DSHW-2025-000676

St. George Place Development (Risk Assessment) R&R Report #25-009812 (01-24-2025)
Washington County Landfill

R & R Environmental, Inc.
47 West 9000 South, Suite #2, Sandy, Utah 84070 [phone]: Office   [phone]: Fax

February 4, 2025

Matt Sullivan, Environmental Scientist
Utah Division of Waste Management and Radiation Control
Multi Agency State Office Building
195 North 1950 West, DEQ Second Floor
Salt Lake City, Utah 84116
[phone]
[e-mail]
[e-mail]

RE: St. George Place Development (Risk Assessment)
Washington County Landfill
R&R Report #25-009812 (02-04-2025)

Background History:

The St. George Place development located at 745 South Bluff Street, St. George Utah, was
formerly known as the “K-Mart Shopping Center” or the “Albertson’s Shopping Center” is a
multiunit retail location that is currently under construction. The original construction was
conducted in 1983. Bluff Springs LLC owns and is developing the property with includes new
construction as well as renovating existing structures. The various buildings were inspected for
asbestos by Sullivan Builders in February of 2023, five (5) inspection reports were produced. No
vermiculite loose-fill insulation was identified in any of the inspections. Construction began on
August 5, 2024. Some of the exterior walls were demolished and others were cut into beginning
in August.

During the month of December, vermiculite loose-fill insulation was noted by the General
Contractor (R & O Construction) and Subcontractor “Truline Cut’N Core” coming from the
exterior masonry walls. The original inspection firm, Sullivan Builders was contacted, and the
vermiculite material was sampled on December 23, 2024. The material was analyzed by PLM,
verified by Transmission Electron Microscopy (TEM), point-counted, and found to contain up to
1.8% tremolite asbestos. This material is friable and is classified as a regulated asbestos
containing material (RACM). Upon receipt of the report, the General Contractor shut the project
down on December 30, 2024. R & R was contacted to provide a Project Design and oversite for
the clean-up and arrived on January 2, 2025.

St. George Place Development (Risk Assessment) R&R Report #25-009812 (01-24-2025)
Washington County Landfill

Site conditions found on January 2, 2025, discovered all the interior areas of buildings to be
contaminated with vermiculite loose fill insulation. The exterior around the buildings was also
found to be contaminated with vermiculite material to approximately 15 feet from the wall.
Dumpsters, equipment, and construction materials were also found to be contaminated with
vermiculite material. Multiple dumpsters of construction debris (one dumpster included
vermiculite material) were taken off-site to the Washington County Landfill.

On January 15, 2025, R&R inspector Jamison Moss (escorted by Republic Services personnel)
walked the designated area (working face) of the Washington County Landfill looking for
vermiculite loose fill insulation. Mr. Moss was looking for any contents of the contaminated
dumpster, consisting of construction debris and vermiculite. No visible vermiculite was detected,
no contents of the dumpster were found. An existing photo of the dumpster contents taken on
January 2, 2025 was used in the search process. The contaminated area is estimated by landfill
personnel to be ~120’ long by ~50’ wide, and ~5-10’ deep. This area was flagged by the
inspector for future location and also flown by drone to verify surface measurement.

Risk Management Proposal:

In as much as the dumpster contents and/or vermiculite could not be identified at the landfill,
R&R proposes to conduct the following air sampling to help assess potential asbestos exposure
to landfill personnel and members of the community.

The Consultant (R&R) will determine wind direction at the start of the sampling and on each
additional day of sampling. R&R will set air sampling pumps in the upwind and downwind
locations on each day of the sampling. A minimum of two additional sampling locations
collected at ninety-degree angles to the upwind and downwind sampling sites. Additional
sampling locations will also be collected to adequately capture potential asbestos exposure
from two to three (2-3) landfill personnel at any and all locations of the project site. Samples
will be initially analyzed using phase contrast microscopy (PCM) and transmission electron
microscopy (TEM) will be used, if necessary. Electronic copies of all accredited asbestos
laboratory results will be sent to the DEQ within 72-hours of receipt on business days.

R&R initially proposes three days of the sampling as outlined above. For PCM, the level of
airborne fibers for each of the samples inside the work area should be less than PCM’s limit of
reliable quantification, 0.0075 or fewer fibers per cubic centimeter (f/cc) (with a minimum
volume of 3,850 liters). Samples exceeding this limit, will be analyzed via TEM.

All TEM samples will be sent 1-day delivery or hand carried to the accredited asbestos laboratory
within 48-hours of determining PCM sample analysis results above 0.0075 f/cc on business days. All
samples will be sent with requested analysis of 24-hours or less of receipt by the accredited asbestos
laboratory on business days. Electronic copies of all accredited asbestos laboratory results will be sent
to the DEQ within 24-hours of receipt on business days.

St. George Place Development (Risk Assessment) R&R Report #25-009812 (01-24-2025)
Washington County Landfill

If the first six TEM sample results are below the AHERA clearance criteria of 70 structures per
square millimeter (S/mm2) based on a 1,199 liter sample for a 25 mm cassette or on a 2,799 liter
sample for a 37 mm cassette, the consultant may propose to the DEQ raising the TEM analysis
trigger level to the PCM accredited asbestos laboratory level of 0.010 fibers per cubic centimeter
(f/cc). If the sample volume is less than 1199 liters, the AHERA clearance criteria of 70 S/mm2 will
be reduced proportionally. Air sampling results above the appropriate TEM analysis trigger level
will require an immediate evaluation.

Upon completion of sampling, R&R will prepare and submit to Utah DEQ a FINAL project
closeout report containing: 1) a summary of sampling activities including a photo log and
sampling map; 2) copies of accredited asbestos laboratory results; and 3) the names and
certification information for all R&R personnel participating in the sampling activities. The
report must be submitted no later than 10 days following the completion of sampling activities.

Summary (Conclusion):

The FINAL project closeout report will be used as the basis for further discussion with DEQ
regarding next steps for recommendations for clean-up (if any).

Sincerely,

R & R ENVIRONMENTAL, INC.

David C. Roskelley, MSPH, CIH, CSP
State of Utah Inspector #ASB-1370
State of Utah Company Asbestos Certification #ASBC-237
President