DERR-2025-000130

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-130-24
August 23, 2024
Phil Schull
Poindexter Properties, LLC
600 Travis Street, Suite #400
Houston, Texas 77002
RE: Technical Review Comments - Semi Service Site Characterization Report
North Salt Lake, Davis County, Utah
Dear Mr. Schull:
The Division of Environmental Response and Remediation (DERR) has reviewed the
Site Characterization Report,dated May 24, 2024, for the referenced site. The review was conducted
in accordance with the requirements of the Voluntary Cleanup Program (VCP).
Based on our assessment, the DERR has enclosed technical comments for your review.
Please address these comments and submit a revised Site Characterization Report.
Thank you for your continued participation in the VCP. If you have any questions, please
contact me at [phone].
Sincerely,
Leigh Anderson, Project Manager
Division of Environmental Response and Remediation
KLA/tt
cc: Brian E. Hatch, Director, Davis County Health Department
Jay Clark, Environmental Health Director, Davis County Health Department
Page 2
DERR Review Comments
Site Characterization Report (SCR) Comments – Semi Service VCP Site
General Comments:

1. During prior discussions on the development of the Site Characterization Workplan, it
was agreed that sampling for PFAS constituents would be deferred until appropriate standards
and laboratory methods were established. As discussed during our recent meeting, these
standards have now been established. Given the site’s proximity to a historical landfill, PFAS
sampling is now requested. Please propose additional sampling to address this comment.
2. Since the Site Characterization Report (SCR) recommended further sampling to better
assess the site, it would be acceptable to include the PFAS sampling requested in General
Comment #1 within a single additional workplan. Please submit this revised workplan for
review.
3. Groundwater sample results should be compared to Maximum Contaminant Levels
(MCLs). If no MCL exists, please use the EPA Regional Screening Levels for Tap Water as a
reference.
4. The designations for TB, EB, and RB samples are unclear. If these represent Trip Blank,
Equipment Blank or other QA/QC samples, please clarify this in the report.
5. The Quality Assurance Project Plan (QAPP) indicated that the Sensitivity evaluation for
groundwater samples would be based on comparing the Method Detection Limit to screening
levels. However, the tables in the report use the Reporting Limit instead. Please revise the table
to ensure consistency with the QAPP
Technical Comments:

1. Page 7: Please revise the text that indicates the site is downgradient of the Old North Salt
Lake Landfill. The boundaries of the former landfill are unclear, and it is uncertain whether the
landfill may have extended beneath the site.
2. Figure 3: Please include numeric values for screening levels so that the results can be
compared to those values. If concentrations are below detection limits, please report the
detection limits.
3. Figure 4: Several analytes are reported below detection limits, but these limits are above
screening levels, which could raise concerns regarding quality assurance (Sensitivity). Please
propose a strategy to address this issue, particularly for potential contaminants such as PCBs and
hexavalent chromium.

4. Table 5: The laboratory results include both Heptane and n-Heptane. Please revise the
table to distinguish between these results.