DERR-2025-008675

VCP Comment Wasatch Response to VCP Comment (Blake Downey, P.G.)
Preliminary Explanation of Project Goals and Benefits
Wasatch is working with Washmore Laundry, LLC, (Client) to establish a feasible cleanup plan for the 1300 South SLC project
where chlorinated solvent, PFAS, and a petroleum release is located at 1215 South 400 West, 1225 South 400 West, and 390
West 1300 South in Salt Lake City, Utah (“Site”). The Site has been historically used as a machining/welding shop with some
small equipment service for a number of years. Previous owners did nothing to address any of the releases at the Site. The
cleanup plan for this Site is intended to eliminate the release(s) and reduce analyte concentrations that are acting as sources of
soil, groundwater, and soil gas contamination. Wasatch intends to submit a Remedial Action Plan (RAP) to the Utah Voluntary
Cleanup Program (VCP) for review, comment, and approval to address the know releases at the Site.
VCP COMMENTS
1. General SCWP Comment 1: The SCWP, SAP, and QAPP
all contain references that suggest benzene and PFAS
compounds originate from an off-site source. However, further
characterization is necessary to better understand the site and
reported impacts. Please remove these references from the
text, as site characterization is still ongoing, or include a
notation in the text stating that this is the Applicant’s opinion and
further data collection is still needed to verify conclusions
regarding any impacts that might be migrating onto the property.
This change has been incorporated.

2. General SCWP Comment 2: With regards to the above
comment, please confirm the groundwater flow direction
so that current conditions can be better assessed.
Wasatch will collect depth to groundwater on the existing
piezometers at the Site to construct a piezometric surface map
to be included in the report as stated in Task 2.
3. General SCWP Comment 3: Please include a table that
clearly outlines the proposed sample locations, methods,
analytes, and the rationale for each location to help
summarize the proposed sampling.
The requested table has been included.

4. General SCWP Comment 4: Surface soil sampling has not
been conducted at the site. Please propose a sampling
strategy to address this data gap for areas where
redevelopment will involve direct contact with surface soils.
Given that Wasatch is sampling suspected release areas
(stained areas and areas with potential release features), that
the Site has been paved for most if its history, and chemical
products have not been stored over the whole Site; it is
Wasatch’s opinion that the collection of surface soil samples
across the whole site is unwarranted. However, to address this
concern Wasatch recommends that a contingency be place
within the future RAP that states Wasatch will survey the
surface soils for potential impacts once the pavement is
removed and collect samples in locations that appear to be
impacted.
5. General SCWP Comment 5: During the site visit on October
1, 2025, a covered sump was observed in the southern building.
Wasatch Environmental explained that access to the sump was
limited during previous investigations, preventing the collection
of a nearby sample. Now that the area is accessible, please
propose a sample location near the sump to better analyze for
potential impacts in the soil and groundwater.
Wasatch has moved boring GP-27 to the Sump as shown in
Figure 2.

6. General SCWP Comment 6: During the site visit on October
1, 2025, an area immediately outside the Wasatch Equipment
Sales and Services building exhibited staining, with several
used oil buckets nearby. Please propose sampling to
characterize this area. Additionally, two catch basins were
observed along the eastern boundary. The property owner
indicated that one drain potentially led to an off-site grease trap.
To help guide characterization efforts, please identify the nature
and direction of these subsurface features in the SCWP.
Wasatch has added boring GP-28 to be completed in the oil-
stained area as requested. This boring will be advanced in the
area that exhibits the highest degree of surface staining.
Wasatch will use our line inspection camera to inspect the lines
going to and from the catch basins to determine direction of
these subsurface features.
7. Specific SCWP Comment 1: Section 1, third sentence-
Please correct the VCP number to #140.
This has been corrected.
8. Specific SCWP Comment 2: Task 2a, third paragraph, fifth
sentence- The plan states that lower soil samples will only be
analyzed if the upper sample exceeds a screening level.
Wasatch will ensure this request, and this is now stated in the
revised SCWP.

Please ensure that any samples analyzed at a later date meet
the method's preservation and holding time requirements to
guarantee project data quality standards.
9. Specific SCWP Comment 3: Task 2a, fifth paragraph, third
sentence- Tetrachloroethene (PCE) and benzene exceedances
were reported in soil gas and groundwater near proposed
sample locations GP-23 and GP-25. To help define the
horizontal and vertical extent of contamination and identify
potential sources, please also analyze for volatile organic
compounds (VOCs) in soil and groundwater at these proposed
boring locations.
These sample locations are located directly adjacent to previous
borings (GP-2 and GP-3) where VOCs in soil and groundwater
have been previously analyzed. There is not sufficient distance
from these previously borings to gain any additional data that
would be helpful regarding the distribution of VOC impacts. We
were completing these borings to get hexavalent chromium data
in these areas. We request that we not analyze for VOCs in
these areas as the data already exists. However, Wasatch has
edited the SCWP to state that if unknown soil impacts to soil are
observed, Wasatch will collect appropriate soil samples and
coordinate with the VCP and our Client to determine what
constituents to analyze for.
10. Specific SCWP Comment 4: Task 4, sixth sentence- Please
note that the SCWP is not a decision document and cleanup
levels should be removed from the document and proposed in
the Remedial Action Plan. Contaminants should be screened
against the most current EPA Regional Screening Levels
(RSLs), Initial Screening Levels (for TPH and TRPH), Maximum
Contaminant Levels (MCLs), and EPA Vapor Intrusion
Screening Levels (VISLs).
The SSCL verbiage has been removed.
11. Specific SCWP Comment 5: Figure 2- Previous
investigations detected PCE above screening levels in the
groundwater and soil gas beneath the Wasatch Equipment
Sales and Services building. To gather current data and
evaluate potential sources, please propose an additional
sample near GP-4 and SG-6.
Boring GP-29 has been added to this area for analysis of VOCs.
12. Specific SAP Comment 1: Section 4.0, third paragraph,
second sentence- Please remove references to background
arsenic concentrations, as arsenic was reported above the RSL
This has been removed. Agreed, Wasatch will work with DERR
to develop site-specific arsenic cleanup levels.

in soil. The DERR recognizes that naturally occurring levels of
arsenic in the Salt Lake Valley can exceed the RSL (residential
and commercial for arsenic); however, the SAP is not a decision
document, and site-specific levels will need to be proposed in
the RAP. Please work with the DERR during the development
of the RAP to address this matter.
13. Specific SAP Comment 2: Section 4.0, eighth paragraph,
second sentence- Under the VCP, the DERR does not use Tier
1 screening levels. It is acceptable to screen against the Initial
Screening Levels (for TPH-DRO/GRO and TRPH only).
However, the Applicant may wish to refine the evaluation of the
potential risks and address any uncertainty by using the
underground storage tank (UST) Fractionation method to
differentiate the petroleum hydrocarbons.
Agreed, in the future, if needed, Wasatch would fractionate
samples that exceed the applicable Utah ISLs to support future
confirmation sampling. I also removed the reference to RBCA
Tier I Screening Levels.
14. Specific SAP Comment 3: Tables 1 and 2- Please include a
table in the text that lists containers, preservatives, and hold
times for each analytical method and sampled media.
Table 3 has been added to address this request.
15. General QAPP Comment 1: Please identify the screening
levels to be used during the course of the project, as these are
not identified in the QAPP.
This has been stated in Section 5.
16. General QAPP Comment 2: Please include the training and
certification requirements for all personnel involved with the
project. Consult Element A11 of the EPA Crosswalk guidance
provided in the link to address this comment.
Wasatch has not been required to provide this in the past.
However, see Section 12 which was added to address this
comment.
17. Specific QAPP Comment 3: Table 1, precision- Please
change the relative percent difference (RPD) to 25% for
groundwater samples.
The VCP has previously accepted 30% RPD for precision
evaluation in previous QAPPs. However, this change has been
made.
18. Specific QAPP Comment 4: Table 1, sensitivity - To
properly assess data quality objectives as defined in the QAPP,
analytical tables and laboratory data reports should reference
This has been added to the table.

the method detection limit (MDL) rather than the laboratory
reporting detection limit (RDL). Please adjust this in the table to
ensure future laboratory data includes both the MDL and RDL.