DERR-2025-005671

Leigh Anderson <[e-mail]>
Pride Comments should go out today.
16 messages
Leigh Anderson <[e-mail]>Tue, Jul 29, 2025 at 8:06 AM
To: Blake Downey <[e-mail]>
Hey Blake, the comments should go out soon. I'm pretty open today so if you need me to hop on a call to have any
discussions, let me know. I don't think anything is too bad, I think we can wrap this up and I'm hoping we can move to
public comments around 1st of august, which would let you guys start in September.
Leigh Anderson <[e-mail]>Tue, Jul 29, 2025 at 8:11 AM
To: Blake Downey <[e-mail]>
I'm also free tomorrow before 12:30 pm, and thursday after 10 am.
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Blake Downey <[e-mail]>Tue, Jul 29, 2025 at 8:17 AM
To: Leigh Anderson <[e-mail]>
ok

Thank you!

Blake Downey, P.G.
Vice President and Senior Project Hydrogeologist
Wasatch Environmental
2410 West California Avenue
Salt Lake City, Utah 84104
Cell: 435-760-8269
Office: 801-972-8400
Email: [e-mail]
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Blake Downey <[e-mail]>Tue, Jul 29, 2025 at 8:22 AM
To: Leigh Anderson <[e-mail]>
Can you email me the comments?

Thank you!
8/5/25, 1:07 PM State of Utah Mail - Pride Comments should go out today.
https://mail.google.com/mail/u/0/?ik=5be3741f93&view=pt&search=all&permthid=thread-a:r3510619791034559909&simpl=msg-a:r184822094490588…1/6

Blake Downey, P.G.
Vice President and Senior Project Hydrogeologist
Wasatch Environmental
2410 West California Avenue
Salt Lake City, Utah 84104
Cell: 435-760-8269
Office: 801-972-8400
Email: [e-mail]

From: Leigh Anderson <[e-mail]>
Sent: Tuesday, July 29, 2025 8:12 AM
To: Blake Downey <[e-mail]>
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Leigh Anderson <[e-mail]>Tue, Jul 29, 2025 at 8:26 AM
To: Blake Downey <[e-mail]>
Someone on our admin staff needed to change something on the formal letter but I could send the word document without
letterhead, that shouldn't be changed.
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Pride RAP Comments2C.doc
41K
Blake Downey <[e-mail]>Tue, Jul 29, 2025 at 8:39 AM
To: Leigh Anderson <[e-mail]>
Great thanks!
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Blake Downey <[e-mail]>Mon, Aug 4, 2025 at 10:58 AM
To: Leigh Anderson <[e-mail]>
8/5/25, 1:07 PM State of Utah Mail - Pride Comments should go out today.
https://mail.google.com/mail/u/0/?ik=5be3741f93&view=pt&search=all&permthid=thread-a:r3510619791034559909&simpl=msg-a:r184822094490588…2/6
Leigh,

I have taken care of all the comments but Specific Comment #4. I am wondering if we could have a quick chat to fix this,
as what I have in here is what was requested last time? Or, can you provide me with a paragraph example that would
meet your needs?
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Leigh Anderson <[e-mail]>Mon, Aug 4, 2025 at 1:53 PM
To: Blake Downey <[e-mail]>
Hey again Blake, I sent out a video chat meeting that I'll be on for whenever you can join today. You can also give me a
call at 385-391-8144 or email me here.
I can see one part of why this comment may have caused confusion, I mix and matched between the workplan page
number and the pdf page number in this comment. Section 2.5 is on page six of the workplan, not page 9, page 9 is the
pdf search function.
The problem in section 2.5 is this sentence: "Additionally, the PFAS analyte concentrations were similar in concentration
to the analytes entering the Site from the
upgradient property." We've been hesitant about committing to this statement as you might recall, we'd rather just not
comment on whether what's on-site is "similar" to the concentrations off-site because we see them as elevated as
compared to the off-site numbers. Ultimately we're going to be determining what's going on with the PFAS by getting out
there and doing your clean up and determining from post-remedial sampling if there's anything else still to do.
For the other part of this comment, we simply can't accept using the concentrations coming on site from the south as the
cleanup numbers. The cleanup numbers for a residential site are the EPA numbers, if the remediation can't reach the EPA
cleanup goals, then that will have to be addressed by further coordination with us in regards to either more monitoring, or
additional work or management practices that will reduce the residential exposure risk.
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Blake Downey <[e-mail]>Mon, Aug 4, 2025 at 2:37 PM
To: Leigh Anderson <[e-mail]>
Leigh,

See sections 1.4 and 2.5 below. Are those sufficient to address your Specific Comment 4?

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) for groundwater or to SSCLs.
However, 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.
8/5/25, 1:07 PM State of Utah Mail - Pride Comments should go out today.
https://mail.google.com/mail/u/0/?ik=5be3741f93&view=pt&search=all&permthid=thread-a:r3510619791034559909&simpl=msg-a:r184822094490588…3/6

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) and PFAS exhibit concentrations below their applicable U.S. EPA MCLs for a period of 1 year. However, if
background PFAS or VOC concentrations in groundwater can be determined, the Client will work with DERR to
evaluate if the background concentrations can be used to determine that additional monitoring is no longer required.
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Blake Downey <[e-mail]>Tue, Aug 5, 2025 at 7:56 AM
To: Leigh Anderson <[e-mail]>
Leigh,

Please see the attached revised RAP for pride cleaners and a response to comments.

Thank you!

Blake Downey, P.G.
Vice President and Senior Project Hydrogeologist
Wasatch Environmental
2410 West California Avenue
Salt Lake City, Utah 84104
Cell: 435-760-8269
Office: 801-972-8400
Email: [e-mail]

From: Leigh Anderson <[e-mail]>
Sent: Monday, August 4, 2025 1:53 PM
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2 attachments
Final VCP Comments.pdf
236K
8/5/25, 1:07 PM State of Utah Mail - Pride Comments should go out today.
https://mail.google.com/mail/u/0/?ik=5be3741f93&view=pt&search=all&permthid=thread-a:r3510619791034559909&simpl=msg-a:r184822094490588…4/6
Former Pride Cleaners RAP.pdf
15881K
Leigh Anderson <[e-mail]>Tue, Aug 5, 2025 at 8:48 AM
To: Blake Downey <[e-mail]>
Okay got it. I'm also going to send it over to tanks to check that they have their comments addressed, I'm pretty sure their
main concern was wanting confirmation sampling around the former tank area with groundwater monitoring wells, so I
don't think it'll take them long to check.
I'll let you know when it's been through us both (and I'm hoping that'll be today).
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Leigh Anderson <[e-mail]>Tue, Aug 5, 2025 at 8:53 AM
To: Blake Downey <[e-mail]>
Hey Blake? I just scrolled down to check the Ex-3 confirmation sampling section and it still says you'll be taking the
sample from the excavation. Is this the correct version? It says it was updated August 4, but I wonder if it has all the other
changes discussed in it.
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Leigh Anderson <[e-mail]>Tue, Aug 5, 2025 at 10:08 AM
To: Blake Downey <[e-mail]>
Here is the language I'm proposing.
Section 2.2 - the cleanup goals are the EPA numbers. We will collaborate on risk mitigation and/or further action for
anything above the cleanup goals. Propose removing language about "determining cleanup goals" and clarification on the
soil arsenic.
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, and will be addressed via other forms of management. It is
also proposed to address arsenic in groundwater by risk management, pending the results of confirmation sampling near
the former tank area. Unexpected results will be addressed according to the contingency plan in section 7.
PFAS is migrating onto the Site from an off-Site source at concentrations that exceed 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 potential risk mitigation
measures.
Section 2.4 - Spell out the first instance of SMP and EC as Site Management Plan and Environmental Covenant, given
there will be a public review of the document and the public is not necessarily familiar with these abbreviations.
Proposed change to Section 6.4:
6.4 Groundwater Confirmation Sampling
Groundwater confirmation samples will be collected from the proposed wells on figure 11, or if MW-2 is rendered
unusable during foundation removable and a closer well might be more representative, a new well close to Exc-3 in the
former location of GP-5 will be installed to verify that the cleanup levels have been met. Samples will be collected
according to the procedures proposed in section 6.5.
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Blake Downey <[e-mail]>Tue, Aug 5, 2025 at 11:43 AM
To: Leigh Anderson <[e-mail]>
8/5/25, 1:07 PM State of Utah Mail - Pride Comments should go out today.
https://mail.google.com/mail/u/0/?ik=5be3741f93&view=pt&search=all&permthid=thread-a:r3510619791034559909&simpl=msg-a:r184822094490588…5/6
Leigh,

Let me know if this version works for you.

Thank you!

Blake Downey, P.G.
Vice President and Senior Project Hydrogeologist
Wasatch Environmental
2410 West California Avenue
Salt Lake City, Utah 84104
Cell: 435-760-8269
Office: 801-972-8400
Email: [e-mail]

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Former Pride Cleaners RAP.pdf
15413K
Leigh Anderson <[e-mail]>Tue, Aug 5, 2025 at 11:54 AM
To: Blake Downey <[e-mail]>, Jacob Elsmore <[e-mail]>
Hey Blake, I think this is good based on the discussion this morning. I'm going to send it over to tanks for them to verify
that their part is in how they want it, now that I have feedback of what exactly they want from them. Once they confirm, I'm
putting it online, and I'll send a follow up email that will serve as approval to get it published for public comment while I
prepare the formal letter about it.
Thanks,
Leigh
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Leigh Anderson <[e-mail]>Tue, Aug 5, 2025 at 1:07 PM
To: Leigh Anderson <[e-mail]>
Note to file: The language proposed in this email was discussed further during a meeting between Blake Downey, Scott
Everett, and DERR so that all parties could reach a consensus on clean up goal language and the approach for the tanks
confirmation sampling. Tanks has also subsequently approved the language proposed, and the corrected language is now
represented in the newest version of the RAP.
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8/5/25, 1:07 PM State of Utah Mail - Pride Comments should go out today.
https://mail.google.com/mail/u/0/?ik=5be3741f93&view=pt&search=all&permthid=thread-a:r3510619791034559909&simpl=msg-a:r184822094490588…6/6