DERR-2025-000687

Allison Stanley <[e-mail]>
Proposed Paxton Demolition Activities
3 messages
Brent Robinson <[e-mail]>Tue, Oct 22, 2024 at 4:42 PM
To: Bill Rees <[e-mail]>, Allison Stanley <[e-mail]>
Cc: Bruce Bastian <[e-mail]>
Allison/Bill,

Thank you for making time today to discuss the planned demolition activities at the Paxton site (Voluntary Cleanup
Program Site #129). We apologize for the short notice provided regarding the demolition – we were also just notified of
the schedule as permit approval was apparently obtained late last week. We are providing an overview of the demolition
activities that are currently planned herein and are seeking your approval to move forward with these activities.

Paxton has retained Impact Demolition (Impact) to conduct the demolition activities, which they are planning to initiate
tomorrow (10/23) for the aboveground structures. Paxton/Impact have obtained demolition permits and have terminated
the site utilities. Impact has a Fugitive Dust Control Plan and is planning to access the buildings to be demolished via
paved surfaces to avoid contact with impacted soils. Asbestos and lead based paint survey/abatement activities have
been conducted for the buildings to be demolished. Fresh Air Environmental conducted the asbestos abatement. All
known hazardous materials have also been removed from the building and property by EnviroCare. A Geosyntec
representative will visit the site periodically during excavation of the above ground structures.

Impact is planning to start demolition of the hardscape and foundations on Friday (10/25). In conjunction with these
activities, Impact plans to uncover and remove the two historic hydraulic lifts that are present at the site. As the lifts have
not been used for some time, the condition of the lifts is unknown. Efforts were previously made to remove any potential
hydraulic oil from the lifts, but no fill ports, tanks, or means to remove any hydraulic oil were not identified. Removal of the
overlying concrete will be necessary to further evaluate and remove hydraulic oil from the lifts. EnviroServe will be on-site
to help remove hydraulic fluids from the lifts. A Geosyntec representative will be on-site during all of the
hardscape/foundation demolition and hydraulic lift related activities.

During our communications, you conveyed your preference to remove the hardscape/foundations in conjunction with an
approved Remedial Action Plan (RAP) for the site. Paxton plans to prepare and implement a RAP for the site but would
prefer to conduct the hardscape/foundation demolition activities beforehand. It is our opinion that this will allow for
preparation of a more focused and effective RAP, as it would help us better understand and address actual site
conditions, and that it would not result in significantly greater risk, as an environmental professional (and DERR
representative, if desired) will be on-site observing, documenting, and directing these activities.

During our discussion, you also indicated that DERR correspondence for the project indicates your preference to remove
the hardscape/foundations during RAP implementation. We respectfully disagree and have provided references to
relevant language from prior communications below which we believe has been followed in preparing for the planned
demolition activities of the hardscape/foundations/hydraulic lift.

DERR Comments for Environmental Assessment (May 7, 2024) – Comment #8: Building demolition may
occur down to the foundations in accordance with all rules and regulations (e.g., meeting DAQ program
requirements for asbestos containing material). The fact sheet contained in the link provides useful information
and should be followed to ensure the protection of human health and the environment. Please coordinate with the
DERR on this activity. Removal of material under the foundations should be conducted in accordance with a RAP.
1/27/25, 7:50 AM State of Utah Mail - Proposed Paxton Demolition Activities
https://mail.google.com/mail/u/0/?ik=e22438591e&view=pt&search=all&permthid=thread-f:1813655777454406491&simpl=msg-f:18136557774544064…1/4

DERR General Comments on the SCW (June 14, 2024) - Comment #1: Since characterization activities are
not proposed under the buildings and other hardscape locations in the Site Characterization Workplan (SCW),
further sampling should be proposed in the Remedial Action Plan (RAP) once the buildings have been
demolished and the foundations/hardscape removed. Due to the age of the Site, potential unknowns may exist
under the buildings beyond the reported hydraulic lifts. An environmental professional should be on-site as these
surfaces are removed.

We appreciate your consideration of our request and continue to be interested in moving the project forward in an efficient
manner that meets the requirements of the Voluntary Cleanup Program

Thank you and best regards,

Brent

Brent C. Robinson, P.E.
Senior Principal Engineer

215 South State Street, Suite 500
Salt Lake City, Utah 84111
Phone: [phone] Mobile: [phone]
E-mail: [e-mail]

GEOSYNTEC | SIREM | SAVRON | GREEN HARBOR ENERGY

From: Bill Rees <[e-mail]>
Sent: Friday, June 14, 2024 2:02 PM
To: Bruce Basan <[e-mail]>
Cc: Allison Stanley <[e-mail]>; Brent Robinson <[e-mail]>
Subject: The Paxton SCWP Review Comments

1/27/25, 7:50 AM State of Utah Mail - Proposed Paxton Demolition Activities
https://mail.google.com/mail/u/0/?ik=e22438591e&view=pt&search=all&permthid=thread-f:1813655777454406491&simpl=msg-f:18136557774544064…2/4
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Bruce,

See attached. I am sending these for Allison. She will sign the final sometime when she returns later this month.

Bill

Bill Rees
Section Manager
VCP/Brownfields Section
P: [phone]
environmentalresponse.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.

Bill Rees <[e-mail]>Wed, Oct 23, 2024 at 8:25 AM
To: Hans Millican <[e-mail]>, Allison Stanley <[e-mail]>
Hans,
Below is an email I would like to discuss with you today.
Bill
[Quoted text hidden]
Bill Rees <[e-mail]>Wed, Oct 23, 2024 at 3:18 PM
To: Brent Robinson <[e-mail]>
Cc: Allison Stanley <[e-mail]>, Bruce Bastian <[e-mail]>, Hans Millican <[e-mail]>
Brent,
We have reviewed your email request and cannot accept the proposal to remove the foundations without a RAP. First,
this would be inconsistent with how the program has operated for years. Second, the RAP is designed to establish
1/27/25, 7:50 AM State of Utah Mail - Proposed Paxton Demolition Activities
https://mail.google.com/mail/u/0/?ik=e22438591e&view=pt&search=all&permthid=thread-f:1813655777454406491&simpl=msg-f:18136557774544064…3/4
procedures and a process to address contamination, suspected contamination and areas contributing to the
contamination once the foundations/hardscape are removed. Third, your proposal to remove the hydraulic lifts and any
oil, etc.. would definitely need to be under a RAP.
Again, we have green lighted the vertical demolition to the foundation. The work can commence anytime provided SLC,
SLCO, etc requirements have been met. Please send the disposal documentation for the various drums, etc. that were
previously removed.
Finally, I disagree with the interpretation regarding our review comments. Comment #8 was included in the EA
comments to head off this very issue. The EA comments were one of the first deliverables for the site and were provided
in May of this year. Every comment since that time has been based on that premise. Why was it not discussed earlier
rather than one day before the work is scheduled to commence?
Our goal is to see this site addressed and are working to help your client meet the objectives, but we need to be
consistent with the agreement and overall program implementation.
Regards,
Bill
Bill Rees
Section Manager
VCP/Brownfields Section
P: [phone]
environmentalresponse.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
[Quoted text hidden]
1/27/25, 7:50 AM State of Utah Mail - Proposed Paxton Demolition Activities
https://mail.google.com/mail/u/0/?ik=e22438591e&view=pt&search=all&permthid=thread-f:1813655777454406491&simpl=msg-f:18136557774544064…4/4