DERR-2025-000998

WASATCH ENVIRONMENTAL, INC.
ENVIRONMENTAL SCIENCE AND ENGINEERING

2410 WEST CALIFORNIA AVENUE
SALT LAKE CITY, UTAH 84104
PHONE [phone]
FAX [phone]
e-mail: [e-mail]
www.wasatch-environmental.com

CORRECTIVE ACTION PLAN
Vacant Redevelopment Parcel
2186 South Washington Boulevard
Ogden, Utah
Facility Identification No. 1200646
Release Site NQT

Project No. 1897-002

Prepared for:

Mr. Mark Crim
Utah Department of Environmental Quality
Division of Environmental Response and Remediation
Underground Storage Tank Branch
P.O. Box 144840
Salt Lake City, UT 84114-4840

February 5, 2025

Prepared by:

Wasatch Environmental, Inc.
2410 West California Avenue
Salt Lake City, UT 84104

________________________________________
Christopher J. Nolan, P.G.
Senior Project Manager
Utah Certified UST Consultant CC0118

Corrective Action Plan 2186 South Washington Boulevard
Wasatch Environmental, Inc. Page i
TABLE OF CONTENTS
Section Page No.
1. INTRODUCTION ............................................................................................................. 1
1.1 Site Description ................................................................................................................... 1
1.2 Site Background .................................................................................................................. 1
1.3 Objective ............................................................................................................................. 2
1.4 Project Milestones ............................................................................................................... 2
2. CORRECTIVE ACTION .................................................................................................. 2
2.1 Site Characteristics ............................................................................................................. 2
2.2 Land Use ............................................................................................................................. 2
2.3 Proposed Cleanup Levels ................................................................................................... 3
2.4 Proposed Corrective Action Measures ............................................................................... 3
3. CORRECTIVE ACTION DESIGN .................................................................................... 3
3.1 Excavation and Off-Site Disposal of Impacted Soil ............................................................ 3
4. PERMITTING REQUIREMENTS ..................................................................................... 4
4.1 Blue Stakes Utility Clearance Request ............................................................................... 4
5. PUBLIC NOTIFICATION ................................................................................................. 4
6. SAMPLING AND ANALYSIS ........................................................................................... 4
6.1 Waste Characterization Sampling ....................................................................................... 4
6.2 Excavation Confirmation Soil Sampling .............................................................................. 4
6.3 Excavation Confirmation Groundwater Sampling ............................................................... 4
6.4 CAP Implementation Report ............................................................................................... 5

FIGURES

Figure 1 – Site Location Map
Figure 2 – Cardno Sample Location Map

APPENDIX

Appendix A – Public Notification
Corrective Action Plan 2186 South Washington Boulevard
Wasatch Environmental, Inc. Page 1
CORRECTIVE ACTION PLAN
VACANT REDEVELOPMENT PARCEL
2186 SOUTH WASHINGTON BOULEVARD
OGDEN, UTAH

1. INTRODUCTION

On behalf of Suburban Land Reserve, Inc. (SLR), the current owner of the vacant redevelopment parcel,
located at 2186 South Washington Boulevard in Ogden, Utah (Site), Wasatch Environmental, Inc.,
(Wasatch) has prepared this Corrective Action Plan (CAP) for addressing residual petroleum hydrocarbon
impacts to soil that have been identified at the Site.

1.1 Site Description

The Site is located at 2186 South Washington Boulevard in Ogden Utah, on the northeast corner of the
intersection of Washington Boulevard and 22nd Street. The Site is currently vacant land. The Site was
historically a vehicle service station and gasoline retailer for approximately 40 years between 1930 and
1970. The Site is a Leaking Underground Storage Tank (LUST) site identified as Facility ID 1200646 and
Release Site NQT. Additional details are provided in Section 1.2 of this CAP.

1.2 Site Background

Multiple environmental investigations have been conducted at the Site beginning in 2010. The Site was
identified as containing a dry cleaner on the northern portion and a service station on the southern portion
from the 1930s to 1970s. In January 2018, six underground storage tanks (USTs) were removed from
the Site. Subsequent soil and groundwater investigations by Cardno concluded that:

“With the residual soil contamination allowed to remain in place at depths ranging between 12.5
ft. and 15 ft. below ground surface, under the current land use, there is no pathway for exposure
to any receptors. For any future redevelopment of the Site a Si te Management Plan (SMP) to
address future proposed land uses and potential changes to exposure may need to be
addressed. At the time of any proposed redevelopment of the Site, the Utah DERR [Division of
Environmental Response and Remediation] would need to be contacted to address any NFA [No
Further Action] status applicable for the current vacant and undeveloped land use.”

On March 13, 2024, a letter was sent to SLR by the Utah Division of Environmental Response and
Remediation (DERR) requesting that a Corrective Action Plan (CAP) be submitted as outlined in an
earlier letter dated March 5, 2020.

The March 2020 letter from DERR reviews the Cardno report and outlined pathways to address the
residual petroleum impacts at the Site in order to receive a NFA letter closing the release. The letter
describes two areas of remaining soil impacts that need to be addressed. Shallow contamination “from
about 3 to 5 feet depth at the TP-5 and TP-16 locations which appears to be of limited horizontal and
vertical extent and must be cleaned up prior to NFA consideration”.

Deeper contamination is present at a depth of 12 to 16 feet below grade extending from the west and
northwest of the former USTs to the western property boundary. It is estimated to be 233 cubic yards of
material. Cardno’s conclusion that the deeper impacts do not represent a pathway to exposure if allowed
to remain in place is agreed with by DERR with their descriptions of conditions needed to obtain a NFA
while leaving the deeper impacts in place.

“Pathway i) NFA is possible following the removal of the shallow contamination at the
TP-5 and TP-16 locations. Regarding the deeper waste, the DERR may produce an NFA
letter coupled with a site map showing the remaining site contamination and other
descriptions of the contamination that is above the Initial Screening Level (ISL) cleanup
standard. In this case, SLR would be the responsible party to the petroleum
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Wasatch Environmental, Inc. Page 2
contamination and be responsible for environmental site safety and proper disposal of
that waste, should it be encountered or disturbed during future development of the site.”

“Pathway ii) NFA is possible following the removal of the shallow contamination at the
TP-5 and TP-16 locations. Regarding the deeper waste, the DERR may produce an NFA
letter coupled with an Environmental Covenant that runs with the land. In this case,
future landowners would be a responsible party to the petroleum contamination and be
responsible for environmental site safety and proper disposal of that waste, should it be
encountered or disturbed during future development of the site.”

SLR agrees that the shallow soil be addressed, and the deeper soil contamination remain in place until
final redevelopment plans for the Site are determined.

The DERR held a CAP meeting by phone with Wasatch Environmental on February 5, 2025, and
addressed proposed corrective action activities, cleanup goals, and DERR requirements moving forward.
The meeting was attended by Mark Crim (DERR Project Manager), and Christopher J. Nolan, P.G.
(Wasatch).

1.3 Objective

The objective of this CAP is to obtain a NFA letter following remediation of the shallow contamination at
the TP-5 and TP-16 locations. Regarding the deeper waste, the DERR may produce an NFA letter
coupled with a site map showing the remaining site contamination and other descriptions of the
contamination that is above the ISL cleanup standard. In this case, SLR would be the responsible party
to the petroleum contamination and be responsible for environmental site safety and proper disposal of
that waste, should it be encountered or disturbed during future development of the site.

1.4 Project Milestones

The following are the major milestones for the corrective action and the estimated dates of completion:
• Public notification posted; public comment period commences – February 2025
• Blue Stake utility clearance completed – February 2025
• Public comment period closes - February 2025
• Final approval of the CAP by the Utah DERR – March 2025
• Commencement of corrective action field work – March 2025
• Corrective action field work completed – March 2025
• Corrective action implementation report submitted to Utah DERR – March 2025
• Formal regulatory closure granted by Utah DERR - April 2025

2. CORRECTIVE ACTION

2.1 Site Characteristics

The test pit logs provided by AGEC provide details as to subsurface conditions. At TP-16 concrete debris
with petroleum odor was encountered at approximately 4 feet below ground surface (bgs). At TP-5 silty
sand fill with minor concrete and asphalt debris were encountered at a depth of 3.5 feet, and elevated
volatile organic compound readings were identified at approximately 2.5 to 3.5 feet bgs.

2.2 Land Use

The Site is currently vacant land. The Site was historically a vehicle service station and gasoline retailer
for approximately 40 years between 1930 and 1970. The area is mainly mixed commercial and
residential land use. There are residential homes adjoining to the east and commercial properties located
across 22nd Street to the south. The Ogden Temple is located to the West across Washington Boulevard.
Corrective Action Plan 2186 South Washington Boulevard
Wasatch Environmental, Inc. Page 3

2.3 Proposed Cleanup Levels

Because the potential future land use could include residential use, the proposed cleanup levels for this
corrective action will be Utah ISLs. The proposed cleanup levels are presented below:

Proposed Soil Cleanup Levels
2186 South Washington Boulevard
Ogden, Utah
(all values in milligrams per kilogram (parts per million))

Compound Cleanup Level
TPH-DRO 500
TRPH (O&G) 1,000
TPH-GRO 150
MTBE 0.3
Benzene 0.2
Toluene
Ethylbenzene
Xylenes
Naphthalene
9
5
142
51

2.4 Proposed Corrective Action Measures

Given the site characteristics, nature and distribution of contaminants; Wasatch proposes excavation and
off-site disposal of petroleum-contaminated shallow soil exhibiting petroleum hydrocarbon concentrations
above the ISLs at each of the two (TP-5 and TP-16) locations of impacts. Details regarding these
corrective action measures are provided in Section 3 of this CAP.

3. CORRECTIVE ACTION DESIGN

3.1 Excavation and Off-Site Disposal of Impacted Soil

Wasatch proposes excavating soil contaminated with petroleum hydrocarbons at concentrations above
the ISLs. Excavation efforts would be guided by laboratory analytical data, field screening with a
photoionization detector (PID), and field observations of staining and petroleum hydrocarbon odors. Over
burden soil which is not impacted by petroleum hydrocarbons may be segregated, stockpiled, and re-
used for backfilling if analytical results demonstrate that it meets the Cleanup Levels. Wasatch would
oversee the excavation contractor during the excavation and removal of impacted soils from the Site.
Impacted soils are planned for removal to meet ISLs. Wasatch anticipates excavating to a maximum
depth of approximately 5 to 6 feet bgs.

Based on previous sampling results, we anticipated the areas of the excavations to be approximately 15
by 15 feet at each area. Impacted soil would be removed and transported off-site for disposal at the
Moulding and Sons Landfill, located west of the Site, at 10485 West 900 South, Ogden, Utah. Wasatch
estimates that a total of approximately 126 tons of impacted soil will be removed and disposed of off-site
from the excavation activities. The anticipated excavation extent is shown on Figure 2. Upon completion
of the confirmation sampling and review of the analytical results confirming that the ISLs were met, the
excavations will be backfilled and compacted with clean fill material.

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4. PERMITTING REQUIREMENTS

4.1 Blue Stakes Utility Clearance Request

A utility clearance request will be submitted to Blue Stakes by the remediation contractor at least two full
business days prior to the commencement of the excavation work. The Blue Stakes utility clearance will
be renewed every 12 calendar days for the duration of the project, if needed.

5. PUBLIC NOTIFICATION

Public notification will be completed, and any relevant comments addressed, prior to final DERR-approval
of this CAP. Public notification will be completed by hand-delivering flyers to businesses and residents
located on properties adjoining the Site. An example of the public notification is presented in Appendix A.
The dates and addresses where the flyers are delivered will be documented in field notes. The 15-day
public comment period is expected to begin in February and end in February 2025. A copy of the CAP
will be made available for review online at http://eqedocs.utah.gov, and at the DERR office building.

6. SAMPLING AND ANALYSIS

6.1 Waste Characterization Sampling

Once the soil has been excavated and stockpiled, the soil will be sampled and analyzed to profile into the
Moulding and Sons landfill. Copies of the stockpile sampling results, authorization to accept the soil, and
weigh tickets will be included in the CAP Implementation Report.

6.2 Excavation Confirmation Soil Sampling

To confirm that cleanup objectives have been met, Wasatch will collect a floor sample from the floor
within the excavations and a minimum of one sidewall sample will be collected from each sidewall of each
excavation.

If either excavation is larger than anticipated, additional floor and sidewall confirmation samples will be
collected.

Soil confirmation sample locations from the excavation walls will be biased to the impacted depth
intervals as indicated by subsurface investigation data, field observations of staining, petroleum
hydrocarbon odors, and elevated PID readings. Soil confirmation samples collected from the walls and
floor of the excavations will be collected using the track hoe bucket.

Soil confirmation samples will be collected with gloved hands and dispensed into laboratory supplied 2-
ounce glass jars. The samples will be placed on ice and delivered to Chemtech-Ford, under chain of
custody protocol, for analysis of Total Recoverable Petroleum Hydrocarbons (TRPH) with silica gel
treatment (SGT) by U.S. EPA method 1664B-SGTMod, TPH-GRO and methyl tertiary butyl ether (MTBE)
benzene, toluene, ethyl benzene, xylenes and naphthalene (MBTEXN) by U.S. EPA Method 8260C, and
total petroleum hydrocarbons diesel range organics (TPH-DRO) by U.S. EPA Method 8015D with SGT.
All samples will be analyzed on a laboratory expedited turn-around time.

6.3 Excavation Confirmation Groundwater Sampling

Wasatch does not anticipate encountering groundwater within either shallow excavation. If groundwater
is encountered, Wasatch will collect at least one groundwater confirmation sample from each of the open
excavation using a Teflon dipper. The groundwater confirmation samples will be collected with gloved
hands and dispensed into the appropriate laboratory supplied/preserved jars for the required analysis.
Corrective Action Plan 2186 South Washington Boulevard
Wasatch Environmental, Inc. Page 5
The samples will be immediately placed on ice and hand delivered to Chemtech-Ford, under chain of
custody protocol, for analysis of the same analytes as the soil confirmation samples .

6.4 CAP Implementation Report

Wasatch will prepare a CAP Implementation Report documenting the action completed during the soil
remediation activities. The report will include narrative text, data tables, analytical laboratory report, a
sample location map, weight tickets and tonnage of soil disposed, and document the Public Notice
process. The report will request that NFA for the shallow soils be granted by the Utah DERR.

Figures

The use or reuse of this information is restricted to the referenced document unless otherwise authorized.
Wasatch Environmental Copyright 2006
SLR PROPERTY CAP AND REMEDIATION WEI 1897-002
Site Location Map Figure 1
22nd Street
Was
h
i
n
g
t
o
n

B
o
u
l
e
v
a
r
d
TP-5
TP-16
Approximate Location of Proposed Excavation
The use or reuse of this information is restricted to the referenced document unless otherwise authorized.
Wasatch Environmental Copyright 2006
Cardno Sample Location Map Figure 2
SLR PROPERTY CAP AND REMEDIATION WEI 1897-002

Appendix A
Public Notice

PUBLIC NOTICE

PUBLIC NOTIFICATION AND COMMENT PERIOD
February 13, 2025 – February 27, 2025
Start Date End Date

Leaking Underground Storage Tank Petroleum Cleanup Project
(Facility ID 1200646, Release Site NQT, located at 2186, Washington Blvd , Ogden, Utah)

Land Reserve is requesting approval from the Utah Department of Environmental Quality, Division
of Environmental Response and Remediation (DERR) of a Corrective Action Plan (CAP) to
remediate petroleum -contaminated soil at the vacant property located at 2186 Washington Blvd .in
Ogden, Utah . The environmental consultant for this project is Wasatch Environmental, Inc .,
(Wasatch).

Site Description
Multiple environmental investigations have been conducted on the Property beginning in 2010. The
Property was identified as containing a dry cleaner on the northern portion and a service station on the
southern portion from the 1930s to 1970s. In January 2018, six underground storage tanks (USTs) were
removed from the Property.

The March 2020 letter from DERR reviews the Cardno report and outlined pathways to address the
residual petroleum impacts at the Property in order to receive a NFA letter closing the petroleum release.
The letter describes two areas of remaining soil impacts that need to be addressed. Shallow
contamination from about 3 to 5 feet depth at the TP-5 and TP-16 locations which appears to be of limited
horizontal and vertical extent and must be cleaned up prior to NFA consideration.

A letter was sent to Land Reserve by the Utah DERR requesting that a Corrective Action Plan (CAP) be
submitted as outlined in an earlier letter dated March 5, 2020.

Cleanup Measures
The proposed cleanup approach is excavation and off-site disposal of the petroleum impacted soil.

Schedule
Corrective action work is planned to begin March, 202 5 and is expected to take approximately one
week to complete.
To Submit Comments or For More Information
A copy of the Corrective Action Plan summary for this site can be obtained by submitting an email
request to either Christopher Nolan cn@wasatch -environmental.com , or Mark Crim
mcrim @utah.gov . To submit written comments or for additional information, please contact
(before February 27, 2025 ):

Mark Crim, Project Manager (801 -536-4100)
Division of Environmental Response and Remediation
195 North 1950 West
P.O. Box 144840
Salt Lake City, Utah 84114 -4840