 0.277 Kolmogorov-Smirnov Gamma GOF Test
Gamma GOF Test
A-D Test Statistic 1.346 Anderson-Darling Gamma GOF Test
95% UPL (t) 11.91 95% Percentile (z) 11.42
95% USL 13.58 99% Percentile (z) 13.35
Background Statistics Assuming Normal Distribution
95% UTL with 99% Coverage 16.73 90% Percentile (z) 10.39
5% Lilliefors Critical Value 0.22 Data appear Normal at 5% Significance Level
Data appear Approximate Normal at 5% Significance Level
5% Shapiro Wilk Critical Value 0.881 Data Not Normal at 5% Significance Level
Lilliefors Test Statistic 0.203 Lilliefors GOF Test
Normal GOF Test
Shapiro Wilk Test Statistic 0.873 Shapiro Wilk GOF Test
Critical Values for Background Threshold Values (BTVs)
Tolerance Factor K (For UTL) 3.52 d2max (for USL) 2.409
Coefficient of Variation 0.419 Skewness -1.037
Mean of logged Data 1.743 SD of logged Data 0.745
Maximum 9.77 Third Quartile 8.69
Mean 6.763 SD 2.831
Minimum 0.618 First Quartile 5.325
Second Largest 9.56 Median 7.58
As_3fbg
General Statistics
Total Number of Observations 15 Number of Distinct Observations 15
Note: The use of USL tends to yield a conservative estimate of BTV, especially when the sample size starts exceeding 20.
Therefore, one may use USL to estimate a BTV only when the data set represents a background data set free of outliers
and consists of observations collected from clean unimpacted locations.
The use of USL tends to provide a balance between false positives and false negatives provided the data
represents a background data set and when many onsite observations need to be compared with the BTV.
95% USL 9.82 95% KM Chebyshev UPL 17.62
Approx, f used to compute achieved CC 0.505 Approximate Actual Confidence Coefficient achieved by UTL 0.395
Approximate Sample Size needed to achieve specified CC 299 95% UPL 9.721
Nonparametric Upper Limits for BTVs(no distinction made between detects and nondetects)
Order of Statistic, r 50 95% UTL with99% Coverage 9.82
DL/2 is not a Recommended Method. DL/2 provided for comparisons and historical reasons.
Nonparametric Distribution Free Background Statistics
Data appear to follow a Discernible Distribution at 5% Significance Level
90% Percentile (z) 10.37 95% Percentile (z) 13.27
99% Percentile (z) 21.05 95% USL 32.28
SD in Original Scale 2.848 SD in Log Scale 0.678
95% UTL99% Coverage 30.12 95% UPL (t) 13.71
Background DL/2 Statistics Assuming Lognormal Distribution
Mean in Original Scale 5.253 Mean in Log Scale 1.47
KM SD of Logged Data 0.66 95% KM UPL (Lognormal) 13.4
95% KM Percentile Lognormal (z) 12.98 95% KM USL (Lognormal) 30.87
Statistics using KM estimates on Logged Data and Assuming Lognormal Distribution
KM Mean of Logged Data 1.477 95% KM UTL (Lognormal)99% Coverage 28.85
99% Percentile (z) 20.37 95% USL 30.87
95% Bootstrap (%) UTL99% Coverage 9.82 95% UPL (t) 13.42
90% Percentile (z) 10.23 95% Percentile (z) 13
SD in Original Scale 2.83 SD in Log Scale 0.659
95% UTL99% Coverage 28.85 95% BCA UTL99% Coverage 9.82
Background Lognormal ROS Statistics Assuming Lognormal Distribution Using Imputed Non-Detects
Mean in Original Scale 5.266 Mean in Log Scale 1.48
5% Lilliefors Critical Value 0.126 Detected Data appear Lognormal at 5% Significance Level
Detected Data appear Approximate Lognormal at 5% Significance Level
5% Shapiro Wilk Critical Value 0.947 Data Not Lognormal at 5% Significance Level
Lilliefors Test Statistic 0.114 Lilliefors GOF Test
Lognormal GOF Test on Detected Observations Only
Shapiro Wilk Test Statistic 0.921 Shapiro Wilk GOF Test
11.77
95% KM Gamma Percentile 11.17 11.49 95% Gamma USL 19.31 21
95% Approx. Gamma UTL with 99% Coverage 14.69 15.5 95% Approx. Gamma UPL 11.42
The following statistics are computed using gamma distribution and KM estimates
Upper Limits using Wilson Hilferty (WH) and Hawkins Wixley (HW) Methods
WH HW WH HW
80% gamma percentile (KM) 7.416 90% gamma percentile (KM) 9.136
95% gamma percentile (KM) 10.73 99% gamma percentile (KM) 14.18
nu hat (KM) 351.5 nu star (KM) 331.7
theta hat (KM) 1.497 theta star (KM) 1.586
k hat (KM) 3.515 k star (KM) 3.317
BTVwND_All 95_99 Page 2 of 5
5% A-D Critical Value 0.746 Detected data appear Gamma Distributed at 5% Significance Level
K-S Test Statistic 0.152 Kolmogorov-Smirnov GOF
Gamma GOF Tests on Detected Observations Only
A-D Test Statistic 0.446 Anderson-Darling GOF Test
99% Percentile (z) 11.01 95% USL 11.51
DL/2 is not a recommended method. DL/2 provided for comparisons and historical reasons
95% UTL99% Coverage 13.98 95% UPL (t) 9.471
90% Percentile (z) 8.03 95% Percentile (z) 9.065
DL/2 Substitution Background Statistics Assuming Normal Distribution
Mean 4.38 SD 2.848
99% KM Percentile (z) 10.76 95% KM USL 11.25
95% UTL99% Coverage 13.61 95% KM UPL (t) 9.292
90% KM Percentile (z) 7.912 95% KM Percentile (z) 8.903
Kaplan Meier (KM) Background Statistics Assuming Normal Distribution
KM Mean 4.416 KM SD 2.728
5% Lilliefors Critical Value 0.207 Detected Data appear Normal at 5% Significance Level
Detected Data appear Approximate Normal at 5% Significance Level
5% Shapiro Wilk Critical Value 0.892 Data Not Normal at 5% Significance Level
Lilliefors Test Statistic 0.194 Lilliefors GOF Test
Normal GOF Test on Detects Only
Shapiro Wilk Test Statistic 0.885 Shapiro Wilk GOF Test
Critical Values for Background Threshold Values (BTVs)
Tolerance Factor K (For UTL) 3.37 d2max (for USL) 2.504
Mean of Detected Logged Data 1.339 SD of Detected Logged Data 0.63
Variance Detected 7.864 Percent Non-Detects 5.556%
Mean Detected 4.579 SD Detected 2.804
Minimum Detect 1.36 Minimum Non-Detect 2
Maximum Detect 9.68 Maximum Non-Detect 2
Number of Detects 17 Number of Non-Detects 1
Number of Distinct Detects 17 Number of Distinct Non-Detects 1
Total Number of Observations 18 Number of Missing Observations 0
Number of Distinct Observations 18
represents a background data set and when many onsite observations need to be compared with the BTV.
As_9fbg
General Statistics
Note: The use of USL tends to yield a conservative estimate of BTV, especially when the sample size starts exceeding 20.
Therefore, one may use USL to estimate a BTV only when the data set represents a background data set free of outliers
and consists of observations collected from clean unimpacted locations.
The use of USL tends to provide a balance between false positives and false negatives provided the data
95% Chebyshev UPL 19.51 99% Percentile 9.741
95% USL 9.77
95% UPL 9.77 90% Percentile 9.396
90% Chebyshev UPL 15.53 95% Percentile 9.623
Approximate Sample Size needed to achieve specified CC 299
95% Percentile Bootstrap UTL with 99% Coverage 9.77 95% BCA Bootstrap UTL with 99% Coverage 9.77
Order of Statistic, r 15 95% UTL with 99% Coverage 9.77
Approx, f used to compute achieved CC 0.152 Approximate Actual Confidence Coefficient achieved by UTL 0.14
Nonparametric Distribution Free Background Statistics
Data appear Approximate Normal at 5% Significance Level
Nonparametric Upper Limits for Background Threshold Values
95% UPL (t) 22.18 95% Percentile (z) 19.48
95% USL 34.44 99% Percentile (z) 32.38
Background Statistics assuming Lognormal Distribution
95% UTL with 99% Coverage 78.83 90% Percentile (z) 14.86
5% Lilliefors Critical Value 0.22 Data Not Lognormal at 5% Significance Level
Data Not Lognormal at 5% Significance Level
5% Shapiro Wilk Critical Value 0.881 Data Not Lognormal at 5% Significance Level
Lilliefors Test Statistic 0.298 Lilliefors Lognormal GOF Test
Lognormal GOF Test
Shapiro Wilk Test Statistic 0.707 Shapiro Wilk Lognormal GOF Test
95% HW Approx. Gamma UTL with 99% Coverage 35.09
95% WH USL 19.83 95% HW USL 21.8
95% Hawkins Wixley (HW) Approx. Gamma UPL 16.51 95% Percentile 14.89
95% WH Approx. Gamma UTL with 99% Coverage 30.08 99% Percentile 20.24
Background Statistics Assuming Gamma Distribution
95% Wilson Hilferty (WH) Approx. Gamma UPL 15.49 90% Percentile 12.44
MLE Mean (bias corrected) 6.763 MLE Sd (bias corrected) 4.235
Theta hat (MLE) 2.16 Theta star (bias corrected MLE) 2.652
nu hat (MLE) 93.95 nu star (bias corrected) 76.5
Gamma Statistics
k hat (MLE) 3.132 k star (bias corrected MLE) 2.55
Data Not Gamma Distributed at 5% Significance Level
BTVwND_All 95_99 Page 3 of 5
Note: The use of USL tends to yield a conservative estimate of BTV, especially when the sample size starts exceeding 20.
95% USL 9.68 95% KM Chebyshev UPL 16.63
Approx, f used to compute achieved CC 0.182 Approximate Actual Confidence Coefficient achieved by UTL 0.165
Approximate Sample Size needed to achieve specified CC 299 95% UPL 9.68
Nonparametric Upper Limits for BTVs(no distinction made between detects and nondetects)
Order of Statistic, r 18 95% UTL with99% Coverage 9.68
DL/2 is not a Recommended Method. DL/2 provided for comparisons and historical reasons.
Nonparametric Distribution Free Background Statistics
Data appear to follow a Discernible Distribution at 5% Significance Level
90% Percentile (z) 8.557 95% Percentile (z) 10.99
99% Percentile (z) 17.56 95% USL 19.85
SD in Original Scale 2.848 SD in Log Scale 0.688
95% UTL99% Coverage 36.01 95% UPL (t) 12.12
Background DL/2 Statistics Assuming Lognormal Distribution
Mean in Original Scale 4.38 Mean in Log Scale 1.265
KM SD of Logged Data 0.626 95% KM UPL (Lognormal) 11.15
95% KM Percentile Lognormal (z) 10.19 95% KM USL (Lognormal) 17.46
Statistics using KM estimates on Logged Data and Assuming Lognormal Distribution
KM Mean of Logged Data 1.292 95% KM UTL (Lognormal)99% Coverage 30.02
99% Percentile (z) 16.37 95% USL 18.37
95% Bootstrap (%) UTL99% Coverage 9.68 95% UPL (t) 11.55
90% Percentile (z) 8.323 95% Percentile (z) 10.53
SD in Original Scale 2.813 SD in Log Scale 0.648
95% UTL99% Coverage 32.19 95% BCA UTL99% Coverage 9.68
Background Lognormal ROS Statistics Assuming Lognormal Distribution Using Imputed Non-Detects
Mean in Original Scale 4.41 Mean in Log Scale 1.289
5% Lilliefors Critical Value 0.207 Detected Data appear Lognormal at 5% Significance Level
Detected Data appear Lognormal at 5% Significance Level
5% Shapiro Wilk Critical Value 0.892 Detected Data appear Lognormal at 5% Significance Level
Lilliefors Test Statistic 0.128 Lilliefors GOF Test
Lognormal GOF Test on Detected Observations Only
Shapiro Wilk Test Statistic 0.946 Shapiro Wilk GOF Test
10.32
95% KM Gamma Percentile 9.48 9.617 95% Gamma USL 13.83 14.47
95% Approx. Gamma UTL with 99% Coverage 16.26 17.28 95% Approx. Gamma UPL 10.13
The following statistics are computed using gamma distribution and KM estimates
Upper Limits using Wilson Hilferty (WH) and Hawkins Wixley (HW) Methods
WH HW WH HW
80% gamma percentile (KM) 6.53 90% gamma percentile (KM) 8.382
95% gamma percentile (KM) 10.14 99% gamma percentile (KM) 14.01
nu hat (KM) 94.33 nu star (KM) 79.94
theta hat (KM) 1.685 theta star (KM) 1.989
Variance (KM) 7.443 SE of Mean (KM) 0.663
k hat (KM) 2.62 k star (KM) 2.221
Estimates of Gamma Parameters using KM Estimates
Mean (KM) 4.416 SD (KM) 2.728
10.78
95% Gamma USL 14.57 15.36
95% Approx. Gamma UTL with 99% Coverage 20.7 22.7 95% Approx. Gamma UPL 10.52
The following statistics are computed using Gamma ROS Statistics on Imputed Data
Upper Limits using Wilson Hilferty (WH) and Hawkins Wixley (HW) Methods
WH HW WH HW
95% Percentile of Chisquare (2kstar) 10.08 90% Percentile 8.36
95% Percentile 10.12 99% Percentile 14.02
nu hat (MLE) 92.78 nu star (bias corrected) 78.65
MLE Mean (bias corrected) 4.388 MLE Sd (bias corrected) 2.969
k hat (MLE) 2.577 k star (bias corrected MLE) 2.185
Theta hat (MLE) 1.703 Theta star (bias corrected MLE) 2.009
Maximum 9.68 Median 3.315
SD 2.838 CV 0.647
This is especially true when the sample size is small.
For gamma distributed detected data, BTVs and UCLs may be computed using gamma distribution on KM estimates
Minimum 1.147 Mean 4.388
Gamma ROS Statistics using Imputed Non-Detects
GROS may not be used when data set has > 50% NDs with many tied observations at multiple DLs
GROS may not be used when kstar of detects is small such as <1.0, especially when the sample size is small (e.g., <15-20)
For such situations, GROS method may yield incorrect values of UCLs and BTVs
MLE Mean (bias corrected) 4.579
MLE Sd (bias corrected) 2.938 95% Percentile of Chisquare (2kstar) 10.85
Theta hat (MLE) 1.578 Theta star (bias corrected MLE) 1.886
nu hat (MLE) 98.64 nu star (bias corrected) 82.56
Gamma Statistics on Detected Data Only
k hat (MLE) 2.901 k star (bias corrected MLE) 2.428
5% K-S Critical Value 0.211 Detected data appear Gamma Distributed at 5% Significance Level
Detected data appear Gamma Distributed at 5% Significance Level
BTVwND_All 95_99 Page 4 of 5
represents a background data set and when many onsite observations need to be compared with the BTV.
Note: The use of USL tends to yield a conservative estimate of BTV, especially when the sample size starts exceeding 20.
Therefore, one may use USL to estimate a BTV only when the data set represents a background data set free of outliers
and consists of observations collected from clean unimpacted locations.
The use of USL tends to provide a balance between false positives and false negatives provided the data
95% Chebyshev UPL 15.86 99% Percentile 9.726
95% USL 9.82
95% UPL 9.82 90% Percentile 8.408
90% Chebyshev UPL 12.43 95% Percentile 9.348
Approximate Sample Size needed to achieve specified CC 299
95% Percentile Bootstrap UTL with 99% Coverage 9.82 95% BCA Bootstrap UTL with 99% Coverage 9.82
Order of Statistic, r 17 95% UTL with 99% Coverage 9.82
Approx, f used to compute achieved CC 0.172 Approximate Actual Confidence Coefficient achieved by UTL 0.157
Nonparametric Distribution Free Background Statistics
Data appear Normal at 5% Significance Level
Nonparametric Upper Limits for Background Threshold Values
95% UPL (t) 11.36 95% Percentile (z) 10.46
95% USL 16.46 99% Percentile (z) 15.18
Background Statistics assuming Lognormal Distribution
95% UTL with 99% Coverage 27.52 90% Percentile (z) 8.571
5% Lilliefors Critical Value 0.207 Data appear Lognormal at 5% Significance Level
Data appear Lognormal at 5% Significance Level
5% Shapiro Wilk Critical Value 0.892 Data appear Lognormal at 5% Significance Level
Lilliefors Test Statistic 0.102 Lilliefors Lognormal GOF Test
Lognormal GOF Test
Shapiro Wilk Test Statistic 0.974 Shapiro Wilk Lognormal GOF Test
95% HW Approx. Gamma UTL with 99% Coverage 19.8
95% WH USL 13.24 95% HW USL 13.81
95% Hawkins Wixley (HW) Approx. Gamma UPL 10.41 95% Percentile 9.877
95% WH Approx. Gamma UTL with 99% Coverage 18.38 99% Percentile 13.04
Background Statistics Assuming Gamma Distribution
95% Wilson Hilferty (WH) Approx. Gamma UPL 10.19 90% Percentile 8.409
MLE Mean (bias corrected) 4.845 MLE Sd (bias corrected) 2.658
Theta hat (MLE) 1.215 Theta star (bias corrected MLE) 1.458
nu hat (MLE) 135.6 nu star (bias corrected) 113
Gamma Statistics
k hat (MLE) 3.988 k star (bias corrected MLE) 3.323
5% K-S Critical Value 0.21 Detected data appear Gamma Distributed at 5% Significance Level
Detected data appear Gamma Distributed at 5% Significance Level
5% A-D Critical Value 0.743 Detected data appear Gamma Distributed at 5% Significance Level
K-S Test Statistic 0.0788 Kolmogorov-Smirnov Gamma GOF Test
Gamma GOF Test
A-D Test Statistic 0.141 Anderson-Darling Gamma GOF Test
95% UPL (t) 9.258 95% Percentile (z) 8.885
95% USL 10.92 99% Percentile (z) 10.56
Background Statistics Assuming Normal Distribution
95% UTL with 99% Coverage 13.23 90% Percentile (z) 7.993
5% Lilliefors Critical Value 0.207 Data appear Normal at 5% Significance Level
Data appear Normal at 5% Significance Level
5% Shapiro Wilk Critical Value 0.892 Data appear Normal at 5% Significance Level
Lilliefors Test Statistic 0.135 Lilliefors GOF Test
Normal GOF Test
Shapiro Wilk Test Statistic 0.945 Shapiro Wilk GOF Test
Critical Values for Background Threshold Values (BTVs)
Tolerance Factor K (For UTL) 3.414 d2max (for USL) 2.475
Coefficient of Variation 0.507 Skewness 0.672
Mean of logged Data 1.447 SD of logged Data 0.547
Maximum 9.82 Third Quartile 5.66
Mean 4.845 SD 2.456
Minimum 1.37 First Quartile 3.03
Second Largest 9.23 Median 4.31
As_15fbg
General Statistics
Total Number of Observations 17 Number of Distinct Observations 17
Therefore, one may use USL to estimate a BTV only when the data set represents a background data set free of outliers
and consists of observations collected from clean unimpacted locations.
The use of USL tends to provide a balance between false positives and false negatives provided the data
represents a background data set and when many onsite observations need to be compared with the BTV.
BTVwND_All 95_99 Page 5 of 5
Liberty Corner, Salt Lake City, Utah September 2024
VCP Site #C125 Version 2
Remedial Action Plan

Project No. 271EM00861 Atlas Technical Consultants LLC

APPENDIX C

Chemical Vapor Barrier Specifications

Engineered protection to create a healthy built environment.
DRAGO® WRAP
VAPOR INTRUSION BARRIER
The Stego
Life of The Building™ Warranty
As the construction industry leader in below-slab barrier materials, Stego
offers the first-of-its-kind warranty for its line of vapor barriers and retarders.
Warranty information available online at: stegoindustries.com/legal
®
3-in-1 product solution
EXPOSURE PATHWAY – VAPOR INTRUSION
For brownfields and contaminated sites, the focus has historically been to protect human health by preventing
exposure to direct contact of contaminated soil or drinking contaminated water. We now know that inhaling
chemical vapors poses a potential risk to the health of residents, workers, and other occupants who are inside
of the building envelope. (Source: EPA)
A VAPOR INTRUSION BARRIER SOLUTION with Unsurpassed Permeation Coefficients
Drago Wrap Vapor Intrusion Barrier is a multi-layered plastic extrusion that combines uniquely
designed materials with only high grade, prime, virgin resins. This patent pending barrier tech-
nology provides high performance and longevity, allowing for the redevelopment of contaminated
sites, creating a healthy built environment.
A cost effective 3-in-1 product solution providing unsurpassed protection from
chlorinated solvents, hydrocarbons, and moisture vapor.
Migration of Soil Vapors to Indoor Air
Both diffusion and advection can draw unwanted chemicals into the building envelope. Regardless of
the path that soil vapors can take, experts agree that a monolithic layer of protection like the Drago
Wrap Vapor Intrusion Barrier System is critical to controlling the transmission of these chemicals
into the building.
WATER TABLESOIL VAPORMIGRATION
SOIL CONTAMINATEDWITH VOCs
GROUNDWATER PLUMEOF VOCs
VAPOR INTRUSIONTHROUGH THEFOUNDATION SLAB
WATER TABLESOIL VAPORMIGRATION
SOIL CONTAMINATEDWITH VOCs
GROUNDWATER PLUMEOF VOCs
DRAGO WRAP VAPOR INTRUSION BARRIER
Vapor-forming chemicals may include:
• Volatile organic compounds (VOCs), such as
trichloroethylene and benzene.
• Select semivolatile organic compounds,
such as naphthalene.
This exposure pathway, known as vapor
intrusion, is the movement of chemical
vapors from the soil and groundwater
into the building envelope.
• In extreme examples, there is a risk of fire
or explosion.
• Other times, at levels with a detectable odor,
there may be acute short-term health issues
such as nausea, headache, and respiratory
irritation.
• More commonly though, long-term exposure
to even low-levels of certain chemical vapors
may increase the risk of chronic health effects,
such as cancer.
Drago Wrap Vapor Intrusion Barrier is the next game-changing barrier technology from the
creators of Stego® Wrap Vapor Barrier, the most widely-specified below-slab moisture vapor
barrier in North America.
(Source: EPA)
“It is estimated that there are more than 450,000 brownfields in the U.S.”
– www.epa.gov/brownfields
WATER TABLESOIL VAPORMIGRATION
SOIL CONTAMINATEDWITH VOCs GROUNDWATER PLUMEOF VOCs
VAPOR INTRUSIONTHROUGH THEFOUNDATION SLAB
WATER TABLESOIL VAPORMIGRATION
SOIL CONTAMINATEDWITH VOCs
GROUNDWATER PLUMEOF VOCs
DRAGO WRAP VAPOR INTRUSION BARRIER
P2 of 4
Continued...
Note - legal notice on the last page.
Extensive testing✓(Source: EPA)

Drago Wrap is specifically engineered to serve as a barrier to volatile organic compounds (VOCs). Through
patented and trade secret processes, Drago Wrap combines engineered barrier materials with the flexibility
and strength of a high-performance polyolefin film into an easy-to-install barrier against hydrocarbons and
chlorinated solvents.
TESTED – PROVEN EFFECTIVENESS
Extensive, independent testing proved Drago Wrap’s effectiveness in attenuating hydrocarbons and chlorinated
solvents. For more information on our independent testing, please contact Stego Industries’ Technical
Department or visit our website at stegoindustries.com.
FEATURES BENEFITS
Independent, university testing
Made from game-changing resin technology
and provides high performance and longevity
Installation methodology derived from extensive
lab and field work based on the principles found in
ASTM E1643 and finally validated through pressure
stress testing of simulated installations
20-mil, multi-layer material
14 ft wide rolls
ASTM E1745 compliant
Efficacy testing for hydrocarbons, chlorinated
solvents, and other soil gases (radon, methane)
Allows Developers, Owners, and Engineers to
redevelop brownfield sites and create a healthy
built environment
Fully intact, dependable installation
Exceptional durability as a result of robust physical
properties
Minimize seams
Designed to be installed below concrete slabs in
commercial, residential, and industrial applications
DRAGO WRAP IS ENGINEERED TO SERVE AS A BARRIER TO
VOLATILE ORGANIC COMPOUNDS
BENEFITS OF THE DRAGO WRAP
VAPOR INTRUSION BARRIER SYSTEM
P3 of 4
Continued...
Note - legal notice on the last page.
COMPLETE PROTECTIONWith Drago Accessory Products
GAME-CHANGING BARRIER SOLUTIONS
All designated trademarks are the intellectual property of Stego Industries, LLC. Installation, Warranty, and State Approval Information: stegoindustries.com/legal.
©2021 Stego Industries, LLC. All rights reserved. 11/2021
ST E G O I N STALLA
TIO
N
• SUPPO R T •
INSTALLATION
Installation methodology derived from extensive lab and field work based on the principles found in ASTM
E1643 and validated through pressure stress testing of simulated installations demonstrates Drago Wrap’s
ability to produce a fully intact, dependable installation.
As with any protection system, the installation of Drago Wrap is critical to the system’s effectiveness. Drago
Wrap and Drago Accessories make it easy to complete a successful installation. Refer to the complete Drago
Wrap Installation Instructions and Warranty Information on the website: stegoindustries.com.
SUPPORT
When you choose Drago Wrap and Drago Accessories, you gain
access to a large nationwide network of full-time technical sales
representatives providing unmatched local support and service to
augment the consistent, high-quality performance of our products.
CONTACT
To learn more about this game-changing technology, contact us to get
in touch with the nearest Stego representative. We look forward to
working with you on your next project.
877-464-7834 | stegoindustries.com
P4 of 4
DragoSeal™ Tape
SEAL AND PATCH
Combines Drago Wrap technology
with a powerful adhesive for a
barrier solution to seal seams,
patches, and other details,
defending against vapor intrusion.
DragoTack® Tape
SEAL THE PERIMETER
A solvent-resistant, double-
sided adhesive strip used to
bond and seal Drago Wrap to
concrete, masonry, wood,
metal, and other surfaces.
Drago® Sealant Form
DETAIL PIPE PENETRATIONS
A low-density, cross-linked,
closed-cell polyethylene
foam designed to be used as
a detailing piece with Drago
Sealant.
Drago® Mastic
DETAIL PIPE PENETRATIONS
A polymer-modified anionic
asphalt emulsion, designed to
be used with Drago Wrap, for
sealing utility, pipe penetrations,
and terminating edges.
Drago® Sealant
DETAIL PIPE PENETRATIONS
A two-component, high-performance
epoxy, designed to be used with
Drago Wrap for sealing utility and
pipe penetrations.
Utah Department of
Environmental Quality
195 North 1950 West
Salt Lake City, Utah 84114-4820
DAQ, Fugitive Dust Control Plan

Congratulations! Your Fugitive Dust Control Plan was successful.
1. Applicant Information
Name: Zachary Jones
Address: 6440 S Wasatch Blvd, Salt Lake City, 84121
Phone: [phone]
Email: [e-mail]
Applicant Type: Property Owner
2. Project Information
Project Name: Libery Corner
Address: 1265 S 300 West, Salt Lake City, 84101
County: Salt Lake
Directions:
Acreage: 2.21
Latitude: 40.741970
Longitude: -111.899250
3. Point of Contact
Name: Brent Harman
Company Name: Cowboy Partners, Salt Lake City, 84121
Address: 6440 S Wasatch Blvd
Phone: [phone]
Cell:
4. By submitting this plan I certified that:
A. I am authorized, on behalf of the individual or company listed in Section 1, as Applicant, to
apply for a Fugitive Dust Control Plan and to commit to al l of the terms and conditions of the
requested plan.
B. Construction activities will be limited to lands that the applicant either owns or is authorized
to use for construction activities.
C. The applicant accepts responsibility for assuring that all contr actors, subcontractors, and all
other persons on the construction site covered by this plan, comply with the terms and
conditions of the Fugitive Dust Control Plan.
D. I understand that any false material statement, representation or certification made in this
application may invalidate the plan or cause me to be subject to enforcement action pursuant
to Utah Code Ann. 19-2-115.
E. Failure to comply with fugitive dust rules may result in compliance action and penalties up to
$10,000 per violation/day.
Printed Name: Zachary Jones
Title: Property Owner
Company Name: Cowboy Partners
Dust Plan Number: e983b60d-efbe-451a-864c-4d754fd3b974
Dust Suppressants

FUGITIVE DUST CONTROL PLAN
GENERAL REQUIREMENT: ALL ACTIVITIES
MUST MEET OPACITY REQUIREMENTS IN R307 -
309-5
THE FOLLOWING IS A LIST OF PROJECT ACTIVITIES AND BEST MANAGEMENT PRACTICES
(BMP) THAT WILL BE CONDUCTED AT THIS SITE

BMP 04 CLEARING FORMS, FOUNDATIONS, SLAB CLEARING AND CLEANING OF FORMS,
FOUNDATIONS AND SLABS PRIOR TO POURING CONCRETE.
04-02 Use sweeping and water spray to clear forms, foundations and slabs.

BMP 08 DEMOLITION - MECHANICAL/MANUAL DEMOLITION OF WALLS, STUCCO, CONCRETE,
FREESTANDING STRUCTURES, BUILDINGS AND OTHER STRUCTURES.

Stabilize surface areas where support equipment and vehic les will operate.
08-01 Pre-water and maintain surface soils in a stabilized condition.

Stabilize demolition debris during handling.
08-04 Apply water.

Stabilize debris following demolition.
08-05 Apply water.

Stabilize surrounding area following demolition.
08-07 Apply water.

BMP 09 DISTURBED SOIL THROUGHOUT PROJECT INCLUDING BETWEEN STRUCTURES.
Limit disturbance of soils where possible.
09-01 Limit disturbance of soils with the use of fencing, barriers, barricades, and/or wind
barriers.

Stabilize and maintain stability of all disturbed soil throughout construction site.

BMP 11 HAULING MATERIALS.

Limit visible dust opacity from vehicular operations.
11-01 Apply and maintain water/chemical suppressant to operational areas and haul routes.

Stabilize materials during transport on site.
11-03 Use tarps or other suitable enclosures on haul trucks.

Clean wheels and undercarriage of haul trucks prior to leaving construction site.
11-06 Sweep or water haul road.

BMP 14 SCREENING OF ROCK, SOIL O R CONSTRUCTION DEBRIS.

Stabilize surface soils where support equipment and vehicles will operate.
14-01 Pre-water and maintain surface soils in a stabilized condition.

Pre-treat material prior to screening.
14-04 Apply a dust suppressant to material.

Stabilize material during screening.
14-05 Dedicate water source to screening operation and apply water as needed to prevent
dust.

Stabilize material and surrounding area immediately after screening.
14-09 Minimize storage pile height.

Transfer height
14-10 Drop material through the screen slowly and minimize drop height.

BMP 15 STAGING AREAS, EQUIPMENT STORAGE, VEHICLE PARKING LOTS, AND MATERIAL
STORAGE AREAS.

Limit visible dust opacity from vehicular operations.
15-02 Apply water on all vehicle traffic areas in the staging areas and unpaved access routes.

Stabilize staging area soils during use.
15-03 Pre-water and maintain surface soils in a stabilized condition.

Stabilize staging area soils at project completion.
15-09 Completed project will cover staging area with buildings, paving, and/or landscaping.

BMP 18 TRACKOUT PREVENTION AND CLEANUP OF MUD, SILT AND SOIL TRACKED OUT ONTO
PAVED ROADS.
Prevent dust from trackout.
18-01 Clean trackout at the end of the work shift from paved surfaces to mainta in dust control.

All exiting traffic must be routed over selected trackout control device(s).
18-08 Clearly establish and enforce traffic patterns to route traffic over selected trackout
control device(s).

BMP 21 TRUCK LOADING WITH MATERIALS INCLUDING CONSTRUCTION AND DEMOLITION
DEBRIS, ROCK AND SOIL.
21-03 Empty loader bucket slowly and keep loader bucket close to the truck to minimize the
drop height while dumping.
February 2, 2024
Liberty Corner Apartments
1265 S 300 W
Salt Lake City, UT 84101
Salt Lake City Public Utilities
Salt Lake City Storm Water
Salt Lake City, UT 84101
Reference:
Dear Salt Lake City Public Utilities:
Silver Leaf SWPPP has prepared the Storm Water Pollution Prevention Plan (SWPPP) for
Liberty Corner Apartments.
The SWPPP Includes:
•Notice of Intent
•Construction General Permit
•Site Maps with Best Management Practices Types and Site Locations
•Best Management Practices (BMP) Detailed Specifications and Instructions
•Inspection Report Form
•Civil Site Construction Plans
This report presents our design and construction Best Management Practices recommendations based
on our understanding of the project.
It has been rewarding to be of service to Jacobsen Construction during the Storm Water Pollution
Prevention Plan phase of this project. Please contact us, if you have any questions concerning the
information contained in this report, or if we can be of further assistance to you.
Sincere Regards,
Silver Leaf SWPPP
Jessica Jane Hall, P.E.
Project Specialist
[e-mail]
Mike Christofferson
Chief Executive Officer
[e-mail]
The electronic seal in this document was authorized by Jessica Jane Hall, P.E. No 343788-2202, on February 2, 2024
E[SHULHQFH 6LOYHU /HDI 6:333
Storm Water Pollution Prevention Plan (SWPPP)
Liberty Corner Apartments
Utah SWPPP Template, February 2021
SECTION 11: SWPPP PREPARER CERTIFICATION
SWPPP Preparer
I certify under penalty of law that this document and all attachments were prepared
under my direction or supervision in accordance with a system designed to assure that
qualified personnel properly gathered and evaluated the information submitted. Based
on my inquiry of the person or persons who manage the system, or those persons
directly responsible for gathering the information, the information submitted is, to the
best of my knowledge and belief, true, accurate, and complete. I am aware that there
are significant penalties for submitting false information, including the possibility of fine
and imprisonment for knowing violations.
Name: Title:
Signature: Date:
Instructions:
― Starting January 1, 2021: A SWPPP writer for a site greater than 5 acres, with a perennial surface water
within 50 feet of the project, or with a steep slope (70% or 35 degrees or more) must hold a certification to
demonstrate that they are a “qualified person” per CGP Part 7.2..
Jessica Jane Hall, P.E.Professional Engineer State of Utah
2/2/2024
Storm Water Pollution Prevention Plan
This SWPPP has been created following the State template guidelines of 2021.
This SWPPP adheres to the Utah Construction General Permit .
Link to ComplianceGO site: https://app.compliancego.com/site/08f0bc8b-b67a-4cbb-9f9e-f90036623b7a
Storm Water Pollution Prevention Plan for:
Operator:
Primary SWPPP Contact
SWPPP Preparation Date:
UPDES Permit Tracking Number*:
*This is the unique number assigned to your project after you have applied for coverage under the Utah Pollutant
Discharge Elimination System (UPDES) construction general permit. If this template is filled out first, you can leave
the tracking number blank until after you have applied for coverage.
Storm Water Pollution Prevention Plan (SWPPP)
Silver Leaf SWPPP
Contents
SECTION 1: CONTACT INFORMATION/ RESPONSIBLE PARTIES 1
1.1 Storm Water Team 1
SECTION 2: NATURE OF CONSTRUCTION ACTIVITIES 2
2.1 Construction Site Estimates 2
2.2 Construction Activity Descriptions 2
2.3 Phase/Sequence of Construction Activity 3
2.4 Maps 4
SECTION 3: WATER QUALITY 5
3.1 Discharge Information 5
3.2 Receiving Waters 5
3.3 Impaired Waters 5
3.4 High Water Quality 6
SECTION 4: POLLUTION PREVENTION STANDARDS 7
4.1 Potential Sources of Pollution 7
4.2 Non-Storm Water Discharges 8
4.3 Dewatering Practices 8
4.4 Natural Buffers or Equivalent Sediment Controls 9
SECTION 5: EROSION AND SEDIMENT CONTROLS – BMPS 10
5.1 List of Erosion and Sediment BMPs on Site 10
5.2 Linear Site Perimeter Control Exemption 12
5.3 Final Stabilization 12
SECTION 6: BMPS - POLLUTION PREVENTION/OPERATIONAL CONTROLS 13
6.1 Spill Prevention and Response 13
6.2 Pollution Prevention Controls 15
SECTION 7: SPECIAL CONDITIONS 16
7.1 Emergency Related Projects 16
7.2 UIC Class 5 Injection Wells 16
7.3 Chemical Treatment 17
SECTION 8: INSPECTIONS & CORRECTIVE ACTIONS 18
8.1 Inspections 18
8.2 Corrective Actions 19
8.3 Delegation of Authority 19
SECTION 9: RECORDKEEPING 20
9.1 Recordkeeping 20
9.2 Log of Changes to the SWPPP 20
SECTION 10: CERTIFICATION
SECTION 11: SWPPP PREPARER CERTIFICATION (SEE COVER SHEET)
21
Appendix A – Site Maps
Appendix B – NOI
Appendix C – Inspection Reports
Appendix D –Corrective Action Report
Appendix E – Subcontractor Certifications/Agreements/Delegation of Authority
Storm Water Pollution Prevention Plan (SWPPP)
Silver Leaf SWPPP
Appendix F – Training Logs (CGP Part 6) and Certifications
Appendix G – Additional Information (i.e., Other permits and out of date SWPPP documents)
Appendix H – BMP Specifications
Appendix I – Construction General Permit
Storm Water Pollution Prevention Plan (SWPPP)
Silver Leaf SWPPP
SECTION 1: CONTACT INFORMATION/
RESPONSIBLE PARTIES
1.1 Storm Water Team
Name and/or Position,
and Contact
Responsibilities, Qualifications, and Training
Responsibilities: In charge of completing/managing and being
involved with: Phases of construction, SWPPP preparation,
inspections, install and upkeep of BMPs, and site emergencies.
Responsibilities: Install and maintain BMPs throughout the duration
of the project.
Responsibilities: Conduct storm-water inspections on a regular basis.
RSI, ECS, CISEC, etc.
Responsibilities: Prepares the SWPPP.
Responsibilities: Develop engineered civil plans.
Team Leader
Civil Drawings
Emergency Contact
BMP Installation & Maintenance
Install/Maintenance Crew
Qualified Inspector
RSI/ECS
Silver Leaf SWPPP
Project Specialist
Jessica Jane Hall, P.E.
[e-mail]
Storm Water Pollution Prevention Plan (SWPPP)
Silver Leaf SWPPP
https://drive.google.com/drive/folders/1UvTVywEbZVX0pjehNaWMzHyvCv_eJXey
1
SECTION 2: NATURE OF CONSTRUCTION ACTIVITIES
2.1 Construction Site Estimates
The following are estimates for the construction site.
Total project area acreage:
2.2 Construction Activity Descriptions
Describe the general scope of the work for the project, major phases of construction, etc:
Typical site business days and times:
Monday-Friday
8:00am-5:00pm
Storm Water Pollution Prevention Plan (SWPPP)
Silver Leaf SWPPP
Area to be disturbed:
Describe any on-site and off-site construction support activity areas:
YES N/A
2
Storm Water Pollution Prevention Plan (SWPPP)
Silver Leaf SWPPP
 PKaVeSeTuenFe of &onVtruFtion $Ftivit\
Stage I
Stage II
Stage III
Stage IV
3
2.4 Maps
The SWPPP site map(s) are filed in Appendix A
Storm Water Pollution Prevention Plan (SWPPP)
Silver Leaf SWPPP
4
SECTION 3: WATER QUALITY
3.1 Discharge Information
Does your project/site discharge storm water into a Municipal Separate Storm Sewer System
(MS4)?
List the MS4 that receives the discharge from the construction project:
3.2 Receiving Waters
Names of Receiving Waters
Name of Receiving Water ​(first
surface water that receives storm
water or where storm system
discharges to)
Is the water impaired or
high quality?
If high quality: Is it
Category 1 or 2?
If impaired: List
pollutants that the
waterbody is
impaired for
3.3 Impaired Waters
Description of additional precautions taken if you are discharging to an impaired surface water.
State if no impairment causing pollutants are on site:
YES NO
YES NO
Inspections will be increased to weekly with rain events following rainstorm
events measuring 0.5” or greater. The Correct BMPs will be in place to protect
the river from the site pollutants.
N/A
The receiving water is impaired and perimeter controls will be put in place to
protect the site and the water. Site is NOT required to increase inspection
frequency.
Storm Water Pollution Prevention Plan (SWPPP)
Silver Leaf SWPPP
5
3.4 High Water Quality
Description of additional precautions taken to minimize pollution effects if you are discharging
to a high quality surface water:
YES NO
Inspections will be increased to weekly with rain events following rainstorm
events measuring 0.5” or greater. The Correct BMPs will be in place to protect
the river from the site pollutants.
N/A
Storm Water Pollution Prevention Plan (SWPPP)
Silver Leaf SWPPP
6
SECTION 4: POLLUTION PREVENTION STANDARDS
4.1 Potential Sources of Pollution
Pollutant-Generating Activity
Pollutants or Pollutant
Constituents
(that could be discharged if exposed to
storm water)
Location on Site
(or reference SWPPP site map
where this is shown)
Concrete, paint and stucco washout Slurry and pH levels
Located in site maps on
ComplianceGO as they are
set up.
Dumpsters/Waste Disposal
Portable Toilets
Landscaping
Grading/Excavation
Paving
Dewatering
Vehicles
Sediment and debris
Sanitary waste nutrients, bacteria, pH
levels
Debris, nutrients, pH levels, sediment
Sediment, pH levels, debris
Sediment, pH levels, debris
pH levels and TSS
Oil, grease, debris, sediment
Other
Storm Water Pollution Prevention Plan (SWPPP)
Silver Leaf SWPPP
7
4.2 Non-Storm Water Discharges
Authorized Non-Storm Water Discharges Present Comments/Controls
Discharges from emergency fire-fighting
activities ☐Y ☒ N
Fire hydrant flushing ☐Y ☒ N
Properly managed landscape irrigation
(excludes fertilizer injector systems) ☒Y ☐ N Perimeter Controls
Properly managed vehicle and
equipment wash water with no soaps,
solvents, or detergents ☒Y ☐ N Track out pad
Water used to control dust ☒Y ☐ N See Fugitive Dust plan in Appendix G and
on ComplianceGO
Drinking water, includes uncontaminated
water line flushing ☒Y ☐ N Perimeter Controls
External building washdown with no soaps,
solvents, detergents, or hazardous substances ☐Y ☒ N
Pavement wash waters with no detergents or
toxic or hazardous materials. Must have a
sediment basin, sediment trap, of similarly
effective control prior to discharge. ☐Y ☒ N
Uncontaminated air conditioning or
compressor condensate ☐Y ☒ N
Uncontaminated, non-turbid
discharges of ground water (from
natural sources) or spring water ☐Y ☒ N
Uncontaminated foundation or footing
drains ☐Y ☒ N
4.3 Dewatering Practices
YES N/A
If checked "YES" a State de-watering permit will be obtained once they begin de-watering
on site. Weekly inspections will be implemented during the duration of the de-watering to
inspect the quality of the water. The samples are tested for pH levels and TSS and
monthly DMR reports are submitted to the DEQ. De-watering inspection reports are
located on ComplianceGO through the link in Appendix G.
Storm Water Pollution Prevention Plan (SWPPP)
Silver Leaf SWPPP
8
4.4 Natural Buffers or Equivalent Sediment Controls
Buffer Compliance Alternatives
Are there any surface waters within 50 feet of your project’s earth disturbances?
YES NO
Surface Water Distance:
Storm Water Pollution Prevention Plan (SWPPP)
Silver Leaf SWPPP
If Yes:
A 50-foot undisturbed natural buffer will be provided
When infeasible to provide the full 50-foot buffer an equivalent erosion control will
be implemented
•Reason that 50-foot buffer can not be obtained:
•Width of buffer that will be retained:
•Additional controls used to achieve equivalent sediment load reduction
of a 50-foot buffer:
9
SECTION 5: EROSION AND SEDIMENT CONTROLS –
BMPS
5.1 List of Erosion and Sediment BMPs on Site
CGP Requirement Example BMPs EPA
SWPPP
Guide
Section
BMPs Selected (Name
and Reference Number
if applicable)
Preserve vegetation where
possible and direct
storm water to
vegetated areas when
feasible (CGP 2.2.2.)
Phasing to minimize
disturbance, signs/fences
to protect areas not being
disturbed.
Chapter 4,
ESC
Principle 1
Phasing to minimize
disturbance, signs/fences
to protect areas not being
disturbed.
Install sediment controls
along perimeter areas that
receive pollutant discharges
(CGP 2.2.3.).
Silt fence, fiber rolls, earth
berms
Chapter 4,
ESC
Principle 7
Straw Wattle
Minimize sediment
track-out (CGP 2.2.4.)
Restrict access, stabilize
exits, track-out pads, tire
washing station, clean-up
sediments

Chapter 4,
ESC
Principle 9
Track out pad
Manage stockpiles with
perimeter controls and
locate away from
storm water
conveyances (CGP
2.2.5.)
Sediment barriers
downgradient, proper
location, covered
stockpiles, diverting storm
water from stockpiles
Chapter 4,
ESC
Principle 4
N/A
Minimize dust (CGP
2.2.6.)
Water application, mulching,
chemical dust suppression
techniques
Track out pad and
specific vehicle access
Minimize steep slope
disturbance (CGP 2.2.7.)
Erosion control blankets,
tackifiers, protect slopes
from disturbance
Chapter 4,
ESC
Principle 5
N/A
Preserve topsoil (CGP
2.2.8.)
Stockpile topsoil Chapter 4,
ESC
Principle 1
N/A
Storm Water Pollution Prevention Plan (SWPPP)
Silver Leaf SWPPP
10
Minimize soil compaction
where final cover is
vegetation (CGP
2.2.9.)
Restrict vehicle access,
recondition soils before
seeding
Restrict vehicle access
Protect storm drain inlets
(CGP 2.2.10.)
Inserts, rock-filled bags,
covers
Chapter 4,
ESC
Principle 6
Dandy bags/Flex Storms
Slow down runoff with
erosion controls and
velocity dissipation
devices (CGP 2.2.11.)
Check dams, riprap Chapter 4,
ESC
Principle 3
N/A
Appropriately design any
sediment basins or
impoundments (CGP
2.2.12.)
Design to 2-year 24-hour
storm or 3,600 cubic feet
per acre drained, include
design specifications
Chapter 4,
ESC
Principle 8
N/A
Follow requirements for
any treatment
chemicals (polymers,
flocculants, coagulants,
etc.)
Store in leak proof
containers and cover, proper
training, minimize use
N/A
Stabilize exposed portions
of site with 14 days of
inactivity (CGP
2.2.14).
Seeding, erosion
control blankets,
gravel, hydromulch
Chapter 9 Landscaping and paving
BMPs are installed prior to the start of the construction, maintained during construction and they
will be removed at the termination of the project.
List of BMPs:
Silt Fence
Straw Wattle- 9” and 12”
Cutbacks
Gator Guard
Gator Bags (Gutter Otters)
Flex Storms
Dandy Bags
De-watering Bags
Top Guard
Gravel Bags
Sandbags
Erosion Control Blankets
Storm Water Pollution Prevention Plan (SWPPP)
Silver Leaf SWPPP
11
See Appendix H for specifications, description, and instructions.
Responsible Staff:
Silver Leaf SWPPP
801-642-2097
[e-mail]
5.2 Linear Site Perimeter Control Exemption
5.3 Final Stabilization
Type of stabilization
(vegetation/landscaped,
graveled, paved, etc.)
Location Implementation Schedule
YES N/A
If "YES" and perimeter controls are not feasible describe other practices that will be
used:
Storm Water Pollution Prevention Plan (SWPPP)
Silver Leaf SWPPP
12
SECTION 6: BMPS - POLLUTION
PREVENTION/OPERATIONAL CONTROLS
6.1 Spill Prevention and Response
Describe spill procedures and materials available for expeditious containment, clean-up and
disposal of spills:
Please see ​the EPA’s Spill Prevention and Control Plan BMP Fact Sheet​ :
https://www.epa.gov/system/files/documents/2021-11/bmp-spill-prevention-and-control-measures.pdf
Spills must be minimized and controlled within a timely manner. Please provide at least the
minimum requirements listed below:
Any discharges in 24 hours equal to or in excess of the reportable quantities listed in 40 CFR
117, 40 CFR 110, and 40 CFR 302 will be reported to the National Response Center and the
Division of Water Quality (DWQ) as soon as practical after knowledge of the spill is known to
the permittees. The permittee shall submit within 14 calendar days of knowledge of the release a
written description of: the release (including the type and estimate of the amount of material
released), the date that such release occurred, the circumstances leading to the release, and
measures taken and/or planned to be taken to the Division of Water Quality (DWQ), 288 North
1460 West, P.O. Box 144870, Salt Lake City, Utah 84114-4870. The Storm Water Pollution
Prevention Plan must be modified within14 calendar days of knowledge of the release to provide
a description of the release, the circumstances leading to the release, and the date of the release.
In addition, the plan must be reviewed to identify measures to prevent the reoccurrence of such
releases and to respond to such releases, and the plan must be modified where appropriate.
Storm Water Pollution Prevention Plan (SWPPP)
Silver Leaf SWPPP
Emergency Contact:
Emergency Contact Phone Number:
13
Agency Phone Number
National Response Center [phone]
Division of Water Quality ( DWQ)
24-Hr Reporting
(801)-231-1769
[phone]
Utah Department of Health
Emergency Response [phone]
Material Media Released To Reportable Quantity
Engine oil, fuel, hydraulic &
brake fluid Land 25 gallons
Paints, solvents, thinners Land 100 lbs (13 gallons)
Engine oil, fuel, hydraulic &
brake fluid Water Visible Sheen
Antifreeze, battery acid, gasoline,
engine degreasers Air, Land, Water 100 lbs (13 gallons)
Refrigerant Air 1 lb
Storm Water Pollution Prevention Plan (SWPPP)
Silver Leaf SWPPP
1st Priority: Protect all people
2nd Priority: Protect equipment and property
3rd Priority: Protect the environment
1.Make sure the spill area is safe to enter and that it does not pose an immediate threat to health
or safety of any person.
2.Stop the spill source.
3.Check for hazards (flammable material, noxious fumes, cause of spill) –if flammable liquid,
turn off engines and nearby electrical equipment. If serious hazards are present leave area and
call 911. LARGE SPILLS ARE LIKELY TO PRESENT A HAZARD.
4.Call co-workers and supervisor for assistance and to make them aware of the spill and
potential dangers.
5.If possible, stop spill from entering drains (use absorbent or other material as necessary).
6.Stop spill from spreading (use absorbent or other material).
7.If spilled material has entered a storm sewer; contact the City Storm Water Department.
8.Clean up spilled material according to manufacturer specifications, for liquid spills use
absorbent materials and do not flush area with water.
9.Properly dispose of cleaning materials and used absorbent material according to manufacturer
specifications.
10. Report the reportable quantity to Storm Water Division.
Course of Action Plan:
14
6.2 Pollution Prevention Controls
CGP Requirements Example BMPs EPA SWPPP
Guide Section
BMPs Selected
(Name and Reference
Number if
applicable)
Equipment and vehicle
fueling (CGP 2.3.1)
Spill kits, SPCCP, drip pans, locate
activities away from conveyances,
use secondary containment
Chapter 5,
P2 Principle 4
Spill kit and drip pans
Equipment and vehicle
washing (CGP 2.3.2.)
Locating away from surface waters
and storm water conveyances,
directing wash waters to a sediment
basin or sediment trap, using
filtration devices
Chapter 5,
P2 Principle 5
Locating away from
surface waters and
storm water
conveyances, directing
wash waters to a
sediment basin or
sediment trap, using
filtration devices
Storage, handling, and
disposal of building
products and waste (CGP
2.3.3.)
Cover (plastic sheeting / temporary
roofs), secondary containment,
leakproof containers, proper
dumpsters, secured portable toilets,
locate away from storm water
conveyances
Chapter 5,
P2 Principle 1
and 2
Proper dumpsters,
secured portable
toilets, locate away
from storm water
conveyances
Washing of stucco, paint,
concrete, form release oils,
curing compounds, etc.
(CGP 2.3.4.)
Leak proof containers, lined pits,
locate away from storm water
conveyances
Chapter 5,
P2 Principle 3
Leak proof containers,
locate away from
storm water
conveyances
Properly apply fertilizer
(CGP 2.3.5)
Follow manufacture specifications,
document deviations in applications,
avoid applications to frozen ground,
before heavy rains, or to storm water
conveyances
N/A
Storm Water Pollution Prevention Plan (SWPPP)
Silver Leaf SWPPP
It is important to have in place a regular schedule for site housekeeping and clean up. Construction site debris and trash should be picked up and
disposed of properly by the contractor. Instruct all site personnel including subcontractors to routinely pick up and place trash into approved
receptacles and covered dumpsters.
Examples of construction and domestic waste include packaging materials, scrap construction materials, masonry products, timber, pipe and
electrical cuttings, plastics, styrofoam, concrete, demolition debris; and other trash or building materials. This includes building materials such
as insulation, nails, electrical wiring, shingle, and roofing as well as waste originating from site preparation such as dredging materials, tree
stumps, and rubble. Construction waste may contain lead, asbestos, or other hazardous substances.
List of Pollution Prevention Controls for Spill Control:
Perimeter Controls
Spill Kit
Dumpsters
Concrete Washout
Details and Specifications are found in Appendix H.
15
SECTION 7: SPECIAL CONDITIONS
7.1 Emergency Related Projects
7.2 UIC Class 5 Injection Wells
Class V UIC Wells on site (all must be reported to DWQ for inventory):
Infiltration trenches (if storm water is directed to any shaft or hole that is deeper than its
widest surface dimension or has a subsurface fluid distribution system)
Commercially manufactured pre-cast or pre-built subsurface detention
vault/infiltration system
Drywell, seepage pit, or improved sinkhole (if storm water is directed to any shaft or
hole that is deeper than its widest surface dimension or has a subsurface fluid
distribution system)
UIC Description and specifications are found in Appendix G through the link to
ComplianceGO in the "Documents" section.
YES N/A
YES N/A
Storm Water Pollution Prevention Plan (SWPPP)
Silver Leaf SWPPP
16
7.3 Chemical Treatment
Soil Types
List all the soil types (including soil types expected to be found in fill material) that are
expected to be exposed during construction and that will be discharged to locations where
chemicals will be applied:
Treatment Chemicals
List all treatment chemicals that will be used at the site and explain why these chemicals are
suited to the soil characteristics:
Describe the dosage of all treatment chemicals you will use at the site or the methodology you
will use to determine dosage:
Provide information from any applicable Safety Data Sheets (SDS):
Describe how each of the chemicals will stored:
Include references to applicable state or local requirements affecting the use of treatment
chemicals, and copies of applicable manufacturer’s specifications regarding the use of your
specific treatment chemicals and/or chemical treatment systems:
Special Controls for Cationic Treatment Chemicals​ ​(if applicable)
If you have been authorized by DWQ to use cationic treatment chemicals, identify the specific
controls and implementation procedures you are required to implement to ensure that your use
of cationic treatment chemicals will not lead to a violation of water quality standards or harm
aquatic life:
Schematic Drawings of Storm Water Controls/Chemical Treatment Systems
Provide schematic drawings of any chemically-enhanced storm water controls or chemical
treatment systems to be used for application of treatment chemicals:
Training
Describe the training that personnel who handle and apply chemicals have received prior to
permit coverage, or will receive prior to the use of treatment chemicals:
Storm Water Pollution Prevention Plan (SWPPP)
Silver Leaf SWPPP
YES NO
17
SECTION 8: INSPECTIONS & CORRECTIVE ACTIONS
8.1 Inspections
Inspection Reports are filed in Appendix C
How we obtain our Weather Events data:
Weather Program Information The ComplianceGO weather program is a cutting-edge approach to meeting
Stormwater permit requirements for rain event inspections due to precipitation and forecasts. We are
utilizing the Weather Company data which consists of the following: • 160 different statistically weighted
models • Radar – including many independent radars procured over the years • Satellite • Streaming airline
upper air observations • Weather Underground personal weather stations (200,000+) • Gov’t sensors and
other publicly available sensors The Weather Company ingests over 400 TB of data to provide the most
accurate precise location observations and forecasts across the world! Weather information is at best only
as accurate as the closest sensors to the actual site being monitored. Because the amount of precipitation
can change from one location to another with very short distances apart, the most accurate precipitation
information would be either a weather station on the site or an onsite rain gauge. Flooding conditions can
result from precipitation miles away. Regulatory bodies rely upon weather information provided by weather
stations, such as the Weather Company or NOAA to determine if there was a rain event. On that basis, the
precipitation information provided by ComplianceGO is reliable and can be used to meet regulatory
inquiries. If you receive a notification from ComplianceGO of a rain event for your site, and if you have an
onsite rain gauge that differs from the ComplianceGO information, be sure to enter the rain gauge findings
in the note box on the inspection form and be guided by the actual precipitation shown with the rain gauge.
Whenever you perform an inspection in ComplianceGO, ComplianceGO goes to the Weather Company
source and grabs the current precipitation,showing the amount of precipitation for the past 24 hours. The
historical precipitation shown on the inspection form is a 24-hour precipitation accumulation for the site
for that date.
Standard Frequency:
Once every 7 calendar days.
Once every 14 calendar days and within 24 hours of the end of a storm event of 0.5
inches or greater.
Increased Frequency: Sites discharging to impaired or high quality waters
Once every 7 calendar days and within 24 hours of the end of a storm event of 0.5
inches or greater.
Decreased Frequency: Frozen conditions with work suspended
One inspection every month
Other:
Storm Water Pollution Prevention Plan (SWPPP)
Silver Leaf SWPPP
18
8.2 Corrective Actions
Correction Action Report is filed in Appendix D.
8.3 Delegation of Authority
See the signed delegation of authority forms in Appendix E.
Storm Water Pollution Prevention Plan (SWPPP)
Silver Leaf SWPPP
19
SECTION 9: RECORDKEEPING
9.1 Recordkeeping
Recordkeeping is done electronically through
ComplianceGO
The Construction General Permit is located in Appendix I
The NOI is located in Appendix B
All paperwork kept for 3 years from final stabilization date
9.2 Log of Changes to the SWPPP
An Amendment Log is located on ComplianceGO within the Documents section
Storm Water Pollution Prevention Plan (SWPPP)
Silver Leaf SWPPP
20
SECTION 10: CERTIFICATION
Signed Certification Pages can be found in Appendix E.
Storm Water Pollution Prevention Plan (SWPPP)
Silver Leaf SWPPP
21
SWPPP APPENDICES
Appendix A – Site Maps
Appendix B – NOI
Appendix C – Inspection Reports
Appendix D –Corrective Action Report
Appendix E – Subcontractor Certifications/Agreements/Delegation of
Authority (see CGP 9.16(1)b.)
Appendix F – Training Logs and Certifications (see CGP 6)
Appendix G – Additional Information (i.e., Other permits such as
dewatering, stream alteration, wetland; and out of date
swppp documents)
Appendix H – BMP Instruction and Detail Specifications
Appendix I – Construction General Permit
Storm Water Pollution Prevention Plan (SWPPP)
Silver Leaf SWPPP
Vicinity Map:
Yes No
6toUm WateU 3ollution 3Uevention 3lan 6W333
6ilveU /eaI 6W333
Wetlands:
Are there Wetlands on or surrounding the site?
https://www.fws.gov/wetlands/data/mapper.html
Appendix A: Site Maps
Jacobsen ConstructionErosion Control Map.pdf
Liberty Corner Apartments L E G E N D
Perimeter Control (2)
Drain Inlet Protection (7)
Track out pad (1)
Concrete Washout (1)
Concrete Washout Sign (1)
Dumpster (1)
Toilet (1)
Material Storage (1)
SWPPP Sign (1)
Spill Kit (1)
Storm Water Pollution Prevention Plan (SWPPP)
Silver Leaf SWPPP
Appendix B: NOI
The NOI is located on ComplianceGO in the “Documents” section, link located on title page.
First Name   Middle Initial   Last Name:Brent  Harman
First Name   Middle Initial   Last Name:Reed  Price
First Name   Middle Initial   Last Name:Mykayla  Dickert
Permit Information
Owner/Operator Information
Owner Information
Owner Point of Contact Information
Operator Information
Operator Point of Contact Information
NOI Preparer Information
Project/Site Information
STATE OF UTAH, DEPARTMENT OF ENVIRONMENTAL QUALITY, DIVISION OF WATER QUALITY
195 North 1950 West, P.O Box 144870, Salt Lake City, UT 84114-4870 [phone]
Notice of Intent (NOI) for Storm Water Discharges Associated with Construction
Activity Under the Construction General Permit (CGP) UPDES General Permit
No. UTRC00000 NOI

Master Permit Number: UTRC00000
UPDES ID: UTRC08251
State/Territory to which your project/site is discharging: UT
Is your project/site located on federally recognized Indian Country Lands?No
Which type of form would you like to submit? Notice of Intent (NOI)
Have stormwater discharges from your project/site been covered previously under an UPDES permit? No
Has a Stormwater Pollution Prevention Plan (SWPPP) been prepared in advance of filling this NOI, as required? Yes

Owner: Cowboy Properties
Status of Owner: Private
Owner Mailing Address:
Address Line 1:6440 South Wasatch Blvd. Suite 100
Address Line 2:City:Salt Lake City
ZIP/Postal Code:84121 State:UT
Title:Partner
Phone:[phone] Ext.:
Email:[e-mail]
Is the Operator Information the same as the Owner Information? No
Operator: Jacobsen Construction
Operator Mailing Address:
Address Line 1:5181 West Amelia Earhart Drive
Address Line 2:City:Salt Lake City
ZIP/Postal Code:84116 State:UT
Title:Project Manager
Phone:[phone] Ext.:
Email:[e-mail]
 This NOI is being prepared by someone other than the certifier.
Organization:Silver Leaf SWPPP
Phone:[phone] Ext.:
Email:[e-mail]

Project/Site Name:Liberty Corner Apartments
Project Number:23047
Project/Site Address
Latitude/Longitude for the Project/Site
Proposed Best Management Practices
Proposed Good Housekeeping Practices
Site Construction Types
Site Activity Information
Subdivision Information
Certification Information
Address Line 1:1265 South 300 West
Address Line 2:City:Salt Lake City
ZIP/Postal Code:84101 State:UT
County or Similar Division:Salt Lake
Have you submitted a Fugitive Dust Control Plan to UT Division of Air Quality? Yes
Coordinate System: Decimal Degrees
Latitude/Longitude:40.742085°N, 111.89891°W
Estimated Project Start Date:09/02/2024 Estimated Project End Date:01/08/2027 Total Area of Plot (in Acres):2.05
Estimated Area to be Disturbed (in Acres):2.05
 Silt Fence/Straw Wattle/Perimeter Controls
 Other
ContouringLandscaping
 Sanitary/Portable Toilet
 Washout Areas
 Construction Chemicals/Building Supplies Storage Area
 Garbage/Waste Disposal
 Non-Storm Water
 Track Out Controls
 Spill Control Measures
 Commercial
 Utility
 Contouring, Landscaping

Municipal Separate Storm Sewer System (MS4) Operator Name: Salt Lake City
Receiving Water Body: Jordan River
This is known
What is the estimated distance to the nearest water body?2013.75 Unit:Feet
Is the receiving water designated as impaired? Yes
Will any part of the project area be located within 50 feet of any Water of the State? No
Does this project site have any other UPDES permits? No

Is this project involved in the development of a subdivision? No

I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in accordance with a system designed to assure that qualified personnel properly gathered and evaluated the
information submitted. Based on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the information submitted is, to the best of my knowledge and belief, true,
accurate, and complete. I have no personal knowledge that the information submitted is other than true, accurate, and complete. I am aware that there are significant penalties for submitting false information, including the possibility of
fine and imprisonment for knowing violations. Signing an electronic document on behalf of another person is subject to criminal, civil, administrative, or other lawful action.
Certified By: Reed Price
Certifier Title: Vice President Project Executive
Certifier Email: [e-mail]
Certified On:  02/02/2024 3:25 PM ET
2/5/24, 8:53 AM Authorization Email
about:blank 1/1
STATE OF UTAH, DEPARTMENT OF ENVIRONMENTAL QUALITY, DIVISION OF
WATER QUALITY
195 North 1950 West, P.O. Box 144870 Salt Lake City, Utah 84114-4870 (801)-536-4300
Authorization to Discharge under the
Construction General Permit (CGP)
for Storm Water Discharges
Associated with Construction
Activity
CGP
The Utah Division of Water Quality (DWQ) is in receipt of the Notice of Intent (NOI)
requesting coverage for Liberty Corner Apartments, 1265 South 300 West, Salt Lake City, UT
84101 under the Construction General Permit for Storm Water Discharges (CGP). As of
02/05/2024, this facility is authorized to discharge storm water, provided that all discharges are
in compliance with the requirements of the current CGP. This includes development and
implementation of a storm water pollution prevention plan, conducting self-inspections,
training, visual assessments of discharges, and potentially analytical monitoring. Please keep a
copy of this Authorization to Discharge on site with your NOI.
An annual fee is required each calendar year to maintain coverage. If the fee is paid and the
facility complies with the permit terms, then the coverage will remain effective until
02/04/2025. At that time the NOI will need to be re-certified and a new Authorization to
Discharge will be issued.
Your electronic signature on the NOI form certifies that you have read, understood, and are
implementing all of the applicable requirements. An important aspect of this certification
requires that you have correctly determined whether you are eligible for coverage under this
permit. This authorization does not represent a determination by DWQ regarding the validity
of the information provided on the NOI. A copy of the NOI submission can be downloaded at
this link: https://npdes-ereporting.epa.gov/net-cgp/api/public/v1/form/1805757/attachment/zip.
Site Details
UPDES Permit Number: UTRC08251
Project/Site Name: Liberty Corner Apartments
Project/Site Address: 1265 South 300 West, Salt Lake City, UT 84101
Effective Date: 02/05/2024
Expiration Date: 02/04/2025
Salt Lake City Department of Public Utilities
Storm Water Division
1530 S. West Temple
Salt Lake City, Utah 84115

Stormwater Discharge Permit for Construction Activities
Notice of Intent
Date Received (internal SLCDPU only):
Permit No. (PUT#) (internal SLCDPU only):

I. OWNER INFORMATION:
Name (Owner): Phone:
Address:
City: State: Zip:
Contact Person: Phone:
Email:
OPERATOR INFORMATION:
Name (Operator): Phone:
Address:
City: State: Zip:
Contact Person: Phone:
Email:
*If you have more co-permittees than space allows on this form, please use back of page.
II. SITE INFORMATION:
Name (Facility/Project):
Address:
City: State: Zip:
Site Contact Person: Phone:
Email:
III. SWPPP COORDINATOR:
Name of the contact person responsible for overseeing implementation and coordination of the
SWPPP on behalf of the Owner/Operator if different from the Owner/Operator contact:
Name: Company: Phone:
Address:
City: State: Zip:
Email:
1

Version Date: July 1, 2022
ALL NECESSARY INFORMATION MUST BE PROVIDED ON THIS FORM
Notice of Intent (NOI) for Storm Water Discharges Associated with Construction Activities Under the Salt Lake City Multiple Separate Storm Sewer
System (MS4) UPDES Permit UTS000002 with a land disturbance of greater than or equal to one acre, including projects less than one acre that are part
of a larger common plan of development or sale, including projects less than one acre that are located in a sensitive or high-profile area.

Storm Water Pollution Prevention Plan SWPPP requirements can be found in the UPDES Construction General Permit (U-CGP). A copy of the
UPDES permit may be downloaded from the internet at https://deq.utah.gov/water-quality/general-construction-storm-water-updes-permits.

Submission of this Notice of Intent constitutes the understanding that the party(s) identified in Section I of this form intends to be authorized under Salt
Lake City’s Storm Water Discharges Construction Activities permit (SW# ). Becoming a Permittee obligates such discharger to comply with
all the terms and conditions of Salt Lake City’s Storm Water Ordinance Title 17.84 and the State of Utah (UPDES) Construction General Permit,
regardless of state permit coverage status, in addition to annual inspections and maintenance of post construction BMPs.

Ground disturbing and construction activities shall not commence until: (1) the Owner/Operator have received a SLC Construction Activities
Permit (PUT#), (2) Best Management Practices (BMPs) have been installed per the approved SWPPP, (3) a SWPPP Pre-Construction meeting
with the SLCDPU Stormwater Quality Team has been completed, and (4) an initial inspection of the site’s installed BMPs has been completed
which demonstrates full compliance with the project’s SWPPP. To schedule the Pre-Construction Meeting and Initial Inspection, please contact
the SLCDPU Stormwater Quality team at [e-mail].

All fields must be legibly filled out in type or print in black/blue ink
(refer to pages 3, 4, and 5 for details and instructions)
Cowboy Properties 801-424-4412
6440 South Wasatch Blvd. Suite 100
Salt Lake City UT 84121
Brent Harman 801-424-4412
[e-mail]
Jacobsen Construction 801-573-1817
5181 West Amelia Earhart Drive
Salt Lake City UT 84116
Reed Price 801-573-1817
[e-mail]
Liberty Corner Apartments
1265 South 300 West
Salt Lake City UT 84101
Reed Price 801-573-1817
[e-mail]
Salt Lake City Department of Public Utilities
Storm Water Division
1530 S. West Temple
Salt Lake City, Utah 84115
2

IV. TYPE OF CONSTRUCTION
Identify the type of construction (check all that apply): ☐ Residential ☐ Commercial ☐ Industrial ☐ Road ☐ Bridge ☐ Utility ☐ Contouring, Landscaping ☐ Other

V. BEST MANAGEMENT PRACTICES
Identify the best management practices (BMPs) proposed for the site and date of implementation: ☐ Silt Fences/Other ☐ Inlet protection ☐ Track out ☐ Sweeping ☐ Sediment ponds ☐ Berms/ditches ☐ Mulching/Geotextiles ☐ Seeding/preservation of vegetation ☐ Other:
Date of implementation:

VI. ESTIMATED DATES OF CONSTRUCTION & AREA OF DISTURBANCE:
Start Date:
Estimated Completion Date:
Estimated area to be disturbed (in acres):

VII. STORM WATER POLLUTION PREVENTION PLAN: A storm water pollution prevention
plan (SWPPP) is required to be developed, submitted, and approved before the NOI will be issued.

Storm Water Pollution Prevention Plan SWPPP requirements can be found in the UPDES
Construction General Permit for Construction Activities (U-CGP). A copy of the UPDES permit
document may be downloaded from the internet at: https://documents.deq.utah.gov/water-
quality/stormwater/construction/DWQ-2020-013890.pdf.

Additionally, a SWPPP template has been provided by the state of Utah (DWQ) which meets the
requirements of the U-CGP: https://documents.deq.utah.gov/water-quality/permits/updes/DWQ-
2021-002832.docx.
☐ SWPPP on file with SLCDPU
VIII. RECEIVING WATERS OF THE STATE:
Identify the Waters of the State of Utah identified under Salt Lake City’s MS4 permit that receive
storm water discharges near the Construction activities site: ☐ Emigration Creek ☐ Parley’s Creek ☐ City Creek ☐ Jordan River ☐ Red Butte Creek ☐ Other:
Approximate distance from receiving water identified:

IX. CERTIFICATION
I certify under penalty of law that I am duly authorized to sign this NOI, and that I have read and
understand the Part 1 eligibility requirements for coverage under the U-CGP for storm water
discharges from construction activities. I further certify that to the best of my knowledge, all
discharges and BMPs that have been scheduled and detailed in a storm water pollution
prevention plan will satisfy requirements of this permit. I understand that continued coverage
under this permit is contingent upon maintaining eligibility as provided herein.
n
n n
n n n
TBD
9/2/24
1/8/27
2.05
n
2013.75 ft
Salt Lake City Department of Public Utilities
Storm Water Division
1530 S. West Temple
Salt Lake City, Utah 84115
3

I certify under penalty of law that this document and all attachments were prepared under the
direction or supervision of those who have placed their signature(s) below, in accordance with a
system designed to assure that qualified personnel properly gather and evaluate the information
submitted. Based on my inquiry of the person or persons who manage the system, or those
persons directly responsible for gathering the information, the information submitted is, to the
best of my knowledge and belief, true, accurate, and complete. I am aware that there are
significant penalties for submitting false information, including the possibility of fine and
imprisonment for knowing violations.

Owner: (print name and signature of responsible person for the Permittee from first page)
Printed Name:
Signature:
Date:

Operator/Contractor: (print name and signature of the Operator from first page)
Printed Name:
Signature:
Date:

Fee: Amount of Permit Fee Enclosed: $

Who must file for a Notice of Intent (NOI) form?

(a) Owner: The party that owns/leases the land on which the construction activities
occur and has ultimate control over the project; OR
(b) Operator: The party that has the day-to-day operational control of the project and
site activities and ensures compliance with this permit.

Where to file Notice of Intent (NOI) form:
If submitting electronically, submit the NOI form to [e-mail]
If submitting hardcopy, the NOI form with application fee must be sent to the following address:

Salt Lake City Corporation
Department of Public Utilities
Attention: SLCDPU Contracts Office
1530 South West Temple
Salt Lake City, UT 84115
Permit Application Fees: $125
MAKE CHECKS PAYABLE TO: Salt Lake City Department of Public Utilities

Initial Inspection Fee: $110.00
Inspection/Re-Inspection Fee: $30.00
Liberty Corner Associates, LLC by its manager Cowboy Partners by Brent M. Harman (Feb 2, 2024 16:31 MST)
Liberty Corner Associates, LLC by its manager Cowboy Partners by Brent M. Harman
Feb 2, 2024
eed Price (Feb 2, 2024 1ц:21 MST)
Reed Price
eed Price
Feb 2, 2024
Salt Lake City Department of Public Utilities
Storm Water Division
1530 S. West Temple
Salt Lake City, Utah 84115
4

Beginning of coverage:
Coverage under the SLC Storm Water Discharge Permit for Construction Activities is
immediate after a Public Utilities Permit (PUT number) is issued, application fees are paid,
and this NOI is signed and included in the project’s SWPPP, at which time this completed
NOI form becomes your Salt Lake Storm Water Discharge Permit for Construction
Activities.

Ground disturbing and construction activities shall not commence until:

(1) the Owner/Operator have received a SLC Storm Water Construction Activities Permit
Number (PUT#),

(2) Best Management Practices (BMPs) have been installed per the approved SWPPP,

(3) a SWPPP Pre-Construction meeting with the SLCDPU Stormwater Quality Team has
been completed, and

(4) an initial inspection of the site’s installed BMPs has been completed which
demonstrates full compliance with the project’s SWPPP.

To schedule the Pre-Construction Meeting and Initial Inspection, please contact the
SLCDPU Stormwater Quality team at [e-mail].

A copy of the SWPPP, U-CGP, State NOI and this Permit shall remain on
site throughout the course of the project.

Duty to Comply:
By accepting this Permit the Permittee(s) must comply with all conditions of the UCGP
and this Permit. Any Permit noncompliance constitutes a violation and is grounds for
escalating enforcement including but not limited to penalties, permit termination,
revocation, or denial for permit renewal.

Inspections will be performed throughout the duration of the project. Fees and penalties
may be assessed for permit/ordinance violations. See Attachments 1 and 2.

Notice of Termination (NOT):
Upon completion of construction activities, the site must be stabilized (see the U-CGP for
final stabilization requirements) and post-construction BMPs installed according to the
stamped engineering plans.

The NOT form must be completely filled out, all fees and penalties must be paid, all
temporary BMPs must be removed and a final site inspection scheduled with the City
SWPPP inspector must be completed before A Certificate of Occupancy (C/O) is released.

Penalties for Violations of Permit Conditions:
Penalties will be determined using the:
• Single Event Violation Codes (refer to Attachment 1)
• Utah Water Quality Act Civil Penalty Determination Chart (refer to Attachment 2)
Salt Lake City Department of Public Utilities
Storm Water Division
1530 S. West Temple
Salt Lake City, Utah 84115
5

Instruction for filling out the NOI

SECTION I - FACILITY OPERATOR INFORMATION
The Owner is typically the property owner, developer or business owner. This section must
be completely filled out with the legal name(s) of the person(s), firms(s), public or
organization(s) that is responsible for the construction activity being performed.

The Operator is typically the general contractor responsible for day to day site operations
including the implementation of the SWPPP, and coordination with the inspector(s).

SECTION II - FACILITY/SITE LOCATION INFORMATION
Enter the official or legal name and project number (if any) and complete street address,
including city, state and ZIP code. If the facility or site lacks a street address, indicate the
approximate location providing the nearest cross street address.

SECTION III - TYPE OF CONSTRUCTION
Check each type of construction that applies to this application.

SECTION IV – BEST MANAGEMENT PRACTICES
Check each type of BMP that will be used to control storm water runoff at the job site.

SECTION V - ADDITIONAL INFORMATION REQUIRED
Enter the project start date and the estimated completion date for the entire development
plan. Provide an estimate of the total area on which soil will be disturbed (round to the
nearest acre).

SECTION VI - CERTIFICATION
State statutes provide for severe penalties for submitting false information on this
application form. City ordinance requires this application to be signed as follows:

For a corporation: by a responsible corporate officer, which means: (i) president, secretary,
treasurer, or vice-president of the corporation in charge of a principal business function, or
any other person who performs similar policy or decision making functions, or (ii) the
manager of one or more manufacturing, production, or operating facilities employing more
than 250 persons or having gross annual sales or expenditures exceeding $25 million, if
authority to sign documents has been assigned or delegated to the manager in accordance
with corporate procedures;

For a partnership or sole proprietorship: by a general partner or the proprietor; or

For a municipality, state, federal, or other public facility: by either a principal executive
officer or ranking elected official.
EXPEDITED FINE SCHEDULE – Construction
SWPPP = Stormwater Pollution Prevention Plan
RIGHT OF DISPUTE DISCLAIMER: Responsible parties desiring to dispute any fines issued for
violations enumerated on this document, must submit a written request to the Stormwater Quality
Program Manager by emailing [e-mail].
6

SEV # PERMIT COVERAGE 1st
Offense
2nd
Offense
3rd
Offense
Penalties after
3rd Offense

1
Operator unpermitted for
months (# months
unpermitted equals number of
violations)

$400.00 per month unpermitted

SWPPP REVIEW

2
SWPPP not prepared (If no
SWPPP, leave elements 3 - 24
blank and put "1" for deficiencies)

$3,000.00

$6,000.00

$9,000.00
SLC
Ordinance
17.87

3
SWPPP prepared but prepared
after construction start (# of
months = # of violations)
$200.00 per month without
SWPPP prepared

4
SWPPP does not list and identify
all potential sources of pollution to
include: portable toilet, fuel tanks,
egress points, staging areas,
waste containers, chemical
storage areas, concrete washout, paints, solvents, etc.

$75.00

$150.00

$225.00

SLC
Ordinance
17.87

5
SWPPP does not identify all
owner and general contractor for
the project site

$50.00

$100.00

$150.00
SLC
Ordinance
17.87
SWPPP does not have site
description, as follows (6-10):

6 Nature of activity in description
(including disturbed & total acres)

$40.00

$80.00

$120.00
SLC
Ordinance
17.87

7 Intended sequence of major
activities

$40.00

$80.00

$120.00
SLC
Ordinance
17.87

8

Site Map

$400.00

$800.00

$1200.00
SLC
Ordinance
17.87

9
Site map does not show
boundaries of project &
disturbances, drainage patterns,
slopes, stockpiles, surface
waters, inlets, egress points,
storm water control measures,
natural buffers, structures (to be
constructed), stabilization
practices, offsite staging, waste
bins, equipment storage areas,
discharge points, areas of final
stabilization (each relevant
omission is 1 violation)

$25.00

$50.00

$75.00

SLC
Ordinance
17.87
EXPEDITED FINE SCHEDULE – Construction
SWPPP = Stormwater Pollution Prevention Plan
RIGHT OF DISPUTE DISCLAIMER: Responsible parties desiring to dispute any fines issued for
violations enumerated on this document, must submit a written request to the Stormwater Quality
Program Manager by emailing [e-mail].
7

SEV #

PERMIT COVERAGE

1st Offense

2nd Offense

3rd Offense Penalties
after 3rd
Offense

10
SWPPP does not have
location/description industrial
activities including concrete,
asphalt batch plants, staging
areas, equipment or supply
storage, borrow areas (including
those that are off-site).

$75.00

$150.00

$225.00

SLC
Ordinance
17.87

11
SWPPP does not describe all
pollution control measures (e.g.
BMPs), and show details and
specifications for proper
installation. (include 0.5 for
description and 0.5 for details &
specifications for each BMP not
provided in SWPPP).

$75.00

$150.00

$225.00

SLC
Ordinance
17.87

12
SWPPP does not describe
permanent and interim
stabilization practices

$75.00

$150.00

$225.00
SLC
Ordinance
17.87

13
SWPPP does not identify and
show locations of the source of
non-storm water discharge.

$100.00

$200.00

$300.00
SLC
Ordinance
17.87

14
SWPPP does not describe and
show locations of natural buffer
by water body(ies).

$150.00

$300.00

$450.00
SLC
Ordinance
17.87

15 SWPPP does not describe the
use of treatment chemicals

$100.00

$200.00

$300.00 SLC
Ordinance
17.87

16
SWPPP does not have
description of spill prevention
and response procedures.

$50.00

$100.00

$150.00
SLC
Ordinance
17.87

17
SWPPP does not have a
description of measures that will
be used to control waste on the
site including: demolition debris,
spoils (unwanted dirt),
construction waste, hazardous or
toxic waste, and sanitary waste.
(include 1 for each deficiency).

$50.00

$100.00

$150.00

SLC
Ordinance
17.87

18
SWPPP does not describe
inspection procedures including
inspectors (and certifications),
inspection schedules, inspection
forms or checklists, and
procedures for corrective action.
(1 violation for each deficiency).

$50.00

$100.00

$150.00

SLC
Ordinance
17.87
EXPEDITED FINE SCHEDULE – Construction
SWPPP = Stormwater Pollution Prevention Plan
RIGHT OF DISPUTE DISCLAIMER: Responsible parties desiring to dispute any fines issued for
violations enumerated on this document, must submit a written request to the Stormwater Quality
Program Manager by emailing [e-mail].
8

SEV #

PERMIT COVERAGE

1st Offense

2nd Offense

3rd Offense

Penalties
after 3rd
Offense

19
SWPPP does not describe
training of personnel responsible
for conducting inspections, taking
corrective action, applying or
storing treatment chemicals, and
those involved with design;
installation; maintenance; and
repair of storm water control
measures.

$100.00

$200.00

$300.00

SLC
Ordinance
17.87

20
Copy of permit and/or NOI not
in SWPPP (each omission is 1
violation)

$50.00

$100.00

$150.00
SLC
Ordinance
17.87

21
SWPPP has not been updated
to match corrections and
modifications made on the site.

$100.00

$200.00

$300.00
SLC
Ordinance
17.87

22

Copy of SWPPP not retained on
site

$300.00

$600.00

$900.00

SLC
Ordinance
17.87

23 A SWPPP not made available
upon request

$100.00

$200.00

$300.00
SLC
Ordinance
17.87

24 SWPPP not signed/certified
$50.00

$100.00

$150.00 SLC Ordinance
17.87
EXPEDITED FINE SCHEDULE – Construction
SWPPP = Stormwater Pollution Prevention Plan
RIGHT OF DISPUTE DISCLAIMER: Responsible parties desiring to dispute any fines issued for
violations enumerated on this document, must submit a written request to the Stormwater Quality
Program Manager by emailing [e-mail].
9

SEV #

PERMIT COVERAGE

1st Offense

2nd Offense

3rd Offense Penalties
after 3rd
Offense
INSPECTIONS

25
Number of inspections not
performed and documented either
once every 7 days, or once every
14 days and within 24 hours after
storm event greater than 0.5
inches (not required if: permanent
stabilization; runoff unlikely due to
winter conditions; once a month if
temp stabilization) Count each
failure to inspect and document
as one violation -- see next 5
rows.

$200.00

$400.00

$600.00

SLC Ordinance
17.87
No inspections conducted and
documented (if true leave
elements 26 to 29 blank):

True or False

Number of inspections
expected if performed every 7 days:

(multiplier)

(multiplier)

(multiplier) SLC Ordinance
17.87
Number of inspections expected
if performed biweekly:

(multiplier)

(multiplier)

(multiplier) SLC Ordinance
17.87
If known, number of days of
rainfall of >0.5" that occurred during the construction time: _

(multiplier)

(multiplier)

(multiplier) SLC Ordinance
17.87
26 Inspections not conducted by
qualified personnel $40.00 $80.00 $120.00 SLC Ordinance
17.87

27
All areas with construction activity
disturbance, storm water control
measures, construction support
areas, exposed to precipitation
with storm water flows,
temporarily stabilized areas, and
storm water discharge points not inspected.

$40.00

$80.00

$120.00

SLC
Ordinance
17.87

28
Incomplete site inspection reports
(date, name and qualifications of
inspector, weather information,
location of sediment/pollutant
discharge, BMP(s) requiring
maintenance, BMP(s) that have
failed, BMP(s) that are needed,
corrective action required
including changes/updates to SWMP and schedule/dates).

$40.00

$80.00

$120.00

SLC
Ordinance
17.87

29
Inspection reports not properly
signed/certified (count each
failure to sign/certify as 1
violation)

$25.00

$50.00

$75.00
SLC
Ordinance
17.87
EXPEDITED FINE SCHEDULE – Construction
SWPPP = Stormwater Pollution Prevention Plan
RIGHT OF DISPUTE DISCLAIMER: Responsible parties desiring to dispute any fines issued for
violations enumerated on this document, must submit a written request to the Stormwater Quality
Program Manager by emailing [e-mail].
10

SEV #

PERMIT COVERAGE

1st Offense

2nd Offense

3rd Offense Penalties
after 3rd
Offense
AVAILABILITY OF RECORDS
30 Sign/notice not posted $100.00 $200.00 $300.00 SLC Ordinance
17.87
31 Does not contain copy of
complete NOI $40.00 $80.00 $120.00 SLC Ordinance
17.87
32 Contact information on site
sign/notice was not available. $40.00 $80.00 $120.00 SLC Ordinance
17.87
BEST MANAGEMENT
PRACTICES

33
No velocity dissipation devices
located at discharge locations or
outfall channels to ensure non-
erosive flow to receiving water.

$100.00

$200.00

$300.00

SLC Ordinance
17.87

34
Control measures are not
properly:
Selected, installed and
maintained

$100.00

$200.00

$300.00

SLC Ordinance
17.87

35
Maintenance not performed
regular enough to maintain
effectiveness of BMPs (count
each failure to select,
install, maintain each BMP as
one violation)

$100.00

$200.00

$300.00

SLC Ordinance
17.87

36
When sediment escapes the site
from track out or bypassing
BMPs, it is not removed at a
frequency necessary to minimize
off-site impacts.

$100.00

$200.00

$300.00

SLC Ordinance
17.87

37
Natural vegetated buffer is not
present adjacent to bordering
water bodies (or substituted
equivalent BMPs).

$100.00

$200.00

$300.00

SLC Ordinance
17.87

38
Litter, construction debris, and
construction chemicals exposed
to storm water are not
prevented from becoming a
pollutant source.

$100.00

$200.00

$300.00

SLC Ordinance
17.87
EXPEDITED FINE SCHEDULE – Construction
SWPPP = Stormwater Pollution Prevention Plan
RIGHT OF DISPUTE DISCLAIMER: Responsible parties desiring to dispute any fines issued for
violations enumerated on this document, must submit a written request to the Stormwater Quality
Program Manager by emailing [e-mail].
11

SEV # PERMIT COVERAGE 1st
Offense
2nd
Offense
3rd
Offense
Penalties after 3rd
Offense

39
Stabilization measures are not
initiated as soon as practical on
portions of the site where
construction activities have
temporarily or permanently
ceased within 14 days after such cessation.

$500.00

$1000.00

$1500.00

SLC
Ordinance
17.87 *EXCEPTIONS:
(a) Snow or frozen ground
conditions.
(b) Activities will be resumed
within 14 days.
(c) Arid or Semi-arid areas (<20
inches per year).

40
Common Drainage not having a
sedimentation basin for the 2-
year, 24-hour storm, or 3600
cubic ft. storage per acre drained.

$100.00

$200.00

$300.00

SLC Ordinance
17.87

41
Where sedimentation basin not
attainable, smaller sediment
basins, sediment traps, or
erosion controls not implemented
for downslope boundaries.

$100.00

$200.00

$300.00

SLC
Ordinance
17.87

42
Sediment not removed from
sediment basin or traps when
design capacity reduced by 50% or more.

$100.00

$200.00

$300.00
SLC
Ordinance
17.87

43
Common Drainage does not have
sediment traps, silt fences,
vegetative buffer strips, or
equivalent sediment controls for
all down slope boundaries (not
required if sedimentation basin meeting criteria in 37, above).

$100.00

$200.00

$300.00

SLC
Ordinance
17.87
ADDITIONAL FACTORS
44 Is the project over 30 acres? (Yes or No) ADD 15% TO PENALTY
45 Is the project over 100 acres? (Yes or No) ADD 50% TO
PENALTY
46 Does the project border on a water body? (Yes or No) ADD 20% TO
PENALTY
47 Significant Economic Benefit? (Yes or No) ADD 20% TO
PENALTY
12

Determine penalty amount
within selected category using
the following criteria:
A. History of compliance
or n on -complian ce
(33.3%)
B. Degree or willfulness
or negligenc e (33.3% )
C. Good faith efforts to comply and cooperation (33.3%)

Utah Water Quality Act
Civil Penalty Determination
UAC R317-1.9

Yes

No

Yes Category “A” $7,000 -$10,000/day

No

Yes

No

Yes

No
Category “B ” $2,000 - $7,000/day

Yes

No

Yes

No

Yes Category “C” $500 - $2,000/day

Category “D”
No $0 - 500/day (Minor violations)
Was there a signifant quantity or concentration of non- toxic or non- hazardous material?
Adjustments: Add to the above
penalty amount the following:
Multiply pe nalty by number of
days violation occurred

A. Economic benefit of
non- compliance

Was there substantial non-compliance of
requirements?
C. Documented costs associated with environmental damage
Penalty amount
associated with violation

Did the
violation result in documented public health effect?
B. Investigative and
other costs

Was there significant environmental damage?

Did the
violation result in a serious hazard to public health or environment?

Was there a signficant quantity or concentration of toxic or hazardous material?

Was there a signficant violation of the permit effluent limitations?
Appendix C: Inspection Reports
Storm Water Pollution Prevention Plan (SWPPP)
Silver Leaf SWPPP
Inspection reports are located on ComplianceGO in the “Reports” section, link located on title page.
Appendix D: Corrective Action Report
Storm Water Pollution Prevention Plan (SWPPP)
Silver Leaf SWPPP
Corrective Action Reports are located on ComplianceGO in the “Reports” section, link located on
title page.
Storm Water Pollution Prevention Plan (SWPPP)
Silver Leaf SWPPP
Appendix E: Subcontractor Certifications/Agreements/Delegation of
Authority (CGP 9.16.1b.)
All Signed SWPPP Documents are located on ComplianceGO in the Documents” section, link
located on title page.
Delegation of Authority
I, , hereby designate the person or specifically described position
below to be a duly authorized representative for the purpose of overseeing compliance with
environmental requirements, including the UPDES “General Permit for StormWater Discharges
Associated with Construction Activity” (Construction General Permit), at the Liberty Corner
Apartments construction site. The designee is authorized to sign any reports, stormwater pollution
prevention plans and all other documents required by the permit.
Our company is hereby designating Jacobsen Construction as duly authorized representatives
responsible for:
● Overseeing sub-contractors (such as earthwork contractors, framers, landscaping crew, concrete
contractors, asphalt contractors, stucco / painters, etc.)
● Managing Concrete Washout and providing adequate bins.
● Manage trash and debris on site (good housekeeping).
● Provide adequate Dumpsters for waste and construction site debris.
● Securing portable toilets 10’ or more from the curb.
● Trackout controls and designated construction exit points.
We are also designating Stormwater Compliance Specialists with Silver Leaf SWPPP as duly authorized
representatives with a scope of work including:
● Engineered SWPPP
● Prepare SWPPP related permits
● Providing Signage for NOI, Site Notice, Concrete Washout
● Inspections (including rain events).
●Installation and Maintenance of Inlet Protection
●Installation and Maintenance of Perimeter Controls (Fiber
rolls and/or Silt fence).
By signing this authorization, I confirm that I meet the requirements to make such a designation as set
forth in Part 9.16 of the CGP, and that the designee above meets the definition of a “duly authorized
representative” as set forth in Part 9.16 of the CGP. I certify under penalty of law that this document and
all attachments were prepared under my direction or supervision in accordance with a system designed
to assure that qualified personnel properly gathered
and evaluated the information submitted. Based on my inquiry of the person or persons who manage the
system, or those persons directly responsible for gathering the information, the information submitted is,to
the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant
penalties for submitting false information, including the possibility of fine and imprisonment for knowing
violations.
Name:
Company:
Title:
Signature:
Date:
Liberty Corner Associates, LLC by its manager Cowboy Partners by Brent M. Harman (Feb 2, 2024 16:31 MST)
Liberty Corner Associates, LLC by its manager Cowboy Partners by Brent M. Harman
Liberty Corner Associates, LLC
Development Partner, Vice President
Feb 2, 2024
Liberty Corner Associates, LLC by its manager Cowboy Partners by Brent M. Harman
SECTION 10: CERTIFICATION
Owner
I certify under penalty of law that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gathered and evaluated the information submitted. Based on my inquiry of the person
or persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true, accurate,
and complete. I am aware that there are significant penalties for submitting false information,
including the possibility of fine and imprisonment for knowing violations.
Operator
I certify under penalty of law that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gathered and evaluated the information submitted. Based on my inquiry of the person
or persons who manage the system, or those persons directly responsible for gathering the
information, the information submitted is, to the best of my knowledge and belief, true, accurate,
and complete. I am aware that there are significant penalties for submitting false information,
including the possibility of fine and imprisonment for knowing violations.
Name: ___________________________Title: ___________________________
Signature: ________________________Date: ___________________________
Name: ___________________________Title: ___________________________
Signature: ________________________Date: ___________________________
Liberty Corner Associates, LLC by its manager Cowboy Partners by Brent M. Harman (Feb 2, 2024 16:31 MST)
Liberty Corner Associates, LLC by its manager Cowboy Partners by Brent M. Harman Development Partner, Vice President
Feb 2, 2024
eed Price (Feb 2, 2024 1ц:21 MST)
Reed Price Feb 2, 2024
Vice President Ҋ Pro%ect 3ec0tiveeed Price
Storm Water Pollution Prevention Plan (SWPPP)
Silver Leaf SWPPP
Appendix F: Training Logs and Certifications (see CGP 6)
Inspector certifications are located through this link:
https://drive.google.com/drive/folders/1UvTVywEbZVX0pjehNaWMzHyvCv_eJXey
Training logs are located on ComplianceGO in the “Documents” Section, link located on title page.
Appendix G: Additional Information
Storm Water Pollution Prevention Plan (SWPPP)
Silver Leaf SWPPP
Additional information can be found on the ComplianceGO site, link located on title page.
F ugitive Dust
2/5/2024 8:45:46 AM
Introduction
Please complete the following information in order to create a Fugitive D ust Application for your
pro ject.  You will have a chance to review the plan prior to nal s ubmission.
Introduction
A Fu gitive Dust Con trol Plan is requ ired if you r project is 1/4 acre or larger an d located in
Cache, Box Elder, Weber, Davis, Salt Lake, Tooele or Utah Cou nty. Other areas and
con dition s are option al.  Please complete the form to assess your project.
Project Location
Projec t Loc ation
A Fu gitive Dust Con trol Plan is requ ired if you r project is 1/4 acre or larger an d located in
Cache, Box Elder, Weber, Davis, Salt Lake, Tooele or Utah Cou nty. Other areas and
con dition s are option al.
Select th e Coun ty where you r project will be located :Salt Lake
Utah Administrative Code (UAC) 307-309-6 re quire s that any person owning or ope rating
a source of fugitive dust within PM10 and PM2.5 non-attainment and maintenance plan
are as on cle ared land grea te r than 1/4 acre in size m ust submit a completed Fugitive Dust
Control Plan. The DAQ Tempora ry Relocation Form re quire s the submission of a Fugitive
Dust Control Plan Permit Num ber for a ll temporary re location proje cts.
Is th is project a temporary relocation project?:
Yes
No
N on-A ttainment Dust Tutorial
W hat is Fugitive D ust?
Fugitive dust is dust that is stirr ed up, creating an air quality pro blem. It is made up of ne
particles called particulate matter. It is a health concern because it ir r itates eyes and nas al tissue
and seriously impacts the r espir ator y system.
x
Fugitive dust may come from gravel o per ations,
construction or demolition activities, land clear ing and
exposed sur faces, r oadways, and mining activities.
Tracko ut fr om muddy work areas also create fugitive
dust when the mud dries.
How We Measu re Compliance-Opac ity
Opacity is the
amount of light
that is blo cked
by something
else such as
smoke or a
tinted window.
The percentage
of opacity can
pro vide a measur e of the par ticulate matter in the air .
Opacity is meas ur ed as a percentage - 0% means that all light passes thr ough; 100% means that
no light can pass through. The more particles pr esent, the higher the opacity percentage.
Utah Fugitive Dust Ru le R307-309-5
Non -a tta in m e nt D u st Ru le
Acknowledgements::
I acknowledge that Utah regulation R307-309-5(1)(a) pro hibits fugitive dust to exceed 10%
opacity at the pr operty boundar y;
I acknowledge that Utah regulation R307-309-5(1)(b) prohibits fugitive dust to exceed 20%
opacity on s ite;
I acknowledge that Utah regulation R307-309-5(3) exempts the opacity requirements abo ve,
ONLY when wind speed exceeds 25 miles per hour AND fugitive dus t controls are maintained. The
online fugitive dust contr ol plan r equir es selection of appropriate contr ol measures that must be
implemented for this exemption to apply; and
I acknowledge that failure to comply with fugitive dust rules may r esult in compliance action
and penalties up to $10,000 per violation/day.
Applicant Inform ation
Applican t Type::Pr ime Contractor
Plan Certicate Number:C8B648FFBF
Name:Jacobsen Constr uction
x
x
x
x
Mailing Address
Mailin g Address - Address Line 1:5181 West Amelia Earhar t Drive
Mailin g Address - Address Line 2:
Mailin g Address - City:Salt Lake City
Mailin g Address - State:Utah
Mailin g Address - Zip:84116
Email:r [e-mail]
Ph one:[phone]
Project Inform a tion
Project Name:Liber ty Corner Apartments
Project End Date:1/8/27
Pr oject L ocation
Address Lin e 1:1265 South 300 Wes t
Address Lin e 2:
City:Salt Lake City
State:Utah
Zip:84101
Site Direction s:1265 South 300 West
County:Salt Lake
Acreage:2.05
Calcu lated Acreage:2.1
La titude/L ongitude Verication
For Ma nu a l La titu d e a nd Lon gitu de in p u t: 
Ma ke su r e to in clu de a t lea st 6 d igits a fter th e d e cim al a n d it m u st fa ll w ith in th e
sta te of Uta h .
E xa m p le 40.404976 or 40.404976232
Latitude (Decimals Only) :40.742085
Lon gitu de (Decimals Only) :-111.89891
Map Ver ic ation
Copy the following URL into your br owser so you can verify on a map that the pr oject latitude and
longitude you pr ovided ar e co rrect.
Map Calcu lation :https://www.google.com/maps/place/40.742085,-111.89891
Latitu de/Lon gitu de verication :
The above Latitude and Longitude have been veried.
Point of Contact
Point of Contact for du st c ontrol matters and to wh om a COMPLIANCE ACTION
sh ou ld be sen t if n ecessary.
Name:Reed Pr ice
Compan y:Jacobsen Cons truction
Addr ess
Address Lin e 1:5181 Wes t Amelia Ear hart Dr ive
Address Lin e 2:
City:Salt Lake City
State:Utah
Zip:84116
Ph one nu mber:[phone]
Cell n umber:
Dust Suppressants
Do you plan on using chemical dust su ppressing or stabilizin g agents?:
Yes
No
Best Manag em ent Practices (BMP) Checklist
Best Man agemen t Practices (BMP) Ch ecklist Instru ctions
Place a check mark next to every activity th at will be con ducted on th is site.  
For each checked activity, complete the corresponding control measures/best management practices (BMP)
selection page.  When completed, we will email the entire plan to you. 
Fu gitive Du st Plan Nu mber:C8A9686DF0
x
x
Select all that apply:
01. Backlling area previously excavated or trenched.
02. Blasting so il and rock - drilling and blasting.
03. Clearing for site pr eparation and vacant land cleanup.
04. Clearing forms, foundations, slab clear ing and cleaning of for ms , foundations and slabs
prior to pour ing concrete.
05. Crushing o f constr uctio n and demolition debr is, rock and soil.
06. Cut and ll soils for site gr ade pr eparation.
07. Demolitio n - Implosive demolition of a structure, using explosives.
08. Demolitio n - mechanical/manual demolitio n o f walls, stucco , concrete, freestanding
str uctures, buildings and o ther str uctur es.
09. Disturbed so il throughout pr oject including between s tructures. THIS ACTIV ITY MUST BE
SELECTED FOR ALL PROJECTS.
10. Disturbed land - long term stabilization and erosion contr ol of large tracts of distur bed
land that will not have continuing activity for mo re than 30 days.
11. Hauling mater ials.
12. P aving/subgr ade preparation fo r paving streets, par king lots, etc.
13. Sawing/cutting mater ial, concrete, asphalt, block or pipe.
14. Screening of rock, soil or cons truction debris.
15. Staging ar eas, equipment stor age, vehicle parking lo ts, and material stor age ar eas.
16. Stockpiles materials (storage), other soils, rock or debris, for future use or export.
17. Tailings piles, ponds and erosion contr ol.
18. Trackout, Pr evention and cleanup of mud, silt and soil tracked out onto paved roads. (THIS
ACTIV ITY MUST BE SELECTED FOR ALL PROJECTS.)
19. Trac - unpaved r outes and par king, constr uctio n related trac on unpaved interior
and/or access r oads and unpaved employee/wo rker parking ar eas.
20. Trenching with track or wheel mounted excavator, shovel, backhoe or trencher .
21. Truck loading with mater ials including constr uction and demolition debr is, rock and soil.
BMP - 09 Disturbed soil throughout project including between
structures.
GENERAL REQUIREMENT: ALL ACTIVITIES MUST MEET OP ACITY REQUIREMENTS IN R307-309-5
MAKE AT LEAST ONE SELECTION FROM EACH SECTION.
Limit disturbance of soils where possible.:
09-01. Limit disturbance of s oils with the use o f fencing, bar r iers, barricades, and/or wind
barrier s.
09-02. Limit vehicle mileage and reduce speed.
x
x
x
Stabilize and maintain stability of all disturbed soil throu ghou t con struction site.:
09-03. Apply water to stabiliz e disturbed so ils . Soil mo isture must be maintained such that
soils can be worked without generating fugitive dus t.
09-04. Apply and maintain a chemical stabilizer.
09-05. Use wind breaks.
09-06. Apply cover (natur al or synthetic).
BMP - 18 Tra ckout, Prevention a nd clea nup of mud, silt a nd
soil tra cked out onto pa ved roa ds.
GENERAL REQUIREMENT: ALL ACTIVITIES MUST MEET OP ACITY REQUIREMENTS IN R307-309-5
MAKE AT LEAST ONE SELECTION FROM EACH SECTION.
Prevent dust from trackou t.:
18-01. Clean tr ackout at the end of the work shift fr om paved sur faces to maintain dust
contro l
18-02. Maintain dust contr ol during wo rking hours and clean tracko ut fr om paved sur faces at
the end of the wor k shift/day.
18-03. Install gravel pad(s), clean, well-gr aded gravel or cr ushed rock. Minimum dimensions
must be 30 feet wide by 3 inches deep, and, at minimum, 50' o r the length of the longest haul
tr uck, whichever is greater. Re-screen, wash or apply additional rock in gravel pad to maintain
eectivenes s .
18-04. Install wheel shaker s. Clean wheel shaker s o n a r egular basis to maintain
eectivenes s .
18-05. Install wheel washers. Maintain wheel was her s o n a r egular basis to maintain
eectivenes s .
18-06. Motoriz ed vehicles will only operate on paved sur faces.
18-07. Install cattle guard before paved road entrance.
All exiting trac mu st be rou ted over selected trackou t con trol device(s).:
18-08. Clearly establish and enforce tr ac patterns to route tr ac over selected tr ackout
contro l device(s).
18-09. Limit site accessibility to ro utes with trackout contro l devices in place by installing
eective barr iers on unprotected routes.
Reviewing Your Pla n
Please carefully review yo ur plan befo re submitting it. Once the plan has
been submitted, it CANNOT be edited.
x
x
x
BEFO RE you submit your plan, if you ne ed to m ake cha nges, navigate back to those
sections via the left navigation or the Previous button to complete those cha nges.
Whe n you are satisfied, submit your plan.
The plan will be available to download in the My Forms section, under the Done
tab.
By s ubmitting this plan I agree to the following terms :
A. I am authorized, on be half of the individual or compa ny liste d in Se ction 1, as
Applicant, to apply for a Fugitive Dust Control Plan and to com m it to a ll of the terms and
conditions of the re que ste d pla n.
B. Construction a ctivities will be limited to lands that the applicant e ithe r owns or is
authorize d to use for construction activitie s.
C. The applica nt a cce pts re sponsibility for assuring that all contractors, subcontractors, and
all othe r pe rsons on the construction site covered by this plan, comply with the terms and
conditions of the Fugitive Dust Control Plan.
D. I unde rstand that any false m ate rial state m ent, re presentation or certification made in
this application may invalidate the plan or ca use me to be subject to e nforcement action
pursuant to Utah Code Ann. 19-2-115.
E. Failure to comply with fugitive dust rules m ay result in compliance action and penalties
up to $10,000 pe r violation/day.
Conrmation of terms:
My plan is r eady to be submitted.
Fr equently As ked Questions
Division of Air Quality
Utah Depar tment of Environmental Quality
Feedback
Div isio n of Air Quality
Address: 195 North 1950 West
P.O. Box 144820
Salt Lake City, UT 84114-482
Contact Phone: [phone]
Contact Fax: [phone]
Frequently Asked Questions
x
Fr equently As ked Questions
Division of Air Quality
Utah Depar tment of Environmental Quality
Feedback
Div isio n of Air Quality
Address: 195 North 1950 West
P.O. Box 144820
Salt Lake City, UT 84114-482
Contact Phone: [phone]
Contact Fax: [phone]
Appendix H: BMP Instruction and Detail Specifications
All BMP Instructions and Detail Specifications are located within the link below:
https://drive.google.com/drive/folders/1csHnxKAa8U1vmDjV6gx_fsYMSmUoyfOK?usp=shari
ng
Storm Water Pollution Prevention Plan (SWPPP)
Silver Leaf SWPPP
Appendix I: Construction General Permit
A link to the Construction General Permit can be found below:

Storm Water Pollution Prevention Plan (SWPPP)
Silver Leaf SWPPP
https://drive.google.com/file/d/1xjpxBgyGHLiWZNEsQMdfENhRmteZPCwP/view
PUBLIC NOTICE
Liberty Corner Apartments Remediation
Formerly known as Schmidt Signs
1229-1265 SOUTH 300 WEST
SALT LAKE CITY, UTAH 84101
UDEQ VOLUNTARY CLEANUP PROGRAM SITE #C125
A 30-day public comment period will run from (DATE TBD) to receive comments on the planned
remediation of the proposed redevelopment of the former Schmidt Sign Company property
located in Salt Lake City, Utah. The development area includes Salt Lake County Parcels
15124580010000, 15124580020000, 15124580030000, 15124580070000, and
15124580110000.
Sampling conducted on the site has identified elevated concentrations of metals and petroleum
hydrocarbons in soil and shallow groundwater at the property. The Voluntary Action Program
(VCP) Applicant (Liberty Corner Associates, LLC) has submitted a Remedial Action Plan (RAP)
in accordance with the Utah Department of Environmental Quality (UDEQ) Voluntary Cleanup
Program. The plan details the removal of metals and petroleum impacted soils exceeding
cleanup goals. Impacted soils removed during these activities will be transported for off-site
disposal, and future management of the Multi-Family development in compliance with UDEQ
approvals. Copies of the RAP may be viewed on line at http://eqedocs.utah.gov and are also
available for review during normal business hours at the following location:
UDEQ/DERR
VCP/Brownfields Section
PO Box 144840195 N. 1950 West
Salt Lake City, UT 84114-4840
[phone]; Mon – Fri 8am-5pm
Liberty Corner, Salt Lake City, Utah September 2024
VCP Site #C125 Version 3
Remedial Action Plan
Project No. 271EM00861 Atlas Technical Consultants LLC

APPENDIX G

UDEQ DERR RAP Comment Letter Dated July 15, 2024, and
UDEQ Email Correspondence Dated August 29, 2024
UDEQ Email Correspondence Dated September 26, 2024

Liberty Corner Response to Comments Page 1
350 South 700 East, B518
Salt Lake City, Utah 84102
Office: 801-935-4917
www.oneatlas.com
July 18, 2024

Mr. Lincoln Grevengoed
Utah Department of Environmental Quality
Division of Environmental Response and Remediation
195 North 1950 West
Salt Lake City, Utah 84114

RE: Response to UDEQ Comments
Remedial Action Plan Dated May 29, 2024
Liberty Corner
1229-1265 South 300 West
Salt Lake City, Utah
VCP Site #125

Dear Mr. Grevengoed:

On May 29, 2024, Atlas Technical Consultants (Atlas) submitted a Remedial Action Plan (RAP) to the Utah
Department of Environmental Quality, Division of Environmental Response and Remediation (DERR) at
the request of Liberty Corner Associates, LLC. Upon review of the RAP, the DERR issued a
correspondence dated July 15, 2024, with general comments and specific comments associated with the
document.

A response to each of the DERR’s comments is include below. Preparation of the revised RAP is under
way and will be submitted to the DERR in the near future.

DERR General Comments

1. Please include a statement in the plan that an environmental professional will be present to observe
the soil underneath the foundations as they are removed. Please also add to the text that the
environmental professional will collect opportunity samples if signs of previously unencountered
contamination are observed. To assist with building demolition, please see the following fact sheet.

Response – A statement will be added to Section 6.0 indicating that an environmental professional will be
present on site during removal of the building foundations just in case previously unencountered signs of
soil impacts are observed.

2. The building on the southeast portion of the Site was not evaluated as it was still serving as a residence
and the DERR and contractor were not able to access the building during site characterization. Please
include a plan to evaluate this area and characterize soils when the building is removed.

Response – A discussion will be added to Section 6.1 describing how the area under the building will be
investigated. Once the building has been removed three test pits will be excavated within the building
footprint. Historical information obtain for the Site indicates that the building was used for commercial office
purposes with no obvious historical manufacturing or auto repair occurring at this location. Therefore, only
the fill material beneath the building will be investigated and samples will be collected from each test pit at
a depth of approximately 2-3 feet below grade. The samples will be submitted a Utah Certified Testing
laboratory for analysis of Volatile Organic Compounds (VOCs) analysis using EPA Method 8260, TPH GRO
and DRO using EPA Method 8015, Polyaromatic Hydrocarbons (PAHs) with Selected Ion Monitoring (SIM)
using EPA Method 8270, Oil & Grease with Silica Gel Treatment (SGT) using EPA Method 9071, and
RCRA 8 metals (arsenic, barium, cadmium, chromium, lead, mercury, selenium, and silver) using EPA
Method 6010/7471.

Liberty Corner Response to Comments Page 2
DERR Specific Comments

1. Section 1.0, Introduction and Site Description: The text states that the property is 2.2 - acres.
However, the Voluntary Cleanup Agreement Legal Description and the application state that the site
is 2.042 - acres. Please ensure that the correct area is used in the report.

Response – Atlas will confirm the acreage of the site with the property owner and will update the report
accordingly.

2. Section 1.0, Introduction and Site Description: Multiple containers and materials were observed as
being stored at the site, possibly as part of the auto body shop operations. If these items still remain
at the Site, please include a Materials Management Plan to regulate their removal. For further
information, please see the fact sheet noted in General Comment # 1.

Response – According to the property owner, all of the containers that were present at the time of the Site
Characterization effort have been removed from the site and the buildings are now vacant.

3. Section 3.0, Primary Contaminants of Concern: Oil and Grease, TPH-GRO, and TPH-DRO were
detected above screening levels around the oil water separator and are included as one of the
targets of the RAP. However, these analytes are not listed as Primary Contaminants of Concern.
Please include these analytes among the Primary Contaminants of Concern.
Response – Section 3.0 will be modified to include Oil and Grease, TPH-GRO, and TPH-DRO as primary
contaminants of concern.

4. Section 5.2.1 Soil: Please use the Regional Screening Level (RSL) for Naphthalene instead of the
Initial Screening Level (ISL). The RSL reflects newer data indicating that Naphthalene is potentially
carcinogenic. The ISL was crafted before this data emerged and reflects a non-carcinogenic reference
dose.

Response – The report will be revised to include the naphthalene RSL instead of the ISL.

5. Section 6.1, Soil Removal Procedures: Please add to Section 6.1 that confirmation samples for other
analytes will be included if other contaminants are suspected to be present based on field
observations or other pertinent information.

Response – Text will be added to Section 6.1 clarifying that the analysis of confirmation samples for other
analytes will be included if other contaminants are suspected to be present based upon field observations
or other pertinent information.

6. Section 6.1, Soil Removal Procedures: The plan does not contain a map showing were remedial
activities will take place. For the sake of clarity, please include a map showing the anticipated
locations/extent of the excavations.

Response – A map depicting the locations of the proposed excavations will be included in the revised RAP.

7. Section 6.1, Soil Removal Procedures: The plan mentions that dewatering may be necessary if
the groundwater interferes with soil sample collection. Groundwater in some samples (SB-1) had
analytical concentrations above screening levels and should be handled and disposed of
appropriately. Please add to the text procedures for the handling and disposal of the possibly
contaminated water. In addition, the Division of Water Quality should be contacted for appropriate
dewatering requirements.

Response – Text will be added to the revised RAP discussing the process that will be followed if dewatering
is necessary.

Liberty Corner Response to Comments Page 3
8. Section 6.2, Post Excavation Groundwater Monitoring: The text does not mention what steps will
be taken if groundwater samples are above cleanup goals. Please add text clarifying the remedy for
groundwater impacts above cleanup goals (e.g. DRO concentrations at sample location SB-1).

Response – If groundwater monitoring is required after the property is redeveloped, monitoring wells will
be installed and a quarterly groundwater monitoring program will be implemented. The remedy for this
site will be Monitored Natural Attenuation (MNA).

9. Section 6.6.6, Public Notice: While this section discusses the Public Notice, the actual document is
not included in the plan. Please include the final Public Notice as an appendix to the RAP. Please also
include in the Public Notice that all VCP documents including the RAP may be viewed online at
http://eqedocs.utah.gov.

Response – A copy of the Public Notice (PN) will be included in the revised RAP, and text will be added to
the PN describing where documents can be reviewed.

10. Section 6.6.6 Public Notice: Please ensure that all parcels covered by the RAP are included in the
Public Notice. Parcel # 1512458001000 appears to lie within the Site boundaries, but is not listed in
the Public Notice.

Response – Parcel 1512458001000 will be added to the Public Notice.

11. Section 6.7, Environmental Covenants: The plan mentions that the risk of vapor will be managed
by the use of the first two floors as an open-air parking garage or long-term operation of a vapor
mitigation system. However, the text is unclear on when and under what conditions each strategy
would be pursued. Please specify in the text where/when each strategy will be implemented. To help
with the design, soil gas samples are recommended.

Response – The text “or long-term operation of a vapor mitigation system” will be removed from RAP. The
VOC data indicates that a vapor mitigation system is not warranted; therefore Atlas does not recommend
soil gas sampling.

12. Section 7.0, Schedule: Please do not proceed with removal of the building foundations until the RAP
has been approved (completion of the public comment period). However, it is acceptable to proceed
with the demolition of the buildings down to the foundations as discussed. Demolition of the building
should follow all current local, state, and federal requirements and is ultimately a business decision
made by the applicant.

Response – The building foundations will remain in place until the RAP has been approved by the DERR
(completion of the public comment period).

End of DERR Review Comments.
From:Lincoln Grevengoed
To:Jim Coletta
Subject:[EXTERNAL] Response to RAP Comments
Date:Thursday, August 29, 2024 11:17:22 AM
[External Email] This email originated from outside of the Atlas mail system. Please use
caution when opening attachments.
Hi Jim,
With respect to your request regarding the Response to UDEQ Comments, we are fine with the
majority of the responses and will look for this information in the revised RAP. Additionally,
concerning Responses # 8 and # 11, please see the following.
1. Concerning Response # 8: Please provide supporting information that monitored
natural attenuation will achieve the cleanup goals at the Site. If this remedial approach does
not achieve the cleanup goals, another method should be proposed.
2. Concerning Response #11: Unless additional information is provided, a vapor
mitigation strategy should be proposed for locations where benzene was detected above the
VISL (SB-19, SB-14, etc.) . The contingency plan, included in the RAP, should include
procedures to manage any possible unknowns (e.g. vapor) should these issues be
encountered during future remediation and construction. A number of buildings are still
present and will need to be removed.

Regards,
Lincoln
From:Lincoln Grevengoed
To:Jim Coletta
Subject:[EXTERNAL] DERR RAP Comments
Date:Wednesday, September 25, 2024 9:13:27 AM
[External Email] This email originated from outside of the Atlas mail system. Please use
caution when opening attachments.
Hi Jim,
The DERR has only two comments regarding the revised RAP. As requested, please find the
written version of the comments below.
1. The previous Specific Comment #4 from the DERR's Remedial Action Plan Comments
requested that the Regional Screening Level (RSL) for naphthalene be used instead of Utah's
Initial Screening Level (ISL). The table under Section 5.2.1 still states that the Cleanup
Objective Basis for naphthalene is the UDEQ ISL and not the EPA RSL. Please ensure that
the table references the EPA RSL and not the UDEQ ISL for naphthalene.
2. As requested by the DERR's previous Remedial Action Plan General Comment # 1, please
state that the onsite environmental professional will have the ability to take
opportunity samples if previously unencountered contamination is observed.
Regards,
Lincoln