DERR-2025-005545

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. 800 346-3128
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor
Department of
Environmental Quality
Tim Davis
Executive Director

DIVISION OF ENVIRONMENTAL
RESPONSE AND REMEDIATION

Brent H. Everett
Director

ERRC-163-25

July 29, 2025

Jake Elsmore
Washmore, LLC
8234 South Roosevelt Street
Midvale, Utah 84047

RE: Remedial Action Plan Comment Letter, Pride Cleaners VCP Site
Salt Lake City, Salt Lake County, Utah

Dear Mr. Elsmore:

The Division of Environmental Response and Remediation (DERR) has reviewed the
revised Remedial Action Plan (RAP), dated March 26, 2025, for the referenced site. The review
was conducted as required by the provisions of the Voluntary Cleanup Program (VCP). The DERR
has enclosed technical comments. Please address the comments and submit a final RAP.

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

Sincerely,

Leigh Anderson, Project Manager
Division of Environmental Response and Remediation

KLA/jn

cc: Ron Lund, Environmental Health Director, Salt Lake County Health Department
Eric Peterson, Environmental Health Deputy, Salt Lake County Health Department
Blake Downey, Wasatch Environmental, Inc.
Quinn Walker, Division of Environmental Response and Remediation

Leigh Anderson (Jul 28, 2025 17:52:31 MDT)
Page 2
DERR Review Comments
Remedial Action Plan – Pride Cleaners VCP Site

General Comment:

1. Please indicate if a Site Management Plan and Environmental Covenant are proposed as a
component of this remedy.

Specific Comments:

1. Page 3, section 1.2, last paragraph: Please include a discussion of chloroform and TCE indoor air
and sub-slab samples relative to potential soil and groundwater impacts, as the last sentence of the
paragraph applies only to benzene and ethylbenzene.

2. Page 5, section 1.2, second paragraph and page 10, section 3.4: Please clarify whether vapor
barriers will be installed or if they will only be installed in the event cleanup goals or acceptable
fractionation risk goals cannot be met, as these two sections contradict each other. Please indicate
if any fans or vents will be included as part of the vapor mitigation strategy.

3. Page 6, section 1.3, paragraph 6: Please revise the text in these sections to indicate that the
concentration of PFAS was more than double on-site versus what could potentially be migrating
onto the property, or remove the statement that a nalyte concentrations were similar in concentration
to the analytes entering the Site.

4. Page 7, section 1.4 and page 9, section 2.5: Both arsenic and PFAS have MCLs. The DERR does
not set a new standard because contamination could be migrating onto the site. Appropriate risk
management will be used in the decision process (including the consideration of off-site
contamination) to reach the screening goals. Please revise the text in these sections.

5. Page 10, section 3.2 paragraph 2: The statement that groundwater is not expected to be
encountered in excavations contradicts other parts of the proposal, such as taking groundwater
confirmation samples directly from excavations in section 6.4. Please revise the text.

6. Page 14, section 6.4: In accordance with the letter sent June 19, 2025 from DERR’s Leaking
Petroleum Storage Tank (LPST) program, please revise sampling from the open excavations to
confirmation sampling from the monitoring wells in section 6.5 instead, and include petroleum
compounds. Please continue to coordinate with the LPST project manager and VCP project
manager.

7. Figure 10, Conceptual Site Model: Please remove the columns regarding residents and site
workers, as the site is currently not operating commercially and there are no residents yet. Site
Conceptual Models typically model current conditions, which helps guide remedial decisions.

8. Appendix A, Public Notice: Please add the following link for the public to view the RAP on-line:
https://deq.utah.gov/environmental-response-and-remediation/public -notices-utah-division-of-
environmental-response-and -remediation.