DSHW-2023-005257 - 0901a06881207577

5/26/23, 1:40 PM State of Utah Mail - Fwd: Trinity Highway - Meeting Request
https://mail.google.com/mail/b/ADwNV_dVYFChAafwlXqH0NE62WZhTbi8bUiClmjg_VRizZztnxOy/u/0/?ik=adf9d5e615&view=pt&search=all&permthi…1/17
Deq submit <[e-mail]>
Fwd: Trinity Highway - Meeting Request
1 message
Dale Urban <[e-mail]>Fri, May 26, 2023 at 11:59 AM
To: Deq submit <[e-mail]>
Please put into D2 under the Trinity Hwy Products project
Thanks
---------- Forwarded message ---------
From: Jamie Russell <[e-mail]>
Date: Fri, May 26, 2023 at 10:10 AM
Subject: RE: Trinity Highway - Meeting Request
To: Dale Urban <[e-mail]>
Cc: Paige Walton <[e-mail]>, Eric Baiden <[e-mail]>, Daryl Hancock <[e-mail]>
Hi Dale –

This is Jamie from RMEC. Attached is the current soil data from the additional site characterization work completed for SWMUs 1 and 2 at the
Trinity Highway Products site. Please let me know if anything else is needed from our end.

Thanks!
Jamie

Jamie Russell
Project Manager
RMEC Environmental, Inc.
476 West 325 South, Bountiful, UT 84010
Office: 801.467.3661 Cell:
www.rmec.net

From: Dale Urban <[e-mail]>
Sent: Wednesday, May 24, 2023 8:15 AM
To: Daryl Hancock <[e-mail]>
Cc: Paige Walton <[e-mail]>; Eric Baiden <[e-mail]>
Subject: Re: Trinity Highway - Meeting Request

Hi Daryl;

Yes, we can meet next Thursday (June 1st) at 2:30 here in our office building. Come up to the 2nd floor and ask for me. I have the
"Canyonlands" conference room reserved for our meeting.

If you have any recent data/information from the most recent additional site characterization work that you did, that would be helpful if you
could share it with us prior to the meeting to make our discussion more efficient.
5/26/23, 1:40 PM State of Utah Mail - Fwd: Trinity Highway - Meeting Request
https://mail.google.com/mail/b/ADwNV_dVYFChAafwlXqH0NE62WZhTbi8bUiClmjg_VRizZztnxOy/u/0/?ik=adf9d5e615&view=pt&search=all&permthi…2/17

Thanks & seen you next week

On Tue, May 23, 2023 at 4:06 PM Daryl Hancock <[e-mail]> wrote:
Hello Dale –

As we discussed before, RMEC and Stokes Stevenson is interested in evaluating the potential requirements for closure under
commercial/industrial standards.

I reached out to Eric earlier today to clarifications regarding the Risk Assessment for the property. In essence, we are trying to delineate
the necessary elements for closure of the site based on the conclusions of the existing Risk Assessment. It sound like it would be
beneficial to have a meeting. Would you be available to meet at the DEQ offices next Thursday (June 1) at 2:30 pm? It sounds like Eric is
available at the date and time.

Let me know and thanks –

Daryl

Daryl Hancock, CHMM, CEM
RMEC Environmental, Inc.
476 West 325 South, Bountiful, UT 84010
Office: 801.467.3661 Cell:
www.rmec.net

From: Dale Urban <[e-mail]>
Date: Friday, March 24, 2023 at 12:54 PM
To: Daryl Hancock <[e-mail]>
Cc: Deq submit <[e-mail]>, Paige Walton <[e-mail]>
Subject: Re: Trinity Highway - Groundwater
Hi Daryl;

Thanks for sending over the 2020 GWM report for the Trinity Hwy project. I will review the report, but as far as making any site-wide
determination(s), I would prefer to evaluate it for compliance with the cleanup rule and approved site management plan once I get the
additional SI report that your recent work plan discussed. That way, with both reports and data packages, I can evaluate all the impacted
media (soil and shallow groundwater) at the same time in terms of potentially complete or complete exposure pathways for any residual
contamination remaining at the property. With this additional information and subsequent evaluation, I can then recommend the most
appropriate steps, such as a risk-based closure or other appropriate regulatory decision, to take at the site moving forward prior to site
redevelopment activities.

Good luck w/ the upcoming field work and thanks for your efforts with this project.

On Fri, Mar 24, 2023 at 10:44 AM Daryl Hancock <[e-mail]> wrote:
5/26/23, 1:40 PM State of Utah Mail - Fwd: Trinity Highway - Meeting Request
https://mail.google.com/mail/b/ADwNV_dVYFChAafwlXqH0NE62WZhTbi8bUiClmjg_VRizZztnxOy/u/0/?ik=adf9d5e615&view=pt&search=all&permthi…3/17
Dale –

Please see the attached 5-year groundwater monitoring report for the THP site. You’ll note that the only
parameters that exceed any threshold values are iron and sulfate. The standard for Iron is a Tap Water
standard and the standard for Sulfate is a based on a secondary drinking water standard. Neither of these
compounds should be a concern for keeping the groundwater issue open. I spoke with Eric Baiden about this
and he seemed to agree with this position.

Anyway, please review and let me know your thoughts. If you are agreement with this conclusion, Stoke
Stevenson we would formally request cessation of groundwater monitoring and closure of the groundwater
issue.

Thanks and hope all is well –

Daryl

Daryl Hancock, CHMM, CEM
RMEC Environmental, Inc.
476 West 325 South, Bountiful, UT 84010
Office: 801.467.3661 Cell:
www.rmec.net

From: Daryl Hancock <[e-mail]>
Date: Monday, March 13, 2023 at 2:27 PM
To: Dale Urban <[e-mail]>
Cc: Sam Nelson <[e-mail]>, Bryan Stevenson <[e-mail]>, Eric
Baiden <[e-mail]>, Jamie Russell <[e-mail]>, Paige Walton <[e-mail]>, Deq
submit <[e-mail]>
Subject: Re: Trinity Highway Comfort Letter Request
Dale –

As discussed, please see the attached Work Plan for your review. Feel free to contact me with any questions or concerns.

Thanks so much for you efforts on this project.

Daryl

Daryl Hancock, CHMM, CEM
RMEC Environmental, Inc.
476 West 325 South, Bountiful, UT 84010
Office: 801.467.3661 Cell:
5/26/23, 1:40 PM State of Utah Mail - Fwd: Trinity Highway - Meeting Request
https://mail.google.com/mail/b/ADwNV_dVYFChAafwlXqH0NE62WZhTbi8bUiClmjg_VRizZztnxOy/u/0/?ik=adf9d5e615&view=pt&search=all&permthi…4/17
www.rmec.net

From: Daryl Hancock <[e-mail]>
Date: Wednesday, February 22, 2023 at 12:30 PM
To: Dale Urban <[e-mail]>
Cc: Sam Nelson <[e-mail]>, Bryan Stevenson <[e-mail]>, Eric
Baiden <[e-mail]>, Jamie Russell <[e-mail]>, Paige Walton <[e-mail]>, Deq
submit <[e-mail]>
Subject: Re: Trinity Highway Comfort Letter Request
Hey Dale –

This is such great news. With clarity on this issue, we will get working on a draft sampling work plan.

I will reach out with any questions that come up as we are working on it.

Thanks for all your hard work on this –

Daryl

Daryl Hancock, CHMM, CEM
RMEC Environmental, Inc.
476 West 325 South, Bountiful, UT 84010
Office: 801.467.3661 Cell:
www.rmec.net

From: Dale Urban <[e-mail]>
Date: Friday, February 17, 2023 at 10:52 AM
To: Daryl Hancock <[e-mail]>
Cc: Sam Nelson <[e-mail]>, Bryan Stevenson <[e-mail]>, Eric
Baiden <[e-mail]>, Jamie Russell <[e-mail]>, Paige Walton <[e-mail]>, Deq
submit <[e-mail]>
Subject: Re: Trinity Highway Comfort Letter Request
Hi Daryl;

After a careful file review, I concur with your conclusions to proceed with the work plan submittal for review and approval prior to
conducting the additional site characterization, but without the need to do any additional hazardous waste testing by TCLP analysis.
The risk assessment effectively eliminated the need for any more TCLP analysis at the site (at least for the Divisions needs).

As to the need for requesting a Contained-Out determination from the Division Director, let's just wait for the analytical results of this
additional site work and then revisit the matter if needed.

Thanks for your assistance with this project.
5/26/23, 1:40 PM State of Utah Mail - Fwd: Trinity Highway - Meeting Request
https://mail.google.com/mail/b/ADwNV_dVYFChAafwlXqH0NE62WZhTbi8bUiClmjg_VRizZztnxOy/u/0/?ik=adf9d5e615&view=pt&search=all&permthi…5/17

On Mon, Jan 9, 2023 at 9:29 AM Daryl Hancock <[e-mail]> wrote:
Happy Monday, Dale –

Since we last spoke, I submitted a GRAMA record request with the Division and I received the Corrective Measures Implementation
(CMI) Plan from 1997, along with the 1998 Risk Assessment for the site. I had held off on the submittal of the workplan until we had
this information.

You should be able to access these documents at the link below:
Syro Steel UTD041075896 Corrective Measures Imp...
Syro Steel UTD041075896 Risk Assessment October...

Based on my review, it appears that all soils exceeding TCLP limits were addressed/removed as part of the CMI. Please review and
let me know your thoughts. RMEC would still move forward with conducting site investigation work in SWMU #1 and #2, which will be
detailed in a workplan. However, based on the CMI work, I’m hoping you will agree that a “contained out” request and/or additional
testing for hazardous waste characterization can be eliminated. Site characterization work would focus on determining the target
depths and meets and bounds of soils impacted above industrial RSLs in SWMU #1 and #2.

Let me know if we have your concurrence on the waste characterization issue and we will get a work plan submitted. Thanks so
much -

Daryl

Daryl Hancock, CHMM, CEM
RMEC Environmental, Inc.
476 West 325 South, Bountiful, UT 84010
Office: 801.467.3661 Cell:
www.rmec.net

From: Dale Urban <[e-mail]>
Date: Tuesday, January 3, 2023 at 10:30 AM
To: Sam Nelson <[e-mail]>
Cc: Bryan Stevenson <[e-mail]>, Daryl Hancock <[e-mail]>, Eric
Baiden <[e-mail]>, Jamie Russell <[e-mail]>, Paige Walton <[e-mail]>, Deq
submit <[e-mail]>
Subject: Re: Trinity Highway Comfort Letter Request
All;

It is my understanding that we are waiting on a work plan proposal from Daryl for some additional site characterization work in order
to evaluate whether a "Contained-Out" (CO) determination is appropriate for the disposal of source material still present at the site. If
so, off-site disposal costs for a non-hazardous waste would be a significant cost savings rather than having to dispose of it as a
hazardous waste at a properly permitted landfill facility. Once I receive the work plan, and the Division has approved the work, then
the next phase would be the field work and submitting a report that documented the findings. An application for the CO determination
could also be submitted with the upcoming investigation report if your consultant recommends that path forward based on the
5/26/23, 1:40 PM State of Utah Mail - Fwd: Trinity Highway - Meeting Request
https://mail.google.com/mail/b/ADwNV_dVYFChAafwlXqH0NE62WZhTbi8bUiClmjg_VRizZztnxOy/u/0/?ik=adf9d5e615&view=pt&search=all&permthi…6/17
contaminant concentrations and the "sludge" versus "soils" issue previously discussed in the December 2nd email I sent out to the
group.

After this additional site characterization work has been completed, then any residual contamination at the property would need to be
evaluated for the need to conduct cleanup at the site before any future site redevelopment takes place. If cleanup actions are
needed at the site, then prior to conducting any on-site remediation activities, we would also need to review and approve of a
Corrective Action Plan which would outline your proposed cleanup approach. An example of the contents for a proposed cleanup
plan can be found here: https://documents.deq.utah.gov/waste-management-and-radiation-control/corrective-action/DSHW-2019-
016485.pdf

Here is the link to the Contained-Out document which explains the determination process our Division uses in case you need it
again: https://documents.deq.utah.gov/waste-management-and-radiation-control/hazardous-waste/DSHW-2020-015943.pdf

In addition, my supervisor Brad Maulding has retired and has been replaced by Paige Walton, who is cc'd on this. Feel free to reach
out to me or to Paige if we can be of any further assistance in moving this project forward in a timely manner.

Best regards.

On Tue, Jan 3, 2023 at 9:47 AM Sam Nelson <[e-mail]> wrote:
Dale/Daryl,

Hope you all had a wonderful Holiday Season.

I wanted to follow up on this to see if there was anything needed on the Stokes Stevenson end. I want to be sure nothing falls
through the cracks on our side and we would like to get an update on the status of this as well. Feel free to reach out to me
anytime if you need anything from us.

Happy New Year.

Regards,

Sam Nelson
Development Associate
Stokes Stevenson
Mobile.
Email. [e-mail]
From: Bryan Stevenson <[e-mail]>
Sent: Friday, December 2, 2022 12:15:26 PM
To: Dale Urban <[e-mail]>
Cc: Daryl Hancock <[e-mail]>; Brad Maulding <[e-mail]>; [e-mail]
<[e-mail]>; Eric Baiden <[e-mail]>; Jamie Russell <[e-mail]>
Subject: Re: Trinity Highway Comfort Letter Request

Thanks Dale
Have a great weekend. Daryl, let's chat monday to get going on this.

5/26/23, 1:40 PM State of Utah Mail - Fwd: Trinity Highway - Meeting Request
https://mail.google.com/mail/b/ADwNV_dVYFChAafwlXqH0NE62WZhTbi8bUiClmjg_VRizZztnxOy/u/0/?ik=adf9d5e615&view=pt&search=all&permthi…7/17

Bryan Stevenson
Managing Partner
[e-mail]
Mobile.
Website.stokesstevenson.com

On Fri, Dec 2, 2022 at 1:06 PM Dale Urban <[e-mail]> wrote:
Daryl;

I agree that the next most logical step in the process would be to submit a work plan to conduct additional soil sampling in the
areas of concern for review and approval prior to the field work. Considering the length of time between now and the original
sampling performed which characterized the impacted media, it makes sense to collect more data to quantify the current
residual contaminant levels at the project site.

Once the extent and degree of residual contamination is known, then an evaluation could be performed to determine if
requesting a "Contained-Out Determination" is a feasible option to assist with the off-site disposal of materials as "non-
hazardous", which would obviously reduce the overall project costs for cleanup/disposal. TCLP testing of representative
samples would also be needed to determine if the waste still had a hazardous waste characteristic such as toxicity.

The work plan for the additional investigation should be consistent with previous data collection events in terms of the requested
laboratory methods for sample analysis. In addition, additional parameters (USC, % moisture, effective porosity, etc.) would be
helpful to obtain to make a case that the historical "sludge" could now be considered to be a "soil", if that turns out to be a
relevant argument to form the basis for requesting a Contained-Out Determination from the Division Director.

Give me a call if you want to discuss the elements of the work plan before submitting it to me for review and approval.

Thanks

On Wed, Nov 30, 2022 at 12:07 PM Daryl Hancock <[e-mail]> wrote:
Dale:

I do believe the term “sludge” was attributed to suspect soils/materials that were impacted by discharges of pickling liquors to
the unlined detention basins as they were encountered during drilling and test pit excavations. However, based on boring logs
descriptions and the fact that these basins have been leveled with soils, I don’t believe it is a characterization of the physical
state of the soils and I’m fairly certain they would qualify as “soils”.

5/26/23, 1:40 PM State of Utah Mail - Fwd: Trinity Highway - Meeting Request
https://mail.google.com/mail/b/ADwNV_dVYFChAafwlXqH0NE62WZhTbi8bUiClmjg_VRizZztnxOy/u/0/?ik=adf9d5e615&view=pt&search=all&permthi…8/17
As to a “contained out” determination, we would need to know the current disposition of the waste from the DWMRC
standpoint. For example, were these designated as SWMU because they contained a “hazardous waste”? See my notes on
the attached contained-out process flow outline from the guidance document and let me know your thoughts on how we
might go about making a contained out determination.

Given the documentation in the RFI and the 30 years that has passed since the testing was performed, I am not sure how we
would go about identifying the exact location of these 2 “hot spot” location that exceeded the TCLP limits for lead in the RFI;
however, we need to keep in mind that the RFI collected targeted samples. There is a very good chance that none of the soils
would exceed TCLP thresholds if we could take a fresh look at characterization of the soils in the SWMUs based on the
proposed removal action. The removal action would be based on the assumption that all soils above EPA RSL would be
removed from the SWMUs, which would require the removal of the entire “sludge” zone along with some portion of the
underlying and overlying soils that are secondarily contaminated by mixing and leaching (above RSLs).

Ultimately, I think RMEC and Stokes Stevenson would like to know if a proposal for characterization of the SWMU would be
acceptable to the DWMRC. RMEC would detail the proposed action in a work plan, but essentially the proposal would be to
conduct soil borings on an pre-established grid over each of the SWMU and use visual observations and XRF screening to
collect discrete samples of the impacted soil cross-sections. Samples would be analyzed for lead by TCLP along with USC
and moisture testing if you feel it is necessary.

Let me know your thoughts on that and thanks again for your time and attention to this matter –

Daryl

Daryl Hancock, CHMM, CEM
RMEC Environmental, Inc.
476 West 325 South, Bountiful, UT 84010
Office: 801.467.3661 Cell:
www.rmec.net

From: Dale Urban <[e-mail]>
Date: Wednesday, November 23, 2022 at 4:06 PM
To: Daryl Hancock <[e-mail]>
Cc: Brad Maulding <[e-mail]>, [e-mail]
<[e-mail]>, Eric Baiden <[e-mail]>, Bryan Stevenson
<[e-mail]>
Subject: Re: Trinity Highway Comfort Letter Request
Daryl;

Is there any chance that the material in question would qualify for requesting a "Contained-Out" determination from the
Division Director? The link to the document is below, and it was specifically written to address impacted soils, but perhaps at
this point in time the material in SWMUs #1 & #2 might qualify as "soils" depending on the USC classification and moisture
content, etc.
https://documents.deq.utah.gov/waste-management-and-radiation-control/hazardous-waste/DSHW-2020-015943.pdf

If the material does qualify for the Contained-Out Determination as a non-hazardous waste, then that would obviously lower
the off-site disposal costs. If not, then perhaps the wastes could be segregated into hazardous versus non-hazardous waste
5/26/23, 1:40 PM State of Utah Mail - Fwd: Trinity Highway - Meeting Request
https://mail.google.com/mail/b/ADwNV_dVYFChAafwlXqH0NE62WZhTbi8bUiClmjg_VRizZztnxOy/u/0/?ik=adf9d5e615&view=pt&search=all&permthi…9/17
stockpiles during any future excavation or cleanup activities, as an effort to minimize the volume of materials that had to be
disposed of as hazardous wastes at a permitted RCRA hazardous waste disposal facility.

I hope this helps you in moving the project forward in a timely and cost-effective manner.

Thanks

On Wed, Nov 23, 2022 at 3:54 PM Daryl Hancock <[e-mail]> wrote:
Hey Dale –

Development and disturbance of the SWMU will be required based on the proposed development of the site. As such,
there could be some significant cost consideration tied to the waste characterization question at hand. No “deliverables”
per se, but I think Bryan and the rest of the development team would like to have a more complete understanding of these
potential cost implications before this December 10 deadline.

Thanks for looking ahead for clarification on this. I hope this makes sense and really do appreciate your responsiveness.

Have a great Thanksgiving!

Daryl

Daryl Hancock, CHMM, CEM
RMEC Environmental, Inc.
476 West 325 South, Bountiful, UT 84010
Office: 801.467.3661 Cell:
www.rmec.net

From: Bryan Stevenson <[e-mail]>
Date: Wednesday, November 23, 2022 at 3:25 PM
To: Dale Urban <[e-mail]>
Cc: Daryl Hancock <[e-mail]>, Brad Maulding <[e-mail]>,
[e-mail] <[e-mail]>, Eric Baiden <[e-mail]>
Subject: Re: Trinity Highway Comfort Letter Request
Thanks Dale it is good to hear from you. I think the feedback we were hoping for by next week is the characterization of the
classification of the material we are hoping to remove and dispose of. Daryl is guiding us through this process and he is
clearly the expert on it, I am not by any means. But we are hoping to have it qualify as non-hazardous material so we can
dispose of the material off-site.
5/26/23, 1:40 PM State of Utah Mail - Fwd: Trinity Highway - Meeting Request
https://mail.google.com/mail/b/ADwNV_dVYFChAafwlXqH0NE62WZhTbi8bUiClmjg_VRizZztnxOy/u/0/?ik=adf9d5e615&view=pt&search=all&permt…10/17
Daryl, feel free to clarify my comments here.
Thanks for your help to all.
Bryan

Sent from my iPhone

On Nov 23, 2022, at 11:48 AM, Dale Urban <[e-mail]> wrote:

Mr. Stevenson;

I was hoping to clarify for everyone involved in this project, what exactly are you hoping to get in terms of the
type of deliverable(s) and/or how they would be sent out (via email, phone call, official letter, etc.) from the
division by "next week" as it pertains to you closing on the bank loan on December 10th?

Eric has been off on vacation all of this week, so I don't even know if he has seen my request for his
assistance in reviewing the 1994 RFI documents submitted by Daryl?

I just wanted some clarification on short-term expectations so that we could work together to try to reach an
agreement on what is feasible for deliverables within the next week or two (especially if the bank loan is
depending on a specific document from us).

Thank you in advance for your patience with the regulatory framework we are sometimes constrained by.

Best regards,

On Mon, Nov 21, 2022 at 10:59 AM Bryan Stevenson <[e-mail]> wrote:
Thanks Brad and Dale
Next week works for us. We are planning to close a loan on this property on the 10th of December so if
we can get this by next week that should give us the time needed to get the bank on board.
Thanks Brad !

Bryan Stevenson
Sent from my iPhone

On Nov 21, 2022, at 10:54 AM, Dale Urban <[e-mail]> wrote:

Hi Daryl;

Thank you for the additional information about the project. I will evaluate the reports and get
back to you regarding the additional characterization approaches for the sludges in the two
SWMUs you mentioned. I have also asked our Divisions Risk Assessor, Eric Baiden, to
review the information and the request for consideration of off-site disposal of the sludges
as non-hazardous waste.
5/26/23, 1:40 PM State of Utah Mail - Fwd: Trinity Highway - Meeting Request
https://mail.google.com/mail/b/ADwNV_dVYFChAafwlXqH0NE62WZhTbi8bUiClmjg_VRizZztnxOy/u/0/?ik=adf9d5e615&view=pt&search=all&permth…11/17

With the holiday this week, it won't be until next week (or maybe later?) that Eric and I will
both have had time to review the submitted reports and can compare our notes/thoughts on
the matter before discussing the best path forward for you and your client.

Thank you in advance for your patience.

On Mon, Nov 14, 2022 at 3:48 PM Daryl Hancock <[e-mail]> wrote:
Howdy Dale –

We were able to obtain a copy of the EPA’s 1994 RFI and I am providing you with a copy
as an attachment. Also, attached are figures and excerpts from the body of the RFI on
analytical test results from Solid Waste Management Units (SWMU) #1 and #2.

Stokes Stevenson Centerville Flex is in the process of evaluating the potential for
removal and offsite disposal of sludges associated with these SWMUs as they are under
the proposed footprints of future buildings and parking lots. You’ll note in your review of
the attached RFI documentation that soils from 18 locations were tested by TCLP for
specific D-list metals. Two (2) locations out of the 18 tested exceeded the EPA
characteristic hazardous waste criteria for lead (D008) at 6.9 and 7.5 mg/L.

The allowance of this material for offsite disposal as a “non-hazardous waste” will
significantly impact the viability of potential removal and offsite disposal options. I would
like to discuss potential options for additional characterization approaches for the sludges
in SWMU #1 and #2 for offsite disposal as a non-hazardous waste after you’ve reviewed
the attached documentation.

Thank you for your time and attention in this matter. Sincerely,

Daryl

Daryl Hancock, CHMM, CEM
RMEC Environmental, Inc.
476 West 325 South, Bountiful, UT 84010
Office: 801.467.3661 Cell:
www.rmec.net

From: Dale Urban <[e-mail]>
Date: Tuesday, September 20, 2022 at 4:39 PM
To: Daryl Hancock <[e-mail]>
Cc: Brad Maulding <[e-mail]>, Thomas Ball
<[e-mail]>, Bryan Stevenson <bstevenson@blackcliffcapital.
com>, [e-mail] <[e-mail]>
Subject: Re: Trinity Highway Comfort Letter Request
Hi Daryl;

5/26/23, 1:40 PM State of Utah Mail - Fwd: Trinity Highway - Meeting Request
https://mail.google.com/mail/b/ADwNV_dVYFChAafwlXqH0NE62WZhTbi8bUiClmjg_VRizZztnxOy/u/0/?ik=adf9d5e615&view=pt&search=all&permt…12/17
On behalf of Brad Maulding, I am responding to your inquiry about site information that
could be used in preparing a modified Site Management Plan. The project is currently
known as the Trinity Highway Products (aka Stokes Stevenson). In addition, the site
used to be known as "Syro Steel".

I did a quick search on our Interactive Map using the current name "Trinity Highway
Products" on our Department's website which can be found here: https://enviro.deq.
utah.gov/

My search brought up a total of 125 documents that had either the DERR or the DSHW
as the two divisions that had correspondence for this project. You may want to see if any
of those documents will provide you with the information that you are looking for?

Let me know if you have any questions or need help doing a search on the map, and I
would be happy to help.

Best regards,

On Tue, Sep 20, 2022 at 12:19 PM Daryl Hancock <[e-mail]> wrote:
Hello Brad –

I am hoping you could direct me to soil data from the closure of the site for future
integration into the SMP and planning for proposed development of this site.
Specifically, I am trying to get some information regarding contaminants concentrations
along with the meets, bounds, elevations, and depth of cover on the impacted
materials in SWMU 1 and 2. The information is not contained in the current SPM;
however, I believe this would be contained in the 1994 Remedial Feasibility
Investigation (RFI) by the EPA. Can you assist, or do you have any recommendations
on the best and fastest way to obtain this report? It doesn’t appear to be on the DEQ
online database.

Thanks so much and hope you’re doing well.

Cheers –
Daryl

Daryl Hancock, CHMM, CEM
RMEC Environmental, Inc.
476 West 325 South, Bountiful, UT 84010
Office: 801.467.3661 Cell:
www.rmec.net

From: Brad Maulding <[e-mail]>
Date: Thursday, July 21, 2022 at 6:00 PM
To: [e-mail] <[e-mail]>
Cc: Daryl Hancock <[e-mail]>, Thomas Ball
5/26/23, 1:40 PM State of Utah Mail - Fwd: Trinity Highway - Meeting Request
https://mail.google.com/mail/b/ADwNV_dVYFChAafwlXqH0NE62WZhTbi8bUiClmjg_VRizZztnxOy/u/0/?ik=adf9d5e615&view=pt&search=all&permt…13/17
<[e-mail]>, Dale Urban <[e-mail]>
Subject: Fwd: Trinity Highway Comfort Letter Request
Good evening Bryan,
I am contacting you to see if you can assist me on a few things related to the Comfort
Letter request for the Trinity Highway Products property. We have a draft letter ready
to forward to our Director. However, the AG's Office assisting us is questioning the
address found as item #3 in the request (Bryan Stevenson, Managing Partner, Stokes
Stevenson, 1215 Ste 120, Salt Lake City, UT 84106). Is this the correct address for
the request response to be sent? In addition, not sure if anyone noticed on your end
but the Phase I ESA is marked confidential. It is forcing us to send a formal letter to
you seeking a response as to whether it needs to be maintained as confidential in our
records. The address in question affects this letter.
Appreciate your feedback so we can have the Comfort Letter response ready when
our Director returns to the office next Tuesday and to address the Phase I ESA
confidentiality issue.
Thanks, Brad

Brad Maulding, PG
Program Manager | Corrective Action Section |
Division of Waste Management and Radiation Control
Office: [phone] | Front Desk: [phone]
wasteandradiation.utah.gov
Emails to and from this email address may be considered public records and thus subject
to Utah GRAMA requirements.
Statements made in this email do not constitute the official position of the Director of the
Division of Waste Management and Radiation Control. If you desire a statement of the
Division Director ’s position, please submit a written request to the Director, including
copies of documents relevant to your request.

---------- Forwarded message ---------
From: Thomas Ball <[e-mail]>
Date: Wed, Jul 20, 2022 at 10:57 AM
Subject: Trinity Highway Comfort Letter Request
To: Urban, Dale <[e-mail]>, Brad Maulding <[e-mail]>

Dale and Brad,

The Phase I ESA attached to the Trinity Highway request for a comfort letter is marked
Confidential. The submitter does not make a claim of business confidentiality in their
letter. Because there is no claim in the letter we will have to send them a letter asking
if they meant to make a claim or if we should manage the document as a public record.

I need a contact name and address for this letter.
5/26/23, 1:40 PM State of Utah Mail - Fwd: Trinity Highway - Meeting Request
https://mail.google.com/mail/b/ADwNV_dVYFChAafwlXqH0NE62WZhTbi8bUiClmjg_VRizZztnxOy/u/0/?ik=adf9d5e615&view=pt&search=all&permt…14/17

Thanks.

Tom

Tom Ball, CHMM
Manager | Planning and Technical Support Section
Division of Waste Management and Radiation Control

Office: [phone] | Front Desk: [phone]
wasteandradiation.utah.gov

Emails to and from this email address may be considered public records and thus
subject to Utah GRAMA requirements.
Statements made in this email do not constitute the official position of the Director
of the Division of Waste Management and Radiation Control. If you desire a
statement of the Division Director’s position, please submit a written request to the
Director, including copies of documents relevant to your request.

--
Dale T. Urban, P.G. | Environmental Scientist
Phone: [phone]
DISCLAIMER: Statements made in this e‑mail do not constitute the official position of the
Director of the Division of Waste Management and Radiation Control.

--
Dale T. Urban, P.G. | Environmental Scientist
Phone: [phone]
DISCLAIMER: Statements made in this e‑mail do not constitute the official position of the
Director of the Division of Waste Management and Radiation Control.

--
Dale T. Urban, P.G. | Environmental Scientist
Phone: [phone]
5/26/23, 1:40 PM State of Utah Mail - Fwd: Trinity Highway - Meeting Request
https://mail.google.com/mail/b/ADwNV_dVYFChAafwlXqH0NE62WZhTbi8bUiClmjg_VRizZztnxOy/u/0/?ik=adf9d5e615&view=pt&search=all&permt…15/17
DISCLAIMER: Statements made in this e‑mail do not constitute the official position of the Director of the Division
of Waste Management and Radiation Control.

--
Dale T. Urban, P.G. | Environmental Scientist
Phone: [phone]
DISCLAIMER: Statements made in this e‑mail do not constitute the official position of the Director of the Division of Waste
Management and Radiation Control.

--
Dale T. Urban, P.G. | Environmental Scientist
Phone: [phone]
DISCLAIMER: Statements made in this e‑mail do not constitute the official position of the Director of the Division of Waste
Management and Radiation Control.

--
Dale T. Urban, P.G. | Environmental Scientist
Phone: [phone]
DISCLAIMER: Statements made in this e‑mail do not constitute the official position of the Director of the Division of Waste Management and
Radiation Control.

--
Dale T. Urban, P.G. | Environmental Scientist
Phone: [phone]
DISCLAIMER: Statements made in this e‑mail do not constitute the official position of the Director of the Division of Waste Management and
Radiation Control.

--
Dale T. Urban, P.G. | Environmental Scientist
Phone: [phone]
5/26/23, 1:40 PM State of Utah Mail - Fwd: Trinity Highway - Meeting Request
https://mail.google.com/mail/b/ADwNV_dVYFChAafwlXqH0NE62WZhTbi8bUiClmjg_VRizZztnxOy/u/0/?ik=adf9d5e615&view=pt&search=all&permt…16/17
DISCLAIMER: Statements made in this e‑mail do not constitute the official position of the Director of the Division of Waste Management and
Radiation Control.

--

Dale T. Urban, P.G.
Environmental Scientist | Corrective Action Section
Division of Waste Management and Radiation Control

Office: [phone] | Front Desk: [phone]
wasteandradiation.utah.gov

Emails to and from this email address may be considered public records and thus
subject to Utah GRAMA requirements.
Statements made in this email do not constitute the official position of the Director of
the Division of Waste Management and Radiation Control. If you desire a statement
of the Division Director’s position, please submit a written request to the
Director, including copies of documents relevant to your request.

--

Dale T. Urban, P.G.
Environmental Scientist | Corrective Action Section
Division of Waste Management and Radiation Control

Office: [phone] | Front Desk: [phone]
wasteandradiation.utah.gov

Emails to and from this email address may be considered public records and thus
subject to Utah GRAMA requirements.
Statements made in this email do not constitute the official position of the Director
of the Division of Waste Management and Radiation Control. If you desire a
statement of the Division Director’s position, please submit a written request to the
Director, including copies of documents relevant to your request.
5/26/23, 1:40 PM State of Utah Mail - Fwd: Trinity Highway - Meeting Request
https://mail.google.com/mail/b/ADwNV_dVYFChAafwlXqH0NE62WZhTbi8bUiClmjg_VRizZztnxOy/u/0/?ik=adf9d5e615&view=pt&search=all&permt…17/17
4403-23E_Soil Data Summary Table_SWMU 1 & 2 - Metals_Current Soil Data.pdf
80K
Sample Name Sample Depth
(feet bgs)Date Arsenic2 Cadmium Lead Manganese Zinc
SWMU 1 - A1 4.5 3/31/2023 7.21 0.236 J 29.9 316 114
SWMU 1 - A2 7.5 3/31/2023 11.3 9.33 10.1 153 1,060
SWMU 1 - A3 7.5 3/30/2023 4.39 <0.0554 232 129 988
SWMU 1 - A4 6.5 3/30/2023 6.86 <0.0592 166 289 378
SWMU 1 - A5 4.5 3/30/2023 7.51 0.152 J 344 301 1,790
SWMU 1 - A6 7.5 3/30/2023 2.73 1.50 6.65 93.7 546
SWMU 1 - B1 4.5 3/31/2023 5.31 0.0778 J 208 46.6 452
SWMU 1 - B2 7.5 3/31/2023 294 <0.0613 20.9 292 2,060
SWMU 1 - B3 8.5 3/31/2023 39.8 <0.0627 27.4 208 383
SWMU 1 - B4 8.5 3/31/2023 36.6 0.944 20.7 228 1,460
SWMU 1 - B5 7.5 3/31/2023 2.87 0.346 J 477 34.5 8,380
SWMU 1 - B6 4.5 3/31/2023 11.6 <0.0636 4,160 58.7 1,220
SWMU 2 - C1 7.5 4/3/2023 4.36 0.0911 J 16.1 93.2 1,950
SWMU 2 - C2 4.5 4/3/2023 12.7 19.4 1,080 503 38,300
SWMU 2 - C3 7.5 4/3/2023 3.18 3.47 786 V 257 J3 J6 14,900
SWMU 2 - C4 8.5 4/3/2023 <0.647 0.138 J 268 15.1 1,400
SWMU 2 - C5 4.5 4/3/2023 14.3 0.476 J 31.8 1,660 29,500
SWMU 2 - D1 3.5 4/3/2023 26.7 1.11 319 710 20,600
SWMU 2 - D2 4.5 4/3/2023 18.0 0.748 116 315 9,400
SWMU 2 - D3 8.5 4/3/2023 11.7 2.17 32.0 894 13,800
SWMU 2 - D4 4.5 4/3/2023 19.3 0.724 412 515 6,360
SWMU 2 - D5 8.5 4/3/2023 8.57 1.25 958 77.6 7,020
SWMU 2 - E1 4.5 4/5/2023 4.68 <0.0580 14.3 486 12,900
SWMU 2 - E2 4.5 4/5/2023 10.4 1.79 169 230 1,400
SWMU 2 - E3 8.5 4/5/2023 8.09 3.04 68.3 163 5,700
SWMU 2 - E4 3.5 4/5/2023 9.25 0.160 J 60.5 553 666
SWMU 2 - E5 8.5 4/5/2023 47.4 <0.0591 22.2 357 10,000
SWMU 2 - F1 4.5 4/5/2023 11.2 <0.0595 17.2 509 26,700
SWMU 2 - F2 3.5 4/5/2023 16.4 4.94 1,570 316 85,700
SWMU 2 - F3 3.5 4/5/2023 7.47 0.477 J 149 452 4,870
SWMU 2 - F4 4.5 4/5/2023 11.0 <0.0586 26.7 408 79.7
SWMU 2 - F5 4.5 4/5/2023 8.49 <0.0577 30.2 411 85.9
mg/kg - milligrams per kilogram
EPA - Environmental Protection Agency
RSL - Regional Screening Levels
< - analyte not detected at the Reporting Limit or Method Detection Limit (MDL) where applicable.
J - laboratoy identification of the analyte is acceptable; the reported value is an estimate.
J3 - associated batch QC was outside the established quality control range for precision.
J6 - sample matrix interfered with the ability to make any accurate determination; spike value was low.
V - sample concentration was too high to evaluate accurate spike recoveries.
CENTERVILLE FLEX UTAH
EPA Industrial RSLs 100 800 26,000 350,000
TABLE 1
SUMMARY OF SLUDGE AND SOIL ANALYTICAL RESULTS - METALS
SOLID WASTE MANAGEMENT UNIT NO.'s 1 & 2
TRINITY HIGHWAY PRODUCTS PROPERTY
950 WEST 400 SOUTH
2 - Arsenic background concentration is based on the accepted baseline standard presented in Table 3-1 of the Risk Assessment (1998).
BOLD exceeds the arsenic background concentration level.
BOLD exceeds the EPA industrial screening levels.
Results in milligrams per kilogram (mg/kg-dry)
Screening Levels 1 33
SWMU NO. 1
SWMU NO. 2
1 - EPA Regional Screening Levels (November 2022) for industrial properties (TR=1E-06, THQ=1.0) cited.