DERR-2024-005484

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-046-24

April 1, 2024

Scott Wetzel
PacifiCorp
1407 West North Temple
Salt Lake City, Utah 84116

Re: Rocky Mountain Power – Power Redevelopment Project Voluntary Cleanup Program
Site #119, Salt Lake City, Salt Lake County

Dear Mr. Wetzel:

The Division of Environmental Response and Remediation (DERR) has reviewed the
following documents as required by the provisions of the Voluntary Cleanup Program (VCP):

• Hill West Environmental, Power District Redevelopment Project- VCP Area ‘A’-
Former AST Area Soil Removal Report, dated January 16, 2024;
• Hill West Environmental, Power District Redevelopment Project- VCP Area ‘A’- Coal
Removal Completion Report, dated January 29, 2024; and
• Hill West Environmental, Power District Redevelopment Project- Jordan River
Additional Sediment Assessment Report, dated February 1, 2024.

The DERR has attached technical comments for each report in this letter. Several of the
comments have a similar theme and were included with each set of technical comments to ensure
the reports are stand-alone documents once they are accepted by the DERR. Please work with your
environmental professional to address the DERR comments and submit the revised documents.
Please note additional actions are still necessary to complete the Remedial Action Plan including
removing the building in the northwest corner of Area A as well as finalizing a Site Management
Plan and Environmental Covenant.

Page 2
Thank you for your participation in the VCP. If you have any questions about this letter or
the enclosed comments, please contact me at [phone].

Sincerely,

Christopher Howell P.G., Project Manager
Division of Environmental Response and Remediation

CJH/tt

Enclosure: Technical Comments

cc: Claude Dahlk, Hill West Environmental
Ron Lund, Environmental Health Director, Salt Lake County Health Department

Chris Howell (Apr 1, 2024 12:05 MDT)
Page 3
DERR Review Comments – VCP Area ‘A’- Former AST Area Soil Removal Report
Dated January 16, 2024
Rocky Mountain Power VCP Site #119
General Comments:
1. Please do not assume that a remedy has already been accepted for impacted material along
the banks of the Jordan River. Please revise the report to state that impacted soil remains
on-site and along the banks of the Jordan River that exceeds cleanup levels and additional
actions will be proposed.
2. With respect to General Comment #1, a remedial approach should be proposed as an
amendment to the Area A Remedial Action Plan (RAP) to address the comment.
3. On January 17, 2024, EPA published the Updated Residential Soil Lead Guidance. This
guidance took effect immediately and lowered the residential lead screening number from
400 mg/kg to 200 mg/kg. The DERR has adopted this lead screening number to ensure the
health and safety of the public. The RAP for Area A is intended for commercial use, so the
remedial approach does not need to be altered. However, the data tables and text should
incorporate this new residential screening level to account for any potential change in land
use. Please review the data in this report and incorporate the new residential lead screening
number.
4. Multiple Utah Asbestos Program Certification Cards have expired as of the date of this
report. Please update the report with current asbestos certifications.
Specific Comments:
5. Section 6.4, pages 6-3 to 6-4- For the asbestos abatement and disposal work completed in
the Former AST Area, compliance and coordination with the UDEQ Division of Air
Quality Air Toxics, Lead and Asbestos (ATLAS) Program is a requirement of the RAP.
Please revise the text to address this comment and provide documentation of compliance
with the ATLAS Program requirements.
6. Table 1- Please incorporate the site-specific arsenic cleanup level identified in the Area A
RAP and the updated residential lead screening level to ensure this table is complete.
7. Tables 1-3- Please report concentrations for AA-24 and AA-26 that remain in Area A.
8. Appendix A, Attachment 3- This report has a formatting error and cannot be viewed.
Please address the formatting so the document can be reviewed.

Page 4
DERR Review Comments – Jordan River Additional Sediment Assessment Report
Dated February 1, 2024
Rocky Mountain Power VCP Site #119
General Comments:
1. Please remove “VCP Area ‘A’ “from the title of this report.
2. New data indicates that contamination exceeds cleanup levels along the banks of the
Jordan River. This may pose a risk of being released into the river due to future erosion
and flooding events. To address this concern, the DERR requests an addendum to the Area
A Remedial Action Plan (RAP) proposing a remedial approach to address this potential
risk. Remedial work on other portions of Area A can continue under the current Area A
RAP.
3. Sampling results and conclusions should assess if arsenic values exceed the cleanup level
of 14 mg/kg established in the Area A RAP. Please review and revise the text, tables (e.g.
Table 1), and figures as necessary. If contamination remains in place above the cleanup
level, a strategy should be proposed to manage the site.
4. On January 17, 2024, EPA published the Updated Residential Soil Lead Guidance. This
guidance took effect immediately and effectively lowered the residential lead screening
number from 400 mg/kg to 200 mg/kg. The DERR has adopted this lead screening number
to ensure the health and safety of the public. The RAP for Area A is intended for
commercial use, so the remedial approach does not need to be altered. However, the data
tables and text should incorporate this new residential screening level to account for any
potential change in land use. Please review the data in this report and incorporate the new
residential lead screening number.

Specific Comments:
5. Section 2.2, page 2-2- This report presents information related to the eastern boundary of
the VCP Area ‘A’ as well as sediment within the Jordan River. Please update the text to
reflect this distinction.
6. Section 3.3.1, page 3-3- Please revise the name of “West North Temple Street” to “North
Temple Street”.
7. Sections 4.2.1 and 6.2.1, bullet items discussing lead- the screening values for lead are
incorrect. Please review and revise as necessary.
8. Section 6.3, page 6-4- The conclusion should clearly state that contaminated soil is located
along the bank of the Jordan River at both depth intervals. Although current conditions
along the river bank may be stable, a remedial approach is necessary to address the
potential release of contaminated soil into the river from future erosion or flooding events
as stated in General Comment #2. Please revise the text to address this comment.
9. Section 6.3, page 6-4- Natural background concentrations of native soil have not been
thoroughly evaluated in the Jordan River sampling. Please remove “…and from
background levels of native soil” from the text.

Page 5
DERR Review Comments – VCP Area ‘A’- Coal Removal Completion Report
Dated January 16, 2024
Rocky Mountain Power VCP Site #119

General Comments:
1. This report documented the removal of coal and impacted soil from Area A and did not
include an additional monitoring plan. To align with the accepted Coal Removal
Management Plan, please title this document “VCP Area ‘A’- Coal Removal Completion
Report.
2. On January 17, 2024, EPA published the Updated Residential Soil Lead Guidance. This
guidance took effect immediately and effectively lowered the residential lead screening
number from 400 mg/kg to 200 mg/kg. The DERR has adopted this lead screening number
to ensure the health and safety of the public. The Remedial Action Plan (RAP) for Area A
is intended for commercial use, so the remedial approach does not need to be altered.
However, the data tables and text should incorporate this new residential screening level to
account for any potential change in land use. Please review the data in this report and
incorporate the new residential lead screening number.
3. Sampling results and conclusions should assess if arsenic values exceed the cleanup level
of 14 mg/kg established in the Area A RAP. Please review and revise the text, tables (e.g.
Table 1), and figures as necessary. If contamination remains in place above the cleanup
level, a strategy should be proposed to manage the site.
4. Multiple Utah Asbestos Program Certification Cards have expired as of the date of this
report. Please update the report with current asbestos certifications.
Specific Comments:
1. Sections 6.3.1 and 6.4- The post-excavation sampling identified SVOCs above residential
RSLs but below the commercial cleanup levels. Please review the data and revise the text
accordingly.
2. Section 6.5- For the asbestos abatement and disposal work completed in the Coal Area,
compliance and coordination with the UDEQ Division of Air Quality Air Toxics, Lead and
Asbestos (ATLAS) Program is a component of the RAP. Please revise the text to address
this comment and provide documentation of acceptance from the ATLAS Program.
3. Table 3- Please highlight that sample location CP-03 NE Corner was over-excavated to
remove contaminated soil exceeding cleanup goals.