DERR-2024-006927

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
Printed on 100% recycled paper
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-067-24

May 7, 2024

Bruce Bastian
Paxton Project LLC
2483 North Canyon Road
Provo, Utah 84604
Re: The Paxton Voluntary Cleanup Program Site #129
Salt Lake City, Salt Lake County, Utah

Dear Mr. Bastian:

The Division of Environmental Response and Remediation (DERR) has reviewed the
following documents as required by the provisions of the Voluntary Cleanup Program (VCP):

● AGEC Applied Geotech, Limited Subsurface Sampling Investigation, dated
September 5, 2023;
● AGEC Applied Geotech, Limited Subsurface Sampling Investigation No. 2, dated
October 26, 2023; and
● Atlas Technical Consultants, Phase I Environmental Site Assessment, dated
December 20, 2023.

Collectively, these documents are considered the Environmental Assessment for the site
under the VCP. Based on a review of the documents, the DERR has enclosed technical comments
to gather additional information about the site and associated environmental conditions in advance
of evaluating a remedy for the property.

Please address the comments and submit a Quality Assurance Project Plan and Site
Characterization Workplan for review. Thank you for your participation in the VCP. If you have
any questions, please contact me at [phone].

Sincerely,

Allison Stanley, Project Manager
Division of Environmental Response and Remediation
Page 2
AS/tt

Enclosure: Technical Comments

cc: Brent Robinson, Geosyntec Consultants
Ron Lund, Environmental Health Director, Salt Lake County Health Department
Dorothy Adams, Interim Executive Director, Salt Lake County Health Department

Page 3
DERR Comments for Environmental Assessment
The Paxton VCP Site #129
General Comments:
1. Additional activities are necessary to investigate the site and delineate the nature and extent
of contamination prior to evaluating a remedy. Please propose a Site Characterization
Workplan (SCW) consistent with the fact sheet contained in the link detailing an
investigation approach and sampling scheme to address General Comments #8 - #14. The
SCW should include proposed sample locations, procedures, and analytical methods based
on historical site operations to characterize the nature and extent of contamination.
2. Please submit a Quality Assurance Project Plan (QAPP), and ensure the QAPP addresses
elements required in EPA’s QAPP guidance. The QAPP should include a Level 3 Reporting
Package or equivalent for all analytical data generated for the project. The Level 3 Reporting
Package should include a case narrative, all analytical results and qualifiers, surrogates, and
batch Quality Control (QC) results (Matrix Spike/Matrix Spike Duplicates, Lab Control
Samples, Method Blanks, etc.).
3. The SCW should discuss screening levels proposed for the project. 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). Additionally, please ensure that the laboratory
reporting limits are below the proposed screening levels.
4. For sites under the VCP, the DERR requests that non-detections be presented in the
summary tables as less than the method detection limit (MDL) rather than non-detect (ND).
In addition, results should be accompanied by the appropriate qualifier, if applicable.
5. The DERR will collect split samples, as appropriate, 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.
6. Please note that agency acceptance and a 30-day public comment period are necessary
before implementing a proposed remedial action plan (RAP) under the VCP. Public
comments, if any, must be addressed before beginning remedial action. At a minimum, the
RAP should propose a strategy to address known impacts identified during the investigations
such as the subsurface hydraulic post lift in the Quonset hut and any potential vapor intrusion
risks.
7. There are some transcription errors in Table 1A and Table 2 of the Limited Subsurface
Investigation, dated October 2023. Please review the accompanying lab reports and provide
an accurate table in the SCW to ensure that the historical data is accurate moving forward.
8. Building demolition may occur down to the foundations in accordance with all rules and
regulations (e.g., meeting DAQ program requirements for asbestos containing material).
The fact sheet contained in the link provides useful information and should be followed to
ensure the protection of human health and the environment. Please coordinate with the
DERR on this activity. Removal of material under the foundations should be conducted in
accordance with a RAP.
9. Due to the history of the site, uncertainty exists underneath the building foundations on the
property. To address the uncertainty, data should be collected to evaluate potential impacts.
Page 4
Characterization can take place as part of the SCW or be incorporated into the RAP once
characterization for the remainder of the site is accepted.
10. Once the site has been vacated by the current tenant, please conduct an additional inspection
to identify any additional areas of concern, as well as, possible hazardous materials that may
remain on the property that will need to be addressed. These activities should be coordinated
with the DERR.
11. Future work that may involve dewatering activities on the site must meet all current rules
and regulations. Please reach out to the appropriate entities to determine if analytical data is
required and coordinate these efforts with the DERR.
12. The EA identified groundwater impacts at the site, but the source is unclear. Some of the
documents suggested the contamination is emanating from an off-site source, but the
groundwater flow direction has not been defined to definitively make this conclusion. Please
define the groundwater flow direction and propose an updated round of groundwater
sampling so current conditions can be evaluated and the next steps determined.
13. During the site visit conducted on April 10, 2024, and during previous sampling events,
many areas of the site were inaccessible due to vehicles, equipment, and other debris
blocking access. Please propose a strategy to complete characterization efforts as the site is
cleared. The additional sampling should include a more robust surface sampling strategy
and vertical delineation as appropriate to define the extent of contamination.
Characterization is necessary even if the site will be excavated from boundary to boundary
as the data could impact future disposal options.
14. Previous investigations were unable to determine the exact structure of the underground
vault, lift, and/or tank outside of the former Auto Repair building at 225 West Paxton
Avenue. Characterization to identify and assess this structure may take place as part of the
SCW or be incorporated into the RAP, but additional information is necessary.
End of DERR EA Review Comments