DERR-2024-004254

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144840 • Salt Lake City, UT 84114-4840
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
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State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor
Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF ENVIRONMENTAL
RESPONSE AND REMEDIATION

Brent H. Everett
Director
ERRC-013-24 January 23, 2024 Scott Wetzel PacifiCorp 1407 West North Temple Salt Lake City, Utah 84116 RE: Rocky Mountain Power – Power Redevelopment Project Voluntary Cleanup Program Site #119, Salt Lake City, Salt Lake County Dear Mr. Wetzel: The Division of Environmental Response and Remediation (DERR) has reviewed the Environmental Assessment (EA) for Areas B, C & D of the Rocky Mountain Power – Power Redevelopment Project site as required by the provisions of the Voluntary Cleanup Program (VCP). The documents previously reviewed as part of the EA are outlined in the DERR’s letter to PacifiCorp dated August 8, 2022. To facilitate project timelines, Area A was the first portion of the site to be characterized and moved forward under the VCP. The DERR has enclosed technical comments for Areas B, C & D to gather additional information in advance of evaluating a remedy for the site. Please address the comments and submit a Site Characterization Workplan for review. Thank you for your participation in the VCP. If you have any questions, please contact me at [phone]. Sincerely, Christopher Howell P.G., Project Manager Division of Environmental Response and Remediation CJH/tt Enclosure: Technical Comments cc: Angela Dunn, MD, MPH, Executive Director, Salt Lake County Health Department
Chris Howell (Jan 23, 2024 16:33 MST)
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DERR Review Comments - Environmental Assessment (Areas B, C & D)
Rocky Mountain Power VCP Site #119

General Comments:
1. Remedial actions in Area A are ongoing. Please continue to keep the DERR informed of
the schedule. In addition, the DERR will evaluate the recent data collected from the
Jordan River and surrounding banks before determining next steps.
2. Additional activities are necessary to investigate the site (Areas B, C & D) and delineate
the nature and extent of contamination prior to evaluating a remedy. Please propose a Site
Characterization Workplan (SCW) consistent with the DERR fact sheet detailing an
investigation approach and sampling scheme to address these review comments. The SCW
should include proposed sample locations, procedures, and analytical methods based on
historical site operations. In addition, the SCW should discuss the screening levels to be
used to evaluate the data. Analytical data in the VCP are typically screened against current
EPA Regional Screening Levels (RSLs), Initial Screening Levels (for TPH and TRPH),
Maximum Contaminant Levels (MCLs) and Vapor Intrusion Screening Levels (VISLs).
3. Please review the current sitewide Quality Assurance Project Plan (QAPP) to ensure that
the work proposed in the SCW for Areas B, C & D meets all necessary requirements.
4. If additional documentation of environmental conditions exists in Areas B, C & D such as
reports relative to the abatement canal, ACM consolidation under parking lots or any other
areas with previous work, please provide the reports to the DERR and summarize the
current status of the areas. This information will be necessary to review the proposed
SCW.
5. Surface soil was not previously evaluated in Areas B, C & D. Please propose sampling to
address surface soil in Areas B, C & D. Subsurface soil should be sampled, as appropriate,
to define the extent of contamination. At a minimum, the analytical method should include
metals, VOC’s, SVOC’s, PCB’s, cyanide, and TPH.
6. In order to fully characterize the site, additional groundwater data will be needed to
establish the groundwater gradient, and to evaluate, at a minimum, SVOCs (including 1,4-
dioxane), cyanide, dissolved metals and PFAS compounds. Please propose additional
groundwater sampling to characterize Areas B, C & D.
7. A composite sample was collected from borings NTO-9 and NTO-10 that show elevated
lead levels in soil. Please propose sampling to define the horizontal and vertical extent of
contamination in soil and sample groundwater to determine if there are potential impacts.
8. Previous Underground Storage Tanks (UST’s) were closed with contamination in place (FI
4001209, Releases HFH, KDK, GEI, JBQ). Please summarize all data from the previous
UST investigations and discuss the current status. If non-petroleum contamination is
commingled with a UST release, please discuss this in the SCW.
9. With respect to the comment above, the UST project manager should be contacted to
determine if any further cleanup actions will be necessary based on a possible change in
land use. As noted in the Voluntary Cleanup Agreement (VCA), UST releases are carved
out of the VCA and should be addressed in coordination with the DERR UST Branch.
10. Conditions under the remaining foundations, asphalt and concrete slabs are unknown. As
noted in General Comment #2, additional characterization is necessary at the site. Please
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propose sampling under these features or indicate that potential unknowns will be
addressed in the Remedial Action Plan (RAP) as the foundations and asphalt material are
removed to facilitate redevelopment. To assist with future development, please see the
following DERR fact sheet for Building Demolition and Foundation Removal.
11. Please note that agency acceptance and a 30-day public comment period are necessary
prior to implementing a proposed remedial action under the VCP (if the cleanup will be
phased, multiple public comment periods may be necessary). Public comments, if any,
must be addressed prior to beginning a remedial action.
12. The DERR will collect split samples, to be analyzed at a separate laboratory from the
laboratory selected by the applicant for sample analysis, as an independent quality
assurance measure. The applicant is responsible for paying for the analytical costs of the
split samples. Please designate and set up a state certified laboratory for analysis of split
samples.
13. If a Human Health and Ecological Risk Assessment will be proposed under the VCP,
please work closely with the DERR to ensure the parameters and methods align with
current criteria.

End of DERR EA Review Comments for Areas B, C & D