DERR-2025-007817

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

SITE MANAGEMENT PLAN
FORMER SOMMERS AUTO WRECKING
647 WEST 3300 SOUTH
SOUTH SALT LAKE, UTAH
VOLUNTARY CLEANUP PROGRAM SITE NO. C122

Project No. 2469-002I

To:

Mr. Brent Everett
Utah Department of Environmental Quality
Division of Environmental Response and Remediation
195 North 1950 West
P.O. Box 144840
Salt Lake City, Utah 84114-4880

Prepared for:

Mr. Mark Bond
Mountain Crest Wasatch, LLC
3150 West 900 South
Salt Lake City, Utah 84104

Prepared by:

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

June 11, 2025

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Site Management Plan Former Sommers Auto Wrecking
Wasatch Environmental, Inc. Table of Contents
Page i
TABLE OF CONTENTS

Section Page No.
1. INTRODUCTION ............................................................................................................. 1
1.1 Site Description ................................................................................................................... 1
1.2 Site Background .................................................................................................................. 2
2. SITE MANAGEMENT ...................................................................................................... 3
2.1 Activity and Use Limitations ................................................................................................ 3
2.1.1 Site Management Plan ........................................................................................... 3
2.1.2 Land Use Limitations .............................................................................................. 3
2.1.3 Groundwater Limitations ......................................................................................... 3
2.1.4 Disturbance Limitations .......................................................................................... 4
2.1.5 Construction Dewatering Limitation ........................................................................ 4
2.1.6 Vapor Intrusion Limitations ..................................................................................... 4
2.1.7 Compliance Reporting ............................................................................................ 4
2.2 Maintenance, Access, and Inspections .............................................................................. 5
2.2.1 Notice ...................................................................................................................... 5
2.2.2 Disruption ................................................................................................................ 5
2.3 Environmental Covenant ..................................................................................................... 5
2.4 Monitoring Requirements .................................................................................................... 5
2.5 Site Management Contacts ................................................................................................. 6

Exhibits

Exhibit A – Property Location Map, Historical Sample Location Map, and Excavation and Sample
Location Map

Exhibit B – Sub-slab Depressurization System Conceptual Design

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SITE MANAGEMENT PLAN
FORMER SOMMERS AUTO WRECKING
647 WEST 3300 SOUTH
SALT LAKE CITY, UTAH 84104

1. INTRODUCTION

Wasatch Environmental, Inc., (Wasatch) has prepared this Site Management Plan (SMP) to present the
planned long-term approach for managing petroleum hydrocarbons and heavy metals impacts to soil and
groundwater at the former Sommers Auto Wrecking property (Property), located at 647 West 3300 South
in South Salt Lake, Utah.

This SMP has been prepared in accordance with the requirements of R315-101 “Cleanup Action and
Risk-Based Closure Standards” that establish information requirements to support risk-based cleanup
and closure standards at facilities for which remediation or removal of hazardous constituents to
background levels is not expected to be achieved. The “Owner” as defined in the Environmental
Covenant (EC) shall comply with the SMP, including provisions relating to the Activity and Use Limitations
pertaining to land use limitations, groundwater limitations, and disturbance limitations.

1.1 Site Description

The Property is an approximately 5.15-acre tract of real property, further identified as Tax Parcel
Numbers: 15-25-351-034 and 15-26-477-006. At the time of this document, the Property is developed for
industrial use (as shown in Exhibit A, Figures 1, 2, and 3). The legal description of the Property is:

15-25-351-034: BEG 165 FT W & 1027.7 FT N FR SE COR SEC 26, T1S, R1W, SL MER; N 81¿15' E
ALG S LINE OF 3300 S ST 89 FT; S 118 FT; W 87.95 FT TO STREET; N 104.6 FT TO BEG. ( BEING IN
LOT 9, BLK13, 10 AC PLAT A, BIG FIELD SUR ). ALSO, BEG N 81¿31'30" E 89.5 FT & N 1027.7 FT &
W 165 FT FR SW COR OF SEC 25, T1S, R1W, SLB & M; N 81¿31'30" E 80.43 FT; S 129.85 FT; W
79.55 FT; N 118 FT TO BEG. LESS ST. ALSO, BEG N 893.89 FT & E 3 FTFR SW COR SEC 25, T1S,
R1W, SLB & M; W 167.5 FT M OR L; N 28.8 FT M OR L; E 167.5 FT; S 28.8 FT M OR L TO BEG. ALSO,
BEG N 893.89 FT & W 165 FT FR SW COR SEC 25, T1S, R1W, SLB &M; E 167.5 FT M OR L; S 59.2
FT; W 167.5 FT TO E LINE ROAD; N 59.2 FT ALG SD ROAD TO BEG. ALSO, BEG 759.7 FT N & 3 FT
E FR SW COR SEC 25, T1S, R1W, SLB & M; W 168 FT M OR L TO E LINE OF 6TH WEST ST; N 75
FT; E 168 FT; S 75 FT TO BEG. ( BEING IN LOT 9, BLK 13, 10 AC PLAT A ). ALSO, BEG 31.8 RDS N&
3 FT E FR SW COR OF SEC 25, T 1S, R 1W, SLB & M; W 68 FT; N 175 FT; W 100 FT; N 60 FT; E 168
FT; S 235 FT TO BEG. ALSO, BEG 31.8 RDS N & 65 FT W FR SW COR SEC 25, T1S, R1W, SLB & M;
N 100 FT; W 100 FT; S 100 FT; E 100 FT TO BEG. ALSO, BEG 31.8 RDS N & 3 FT E FR SW COR SEC
25, T1S, R1W, SLB & M; E 167.05 FT; N 34.8 RDS TO S LINE 33RD S ST; S 81¿15' W ALG ST TO PT
DUE N OF BEG S TO BEG. ( BEING IN LOT 9, BLK 13, 10 AC PLAT A, BF SUR ). ALSO, BEG 31.8
RDS N & 170.05 FT E FR SW COR SEC 25, T1S, R1W, SLB & M; E 82.4 FT; N 34.8 RDS; S 81¿15' W
82.4 FT M OR L TO A PT DUE N OF BEG; S TO BEG. LESS STATE ROAD. ( BEING IN LOT 9, BLK 13,
10 AC PLAT A, BF SUR ). ALSO, BEG 1386 FT E & 526.46 FT N & 1133.55 FT W & N 521.72 FT M OR
L FR SW COR OF SEC 25, T1S, R1W, SLB & M; N 85¿11'10" E 17.72 FT; S 0¿16'43" E 523.23 FT; W
20.2 FT; N 521.72 FT TO BEG. 4.98 AC M OR L. 3826-45,46 4556-862 4873-838 5228-1051 5461-842
5929-1564 5941-482 5962-1387 6018-1950 6033-1331 6146-0207 6284-3048

Contains 4.98 acres

15-26-477-006: COM 624.7 FT N & 65 FT W FR SW COR SEC 25 T 1S R 1W SL MER N75 FT W 100
FT S 75 FT E 100 FT TO BEG 0.17 AC. 630-318 10325-8331 10393-8580 10559-7789

Contains 0.17 acres

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1.2 Site Background

The Site was formerly an auto wrecking yard occupied by Sommers Auto Wrecking. Currently, the Site is
occupied by a landscaping company and will be occupied by a metals recycling facility in the near future.

Our research indicates that the Site was residential and agricultural until 1956, when the former Sommer
Auto Wrecking business started on the eastern portion of the Site. The wrecking yard expanded to the
west between the 1960s and 1990s. In 2019, Sommers Auto Wrecking vacated the Site.

Wasatch prepared an August 19, 2021, Phase I Environmental Site Assessment for the Site. During the
completion of the Phase I Environmental Site Assessment, Wasatch identified the following recognized
environmental conditions in connection with the Site:

• In 2012, the Utah Division of Solid and Hazardous Waste (DSHW) recommended that the Site
owner remove oil-impacted soil in the area of the dismantling building. Approximately 840 tons of
impacted soil was removed and disposed off-Site. The excavation reportedly stopped at a clay
layer approximately 4 feet below ground surface (bgs), and confirmation soil samples were not
collected. No formal closeout documentation was created. Given that no confirmation soil
samples were collected, there was a potential for residual impacts in this area.

• Total petroleum hydrocarbons as gasoline-range organics (TPH-GRO) and oil and grease (O&G)
impacts to soil and groundwater exceeding Utah Initial Screening Levels (ISLs) and/or Utah Risk-
Based Corrective Action (RBCA) Tier 1 Screening Levels were identified by DSHW in 2012.

• Low concentrations of tetrachloroethene (PCE) were detected in soil and water samples in two
areas in 2012 indicating that PCE was either brought onto, or used at, the Site; therefore, there
was a potential for elevated concentrations of PCE to be present in soil and groundwater in other
areas of the Site.

• Soil samples collected in 2012 were analyzed for Toxicity Characteristic Leaching Procedure
(TCLP) metals, which is an analysis that measures leaching potential when evaluating soil
disposal options. While the TCLP metals concentrations were below United States
Environmental Protection Agency (U.S. EPA) landfill regulations, this analysis only applies to
hazardous waste determination. Later in 2012, lead was detected in a waste characterization soil
sample that was collected during excavation activities at concentrations that exceeded U.S. EPA
Residential and Commercial Regional Screening Levels (RSLs), indicating that elevated metals
concentrations are likely present at the Site.

• There was a drainage system and sump in the former oil storage building that was reportedly not
working and has since been filled with concrete. There was a potential for impacts to the
subsurface from this former drainage system.

• Given the long-term use of the Site for auto wrecking and evidence of long-term poor
housekeeping practices, there was a potential for impacts to the Site in areas that were not
investigated in 2012.

• There was a potential for impacts to the Site from releases associated with the long-term use of
the east adjoining Pick-n-Pull property for auto wrecking.

From 2021 through 2023, Wasatch completed three soil and groundwater sampling investigations that
identified and characterized heavy metals and petroleum hydrocarbon impacts at the Property. No
chlorinated solvent impacts were discovered above U.S. EPA Regional Screening Levels (RSLs).
Wasatch recommended that impacts be reported to the Utah Department of Environmental Quality
(UDEQ). The owner/operator of the Property reported the release to the UDEQ. On July 22, 2022, the
Property was entered into the Utah Voluntary Cleanup Program (VCP) for regulatory oversight and was
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assigned VCP Site #C122. The Utah VCP requested that additional Property characterization activities
be completed at the Site, at the time of entry into the VCP, to facilitate the development of a remedial
action plan (RAP).

The Property was sufficiently characterized and documented in the VCP-approved “Site Characterization
Report – Revised” dated November 27, 2023, which was completed by Wasatch. Based on this report,
lead and arsenic were detected in soils at concentrations that exceeded the U.S. EPA RSL for Industrial
Soil, and petroleum hydrocarbons were detected in soil and groundwater at concentrations that exceeded
their applicable Utah Initial Screening Level, U.S. EPA RSL for Industrial Soil, U.S. EPA Maximum
Contaminant Level (MCL), and/or the calculated Site-Specific Cleanup Levels (SSCLs) calculated using
the UDEQ Division of Environmental Response and Remediation (DERR)-approved Risk-Based
Corrective Action (RBCA) SSCL calculator. Four impacted areas were identified by Wasatch and
recommended for active remediation.

Given the totality of the Site characterization data, Wasatch submitted a RAP to the VCP, which was
approved in a letter from the VCP dated January 30, 2024. In the RAP, an arsenic in soil cleanup goal of
45 milligrams per kilogram (mg/kg) was requested by Wasatch and accepted by the VCP.

Given the totality of the volatile organic compound (VOC) and petroleum hydrocarbon data, it does not
appear that these impacts are migrating off the Property. This is likely due to the clay lithology of the
Property.

See Exhibit A, Figure 2 for the historical sample locations and Property features.

In 2024, Wasatch completed four excavations at the Property that removed the heavy metal impacts and
petroleum hydrocarbon impacts to soil to concentrations below the VCP-approved cleanup goals, except
for one western sidewall sample within excavation 4 (EXC-4, the petroleum hydrocarbon excavation).
EXC-4 was extended to the west to the Property boundary, where numerous underground utilities were
present, restricting additional soil removal in this area. Additionally, groundwater was extracted from
EXC-4, treated on the Property, and discharged to the storm sewer under a Division of Water Quality
permit to remediate groundwater petroleum hydrocarbon impacts in that area. See Exhibit A, Figure 3 for
excavation and sample locations.

As part of closure activities, Wasatch will submit the required documents for the DERR to complete a Blue
Stakes notice for the utility corridor along the western Property boundary near excavation EXC-4.

2. SITE MANAGEMENT

2.1 Activity and Use Limitations

The EC to be recorded against the Property imposes the following activity and use limitations on the
Property:

2.1.1 Site Management Plan

The Owner shall comply with this SMP.

2.1.2 Land Use Limitations

The Property is suitable for commercial and industrial use consistent with applicable local zoning
laws. Planting crops or fruit trees for consumption by humans or livestock is prohibited.

2.1.3 Groundwater Limitations

Groundwater from the shallow unconfined aquifer shall not be used for drinking water, irrigation,
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bathing, or other domestic purposes. Other uses of groundwater, if desired, from the water table
on the Property shall be subject to review and approval by the Director prior to implementation.

2.1.4 Disturbance Limitations

Appropriate care shall be exercised during construction, remodeling, and maintenance activities
at the Property so as to prevent exposure to heavy metals and petroleum hydrocarbon-impacted
soils. If disturbances are anticipated, the following apply:

1. Workers will be required to comply with the Occupational Safety and Health
Administration (OSHA) training for hazardous materials.
2. All Workers must wear appropriate personal protective equipment (PPE) while
completing the work, and be sufficient to prevent exposure to heavy metals and petroleum
hydrocarbon-impacted soils.

3. If disturbances require the removal and off-Property disposal of soil, the soil that is
removed shall be treated/disposed of in accordance with applicable law. Additionally, prior to
soil removal and disposal, the DERR must be notified and approve the proposed removal and
disposal activities, which will include the appropriate soil waste sample characterization and
proposed disposal facility. Once the excavation and disposal work are completed, disposal
documentation must be submitted to the DERR.

4. If disturbances require the temporary excavation of soils, but do not require off-Property
disposal, the excavated soils must be segregated, properly stockpiled on plastic, covered with
plastic until re-deposition, redeposited, and covered with the excavated overburden or clean
soil.

5. DERR shall be notified of any plans for excavations. DERR may require sampling of the
surface used to store any excavated material.

2.1.5 Construction Dewatering Limitation

Dewatering conducted to facilitate construction on the Property may require that the groundwater
be treated to reduce contaminant concentrations prior to discharge. Prior to commencement of
dewatering activities, appropriate permit(s) shall be obtained for discharge to either the
stormwater system (under a Utah Pollutant Discharge Elimination System permit obtained from
the Utah DEQ, Division of Water Quality) or to the sanitary sewer (under a Wastewater Discharge
Permit obtained from the sewer district). Testing and/or treatment of the groundwater may be
required by the receiving facility.

2.1.6 Vapor Intrusion Limitations

Given the constituents of concern, vapor intrusion of petroleum hydrocarbons is of concern.
Should buildings be constructed within 100 feet of the EXC-4 excavation area (see Figure 3),
vapor mitigation measures should be installed to mitigate potential vapor intrusion. Exhibit C
includes details for a potential vapor mitigation measure, or a chemical grade vapor barrier
capable of preventing petroleum hydrocarbons or chlorinated solvents from entering the building
could be installed.

2.1.7 Compliance Reporting

Upon request, the Owner shall submit written documentation to the UDEQ verifying that the
activities and use limitations remain in place and are being followed.

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2.2 Maintenance, Access, and Inspections

Under the EC, the Owner of any portion of the Property, shall be responsible for compliance with the SMP
and EC.

The Holder under the EC and the Director and their respective authorized agents, employees, and
contractors shall have rights of reasonable access to the Property at any time after the effective date of
the EC for inspections and monitoring of the compliance with the EC, and for complying with the terms
and conditions of the EC and this SMP. Nothing in this SMP shall be construed as expanding or limiting
any access and inspection authorities of the Holder or Director under the law.

2.2.1 Notice

Any party or person desiring to access the Property under authority of the EC shall provide notice
to the then-current Owner of the affected portion of the Property not less than 48 hours in
advance of accessing the Property, except in the event of an emergency condition which
reasonably requires immediate access. In the event of any such emergency condition, the party
exercising this access right will provide notice to the then-current owner of the affected portion of
the Property requiring access as soon thereafter as is reasonably possible.

2.2.2 Disruption

To the extent that the Holder, the Director, or their authorized representatives, conduct any
activities on or within any portion of the Property, they will use reasonable efforts to comply with
the current Owner’s business operation and security needs and requirements, and will conduct
such activities so as to cause the least amount of disruption to the use of the affected portion of
the Property as may be reasonably possible. Any person who conducts any activities shall repair
or replace any improvements or landscaping damaged on the affected portion of the Property by
such activities. The Director will determine what needs, requirements, and activities are
reasonable. Should the Director’s activities cause damage to the affected portion of the Property
improvements or landscaping that are not repaired or replaced, the injured party may present a
claim against the State of Utah in accordance with Utah law.

2.3 Environmental Covenant

An EC containing the above-referenced activity and use limitations will be recorded with the Office of the
County Recorder of Salt Lake County, Utah.

2.4 Monitoring Requirements

The Owner shall comply with the activity and use limitations stated in Section 2.1, and, if constructing a
building within 100 feet of the EXC-4 excavation, complete and report to the Director one or a
combination of the following options: 1) installation of a chemical grade sub-slab vapor barrier capable of
preventing petroleum hydrocarbons or chlorinated solvents from entering the building, 2) installation of a
topcoat vapor barrier (such as Roll-Cote™ or equivalent), and/or 3) installation of sub-slab vapor
depressurization systems and subsequent monthly monitoring to ensure systems are functional. If sub-
slab vapor depressurization systems are required, Owner will be responsible for maintaining sub-slab
depressurization fans, and Owner shall keep maintenance records for sub-slab vapor extraction fans to
be submitted upon request of the DERR.

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2.5 Site Management Contacts

Inquiries concerning the SMP should be directed to the following:

Mountain Crest Wasatch, LLC
Mark Bond
3150 West 900 South
Salt Lake City, Utah 84104
[phone]

And

Utah Department of Environmental Quality
Division of Environmental Response and Remediation
Brent Everett
P.O. Box 144840
Salt Lake City, Utah 84114-4880
[phone]
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EXHIBIT A

Property Location Map
Historical Sample Location and Site Feature Map
Excavation and Sample Location Map
(3 pages)
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The use or reuse of this information is restricted to the referenced document unless otherwise authorized.
Wasatch Environmental Copyright 2006
FORMER SOMMERS AUTO WRECKING WEI 2469-002I
Figure 1 Site Location Map
Approximate
Location of Site
1 inch is equal
to 840 feet
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The use or reuse of this information is restricted to the referenced document unless otherwise authorized.
Wasatch Environmental Copyright 2006
Figure 2
Office
(1940)
Inaccessible
Garage
(2000s)
Original
Garage
(1950s)
Dismantling
Building (2013/2014)
(Area of 2012 Soil Removal)
Oil
Building
(1990s)
(Former Sump
in This Building)
Secondary
Containment (Added in 2012)
(Area Where Oil and Grease
Concentration Exceeded
Tier 1 in Soil and Low Concentration
of PCE Was Detected in Water [2012])
Canopy
Stained
Concrete
Stained
Soil and
Concrete
Former Diesel
AST Location
Former Significant Current
and Historical Staining
on Degraded Concrete
Former
Drum StorageFormer Engine Storage
Area Where
TPH-GRO
Exceeded ISLs in Soil
(2012)
Area of Where
TPH-GRO Exceeded
ISLs and Low Concentration
of PCE in Soil Detected (2012)
Building and
Wrecked Vehicles
Where Previously
Located in This Area
(1950s-1980s)
Historical Sample Location and Site Feature Map
FORMER SOMMERS AUTO WRECKING WEI 2469-002I
GP-1
GP-2
GP-3
GP-4
GP-6
GP-7GP-8
GP-9 GP-10 GP-11
GP-12
GP-13
GP-15
GP-16
GP-17
GP-18
1 inch is equal
to 50 feet
GP-25 GP-24
GP-23
3300 South
70
0

W
e
s
t
GP-26
GP-27
DU-1
DU-2
DU-3DU-4
DU-5
Monitoring Well Location
LEGEND
DU-X Initial Surface Soil Sampling Decision Unit
Boring Location
GP-30
GP-32
GP-28
GP-29
GP-31
MW-2
MW-3
MW-4
MW-5
MW-1
GP-33
DU-XX Sub-Divided Surface Soil Sampling Decision Unit
GP-5
DU-1A
DU-1B DU-1C DU-1D DU-1E
DU-2A
DU-2B
DU-2C DU-2D DU-2E
70
0

W
e
s
t
Overhead Power
Sanitary Sewer Line
Storm Water Sewer Line
Communications Line
Water Line
Test Pit Sample Location
TP-1
TP-6
TP-5
TP-2
TP-4
TP-3
MW-6
MW-7
GP-19
GP-20
GP-21
*Map does not include confirmation samples
GP-14
GP-22
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The use or reuse of this information is restricted to the referenced document unless otherwise authorized.
Wasatch Environmental Copyright 2006
Figure 3Excavation and Sample Location Map
FORMER SOMMERS AUTO WRECKING WEI 2469-002I
1 inch is equal
to 50 feet
3300 South
70
0

W
e
s
t
LEGEND
Excavation Area
Soil Confirmation Sample Location
EXC-1
Test Pit Sample Location
TP-1
TP-6
TP-5
TP-2
TP-4
EXC-4
EXC-3
Area of Concrete
Removal and Confirmation
Composite Surface Soil Sample Area
Area of Concrete Removal
EXC-4-NW
EXC-4-NE2
EXC-4-East2
EXC-4-East1/
EXC-4-East10
EXC-4-SEEXC-4-SW
TP-3
EXC-4-Floor3 EXC-4-Floor4
EXC-4 Floor40
EXC-4-Floor2
EXC-4-Floor5
EXC-2-N
EXC-2
EXC-2-W/
EXC-2-W2
EXC-2-S
EXC-2-SE
EXC-2-E
EXC-2-Floor
EXC-3-N
EXC-3-Floor/
EXC-3-Floor10
EXC-3-W
EXC-3-S
EXC-3-E
EXC-1-1
EXC-1-2
EXC-1-4
EXC-1-5
EXC-1-3
EXC-1-16/
ECC-1-160
EXC-1-6
EXC-1-7
EXC-1-8
EXC-1-9
EXC-1-10
EXC-1-11
EXC-1-12
EXC-1-13/
EXC-1-130
EXC-1-14
EXC-1-15
MW-6
MW-7
Monitoring Well Location
Excavation Groundwater Sample Location
EXC-4-GW1
Approximate Site Boundary
Overhead Power
Sanitary Sewer Line
Storm Water Sewer Line
Communications Line
Water Line
EXC-4-West1
EXC-4-West2
EXC-4-Floor1
EXC-4-West3/
EXC-4-West4
EXC-4-GW2
DU-1
DU-2
DU-X Surface Soil Sampling Decision Unit
EXC-4-NE
EXC-1-COMP
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EXHIBIT B

Sub-Slab Depressurization System Conceptual Design
(1 page)
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WEI 2469-002ISub-Slab Depressurization System Conceptual Design
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