DERR-2024-009046

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144840 • Salt Lake City, UT 84114-4840
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah
SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor
Department of
Environmental Quality
Kimberly D. Shelley
Executive Director
DIVISION OF ENVIRONMENTAL
RESPONSE AND REMEDIATION
Brent H. Everett
Director
ERRC-103-24
July 16, 2024
Chris Zarek
Liberty Corner Associates, LLC
1229 – 1265 South 300 West
Salt Lake City, Utah 84101
Re: Response to Liberty Corner Remedial Action Plan Review Comments
1229 – 1265 South 300 West, Salt Lake City, Salt Lake County, Utah
Dear Mr. Zarek:
The Division of Environmental Response and Remediation (DERR) has reviewed the
following document as required by the provisions of the Voluntary Cleanup Program (VCP):
Remedial Action Plan Liberty Corner, May 29, 2024.
Please address the attached comments and submit a revised document for the DERR’s
review.
If you have any questions, please contact me at [phone].
Sincerely,
Lincoln Grevengoed, Project Manager
Division of Environmental Response and Remediation
LG/tt
Enclosure: Technical Comments
cc: Dorothy Adams, Executive Director, Salt Lake County Health Department
Ron Lund, Environmental Health Director, Salt Lake County Health Department
Jim Coletta, Atlas Environmental
•
Page 2
DERR Review Comments – Liberty Corner VCP:
Remedial Action Plan (RAP)
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.
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.

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.
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.
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.
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.
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.
6. Section 6.1, Soil Removal Procedures: The plan does not contain a map showing where
remedial activities will take place. For the sake of clarity, please include a map showing
the anticipated locations/extent of the excavations.
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.
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).
Page 3
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.
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.
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.
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.