DERR-2025-004047

WASATCH ENVIRONMENTAL, INC.
ENVIRONMENTAL SCIENCE AND ENGINEERING

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

REMEDIAL ACTION PLAN
FORMER PRIDE CLEANERS
4358 SOUTH 900 EAST
MILLCREEK, UTAH
VOLUNTARY CLEANUP PROGRAM SITE NO. C124

Project No. 2639-001E

Prepared for:

Mr. Jale Elsmore
Washmore Laundry, LLC
4358 South 900 East
Millcreek, Utah 84124

and

Utah Department of Environmental Quality
Division of Environmental Response and Remediation
Voluntary Cleanup Program
Mr. Bill Rees and
Ms. Leigh Anderson
P.O. Box 144840
Salt Lake City, UT 84114-4840

Prepared by:

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

________________________________________
Blake B. Downey, P.G.
Vice President and Senior Project Hydrogeologist

March 26, 2025

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TABLE OF CONTENTS
Section Page No.
1. INTRODUCTION ............................................................................................................. 1
1.1 Site Description ................................................................................................................... 1
1.2 Site Background .................................................................................................................. 1
1.3 Conceptual Site Model (CSM) ............................................................................................ 5
1.4 Objectives ........................................................................................................................... 7
2. REMEDIAL ACTION SELECTION ................................................................................... 7
2.1 Contaminants of Concern ................................................................................................... 7
2.2 Proposed Cleanup Goals .................................................................................................... 7
2.3 Proposed Remedial Action Measures ................................................................................. 8
2.4 Proposed Engineering and Institutional Controls ................................................................ 8
2.5 Proposed Groundwater Monitoring ..................................................................................... 8
3. REMEDIAL ACTION DESIGN AND CONSTRUCTION ................................................... 9
3.1 VCP-Requested Sampling and Research .......................................................................... 9
3.2 Impacted Soil Excavation and Off-Site Disposal ................................................................ 9
3.3 General Demolition and Construction Issues ................................................................... 10
3.4 Installation of Vapor Barriers ............................................................................................. 10
4. PERMITTING REQUIREMENTS ................................................................................... 10
4.1 Blue Stakes Utility Clearance Request ............................................................................. 10
4.2 Storm Water Pollution Prevention Plan (SWPPP) ............................................................ 10
4.3 Utah Division of Air Quality (DAQ) Requirements ............................................................ 11
4.4 Salt Lake County Health Department ............................................................................... 11
4.5 Millcreek City Permits........................................................................................................ 11
4.6 Underground Injection Control Permit............................................................................... 11
5. PUBLIC NOTIFICATION AND PARTICIPATION ........................................................... 12
6. SAMPLING AND ANALYSIS ......................................................................................... 13
6.1 VCP-Requested Monitoring Well Sampling ...................................................................... 13
6.2 Waste Characterization Sampling ..................................................................................... 13
6.3 Soil Confirmation Sampling ............................................................................................... 14
6.4 Groundwater Confirmation Sampling ................................................................................ 14
6.5 Groundwater Monitoring Sampling ................................................................................... 15
7. CONTINGENCY PLANNING ......................................................................................... 15
8. REMEDIAL ACTION IMPLEMENTATION REPORT ...................................................... 16
9. HEALTH AND SAFETY ................................................................................................. 17
10. PROJECT SCHEDULE ................................................................................................. 17

FIGURES
Figure 1 – Site Location Map
Figure 2 – Parcel Map
Figure 3 – Vicinity Property Use Map
Figure 4 – Historical Sample Location and PCE, Arsenic, and TPH-GR)/DRO Contour Map
Figure 5 – PCE in Groundwater Concentration Map
Figure 6 – Arsenic, TPH-GRO, and TPH-DRO in Groundwater Concentration Map
Figure 7 – Soil Exceedance Map
Figure 8 – September 14, 2023, Shallow Piezometric Surface Map
Figure 9 – September 14, 2023, Intermediate Piezometric Surface Map
Figure 10 – Conceptual Site Model (CSM)
Figure 11 – Proposed Monitoring Well Network
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APPENDICES
Appendix A – Public Notice
Appendix B – Fugitive Emission Monitoring Plan
Appendix C – Vapor Barrier Information
Appendix D – DERR Site-Specific Cleanup Level Document

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REMEDIAL ACTION PLAN
FORMER PRIDE CLEANERS
4358 SOUTH 900 EAST
MILLCREEK, UTAH
VOLUNTARY CLEANUP PROGRAM SITE NO. C124

1. INTRODUCTION

On behalf of Washmore Laundry, LLC, the current property owner of the former Pride Cleaners property
(Site) and the Volunteer, Wasatch Environmental, Inc., (Wasatch) has prepared this Remedial Action
Plan (RAP) for addressing heavy metals, volatile organic compound, per- and polyfluoroalkyl substances
(PFAS), and petroleum hydrocarbon impacts to soil and groundwater that have been identified at the Site.
This RAP is intended to be used in conjunction with the Quality Assurance Project Plan (QAPP) dated
February 22, 2023, the Sampling and Analysis Plan (SAP) dated February 22, 2023, and individual work
plans (if required) prepared for the Site.

The Site is also identified as the Washmore Laundry facility (I.D. 4002623) by the Utah Petroleum
Storage Tank (PST) Branch and had been assigned as release site OFD regarding the fuel release that
originated from the former on-Site underground storage tanks (USTs). All work related to Release Site
OFD will be done under the direction of a Utah-certified PST Consultant and all environmental samples
will be collected by a Utah-certified soil and groundwater sampler. This RAP is acting as a Corrective
Action Plan (CAP) for the PST Branch regarding Release Site OFD.

1.1 Site Description

The Site is located along the western edge of 900 East at 4358 South in Millcreek, Utah (as shown on
Figure 1). The Site totals 0.66 acres and is comprised of two parcels. The Site includes the following
Salt Lake County Assessor’s Office tax parcel numbers: 22-05-176-014 and 22-05-176-015 (see Figure
2).

The southern portion of the Site consists of asphalt and concrete pavement, and the extreme western
portion of the Site consists of a gravel storage yard. The northern portion of the Site is developed with a
vacant, single-story, former dry cleaning and laundry building with retail space.

Property use at the Site and surrounding properties is a mix of residential, commercial, and automotive
repair as shown on Figure 3.

1.2 Site Background

Our research indicates that in 1937 the Site consisted of vacant land that may have been used for
agricultural purposes. The original portion of the current building was constructed in 1950/1951 and has
been expanded over time. The current configuration has been present since 1971. The Si te has been
used for dry cleaning and/or general laundry activities since at least 1958 to the present, and a portion of
the on-Site building was used for automotive service/repair. Regulatory files document that the use,
storage, and/or disposal of a variety of common dry cleaning chemicals including trichloroethylene (TCE),
tetrachloroethylene (PCE), or other chemicals, has taken place at the Site.

Wasatch has completed limited subsurface investigation activities on the adjoining north/west property
(900 East Townhomes project). Chlorinated solvent and petroleum impacts to groundwater at
concentrations above the United States Environmental Protection Agency (U.S. EPA) Maximum
Contaminant Levels (MCLs) and the Utah Initial Screening Levels (ISLs) were identified in groundwater,
and impacts to soil gas at concentrations above the U.S. EPA Vapor Intrusion Screening Level (VISL)
Residential Target Sub-Slab and Near-Source Soil Gas Concentrations (TSSGCs) were identified.
Additionally, Wasatch installed three shallow groundwater piezometers. The groundwater elevations
measured from these piezometers indicated the groundwater flow direction was to the nor thwest. Based
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on the groundwater flow direction and the chlorinated solvent concentrations in groundwater, Wasatch
determined that the source of the impacts on the adjoining north/west property was originating from the
Site (which has had long-term historical uses that include dry cleaning and automotive service) and
migrating to the northwest.

The owner (at the time the investigation work was completed) of the adjoining north/west property
provided these data to the Utah Department of Environmental Response and Remediation (DERR) to
obtain an Enforceable Written Assurance (EWA); therefore, these data are in the public domain.

Mr. Jared Doxey with JWD Construction Consulting, LLC, was approached by the Site owner to
redevelop the Site. Given the data from the adjoining north property was provided to the Site owner, Mr.
Doxey contacted Wasatch and requested that investigation activities be completed at the Site to evaluate
the potential release(s) at the Site.

In 2022, Wasatch completed two rounds of investigations at the Site, which consisted of completing a site
inspection and advancing 22 borings at the Site that facilitated the collection and analysis of soil and
groundwater samples. Wasatch also collected six soil gas samples across the Site. The results of the
April 2022 investigation activities are discussed below.

Low concentrations of PCE, below the applicable U.S. EPA MCL, are entering the Site from the adjoining
south automotive repair facility. Additionally, it appears that a minor source of chlorinated solvents is
likely originating from the drum storage area at the Site resulting in the PCE in groundwater exceedances
reported on the western boundary of the Site (western PCE plume).

1,3-butadiene, 1,3,5-trimethylbenzene, and 1,2,4-trimethylbenzene were detected in one or more soil gas
samples at concentrations that exceed the applicable U.S. EPA VISL Residential TSSGC, but below the
U.S. EPA VISL Commercial TSSGCs. PCE and TCE were detected in one or more soil gas samples at
concentrations that exceed the applicable U.S. EPA VISL Residential TSSGC and the U.S. EPA VISL
Commercial TSSGC.

Although the detected concentrations of PCE in soil samples GP-19@8, GP-20@4, GP-20@8, and GP-
21@9 (collected near a floor drain and the area of former PCE-containing equipment) did not exceed the
applicable U.S. EPA RSL for Residential Soil, these detections indicate that this area is a source area for
the eastern chlorinated solvent impacts (eastern PCE plume) at the Site. This is further supported by the
elevated PCE in groundwater and soil gas concentrations detected in this area.

Based on the PCE concentrations detected in groundwater in the GP-22S and GP-22D groundwater
samples, it appears that the PCE impacts have migrated to a depth of at least 30 feet bgs. However, the
groundwater samples were collected as turbid grab samples, and the PCE concentration in groundwater
is likely to decrease, and be more representative of dissolved-phase concentrations, if collected from a
properly installed monitoring well.

Arsenic was detected in all soil samples analyzed for metals at concentrations that exceed both the U.S.
EPA Regional Screening Level (RSL) for Residential Soil and the U.S. EPA RSL for Industrial Soil.
However, it has been Wasatch’s experience/opinion that the detected arsenic concentrations in soil are
within the typical range of background concentrations for the area, and no further evaluation for arsenic in
soil is warranted at this time.

Groundwater samples GP-5S and GP-6 exhibited elevated concentrations of arsenic that exceed the U.S.
EPA MCLs. It is Wasatch’s opinion that these concentrations indicate that a petroleum hydrocarbon
release in this area has likely resulted in the mobilization of arsenic into groundwater due to the lowering
of the pH in groundwater. These samples are located hydraulically downgradient of the western former
USTs located at the Site.

Total petroleum hydrocarbons as gasoline-range organics (TPH-GRO) was detected in soil at
concentrations that exceed the Utah ISL in soil samples GP-6@9’ and GP-7@9’. TPH-GRO and total
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petroleum hydrocarbons as diesel-range organics (TPH-DRO) were detected in groundwater at
concentrations that exceed their Utah ISL in groundwater sample GP-6. Based on the detected
petroleum hydrocarbons in soil, soil gas, and groundwater; it appears the source of the petroleum impacts
originate from the area of the USTs located at the Site. Wasatch acknowledges these impacts are
regulated by the Utah Leaking Underground Storage Tank (LUST) program, and this RAP will be
provided to the LUST program for acceptance or comments.

Wasatch recommended that additional subsurface investigation be completed to further define the nature
and extent of the source areas and further evaluate the impacts at the Site to develop appropriate
mitigation and/or remediation activities to facilitate the proposed redevelopment activities at the Site.
Additionally, Wasatch recommended that the release be reported to the Utah Division of Environmental
Response and Remediation (DERR).

In June 2022, Direct Push Services (DPS) removed the two USTs from the Site. The two USTs contained
petroleum fuels and were utilized by the prior automotive service occupant of the Site. Prior to the
removal of the USTs, DPS submitted a Closure Plan to the Utah DERR for approval. After DERR
approved the closure plan, DPS properly removed the USTs from the Site. The western UST was
approximately 1,000 gallons in capacity and the eastern UST was approximately 500 gallons in capacity.
Based on the closure soil sampling data, a release of petroleum hydrocarbons has occurred from both
USTs.

The closure soil sampling completed by DPS for the USTs that were removed indicated petroleum
hydrocarbon releases have occurred from both of the USTs. Given this and the totality of the soil and
groundwater data collected, it is Wasatch’s opinion that the USTs are the source area for the observed
petroleum hydrocarbon impacts. Additionally, the hydraulically downgradient petroleum hydrocarbon
impacts originating from the former USTs appear to be constrained to the observed smear zone depth
interval located from approximately 9 to 12 feet bgs.

Wasatch recommended that these releases be reported to the Utah DEQ for regulatory oversight and
guidance to achieve closure of the releases.

The owner/operator of the Site has reported the release to the Utah DEQ. As of December 8, 2022, the
Site has been entered into Utah VCP for regulatory oversight and has been assigned VCP Site #C124.
Additionally, given the release from the USTs, the Site was also entered into the Utah DERR Leaking
Underground Storage Tank (LUST) program.

Wasatch recommended additional subsurface investigation to further define the nature and extent of the
source areas and further evaluate the impacts at the Site to develop appropriate mitigation and/or
remediation activities to facilitate the proposed redevelopment activities at the Site.

The Utah VCP requested that additional Site characterization be completed at the Site to facilitate the
development of a RAP.

In 2023, Wasatch completed additional Site characterization activities at the Site, which consisted of
advancing 11 borings of which six were converted into groundwater monitoring wells. Three shallow
wells (MW-1S, MW-2S, and MW-3S) and three intermediate wells (MW-1M, MW-2M, and MW-3M) were
installed, developed, surveyed, and sampled at the Site. Additionally, Wasatch collected four indoor air
and one outdoor air sample at the Site.

Benzene, ethylbenzene, chloroform, and TCE were detected in the ambient air samples at concentrations
that exceeded their applicable U.S. EPA RSL for Industrial and/or Residential Air in one or more samples
collected. However, the OA-1 outdoor air (background) sample exhibited the highest concentrations of
benzene and ethylbenzene. This indicates that the indoor air impacts detected are below the background
outdoor air ethylbenzene and benzene concentrations and are likely not a result of indoor sources o r
vapor intrusion from soil and groundwater impacts.

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PFAS were not detected in the soil samples collected at concentrations that exceed ed the applicable U.S.
EPA RSLs for Residential Soil. PFAS were detected at concentrations that exceeded the U.S. EPA
MCLs or Hazard Index (HI) entering the Site from the upgradient property. The PFAS analytes detected
on-Site were similar to the analytes entering the Site from the upgradient property. There is a potential
that the PFAS impacts originating from the Site may have contributed to the impacted groundwater at the
Site. It is possible that these impacts may be able to be managed through the use of institutional and/or
engineering controls at the Site to prevent potential exposure, but additional sampling may be required to
evaluate the PFAS impacts at, entering the Site from off-Site sources, and migrating off-Site to determine
if active remediation will be necessary.

The closure soil sampling completed by DPS for the USTs that were removed indicated that petroleum
hydrocarbon releases have occurred from both of the USTs. Given this , and the totality of the soil and
groundwater data collected, it is Wasatch’s opinion that the USTs are the source area for the observed
petroleum hydrocarbon impacts. Additionally, the hydraulically downgradient petroleum hydrocarbon
impacts originating from the former USTs appear to be constrained to the observed smear zone depth
interval located from approximately 9 to 12 feet bgs.

The previous direct-push groundwater sample GP-15 exhibited the greatest petroleum hydrocarbon
impacts to groundwater and DERR postulated that another petroleum source may be located in that area.
Wasatch hypothesized to DERR that the elevated petroleum impacts to groundwater in this area were
likely due to the presence of the petroleum smear zone in this area and the collection method that
resulted in a turbid direct-push groundwater sample from this boring. Therefore, monitoring well MW-2S
was placed directly adjacent to the GP-15 boring. Based on the petroleum hydrocarbon data obtained
from groundwater sample MW-2S, TPH-GRO and TPH-DRO were not detected in this sample and no
site-specific cleanup levels (SSCLs) were exceeded by the fractionated data. This supports Wasatch’s
hypothesis that the original grab sample was biased high due to the turbid sample collection method, and
that petroleum hydrocarbon impacts to groundwater appear to be localized around the f ormer UST basins
where elevated soil impacts still remain.

The petroleum-impacted soil within the observed smear zone at the Site appears to be highly weathered.
Based on the soil TPH fractionation data, petroleum impacts to soil within the smear zone do not result in
SSCLs being exceeded. However, Wasatch recommended the elevated petroleum impacts to soil near
the former UST basins (which appear to be localized around the former UST basins) be excavated and
disposed off-Site.

Based on the soil and groundwater data from borings GP-24 and GP-25 and from monitoring wells MW-1
and MW-1M (the western PCE plume source area), no soil impacts in this area exceed applicable U.S.
EPA RSLs for Residential Soil. Additionally, the groundwater impacts appear to originate from the
northwest section of the former drum storage area and the lateral and vertical chlorinated solvent impacts
have been defined for the shallow western PCE plume.

Given the PCE concentration of groundwater sample GP-27 (4.5 µg/L), the lateral extent of the shallow
eastern PCE plume has been defined.

Based on the totality of the soil and groundwater data collected from the eastern PCE plume source area,
no chlorinated solvent impacts to soil in this area exceeded the U.S. EPA RSL for Residential Soil.
However, some of the detected PCE concentrations in soil in this area exceed the U.S. EPA RSL
Protection of Groundwater Soil Screening Levels (PGSSLs). Therefore, to eliminate the source of the
PCE plume in this area, Wasatch recommended that the soil exceeding the U.S. EPA RSLs PGSSLs be
excavated and disposed off-Site. Additionally, it is Wasatch’s opinion that the vertical extent of
chlorinated solvent impacts in the eastern PCE plume source area have been sufficiently defined and
reaches approximately 30 feet bgs.

Based on the totality of the analytical data collected from the Site, it is Wasatch’s opinion that impacts at
the Site have been sufficiently defined to develop an effective RAP.

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See Figure 4 for the historical sample locations, Figure 5 for a PCE groundwater concentration map;
Figure 6 for arsenic, TPH-GRO, and TPH-DRO concentrations in groundwater map; Figure 7 for select
soil exceedances and source areas; and Figures 8 and 9 for piezometric surface maps.

The Site is planned for redevelopment with a mixed residential and commercial use with multiple
residential and commercial structures. Typical residential structures are planned to be constructed with
ground floor storage and an enclosed garage. Typical commercial structures are planned with ground
floor office space. Although, no commercial or residential structures are designed for living spaces on the
ground floor. Prior to installing the concrete floors, Drago wrap (a chemical vapor barrier) will be installed
beneath the concrete floors for the entirety of the ground floor of the structures. This vapor barrier will be
installed by a certified contractor and installed following the manufacturer’s instructions which require all
penetrations to be properly sealed. See Section 3.4 for more details regarding the Drago wrap product.

1.3 Conceptual Site Model (CSM)

The Site is located within the discharge area for the principal basin-fill aquifer system. The discharge
area of the basin-fill aquifer system is characterized by a shallow unconfined aquifer overlying a deep
confined aquifer, with a confining layer (aquitard) separating the shallow unconfined aquifer from the deep
confined aquifer. The discharge area typically exhibits an upward vertical hydraulic gradient.

Soils at the Site consist of a gravely sand fill (GP), sandy clay/silty clay/clay (CL), trace sand (SP), some
silty sand (SM), and some sandy silt (ML). The fill is underlain primarily by clays (CL) and some sandy
silts (ML). The dominant lithology for the Site is clay (CL). Based on previous borings and monitoring
wells, depth to groundwater at the Site ranges from approximately 7 to 13 feet bgs. The hydraulic
gradient is generally to the west by northwest. Soils consisting primarily of silts and clays are potential
contaminant storage zones.

No metals impacts to soil were detected at the Site at concentrations that exceed their applicable U.S.
EPA RSL for Residential Soil, except for arsenic. However, the detected arsenic concentrations in soil
are considered to be within the background concentration range for this area. Therefore, the arsenic
impacts to soil do not require active remediation.

Groundwater samples GP-5S and GP-6 exhibited elevated arsenic in groundwater concentrations that
exceed the U.S. EPA MCLs. It is Wasatch’s opinion that these concentrations are a result of a petroleum
hydrocarbon release in this area that has likely resulted in the mobilization of arsenic into groundwater
due to the lowering of the pH in groundwater. These samples are located hydraulically downgradient of
the former UST located at the Site. Given the petroleum release source area is planned for active
remediation, this should result in the reduction of arsenic in groundwater to local background
concentrations at the Site over time. Wasatch plans to monitor groundwater for arsenic after the
petroleum impacts to soil have been remediated.

Based on the groundwater samples collected by Wasatch, no other metals were detected at
concentrations that exceeded their applicable U.S. EPA MCL. Given the Site will be using a municipal
water supply and not the shallow groundwater, this exposure pathway for metals is considered to be
incomplete. Therefore, Wasatch plans to mitigate these impacts and potential exposure risks through the
use of institutional controls to be placed at the Site.

A release of petroleum fuel originated from the former USTs located at the Site (see Figures 6 and 7 for
petroleum hydrocarbon-impacted areas). The USTs have been properly closed and removed from the
Site. Based on the data collected at the Site, low concentrations of TPH-GRO impacts to soil extend
along a smear zone (present from approximately 9 to 12 feet bgs) from the former UST basin area to the
northwest. The soil and groundwater samples collected within the smear zone (downgradient of the
former USTs) slightly exceed the Utah ISLs; however, when soil and groundwater samples within the
smear zone were analyzed for TPH fractionation, no detections exceeded the calculated SSCLs.
Therefore, remediation of the smear zone does not appear to be necessary.

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Based on the closure sampling activities for the UST closures, there are petroleum hydrocarbon impacts
exceeding the Utah ISLs and the calculated SSCLs to soil adjacent to the former UST basin area.
Wasatch assumes these impacts do not extend deeper than 10 to 12 feet bgs, and given the clay soil
present in this area, lateral soil impacts are likely localized around the former UST basin area.

An area just south of the southwest corner of the building was historically used as a drum storage area.
This area is referred to by Wasatch as the “western PCE plume source area.” Although no PCE soil
impacts were detected at concentrations that exceed the U.S. EPA RSL for Residential Soil within this
area, the data indicate the source of the PCE impacts to groundwater in this area are originating from this
location. It is Wasatch’s opinion that a surface release from the drum storage area has resulted in the
observed impacts within the western PCE plume area.

The former dry-cleaning machine (which contained and used PCE) used at the Site was located along the
eastern wall of the processing area of the building. There is also a floor drain located within this area of
the building. It is Wasatch’s opinion that these features are the primary release points and source for the
eastern PCE plume impacts. Although, no PCE soil impacts were detected at concentrations that exceed
the U.S. EPA RSL for Residential Soil within this area, PCE was detected at concentrations that exceed
the U.S. EPA PGSSL in the vadose zone.

PCE impacts to groundwater have migrated from the Site onto the adjoining north property (currently
vacant land) but do not extend beyond the north adjoining property’s boundary. The groundwater
samples collected off-Site were collected as turbid grab samples and not from properly developed
groundwater monitoring wells. It is Wasatch’s opinion that the majority of the detected off-Site PCE
concentrations would likely exhibit PCE concentrations below the U.S. EPA MCL if collected from properly
developed groundwater monitoring wells. Additionally, the adjoining property owners have been notified
of the impacts migrating onto their property, and DERR-approved reasonable steps have been developed
to avoid exposure to these impacts. Wasatch plans to request that the adjoining property owner allow
groundwater monitoring wells to be installed and monitored overtime to evaluate remedial actions
completed. However, if the land owner denies our request, and if the VCP cannot compel the land owner
to allow this, than these wells may potentially not be installed.

PCE and PFAS impacts to groundwater are also migrating onto the Site along the southern Site
boundary. The detected PCE concentrations were below the U.S. EPA MCL, but the detected PFAS
concentrations exceeded applicable U.S. EPA MCLs and HI.

PFAS were not detected in the soil samples collected at concentrations that exceed the applicable U.S.
EPA RSLs for Residential Soil. PFAS were detected at concentrations that exceed the U.S. EPA MCLs
or HI entering the Site from the upgradient property. It is Wasatch’s opinion that the PFAS analytes
detected on-Site were similar to the analytes entering the Site from the upgradient property. Additionally,
the PFAS analyte concentrations were similar in concentration to the analytes entering the Site from the
upgradient property.

There is a potential that a PFAS release originating from the Site has contributed to the impacted
groundwater at the Site. It is Wasatch’s opinion that the PFAS has likely been released from the same
locations as the PCE was released. Therefore, remediation of the PCE-impacted soil in the western and
eastern PCE source areas would likely remediate the PFAS impacts to groundwater originating from the
Site. It is possible that these impacts may be able to be managed through the use of institutional and/or
engineering controls at the Site to prevent potential exposure, but additional sampling may be required to
evaluate the PFAS impacts at, entering the Site from off-Site sources, and migrating off-Site to determine
if active remediation will be necessary.

The source areas have been identified at the Site. See Figure 7 for source area locations. Figure 10 is a
graphical depiction of the CSM envisioned as an exposure model showing pathways from the
contaminants and contaminant sources to the exposure media, exposure routes, and receptors.

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1.4 Objectives

Washmore Laundry, LLC, plans to redevelop the Site for mixed residential and commercial use.
Therefore, the objective of this remedial action is to remediate soil and groundwater at the Site to meet
the U.S. EPA RSLs for Residential Soil (not including arsenic) and U.S. EPA MCLs (not including arsenic
and PFAS) for groundwater or to SSCLs. Wasatch proposes that arsenic and PFAS be remediated to
concentrations approximate to the regional/background arsenic and PFAS concentrations in groundwater
as arsenic is ubiquitously present at elevated concentrations in groundwater and PFAS is known to enter
the Site at concentrations above the applicable U.S. EPA MCLs. This will require further evaluation of
arsenic and PFAS in groundwater to be evaluated through the installation and sampling of additional
groundwater monitoring wells both on and off-Site. Wasatch will work with the VCP to determine the
appropriate cleanup goals for arsenic and PFAS in groundwater based on the baseline data obtained
from the proposed wells. Given that the Site will be using a municipal water supply and not shallow
groundwater, the direct ingestion exposure pathway is considered to be incomplete and exposure risks to
the groundwater impacts will be mitigated using institutional controls described below .

2. REMEDIAL ACTION SELECTION

Site characteristics, historical and proposed future land use of the Site, current land use of properties
surrounding the Site, and the nature and distribution of contamination at the Site are discussed in
Sections 1.1 Site Description, 1.2 Site Background, and 1.3 Conceptual Site Model of th is RAP. The
information presented in these sections of the RAP serves as the basis for the selection of appropriate
remedial action measures, engineering controls, and institutional controls as discussed in the followi ng
sections.

2.1 Contaminants of Concern

Contaminants of concern at the Site are arsenic (groundwater only), BTEXN, TPH-GRO, TPH-DRO,
ethylbenzene (soil only), PFAS (groundwater only), and PCE.

2.2 Proposed Cleanup Goals

Based on the totality of the arsenic soil data, all detected arsenic concentrations in soil exceed the U.S.
EPA RSLs for Residential and Industrial Soil. As a site-specific background level for arsenic is not
available, for the initial proposed cleanup goal for arsenic, a value of 25 mg/kg is requested. If this
cleanup goal concentration is acceptable, Wasatch has determined that remediation and additional soil
sampling for evaluating arsenic is not required as the highest arsenic concentration detected in soil is
17.0 mg/kg.

Given that PFAS is migrating onto the Site from an off-Site source at concentrations that exceed the
applicable U.S. EPA MCLs and HI, Wasatch requests that the groundwater cleanup goal for PFAS be
similar to the background PFAS concentrations for this area and not the applicable U.S. EPA MCLs and
HI. Wasatch would install additional groundwater monitoring wells both on and off-Site to further evaluate
the PFAS impacts migrating onto and off the Site. Wasatch would collaborate with the DERR to
determine appropriate PFAS clean up goals.

Soil at the Site would be remediated to meet the U.S. EPA RSLs for Residential Soil (except for arsenic
as discussed above) or for TPH-GRO and TPH-DRO site-specific fractionation risk cleanup goals
(calculated using the DERR-approved DERR RBCA Site-Specific Cleanup Level [SSCL] calculator, see
Appendix D) will apply for the following exposure pathways: surface soil ingestion and subsurface soil
ambient air vapor inhalation. The SSCL for subsurface soil indoor air vapor inhalation will also be
evaluated, but would not be considered a remediation goal, as if this threshold is exceeded this exposure
would be mitigated using engineering controls. Remediation of soil to this standard is protective of
composite workers and construction workers with respect to the soil ingestion and inhalation exposure
pathways.
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It is our opinion that the release of petroleum hydrocarbons has resulted in localized arsenic-impacts to
groundwater at the Site. Wasatch plans active remediation of the petroleum hydrocarbon source area
which should result in the reduction of arsenic in groundwater to the local background concentration
ranges. The shallow groundwater at the Site is not in use and is not planned to be; therefore, Wasatch
requests these impacts be addressed through the use of engineering and/or institutional controls, and no
further evaluation or remediation of arsenic in groundwater be required.

Groundwater at the Site would be remediated to meet the U.S. EPA MCLs (except for arsenic and PFAS
as discussed above), or Utah ISLs or SSCLs (for petroleum hydrocarbons) for the groundwater outdoor
air vapor inhalation pathway. The SSCL for groundwater indoor air vapor inhalation pathway would be
evaluated, but would not be considered a remediation goal, as if this threshold is exceeded this exposure
would be mitigated using engineering controls. Groundwater is not used at the Site; therefore, the
ingestion of groundwater exposure pathway is not complete and this exposure would be mitigated using
engineering or institutional controls.

If residual petroleum contamination at concentrations above the U.S. EPA RSLs for Residential Soil but
below the U.S. EPA RSLs for Industrial Soil or TPH-GRO and TPH-DRO concentrations above Utah ISLs
remains on-Site, that for whatever reason could not be adequately addressed during the remedial action,
Wasatch would collect additional samples to be fractionated to determine potential risks if left in place. If
fractionation results indicate applicable risks are acceptable, Wasatch would request regulatory closure
be issued for the release.

Following active Site remediation, residual risk to on-Site receptors would be managed through the use of
engineering and institutional controls (discussed in Section 2.4 below), if required.

2.3 Proposed Remedial Action Measures

Given the Site characteristics, nature and distribution of contaminants, and proposed future land use;
Wasatch proposes over-excavation and off-Site disposal of the impacted soil within the identified source
areas. Details regarding the remedial action measures are provided in Section 3 of this RAP.

2.4 Proposed Engineering and Institutional Controls

The following engineering and institutional controls are proposed in the event that the remedial action fails
to fully achieve the proposed cleanup levels and to manage residual exposure risks following remedial
action.

If residual contamination at concentrations above the Utah ISLs/U.S. EPA RSLs for Residential Soil but is
below U.S. EPA RSLs for Industrial Soil, or exceeds acceptable fractionation risk cleanup goals, remains
on-Site that for whatever reason and could not be adequately addressed during the remedial action;
institutional controls (i.e., an EC and/or SMP, etc.) and engineering controls may be implemented to
reduce the probability of exposure to the contaminated soil and/or groundwater by restricting how the Site
may be used (e.g., forbidding the extraction and use of shallow groundwater , providing directions for
managing impacted soil and groundwater in the future [groundwater monitoring, obtaining groundwater
dewatering permits if needed], etc.). This would be protective of Site occupants and could facilitate
regulatory closure of the release site with residual soil and/or groundwater contamination left in place on -
Site. The EC and SMP would be subject to review and approval by the Utah DERR.

2.5 Proposed Groundwater Monitoring

Wasatch assumes that groundwater will need to be monitored for an unknown period of time to verify that
the remedial actions are reducing the impacts to groundwater at, and migrating off, the Site. Wasatch
proposes that the groundwater be monitored over time until the following have been achieved: the
chlorinated solvent impacts (mainly PCE) exhibit concentrations below their applicable U.S. EPA MCLs,
or equivalent to the VOC concentrations migrating onto the Site (if accepted by the DERR), for a period of
1 year; and the PFAS impacts to groundwater exhibit concentrations below their applicable U.S. EPA
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MCLs, or equivalent similar to the impacts migrating onto the Site (if accepted by the DERR) from off-Site
sources.

Wasatch proposes initially collecting groundwater samples on a quarterly basis. Groundwater samples
would be collected using low-flow sampling techniques. Groundwater samples would initially be collected
and analyzed for PFAS, arsenic, and VOCs. See Figure 11 for the initial proposed monitoring well
network. Wasatch would coordinate with DERR to determine if the proposed monitoring well network and
sample regime will require changes over time under a separate cover, as required by DERR. The
groundwater monitoring requirements would also be detailed in the SMP and EC, if required.

3. REMEDIAL ACTION DESIGN AND CONSTRUCTION

Details of the remedial design (i.e., excavation boundaries and depths) may be subject to revision based
on unforeseen Site conditions and the results of any additional site characterization work (if required) or
confirmation sampling results. Any substantive revisions to the approved RAP would be submitted in
writing to the VCP prior to implementation of the revision, and would be subject to VCP review and
approval. Critical aspects of the remedial design are illustrated in Figure 7.

3.1 VCP-Requested Sampling and Research

Given that the PCE concentration detected in groundwater collected from monitoring well MW-3M slightly
exceeded the U.S. EPA MCL, the VCP has requested that another sample be collected from this
monitoring well to evaluate if the PCE concentration has reduced over time. This sample would be
collected as a low-flow sample and analyzed for volatile organic compounds (VOCs) using U.S. EPA
Method 8260D to further evaluate the risks associated with these impacts. See Figure 4 for the
monitoring well location.

Wasatch will complete a water rights search for potential drinking water wells located within 0.5 miles
from the release and evaluate if the potential wells may be impacted.

3.2 Impacted Soil Excavation and Off-Site Disposal

Chlorinated solvent and PFAS impacts have been detected in the western PCE plume source area
(proposed excavation EXC-1) and in the eastern PCE plume source area (proposed excavation EXC-2).
See Figure 7 for the estimated areal extent of the soil impacts. Petroleum hydrocarbon impacts to soil
were identified within the former UST basin located at the Site (proposed excavation EXC-3). Wasatch
proposes over-excavation and off-Site disposal of these source areas. Wasatch assumes the impacted
soil areas would be excavated using an excavator and directly loaded into dump trucks and transported to
the disposal facilities. Wasatch assumes the petroleum hydrocarbon impacted soil areas would be
excavated using an excavator and directly loaded into dump trucks and transported to ET Technologies.
Each load would be documented with a non-hazardous waste manifest. If soil cannot be directly loaded
into a dump truck, soil may be stockpiled at the Site only on impacted areas that have not been
remediated or on visqueen that has been bermed to prevent leakage of any liquids . If the stockpile is to
be left overnight, the stockpiled soil will be covered in plastic sheeting and secured to prevent dust
migration. However, the characterization of the waste will determine the final disposition of the waste at
an appropriate facility.

When excavations EXC-1 and EXC-2 have been excavated to their required depths to achieve the stated
cleanup goal, approximately 60 gallons of RemOx L permanganate will be placed over the excavation
floors prior to backfilling the excavations.

The anticipated depth of EXC-1 is approximately 5 feet bgs. The anticipated depth of EXC-2 is
approximately 10 feet bgs. The areal extent of excavations EXC-1 and EXC-2 will be guided by past
data, the use of a PID, and soil confirmation sampling data. See Figure 7 for a map of soil exceedances
and proposed initial EXC-1 and EXC-2 extents.
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The anticipated depth of EXC-3 is likely to range from 10 to 12 feet bgs. The areal extent of EXC-3 will
be guided by past data, the use of a PID, and soil confirmation sampling data. See Figure 7 for a map of
soil exceedances and proposed initial EXC-3 extent.

It is Wasatch’s opinion that impacted groundwater will not be significantly encountered during the soil
remediation activities. Therefore, Wasatch does not anticipate having to manage or treat groundwater
within the proposed excavations. See Section 7 for potential contingencies.

3.3 General Demolition and Construction Issues

The following best management practices would be employed during implementation of the remedies
specified in this RAP:

• The VCP would be notified and provided with an opportunity to be present on-Site to observe the
remedial activities.

• Storm drain openings would be covered, and runoff would be controlled during drilling (if required)
and excavation activities to prevent mud and contaminants from entering the storm sewer
system.

• The soil excavation subcontractor would be required to decontaminate their equipment prior to
arrival at the Site, and prior to demobilization from the Site.

• A track-out area would be constructed by the excavation subcontractor (DPS) and utilized for any
heavy equipment leaving the Site to prevent tracking mud and/or contaminants on to public
roadways.

• Site access would be limited by erecting temporary chain-link fencing or other appropriate
barriers around any excavation that extends beyond 1 foot in depth. The fencing would remain in
place until the excavations deeper than 1 foot bgs are backfilled to 1 foot bgs or less.

3.4 Installation of Vapor Barriers

If cleanup goals or acceptable fractionation risk cleanup goals cannot be met, Wasatch would propose
the installation of vapor barriers consisting of 20-mil Drago® Wrap (or equivalent) beneath all the new
occupied structures constructed on the Site within 50 feet of the remain ing petroleum hydrocarbon or
VOC impacts of concern. Drago Wrap is specifically designed as a vapor intrusion barrier for VOC
constituents. A qualified contractor would install the vapor barriers. All seams, edges, and penetrations
would be sealed in accordance with the manufacturer’s recommend ations. Specifications and installation
instructions for the vapor barrier are provided in Appendix C.

4. PERMITTING REQUIREMENTS

4.1 Blue Stakes Utility Clearance Request

A utility clearance request would be submitted to Blue Stakes at least two full business days prior to the
commencement of the remediation work. The Blue Stakes utility clearance would be renewed every 16
calendar days for the duration of the project.

4.2 Storm Water Pollution Prevention Plan (SWPPP)

Given that the total area of soil disturbance is below the Millcreek area threshold, a SWPPP will not be
required for the work described in this RAP. However, subcontractors will be required to use best
management practices (i.e., cover exposed storm drains and manage runoff, etc.) to prevent adverse
impacts to the storm sewer system.
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4.3 Utah Division of Air Quality (DAQ) Requirements

Per Utah DAQ requirements, a Fugitive Dust Control Plan (FDCP) has been completed and approved by
the Utah DAQ and included in the Fugitive Emissions Monitoring Plan (FEMP) in Appendix B . See
Appendix B for the full copy of the FEMP that applies to the proposed remedial activities.

Dust control is a top priority for the successful completion of this remediation. Because of the potential of
VOCs, arsenic, and petroleum hydrocarbons in the soils being disturbed during the project, dust control is
essential to prevent potential exposure of impacted dust to adjoining properties and on-Site workers. The
remediation contractor and Wasatch will be responsible for controlling fugitive dust emissions during the
project and for implementing a Utah DAQ-approved FEMP for the project.

Fugitive dust will be controlled using standard construction practices. Wetting the soil will be the primary
control technology for fugitive dust emissions. If wetting the soils cannot control the fugitive emissions,
additional dust-control measures will be implemented, which may include the following:

• Reducing on-Site vehicle speeds,

• Limited drop heights when loading soil,

• Reducing work activities,

• Halting work if fugitive dust emissions cannot be controlled,

• Wetting soil stockpiles, and

• Tarping all loads exiting the Site.

The plan’s objective is to limit potential exposures to fugitive dust emissions to commercial/industrial
workers at adjacent properties to the Site, nearby commercial workers, nearby residential occupants, and
workers involved with soil removal activities. Fugitive dust levels will be assessed using U.S. EPA
Method 9 (Visual Determination of Opacity of Emissions from Stationary Sources). If the Method 9 results
do not meet the air monitoring objectives, implementation of the best management practices documented
in the FEMP will be immediately implemented.

4.4 Salt Lake County Health Department

The Salt Lake County Health Department would be notified at least 72 hours prior to commencement of
fieldwork related to the remediation activities at the Site.

4.5 Millcreek City Permits

A Millcreek City excavation permit will be obtained prior to commencing with the excavation activities, if
required.

4.6 Underground Injection Control Permit

Wasatch would submit an application for an Underground Injection Control (UIC) permit to the Division of
Water Quality (DWQ) for Class 5B6 beneficial use injection well(s) [subsurface environmental remediation
injection well(s)] prior to the commencement of fieldwork. Injections would not be performed until the UIC
permit has been approved. Wasatch would notify the DWQ when the work has been completed and the
permit can be discontinued.

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5. PUBLIC NOTIFICATION AND PARTICIPATION

The Volunteer, and Wasatch acting as an agent of the Volunteer, would clearly convey to stakeholders a
commitment to open an honest communication, a commitment to partnering with the Utah Department of
Environmental Quality (UDEQ) in matters of public involvement, and a commitment to being sensitive and
responsive to the concerns of stakeholders. Stakeholders include not only the Volunteer, Volunteer’s
environmental attorney, Volunteer’s consultant, UDEQ, and affected and nearby property
owners/lessees/occupants; but may also include public utilities, the Salt Lake County Health Department,
and Millcreek City government.

In stakeholder communications, Wasatch would explain the iterative nature of environmental
investigations and complexities related to actual exposure risk. Wasatch would explain that
contamination present in soil or groundwater does not necessarily result in exposure risk. Wasatch would
further explain that the data we are gathering would allow us to identify and then reduce or eliminate
exposure pathways and associated risks during Site remediation and mitigation efforts.

Communication with stakeholders may be necessary in order to obtain access agreements. All access
agreements would be obtained in writing, prior to the commencement of fieldwork. When requesting
access to perform investigation, remediation, or mitigation activities on -Site Wasatch would:

• Explain why the work needs to be performed.

• Explain what is known about the release(s) at the time of the request for access that is driving the
need for access (without engaging in speculation).

• Clearly describe the nature of the work to be performed.

• Meetings with the Wasatch project manager and VCP project manager would be offered if
stakeholders have questions or concerns that cannot otherwise be immediately addressed.

• Allow stakeholders to provide input on sampling locations, dates, and times (when work would be
conducted on-Site).

• Provide the stakeholders with contact information for the Wasatch project manager and VCP
project manager.

Communication with stakeholders would also be necessary as the results from various phases of
investigation and confirmation sampling become available. Wasatch, with assistance from the UDEQ (if
required), would communicate with stakeholders to inform stakeholders of the results of the remediation
and confirmation sampling as it proceeds, and provide stakeholders with updated information as it is
warranted and in a timely manner. If requested by stakeholders, Wasatch would provide stakeholders
with data related to their specific business (i.e., confirmation soil data) and Site-wide groundwater data
maps. Stakeholders would be provided with information on how they may obtain copies of complete
project-related documents through the UDEQ website or by submitting a Government Records Access
and Management Act (GRAMA) request. Wasatch would also offer to facilitate meetings between
concerned stakeholders, the UDEQ, Volunteer, and Volunteer’s environmental attorney, as necessary.

Wasatch would submit drafts of any written public outreach materials to the VCP project manager for
review and provide final copies for the VCP project file. Depending on the number of stakeholders that
ultimately become affected by the investigation and remediation activities, Wasatch (in cooperation with
the Volunteer, Volunteer’s environmental attorney, and UDEQ) may need to conduct public meetings to
facilitate effective communication with multiple stakeholders.

A public notice informing the general public and adjacent industrial/commercial properties of the proposed
remediation activities and how to obtain additional details of the proposed project has been prepared. A
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copy of the notice (presented as Appendix A) will be hand delivered to the adjoining property owners and
will be published in the Salt Lake Tribune.

For community questions or concerns during remediation activities, a sign at the construction entrance
will direct questions and/or comments to Mr. Blake Downey, Wasatch Environmental [phone].
The Volunteer, and Wasatch acting as an agent of the Volunteer, would adhere to the VCP requirements
regarding the public comment period required prior to implementing any remediation strategy. Prior to
implementation of any remediation strategy, written notification would be provided to adjacent landowners
and a notice would be placed in a local newspaper. Notification would be followed by a public comment
period on the RAP of no less than 30 days. Any substantive public comments that are received would be
responded to per VCP procedures prior to implementation of the R AP.

6. SAMPLING AND ANALYSIS

6.1 VCP-Requested Monitoring Well Sampling

One groundwater sample would be collected from monitoring well MW-3M prior to remedial activities.

The groundwater sample would be collected using a low-flow sampling procedure following U.S. EPA
guidelines. The sampling procedure involves inserting ¼-inch outside diameter, low-density polyethylene
tubing into the monitoring well. The tubing would be run through a peristaltic pump, then to a flow cell to
which a multi-parameter AquaTroll 500 meter (or equivalent) would be attached, and finally to a 5-gallon
bucket to collect the purge water. Initial water levels would be measured and recorded prior to the
initiation of pumping. Once pumping is initiated, water levels, pumping rate, cumulative volume purged,
water temperature, specific conductivity, pH, oxidation-reduction potential, dissolved oxygen (DO), and
turbidity would be recorded at five-minute intervals until either stabilization was achieved or the well
pumps dry. Pumping rates would be maintained at a rate of 50 to 200 milliliters per minute to minimize
drawdown. Stabilization is defined as three consecutive measurement intervals where temp erature and
specific conductivity were +/- 3%, pH was +/- 0.1, DO was +/-10% (or less than 0.5 mg/L), and turbidity
was +/- 10% (or less than five nephelometric turbidity units). If monitoring the well pumps dry, it would be
allowed to recharge to a minimum of at least 90% of their static water level prior to sampling. After
stabilization is achieved, the tubing would be disconnected from the flow cell and the groundwater
samples would be dispensed into appropriate laboratory -supplied containers. The sample containers
would each be labeled with the analysis required, sampler’s name, sample identification number, sample
location, date, and time of sample collection.

The groundwater sample would be collected using gloved hands and dispensed into appropriate
laboratory-supplied/prepared containers and placed in iced coolers. Each sample would be labeled with
date of collection, sample time, sample identification, and requested analysis. The groundwater sample
would be submitted under chain-of-custody protocol (in accordance with the Utah VCP-approved SAP
and QAPP) to Chemtech-Ford Laboratories (CF) for analysis. The groundwater sample would be
analyzed for VOCs using U.S. EPA Method 8260D.

All samples will be documented and handled in accordance with the Utah VCP-approved SAP and QAPP.
The groundwater sample would be analyzed at standard laboratory turnaround time unless Wasatch is
directed by Washmore Laundry, LLC, to expedite the analyses.

The monitoring well sample will be mapped and documented.

6.2 Waste Characterization Sampling

Waste soil will be generated in conjunction with the excavation activities. Wasatch would perform waste
characterization sampling prior to commencing with the proposed excavation activities in accordance with
the SAP and complete the appropriate waste profiles to be approved by the facility receiving the waste
(Salt Lake County Landfill [chlorinated solvent and PFAS-impacted waste] or ET Technologies [petroleum
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impacted soil]) based on the waste characterization sampling results. If required, Wasatch would submit
a work plan to the Utah Division of Waste Management and Radiation Control (DWMRC) to provide
sufficient waste characterization data to obtain a ”not contained-in” determination from the Utah DWRMC.
This will be completed to verify the produced soil waste is considered not characteristically hazardous.
The soil waste will be transported by the Clients subcontractor to Salt Lake County Landfill or ET
Technologies. All waste materials generated for off-Site disposal will be taken to permitted facilities
capable of managing the specific waste stream.

6.3 Soil Confirmation Sampling

Soil confirmation samples will be collected to verify that the cleanup levels have been met. Soil
confirmation samples would be collected from the floor and sidewalls of all excavations. One soil
confirmation sample would be collected per 25 feet of excavation sidewall not allowing more than 25 feet
of sidewall to go unsampled with a minimum of four sidewall samples per excavation . One soil
confirmation sample would be collected for every 500 square feet of excavation floor area with a minimum
of one floor sample per excavation.

The soil confirmation samples would be collected using gloved hands and dispensed into appropriate
laboratory supplied/prepared containers and immediately placed in iced coolers. Each sample would be
labeled with date of collection, sample time, sample identification, and requested analysis. The soil
samples would be submitted under chain-of-custody protocol (in accordance with the Utah VCP-approved
SAP and QAPP) to CF for analysis. The confirmation soil samples collected from excavations EXC-1 and
EXC-2 would be analyzed for VOCs using U.S. EPA Method 8260D and PFAS using U.S. EPA Method
1663 (to be analyzed by Eurofins Testing American [Eurofins]). The soil confirmation samples collected
from excavation EXC-3 would be analyzed for MBTEXN and TPH-GRO (and TPH-GRO fractionation if
necessary to support evaluations) using U.S. EPA Method 8260D, and TPH-DRO using U.S. EPA
Method 8015D with silica get treatment (SGT). Additionally, analysis of TPH-DRO fractionation would be
completed using U.S. EPA Method 8270E if necessary to support evaluations. See Figure 7 for a map of
the anticipated excavation extents.

All soil confirmation samples collected from EXC-3 will be collected by a Utah-certified Soil and
Groundwater Sampler. All samples will be documented and handled in accordance with the Utah VCP-
approved SAP and QAPP. The resulting laboratory data will be subject to third-party data validation. Soil
samples would be analyzed at standard laboratory turnaround time unless Wasatch is directed by
Washmore Laundry, LLC to expedite the analyses.

All soil confirmation samples will be mapped and documented.

6.4 Groundwater Confirmation Sampling

Groundwater confirmation samples will be collected from the EXC-3 excavation (if encountered) to verify
that the cleanup levels have been met. Groundwater confirmation samples would be collected from the
excavation pit using a Teflon dipper. At least one groundwater confirmation sample would be from this
excavation.

The groundwater confirmation samples would be collected using gloved hands and dispensed into
appropriate laboratory supplied/prepared containers and immediately placed in iced coolers. Each
sample would be labeled with date of collection, sample time, sample identificat ion, and requested
analysis. The groundwater samples would be submitted under chain-of-custody protocol (in accordance
with the Utah VCP-approved SAP and QAPP) to CF for analysis. The groundwater confirmation samples
collected from excavation EXC-3 would be analyzed for MBTEXN and TPH-GRO (and TPH-GRO
fractionation if necessary to support evaluations) using U.S. EPA Method 8260D, and TPH -DRO using
U.S. EPA Method 8015D with silica get treatment (SGT). Additionally, analysis of TPH -DRO fractionation
would be completed using U.S. EPA Method 8270E if necessary to support evaluations. See Figure 7 for
a map of the anticipated excavation extents.

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All samples will be documented and handled in accordance with the Utah VCP-approved SAP and QAPP.
The resulting laboratory data will be subject to third-party data validation. Soil samples would be
analyzed at standard laboratory turnaround time unless Wasatch is directed by Washmore Laundry, LLC
to expedite the analyses.

All soil confirmation samples will be mapped and documented.

6.5 Groundwater Monitoring Sampling

Groundwater impacts will be monitored over time to evaluate if the remedial actions are reducing impacts
to groundwater. One groundwater sample would be collected from the proposed monitoring wells
depicted on Figure 11 per sampling event.

The groundwater samples would be collected using a low-flow sampling procedure following U.S. EPA
guidelines. The sampling procedure involves inserting ¼-inch outside diameter, low-density polyethylene
tubing into each monitoring well. The tubing would be run through a peristaltic pump, then to a flow cell to
which a multi-parameter AquaTroll 500 meter (or equivalent) would be attached, and finally to a 5-gallon
bucket to collect the purge water. Initial water levels would be measured and recorded prior to the
initiation of pumping. Once pumping is initiated, water levels, pumping rate, cumulative volume purged,
water temperature, specific conductivity, pH, oxidation-reduction potential, dissolved oxygen (DO), and
turbidity would be recorded at five-minute intervals until either stabilization was achieved or the well
pumps dry. Pumping rates would be maintained at a rate of 50 to 200 milliliters per minute to minimize
drawdown. Stabilization is defined as three consecutive measurement intervals where te mperature and
specific conductivity were +/- 3%, pH was +/- 0.1, DO was +/-10% (or less than 0.5 mg/L), and turbidity
was +/- 10% (or less than five nephelometric turbidity units). If monitoring a well pumps dry, it would be
allowed to recharge to a minimum of at least 90% of their static water level prior to sampling. After
stabilization is achieved, the tubing would be disconnected from the flow cell and the groundwater
samples would be dispensed into appropriate laboratory supplied containers. The sample containers
would each be labeled with the analysis required, sampler’s name, sample identification number, sample
location, date, and time of sample collection.

The groundwater sample would be collected using gloved hands and dispensed into appropriate
laboratory supplied/prepared containers and placed in iced coolers. Each sample would be labeled with
date of collection, sample time, sample identification, and r equested analysis. The groundwater sample
would be submitted under chain-of-custody protocol (in accordance with the Utah VCP-approved SAP
and QAPP) to Chemtech-Ford Laboratories (CF) for analysis; however, PFAS samples would be
submitted to Eurofins. The groundwater samples would be analyzed for VOCs using U.S. EPA Method
8260D, arsenic (if determined to be necessary by the VCP) using U.S. EPA Method 6020A, and PFAS
using U.S. EPA Method 1633.

Initially, the sampling frequency will be quarterly for at least two years; however, the sampling regime may
be re-evaluated through coordination with, and approval by, DERR under a separate cover in the future to
meet projects requirements to obtain regulatory closure.

All samples will be documented and handled in accordance with the Utah VCP-approved SAP and QAPP.
The groundwater sample would be analyzed at standard laboratory turnaround time unless Wasatch is
directed by Washmore Laundry, LLC, to expedite the analyses.

The monitoring well samples will be mapped and documented.

7. CONTINGENCY PLANNING

Groundwater monitoring activities will be completed for the known impacts, Wasatch will coordinate with
the VCP to install additional monitoring wells (if required) to evaluate if remediations have been
successful. Wasatch would also coordinate with the VCP to determine appropriate monitoring well
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locations and sampling regime. This would be done through a future work plan to be approved by the
VCP.

Additionally, if remedial activities do not sufficiently remediate the groundwater impacts, Wasatch will
coordinate with the VCP to determine an appropriate course of action for remediating those impacts.

Building demolition is planned at this time, soil samples would be collected from beneath any unidentified
subsurface features of concern where there may be indications of a release. Sampling would be
conducted in accordance with the Utah VCP-approved QAPP and SAP. If contamination above
residential screening levels is confirmed through this sampling; the soil would be excavated, Wasatch
would perform waste characterization sampling in accordance with the SAP, and Wasatch would
complete the appropriate waste profiles to be approved by the facility receiving the waste. All waste
would be left in place or properly contained in labeled 55-gallon drums or roll-off containers pending
laboratory analysis and proper transport and disposal.

If contamination is discovered in unexpected locations, at unexpected concentrations, or if new
contaminants are discovered that were not expected based on Site history and previous data; Wasatch
would immediately communicate relevant findings to Washmore Laundry, LLC, and the DERR and work
to develop an appropriate remedial alternative.

If the data resulting from confirmation sampling indicate that the remedial strategy, after implementation,
has not been effective at remediating the contamination (either in localized areas or Site-wide) Wasatch
would immediately communicate relevant findings to Washmore Laundry, LLC, and the DERR and work
to develop an appropriate remedial alternative.

It is impossible for Wasatch to develop specific contingencies and speculate as to what specific
responses would be appropriate, without knowing the specific conditions and circumstances to which the
contingencies are responding. Contingency responses would always be developed in a manner
consistent with the intended land use, applicable laws and regulations, and with the objectives expressed
by Washmore Laundry, LLC.

If the proposed groundwater confirmation sampling data exceed the clean up goals. Wasatch would
coordinate with Washmore Laundry, LLC., and the VCP to use a vacuum truck to extract the impacted
groundwater and properly dispose of the waste at an appropriate facility, and then resample the
groundwater within the excavation to verify if cleanup goals have been met. This process would be
repeated if necessary.

If the waste characterization sampling to be completed results in identifying the waste as characteristically
hazardous, Wasatch will notify the VCP and work with the VCP to determine an appropriate disposal
facility. Wasatch would complete all waste profiling that may be required by the receiving facility prior to
disposal of any impacted material.

8. REMEDIAL ACTION IMPLEMENTATION REPORT

Following completion of the remedial action, Wasatch would produce a remedial action implementation
report documenting the results of the remedial action. The report would include:

• narrative text explaining objectives, methods, results, and presenting conclusions and
recommendations;

• comprehensive data tables;

• figure(s) depicting the location of excavations, confirmation samples, and other relevant Site
features;

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• photographs;

• laboratory analytical reports;

• waste manifests;

• data validation reports.; and

• copies of permits and approvals.

Additionally, a separate report pertaining only to the OFD release will be provided to the PST Branch
upon completion of the remedial work, but would include the above report components.

9. HEALTH AND SAFETY

All remedial action activities at the Site would be performed by Wasatch and our subcontractors in
accordance with Wasatch’s general health and safety policy. A site-specific health and safety plan would
also be prepared to address specific health and safety concerns and establish protocols for c onducting
work-related activities in a safe manner.

10. PROJECT SCHEDULE

The timing of the remediation work described is anticipated to begin within 30 days of receiving VCP
approval of the RAP. Wasatch anticipates completing the Site remediation work during the spring or
summer of 2025, but may extend into late 2025. Wasatch would communicate scheduling details with the
Utah DERR as the schedule develops.

Figures

The use or reuse of this information is restricted to the referenced document unless otherwise authorized.
Wasatch Environmental Copyright 2006
Figure 1 Site Location Map
PRIDE CLEANERS 2639-001E
Approximate
Location
of Site
1 inch = 288 feet
The use or reuse of this information is restricted to the referenced document unless otherwise authorized.
Wasatch Environmental Copyright 2006
PRIDE CLEANERS WEI 2639-001E
Figure 2 Parcel Map
Approximate
Location of SIte
The use or reuse of this information is restricted to the referenced document unless otherwise authorized.
Wasatch Environmental Copyright 2006
Figure 3Site Vicinity Property Use Map
PRIDE CLEANERS 2639-001E
Approximate
Location
of Site
1 inch = 288 feet
Residential
Residential
Residential
Residential
Residential
Residential
Residential
Residential
Residential
Commercial
Commercial
Commercial
Commercial CommercialCommercial
Commercial
Commercial
Residential
Commercial
Commercial
CommercialResidential
Commercial/
Auto Repair
FIGURE
4
DRAWING DATEPROJECT NO.
Environmental Science and Engineering
Approximate Location of Site
So
u
t
h

9
0
0

E
a
s
t
GP-1
USTs
Koodegras
GP-15
GP-10
Previous Off-Site 2021 Boring Location
Previous Off-Site 2022 Boring Location
Previous Deep Boring Location
Previous On-Site Shallow Boring Location
LEGEND
PCE Groundwater Contour (5 ug/L)
Suspected PCE Source Area
PCE Source Area
1 inch = 32 feet
SG-1
SG-3
GP-4
GP-3 GP-2
GP-2
SG-6
SG-5
GP-9
SG-2
GP-17
GP-13
GP-12
GP-11
SV-3
GP-19
GP-22/DGP-16
SV-4
GP-14GP-11
GP-9
GP-8
GP-7
SV-2GP-3
SV-3
GP-5
GP-4
SV-1
SV-2
SV-5
SV-1
Boring Location
Shallow/Deep Monitoring Well Location
Indoor/Outdoor Air Sample Location
Previous Off-Site 2022 Soil Gas Sample Location
Previous Off-Site 2021 Soil Gas Sample Location
Previous On-Site Soil Gas Sample Location
GP-21
GP-20
GP-8
GP-18
GP-6
SG-4GP-14
GP-12
GP-1
GRO/DRO Groundwater Contour (1,000 ug/L)
GP-6
Arsenic Groundwater Contour (10 ug/L)
Previous Temporary Piezometer
IA-3
IA-2
IA-1
GP-7
GP-5/D
Natural Gas Line
Communications Line
Sewer Line
1639-001E Nov. 21, 2023
Historical Sample Location and PCE,
Arsenic, and TPH-GRO/DRO Contour Map
Pride Cleaners
4358 South 900 East, Millcreek, Utah
GP-10
MW-1S/
MW-1M
GP-27
MW-2S/
MW-2M
GP-25
GP-24
GP-23
GP-26
MW-3S/
MW-3M
GP-13
**Only known underground utilities are depicted
OA-1
FIGURE
5
DRAWING DATEPROJECT NO.
Environmental Science and Engineering
Approximate Location of Site
So
u
t
h

9
0
0

E
a
s
t
USTs
Koodegras
Previous Off-Site 2021 Boring Location
Previous Off-Site 2022 Boring Location
Previous Deep Boring Location
Previous On-Site Shallow Boring Location
LEGEND
PCE Groundwater Contour (5 ug/L)
Western PCE Plume Source Area
Eastern PCE Plume Source Area
1 inch = 32 feet
Boring Location
Shallow/Deep Monitoring Well Location
Previous Temporary Piezometer
Natural Gas Line
Communications Line
Sewer Line
1639-001E Nov. 21, 2023
PCE in Groundwater Concentration
Map
Pride Cleaners
4358 South 900 East, Millcreek, Utah
GP-23
GP-26
**Only known underground utilities are depicted
GP-4
PCE - 10.3
GP-9
PCE - 24.1
GP-5S
PCE - <1.00
GP-5D
PCE - 1.05
GP-7
PCE - 1.75
GP-11
PCE - 3.36
GP-2
PCE - 3.28GP-3
PCE - 1.82
GP-12
PCE - 10.4 GP-16
PCE - 1.89
GP-18
PCE - 3.26
GP-17
PCE - 1.99
GP-19
PCE - 11.7
GP-22S
PCE - 59.0
GP-22D
PCE -16.7
GP-21
PCE - 17.7
GP-8
PCE - 11.6
GP-20
PCE - 91.6
GP-13
PCE - 21.0
GP-24
PCE - 4.9
GP-25
PCE - 5.7
GP-27
PCE - 4.5
MW-1S
PCE - 11.4
MW-1M
PCE -4.5
GP-14
PCE - 3.82
MW-3S
PCE - 42.4
MW-3M
PCE -6.3
MW-2S
PCE - 0.9
MW-2M
PCE -2.2
GP-4
PCE: 6.41
GP-5
PCE: 19.2
GP-3
PCE: <2.00
GP-2
PCE: <2.00
GP-1
PCE: <2.00
GP-7
GP-13
GP-6
PCE: 6.04
GP-7
PCE: <2.00
GP-10
PCE: <2.00
GP-8
PCE: <2.00 GP-12
PCE: <2.00
GP-9
PCE: 2.28
GP-11
PCE: 11.0 GP-14
PCE: <2.00
GP-13
PCE: <2.00
GP-1
PCE: <1.00GP-10
PCE: <1.00
GP-15
PCE: <1.00
GP-6
PCE: <1.00
*Borings without labeled concentrations were not analyzed for PCE.
**All concentrations are reported in micrograms per liter
Concentrations in Red exceed the applicable U.S. EPA MCL
The use or reuse of this information is restricted to the referenced document unless otherwise authorized.
Wasatch Environmental Copyright 2006
Figure 6Arsenic, TPH-GRO, and TPH-DRO in Groundwater Concentration Map
PRIDE CLEANERS 2639-001E
Approximate Location of Site
So
u
t
h

9
0
0

E
a
s
t
1 inch = 36 feet
GP-3 GP-2 GP-1
Koodegras
GP-6
Arsenic - 264
TPH-GRO - 1,090
TPH-DRO - 1,650
GP-13
GP-12
GP-11
GP-10
GP-19
GP-20
GP-21
GP-22
GP-18
GP-16
GP-4
Arsenic - <10.0
TPH-GRO - <500
TPH-DRO - 126
GP-7
Arsenic - <10.0
TPH-GRO - <500
TPH-DRO - 215
GP-9
Arsenic - <10.0
TPH-GRO - <500
TPH-DRO - 188
GP-14
TPH-GRO - 969
TPH-DRO - 363
GP-8
*Concentrations in Red exceed the applicable Utah Initial Screening Level or the U.S. EPA MCL
*Only Samples that exhibited at least one detection are labeled
(except for MW-2S), all other samples were non-detect.
Previous Shallow Boring Location
Previous Deep Boring Location
Boring Location
LEGEND
*All concentrations are reported in
micrograms per liter
Arsenic Groundwater Contour (10 ug/L)
GP-17
TPH-GRO - <500
TPH-DRO - 119
GP-15
TPH-GRO - 7,260
TPH-DRO - 14,300
USTs
Petroleum Hydrocarbon Source Area
GP-5S
TPH-GRO - <500
TPH-DRO - 570
Arsenic - 432
MW-3S
GP-26
Shallow Monitoring Well Location
MW-2S
TPH-GRO - <12
TPH-DRO - <1,000
Contour is based on off-Site and on-Site data
GP-9
GP-7
GP-13
Off-Site Boring Location
GP-8
Arsenic - 10.3
GP-12
Arsenic - 79.1
GP-6
Arsenic - 4.02
MW-1S
The use or reuse of this information is restricted to the referenced document unless otherwise authorized.
Wasatch Environmental Copyright 2006
Figure 7Soil Exceedance Map
PRIDE CLEANERS 2639-001E
Approximate Location of Site
So
u
t
h

9
0
0

E
a
s
t
1 inch = 36 feet
Koodegras
GP-6
Arsenic - 12.6
TPH-GRO - 327
GP-3
Arsenic - 10.5
GP-2
Arsenic - 5.63 GP-1
Arsenic - 14.3
GP-8
Arsenic - 17.0
GP-9
Arsenic - 8.54
GP-13
GP-11
GP-10
GP-19
GP-20
GP-21
GP-22
*Only Samples that exhibited at least one exceedence
are depicted, all other samples were non-detect.
GP-15@10
TPH-GRO - 230 GP-16@9
TPH-GRO - 152
GP-14@9
TPH-GRO - 263
GP-18@9
TPH-GRO - 619
**Arsenic concentrations exceed the U.S. EPA RSL for Residential Soil
and the TPH-GRO concentrations exceed the Utah Initial Screening Level
GP-12@9
TPH-GRO - 242
GP-4
Arsenic - 7.57
GP-5@9’
Arsenic - 11.1
GP-17@9
TPH-GRO - 198
GP-7
Arsenic - 9.14
TPH-GRO - 165
Previous Shallow Boring Location
Previous Deep Boring Location
Boring Location
LEGEND
*All concentrations are reported in
milligrams per kilogram
TPH-GRO in Soil Contour (150 mg/kg)
MW-1S
MW-2S
GP-24
GP-26
MW-3S
GP-25
Shallow Monitoring Well Location
USTs
SS-1
UST Closure Sample Location
Proposed Excavation (EXC-1) Area
(Western PCE Plume Source Area)
SS-4
TPH-DRO - 5,270
TPH-GRO - 4,730
Ethylbenzene - 5.06
SS-2
TPH-DRO - 10,700
TPH-GRO - 788
Ethylbenzene - 9.33
Proposed Excavation (EXC-2) Area
(Eastern PCE Plume Source Area)
Proposed Excavation (EXC-3) Area
(Petroleum Hydrocarbon Source Area)
SS-5
TPH-DRO - 2,680
TPH-GRO - 1,500
FIGURE
8
DRAWING DATEPROJECT NO.
Environmental Science and Engineering
Approximate Location of Site
So
u
t
h

9
0
0

E
a
s
t
Former
USTs
LEGEND
Western PCE Plume Source Area
Eastern PCE Plume Source Area
1 inch = 32 feet
Shallow Monitoring Well Location
Natural Gas Line
Communications Line
Sewer Line
1639-001E Dec. 14, 2023
Pride Cleaners
4358 South 900 East, Millcreek, Utah
**Only known underground utilities are depicted
Piezometric Contour
MW-2S
(91.45)MW-3S
(92.31)
Koodegras
MW-1S
(91.57)
Genera
l

G
r
o
u
n
d
w
a
t
e
r
Flow Di
r
e
c
t
i
o
n
Hydrau
l
i
c
Gradie
n
t
0.0052 f
t
/
f
t
91.60
91.65
91.7
0
91.
7
5 91.
8
0
91
.
8
5
91
.
9
0
91
.
9
5
92
.
0
0
92
.
0
5
92
.
1
0
92
.
1
5
92
.
2
0
92
.
2
5
91.50
0.01 Groundwater Elevation
September 14, 2023, Shallow
Piezometric Surface Map
FIGURE
9
DRAWING DATEPROJECT NO.
Environmental Science and Engineering
Approximate Location of Site
So
u
t
h

9
0
0

E
a
s
t
Former
USTs
LEGEND
Western PCE Plume Source Area
Eastern PCE Plume Source Area
1 inch = 32 feet
Intermmediate Monitoring Well Location
Natural Gas Line
Communications Line
Sewer Line
1639-001E Dec. 14, 2023
September 14, 2023, Intermmediate
Piezometric Surface Map
Pride Cleaners
4358 South 900 East, Millcreek, Utah
**Only known underground utilities are depicted
Piezometric Contour
MW-2M
(91.43)MW-3M
(92.31)
Koodegras
MW-1M
(91.47)
91.5
0
91.
7
0
91
.
8
0
91
.
9
0
92
.
0
0
92
.
2
0
0.01 Groundwater Elevation
91.6
0
92
.
1
0
General Ground
w
a
t
e
r
Flow Direction
Hydraulic
Gradient
0.0059 ft/ft
FIGURE
11
DRAWING DATEPROJECT NO.
Environmental Science and Engineering
Approximate Location of Site
So
u
t
h

9
0
0

E
a
s
t
Former
USTs
LEGEND
Western PCE Plume Source Area
Eastern PCE Plume Source Area
1 inch = 32 feet
Existing Monitoring Well Location
Natural Gas Line
Communications Line
Sewer Line
1639-001E January 15, 2025
Proposed Monitoring Well Network
Pride Cleaners
4358 South 900 East, Millcreek, Utah
**Only known underground utilities are depicted
MW-2S/M
MW-3S/M
Koodegras
MW-1S/M
PCE Groundwater Contour (5 ug/L)
Arsenic Groundwater Contour (10 ug/L)
Proposed Monitoring Well Location
MW-6S
MW-5S MW-4S
MW-7SMW-9S MW-8S
General Ground
w
a
t
e
r
Flow Direction
Hydraulic
Gradient
0.0059 ft/ft
FIGUREDATE:PROJECT NO.:Environmental Science and Engineering
Conceptual Site Model (CSM)
Former Pride Cleaners
4358 South 900 East, Millcreek, Utah
2639-001E August 7, 2024 10
Current Use
Dermal ContactFill and Native Soil
Groundwater
Soil Gas
Dermal Contact
Ingestion
Ingestion
Inhalation
Inhalation
Fill and Native Soil
TPH-GRO
Naphthalene
Ethylbenzene
1,1,2-Trichloroethane
4-Methyl-2-Pentanone (MIBK)
Tetrachloroethene (PCE)
* PCE, naphthalene, MIBK, and
1,1,2-trichloroethane were not detected at
concentrations that exceed the U.S. EPA RSL for
Industrial or Residential Soil.
Arsenic
TPH-DRO
TPH-GRO
Tetrachloroethene (PCE)
Perfluoroctanesulfonic Acid (PFOS)
Perfluorooctanoic Acid (PFOA)
PFBS-PFHxS-PFNA-GenX Hazard Index
Chloroform
Trichloroethene (TCE)
Tetrachloroethene (PCE)
1,2,4-Trimethylbenzene
1,3,5-Trimethylbenzene
Groundwater
Soil Gas (assummed)
Complete Exposure Pathway
Potentially Complete Exposure Pathway
Inomplete Exposure Pathway
Co
n
s
t
r
u
c
t
i
o
n

W
or
k
e
r
Si
t
e

W
or
k
e
r
Re
s
i
d
e
n
t
SOURCE AND CONTAMINANTS EXPOSURE MEDIUM
RECEPTORS
EXPOSURE ROUTE

Appendix A
Public Notice

Public Notice
30-Day Comment Period
Former Pride Cleaners Project

Washmore Laundry, LLC, has prepared a Remedial Action Plan (RAP) to address
volatile organic compound and, heavy metal, per- and poly fluorinated alkyl substances
(PFAS), and petroleum hydrocarbon impacts to soil and groundwater at the former Pride
Cleaners property located at 4358 South 900 East in Millcreek, Utah. The current
property owner has entered into an agreement with the Utah Department of
Environmental Quality (UDEQ), Division of Environmental Response and Remediation’s
(DERR’s) Voluntary Cleanup Program (VCP) to remediate the impacted soil and
groundwater to agreed upon cleanup levels to allow commercial and residential use of
the property. During excavation work associated with the impacted soils and
groundwater, access to the site will be controlled and fugitive dust mitigated to ensure
the safety of workers and the community. It is anticipated that work will start in late
2024 or early 2025. Site remedial activities that disturb impacted soils and groundwater
are anticipated to take approximately one to two weeks to complete. The RAP will
describe procedures to manage impacted soil and groundwater (if any) that will be
disturbed during the remedial activities. All VCP documents including the RAP may be
viewed online at http://eqedocs.utah.gov/division-environmental-response-remediation,
and at the Utah DEQ/DERR offices at the address below. The Public Comment period
will commence on November 15, 2024, and comments will be received through
December 16, 2024. Please send written comments, either by mail or email to:

Ms. Leigh Anderson, Project Manager
Voluntary Cleanup/Brownfields Section
Division of Environmental Response and Remediation
Utah Department of Environmental Quality
P. O. Box 144840
195 North 1950 West, 1st Floor
Salt Lake City, Utah 84114-4840
[e-mail]
[phone]

Appendix B
Fugitive Emissions Monitoring Plan

WASATCH ENVIRONMENTAL, INC.
ENVIRONMENTAL SCIENCE AND ENGINEERING

Wasatch Environmental, Inc. 1
FUGITIVE EMISSIONS MONITORING PLAN
FORMER PRIDE CLEANERS
4358 SOUTH 900 EAST
MILLCREEK, UTAH

1. INTRODUCTION

This Fugitive Emissions Monitoring Plan (Plan) has been prepared for soil remediation activities at the
former Pride Cleaners property, consisting of 0.66 acres, located at 4358 South 900 East in Millcreek,
Utah (Site). Chlorinated solvent and petroleum hydrocarbon impacted soil is located at the Site. The
impacted soil will be excavated and disposed off-Site.

This Plan will be followed by the general contractor and all subcontractors during excavation, stockpiling,
on-Site relocation, and backfilling activities on the Site.

2. OBJECTIVES

The purpose of this Plan is to describe the fugitive dust control measures and Best Management
Practices (BMPs) that will be followed during soil excavation and backfilling activities to minimize the
generation of fugitive dust. Also described is the monitoring approach to evaluate effectiveness of the
dust control BMPs and to document those adjoining residents and workers involved with on-Site activities
are not exposed to fugitive dust, and that the State of Utah opacity limits are met.

Potential exposures to fugitive dust emissions by commercial/industrial properties in areas adjacent to the
Site and workers involved with impacted soil removal activities will be assessed using U.S. EPA Method 9
(Visual Determination of Opacity of Emissions from Stationary Sources) at the Site.

The equipment expected to be used during on-Site activities with the potential to generate fugitive dust
includes haul trucks, skidsters, front end loaders, water trucks, and excavators. A majority of this
equipment is not used on public roads so track-out is not expected to be an issue although it will be
monitored and prevented to the extent feasible. A temporary, stabilized gravel track-out pad will be in
place and steps will be taken to minimize track-out from equipment onto public roads.

By complying with the State of Utah Opacity limits, the National Ambient Air Quality Standards for
particulate matter, both particle sizes below 10 microns in diameter (PM10) and 2.5 microns in diameter
(PM2.5) will also be met. The daily limit for PM10 is 150 micrograms per cubic meter (ug/m3) and the daily
limit for PM2.5 is 35 ug/m3.

3. DUST CONTROL MEASURES/BEST MANAGEMENT PRACTICE

Attached to this Plan (as Appendix 1) is the Utah Division of Air Quality (DAQ) approved Fugitive Dust
Control Plan for the former Pride Cleaners project, which describes the construction BMPs to minimize
the generation of fugitive dust. These practices include the use of water to wet soils and haul roads, and
to form a crust on open soils. The Plan also discusses wetting stockpiles, maintaining low drop heights
when loading material, using gravel in lay-down areas, limiting vehicle speeds, and the proper application
of track-out controls. This Plan will be presented to the contractor and any subcontractors during initial
Site training activities. The Plan requires that all construction activities meet opacity requirements in
R307-309-5. It is Wasatch’s experience that wetting of soil greatly decreases any dust generation.

FUGITIVE DUST CONTROL PLAN Former Sommers Auto Wrecking
Wasatch Environmental, Inc. 2

Also attached to this Plan (as Appendix 2) is a wind rose diagram of frequency of wind direction and
speed during November 2022. The diagram shows that the prevailing winds are generally expected to be
out of the south to southeast, or from the northwest. The month of November is representative of the
winds from late summer through late fall.

It is Wasatch’s experience that heavy watering of stockpiles (if used) and exposed soil prior to ending
work before the weekend is effective in forming a “crust” on the soil which should reduce fugitive dust
generation. However, if strong winds are predicted during overnight hours or weekends, arrangements
will be made to provide additional watering.

4. DAILY MONITORING

Wasatch personnel will be on-Site during all soil removal and backfilling activities to screen soils using a
hand-held photoionization detector, collect confirmation soil samples for laboratory analysis, direct Health
and Safety meetings and training, and implement the fugitive dust control and monitoring procedures
described in this Plan.

Compliance with the Utah opacity limits (20% opacity at the generation source and 10% opacity at the
perimeter) will be assessed using U.S. EPA Method 9, modified to account for non-stationary sources.
For non-stationary sources, which would apply to vehicles on-Site, opacity readings are directed to a
point not less than one-half the vehicle length behind the vehicle and not less than one half the vehicle
height.

During soil remediation activities, Wasatch personnel trained as Visible Emission Observers will make
opacity observations at the point of generation and the down-wind property line, as well as at non-
stationary sources such as moving vehicles and/or equipment. These readings will be recorded on a
Visible Emissions Observation Form (Appendix 2), which includes weather conditions, wind speed and
direction, type of activity occurring on-Site, and position of observer relative to dust source. Opacity
readings will be made at least once daily, or as needed during peak work activities, or as weather
conditions require.

5. ACTION LIMITS

Utah opacity action limits will be used as action limits (20% opacity at the generation source and 10%
opacity at the perimeter) for this project.

Any concerns or indications that opacity action limits are being approached or exceeded will be
immediately addressed by aggressively applying additional BMPs, including, as warranted; pre-watering,
shifting the work area, curtailing certain types of work, or shutting down work activities.

When the wind speeds exceed 25 miles per hour, Rule 307-309-5 (3) exempts the opacity limits as long
as the operator continues to implement the approved fugitive dust control plan and administers at least
one of the following control methods: pre-event watering, hourly watering, shifting work areas, or ceases
or reduces dust producing operations.

6. REPORTING

Wasatch will consult frequently (at least weekly) with Utah VCP to discuss, address, and work to remedy
any fugitive dust control issues, including responding to resident complaints, re-evaluating, and modifying
dust control procedures, and other related problems that may arise.

A summary of the dust control measures, copies of the completed daily Air Quality Data Forms and any
corrective actions will be included in the Remediation Action Implementation Report.
FUGITIVE DUST CONTROL PLAN Former Sommers Auto Wrecking
Wasatch Environmental, Inc. 3

Sincerely,

WASATCH ENVIRONMENTAL, INC.

Blake B. Downey, P.G.
Vice President and Senior Project Hydrogeologist

APPEDNDICES

Appendix 1 – DEQ Fugitive Dust Control Plan
Appendix 2 – Daily Air Monitoring Form and Wind Rose Diagram

Appendix 1
DEQ Fugitive Dust Control Plan

Fugitive Dust
8/20/2024 7:40:18 AM
Introduction
Please complete the following information in order to create a Fugitive Dust Application for your
project.  You will have a chance to review the plan prior to nal submission.
Introduction
A Fugitive Dust Control Plan is required if your project is 1/4 acre or larger and located in
Cache, Box Elder, Weber, Davis, Salt Lake, Tooele or Utah County. Other areas and conditions
are optional.  Please complete the form to assess your project.
Project Location
Project Location
A Fugitive Dust Control Plan is required if your project is 1/4 acre or larger and located in
Cache, Box Elder, Weber, Davis, Salt Lake, Tooele or Utah County. Other areas and conditions
are optional.
Select the County where your project will be located :Salt Lake
Utah Administrative Code (UAC) 307-309-6 requires that any person owning or operating
a source of fugitive dust within PM10 and PM2.5 non-attainment and maintenance plan
areas on cleared land greater than 1/4 acre in size must submit a completed Fugitive Dust
Control Plan. The DAQ Temporary Relocation Form requires the submission of a Fugitive
Dust Control Plan Permit Number for all temporary relocation projects.
Is this project a temporary relocation project?:
Yes
No
Non-Attainment Dust Tutorial
What is Fugitive Dust?
Fugitive dust is dust that is stirred up, creating an air quality problem. It is made up of ne particles
called particulate matter. It is a health concern because it irritates eyes and nasal tissue and
seriously impacts the respiratory system.
x
Fugitive dust may come from gravel operations,
construction or demolition activities, land clearing and
exposed surfaces, roadways, and mining activities.
Trackout from muddy work areas also create fugitive
dust when the mud dries.
How We Measure Compliance-Opacity
Opacity is the
amount of light
that is blocked
by something
else such as
smoke or a
tinted window.
The percentage
of opacity can
provide a measure of the particulate matter in the air.
Opacity is measured as a percentage - 0% means that all light passes through; 100% means that
no light can pass through. The more particles present, the higher the opacity percentage.
Utah Fugitive Dust Rule R307-309-5
Non-attainment Dust Rule
Acknowledgements::
I acknowledge that Utah regulation R307-309-5(1)(a) prohibits fugitive dust to exceed 10%
opacity at the property boundary;
I acknowledge that Utah regulation R307-309-5(1)(b) prohibits fugitive dust to exceed 20%
opacity on site;
I acknowledge that Utah regulation R307-309-5(3) exempts the opacity requirements above,
ONLY when wind speed exceeds 25 miles per hour AND fugitive dust controls are maintained. The
online fugitive dust control plan requires selection of appropriate control measures that must be
implemented for this exemption to apply; and
I acknowledge that failure to comply with fugitive dust rules may result in compliance action
and penalties up to $10,000 per violation/day.
Applicant Information
Applicant Type::Sub Contractor
Plan Certicate Number:97A6CB6F7F
Name:Wasatch Environmental, Inc.
x
x
x
x
Mailing Address
Mailing Address - Address Line 1:2410 west California Ave.
Mailing Address - Address Line 2:
Mailing Address - City:Salt Lake City
Mailing Address - State:Utah
Mailing Address - Zip:84104
Email:[e-mail]
Phone:[phone]
Project Information
Project Name:Former Pride Cleaners
Project End Date:estimated to be November 30, 2024
Project Location
Address Line 1:4358 South 900 East
Address Line 2:
City:Millcreek
State:Utah
Zip:84124
Site Directions:Type address into google maps and hit navigate.
County:Salt Lake
Acreage:0.6
Calculated Acreage:0.6
Latitude/Longitude Verication
For Manual Latitude and Longitude input: 
Make sure to include at least 6 digits after the decimal and it must fall within the
state of Utah.
Example 40.404976 or 40.404976232
Latitude (Decimals Only) :40.676529
Longitude (Decimals Only) :-111.866152
Map Verication
Copy the following URL into your browser so you can verify on a map that the project latitude and
longitude you provided are correct.
Map Calculation:https://www.google.com/maps/place/40.676529,-111.866152
Latitude/Longitude verication:
The above Latitude and Longitude have been veried.
Point of Contact
Point of Contact for dust control matters and to whom a COMPLIANCE ACTION
should be sent if necessary.
Name:blake downey
Company:Wasatch Environmental.com
Address
Address Line 1:2410 west California Ave.
Address Line 2:
City:salt lake city
State:Utah
Zip:84104
Phone number:[phone]
Cell number:[phone]
Dust Suppressants
Do you plan on using chemical dust suppressing or stabilizing agents?:
Yes
No
Best Management Practices (BMP) Checklist
Best Management Practices (BMP) Checklist Instructions
Place a check mark next to every activity that will be conducted on this site.  
For each checked activity, complete the corresponding control measures/best management practices (BMP)
selection page.  When completed, we will email the entire plan to you. 
Fugitive Dust Plan Number:D39ACCF929
x
x
Select all that apply:
01. Backlling area previously excavated or trenched.
02. Blasting soil and rock - drilling and blasting.
03. Clearing for site preparation and vacant land cleanup.
04. Clearing forms, foundations, slab clearing and cleaning of forms, foundations and slabs
prior to pouring concrete.
05. Crushing of construction and demolition debris, rock and soil.
06. Cut and ll soils for site grade preparation.
07. Demolition - Implosive demolition of a structure, using explosives.
08. Demolition - mechanical/manual demolition of walls, stucco, concrete, freestanding
structures, buildings and other structures.
09. Disturbed soil throughout project including between structures. THIS ACTIVITY MUST BE
SELECTED FOR ALL PROJECTS.
10. Disturbed land - long term stabilization and erosion control of large tracts of disturbed land
that will not have continuing activity for more than 30 days.
11. Hauling materials.
12. Paving/subgrade preparation for paving streets, parking lots, etc.
13. Sawing/cutting material, concrete, asphalt, block or pipe.
14. Screening of rock, soil or construction debris.
15. Staging areas, equipment storage, vehicle parking lots, and material storage areas.
16. Stockpiles materials (storage), other soils, rock or debris, for future use or export.
17. Tailings piles, ponds and erosion control.
18. Trackout, Prevention and cleanup of mud, silt and soil tracked out onto paved roads. (THIS
ACTIVITY MUST BE SELECTED FOR ALL PROJECTS.)
19. Trac - unpaved routes and parking, construction related trac on unpaved interior
and/or access roads and unpaved employee/worker parking areas.
20. Trenching with track or wheel mounted excavator, shovel, backhoe or trencher.
21. Truck loading with materials including construction and demolition debris, rock and soil.
BMP - 09 Disturbed soil throughout project including between
structures.
GENERAL REQUIREMENT: ALL ACTIVITIES MUST MEET OPACITY REQUIREMENTS IN R307-309-5
MAKE AT LEAST ONE SELECTION FROM EACH SECTION.
Limit disturbance of soils where possible.:
09-01. Limit disturbance of soils with the use of fencing, barriers, barricades, and/or wind
barriers.
09-02. Limit vehicle mileage and reduce speed.
x
x
x
x
x
x
x
x
Stabilize and maintain stability of all disturbed soil throughout construction site.:
09-03. Apply water to stabilize disturbed soils. Soil moisture must be maintained such that soils
can be worked without generating fugitive dust.
09-04. Apply and maintain a chemical stabilizer.
09-05. Use wind breaks.
09-06. Apply cover (natural or synthetic).
BMP - 11 Hauling materials.
GENERAL REQUIREMENT: ALL ACTIVITIES MUST MEET OPACITY REQUIREMENTS IN R307-309-5
MAKE AT LEAST ONE SELECTION FROM EACH SECTION.
Limit visible dust opacity from vehicular operations.:
11-01. Apply and maintain water/chemical suppressant to operational areas and haul routes.
11-02. Limit vehicle mileage and speed.
Stabilize materials during transport on site.:
11-03. Use tarps or other suitable enclosures on haul trucks.
11-04. Apply water prior to transport.
Clean wheels and undercarriage of haul trucks prior to leaving construction site.:
11-05. Clean wheels.
11-06. Sweep or water haul road.
BMP - 15 Staging areas, equipment storage, vehicle parking
lots, and material storage areas.
GENERAL REQUIREMENT: ALL ACTIVITIES MUST MEET OPACITY REQUIREMENTS IN R307-309-5
MAKE AT LEAST ONE SELECTION FROM EACH SECTION.
Limit visible dust opacity from vehicular operations.:
15-01. Limit vehicle mileage and speed limit.
15-02. Apply water on all vehicle trac areas in the staging areas and unpaved access routes.
Stabilize staging area soils during use.:
15-03. Pre-water and maintain surface soils in a stabilized condition.
15-04. Apply and maintain a chemical stabilizer to surface soils.
x
x
x
x
x
x
x
Stabilize staging area soils at project completion.:
15-05. Apply a chemical stabilizer.
15-06. Apply screened or washed aggregate.
15-07. Use wind breaks.
15-08. Pave.
15-09. Completed project will cover staging area with buildings, paving, and/or landscaping.
15-10. Apply water to form adequate crust and prevent access.
BMP - 16 Stockpiles materials (storage), other soils, rock or
debris, for future use or export.
GENERAL REQUIREMENT: ALL ACTIVITIES MUST MEET OPACITY REQUIREMENTS IN R307-309-5
MAKE AT LEAST ONE SELECTION FROM EACH SECTION.
Stabilize surface soils where support equipment and vehicles will operate.:
16-01. Pre-water and maintain surface soils in a stabilized condition.
16-02. Apply and maintain a chemical stabilizer on surface soils.
16-03. Pave area.
Stabilize stockpile materials during handling.:
16-04. Remove material from the downwind side of the stockpile, when safe to do so.
16-05. Reduce height.
16-06. Create wind screen
Stabilize stockpiles after handling.:
16-07. Water stockpiles to form a crust immediately.
16-08. Apply and maintain a chemical stabilizer to all outer surfaces of the stockpiles.
16-09. Provide and maintain wind barriers on 3 sides of the pile.
16-10. Apply a cover (natural or synthetic)
16-11. Wind screen.
16-12. Avoid steep sides to prevent material sloughing.
16-13. Reduce height.
BMP - 18 Trackout, Prevention and cleanup of mud, silt and
soil tracked out onto paved roads.
GENERAL REQUIREMENT: ALL ACTIVITIES MUST MEET OPACITY REQUIREMENTS IN R307-309-5
MAKE AT LEAST ONE SELECTION FROM EACH SECTION.
x
x
x
x
x
x
Prevent dust from trackout.:
18-01. Clean trackout at the end of the work shift from paved surfaces to maintain dust
control
18-02. Maintain dust control during working hours and clean trackout from paved surfaces at
the end of the work shift/day.
18-03. Install gravel pad(s), clean, well-graded gravel or crushed rock. Minimum dimensions
must be 30 feet wide by 3 inches deep, and, at minimum, 50' or the length of the longest haul
truck, whichever is greater. Re-screen, wash or apply additional rock in gravel pad to maintain
eectiveness.
18-04. Install wheel shakers. Clean wheel shakers on a regular basis to maintain eectiveness.
18-05. Install wheel washers. Maintain wheel washers on a regular basis to maintain
eectiveness.
18-06. Motorized vehicles will only operate on paved surfaces.
18-07. Install cattle guard before paved road entrance.
All exiting trac must be routed over selected trackout control device(s).:
18-08. Clearly establish and enforce trac patterns to route trac over selected trackout
control device(s).
18-09. Limit site accessibility to routes with trackout control devices in place by installing
eective barriers on unprotected routes.
BMP - 20 Trenching with track or wheel mounted excavator,
shovel, backhoe or trencher.
GENERAL REQUIREMENT: ALL ACTIVITIES MUST MEET OPACITY REQUIREMENTS IN R307-309-5
MAKE AT LEAST ONE SELECTION FROM EACH SECTION.
Presoak soils prior to trenching activities.:
20-01. Pre-water surface.
Stabilize surface soils where trenching equipment, support equipment and vehicles will
operate.:
20-02. Pre-water and maintain surface soils in a stabilized condition.
20-03. Apply and maintain a chemical stabilizer to surface soils.
20-04. Limit mileage and speed.
Stabilize soils after trenching.:
20-05. Apply and maintain water on excavated soil.
20-06. Apply and maintain chemical stabilizer on excavated soil.
x
x
x
x
x
BMP - 21 Truck loading with materials including construction
and demolition debris, rock and soil.
GENERAL REQUIREMENT: ALL ACTIVITIES MUST MEET OPACITY REQUIREMENTS IN R307-309-5
MAKE AT LEAST ONE SELECTION FROM EACH SECTION.
Apply and maintain a chemical stabilizer on surface soils where loaders, support equipment
and vehicles will operate. :
21-01. Pre-water and maintain surface soils in a stabilized condition where loaders, support
equipment and vehicles will operate.
21-02. Apply and maintain a chemical stabilizer on surface soils where loaders, support
equipment and vehicles will operate.
21-03. Empty loader bucket slowly and keep loader bucket close to the truck to minimize the
drop height while dumping.
Reviewing Your Plan
Please carefully review your plan before submitting it. Once the plan has
been submitted, it CANNOT be edited.
BEFORE you submit your plan, if you need to make changes, navigate back to those
sections via the left navigation or the Previous button to complete those changes.
When you are satisfied, submit your plan.
The plan will be available to download in the My Forms section, under the Done
tab.
By submitting this plan I agree to the following terms:
A. I am authorized, on behalf of the individual or company listed in Section 1, as Applicant,
to apply for a Fugitive Dust Control Plan and to commit to all of the terms and conditions of
the requested plan.
B. Construction activities will be limited to lands that the applicant either owns or is
authorized to use for construction activities.
C. The applicant accepts responsibility for assuring that all contractors, subcontractors, and
all other persons on the construction site covered by this plan, comply with the terms and
conditions of the Fugitive Dust Control Plan.
D. I understand that any false material statement, representation or certification made in
this application may invalidate the plan or cause me to be subject to enforcement action
pursuant to Utah Code Ann. 19-2-115.
x
E. Failure to comply with fugitive dust rules may result in compliance action and penalties
up to $10,000 per violation/day.
Conrmation of terms:
My plan is ready to be submitted.
Frequently Asked Questions
Division of Air Quality
Utah Department of Environmental Quality
Feedback
Division of Air Quality
Address: 195 North 1950 West
P.O. Box 144820
Salt Lake City, UT 84114-482
Contact Phone: [phone]
Contact Fax: [phone]
Frequently Asked Questions
Frequently Asked Questions
Division of Air Quality
Utah Department of Environmental Quality
Feedback
Division of Air Quality
Address: 195 North 1950 West
P.O. Box 144820
Salt Lake City, UT 84114-482
Contact Phone: [phone]
Contact Fax: [phone]
x

Appendix 2
Daily Air Monitoring Form and Wind Rose Diagram
Former Pride Cleaners
Dust Control Form
VISIBLE EMISSION OBSERVATION FORM
Site Name
Address
City State Zip
Process Equipment Operating Mode
Control Equipment Operating Mode
Describe Emission Point

Height of Emission Point Height Relative to Observer

Start End
Distance to Emission Point

Start End
Direction to Emission Point

Start End
Vertical Angle to Observation Pt.
Start End
Direction to Observation Point
Start End
Describe Emissions

Start End
Emission Color

Start End
If Water Droplet Plume (Circle)
Attached Detached N/A
Point In The Plume At Which Opacity Was Determined

Start End
Describe Plume Background

Start End
Background Color

Start End
Sky Condition

Start End
Wind Speed

Start End
Wind Direction

Start End
Ambient Temp

Start End
Relative Humidity %

Additional Information

Continue on reverse side
Observation Date Start Time End Time
Sec Min 0 15 30 45 Comments
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30

Observer’s Name (Print)
Observer’s Signature Date
Organization
Certified by Date

Visible Emission Observation Location Map

Additional Information

Project No.: 2639-001EEnvironmental Science and Engineering
November 2022 Wind Rose Diagram
Former Pride Cleaners
Millcreek, Utah
Date: 8/20/24 Figure 1

Appendix C
Vapor Barrier Information

DRAGO® WRAP
VAPOR INTRUSION BARRIERINSTALLATION INSTRUCTIONS
ENGINEERED PERFORMANCELIFE OF THE BUILDING™ PROTECTION
LIF E O F T H E BUIL
DIN
G
•
WARRA N T Y •
STEGO
™
Additional Drago Wrap installation resources and
videos are available on our website at:
stegoindustries.com/resources
CONTENTS
SECTION 1 Drago Wrap and Drago Accessories . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
SECTION 2 Creating a Monolithic Membrane . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
SECTION 3 Where to Terminate the Drago Wrap . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
SECTION 4 Sealing Drago Wrap at Terminating Edges . . . . . . . . . . . . . . . . . . . . . . . 6,7
SECTION 5 Sealing Damaged Areas . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8
SECTION 6 Sealing Single Pipe Penetrations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
SECTION 7 Sealing Multiple Pipe Penetrations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .10
SECTION 8 Avoid Punctures with Beast Concrete Accessories . . . . . . . . . . . . . . .11
2
The installation recommendations set forth in these instructions are generally
based on ASTM E1643 and specific applications of Drago products. Each section
provides explanations and options for the varying conditions.
ST E G O I N STALLA
TIO
N
•
SUPPO R T •
S O
N
•
SUPPO R T •
Stego Installation Support - A Free Service
When you choose Stego® Barrier Solutions and products, you gain access to a large nationwide
network of full-time technical sales representatives providing unmatched local support and service.
If you ever have a question or concern regarding the following installation scenarios please contact
us and take advantage of our free Stego Installation Support.
For compliance with LARR regulations, some additional installation methods are required. For more information, visit:
stegoindustries.com/drago-larr-specific-installation-instructions
Continued... Note - legal notice on the last page.
Drago Wrap
SECTION 1 Drago Wrap Vapor Intrusion Barrier Installation Instructions 3
DragoSeal® Tape
Combines Drago Wrap technol-
ogy with a powerful adhesive for
a barrier solution to seal seams,
patches, and other details, de-
fending against vapor intrusion.
DragoTack® Tape
A solvent-resistant, double-sided
adhesive strip used to bond and
seal Drago Wrap to concrete,
masonry, wood, metal, and other
surfaces.
Drago® Mastic
A polymer-modified anionic
asphalt emulsion, designed to
be used with Drago Wrap, for
sealing utility, pipe penetra-
tions, and terminating edges.
Drago® Sealant
A two-component, high-
performance epoxy, designed
to be used with Drago Wrap
for sealing utility and pipe
penetrations.
At Stego, we know every project has its own unique challenges. To make a Drago Wrap installation easy and flexible, we
offer an extensive line of accessory items that gives you options to create a monolithic membrane between all interior
intrusion pathways and vapor sources below the slab as well as at the slab perimeter. Consult the project architect,
owner's representative, and design engineer of record before proceeding with any of these options.
Drago® Wrap Vapor Intrusion Barrier is a multi-layered plastic
extrusion that combines uniquely designed materials with only high
grade, prime, virgin resins. This patented barrier technology provides
high performance and longevity, allowing for the redevelopment of
contaminated sites, creating a healthy built environment.
Drago Accessories
Drago® Sealant Form
A low-density, cross-linked,
closed-cell polyethylene
foam designed to be used
as a detailing piece with
Drago Sealant.
Continued... Note - legal notice on the last page.
Creating a Monolithic Membrane
SECTION 2 Drago Wrap Vapor Intrusion Barrier Installation Instructions 4
The key to an effective Drago Wrap installation is to create a monolithic layer of protection between the building foundation
and vapor sources below. While Drago Wrap installation instructions are generally based on ASTM E1643 - Standard
Practice for Selection, Design, Installation, and Inspection of Water Vapor Retarders Used in Contact with Earth or Granular
Fill Under Concrete Slabs, these instructions are meant to be used as a guide, and do not take into account specific job site
situations. Consult local building codes and regulations along with the building owner or owner’s representative before
proceeding.
ASTM E1643 discusses the selection of the vapor retarder and preparation of the subbase to minimize potential damage
during installation and concrete placement.
ASTM E1643, Section 5.3.4.1 - Select a vapor retarder material capable of withstanding potential construction site damage.
ASTM E1643, Section 5.3.5.1 - Select vapor retarder material capable of withstanding tear or puncture damage due to the
type, gradation, and texture of the base material to be installed below the material. Prepare base material to minimize risk
of puncture, for example, by rolling or compacting.
ASTM E1643, Section 6.1 - Level and compact base material.
ASTM E1643 then states to create a monolithic membrane to protect the slab from adjacent moisture sources.
ASTM E1643, Section 6.4 - . . . create a monolithic membrane between the surface of the slab and vapor sources below
the slab as well as at the slab perimeter.
ASTM E1643, Section 6.5 - Lap joints as instructed by the manufacturer and seal laps in accordance with the manufacturer’s
recommendations.
Unroll Drago Wrap over the area where the slab is to be placed.
Note: Grey color side of membrane is face-down, copper color side is face-up.
Unless otherwise indicated by the design professional(s) of record, unfold Drago Wrap to completely cover the placement area.
All joints/seams should be over-lapped a minimum of 12 inches.
1 2 3
Ensure Drago Wrap is clean anddry when applying DragoSeal Tape.
Tip: Use a cloth or other means to remove dust, debris, and excess moisture from Drago Wrap prior to applying DragoSeal Tape.
Seal the seams with DragoSeal Tape.
Note: Remove the release liner of DragoSeal Tape prior to application. After applying DragoSeal Tape, use consistent, firm pressure along the 4” width of DragoSeal Tape to ensure continuous adhesion. Optional ~4” steel roller is ideal.
4 5
Drago Wrap can be installed over an aggregate, sand, or tamped earth base. It is not typically necessary to have a
cushion layer or sand base, as Drago Wrap is tough enough to withstand rugged construction environments. Con-
sult the design team for project-specific recommendations.
OPTIONAL SEALING METHOD:Hot air wedge welding equipment is ideal for heat welding seams of Drago Wrap.
Continued... Note - legal notice on the last page.
Where to Terminatethe Drago Wrap
SECTION 3 Drago Wrap Vapor Intrusion Barrier Installation Instructions 5
Always consult the project design team for where to terminate the vapor barrier to strike a balance between the
location of the vapor barrier on or around foundation constructions and any structural concerns before proceeding.
ASTM E1643 provides direction on where to terminate the vapor barrier as follows:
ASTM E1643, Section 6.4 - Extend vapor retarder over footings and seal to foundation wall, grade beam,
or slab at an elevation consistent with the top of the slab or terminate at impediments such as waterstops or dowels...
ASTM E1643, Section 6.6 - Extend vapor retarder over the tops of pile caps and grade beams to a distance acceptable to
the structural engineer.
In accordance with ASTM E1643, terminate the Drago Wrap as follows:
Note: Turn Drago Wrap up foundation walls or forms. Ensure Drago Wrap is flush against the corner to avoid tenting.
If the location of vapor barrier termination has not been clearly addressed in the construction documents, then clarification
should be requested from the project design team. Should no direction be given, Stego recommends the project team follow,
at minimum, the guidelines of ASTM E1643.
Regardless of where the vapor barrier is determined to be terminated, ASTM E1643 requires the terminating edges to be
sealed.
At Impediments; OR
Note: Impediments may include rebar, dowels, water stops, etc. and may be located at interior grade beams in addition to perimeter walls and footings.
At a location of termination designated by the project design team.
Note: The distance to which the vapor barrier is extended adjacent to, onto, or completely over a
footing or grade beam should be determined by the project design team.
At an elevation (height) consis-tent with the top of the slab;
Continued... Note - legal notice on the last page.
Using Drago Mastic
SECTION 4 Drago Wrap Vapor Intrusion Barrier Installation Instructions 6
IMPORTANT: Make sure the area of adhesion is free of dust, dirt, debris, moisture, and frost to allow
maximum adhesion.
Apply Drago Mastic to the foundation wall at the anticipated edge of the subsequently applied Drago Wrap at the height of the slab or impediments.
Press Drago Wrap firmly against the applied Drago Mastic on the founda-tion wall.
1 2
Sealing the Terminating Edges of Drago Wrap Up Foundation Walls & Vertical SurfacesUsing DragoTack Tape or DragoSeal Tape
DragoTack Tape or DragoSeal Tape can be used to seal Drago Wrap to foundation walls, grade beams or other adjacent
concrete constructions.
IMPORTANT: Make sure the area of adhesion is free of dust, dirt, debris, moisture, and frost to allow maximum adhesion.
Remove the release liner on one side of DragoTack Tape and adhere to foundation wall at the height of the slab or at impediments.
When ready to apply Drago Wrap, remove the exposed release liner from DragoTack Tape.
Press Drago Wrap firmly against DragoTack Tape to secure.
1 2
3
MECHANICAL SEAL OPTION:If a mechanical seal is needed, fasten a termination bar over the top of the Drago Wrap inline with the DragoTack Tape (as shown in image) or DragoSeal Tape.
Fasten a termination bar over the top of the Drago Wrap inline with the Drago Mastic.
Extend Drago Wrap up the vertical surface, likely to the height of the slab.
Note: See Where to Terminate the Drago Wrap, page 5.
Apply DragoSeal Tape on the perimeter edge so that 2” is on the Drago Wrap and 2” is on the wall/vertical surface. Press firmly to secure.
1 2
OR
DragoSeal Tape
DragoTack Tape
3
Continued... Note - legal notice on the last page.
Sealing the Terminating Edges of Drago Wrap on a Horizontal Plane
7
Onto a Perimeter Footing at Impedi-ments: Seal Drago Wrap to concrete with Drago Mastic.
Onto Interior Grade Beams at Imped-iments: Seal Drago Wrap to concrete with Drago Mastic.
At a Location Designated by the Design Team: Seal Drago Wrap to concrete with Drago Mastic.
Using Drago Mastic
Always consult the project design team for where to terminate the vapor barrier to strike a balance between the location
of the vapor barrier on or around foundation constructions and any structural concerns before proceeding.
After the location of where to terminate the vapor barrier has been determined, seal Drago Wrap along all terminating
edges as indicated by the project team.
Onto a Perimeter Footing at Impediments: Seal Drago Wrap to concrete with DragoTack Tape or DragoSeal Tape.
Onto Interior Grade Beams at Impedi-ments: Seal Drago Wrap to concrete with DragoTack Tape or DragoSeal Tape.
At a Location Designated by the Design Team: Seal Drago Wrap to concrete with DragoTack Tape or DragoSeal Tape.
Using DragoTack Tape or DragoSeal Tape
See “ Where to Terminate the Vapor Barrier” on page 5 prior to choosing your terminating edge sealing accessory.
MECHANICAL SEAL OPTION:If a mechanical seal is needed, fasten a termination bar over the top of the Drago Wrap inline with the DragoTack Tape (as shown in image); or fasten a termination bar over the 2” of DragoSeal Tape that is on top of Drago Wrap (not shown).
MECHANICAL SEAL OPTION: If a mechanical seal is needed, fasten a termination bar over the top of the Drago Wrap inline with the Drago Mastic.
SECTION 4 Drago Wrap Vapor Intrusion Barrier Installation Instructions
DragoSeal TapeDragoTack Tape
OR OR
DragoSeal TapeDragoTack Tape
(under Drago Wrap)DragoTack Tape DragoSeal Tape
OR
Continued... Note - legal notice on the last page.
SECTION 5 Drago Wrap Vapor Intrusion Barrier Installation Instructions 8
Sealing Damaged Areas:Small Hole or Slice
In the event that Drago Wrap is damaged during or after installation, repairs must be made. For smaller holes or
slices in Drago Wrap, DragoSeal Tape can be used as noted below.
Small hole or slice in Drago Wrap.Clean area of adhesion.Center DragoSeal Tape over small hole or slice in Drago Wrap. Apply pressure to DragoSeal Tape after application.
1 2 3
Larger Hole
In the event that Drago Wrap is damaged during or after installation, repairs must be made. For larger holes, cut a piece
of Drago Wrap to a size and shape that covers any damage by a minimum overlap of 6” in all directions. Clean all adhesion
areas of dust, dirt, moisture, and frost. Tape down all edges using DragoSeal Tape.

Occasionally there are larger holes in the vapor barrier that require a patch.Measure and cut a piece of Drago Wrap to cover damaged area 6” in all
directions. Clean area of adhesion.
Seal the patch with DragoSeal Tape.
1 32
Continued... Note - legal notice on the last page.
SECTION 6 Drago Wrap Vapor Intrusion Barrier Installation Instructions 9
Sealing Single Pipe Penetration:Minimal Void Space
All penetrations must be sealed. All pipe, ducting, rebar, wire penetrations and block outs should be sealed using Drago
Wrap and either DragoSeal Tape, Drago Mastic, or Drago Sealant and Drago Sealant Form. If penetrations are encased in
other materials, such as expansive materials like foam, unless otherwise specified, Drago Wrap should be sealed directly
to the underlying penetration.
Install Drago Wrap around pipe pen-etrations by slitting/cutting material as needed. Try to minimize the void space created.
Pull material over and flatten. Clean area of adhesion where the Drago accessory will be applied.
If Drago Wrap is close to pipe and void space is minimized then seal around pipe penetration with either DragoSeal Tape (as shown), Drago Mastic or Drago Sealant and Drago Sealant Form.
1 2 3
Larger Void Space Requires Detail Patch
To minimize void space around a larger penetration, a detail patch may be required.
Cut a detail patch to a size and shape that creates a 6” overlap on all edges around the void space at the base of the pipe.
Cut an “X” the size of the pipe diam-eter in the center of the detail patch and slide tightly over pipe.
Seal all sides of the detail patch with DragoSeal Tape.
1 2 3
Seal around the base of the pipe using DragoSeal Tape.Seal around the base of the pipe with Drago Mastic.
Note: apply using disposable glove, paint brush, or similar.
4a 4b
OR
Continued... Note - legal notice on the last page.
Install Drago Sealant Form continu-ously to Drago Wrap and around the entire perimeter of the group of penetrations and at least 1 inch be-yond the terminating edge of Drago Wrap.
3b
Pour Drago Sealant inside of Drago Sealant Form to create a seal around the penetrations.
Drago Sealant Form Drago Sealant
Sealing Multiple Pipe Penetrations:Using Drago Mastic or Using Drago Sealant and Drago Sealant Form
Multiple pipe penetrations in close proximity and very small pipes may be most efficiently sealed using Drago Wrap and
Drago Mastic, or Drago Wrap, Drago Sealant, and Drago Sealant Form.
Cut a slit the size to accommodate the width of the multiple pipes. Try to minimize the void space created.
1
SECTION 7 Drago Wrap Vapor Intrusion Barrier Installation Instructions 10
Place a detail patch over and around the base of the pipe penetrations as closely as possible, ensuring that it is flush with the base of the penetrations. Seal all sides of the detail patch with DragoSeal Tape.
2
Apply Drago Mastic around the entire perimeter of the group of penetra-tions and between the penetrations to
fill any void spaces present.
Note: apply using disposable glove, paint brush,
or similar.
3a
Note: If the void space between Drago Wrap and
the penetrations is not minimized and/or the base
course allows for too much drainage of sealant,
a second coat of Drago Sealant may need to be
poured after the first application has cured.
Drago Sealant pot/working life is roughly
30-45 minutes.
Drago Mastic
OR
3b2
Continued... Note - legal notice on the last page.
NOTE: Stego Industries, LLC’s (“Stego”) installation instructions are based on ASTM E1643 - Standard Practice for Selection, Design, Installation, and Inspection of Water
Vapor Retarders Used in Contact with Earth or Granular Fill Under Concrete Slabs. These instructions are meant to be used as a guide, and do not take into account
specific job site situations. Consult local building codes and regulations along with the building owner or owner’s representative before proceeding. If you have any
questions regarding the above mentioned installation instructions or Stego products, please call us at 877-464-7834 for technical assistance. While Stego employees
and representatives may provide technical assistance regarding the utility of a specific installation practice or Stego product, they are not authorized to make final design
decisions.
Avoid Punctures with Beast® Concrete Accessories
To help eliminate the use of non-permanent penetrations in Drago Wrap installation, Stego recommends the use of
Beast vapor barrier-safe concrete accessories.
IMPORTANT: Avoid puncturing Drago Wrap with stakes while forming, bracing, and screeding.
Set it and forget it. Beast Screed eliminates the need to frequently re-establish grade to ensure floor elevation has not changed during the screeding operation as is typical with traditional wet-screed methods.
Note: Refer to Beast Screed System Installation
Instructions for detailed usage instructions.
This concrete form stake takes the place of traditional nail stakes for interior forming applications, utilizing SpeedTrack™ Fastening Grooves for unlimited fastener placement.
Note: Refer to Beast Form Stake Installation
Guide for detailed usage instructions.
Beast Form Stake is strong enough to withstand a beating during concrete placement while holding its shape. It is easy to remove and reusable for the next job.
Note: Beast Form Stake can be removed once
concrete has set sufficiently to hold its shape. Fill
and repair any voids in the concrete as necessary
once the Beast Form Stake has been removed
and strike Beast Form Stake against a hard sur-
face to loosen the concrete buildup.
BEAST® FORM STAKE can
be used with BEAST® FOOT
as part of the Stego vapor
barrier-safe forming
system which meets ASTM
E1643 requirements.
Preventing punctures in the vapor barrier.
BEAST® HOOK is a
faster, easier way to set 2x4
overhead screeds. Use Beast Foot
and Beast Form Stake and make
it a vapor barrier-safe screed
system.
Locate itand lock it down!
BEAST® SCREED is a fixed-elevation,
point-to-point guide screed system
designed to replace common wet-
screed methods.
Improve efficiency and maintain concrete floor levelness with the BEAST SCREED SYSTEM!
SECTION 8 Drago Wrap Vapor Intrusion Barrier Installation Instructions 11
No tools are required, just grip the knob to loosen or tighten. Fast, easy, efficient.
Continued... Note - legal notice on the last page.
When it comes to building construction, don’t take the vapor intrusion barrier installation lightly. After all, it is there to protect the building’s vital foundation from the threats lurking below the slab.
Stego’s industry-leading barriers and unrivaled support equip you with the confidence to create resilient foundations for buildings where people work, learn, and gather.
DISCUSS YOUR PROJECT NEEDS
We help keep you up to speed on the latest installation methods.
Have questions? Give us a call.
877-464-7834
ST E G O I N STALLA
TIO
N
•
SUPPO R T •
S O
N
•
SUPPO R T •
stegoindustries.com
INDUSTRY LEADING BARRIERS AND UNRIVALED SUPPORT™
Stego Industries, LLC ("Stego"), Intellectual Property, Installation, Warranty, and State Approval Information: stegoindustries.com/legal.
©2024 Stego Industries, LLC. All rights reserved. 5/2024
™
P1 OF 2
DRAGO® WRAPVAPOR INTRUSION BARRIER
A STEGO INDUSTRIES, LLC INNOVATION | VAPOR RETARDERS 07 26 00, 03 30 00 | VERSION: MAY 28, 2024
1. PRODUCT NAME
DRAGO WRAP VAPOR INTRUSION BARRIER
2. MANUFACTURER
Stego Industries, LLC
216 Avenida Fabricante, Suite 101
San Clemente, CA 92672
Sales, Technical Assistance
Ph: [phone]
[e-mail]
stegoindustries.com
3. PRODUCT DESCRIPTION
TABLE 4.1: PHYSICAL PROPERTIES OF DRAGO WRAP VAPOR INTRUSION BARRIER
PROPERTY TEST RESULTS
Under Slab Vapor Retarders ASTM E1745 – Standard Specification for Water Vapor Retarders Used in Contact with Soil or Granular Fill under Concrete Slabs ASTM E1745 Compliant
Water Vapor Permeance ASTM F1249 – Test Method for Water Vapor Transmission Rate Through Plastic Film and Sheeting Using a Modulated Infrared Sensor 0.0069 perms
Push-Through Puncture ASTM D4833 – Test Method for Index Puncture Resistance of Geotextiles, Geomembranes, and Related Products 183.9 Newtons
Tensile Strength ASTM D882 – Test Method for Tensile Properties of Thin Plastic Sheeting 53.5 lbf/in
Permeance After Conditioning ASTM E154 Section 8, F1249 – Permeance after wetting, drying, and soaking 0.0073 perms(ASTM E1745 ASTM E154 Section 11, F1249 – Permeance after heat conditioning 0.0070 permsSections 7.1.2 - 7.1.5) ASTM E154 Section 12, F1249 – Permeance after low temperature conditioning 0.0062 perms ASTM E154 Section 13, F1249 – Permeance after soil organism exposure 0.0081 perms
Hydrocarbon Attenuation Factors Contact Stego Industries’ Technical Department
Chlorinated Solvent Attenuation Factors Contact Stego Industries’ Technical Department
Methane Transmission Rate ASTM D1434 – Test Method for Determining Gas Permeability Characteristics of 7.0 GTR** Plastic Film and Sheeting (mL(STP)/m2*day)
Radon Diffusion Coefficient K124/02/95 9.8 x 10-14 m2/second
Thickness 20 mil
Roll Dimensions 14' x 105' or 1,470 ft2
Roll Weight 150 lb
Note: perm unit = grains/(ft2*hr*in-Hg) ** GTR = Gas Transmission Rate
USES: Drago Wrap Vapor Intrusion Barrer is specifically engineered to attenuate volatile organic compounds (VOCs) and
serve as a below-slab moisture vapor barrier.
COMPOSITION: Drago Wrap Vapor Intrusion Barrer is a multi-layered plastic extrusion that combines uniquely designed
materials with only high grade, prime, virgin resins.
ENVIRONMENTAL FACTORS: Drago Wrap Vapor Intrusion Barrer can be used in systems for the control of various VOCs
including hydrocarbons, chlorinated solvents, radon, methane, soil poisons, and sulfates.
4. TECHNICAL DATA
Continued...
Note – legal notice on page 2.
DRAGO WRAPVAPOR INTRUSION BARRIER
A STEGO INDUSTRIES, LLC INNOVATION | VAPOR RETARDERS 07 26 00, 03 30 00 | VERSION: MAY 28, 2024
5. INSTALLATION
UNDER SLAB: Unroll Drago Wrap Vapor Intrusion Barrer over a tamped aggregate, sand, or earth base. Overlap all
seams a minimum of 12 inches and tape using DragoSeal® Tape. All penetrations must be sealed using a combination
of Drago Wrap Vapor Intrusion Barrer and Drago Accessories.
Review Drago Wrap Vapor Intrusion Barrer’s complete installation instructions prior to installation.
6. AVAILABILITY & COST
Drago Wrap Vapor Intrusion Barrer is available nationally through our network of building supply distributors. For
current cost information, contact your local Drago distributor or Stego® Sales Representative.
7. WARRANTY
Stego believes to the best of its knowledge, that specifications and recommendations herein are accurate and
reliable. However, since site conditions are not within its control, Stego does not guarantee results from the use of the
information provided herein. Stego does offer a limited warranty on Drago Wrap Vapor Intrusion Barrer. Please see
stegoindustries.com/legal
8. MAINTENANCE
Store Drago Wrap Vapor Intrusion Barrer in a dry and temperate area.
9. TECHNICAL SERVICES
Technical advice, custom CAD drawings, and additional information can be obtained by contacting Stego or by visiting
the website.
Email: [e-mail]
Contact Number: [phone]
Website: stegoindustries.com
10. FILING SYSTEMS: stegoindustries.com
P2 OF 2
DATA SHEETS ARE SUBJECT TO CHANGE. FOR MOST CURRENT VERSION, VISIT STEGOINDUSTRIES.COM
[phone] | stegoindustries.com
Stego Industries, LLC ("Stego") Intellectual Property, Installation, Warranty, and State Approval Information: stegoindustries.com/legal.
©2024 Stego Industries, LLC. All rights reserved.

Appendix D
DERR Site-Specific Cleanup Levels Document

Page 1 of 3
SSCL Calculator Prepared for:SSCL Calculator Prepared by:
Site name:
Site address:
Facility ID:
Release ID:
Contact name:
Contact phone:
Contact e-mail:
Site-Specific Cleanup Levels* for Residential/ Unknown Receptors
Air Groundwater Soil
SSCLair SSCLwing SSCLwesp SSCLwamb SSCLs-leach SSCLsesp SSCLsamb SSCLss
(See Eq. D.1)(See Eq. D.2)(See Eq. D.3)(See Eq. D.4)(See Eq. D.5)(See Eq. D.6)(See Eq. D.7)(See Eq. D.8)
Air Groundwater Groundwater Groundwater Subsurface soil Subsurface soil Subsurface soil Surface Soil
Inhalation Ingestion Indoor air
(enclosed space)
vapor inhalation
Outdoor air
(ambient) vapor
inhalation
Leaching to
groundwater
(groundwater
ingestion)
Indoor air
(enclosed space)
vapor inhalation
Outdoor air
(ambient) vapor
inhalation
Ingestion of soil,
inhalation of
vapors and
particles, and
dermal contact
µg/m3 air µg/m3 air mg/L water mg/L water mg/L water mg/L water mg/kg soil mg/kg soil mg/kg soil mg/kg soil mg/kg soil
Benzene (71-43-2)c 4.93E-01 9.87E-03 2.21E+00 5.17E+02 0.005 ND - MW-2S 1.02E-02 2.19E-01 9.35E+00 5.79E+00 0.002 ND
Toluene (108-88-3)nc 7.31E+03 8.18E+00 3.48E+04 8.67E+06 0.012 ND - MW-2S 1.73E+01 5.63E+03 2.41E+05 5.41E+03 0.005 ND
Ethylbenzene (100-41-4)nc 1.48E+03 1.02E+01 7.47E+03 1.93E+06 0.012 ND - MW-2S 4.37E+01 2.02E+03 8.62E+04 6.51E+03 0.005 ND
Xylenes (1330-20-7)nc 1.48E+02 2.04E+01 7.14E+02 1.71E+05 0.012 ND - MW-2S 9.40E+01 2.94E+02 1.26E+04 7.02E+03 0.005 ND
Naphthalene (91-20-3)nc 4.39E+00 2.04E+00 1.06E+02 7.87E+03 0.012 ND - MW-2S 1.30E+01 2.11E+02 9.02E+03 1.01E+03 0.005 ND
MTBE (1634-04-04)nc 4.38E+03 5.11E-01 3.10E+04 1.14E+06 0.012 ND - MW-2S 2.58E-01 5.67E+03 2.42E+05 3.40E+02 0.002 ND
Alkyl benzenes (C9-C10)
[average values]nc 3.07E+02 4.09E+00 1.61E+03 4.15E+05 0.125 ND - MW-2S 3.84E+01 9.77E+02 4.18E+04 2.50E+03 4.17 MW-2S
Alkyl naphthalenes (C11-C13)
[average values]nc 3.07E+02 4.09E+00 6.97E+03 5.31E+05 0.01 ND - MW-2S 2.06E+02 1.08E+05 4.63E+06 1.91E+04 0.25 ND
Total PAHs (C12-C22)
[average values]nc 1.53E+02 3.07E+00 5.58E+02 9.84E+04 0.01 ND - MW-2S 1.36E+03 4.32E+04 1.85E+06 1.35E+04 0.25 ND
Aliphatics (C5-C6)
[Hexane (110-54-3)]nc 3.07E+02 6.13E+00 1.21E+03 3.68E+05 0.125 ND - MW-2S 7.58E+01 9.27E+00 3.96E+02 3.60E+03 0.05 ND
Aliphatics (C7-C8)
[Heptane (142-82-5)]nc 3.07E+02 6.13E+00 1.46E+03 4.46E+05 0.125 ND - MW-2S 2.26E+02 1.88E+01 8.05E+02 3.60E+03 0.08 MW-2S
Aliphatics (C9-C10)
[Nonane (111-84-2)]nc 1.48E+03 1.02E+01 8.24E+03 2.52E+06 0.125 ND - MW-2S 2.58E+03 3.12E+02 1.34E+04 6.51E+03 3.87 MW-2S
Aliphatics (C11-C12)
[Undecane (1120-21-4)]nc 1.48E+03 1.02E+01 9.36E+03 2.86E+06 0.036 MW-2S 2.31E+04 3.91E+03 1.67E+05 6.51E+03 0.25 ND
Aliphatics (C13-C16)
[Hexadecane (544-76-3)]nc 1.48E+03 1.02E+01 1.08E+04 3.30E+06 0.013 MW-2S 3.61E+05 7.12E+04 3.04E+06 6.69E+03 0.25 ND
Aliphatics (C17-C21)
[Heptadecane (629-78-7)]nc 1.02E+04 2.04E+02 8.92E+04 2.72E+07 0.038 MW-2S 5.77E+08 6.88E+07 2.94E+09 1.36E+05 0.25 ND
Aliphatics (C22-C35)
[Heptadecane (629-78-7)]nc 1.02E+04 2.04E+02 8.92E+04 2.72E+07 0.082 MW-2S 5.77E+08 6.88E+07 2.94E+09 1.36E+05 0.25 ND
Highest
Air
Concentrations
Remaining at the
Site
Air
Comments
(e.g. Sample ID,
Sample Date, etc.)
Groundwater Comments
(e.g. Sample ID,
Sample Date, etc.)Chemical Name (CAS #)
Pr
i
m
a
r
y

C
h
e
m
i
c
a
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s

o
f

C
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c
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n
To
t
a
l

P
e
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r
o
l
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H
y
d
r
o
c
a
r
b
o
n

F
r
a
c
t
i
o
n
s
Highest
Groundwater
Concentrations
Remaining at the
Site
Soil
Comments
(e.g. Sample ID,
Sample Depth,
Sample Date, etc.)
Highest
Soil
Concentrations
Remaining at the
Site
Name:
Company, Agency, other:
Phone:
E-mail:
UST Consultant Cert. #:
Blake Downey
C-0268
Wasatch Environmental
435-760-8269
[e-mail]
Date prepared:11/20/2023
Pride Cleaners
Millcreek, Utah
DERRsRBCASSCCalculatorv Page 1 of 3
8/20/2024
7:58 AM
Page 2 of 3
Site-Specific Cleanup Levels* for Residential/ Unknown Receptors
Air Groundwater Soil
SSCLair SSCLwing SSCLwesp SSCLwamb SSCLs-leach SSCLsesp SSCLsamb SSCLss
(See Eq. D.1)(See Eq. D.2)(See Eq. D.3)(See Eq. D.4)(See Eq. D.5)(See Eq. D.6)(See Eq. D.7)(See Eq. D.8)
Air Groundwater Groundwater Groundwater Subsurface soil Subsurface soil Subsurface soil Surface Soil
Inhalation Ingestion Indoor air
(enclosed space)
vapor inhalation
Outdoor air
(ambient) vapor
inhalation
Leaching to
groundwater
(groundwater
ingestion)
Indoor air
(enclosed space)
vapor inhalation
Outdoor air
(ambient) vapor
inhalation
Ingestion of soil,
inhalation of
vapors and
particles, and
dermal contact
µg/m3 air µg/m3 air mg/L water mg/L water mg/L water mg/L water mg/kg soil mg/kg soil mg/kg soil mg/kg soil mg/kg soil
Highest
Air
Concentrations
Remaining at the
Site
Air
Comments
(e.g. Sample ID,
Sample Date, etc.)
Groundwater Comments
(e.g. Sample ID,
Sample Date, etc.)Chemical Name (CAS #)

Highest
Groundwater
Concentrations
Remaining at the
Site
Soil
Comments
(e.g. Sample ID,
Sample Depth,
Sample Date, etc.)
Highest
Soil
Concentrations
Remaining at the
Site
Acenaphthylene (208-96-8)nc 1.53E+02 3.07E+00 1.37E+04 5.04E+05 0.01 ND - MW-2S 6.13E+01 9.93E+04 4.24E+06 1.42E+04 0.5 ND
Acenaphthene (83-32-9)nc 8.69E+01 6.13E+00 6.40E+03 2.52E+05 0.01 ND - MW-2S 1.06E+02 3.96E+04 1.69E+06 2.15E+04 0.5 ND
Fluorene (86-73-7)nc 5.62E+01 4.09E+00 5.61E+03 1.95E+05 0.01 ND - MW-2S 1.14E+02 5.72E+04 2.44E+06 1.59E+04 0.5 ND
Phenanthrene (85-01-8)nc 1.53E+02 3.07E+00 2.25E+04 7.08E+05 0.01 ND - MW-2S 1.78E+02 4.82E+05 2.06E+07 1.50E+04 0.5 ND
Anthracene (120-12-7)nc 4.38E+02 3.07E+01 5.97E+04 1.90E+06 0.01 ND - MW-2S 1.68E+03 1.20E+06 5.15E+07 1.33E+05 0.5 ND
Fluoranthene (206-44-0)nc 5.83E+01 4.09E+00 1.22E+04 3.66E+05 0.01 ND - MW-2S 8.04E+02 8.93E+05 3.81E+07 1.94E+04 0.5 ND
Pyrene (129-00-0)nc 4.38E+01 3.07E+00 8.34E+03 2.48E+05 0.01 ND - MW-2S 5.58E+02 5.64E+05 2.41E+07 1.45E+04 0.5 ND
Benz(a)Anthracene (56-55-3)c 1.96E-01 3.92E-04 3.01E+01 8.94E+02 0.01 ND - MW-2S 2.83E-01 8.07E+03 3.45E+05 2.01E+00 0.5 ND
Chrysene (218-01-09)c 1.96E+00 3.92E-02 4.53E+02 1.33E+04 0.01 ND - MW-2S 2.26E+01 9.68E+04 4.14E+06 1.99E+02 0.5 ND
Benzo(b)Fluoranthene (205-99-2)c 1.96E-02 3.92E-04 4.35E+00 1.33E+02 0.01 ND - MW-2S 2.30E-01 9.46E+02 4.04E+04 1.98E+00 0.5 ND
Benzo(k)-Fluoranthene (207-08-09)c 1.96E-01 3.92E-03 5.28E+01 1.54E+03 0.01 ND - MW-2S 3.35E+00 1.68E+04 7.18E+05 1.99E+01 0.5 ND
Benzo(a)-Pyrene (50-32-8)c 2.35E-03 3.92E-05 3.89E-01 1.13E+01 0.01 ND - MW-2S 3.63E-02 1.34E+02 5.72E+03 1.99E-01 0.5 ND
Indeno(1, 2, 3-Cd)Pyrene (193-39-
5)c 2.35E-02 3.92E-04 1.14E+03 1.37E+03 0.01 ND - MW-2S 2.23E-02 2.30E+04 3.01E+04 1.96E+00 0.5 ND
Dibenzo-(a, h)Anthracene (53-70-
3)c 2.35E-02 3.92E-04 6.69E+00 1.95E+02 0.01 ND - MW-2S 2.05E+00 1.30E+04 5.57E+05 2.00E+00 0.5 ND
Benzo (g, h, i)-Perylene (191-24-2)nc 1.53E+02 3.07E+00 4.07E+04 1.19E+06 0.01 ND - MW-2S 6.74E+03 3.32E+07 1.42E+09 1.56E+04 0.5 ND
Not used c Not used Not used Not used Not used Not used Not used Not used Not used
Not used c Not used Not used Not used Not used Not used Not used Not used Not used
Not used c Not used Not used Not used Not used Not used Not used Not used Not used
Not used c Not used Not used Not used Not used Not used Not used Not used Not used
Not used c Not used Not used Not used Not used Not used Not used Not used Not used
Not used c Not used Not used Not used Not used Not used Not used Not used Not usedAd
d
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t
i
o
n
a
l

C
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m
i
c
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C
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n
(c
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)
In
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P
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H
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s

(
P
A
H
s
)
DERRsRBCASSCCalculatorv Page 2 of 3
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7:58 AM
Page 3 of 3
Site-Specific Cleanup Levels* for Residential/ Unknown Receptors
Air Groundwater Soil
SSCLair SSCLwing SSCLwesp SSCLwamb SSCLs-leach SSCLsesp SSCLsamb SSCLss
(See Eq. D.1)(See Eq. D.2)(See Eq. D.3)(See Eq. D.4)(See Eq. D.5)(See Eq. D.6)(See Eq. D.7)(See Eq. D.8)
Air Groundwater Groundwater Groundwater Subsurface soil Subsurface soil Subsurface soil Surface Soil
Inhalation Ingestion Indoor air
(enclosed space)
vapor inhalation
Outdoor air
(ambient) vapor
inhalation
Leaching to
groundwater
(groundwater
ingestion)
Indoor air
(enclosed space)
vapor inhalation
Outdoor air
(ambient) vapor
inhalation
Ingestion of soil,
inhalation of
vapors and
particles, and
dermal contact
µg/m3 air µg/m3 air mg/L water mg/L water mg/L water mg/L water mg/kg soil mg/kg soil mg/kg soil mg/kg soil mg/kg soil
Highest
Air
Concentrations
Remaining at the
Site
Air
Comments
(e.g. Sample ID,
Sample Date, etc.)
Groundwater Comments
(e.g. Sample ID,
Sample Date, etc.)Chemical Name (CAS #)

Highest
Groundwater
Concentrations
Remaining at the
Site
Soil
Comments
(e.g. Sample ID,
Sample Depth,
Sample Date, etc.)
Highest
Soil
Concentrations
Remaining at the
Site
Not used nc Not used Not used Not used Not used Not used Not used Not used Not used
Not used nc Not used Not used Not used Not used Not used Not used Not used Not used
Not used nc Not used Not used Not used Not used Not used Not used Not used Not used
Not used nc Not used Not used Not used Not used Not used Not used Not used Not used
Not used nc Not used Not used Not used Not used Not used Not used Not used Not used
Not used nc Not used Not used Not used Not used Not used Not used Not used Not used
* - Site-Specific Cleanup Levels assume a Natural Attenuation Factor of 1 (i.e. no natural attenuation). c - carcinogen; nc - non-carcinogen
Site-specific Parameters used in Calculations
Parameter Comments
Soil
Receptor
i
Lgw
Ls
Pavement
Precip.
Soil Zone
W
Ad
d
i
t
i
o
n
a
l

C
h
e
m
i
c
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l
s

o
f

C
o
n
c
e
r
n
(n
o
n
-
c
a
r
c
i
n
o
g
e
n
t
s
)
Width of contaminated source area parallel to groundwater flow or wind direction
Annual precipitation
Is contamination present in the saturated zone?
Is contamination beneath pavement or bare soils?
Depth to contaminated soil
Depth to groundwater
Hydraulic gradient
Select the most sensitive Receptor that is present at the site
Soil type representative of site
Description
23
Yes
70
Value
Silty clay
Residential/ Unknown
0.008
8
8
PAVED: contamination beneath
pavement
inches/year
Not applicable
ft
Units
Not applicable
Not applicable
ft-vertical/ft-lateral
ft
Not applicable
ft
DERRsRBCASSCCalculatorv Page 3 of 3
8/20/2024
7:58 AM