HAZARD RANKING SYSTEM (HRS) DOCUMENTATION RECORD COVER SHEET

Name of Site:

 

 700 South 1600 East PCE Plume

EPA ID No.: UTD981548985

Contact Person:

 U.S. Environmental Protection Agency, Region 8 

 Sabrina Forrest, National Priorities List Coordinator

 1595 Wynkoop Street, Mail Code: 8EPR-B 

 Denver, Colorado 80202-1129

 (303) 312-6484

Pathways, Components, or Threats Not Scored:

The surface water migration, soil exposure, and air migration pathways were not scored in this Hazard Ranking 

System (HRS) documentation record because they are not expected to significantly contribute to the overall site 

score.
HRS Documentation Record

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700 South 1600 East PCE Plume

UTD981548985

HRS DOCUMENTATION RECORD

Name of Site: 700 South 1600 East PCE Plume

EPA Region: 8 

Date Prepared: September 2012

Street Address of Site*: Intersection of 700 South & 1600 East

City, County, State, ZIP Code: Salt Lake City, Salt Lake County, Utah 84102

General Location in the State: North central

Topographic Map: Fort Douglas, Utah

Latitude*: 40.753938° North Longitude*: -111.848022° West (Figure 1)

The location given above is the approximate center of the current known extent of ground water contamination. 

 

Ground water Pathway 100.00

Scores:

Air Pathway NS

Soil Exposure Pathway NS

Surface Water Pathway NS

HRS Site Score 50.00

Note: 

NS = Not scored

* The street address, coordinates, and contaminant locations presented in this HRS documentation record identify the general area the 

site is located. They represent one or more locations EPA considers to be part of the site based on the screening information EPA used 

to evaluate the site for NPL listing. EPA lists national priorities among the known “releases or threatened releases” of hazardous 

substances; thus, the focus is on the release, not precisely delineated boundaries. A site is defined as where a hazardous substance has 

been “deposited, stored, placed or otherwise come to be located.” Generally, HRS scoring and the subsequent listing of a release 

merely represent the initial determination that a certain area may need to be addressed under CERCLA. Accordingly, EPA 

contemplates that the preliminary description of facility boundaries at the time of scoring will be refined as more information is 

developed as to where the contamination has come to be located.
HRS Documentation Record

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UTD981548985

WORKSHEET FOR COMPUTING HRS SITE SCORE

 S S2 

1. Ground water Migration Pathway Score (Sgw): 100

(from Ref.1, Table 3-1, line 13)

10,000

2a. Surface Water Overland/Flood Migration Component: NS

(from Ref.1, Table 4-1, line 30)

NS

2b. Ground water to Surface Water Migration Component: NS

(from Ref.1, Table 4-25, line 28)

NS

2c. Surface Water Migration Pathway Score (Ssw): NS

(Enter the larger of lines 2a and 2b as the pathway score) 

NS 

3. Soil Exposure Pathway Score (Ss): NS

(from Ref.1, Table 5-1, line 22)

NS

4. Air Migration Pathway Score (Sa): NS

(from Ref.1, Table 6-1, line 12)

NS

5. Total of Sgw

2 + Ssw2 + Ss2 + Sa2

: 10,000

6. HRS Site Score: Divide the value on line 5

by 4 and take the square root: 50.00

Note:

NS = Not Scored
HRS Documentation Record (Interim Final)

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700 South 1600 East PCE Plume

UTD981548985 3

TABLE 3-1 (Ref. 1)

GROUND WATER MIGRATION PATHWAY SCORE SHEET

Aquifer Evaluated: ‘Principal Aquifer’

Factor Categories and Factors Maximum Value Value Assigned

Likelihood of Release to an Aquifer

1. Observed Release 550 550

2. Potential to Release:

 2a. Containment 10 NS

 2b. Net Precipitation 10 NS

 2c. Depth to Aquifer 5 NS

 2d. Travel Time 35 NS

 2e. Potential to Release [lines 2a(2b+2c+2d)] 500 NS

3. Likelihood of Release (higher of lines 1 and 2e) 550 550

Waste Characteristics

4. Toxicity/Mobility a 100 

5. Hazardous Waste Quantity a 100 

6. Waste Characteristics 100 10 

Targets

7. Nearest Well b 45

8. Population

 8a. Level I Concentrations b 0 

 8b. Level II Concentrations b 9,051

 8c. Potential Contamination b 254

 8d. Population (lines 8a + 8b + 8c) b 9,305

9. Resources 5 0 

10. Wellhead Protection Area 20 20

11. Targets (lines 7 + 8d + 9 + 10) c 9,370

Ground Water Migration Score for an Aquifer

12. Aquifer Score [(lines 3 x 6 x 11)/82,500] 100 100

Ground Water Migration Pathway Score

13. Pathway Score (SWgw), (highest value from line 

12 for all aquifers evaluated)c

100 100

Notes: 

a = Maximum value applies to waste characteristics category

b = Maximum value not applicable

c = Do not round to the nearest integer

NS = Not scored
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Approximate Extent of Known

Ground Water Contamination 

Fort Douglas 7.5' USGS Quad 

Sugar House 7.5' USGS Quad 

PCE Disposal

Point to Sewer 

Latitude: 40.754o N

Longitude: -111.848o W 

VA Medical Center

Building 7 

Sanitary

Sewer Line 

UOS - START3 

700 SOUTH 1600 EAST PCE PLUME SITE

SALT LAKE CITY, UTAH 

Figure 1: 700 South 1600 East

PCE Plume Location 

07/2012 

0 0.125 0.25

Miles 

USGS Topographic Map1998

Fort Douglas 7.5' Quad

Sugar House 7.5' Quad  ́ 

^_ 

Salt Lake City

U t a h U t a h

Data: Sanitary Sewer Line location: Ref. 8, pp. 39, 40 PCE Disposal Point: Ref. 8, pp. 43 - 45

Contamination extent: Refs. 26, 27, 28 

Legend

VA Medical Center Building 7 

PCE Disposal Point to Sewer 

Sanitary Sewer Line 

Approximate Extent of Known Ground Water Contamination 

Author: skane Date/Time: Friday, July 13, 2012 1:27:54 PM File: T:\START3\East Side Springs HRS\GIS\Maps\Figure1.mxd 
 

 

 

 

 

 

 

 

Sunnyside Ave. 

Sanitary Sewer Line Building 7 

PCE Disposal Point 

to Sewer 

Author: ND_Williams Date/Time: Thursday, July 05, 2012 10:49:12 AM File: T:\START3\East Side Springs HRS\GIS\Maps\Reference 4.mxd 

700 SOUTH 1600 EAST PCE PLUME

SALT LAKE CITY, UTAH 

Figure 2: Source Location 

07/2012 UOS - START3 

0 125 250
  ́ Feet
 

Data: Sanitary Sewer Line location: Ref. 8, pp. 39, 40 

Disposal Point to Sewer: Ref. 8, pp. 43 - 45 

Datum/Projection: NAD 1983 UTM Zone 12N Maps: Bing Maps 2011 
^

^^ ___ SL20

1123 E. Alpine

ESS-SW-16

SL30 

1205 E. Gilmer

Path: T:\START3\East Side Springs HRS\GIS\Maps\Figure3.mxd

700 SOUTH 1600 EAST PCE PLUME

Figure 3. Ground Water Observed Release and 

Location of PCE-Contaminated Springs

Maps: Bing Maps 2011

Projection System: NAD 1983 State Plane 

Utah Central FIPS 4302 Feet  ́

Data: Well and spring locations: Refs. 20, 21, 22, 26, 27, 28, 45

 PCE disposal point to sewer: Ref. 8, pp. 43 - 45

 Sanitary sewer line location: Ref. 8, pp. 30, 40

07/2012 UOS - START3

0 250 500 125

Feet

1156 E. 900 S.

&-

^^

^^

^^

__

__

__

PCE Disposal Point

to Sewer

SLCWS Well #18

East Side Springs

Mount Olivet 

Cemetery Irrigation 

Well

VA Medical

Center Building 7

Sanitary

Sewer Line

ESS-SW-15 

SL62

1127 E. Sunnyside SL18

1143 E. Sunnyside

SL23

SL25

1156 E. 900 S.

ESS-SW-17

1115 E. Sunnyside

EPA-MW-03

EPA-MW-01D/S

EPA-MW-02

EPA-MW-04

EPA-MW-06

EPA-MW-05

Ground Water

Flow Direction

y

!.

&- Mt Olivet Well

!. SLCWS Well #18

^_ PCE-Contaminated Spring 

EPA Wells - 1998

Sanitary Sewer Line

VA Medical Center Building 7

Observed Release to Ground Water

sample ID

address

Fort Douglas

Military Installation

University of Utah

VA Medical 

Center

Salt Lake City

Utah Sports Complex

Army

National

Guard

East High

School

Mount Olivet

Cemetery
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UTD981548985 7

REFERENCES

Ref.

No. Reference description 

1. U.S. Environmental Protection Agency (EPA), Hazard Ranking System (HRS), 55 Federal Register 

51532. December 14, 1990. Excerpt. Cover page only. A complete copy is available at:

http://www.epa.gov/superfund/sites/npl/hrsres/rule/part1_2.pdf and in the Region 8 Docket.

2. EPA. Superfund Chemical Data Matrix (SCDM). January 2004. Updated December 2011 and – 

Volatile Substances, March 31, 2012. 12 pages. Excerpt. A copy of the volatile substances update is 

available at: http://www.epa.gov/superfund/sites/npl/hrsres/tools/volatile-substances-factorvalues.pdf. 

A complete copy of SCDM is available at: http://epa.gov/superfund/sites/npl/hrsres/tools/scdm.htm

3. Reference reserved. 

4. Reference reserved.

5. Utah Geological Survey (UGS). 2012. Evaluating the Seismic Relation between the West Valley 

Fault Zone and Salt Lake City Segment of the Wasatch Fault Zone, Salt Lake Valley, Utah. By 

Michael D. Hylland et. al. In Utah Geological Survey, Survey Notes, Volume 44, Number 2. May 

2012. Excerpt. 3 pages.

6. Toeroek Associates, Inc. 2012. Updated Draft Business Survey dated April 30, 2012, East Side 

Springs Site. Written by Lindsay Garner, Project Manager, Toeroek Associates, Inc. 60 pages. 

7. EPA. CERCLIS Public Access Database. Search for EPA ID: UTD981548985 (700 South 1600 

East PCE Plume) and EPA ID: UTN000802825 (East Side Springs). 2 pages. Accessed on July 10, 

2012. Accessed on-line at: http://cumulis.epa.gov/supercpad/cursites/srchsites.cfm

8. U.S. Department of Veterans Affairs (VA). 2005. Response to EPA Letter July 12, 2005 request for

Information Pursuant to Section 104 of CERCLA for the Mount Olivet Cemetery Plume Site. 

Written by James R. Floyd, Director. Dated September 9, 2005. Excerpt (original copy contains 

oversized construction drawings). 47 pages.

9. Utah Department of Health (UDH), Division of Environmental Health. 1991. Memorandum to File

regarding Contamination of the Mount Olivet Cemetery. Written by Dennis Fredrick, Environmental

Engineer, UDH. Dated February 28, 1991. 3 pages. 

10. State Coalition for Remediation of Drycleaners. 2010. Conducting Contamination Assessment Work

at Dry Cleaning Sites. Revised October 2010. By Bill Linn, et. al. Excerpt. 16 pages. A complete

copy is available at: http://www.drycleancoalition.org/download/assessment.pdf

11. EPA. 1998. Cleaner Technologies Substitutes Assessment: Professional Fabricare Processes. EPA 

744-B-98-001. June 1998. Excerpt. 7 pages. A complete copy is available at:

http://www.epa.gov/dfe/pubs/garment/ctsa/fabricare.pdf

12. IHI Environmental. 2007. Soil Gas Investigation Report. Sanitary Sewer Lateral, VASLCHCS

Building 7 to Sunnyside Avenue, Salt Lake City, Utah. Prepared for VASLCHCS. Dated December

20, 2007. Excerpt. 20 pages. 
HRS Documentation Record (Interim Final)

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700 South 1600 East PCE Plume

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13. URS Operating Services (UOS) (on behalf of the EPA Superfund Technical Assessment and 

Response Team (START) program). 1996. Field Activities and Analytical Results for Soil Gas 

Sampling at the Mount Olivet Cemetery Plume, Salt Lake City, Utah (TDD #9609-0003), by Barry

Hayhurst. December 6, 1996. 16 pages. 

14. Utah Department of Environmental Quality (UDEQ). 2006. Affidavits collected from Rick Bright,

Salt Lake City Department of Public Utilities (SLCDPU) Waste/Stormwater Collections Manager

(collected on 2 June 2006), and Tom Tabish, SLCDPU Lift Station Supervisor (collected on 13 June

2006), regarding observations of dry cleaning solvent within the sanitary sewer line leading from

Building 7 of the VA Medical Center in the early to mid-1980’s. 6 pages.

15. SLCDPU. 2012. Screen shots from a video survey recorded by SLCDPU of the sewer line leading

from Building 7 of the VA Medical Center. Survey performed December 17, 2003. Reference

includes 2 pages of figures entitled Mt. Olivet Cemetary [sic] Plume Site Well and Manhole 

Locations, dated December 23, 2003; and a 2 page email chain concerning the survey between Jeff 

Miller (EPA START) and Chad Gilgen (UDEQ), dated March 15-19, 2012. 16 total pages. 

16. California Environmental Protection Agency Air Resources Board. 1996. Curriculum for the

Environmental Training Program for Perchloroethylene Dry Cleaning Operations. April 1996.

Excerpt. 5 pages. A complete copy is available at: http://www.arb.ca.gov/training/etpmanul.pdf

17. P.M. Santi, et. al. 2005. Investigating cross-contamination of aquifers. Journal of Hydrogeology.

Volume 14, p. 51-68. Excerpt. 6 pages. A complete copy is available online at:

http://inside.mines.edu/~psanti/paper_pdfs/Cross%20contamination.pdf

18. Ecology and Environment, Inc. (E & E) (on behalf of the EPA Superfund Technical Assessment and 

Response Team (START) program. 1995. Analytical Results Report, Mt. Olivet Well Site, Salt Lake 

City, Utah. TDD# TO8-9505-012. Prepared for USEPA Region VIII, Denver, CO, Steve Hawthorn, 

On-Scene Coordinator. By D’Arcy Straub. Dated June 2, 1995. 13 pages. 

19. EPA START (E & E). 1995. Analytical Results Report, Mt. Olivet Well Site, Salt Lake City, Utah. 

TDD# TO8-9505-012. Prepared for USEPA Region VIII, Denver, CO, Steve Hawthorn, On-Scene 

Coordinator. By D’Arcy Straub. Dated August 2, 1995. Reference includes 3 page memorandum 

dated October 4, 1995 from John Noto (E&E) to Steve Hawthorn (USEPA) with corrected Figure 1 

and Table 1 for the report. 14 total pages. 

20. EPA START (UOS). 1999. Site Activities Report, Mount Olivet Cemetery, Salt Lake City, Salt 

Lake County, Utah. TDD No. 9803-0014. By John Noto. Dated May 20, 1999. Reference includes 

data validation report. 129 pages. 

21. EPA START (UOS). 2000. Supplement to the Site Activities Report. Mt. Olivet Cemetery, Salt 

Lake City, Salt Lake County, Utah. TDD No. 9803-0014. By John Noto. Dated March 14, 2000.

Excerpt. Reference includes data validation report. 53 pages. 

22. UDEQ. 2000. Analytical Results Report, Mount Olivet Cemetery Plume, Salt Lake County, Utah 

(UTD981548985). By Neil B Taylor. Dated August 8, 2000. Excerpt. 92 pages.

23. UDEQ. 2004-2005. Analytical Results Report, Mount Olivet Cemetery Plume, Soil Sampling Event 

– June 2004, Groundwater Sampling Event – October 2004. Dated November 11, 2004. Author 

unknown. Draft (pages 7-10 appear to be from a report regarding the Bountiful Woods Cross PCE 
HRS Documentation Record (Interim Final)

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700 South 1600 East PCE Plume

UTD981548985 9

site). Reference includes analytical results, under separate cover, and 2005 data validation report. 73 

total pages.

24. USGS. 2004-2005. Compilation of documents from USGS including email between Susan Thiros 

(USGS) and Jerald Cross (EPA) dated November 16, 2004; and USGS PowerPoint slide shows 

regarding site-specific geologic stratigraphy and analytical results from sampling event conducted 

February 2005. Various dates. Excerpt. 33 total pages. 

25. UDEQ. 2005. Salt Lake City Water System (SLCWS) Well [#18] Analytical Sampling ResultsMount Olivet Ground Water Plume, Salt Lake City, Utah, by Chad Gilgen. Dated November 18, 

2005. Reference includes 2 pages of field notes from sampling logbook. 7 pages. 

26. EPA START (UOS). 2005. Documentation of ground water sampling conducted by EPA START in 

October 2005. Reference includes 9 pages from sampling event logbook, by Bryan Williams (EPA 

START) and data validation report. 54 total pages.

27. SLCDPU. 2010-2011. Compilation of documents from SLCDPU regarding sampling of East Side 

Springs, including a copy of a media advisory regarding the oil spill in Red Butte Canyon (available 

online at: http://www.slcgov.com/oilspill/), copies of laboratory analytical data from the ChemtechFord Laboratories, Murray, Utah, various dates; and one figure from the SLCDPU entitled Parcels 

where SLCDPU Samples were taken with detected PCE – 2010, by Tammy Wambean, SLCDPU. 

47 total pages.

28. UDEQ. 2012. Site Investigation Analytical Results Report. East Side Springs, Salt Lake County,

Utah. UTN000802825. May 2012. Excerpt. 155 pages.

29. MWH Americas, Inc. (MWH). 2012. Draft Hydrogeological and Groundwater Model Summary

Report for: Culinary Water Supply Protection Project at Salt Lake City’s Drinking Water Well #18

(also referred to as the 500 South Well). Prepared for SLCDPU. Dated February 8, 2012. Excerpt.

74 pages. 

30. EPA. 1998. EPA Office of Research and Development. Technical Protocol for Evaluating Natural

Attenuation of Chlorinated Solvents in Ground Water, EPA/600/R-98/128. September 1998. 

Excerpt. 2 pages. A complete copy is available at:

http://www.epa.gov/nrmrl/pubs/600R98128/protocol.pdf

31. EPA START (UOS). 2012. Memorandum of a telephone conversation between Jeff Miller, EPA

START and Tom Tabish, Lift Station Maintenance Supervisor, Salt Lake City Department of Public

Utilities (801) 952-9036, regarding the absence or presence of a liner beneath the sewer line leading

from Building 7 of the VA Medical Center in Salt Lake City. 1 page. Dated March 26, 2012.

32. Victor J. Izzo. 1992. Dry Cleaners – A Major Source of PCE in Ground Water. Dated March 27,

1992. California Regional Water Quality Control Board, Central Valley Region. 25 pages. Available 

online at: http://www.waterboards.ca.gov/rwqcb5/water_issues/site_cleanup/dry_cleaner_rpt.pdf

33. Thomas K. G. Mohr. Undated. Study of Potential for Groundwater Contamination from Past Dry

Cleaner Operations in Santa Clara County, Final Draft. Excerpt. 6 pages. A complete copy is

available at:

http://www.swrcb.ca.gov/sanfranciscobay/publications_forms/documents/SCVWD_Study/Study.pdf
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34. UDEQ. Various dates. Various records from the UDEQ Division of Environmental Response and

Remediation regarding regulation of petroleum leaks from underground storage tanks (USTs)

located within the area of the 700 South 1600 East PCE Plume. Reference includes two maps

showing location of previously leaking USTs. 36 pages. All records and maps available online at:

http://mapserv.utah.gov/Deq

35. Utah National Guard (UNG). Various dates. Correspondence between the Utah National Guard

(UNG) and the UDEQ and EPA regarding activities conducted at the Utah Army National Guard

(UANG) Organizational Maintenance Shop (OMS) 5 and Combined Support Maintenance Shop

(CSMS), located at 720 Guardsman Way (aka 1543 Sunnyside Avenue), Salt Lake City.

Correspondence includes the UNG response to EPA’s Request for Information Pursuant to Section

104 of CERCLA for the UNG OMS-5 and the CSMS. Written by Robert K. Price, State

Environmental Specialist. Dated July 30, 1996. Excerpt. 13 pages.

36. UDEQ. 2009. Expanded Site Inspection, Analytical Results Report, Sugar House Park Plume, Salt

Lake County, Utah. EPA ID: UT0000987776. Division of Environmental Response and

Remediation. By J. D. Keetley. Dated January 5, 2009. Excerpt. 9 pages.

37. Google. 2012. Map showing dry cleaners located within 1.8 miles of known area of PCEcontaminated ground water at the 700 South 1600 East PCE Plume site. 1 page. Source: http://

maps.google.com/

38. USGS. 2003. Hydrogeology of Shallow Basin-Fill Deposits in Areas of Salt Lake Valley, Salt Lake

County, Utah. USGS Water-Resources Investigations Report 03-4029. By Susan A. Thiros. Excerpt.

10 pages. All annotations within reference (pages 5, 6, 9, 10) obtained from References 20-22, 26-

28, 45. A complete copy is available at: http://pubs.usgs.gov/wri/wri034029/pdf/wri034029.pdf

39. USGS. 2009. Surficial Geologic Map of the Salt Lake City Segment and Parts of Adjacent Segments

of the Wasatch Fault Zone, Davis, Salt Lake, and Utah Counties, Utah (digitized from USGS

Miscellaneous Investigations Series Map I-2106, 1992), by Stephen F. Personius and William E. 

Scott. Excerpt (original source copy is oversized). 5 pages. All annotations within reference (page 2)

obtained from References 20-22, 26-28, 45. A complete copy is available at:

http://geology.utah.gov/online/m/m-243.pdf

40. Utah Division of Water Rights (UDWR). 2012. Various information downloaded from the UDWR

map server. Includes well logs and maps identifying location of wells. 14 pages. All annotations 

within pages 1-9 obtained from database. Location: http://maps.waterrights.utah.gov/ 

41. USGS. 2010. Conceptual Understanding and Groundwater Quality of Selected Basin-Fill Aquifers 

in the Southwestern United States. Section 2.-Conceptual Understanding and Groundwater Quality 

of the Basin-Fill Aquifer in Salt Lake Valley, Utah. By Susan A. Thiros. Professional Paper 1781.

Excerpt. 12 pages. Pages 6 and 10 modified; sources of information include References 26-28 and 

http://mapserv.utah.gov/DEQ. A complete copy of Reference 41 is available at:

http://pubs.usgs.gov/pp/1781/

42. UGS. 2009. Ground-Water Quality Classification for the Principal Basin-Fill Aquifer, Salt Lake 

Valley, Salt Lake County, Utah. Open File Report 560. By Janae Wallace and Mike Lowe. Excerpt.

5 pages. A complete copy is available at: http://geology.utah.gov/online/ofr/ofr-560/ofr-560.pdf
HRS Documentation Record (Interim Final)

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43. EPA. 2011. Superfund Analytical Services, Contract Laboratory Program (CLP). SOM01.2 Volatile

Target Compound List and Corresponding CRQLs. 1 page. Source:

http://www.epa.gov/superfund/programs/clp/som-vtarget.htm

44. EPA. 1996. Using Qualified Data to Document an Observed Release and Observed Contamination.

EPA540-F-94-028. OSWER 9285.7-14FS. November 1996. 18 pages.

45. SLCWS and UDEQ. Various dates. Electronic and postal mail correspondence, and historic

analytical results from compliance sampling of water from SLCWS Well #18. 8 pages. 

46. EPA START (UOS). 2012. Memorandum of telephone conversation held on April 5, 2012 between

Florence Reynolds, Water Quality and Treatment Administrator, Salt Lake City Department of 

Public Utilities (SLCDPU) (801)483-6864, Laura Briefer, Special Projects Manager, SLCDPU

(801) 483- 6741, Jesse Stewart, Project Manager, MWH Americas (801) 617-3200, and Jeff Miller, 

EPA START; regarding municipal water sources in Salt Lake City, the SLCWS policy of not 

utilizing water from contaminated sources, and the timing of SLCWS Well #18 being taken offline 

due to tetrachloroethylene (PCE) contamination. Dated April 5, 2012. 1 page.

47. EPA. 1998. Multi-Media, Multi-Concentration, Organic Analytical Service for Superfund.

Publication 9240.0-08FSB. January 1998. 4 pages.

48. Agency for Toxic Substances and Disease Registry (ATSDR). 1997. Toxicological Profile for

Tetrachloroethylene. September 1997. Excerpt. 6 pages. A complete copy is available at:

http://www.atsdr.cdc.gov/toxprofiles/tp18.pdf

49. EPA. 2010. Utah: Salt Lake City – Salt Lake City Works with Stakeholders to Protect its Water

Supply. EPA Office of Water (4606M). Dated January 2010. 4 pages. Source:

http://water.epa.gov/infrastructure/drinkingwater/sourcewater/protection/casestudies/upload/SourceWater-Case-Study-UT-Salt-Lake-City.pdf

50. SLCDPU. 2009. SLCDPU 2009 Water Conservation Master Plan. Excerpt. 4 pages. A complete

copy is available at:

http://www.slcclassic.com/utilities/PDF%20Files/2009%20Water%20Conservation%20Master%2

0Plan%20-%2011-03-2009.pdf

51. EPA START (UOS). 2012. Ground Water Targets figure. Data compiled from UDEQ Division of

Drinking Water and Utah Division of Water Rights records available at:

http://mapserv.utah.gov/Deq/ and http://www.waterrights.utah.gov/wrinfo/query.asp

52. UDWR. 2012. Records of water system facilities (wells, springs, and surface water intakes) for the

Salt Lake City Water System and the South Salt Lake City Water System. Compiled from UDEQ

Division of Drinking Water records available at: http://mapserv.utah.gov/Deq/. All annotations 

within reference obtained within source database or at 

http://www.waterrights.utah.gov/wrinfo/query.asp. 85 pages.

53. South Salt Lake City. 2011. City of South Salt Lake, State of Utah, Comprehensive Annual 

Financial Report for Fiscal Year Ended June 30, 2011. A complete copy is available at:

http://www.southsaltlakecity.com/uploads/documents/City_of_South_Salt_Lake_2011_CAFR[1].pd

f; City of South Salt Lake Public Works, 2011 Annual Report. Excerpt. 2 pages. A complete copy is

available at: http://www.southsaltlakecity.com/uploads/documents/Insert-Water_Quality_Report.pdf

Total of 4 pages.
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54. U.S. Bureau of the Census. 2012. Salt Lake City and County QuickFacts. Persons per household,

2006-2010 and percent population change. 2 pages. Sources: 

http://quickfacts.census.gov/qfd/states/49/49035.html and

http://quickfacts.census.gov/qfd/states/49/4967000.html

55. SLCDPU. Undated. Salt Lake City Watershed Management Programs: 1847 – 1997. By LeRoy W.

Hooton, Jr. Excerpt. 2 pages. A complete copy is available at:

http://www.slcclassic.com/utilities/PDF%20Files/watersh.pdf

56. UDEQ. 2012. Rule R309-600 Drinking Water Source Protection for Ground Water Sources.

Excerpt. 4 pages. A complete copy is available at:

http://www.drinkingwater.utah.gov/documents/rules_ddw_version/R309-600_10-29-03.pdf

57. UDEQ. 2012. Maps showing Ground Water Protection Zones for wells within a 1 mile radius of the 

source (8th South Well and Well #18). 2 maps. Information added to maps obtained from References 

20-22, 26-28, 45 and source database. Location: http://mapserv.utah.gov/DEQ

58. EPA. 1999. USEPA Contract Laboratory Program, National Functional Guidelines for Organic Data

Review. OSWER 9240.1-05A-P. PB99-963506. EPA540/R-99/008. October 1999. Excerpt. 1 page.

A complete copy is available at: http://www.epa.gov/superfund/programs/clp/download/fgorg.pdf

59. EPA. 2008. USEPA Contract Laboratory Program, National Functional Guidelines for Superfund

Organic Methods Data Review. OSWER 9240.1-48. USEPA-540-R-08-01. June 2008. Excerpt. 1

page. A complete copy is available at:

http://www.epa.gov/superfund/programs/clp/download/somnfg.pdf

60. EPA. 2000. Exfiltration in Sewer Systems. EPA/600/R-01/034. December 2000. Excerpt. 7 pages. A 

complete copy is available at: http://nepis.epa.gov/Adobe/PDF/2000E6PB.pdf

61. UDEQ. 2002. Site Inspection Analytical Results Report, University of Utah Building 515, Salt Lake

County, Utah. UT0001908821. Dated July 24, 2002. Excerpt. 39 pages.

62. Jordan Valley Water Conservancy District (JVWCD). 2012. Source Protection. Webpage describing

where JVWCD water sources and delivery. Source: http://www.southsaltlakecity.com/departmentlistings/public-works/water Accessed August 2, 2012.

63. EPA START (UOS). 2012. Telephone conversation with Ed Rufner, Deputy Director, South Salt Lake 

City Department of Public Works (801) 412-3210, regarding the source, blending and distribution of 

water within the South Salt Lake City Water System. August 14, 2012. 1 page.
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SITE DESCRIPTION

The 700 South 1600 East PCE Plume site (‘the site’) includes one source and an area of ground water that has 

been contaminated by tetrachloroethylene (PCE). The scored source is an historic disposal of PCEcontaminated condensate water (aka separator water) from a former dry cleaning facility located within 

Building 7 of the George E. Wahlen Department of Veterans Affairs Medical Center Campus (the ‘VA 

Medical Center’) (Figures 1, 2 of this HRS documentation record). PCE-contaminated condensate from the 

dry cleaning operation was disposed into a drain line attached to a sanitary sewer line (Figures 1, 2; Refs. 8, pp. 

2, 3; 10, pp. 11-13; 11, pp. 2-7). 

The EPA identification number for the site, as recorded in the Comprehensive Environmental Response, 

Compensation and Liability Information System (CERCLIS) database, is UTD981548985 (Ref. 6). The 

related East Side Springs site is a ‘child’ site under CERCLIS and has been given the EPA identification 

number UTN000802825 (Ref. 7). Site-related contamination is also described in East Side Springs documents.

The Maximum Contaminant Level (MCL) for PCE in drinking water set by the United States Environmental 

Protection Agency (EPA) is 5 micrograms per liter (μg/L) (equivalent to 5 parts per billion (ppb)) (Ref. 2, p. 

2). Water from a number of wells and springs in the area has PCE levels above the MCL and a Salt Lake City 

municipal well has been shut down permanently due to the contamination (Figure 1, Refs. 20, p. 13, 25, 27, 

67, 69, 79; 21, pp. 6, 11, 15; 22, pp. 18, 45, 47; 23, pp. 6, 38, 40, 42, 48; 24, pp. 5-33; 25, pp. 2-5; 26, p. 17, 

19; 27, pp. 2-4, 7, 10, 13, 21, 24, 29, 32, 35, 38, 41, 44; 28, pp. 6, 8, 9, 14, 16, 18, 19, 27, 28, 29, 33, 35-37, 

58, 73, 83, 85, 103, 143; 29, pp. 18-22). Ground water collected from a location immediately upgradient of 

Building 7 is not contaminated with PCE (Refs. 20, pp. 25, 27, 79; 23, pp. 6, 50; 24, pp. 6, 24; 26, pp. 2, 17; 

28, pp. 15, 27, 29, 33, 35, 36, 81). 

The contaminated ground water extends from an area immediately hydraulically downgradient from the VA 

Medical Center Building 7 to a number of springs (the ‘East Side Springs’) located approximately 1 mile down

gradient (Figure 1, Refs. 20, p. 13, 25, 27, 67, 69, 79; 21, pp. 6, 11, 15; 22, pp. 18, 45, 47; 23, pp. 6, 38, 40, 

42, 48; 24, pp. 5-33; 25, pp. 2-5; 26, p. 17, 19; 27, pp. 2-4, 7, 10, 13, 18, 21, 24, 29, 32, 35, 38, 41, 44; 28, pp. 

6, 8, 9, 14, 16, 18, 19, 27, 28, 29, 33, 35-37, 58, 73, 79, 83, 85, 103, 105, 142; 29, pp. 18-22). While the full 

extent of the contamination has not yet been determined, the center of the known extent is approximately 

latitude 40.753938° North and longitude 111.848022° West (Figure 1). The elevation is approximately 4,640 

feet above mean sea level (amsl) at this location (Figure 1). 

While ground water collected from various wells immediately downgradient of Building 7 is contaminated 

with PCE, ground water collected from a well (EPA-MW-05) located immediately upgradient of Building 7 is 

not (Refs. 20, pp. 25, 27, 79; 23, pp. 6, 50; 24, pp. 6, 24; 26, pp. 2, 17; 28, pp. 15, 27, 29, 33, 35, 36, 81). 

The surrounding land use includes the University of Utah (U of U) Campus to the north and east, U of U 

housing to the southeast, the Mount Olivet Cemetery, the Salt Lake City Sports Complex/Sunnyside Park to the 

west and southwest and residential areas farther to the south and west (Figure 3). The contaminated ground 

water underlies numerous residences downgradient of the source, as well as the East High School (Figure 1 of 

this HRS documentation record, Ref. 28, pp. 14, 19).

Construction of the VA Medical Center (then called the Fort Douglas Hospital) was completed in 1952 (Ref. 8, 

p. 14). Since its construction, the use of Building 7 (denoted as ‘B.07’ in many VA Medical Center records) 

has been multipurpose and, in addition to laundry facilities (Ref. 8, pp. 20, 21, 25, 28, 29, 30, 32, 34), has 

previously been used for warehousing (Ref. 8, pp. 21, 29), animal surgery and research (Ref. 8, pp. 21, 29), 

and a garage (Ref. 8, pp. 27, 28). A single dry cleaning machine was used at the VA Medical Center from 

approximately 1976 through 1984 and was located at the same area of Building 7 where the current ‘wet’ 
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laundry is located (Ref.8, pp. 2, 3). Architectural drawings supplied by the VA show that a single dry cleaning 

machine was installed inside what was then the northern exterior wall of Building 7, approximately in the 

middle of the building when measured from the southeast to the northwest (Ref. 8, p. 44, 47). Additions have 

since been added to this side of Building 7 (Figure 2). A 1⁄2-inch diameter condensate drain line from the 

machine was tied into a new 2 inch drain line leading from the machine (Ref. 8, p 45- 47). The new 2 inch 

drain line was tied into an existing 10-inch drain line located within an adjacent utility tunnel (Ref. 8, pp. 42-

47). This 10-inch drain line is the sanitary sewer line that leads from Building 7 (Ref. 8, center of page 36, just 

right of center on page 40), travelstowards the southeast, and then runs generally southwest towards Sunnyside 

Avenue (Figures 1, 2, 3 of this HRS documentation record; Ref. 8, pp. 34- 40). The dry cleaning machine was 

removed at some point during or prior to 1984 (Ref. 8, p. 2).

The PCE-contaminated ground water was discovered in 1990 during routine sampling of the Mount Olivet 

Cemetery irrigation well (Ref. 9), which is located about 2,200 feet down hydraulic gradient from Building 7 

(Figure 3). Since that time, the site has been through several name changes, including ‘Utah Army National 

Guard Site’, ‘Mount Olivet Cemetery Plume’, ‘Mount Olivet Ground Water Plume’, and ‘700 South 1600 East 

PCE Plume’, as efforts to define the extent of the contamination, and to pinpoint the source have progressed. 

The full extent of contaminated ground water is unknown, but with the recent (2010/2011) discovery of the 

downgradient PCE-contaminated springs (the ‘East Side Springs’), contamination is now known to cover over 

200 acres (Figures 1, 3 of this HRS documentation record). The vertical extent of contamination is unknown, 

but based on discrete interval sampling conducted in 2011 within the Salt Lake City Water System (SLCWS) 

Well #18 (also known as the 500 South Well (Figure 3)), reaches to at least 274 feet below the ground surface 

(bgs) at that location (Ref. 29, p. 22). This well was taken offline permanently due to this PCE contamination 

in October 2004 (Refs. 46; 52, p. 26).

One source has been identified at the site for HRS scoring purposes. The source is the historic disposal of PCE

from the dry cleaner into a drain line attached to the sanitary sewer line that leads from Building 7 (Ref. 8, p. 

2). It has been documented that PCE was the solvent used at the VA dry cleaning facility (Ref. 8, pp. 2, 3). 

While an exact hazardous waste quantity of PCE disposed into the drain line cannot be determined, it is known 

that condensate water (aka separator water) contains PCE, typically being saturated with respect to the solvent

(Ref. 10, pp. 11, 12; Ref. 11, pp. 2-7). At room temperature, approximately 150 milligrams per liter (mg/L) of 

PCE would have been dissolved in the separator water (Ref. 10, p. 12; Ref. 11, p.4, 5). One study showed that 

the average concentration of PCE in condensate waters from nine dry cleaners in California was 151,800 ppb 

(Ref. 32, p. 12). This level is 30,000 times the MCL (Ref. 2, p. 2). The discharge from most dry cleaning 

units contains primarily water with dissolved PCE, but also contains some pure cleaning solvent and solids 

containing PCE (Ref. 32, p. 4). 

One study has shown that the most frequent type of PCE release from dry cleaners is a release from sewer lines 

(Ref. 33, p. 4). Being heavier than water, PCE settles to the bottom of a sewer line and exfiltrates through it, 

leaking through breaks or cracks, as well as pipe joints and other connections (Ref. 32, pp. 4, 6, 21). 

Exfiltration rates from clay sewer pipes in various areas of the U.S. have been estimated to be between 

approximately 5,000 and 77,000 gallons per inch diameter of pipe, per mile length, per day (Ref. 60, pp. 4-6). 

In addition to leaking through joints and cracks, PCE has been reported to penetrate through sewer lines by 

other methods, including by leaching directly through the line, by volatilizing from the outer edge of the pipe 

into the surrounding soils, and by penetrating the pipe in gas form (Ref. 32, pp. 21-23). Due to having a 

greater vapor density than air, once in soil, PCE vapors sink down through the vadose zone to the ground water 

(Ref. 32, pp. 4, 6, 22).

Employees of the Salt Lake City Department of Public Utilities (SLCDPU) documented observations of 

discolored water and odors of dry cleaner solvent at various dates in the early 1980’s while cleaning the 
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sanitary sewer line (Ref. 14). A video survey of sections of the sewer lines between Building 7 and Sunnyside 

Avenue was conducted on December 17, 2003 by the SLCDPU (Ref. 15). This survey documented numerous 

defects in most of the sections, including cracks, root penetrations, offsets, and a pipe sag, as well as evidence 

of historic breaks, repairs and replacements of the clay pipe (Ref. 15). At least one of these pipe repairs 

documents that the clay pipe had been broken sometime prior to the sewer survey (Ref. 15, p. 11). 

Soil gas above the sanitary sewer line was sampled for PCE in 1996 and again in 2006 (Refs. 12, 13). Despite 

the tests being conducted at least 12 and 22 years, respectively, after the dry cleaner was removed from service, 

and that PCE vapors tend to sink rather than rise through soil (Ref. 32, p. 6), PCE was detected in soil gas at 

some locations above the sanitary sewer line. The highest concentrations detected at locations closest to 

Building 7 (Refs. 12, pp. 6, 7, 13-16; 13, pp. 4, 6, 7, 9, 14). 

Ground water downgradient of Building 7 and the sanitary sewer line contains PCE at concentrations greater 

than background levels, indicating that a release of hazardous substances has occurred to the ground water as 

documented in Section 3.0 of this HRS documentation record. In 2004, thirteen municipal drinking water 

wells located within a 4-mile radius of the source provided water to the local population (Ref. 51; 52, pp. 4, 5, 

8). One of these wells, SLCWS Well #18, was shut down in 2004 due to PCE contamination and is evaluated 

as an actual contamination target (Ref. 46). Four of the remaining wells are evaluated as potential 

contamination targets (see Section 3.3 of this HRS documentation record).

OPERATIONAL AND REGULATORY HISTORY

The dry cleaner was operational from approximately 1976 through 1984 (Ref. 8, pp. 2, 3, 20, 21, 24, 26). Only

one dry cleaning machine was installed and operated, and the estimated quantity of dry cleaning processed 

monthly was 700 items (Ref. 8, p. 2). Items that were dry cleaned were drapes and uniforms (Ref. 8, p. 2). 

PCE was used in the dry cleaning process (Ref. 8, p. 2). 

The dry cleaning system was a ‘closed loop’ system (Ref. 8, p. 2, 3; Ref. 10, p. 7), meaning the system 

contained a distillation process for the recovery of PCE at the end of each cycle (Ref. 8, p. 2, 3). The VA 

reported that there was no documentation to support that they ever had below or above ground tanks used for 

storing spent solvents, chlorinated solvents, waste fluids or materials containing spent chlorinated solvent (Ref. 

8, p. 3). The condensate from the distillation process was emptied directly into a drain line attached to the 

sanitary sewer (Ref. 8, p. 2, 3). The disposal of dry cleaner separator water to a sanitary sewer or septic tank 

was common practice in the 1980’s (Refs. 10, p. 15; 32, pp. 11, 12). 

According to the VA, the distillation process was efficient enough that very little PCE was added to the system 

on a weekly basis for recharge (Ref. 8, p.2, 3). PCE was purchased and stored in 55-gallon containers. The 

rate at which the 55-gallon containers were used is unknown (Ref. 8, p. 2, 3), but PCE consumption per weight 

of material cleaned has been reported to vary from 420 pounds of material per gallon to less than 100 pounds 

of material per gallon, depending upon the overall performance of the dry cleaning equipment and the 

effectiveness of operating procedures (Ref. 16, p. 5). Prior to 1992, a typical dry cleaner business used

between 15 and 40 gallons a month of pure PCE (Ref. 32, p. 5).

No historical records of inspections or historical reports of violations by the operators of the dry cleaning 

operation by any regulatory agency have been located. 

PREVIOUS INVESTIGATIONS

The PCE contamination was first discovered at the 700 South 1600 East site in 1990 when analytical results 

from an irrigation well (the Mount Olivet Cemetery irrigation well) located down-hydraulic gradient of the VA 
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Medical Center indicated a concentration of PCE of 32 μg/L (Figure 3 of this HRS documentation record; Ref.

9). Since that time, numerous investigations have been conducted in the area in an effort to characterize the 

extent, nature and origin of the contamination. 

Under the Safe Drinking Water Act, enacted in 1974 and amended in 1996, the SLCWS is responsible for the 

sampling and analysis (monitoring) of its water supplies in order to ensure that drinking water quality meets 

minimum standards (MCLs) established under the law. Analytical results from this compliance sampling show 

that the SLCWS Well #18 (Figure 3 of this HRS documentation record) was free of PCE contamination until 

1997, when the first detection was recorded (Ref. 45, pp. 1-5). PCE was detected in the well periodically after 

this time, with concentrations dependent upon the duration of pumping of the well (i.e. PCE was generally not 

detected when the well had not been in use for a period of time. Pumping draws the contamination into the 

well, resulting in increasing concentrations of PCE with continued use. When pumping ceases, the 

contamination recovers its ambient flow direction away from the well, resulting in lower PCE concentrations, 

or non-detections.) (Refs. 25, pp. 1-7; 29, pp. 20-22, 28, 33).

1989 through 2004 – SLCWS, ground water from SLCWS Well #18 (Ref. 45)

During May and June of 1995, Ecology and Environment, Inc. (E&E) on behalf of the EPA’s Superfund 

Technical Assessment and Response Team (START) program, collected soil and soil-gas samples from various 

locations in the vicinity of the Mt. Olivet well in an effort to locate the source and extent of the PCE detected 

in the well (Refs. 18, 19). During the first field sampling effort in May, PCE was detected in one of 15 soil gas 

samples at a concentration of 16 ppb (sample ID: OG-SG-06) (Ref. 18, pp. 5-9). EPA START returned the

following month with a hydraulic-push machine to collect ground water samples in the vicinity of the 

maintenance shop and the VA Medical Center. A hard calcareous caliche layer caused refusal at no more than 

12 feet bgs; consequently, only soil gas samples were collected (Ref. 19, p. 5). For example; soil gas samples 

collected on the VA Medical Center property could only be taken from 3 feet bgs (Ref. 19, p. 14). No 

detections of PCE were recorded in any of 4 soil and 5 soil gas samples above the laboratory reporting limit of 

10 ppb (Ref. 19, pp. 4-6, 9-14). The reports completed in regards to this work identified the most likely 

source of contamination for the Mt. Olivet well as appearing to be the Utah National Guard maintenance shops 

located east-southeast of the well (Refs. 18, p. 4; 19, p. 4), but stated that a potential source for the PCE 

contamination of the well was not located (Ref. 19, p. 6).

1995 – EPA START, soil gas (Refs. 18, 19)

Additional soil gas samples were collected by EPA START in October and November, 1996 (Ref. 13). Soil 

gas samples were collected from three different areas on October 18, 1996: three samples were collected from 

east and southeast of Building 7 where the sewer line exited the building, two samples were collected on the 

Fort Douglas Military Reservation (approximately 3,600 feet northeast of Building 7), near Red Butte Creek, 

and one sample was collected near Building 515 of the Fort Douglas Military Reservation (approximately one 

mile northeast of Building 7) (Ref. 13 pp. 2, 3, 6). The same locations were targeted again on November 9, 

1996, although two of the locations near Building 7 could not be resampled due to construction activities (Ref. 

13, p. 3). The results from the other four resampled locations are included in the report and show detections of 

PCE within the one sample collected adjacent to the sewer line near Building 7 (1.9 μg/L), as well as

detections of PCE (49 μg/L) from the sample collected near Building 515 (Ref. 13, pp. 2-4, 6, 7, 9, 11, 14). 

1996 – EPA START, soil gas (Ref. 13)

From June through August 1998, EPA START installed six (one dual-nested and four individual) ground 

water monitoring wells at five locations east and southeast of the cemetery to provide information regarding 

ground water flow direction, gradient, the extent of PCE contamination, and attribution, if possible (Ref. 20, 

pp. 10, 23). 

1998 – EPA START, ground water (Ref. 20)
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The wells were screened in the first aquifer encountered and depth to ground water in November 1998 varied 

from approximately 130 to 205 feet bgs (4483.55 feet to 4527.38 feet amsl) (Ref. 20, pp. 29, 40-51; Tables 5 

and 9 of this documentation record). The ground water flow direction was reported to be towards the 

northwest (Ref. 20, pp. 17, 23), although a recent study utilizing a larger number of wells and ground water 

flow modeling has shown that ground water actually flows to the west-southwest (Ref. 29, pp. 11, 31). 

A formal sampling event was conducted in November 1998 (Ref. 20, pp. 13- 16). Concentrations of PCE in 

the wells ranged from non-detect (at the Contract Required Quantitation Limit (CRQL) of 10 μg/L) in the 

background well EPA-MW-05, to 320 D μg/L in the well EPA-MW-01S (Ref. 20, p. 13, 25, 27, 67, 69, 79). 

PCE contamination was present up-hydraulic gradient of the Utah National Guard maintenance shops, 

previously considered to be the likely source. The report identified the former VA Medical Center dry cleaning

operation as a potential source, and stated that Building 7 could be a source if PCE travelled south or southeast 

from Building 7 along a sewer line or other conduit prior to infiltration to the aquifer (Ref. 20, p. 18, 19). 

One of the wells installed by EPA START in 1998 (EPA-MW-03) was abandoned in September 1999 due to 

the construction of what is now the Salt Lake City Sports Complex (Ref. 21, p. 6). A final sampling of this 

well on September 20, 1999 prior to abandonment confirmed the presence of PCE at a concentration of 7.1 

μg/L (Ref. 21, pp. 6, 11, 15). The laboratory data package for this sample is unavailable. 

1999/2000 – EPA START, ground water (Ref. 21)

Also during this time, an additional well (EPA-MW-06) was installed in the southeast corner of Sunnyside 

Park, in a location thought to be upgradient of both the PCE contaminated wells installed in 1998, as well as 

the sewer line that originates from the former VA dry cleaning facility (Ref. 21, pp. 6, 13). The well was 

screened in the first aquifer encountered and depth to ground water in October 1999 was estimated to be

118.21 feet bgs (4561.79 feet amsl) (Ref. 21, p. 16). The screened interval for EPA-MW-06 is approximately 

(4,580 to 4,550) (Ref. 21, pp. 16, 21, 22).

EPA-MW-06 was sampled on January 6, 2000 returning a non-detect result for PCE at the CRQL of 10 μg/L

(Ref. 21, pp. 7, 9, 10, 15, 18-22, 30, 34, 43). 

It was stated in the report that while the specific location of the PCE release was still not defined, the only 

identified potential source of PCE that was both downgradient of the background wells and upgradient of the 

contamination was the former VA dry cleaning facility (Ref. 21, p. 10).

In August 2000, the UDEQ produced a summary report on the work done at the site to date (Ref. 22). In 

addition to the EPA START soil gas and ground water studies from 1996 through 2000 (included as 

appendices in the report) (Refs. 13, 20, 21), the report also presented analytical data from the sampling of 

springs (screening level data only) conducted by the UDEQ in August and September of 1999, and sampling of 

two water supply wells (SLCWS Well # 18 - called the 1511 East 500 South Salt Lake City well in the report - 

and the Mount Olivet Cemetery well) was conducted in September 1998 (Ref. 22, pp. 11, 12, 17, 18). The 

spring samples were collected in an attempt to track the contamination’s western and southwestern extent, 

under the assumption that ground water flow was to the west to southwest (Ref. 22, p. 11). The Mt. Olivet 

well sample was collected in order to verify the presence or absence of contamination, and the SLCWS Well 

#18 (500 South well) was sampled to help determine the northern extent of the contamination (Ref. 22, p. 12, 

18). 

1999/2000 – UDEQ, ground water (Ref. 22)

Analytical results from the springs showed non-detects for PCE at the CRQL of 10 μg/L (Ref. 22, pp. 28, 30). 

This data was collected for screening purposes only and no primary reference for the data set is available.
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Analytical results from the supply well samples show a PCE concentration of 150 μg/L in the Mt. Olivet well 

(sample IDs: MT-01, HS794) and a non-detect value for SLCWS Well #18 (500 South Well, sample IDs: MT02, HS795) at the CRQL of 10 μg/L (Ref. 22, pp. 18, 45, 47). 

The report identified that the Utah Army National Guard Maintenance Shop 5 was no longer thought to be the 

source (Ref. 22, p. 7, 9) and stated that “...the source for contamination of the aquifer is southeast of 

monitoring wells EPA-MW-01S and EPA-MW-02, west of EPA-MW-05, and northwest of EPA-MW-06. The 

only identified potential source of PCE in this area is the sewer line that originates from the former dry 

cleaning facility at the VA Medical Center.” (Ref. 22, p. 23).

A video survey of sections of the sewer lines between Building 7 and Sunnyside Avenue was conducted on 

December 17, 2003 by the SLCDPU at the request of the UDEQ and the EPA (Ref. 15, p. 15). The survey 

was performed to see if there were any major breaks or cracks in the sewer line that could have provided for a 

historical preferential pathway for contaminants to get into the soil or ground water (Ref. 15, p. 15). This 

survey documented numerous defects in most of the sections, including cracks, root penetrations, offsets, and a

pipe sag, as well as evidence of historic breaks, repairs and replacements of the clay pipe (Ref. 15). 

2003 – UDEQ, EPA, SLCDPU, sewer survey (Ref. 15) 

The UDEQ conducted soil sampling along the sewer line leading from Building 7 in June 2004, and conducted 

a ground water sampling event in October 2004 (Ref. 23). The objective of the soil sampling was to determine 

whether a PCE source existed along the sewer line by collecting soil samples at roughly 50 foot intervals along 

the length of the sewer line, starting at Building 7 and continuing south southwest to Sunnyside Avenue (Ref. 

23, p. 3-6). 

2004 – UDEQ, soil and ground water (Ref. 23)

A total of thirty-two soil samples were collected with a hydraulic-push machine, with sample depths ranging 

from 2 feet to 13 feet bgs. Samples were collected both upgradient and downgradient of the sewer line (Ref. 

23, p. 4). All sample results indicated that no volatile organic substances (VOCs) were detected above the 

reporting limits of 10 to 12 μg/kg (Ref. 23, p. 4-6, 11-30). The possible reasons for the lack of detections 

were not given in the report, although it may be due to a number of factors, including: the length of time that 

had passed since disposal from the dry cleaner had occurred (at least 20 years); inability to sample deep 

enough due to the hard caliche layer reported from earlier investigations; because PCE in its liquid state is 

heavier and less viscous than water and would be expected to sink directly below the pipe (not be found 

above); and that PCE vapors are denser than air, and would also would have been expected to sink below the 

pipe (Ref. 32, pp. 5, 6). Specific sample depths were not cited in the report. 

A total of four ground water monitoring wells (three downgradient and one upgradient of the dry cleaner) were 

sampled on October 15, 2004 as part of this investigation (Ref. 23, pp. 4, 31-73). PCE was detected in all 

three of the downgradient wells with PCE concentrations ranging from 2.23 μg/L in SLCWS Well #18 to 128 

μg/L in the Mt Olivet Well (Ref. 23, pp. 6, 38, 40, 42, 48). The background well EPA-MW-05 was non-detect 

at a reporting limit of 1 μg/L (Ref. 23, p. 50). 

The USGS was engaged by the EPA to perform a ground water study in 2004 and early 2005 (Ref. 24). USGS 

activities included the collection of water level measurements from monitoring and supply wells, and the 

collection of ground water samples from nine wells, including the two U of U wells and the SLCWS Well #18 

(named SLC 1016a in the documents) (Ref. 24, pp. 1-6). The overall objective of the study is not clear from 

available documents. 

2004/2005 - USGS, ground water (Ref. 24)
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Analytical results from the sampling performed in February 2005 show detections of PCE in all wells sampled 

with the exception of the background well EPA-MW-05 and the two U of U wells, which were all non-detect 

for PCE at a reporting limit of 0.1 μg/L (Ref. 24, pp. 5-33). PCE detections ranged from 0.2 μg/L in EPAMW-01D to 296 μg/L in EPA-MW-02 (Ref. 24, pp. 5, 13, 30). 

In September 2005, UDEQ collected a time series of water samples from SLCWS Well #18 in order to 

determine the current level of contamination in the well and whether continuous pumping affected PCE 

concentrations (Ref. 25). PCE concentrations from the well water increased from 1.2 μg/L on September 12 to 

1.8 μg/L on September 29 (Ref. 25, pp. 2-5).

2005 - UDEQ, ground water (Ref. 25)

In October 2005, EPA START collected water samples from four of the ground water monitoring wells 

established in the vicinity of the VA Medical Center in order to determine current contaminant concentrations 

(Ref. 26). PCE concentrations from the wells ranged from non-detect in background well EPA-MW-05 

(Sample ID MW-05) (at a CRDL of 0.5 μg/L) (Ref. 26, pp. 2, 16, 17) to 160 μg/L in downgradient well EPAMW-02 (Sample ID MW-02) (Ref. 26, pp. 3, 18, 19).

2005 – EPA START, ground water (Ref. 26)

In February 2007, IHI Environmental, under contract to the VA Medical Center, installed 48 passive soil gas 

samplers along the sanitary sewer line between Sunnyside Avenue and Building 7 (Ref. 12, p. 4). Two 

additional samplers were installed at background locations (Ref. 12, p. 4). All samplers were deployed from 0-

12” bgs and were retrieved after approximately 10 days exposure to the soil (Ref. 12, pp. 5, 20). 

2007 – IHI Environmental, soil gas (Ref. 12)

Analytical results showed detections of PCE above the method detection limit (of 25 nanograms [ng]) in 6 

samples collected from 4 locations, with a maximum concentration of 90 ng (Ref. 12, p. 7, 11, 12, 13-16). 

Three of these locations were adjacent to Building 7, while the fourth location was along the sewer line 

approximately 1,000 feet southeast of Building 7 (Ref. 12, pp. 11, 12, 13-16). After receiving preliminary 

results, duplicate analysis was performed on two impacted samples (Ref. 12, p. 8). Analytical results from both 

background samples were non-detect at the method detection limit of 25 ng (Refs. 12, pp. 11, 12, 13-16).

It is asserted in the report that “While PCE was present in the soil gas, it was present at concentrations far 

below those expected in a release” (Ref. 12, p. 10). However, although it is stated in the report that 'Weather 

conditions during the soil gas investigation would not have influenced the outcome of the investigation’ (Ref. 

12, p. 5) this assertion is not explained further. As the sampling was conducted in the middle of winter

(February), any PCE in the shallow ground would be expected to be less likely to be volatized than if the 

investigation had been conducted in the higher temperatures of summer. In addition, it is reported that sample 

installation procedures were standardized to those followed for installation of samplers in asphalted locations 

(i.e. samplers were placed within a 1-foot section of copper tube), even for locations where no asphalt was 

present (Ref. 12, p. 5). This procedure may impart a low bias in the analytical results as the samplers would be 

not be exposed to soil gas from the full length of the soil column, but only to that gas able to penetrate the end 

of the tube. Finally, it is indicated that sampling locations were biased in order to detect “worst case” 

conditions directly above the sewer line, even though PCE vapor is heavier than air and highest concentrations 

would be expected beneath or to the sides of the pipe (Ref. 32, p. 6). It may be that concentrations of PCE in 

the soil gas were low simply due to the length of time that had passed since PCE disposal to the sewer line had 

occurred (i.e. at least 23 years).

On June 12, 2010, a release of crude oil from a Chevron pipeline was discovered at the base of Red Butte 

Canyon east of the site (Ref. 27, p. 1). As part of the overall response effort, the SLCDPU began identifying 

2010 – SLCDPU, springs (Ref. 27)
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potential downgradient receptors for the crude oil contamination. SLCDPU identified 25 springs along the 

Wasatch Fault line in the area between 800 South and Michigan Avenue and between 1100 East and 1300 East 

as potential receptors for the contamination (Figure 3; Ref. 28, pp. 8, 9). Due to access issues and other 

factors, samples were collected from only eleven of the springs, as well as one storm drain manhole, and two 

artesian wells available for use by the public. Sampling events were conducted from June through August 

2010 (Refs. 27, pp. 14, 25, 45, 46; 28, pp. 8, 9).

Analytical results from the sampling showed that PCE was present in 6 of the 11 springs sampled, as well as 

from the storm drain (Ref. 27, pp. 3, 4, 7, 10, 13, 18, 21, 24, 29, 32, 35, 38, 41, 44). Concentrations of PCE in 

the springs ranged between 2.5 μg/L and 40.4 μg/L. Given the springs’ locations downgradient of the known 

PCE contamination within the Mt. Olivet well, the existing PCE contamination (i.e. the site) was considered 

the likely source of the PCE (Ref. 28, pp. 6, 19). The area of contaminated springs was listed in the CERCLIS 

database as the “East Side Springs” site in January of 2011 (Ref. 28, p. 9) 

Following the discovery of the contaminated springs in 2010, the UDEQ conducted a follow-on investigation 

in November and December 2011. The investigation involved the collection of surface water, surface soils, 

and ground water from the wider area (including the site), including water and soils from three springs, water 

from three existing ground water monitoring wells and five newly-placed direct-push borings, and water from 

the fountain at Liberty Park and the 8th South artesian well (aka 8th South Well) (Refs. 28, pp. 9, 13; 52, pp. 68, 

69).

2011 – UDEQ, springs, surface soils, ground water (Ref. 28)

Analytical results from the samples confirm the presence of PCE contamination in ground water adjacent to the 

springs, as well as from the existing monitoring wells (Ref. 28, pp. 6, 14, 16, 17, 19, 27-29, 33, 35-37, 73, 79, 

83, 85, 95, 103, 105). Concentrations of PCE in the springs ranged from a non-detect in one spring (at the 

CRQL of 5 μg/L), to 20 μg/L (Ref. 28, pp. 16, 28, 33, 37, 101, 103, 105). Concentrations of PCE in the 

existing wells and the direct-push borings ranged from a non-detect (at CRQL of 5μg/L) in the background 

well EPA-MW-05 to 150 μg/L in well EPA-MW-01S (Ref. 28, pp. 14, 15, 27, 33, 35, 36, 73, 79, 81, 83, 85, 

95). Contamination was not documented in either the soils collected from near the springs, or the two artesian 

wells located farther downgradient from the springs (Ref. 28, pp. 13, 15, 27, 34, 35, 75, 77, 120, 121). 

From the Fall of 2010 until early 2012, MWH, under contract to the SLCDPU, conducted a variety of activities 

in an effort to assess the short- and long-term impacts of PCE contamination to SLCWS Well #18, to make 

recommendations for the future use of the well, and, if deemed appropriate, to design a well-head treatment 

system (Ref. 29, p. 9). These activities included geophysical and hydrophysical evaluation of the well, discrete 

interval ground water sampling, aquifer testing, and the construction of a ground water model to simulate 

contaminant transport (Ref. 29, pp. 4, 5, 17-22, 27-33).

2010/2011/2012 – MWH, assessment of SLCWS Well #18, ground water sampling and modeling (Ref. 29) 

The study confirmed that the well is screened from approximately 260-470 feet bgs (4,410 to 4,190 feet amsl) 

(Refs. 29, pp. 24, 51; 40, pp. 1, 9). The three most hydraulically-conductive intervals found in the well were 

found in its upper portion, from 271 to 368 feet bgs (Ref. 29, 19). During initial interval-specific sampling 

efforts, trace-level concentrations (i.e. less than 0.03 ppb) of PCE were detected from the following depth 

intervals: 277-280, 302-305, 346-349, 369-372 feet bgs (Ref. 29, p. 18). Later sampling performed during a 

high capacity pump testing showed that PCE contamination increased with pumping duration, showed that 

contamination is in the upper flow zone (271-274) and was detectable after less than 10 days of pumping, and 

recorded a maximum PCE concentration of 0.81 ppb 18 days into the test (Ref. 29, pp. 20-22). 

Information gathered from the aquifer testing, coupled with historic contamination concentration data from 

established monitoring wells was incorporated into a ground water model for the site (Ref. 29, pp. 24-27). 

While the identification of a definitive source of contamination was beyond the scope of the investigation, for 
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the purposes of the model, a source was assumed to be upgradient of the known contamination and was 

therefore located near monitoring well EPA-MW-05 at the VA Medical Center (Ref. 29, pp. 25-26, 33, 47. 

48). The ground water modeling consisted of both particle-tracking and contaminant transport modeling 

simulations run over a variety of pumping and source concentration scenarios (Ref. 29, pp. 30-31). Under 

steady-state (no pumping) ambient flow the model predicted ground water flows from the northeast to the 

southwest (Ref. 29, p. 31). Discrepancies between the model-predicted ground water gradient and the 

potentiometric surface that has been drawn in previous reports (e.g. Ref. 20, p. 23) is attributed by MWH to be 

due to perched water and that the ground water flow direction is as modeled (from the northeast to the 

southwest (Ref. 29, p. 11). The report further states that this flow direction is physically evident given the 

known distribution of PCE contamination with high concentrations in the vicinity of the well pair at EPA-MW01 (i.e. deep and shallow wells) and the detected contamination in springs along the Wasatch Fault line (i.e. the 

East Bench Fault) (Ref. 29, p. 31). 

Conclusions from the ground water modeling included that, if the well were to be used, PCE contamination

would continue to impact the well as its extraction rate (up to 2,300 gallons per minute [gpm]) would be 

sufficient to alter the ground water flow regime in the area and would draw contamination into the well (Ref. 

29, pp. 33, 48). 

2.2 SOURCE CHARACTERIZATION (Ref. 1, p.51588)

2.2.1 SOURCE IDENTIFICATION (Ref. 1, p. 51588)

Source Type: Other (historic disposal of PCE to sewer) 

Description and Location of Source: (Figures 1 and 2 of this HRS documentation record):

The source is the historic disposal of PCE-contaminated condensate (aka separator water) from the distillation 

process of the former VA Medical Center dry cleaning operation to the drain attached to the sanitary sewer line 

that leads from Building 7 (Ref. 8, p. 2). 

It has been documented that PCE was the solvent used at the VA dry cleaning facility (Ref. 8, pp. 2, 3). The 

dry cleaning system was a closed loop system (Refs. 8, p. 2, 3; 10, p. 7). The system contained a distillation 

process for the recovery of PCE at the end of each cycle (Ref. 8, p. 2, 3). The VA reported that there was no 

documentation to support that they ever had below or above ground tanks used for storing spent solvents, 

chlorinated solvents, waste fluids or materials containing spent chlorinated solvent (Ref. 8, p. 3). The 

condensate from the distillation process was emptied directly into a drain line attached to the sanitary sewer 

(Ref. 8, p. 2, 3).

While an exact hazardous waste quantity of PCE disposed into the drain line cannot be determined, it is known 

that condensate (aka separator water) contains PCE, being saturated with respect to the solvent (Refs. 10, pp. 

11-13; 11, pp. 2-7). At room temperature, approximately 150 mg/L of PCE would have been dissolved in the 

separator water (Refs. 10, p. 12; 11, p.4, 5). In addition to condensate water with dissolved PCE, the discharge 

would also have contained some pure cleaning solvent and solids containing PCE (Ref. 32, p. 4). Being 

heavier than water, PCE settles to the bottom of a sewer line and exfiltrates through it, leaking through joints 

and cracks (Ref. 32, p. 4). Exfiltration rates from clay sewer pipes in some areas of the U.S. have been 

estimated to be between approximately 5,000 and 77,000 gallons per inch diameter of pipe, per mile length, 

per day (Ref. 60, pp. 4-6). PCE, being volatile, also turns into gas and penetrates the sewer wall. PCE then 

travels through the vadose zone to the ground water (Ref. 32, p. 4).
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According to the VA, the distillation process was efficient enough that very little PCE was added to the system 

on a weekly basis for recharge (Ref. 8, pp. 2, 3). PCE was purchased and stored in 55-gallon containers. The 

rate at which the 55-gallon containers were used is unknown (Ref. 8, p. 2, 3), but PCE consumption per weight 

of material cleaned has been reported to vary from 420 pounds of material per gallon to less than 100 pounds 

of material per gallon, depending upon the overall performance of the dry cleaning equipment and the 

effectiveness of operating procedures (Ref. 16, p. 5). It has also been reported that, in the early 1990’s a

typical dry cleaner business used between 15 and 40 gallons a month of PCE (Ref. 32, p. 5).

The disposal of dry cleaner separator water to a sanitary sewer or septic tank was common practice in the 

1980’s (Ref. 10, p. 15). One study has shown that the most frequent type of release from dry cleaners is a 

release from sewer lines (Ref. 33, p. 4). 

PCE has been detected in soil gas above the sanitary sewer line that leads from the former location of the dry 

cleaner within Building 7, with the highest concentrations detected at locations closest to Building 7 (Refs. 12, 

pp. 6-7, 13-16; 13, pp. 4, 6, 7, 9, 14). The presence of PCE in soil gas confirms that the soil has been impacted 

by PCE.

Employees of the SLCDPU documented observations of discolored water and odors of dry cleaner solvent at 

various dates in the early 1980’s while cleaning the sanitary sewer line that leads from Building 7 (Ref. 14). A

video survey of sections of the sewer lines between Building 7 and Sunnyside Avenue was conducted on 

December 17, 2003 by the SLCDPU (Ref. 15). This survey documented numerous defects in most of the 

sewer line sections, including cracks, root penetrations, offsets, and a pipe sag, as well as evidence of historic 

breaks, repairs and replacements of the clay pipe (Ref. 15). Waste water, free-phase solvent, and solvent 

vapors can leak from sewer lines through cracks, joints or breaks (Refs. 10, p. 16; 32, pp. 3-4; 33, pp. 4-5).

There is no liner situated between the sewer line and the underlying in-situ soils (Ref. 31).

Ground water and springs downgradient of Building 7 and the sanitary sewer line contain PCE at 

concentrations greater than background levels (Refs. 20, p. 13, 25, 27, 67, 69, 79; 21, pp. 6, 11, 15; 22, pp. 18, 

45, 47; 23, pp. 6, 38, 40, 42, 48; 24, pp. 5-33; 25, pp. 2-5; 26, p. 17, 19; 27, pp. 2-4, 7, 10, 13, 18, 21, 24, 29, 

32, 35, 38, 41, 44; 28, pp. 6, 8, 9, 14, 16, 18, 19, 27, 28, 29, 33, 35-37, 58, 73, 79, 83, 85, 103, 105, 142; 29, 

pp. 18-22). This indicates that a release of hazardous substances has occurred to the ground water migration 

pathway as documented in Section 3.0 of this HRS documentation record. 

Based on the documented waste disposal practices at the former dry cleaning operation, the condition of the 

sewer line leading from the operation, the eye-witness accounts of dry cleaning solvent being present in the 

sewer line, the detection of PCE in soil gas above the sewer line in concentrations greater than background 

levels, and the detection of PCE in ground water and springs downgradient of the sewer line in concentrations 

greater than background levels, the source consists of an historic disposal of an unknown quantity (but greater 

than zero) of waste water containing PCE. 

2.2.2 HAZARDOUS SUBSTANCES ASSOCIATED WITH THE SOURCE (Ref. 1, p. 51588)

The dry cleaning facility was operational from approximately 1976 through 1984 (Ref. 8, pp. 2, 3, 20, 21, 24, 

26). PCE was used in the dry cleaning process (Ref. 8, pp. 2, 3). 

The dry cleaning system was a closed loop system (Refs. 8, p. 2, 3; 10, p. 7). The system contained a 

distillation process for the recovery of PCE at the end of each cycle (Ref. 8, pp. 2, 3). The condensate from the 

distillation process was emptied directly into a drain line attached to the sanitary sewer (Ref. 8, pp. 2, 3). 
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While an exact hazardous waste quantity of PCE disposed into the drain line cannot be determined, it is known 

that condensate (aka separator water) contains PCE, being saturated with respect to the solvent (Refs. 10, pp. 

11-13; 11, pp. 2-7). At room temperature, approximately 150 μg/L of PCE would have been dissolved in the 

separator water (Refs. 10, p. 12; 11, pp.4, 5). 

Employees of the SLCDPU documented observations of discolored water and odors of dry cleaner solvent at 

various dates in the early 1980’s while cleaning the sanitary sewer line that leads from Building 7 (Ref. 14). 

PCE has been detected in soil gas above the sanitary sewer line, with the highest concentrations detected at 

locations closest to Building 7 (Refs. 12, pp. 6-16; 13, pp. 4, 6, 7, 9, 14). The presence of PCE in soil gas 

confirms that soil has been impacted by PCE.

Ground water and springs downgradient of Building 7 and the sanitary sewer line contain PCE at 

concentrations greater than background levels, indicating that a release of hazardous substances has occurred to 

the ground water migration pathway as documented in Section 3.0 of this HRS documentation record. 
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TABLE 1: Evidence Associating PCE with the Source

Hazardous Substance Evidence References

Tetrachloroethylene (PCE) •The VA has stated that PCE was 

used in the dry cleaning process. 

PCE-laden condensate (separator 

water) was disposed to the sewer 

(i.e. deposition to source).

•A strong dry cleaning solvent 

odor and discolored water was 

observed in the sewer during the 

time of dry cleaner operation (i.e. 

direct observation). 

•PCE has been identified in soil 

gas above the sewer, with the 

highest concentrations occurring 

at a location closest to the former 

dry cleaner (i.e. observed release). 

•PCE has been identified in 

ground water immediately 

downgradient, but not 

immediately upgradient of the 

former dry cleaner (i.e. observed 

release). PCE has also been 

identified in springs downgradient 

of the former dry cleaner. 

Ref. 8, pp. 2, 3; Refs. 

10, pp. 11-13; 11, pp. 

2-7 

Ref. 14

Refs. 12, pp. 6-7, 13-

16; 13, pp. 4, 6, 7, 9, 

14

Refs. 20, p. 13, 25, 27, 

67, 69, 79; 21, pp. 6, 

11, 15; 22, pp. 18, 45, 

47; 23, pp. 6, 38, 40, 

42, 48; 24, pp. 5-33; 

25, pp. 2-5; 26, p. 17, 

19; 27, pp. 2-4, 7, 10, 

13, 18, 21, 24, 29, 32, 

35, 38, 41, 44; 28, pp. 

6, 8, 9, 14, 16, 18, 19, 

27, 28, 29, 33, 35-37, 

58, 73, 79, 83, 85, 103, 

105, 142; 29, pp. 18-

22.

Containment

A study has shown that the most frequent type of release from dry cleaners is a release from sewer lines (Ref. 

33, p. 4). Being heavier than water, PCE settles to the bottom of a sewer line and exfiltrates through it, leaking 

through breaks or cracks, as well as pipe joints and other connections (Ref. 32, pp. 4, 6, 21). Exfiltration rates 

from clay sewer pipes in various areas of the U.S. have been estimated to be between approximately 5,000 and 

77,000 gallons per inch diameter of pipe, per mile length, per day (Ref. 60, pp. 4-6). In addition to leaking 

through joints and cracks, PCE has been reported to penetrate through sewer lines by other methods, including 

by leaching directly through the line, by volatilizing from the outer edge of the pipe into the surrounding soils, 

and by penetrating the pipe in gas form (Ref. 32, pp. 21-23). 

A video survey of sections of the sewer lines between Building 7 and Sunnyside Avenue was conducted on 

December 17, 2003 by the SLCDPU (Ref. 15). This survey documented numerous defects in most of the 

sewer line sections, including cracks, root penetrations, offsets, and a pipe sag, as well as evidence of historic 
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breaks, repairs and replacements of the clay pipe (Ref. 15). Waste water, free-phase solvent, and solvent 

vapors can leak from sewer lines through cracks, joints or breaks (Refs. 10, p. 16; 32, pp. 3-4; 33, pp. 4-5). 

There is no liner situated between the sewer line and the underlying in-situ soils (Ref. 31).

2.2.3 HAZARDOUS SUBSTANCES AVAILABLE TO A PATHWAY (Ref. 1, p. 51588)

The source consists of an historic disposal of an unknown quantity (but greater than zero) of waste water 

containing PCE. Because the SLCDPU has confirmed that the sewer line leading from Building 7 is not lined 

and has numerous defects, a containment value of 10, as shown below in Table 2 below, was assigned for the 

ground water migration pathway (Refs. 1, Table 3-2, p. 51596; 22; 31). 

TABLE 2: Containment Factor Value for the Source

Containment Description

Containment

Factor Value References

Gas release to air: NS NA

Particulate release to air: NS NA

Release to ground water: Because of the direct disposal to the sewer 

line, and the containment characteristics of the line discussed above, a 

containment value of 10 has been assigned. In addition, no liner 

exists beneath the sewer line, which has numerous defects.

10 1, Section 

3.1.2.1, Table 

3-2, p. 51596; 

22; 31

Release via overland migration and/or flood: NS NA

Notes:

NS Not Scored

NA Not applicable

2.4.2 HAZARDOUS WASTE QUANTITY (Ref. 1, p. 51590) 

2.4.2.1.1 Hazardous Constituent Quantity (Tier A) (Ref. 1, pp. 51590, 51591)

Description

The information available is not sufficient to adequately determine with reasonable confidence a hazardous 

constituent quantity (Tier A) for Source 1, as required by Reference 1, Section 2.4.2.1.1, p. 51590. Scoring

therefore proceeds to the evaluation of Tier B, hazardous wastestream quantity. 

Assigned Value: Not Evaluated

2.4.2.1.2 Hazardous Wastestream Quantity (Tier B) (Ref. 1, p. 51591) 

Description

As the source being evaluated is the historic disposal of PCE-contaminated condensate from the VA Medical 

Center dry cleaning operation, it is not a source with measurable volume or capacity. However, since it is 

known that some quantity of condensate was disposed, a value of greater than zero can be assigned for the 

hazardous wastestream quantity under Tier B, Hazardous Wastestream Quantity, as outlined in Reference 1, 

Section 2.4.2.1.2, p. 51591.
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Sum (pounds): > 0

Sum of Wastestream Quantity/5,000 (Table 2-5): >0/5,000 = > 0

Hazardous Wastestream Quantity Assigned Value: > 0 

2.4.2.1.3 Volume (Tier C) (Ref. 1, p. 51591) 

Description

As a hazardous wastestream quantity has been evaluated, Tier C has not been evaluated. 

Assigned Value: Not Evaluated

2.4.2.1.4 Area (Tier D) (Ref. 1, p. 51591) 

Description

As a hazardous wastestream quantity has been evaluated, Tier D has not been evaluated. 

Assigned Value: Not Evaluated

2.4.2.1.5 Source Hazardous Waste Quantity Value (Ref. 1, p. 51591) 

The source HWQ value for the source is greater than zero, but undetermined, for Tier B – Hazardous 

Wastestream Quantity (Ref. 1, Table 2-5, p. 51591).

Source HWQ Value: > 0 
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TABLE 3: Summary of Source Descriptions

Source 

No.

Source 

Hazardous

Waste 

Quantity

Value

Source 

Hazardous 

Constituent 

Quantity 

Complete? 

(Yes/No) 

Containment Factor Value by Pathway

Ground water

(GW) (Ref. 1, 

Table 3-2)

Surface Water

Overland/ flood

(Ref. 1, Table 4-2)

Air

Gas (Ref. 1, 

Table 6-3)

Particulate

(Ref. 1, 

Table 6-9)

1 > 0 No 10 NS NS NS

Notes:

> Greater than

NS Not scored

3.0 GROUND WATER MIGRATION PATHWAY (Ref. 1, p. 51595) 

3.0.1 GENERAL CONSIDERATIONS (Ref. 1, p. 51595) 

Ground Water Migration Pathway Description

Regional Geology: 

Salt Lake Valley is within the Basin and Range physiographic province which is characterized by generally 

parallel, north- to northeast-trending mountain ranges separated by broad alluvial basins that are a result of 

Cenozoic-age extensional faulting (Ref. 38, p. 4). The Salt Lake Valley alluvial basin is bounded on the east 

by the Wasatch Fault, which is comprised of several seismically-independent segments that have been active in 

Holocene time (Ref. 39, p. 3). This active fault zone has uplifted the Wasatch Mountains as much as 7,000 

feet relative to the valley. The Wasatch Mountains are comprised of Tertiary-, Mesozoic- and Paleozoic-aged

bedrock which is present at the surface (Ref. 39, p. 2). The source area of the site is located approximately one 

mile southwest of the Wasatch Mountains (Figure 1, Refs. 38, p. 5; 51), above the valley floor. 

The Salt Lake Valley alluvial basin is characterized by unconsolidated Quaternary-age sediments, overlying 

unconsolidated and semi-consolidated Tertiary-age sediments (Ref. 38, p. 4). The Quaternary-age sediments 

were deposited primarily in lacustrine and fluvial environments associated with numerous transgressive and 

regressive phases of the ancestral Lake Bonneville and older lake cycles while the Tertiary-age sediments are 

associated with alluvial fans and volcanic ash and (Refs. 38, p. 4; 39, p. 2, 4, 5). The water level of Lake 

Bonneville began rising about 30,000 years ago to a high of about 5,180 feet in altitude (approximately 450 

feet higher than the site) about 16,000 years ago (Ref. 38, p. 4). This depositional environment resulted in a 

complex subsurface stratigraphy, with interbedded and laterally discontinuous layers (Refs. 29, p. 24; 38, p. 7; 

42, p. 4; 41, p. 5). This complexity is apparent in borehole logs from wells installed at the site (Ref. 20, pp. 

40-57).

In general, sediments deposited near the mountain front (where the site is located) tend to be coarser-grained 

gravels and sands with no substantial, continuous layers of fine-grained materials. Finer-grained silts and clays 

were deposited in the quieter, deeper water on the valley (lake) bottom (i.e. to the west of the site) (Ref. 39, p. 

4; 41, pp. 4, 5). While borehole logs from wells installed at the site show layers of fine-grained materials, these 

layers are not continuous (Ref. 20, pp. 40-57).
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Regional Hydrogeology: 

A generalized model of the basin-fill sediments in Salt Lake Valley consists of a relatively deep unconfined 

aquifer near the mountain fronts (i.e. in the area of the site source) that becomes confined toward the center of 

the valley by layers of silt and clay (Ref. 38, p, 7). Ground water moves laterally from east to west or

southwest in the eastern side of the valley, from the unconfined part of the aquifer towards the confined part of 

the aquifer (Refs. 29, pp. 11, 31; 41, pp. 4-6). Together, the combined unconfined and confined parts of the 

deep aquifer are known as the ‘principal aquifer’ in the valley. The principal aquifer is an important source of 

drinking water for Salt Lake Valley, contributing water to about 38% of the population (Ref. 38, pp. 7, 8; 41, 

p. 7; 42, p. 3). 

The primary recharge area for the principal aquifer is near the mountain fronts where there are no continuous 

layers of fine-grained material to impede the downward movement of water (Refs. 38, p. 7; 41, pp. 5, 8; 42, pp. 

4, 5). Leakage of shallow ground water (i.e. perched water, also called ‘perched aquifers’ in various reports) to 

the principal aquifer is possible where a downward gradient exists and confining layers are thin and 

discontinuous (Ref. 38, p. 7). These conditions are present in the secondary recharge area, which borders the 

primary recharge area on the west, and includes the area of the East Side Springs (Refs. 38, pp.7, 9, 10; 42, p. 

4). As ground water in the principal aquifer flows towards the valley center where it is confined beneath 

laterally continuous fine-grained layers, an upward gradient is created, and ground water flows upward through 

the confining layer, into the shallow unconfined aquifer, and finally discharges to the Jordan River, supply 

wells, springs, drains, canals, and the Great Salt Lake, or is lost through evapotranspiration (Refs. 38, pp. 7, 8; 

42, p. 3). 

It should be noted that various reports mention the presence of ‘perched aquifers’ in the area of the site. For 

ease of discussion in this documentation record, these ‘aquifers’ are referred to within simply as ‘perched 

water’ or ‘perched zones’, to reinforce the fact that they are discontinuous over short distances, and to 

distinguish them from the ‘shallow unconfined aquifer’ that overlies laterally continuous fine-grained layers 

that exist in the center of the valley (Ref. 38, p. 7).

Depth to ground water in the unconfined part of the principal aquifer (i.e. along the mountain fronts) is 

typically from 150 to 200 feet bgs (Ref. 41, p. 11). This correlates well to the depth to water noted in supply 

and monitoring wells at the site (123.98 to 211.39 feet bgs) (Ref. 29, p. 41). Depth to ground water in the 

confined part of the principal aquifer is deepest in the secondary recharge area (100 to 140 feet bgs), and very 

shallow (1 to 5 feet bgs) in the discharge area in the center of the valley (Ref. 41, p. 11).

Site Geology and Hydrogeology: 

The surficial geology changes from east to west across the site area (Ref. 39, pp. 2, 4). The surficial geology of 

the source area of the site is comprised of coarse-grained alluvial fan deposits of gravel in a matrix of sand and 

silty sand, surrounded by lacustrine deposits to the south, west and north (Ref. 39, pp. 2, 4). Generally, the 

lacustrine deposits become more fine-grained to the west of the site, until the East Bench Fault is reached (Ref. 

39, pp. 2, 4). The East Bench Fault, a spur of the Wasatch Fault, branches in two locally, with an eastern 

branch and a western branch (Refs. 27, p. 3; 29, p. 43; 38, pp. 5, 6; 39, p. 2). The western branch of the East 

Bench Fault is defined by the presence of mixed colluvium and alluvium deposited as a debris apron at the 

base of the fault’s scarp (Ref. 39, pp. 2, 4). The unconsolidated and underlying semi-consolidated sediments 

beneath the area of site are hundreds of feet thick (Ref. 5, p. 3). At the SLCWS Well # 18 location, bedrock 

was estimated to occur at approximately 500 feet bgs (Ref. 29, p. 60). According to the driller’s log for 

University of Utah Well #3, clays and gravels were present to nearly 700 feet bgs (Ref. 40, p. 8). 
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The topography of the area slopes to the southwest at a grade of approximately 4% until reaching the fault 

scarp of the western branch of the East Bench Fault (the east branch of the fault is poorly expressed on the 

surface and does not have a readily apparent scarp), where it steepens abruptly to approximately 10% (Figure 

3, Ref. 27, p. 3). It is at this steep scarp that the East Side springs surface (Figure 3, Ref. 27, pp. 3, 4). 

The geologic complexity, caused by the various lacustrine and fluvial environments associated with numerous 

transgressive and regressive phases of the ancestral lakes, is apparent in borehole logs from wells installed at 

the site in 1998 (Ref. 20, pp. 40-57). The closest subsurface boring to the source area of the site is permanent 

ground water well EPA-MW-05. This well was installed in a boring drilled in July 1998 approximately 300 

feet northeast of Building 7 (Figure 3, Refs. 20, pp.11, 12, 23, 37, 38). The log from this boring shows 

interbedded silt, sands, and gravels present through its entire depth to 220 feet below ground surface (Ref. 20, 

pp. 50, 51). The logs from the other borings installed in 1998 show similarly complex interbedded lithologies 

of varying thicknesses that do not correlate well between borings (i.e. that are not laterally continuous) (e.g. 

Ref. 20, p. 55). In 2005, the USGS attempted to correlate lithology between borings in the area of the 

contamination, but noted difficulty in matching stratigraphic layers and the discontinuous nature of the finegrained lower permeability layers identified in the logs (Ref. 24, p. 1). 

The site is located approximately one mile southwest of the Wasatch Mountains (Figure 1, Refs. 38, p. 5; 51)

and overlies the primary recharge area for the principal aquifer (Refs. 38, pp. 7, 9, 10). The source area (i.e. the 

site of the historic disposal at the dry cleaner) is located on the western edge of the primary recharge area, 

where there are no continuous layers of fine-grained material to impede the downward movement of water to 

the principal aquifer (Refs. 20, pp. 40-57; 38, p. 7; 41, pp. 5, 8; 42, pp. 4, 5). The springs are located in the 

secondary recharge area where confining layers are thin and discontinuous (Refs. 24, p. 1; 38, pp. 7, 9, 10). 

All areas of the site, in particular the source area, are primarily underlain by the principal aquifer; there are no 

continuous layers of fine-grained material to impede flow (Refs. 20, pp. 40-57; 24, p. 1; 38, pp. 7, 9, 10).

From the Fall of 2010 until early 2012, MWH, on behalf of the SLCDPU, conducted a variety of activities at 

the site, including aquifer testing and ground water modeling (Ref. 29, pp. 4, 5, 17-22, 27-33). Pump tests 

conducted within SLCWS Well #18 and slug testing in the well EPA-MW-01D yielded an estimated 

transmissivity for the principal aquifer of 22,700 to 35,800 square feet per day, with hydraulic conductivities 

45 to 140 feet per day (Ref. 29, p. 21). Transmissivity is generally highest near the mountains where streams 

entering the valley deposit the coarsest-grained materials (Ref. 41, p. 4).

The pump test also identified the East Bench Fault (identified as a potential spur of the Wasatch fault in the 

report); however, the fault is not a barrier-type boundary because pumping at SLC Well #18 produced a strong 

response at the well EPA-MW-1D, indicating a hydraulic connection between these wells (Ref. 29, p. 30). 

That the fault is not a barrier to ground water flow is also evidenced by the presence of PCE contaminated 

ground water downgradient of the fault (Ref. 29, pp. 22, 29-30, 46-48). As PCE has migrated across this 

boundary, the fault is not considered to be an aquifer discontinuity for the purposes of scoring the site (Ref. 1, 

p. 51595).

The ground water modeling predicted ground water flows to be from the northeast to the southwest under 

steady-state (no pumping) conditions (Ref. 29, p. 31). MWH attributed the discrepancy between the model’s 

prediction and the flow direction identified in previous reports (to the northwest) (e.g. Ref. 20, p. 23) to be due 

to perched water (called ‘perched aquifers’ in the report) (Ref. 29, p. 11). The report further states that the 

modeled flow direction is physically evident given the known distribution of PCE contamination with high 

concentrations in the vicinity of the well pair at EPA-MW-01 (i.e. deep and shallow wells) and the detected 

contamination in springs along the Wasatch Fault line (i.e. the East Bench fault) (Ref. 29, p. 31). 
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Conclusions from the ground water modeling included that, if the well were to be used, PCE contamination 

would continue to impact the well as its extraction rate (up to 2,300 gallons per minute (gpm)) would be

sufficient to alter the ground water flow regime in the area and draw contamination into the well (Ref. 29, pp. 

33, 48). During the MWH study, when pumping SLCWS Well #18, a strong response was noted within EPAMW-1D, indicating a hydraulic connection between these wells (Ref. 29, p. 30). These wells are located 

approximately 1,600 feet apart (Figure 3, Ref. 27, p. 3). 

Aquifer Interconnectivity: 

The site is located approximately one mile southwest of the Wasatch Mountains (Figure 1, Refs. 38, p. 5; 51) 

and overlies the primary recharge area for the principal aquifer (Refs. 38, pp. 7, 9, 10). The source area (i.e. the 

site of the historic disposal at the dry cleaner) is located on the western edge of the primary recharge area, 

where there are no continuous layers of fine-grained material to impede the downward movement of water to 

the principal aquifer (Refs. 20, pp. 40-57; 38, p. 7; 41, pp. 5, 8; 42, pp. 4, 5). The springs are located in the 

secondary recharge area where confining layers are thin and discontinuous (Refs. 24, p. 1; 38, pp. 7, 9, 10). 

All areas of the site, in particular the source area, are primarily underlain by the principal aquifer; there are no 

continuous layers of fine-grained material to impede flow (Refs. 20, pp. 40-57; 24, p. 1; 38, pp. 7, 9, 10).

Ground water moves laterally from the unconfined part of the principal aquifer near the mountains (i.e. at the 

source area of the site) towards the confined part of the aquifer in the valley center (west of the site), therefore 

the two parts of the principal aquifer are interconnected (Refs. 38, p. 7, 9, 10; 41, p. 4, 5; 42, p. 3). A natural 

downward gradient has been documented within the SLCWS Well #18 at the site (Ref. 29, p. 19).

PCE is very mobile, with relatively low solubility and vapor pressure (Refs. 32, p.5; 48, p. 4). Once it enters 

the soil vadose zone (the unsaturated zone), PCE travels downward to ground water (Ref. 32, p. 4). In its 

liquid state, PCE is heavier and less viscous than water and will sink through it (Ref. 32, pp. 5, 6). When PCE 

encounters an aquitard (i.e. a layer of clay that creates a perched zone) that is discontinuous (e.g. such as those 

beneath the site) it is able to flow around the sides of the discontinuous layer in all directions, including in the 

upgradient direction (depending upon the flow gradient and the topography of the layer) (Ref. 17, pp. 2, 3). 

In addition, pumping from the principal aquifer with the local deep water supply wells (e.g. the Mt. Olivet 

irrigation well, the SLCWS Well #18, and the University of Utah Well #2) has accelerated the natural 

downward ground water gradient (Ref. 29, p. 19), causing the contamination to more rapidly spread than 

would otherwise have occurred (Refs. 17, p. 3; 29, p. 21). When pumped, the ground water extraction rate at

SLCWS Well #18 is able to dominate the regional ground water flow (Ref. 29, p. 21). Aquifer testing and 

hydrogeological modeling indicate that previous seasonal pumping of SLCWS Well #18 and pumping of the 

University well laterally expand the contamination to the north, creating a more broad and dilute area of 

contamination (Ref. 29, p. 28). These wells are all perforated into water bearing zones deeper than 400 feet 

bgs (Ref. 29, pp. 14, 24, 51; 40, pp. 1, 6, 8, 9).

Aquifer Discontinuity:

The Wasatch Mountains located to the north and east of the site are comprised of Tertiary-, Mesozoic- and 

Paleozoic bedrock which is present at the surface (Ref. 39, p. 2). This bedrock forms a different aquifer than 

those within the unconsolidated basin-fill sediments present in the valley. Therefore, the base of the Wasatch 

Mountains will be considered an aquifer discontinuity for HRS scoring purposes and all wells identified 

beyond this discontinuity will be eliminated.

Faults within and bounding the basin-fill deposits may affect the hydraulic gradient and ground water 

movement (Ref. 41, p. 8). The East Bench Fault, a spur fault of the Wasatch Fault Zone, exists at the western 
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boundary of the currently known extent of ground water contamination (Refs. 27, p. 3, 4; 29, p. 43; 38, pp. 5, 

6; 39, p. 2). This fault has two branches in the area of the site, with the eastern branch being located 

approximately 3,200 feet downgradient of the VA Medical Center, while the western bifurcation is located 

about 5,800 feet downgradient (Refs. 27, p. 3; 29, p. 43; 38, pp. 5, 6, 39, p. 2). The fault was not modeled as a 

complete barrier-type boundary because pumping at SLC Well #18 produced a strong response at the well 

EPA-MW-1D, indicating a hydraulic connection between these wells (Ref. 29, p. 30). That the fault is not a 

barrier to ground water flow is also evidenced by the presence of PCE contaminated ground water 

downgradient of the fault (Ref. 29, pp. 22, 29-30, 46-48). As PCE has migrated across this boundary, the fault 

is not considered to be an aquifer discontinuity for the purposes of scoring the site (Ref. 1, p. 51595).

While no hydrogeologic testing information is available in regards to the western branch of the East Bench 

Fault, this branch of the fault offsets similar unconsolidated materials as the eastern branch (Ref. 5, p. 3). 

These sediments are many hundreds of feet thick in the area of the site (Ref. 29, p. 60; 40, p. 8). As it offsets 

similar unconsolidated sediments as the eastern branch, it follows that the western branch of the East Bench 

Fault is also not likely to be a complete barrier to ground water flow. Therefore, this branch of the fault is also 

not considered to be an aquifer discontinuity for the purposes of scoring the site (Ref. 1, p. 51595). 

Based upon the evidence presented above, it is considered that any shallow ground water (e.g. isolated perched 

water, the East Side Springs) within a 2-mile radius of the source is connected to the deeper ‘principal aquifer’. 

As such, the principal aquifer will be the only hydrologic unit considered for scoring purposes (Ref. 1, p. 

51595). The principal aquifer is continuous to the south and west of the Wasatch Mountains within the 4-mile 

radius of the source, but the bedrock of the Wasatch Mountains forms a discontinuity to the north and east of 

the site (Refs. 1, p. 51595; 5). 
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TABLE 4: Summary of Aquifer(s) Being Evaluated

Aquifer 

Name

Is Aquifer 

Interconnected 

within 2 miles? 

(Yes/No)

Is Aquifer Continuous 

within 4-Mile TDL? 

(Yes/No)

Is Aquifer 

Karst? 

(Yes/No) 

References

Principal 

Aquifer Yes

Yes (west of the 

Wasatch Mountains) No

27; 29, pp. 22, 29-30, 

66; 38, pp.7, 9, 10; 41, 

pp. 4, 5, 11, 12; 42, p. 4

Notes:

TDL Target Distance Limit

3.1 LIKELIHOOD OF RELEASE (Ref. 1, p. 51595) 

3.1.1 OBSERVED RELEASE (Ref. 1, p. 51595) 

Aquifer Being Evaluated: Principal aquifer

Chemical Analysis

Background Samples: 

PCE is a synthetic chemical (Ref. 48, p. 2) and is not ubiquitous in the area of the site. As such, its

background concentration in ground water would be expected to be at or near zero. Nevertheless, chemical 

analysis will be used to document an observed release of PCE at the site. 

Analytical results from both a permanent monitoring well located upgradient of the source (EPA-MW-05), as 

well as historical results from the municipal supply well SLCWS Well #18 from a time when it was 

uncontaminated (i.e. using SLCWS Well #18 as its own background well), will be used to document 

background levels. Analytical results from each well are discussed separately below.

Background well EPA-MW-05 – well details:

Permanent ground water monitoring well EPA-MW-05 was installed on the VA Medical Center property in 

August 1998 (Ref. 20, pp. 12, 37, 38, 50, 51). The well is located upgradient of the source (i.e. approximately 

300 feet northeast of the former dry cleaner location) (Figure 3, Refs. 20, p. 23; 29, p. 25, 26, 43, 47; 51).

EPA-MW-05 is completed within the principal aquifer to a depth of 221 feet bgs (4,514 feet amsl), and is 

screened from 186 to 221 feet bgs (4,549 to 4,514 feet amsl) (Ref. 20, pp. 50, 51). The ground water elevation 

in the well is similar to those within the other permanent monitoring wells established in the vicinity of the site, 

as well as the ground water elevation within SLCWS Well #18 (Ref. 29, pp. 41, 66; Tables 5, 7, and 9 of this 

documentation record). 

Background well EPA-MW-05 – hazardous substance concentrations:

Water collected from EPA-MW-05 has been sampled and analyzed for VOCs numerous times since its 

installation in 1998, always returning non-detect results for PCE (Refs. 20, pp. 25, 79; 23, pp. 6, 49, 50, 64; 

24, pp. 5, 24; 26, pp. 2, 17, 27; 28, pp. 15, 27, 29, 33, 35, 36, 81). Three samples will be used to document 

background conditions for the site: the sample MT-007, collected from well EPA-MW-05 by the UDEQ and 
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EPA START on October 15, 2004, and the sample MW-05, collected from well EPA-MW-05 by EPA START 

on October 4, 2005, will be used to document background conditions at the time when SLCWS Well #18 was 

permanently taken offline due to PCE contamination (approximately October 2004), and the most recent 

sample (sample ID: H0AA4) collected from EPA-MW-05 on November 16, 2011 will also be used to 

document current background conditions at the site (Refs. 26, pp. 2, 17, 27; 28, pp. 15, 27, 29, 33, 35, 36, 81; 

46; Table 6 of this documentation record).

The sampling performed on October 15, 2004 was conducted through a Cooperative Agreement between the 

EPA and the UDEQ (Ref. 23, p. 3). A background sample was collected from permanent monitoring well 

EPA-MW-05 (sample ID: VA Hosp EPA-MW-05 (MT-007)) and release samples were collected from the 

permanent monitoring well EPA-MW-01D, the Mount Olivet irrigation well, and SLCWS Well #18 (Ref. 23, 

pp. 4, 6, 64). Quality assurance/quality control (QA/QC) samples collected included a duplicate sample from 

the Mount Olivet well (sample ID: Mt Olivet Well-B) (Ref. 23, pp. 6, 41, 64), a field blank (sample ID: Mt 

Olivet Well-C) (Ref. 23, pp. 43, 64) and a trip blank (sample ID: Mt-Olivet Well-D) (Ref. 23, pp. 45, 64). 

Samples were shipped to the EPA Region 8 Laboratory in Golden, Colorado and analyzed for volatile organics 

using EPA Method 8260 (Ref. 23, pp. 31, 32, 35). The analytical results from the EPA-MW-05 sample

(sample ID: VA Hosp EPA-MW-05 (MT-007)) did not reveal any detections of PCE above the analytical 

method reporting limit (MRL) values of 1 μg/L for either analyte, indicating that water from this upgradient 

location was not contaminated above this concentration (Ref. 23, pp. 49, 50, 64). The data were reviewed 

according to the EPA Document “USEPA Contract Laboratory Program National Functional Guidelines for 

Organic Data Review, October 1999” (Ref. 58) by an EPA START chemist in September 2005 and found to 

be acceptable for use with the qualifications noted in the data validation report (Ref. 23, pp. 65, 66). A draft 

report was prepared and both the chain-of-custody and the laboratory sample receipt narrative are available 

(Ref. 23, pp. 1-10, 35, 64). 

The sampling conducted on October 4, 2005 was conducted by EPA START (Ref. 26). A background sample 

was collected from permanent monitoring well EPA-MW-05 and release samples were collected from 

permanent monitoring wells EPA-MW-02, EPA-MW-01D, and EPA-MW-04 (Ref. 26, pp. 1-6, 27). QA/QC 

samples collected included a trip blank (sample ID: TB-01) and a duplicate sample collected from EPA-MW01D (sample ID: MW-11) (Ref. 26, pp. 1-6, 27). Samples were delivered by hand to Data Chem Laboratories 

in Salt Lake City for volatile organic analysis by EPA Method 524.2 (Ref. 26, pp. 6, 9, 27). The analytical 

results from the EPA-MW-05 sample (sample ID: MW-05) did not reveal any detections of PCE above the 

sample-specific Method Detection Limit (MDL) value of 0.110 μg/L, indicating that water from this 

upgradient location was not contaminated above this concentration (Ref. 26, pp. 16, 17). The data were 

reviewed according to the EPA Document “USEPA Contract Laboratory Program National Functional 

Guidelines for Organic Data Review, October 1999” by an EPA START chemist in March 2012 and found to 

be acceptable for use with the qualifications noted in the data validation report (Refs. 26, p. 7; 58).

The sampling conducted in November 2011 was conducted by UDEQ and EPA START (Ref. 28, pp. 9, 41-

53). A background sample was collected from permanent monitoring well EPA-MW-05 on November 16 and 

release samples were collected from the permanent monitoring well EPA-MW-01S, from five newly-placed 

direct-push borings, from water from the fountain at Liberty Park and from the 8th South artesian well (aka 8th

South Well) during November 14-17 (Ref. 28, pp. 9, 35). A sample was collected from EPA-MW-05 on

December 21, 2011 (Ref. 28, pp. 9, 35). Ground water QA/QC samples collected included four trip blanks 

(ESS-GW-12, ESS-GW-32, ESS-GW-33, ESS-GW-34) a rinsate blank (ESS-GW-13), a laboratory duplicate 

(ESS-GW-11), and a field duplicate (ESS-GW-14) (Ref. 28, pp. 17, 18, 32, 36). 

Samples were delivered on November 17 and December 21, 2011 via Federal Express to the EPA Contract 

Laboratory Program (CLP) laboratory Mitkem Laboratories (Spectrum Analytical), in Warwick, Rhode Island 

for volatile low/medium multi-media, multi-concentration organics analysis - SOM01.2 (Ref. 28, pp. 59-62, 
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64, 112, 130). The analytical results from the EPA-MW-05 sample (sample ID: HOAA4) did not reveal any 

detections of PCE above the CRQL value of 5.0 μg/L, indicating that water from this upgradient location was 

not contaminated above this concentration (Refs. 28, pp. 15, 25, 33, 35, 81). The data were reviewed 

according to the EPA Document “USEPA Contract Laboratory Program National Functional Guidelines for 

Superfund Organic Methods Data Review, June 2008” by an EPA START chemist in January 2012 and found 

to be acceptable for use with the qualifications noted in the data validation report (Ref. 28, pp. 18, 63-72, 112-

119, 130-137).

TABLE 5: Background Ground Water Sample and Well Information (EPA-MW-05) – Principal 

Aquifer

Sample ID Well Depth 

(feet amsl)

Screened 

Interval 

(feet amsl)

Ground 

Water 

Elevation* 

(feet amsl)

Sample 

Date

References

VA Hosp EPAMW-05 

(MT-007)

4,514 4,549 to 

4,514

4,524 10/15/2004 20, p. 25, 79; 23, pp. 

1, 3, 6, 49, 50, 64; 

29, pp. 41, 66

MW-05 “ “ “ 10/4/2005 20, p. 25, 79; 26, pp. 

2, 17, 27; 29, pp. 41, 

66

H0AA4 “ “ “ 11/16/2011 20, p. 25, 79; 28, pp. 

28, pp. 15, 25, 33, 

35, 81; 29, pp. 41, 

66

Notes:

Amsl above mean sea level

ID identification number

* Ground water elevation data is taken from Ref. 29 (pp. 41, 66) as this is the only site study available where concurrent 

water levels were collected from all site wells of interest (i.e. Mt. Olivet well, Well #18, and the EPA monitoring wells), 

allowing for comparison between wells.

TABLE 6: Background Ground Water Sample Concentrations (EPA-MW-05) – Principal Aquifer

Sample ID Sample Date Hazardous 

Substance

Concentration

(μg/L) 

Reporting 

Limit 

(μg/L)

References

VA Hosp 

EPA-MW-05 

(MT-007)

10/15/2004 PCE <1.0 1.0 23, pp. 1, 3, 4, 6, 31, 32, 

35, 49, 50, 64-66

MW-05 10/4/2005 PCE <0.110 0.110* 26, pp. 1-7, 16, 17, 27, 

58

H0AA4 11/16/11 PCE <5.0 U 5.0** 28, pp. 15, 25, 33, 35, 81

Notes:

μg/L micrograms per liter

 * sample-specific method detection limit

** Contract Required Quantitation Limit

 U The analyte was not detected above the reporting limit
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SLCWS Well #18 (as its own background well):

SLCWS Well #18 was installed near the northeast corner of 500 South and 1500 East (now called Guardsman 

Way) in October 1956 (Figure 3, Ref. 40, pp. 1, 9). The well, assigned Water Right No. 57-2697, was 

installed to supply culinary (municipal) water to Salt Lake City (Refs. 40, pp. 1, 9; 52, pp. 8, 12, 24-26). The 

well has been referred to by various names, including the 500 South Well, 15th East Well, Well #1061A, and 

SLC Drinking Water Well #18 (Refs. 29, p. 1; 52, pp. 8, 12, 24-26). The well is located approximately 2,200 

feet northwest of the source and approximately 2,300 feet northwest of EPA-MW-05 (Figure 3, Refs. 40, pp. 1, 

9; 51).

SLCWS Well #18 is completed within the principal aquifer to a depth of 510 feet bgs (4,164 feet amsl), being 

perforated from 266 to 470 feet bgs (4,408 to 4,204 feet amsl) (Refs. 29, pp. 13, 41; 40, p. 9) (Note that Ref. 

29, p. 41 contains a typo in the table. The correct number for the top of the perforations, according to the 

original well log, is 266 feet (Ref. 40, p. 9)). The ground water elevation in the well is similar to those within 

the permanent monitoring wells established at the site (Ref. 29, pp. 41, 66; Tables 5, 7, and 9 of this 

documentation record). 

TABLE 7: Background Ground Water Sample and Well Information (SLCWS Well #18) – Principal 

Aquifer

Sample ID Well Depth 

(feet amsl)

Perforated

Interval 

(feet amsl)

Ground Water 

Elevation* 

(feet amsl)

Sample 

Date

References

500 So 1500 East 

7/21

4,164 4,408 to 

4,204

4,491 07/21/1989 29, pp. 41, 51, 52, 66; 

40, pp. 9, 10; 45, p. 2 

1500 E Well “ “ ” 09/20/1994 29, pp. 41, 51, 52, 66; 

40, pp. 9, 10; 45, p. 5

Notes:

Amsl above mean sea level

ID identification number

* Ground water elevation data is taken from Ref. 29 (pp. 41, 66) as this is the only site study available where concurrent 

water levels were collected from all site wells of interest (i.e. Mt. Olivet well, Well #18, and the EPA monitoring wells), 

allowing for comparison between wells.

Background historic analytical results from SLCWS Well #18:

Under the Safe Drinking Water Act (SDWA), enacted in 1974 and amended in 1996, the SLCWS is 

responsible for the sampling and analysis (monitoring) of its water supplies in order to ensure that drinking 

water quality meets minimum standards (MCLs) established under the law. Analytical results from this 

compliance sampling show that the SLCWS Well #18 was free of PCE contamination until 1997, when the 

first detection was recorded (Ref. 45, pp. 1-5). 

Two sets of analytical results from samples collected prior to 1997 have been received from the Water Quality 

and Treatment Administrator for the SLCDPU (Ref. 45, p. 1-5). Specific details on sampling procedures were 

not provided. A sample collected by the SLCWS on July 21, 1989 was analyzed for SDWA List One, Two, 

and Three organic compounds by American West Analytical Laboratories in Salt Lake City using EPA Method 

504 (Ref. 45, pp. 2-4). Results from this sample did not reveal any detection of PCE above the detection limit 

value of 0.5 μg/L, indicating that water from the well was not contaminated with PCE above this concentration

(Ref. 45, p. 2; Table 8 of this documentation record). A sample collected by the SLCWS on September 20, 

1994 was analyzed for SDWA Regulated, List 1, and List 3 organic compounds by the Utah Division of 

Laboratory Services in Salt Lake City using EPA Method 502.2 (Ref. 45, p. 5). Results from this sample did 
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not reveal any detection of PCE above the MDL value of 0.5 μg/L, indicating that water from the well was not 

contaminated with PCE above this concentration (Ref. 45, p. 5; Table 8 of this documentation record).

TABLE 8: Background Ground Water Sample Concentrations (SLCWS Well #18) – Principal Aquifer

Sample ID Sample 

Date

Hazardous 

Substance

Concentration

(μg/L) 

Reporting 

Detection 

Limit

(μg/L)

References

500 So 1500 East 

7/21

07/21/1989 PCE <0.5 0.5* 45, p. 2

1500 E Well 09/20/1994 PCE <0.5 U 0.5** 45, p. 5 

Notes:

μg/L micrograms per liter

 * detection limit

** sample specific method detection limit

NA not applicable

 U The analyte was not detected above the reporting detection limit

Contaminated Samples: 

Ground water samples listed in Tables 9 and 10, and shown in Figure 3, of this HRS documentation record 

were collected from permanent monitoring and supply wells completed in the principal aquifer underlying and 

in the vicinity of the source during two time periods: in 2004/2005 (at the time of and within one year of when 

SLCWS Well #18 was shut down due to PCE contamination), and in November and December 2011, in order 

to assess the current contamination concentrations at the site (Refs. 23, p. 3; 26, pp. 1-6, 27; 28, p. 9).

The sampling performed on October 15, 2004 was conducted through a Cooperative Agreement between the 

EPA and the UDEQ (Ref. 23, p. 3). A background sample was collected from permanent monitoring well 

EPA-MW-05 (sample ID: VA Hosp EPA-MW-05 (MT-007)) and release samples were collected from the 

permanent monitoring well EPA-MW-01D, the Mount Olivet irrigation well, and SLCWS Well #18 (Ref. 23, 

pp. 4, 6, 64). All wells are completed in the same aquifer at similar depths (Ref. 29, p. 41). 

UDEQ and EPA – 2004:

Quality assurance/quality control (QA/QC) samples collected included a duplicate sample from the Mount 

Olivet well (sample ID: Mt Olivet Well-B) (Ref. 23, pp. 6, 41, 64), a field blank (sample ID: Mt Olivet WellC) (Ref. 23, pp. 43, 64) and a trip blank (sample ID: Mt-Olivet Well-D) (Ref. 23, pp. 45, 64). 

Samples were shipped to the EPA Region 8 Laboratory in Golden, Colorado and analyzed for volatile organics 

using EPA Method 8260 (Ref. 23, pp. 31, 32, 35). The data were reviewed according to the EPA Document 

“USEPA Contract Laboratory Program National Functional Guidelines for Organic Data Review, October 

1999” (Ref. 58) by an EPA START chemist in September 2005 and found to be acceptable for use with the 

qualifications noted in the data validation report (Ref. 23, pp. 65, 66). A draft report was prepared and both 

the chain-of-custody and the laboratory sample receipt narrative are available (Ref. 23, pp. 1-10, 35, 64). 

The analytical results from the background sample have been discussed previously. Analytical results from the 

samples found to be contaminated are presented in Table 10 of this documentation record. PCE was detected 

in all three of the downgradient wells with PCE concentrations ranging from 2.23 μg/L in SLCWS Well #18 to 

128 μg/L in the Mt Olivet Well (Ref. 23, pp. 6, 38, 40, 42, 48). 
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The analytical results from the blank samples did not reveal any detections of PCE above the MRL value of 1 

μg/L, showing that potential cross contamination during either field activities or sample handling and shipment 

did not occur (Ref. 23, pp. 36, 43-46). 

The sampling conducted on October 4, 2005 was conducted by EPA START (Ref. 26). A background sample 

was collected from permanent monitoring well EPA-MW-05 and release samples were collected from 

permanent monitoring wells EPA-MW-02, EPA-MW-01D, and EPA-MW-04 (Ref. 26, pp. 1-6, 27). All wells 

are completed in the same aquifer at similar depths (Ref. 29, p. 41).

EPA START – 2005:

QA/QC samples collected included a trip blank (sample ID: TB-01) and a duplicate sample collected from 

EPA-MW-01D (sample ID: MW-11) (Ref. 26, pp. 1-6, 27). 

Samples were delivered by hand to Data Chem Laboratories in Salt Lake City for volatile organic analysis by 

EPA Method 524.2 (Ref. 26, p. 6, 9, 26, 27). The data were reviewed according to the EPA Document 

“USEPA Contract Laboratory Program National Functional Guidelines for Organic Data Review, October 

1999” by an EPA START chemist in March 2012 and found to be acceptable for use with the qualifications 

noted in the data validation report (Refs. 26, p. 7; 58). While a narrative report covering the field sampling 

event is not available, the field logbook and chain-of-custody records are included in the reference (Ref. 26, pp. 

1-5, 27).

The analytical results from the background sample have been discussed previously. Analytical results from the 

samples found to be contaminated are presented in Table 10 of this documentation record. PCE ranged from 

non-detect in background well EPA-MW-05 (at a sample-specific method detection limit of 0.110 μg/L) (Ref. 

26, pp. 2, 6, 16, 17, 27) to 160 μg/L in EPA-MW-02 (Ref. 26, pp. 3, 6, 18, 19, 27).

The analytical results from the blank sample did not reveal any detections of PCE above the sample-specific 

method detection limit of 0.110 μg/L, showing that potential cross contamination during either field activities 

or sample handling and delivery did not occur (Ref. 26, pp. 6, 14, 15, 27). 

The sampling conducted in November 2011 was conducted by UDEQ and EPA START (Ref. 28, pp. 9, 41-

53). A background sample was collected from permanent monitoring well EPA-MW-05 on November 16 and 

release samples were collected from the permanent monitoring well cluster EPA-MW-01S and EPA-MW-01D, 

as well as from five newly-placed direct-push borings, and water from the fountain at Liberty Park and the 8th

South artesian well (aka 8th South Well) from November 14-16 and also December 21, 2011 (Ref. 28, pp. 9, 

35). 

UDEQ and EPA START – 2011:

Ground water samples collected from permanent wells are used to establish an observed release to ground 

water at the site. Analytical results from the samples found to be contaminated are presented in Table 10 of 

this documentation record. 

Ground water QA/QC samples collected included four trip blanks (ESS-GW-12, ESS-GW-32, ESS-GW-33, 

ESS-GW-34) a rinsate blank (ESS-GW-13), a laboratory duplicate (ESS-GW-11), and a field duplicate (ESSGW-14) (Ref. 28, pp. 17, 18, 32, 36). 

Samples were delivered on November 17 and December 21, 2011 via Federal Express to the EPA Contract 

Laboratory Program (CLP) laboratory Mitkem Laboratories (Spectrum Analytical), in Warwick, Rhode Island 

for volatile low/medium multi-media, multi-concentration organics analysis - SOM01.2 (Ref. 28, pp. 59-62, 

64, 112, 130). The data were reviewed according to the EPA Document “USEPA Contract Laboratory 
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Program National Functional Guidelines for Superfund Organic Methods Data Review, June 2008” by an EPA 

START chemist in January 2012 and found to be acceptable for use with the qualifications noted in the data 

validation report (Ref. 28, pp. 18, 63-72, 112-119, 130-137). 

The analytical results from the background sample collected from well EPA-MW-05 are discussed above. 

Analytical results for the samples collected from the existing permanent monitoring wells confirm the presence 

of PCE contamination in ground water (Ref. 28, pp. 14, 15, 19, 27, 29, 33, 35, 58, 73, 139, 143). 

Concentrations of PCE in the existing wells ranged from a non-detect (at the CRQL of 5 μg/L) in the 

background well EPA-MW-05 to 150 μg/L in well EPA-MW-01S (Ref. 28, pp. 14, 15, 19, 27, 29, 33, 35, 73, 

81). 

The analytical results from the blank samples did not reveal any detections of PCE above the CRDL value of 

5.0 μg/L, showing that potential cross contamination during either field activities or sample handling and 

delivery did not occur (Ref. 28, pp. 17, 18, 36, 91, 93, 97, 99, 141). 

TABLE 9: Observed Release Ground Water Sample Information – Principal Aquifer

Well

Sample ID(s) Well 

Depth 

(feet 

amsl)

Screened/ 

Perforated

Interval

(feet amsl)

Ground 

Water 

Elevation

(feet amsl)

Sample

Date(s) References

EPA-MW01S HOAA1 4,441 4,481 – 

4,441 4,508 11/14/11

20, pp. 40, 41, 42; 29, p. 

41; 28, pp. 14, 15, 19, 

27, 29, 33, 35, 73; 51

EPA-MW01D

EPA-MW-01D,

MW-01, 

HOAB9

4,261 4,301 – 

4,261 4,493

10/15/04, 

10/05/05, 

12/21/11

20, pp. 43; 23, pp. 6, 38, 

64; 26, pp. 3, 6, 20; 28, 

pp. 14, 15, 19, 27, 29, 

33, 35, 139; 29, p. 41; 

51

EPA-MW-02 MW-02 4,475

4,505 –

4,475 4,516 10/04/05 20, p. 45; 26, pp. 3, 18, 19, 27; 29, p. 41; 51

EPA-MW-04 MW-04 4,484 4,514 – 

4,484 4,520 10/05/05 20, p. 49; 26, pp. 4, 24, 25, 27; 29, p. 41; 51

SLCWS Well 

#18

SLCDW Well 

#18 4,164 4,448 – 

4,204 4,491 10/15/04 23, pp. 6, 47, 64; 29, p. 41; 40, p. 9; 51

Mt Olivet 

Well

Mt Olivet WellA 4,180 4,468 –

4,180 unknown 10/15/04 23, pp. 6, 39, 64; 29, p. 41; 40, p. 6; 51

Notes:

Amsl above mean sea level

NA not applicable
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TABLE 10: Observed Release Ground Water Sample Concentrations – Principal Aquifer

Sample ID Sample Date Hazardous 

Substance

Concentration

(μg/L) 

Reporting

Limit 

(μg/L)

References

HOAA1 11/14/11 PCE 150 5.0* 28, pp. 14, 29, 33, 

35, 58, 60, 64, 73

EPA-MW-01D 10/15/04 PCE 8.33 1 23, pp. 37, 38, 64

HOAB9 12/21/11 PCE 12 5.0* 28, pp. 14, 15, 19, 

27, 29, 33, 35, 139

MW-02 10/04/05 PCE 160 0.110** 26, pp. 3, 18, 19, 27, 

28

MW-04 10/05/05 PCE 120 0.110** 26, pp. 4, 24, 25, 27, 

28

SLC DW Well 

# 18

10/15/04 PCE 2.23 1.0* 23, pp. 47, 48, 64

Mount Olivet 10/15/04 PCE

 

128 1 23, p. 39, 40, 64

Notes: 

* CRQL 

** sample-specific method detection limit

μg/L micrograms per liter

PCE Tetrachloroethene

Hazardous Substances Released: 

Tetrachloroethylene (PCE) 

Ground Water Observed Release Factor Value: 550

Other Supporting Data

Sampling of springs downgradient of the Mt. Olivet well conducted by the SLCPDU in 2010 revealed 

concentrations of PCE in six of the springs as high as 40.4 μg/L (Figure 3, Refs. 27, pp. 14, 25, 32, 45, 46; 28, 

pp. 8, 9). Given the springs’ locations downgradient of the known PCE contamination within the Mt. Olivet 

well and the EPA monitoring wells, the existing PCE contamination in ground water was considered the likely 

source of the PCE (Ref. 28, pp. 6, 19). 

The UDEQ conducted a follow-on investigation in late 2011 which involved the collection of additional water 

samples from springs, as well as samples of ground water from five newly-placed direct-push borings (Refs. 

28, pp. 9, 13; 52, pp. 68, 69). Analytical results from the UDEQ samples confirmed the presence of PCE 

contamination in two of the springs, as well as ground waters adjacent to the springs. Concentrations of PCE 

in the springs ranged from a non-detect in one spring (at the CRQL of 5 μg/L), to 20 μg/L (Ref. 28, pp. 16, 28, 

33, 37, 101, 103, 105). PCE was detected in two direct-push borings at concentrations of 6.1 μg/L and 8 μg/L 

(Ref. 28, pp. 14, 19, 27, 29, 33, 35, 83, 85). 
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Attribution:

It has been documented that PCE was the solvent used at the VA dry cleaning facility (Ref. 8, pp. 2, 3). The 

dry cleaning system was a closed loop system (Refs. 8, p. 2, 3; 10, p. 7). The system contained a distillation 

process for the recovery of PCE at the end of each cycle (Ref. 8, p. 2, 3). The VA reported that there was no 

documentation to support that they ever had below or above ground tanks used for storing spent solvents, 

chlorinated solvents, waste fluids or materials containing spent chlorinated solvent (Ref. 8, p. 3). The 

condensate from the distillation process was emptied directly into a drain line attached to the sanitary sewer 

(Ref. 8, p. 2, 3).

While an exact hazardous waste quantity of PCE disposed into the drain line cannot be determined, it is known 

that condensate (aka separator water) contains PCE, being saturated with respect to the solvent (Refs. 10, pp. 

11-13; 11, pp. 2-7). At room temperature, approximately 150 mg/L of PCE would have been dissolved in the 

separator water (Refs. 10, p. 12; 11, p.4, 5). In addition to condensate water with dissolved PCE, the discharge 

would also have contained some pure cleaning solvent and solids containing PCE (Ref. 32, p. 4). Being 

heavier than water, PCE settles to the bottom of the sewer line and exfiltrates through it, leaking through joints 

and cracks (Ref. 32, p. 4). Exfiltration rates from clay sewer pipes in some areas of the U.S. have been 

estimated to be between approximately 5,000 and 77,000 gallons per inch diameter of pipe, per mile length, 

per day (Ref. 60, pp. 4-6). PCE, being volatile, also turns into gas and penetrates the sewer wall. PCE then 

travels through the vadose zone to the ground water (Ref. 32, p. 4).

According to the VA, the distillation process was efficient enough that very little PCE was added to the system 

on a weekly basis for recharge (Ref. 8, pp. 2, 3). PCE was purchased and stored in 55-gallon containers. The 

rate at which the 55-gallon containers were used is unknown (Ref. 8, p. 2, 3), but PCE consumption per weight 

of material cleaned has been reported to vary from 420 pounds of material per gallon to less than 100 pounds 

of material per gallon, depending upon the overall performance of the dry cleaning equipment and the 

effectiveness of operating procedures (Ref. 16, p. 5). It has also been reported that, in the early 1990’s a 

typical dry cleaner business used between 15 and 40 gallons a month of PCE (Ref. 32, p. 5).

The disposal of dry cleaner separator water to a sanitary sewer or septic tank was common practice in the 

1980’s (Ref. 10, p. 15). One study has shown that the most frequent type of release from dry cleaners is a 

release from sewer lines (Ref. 33, p. 4). 

PCE has been detected in soil gas above the sanitary sewer line that leads from the former location of the dry 

cleaner within Building 7, with the highest concentrations detected at locations closest to Building 7 (Refs. 12, 

pp. 6-7, 13-16; 13, pp. 4, 6, 7, 9, 14). The presence of PCE in soil gas confirms that the soil has been impacted 

by PCE.

Employees of the SLCDPU documented observations of discolored water and odors of dry cleaner solvent at 

various dates in the early 1980’s while cleaning the sanitary sewer line that leads from Building 7 (Ref. 14). A

video survey of sections of the sewer lines between Building 7 and Sunnyside Avenue was conducted on 

December 17, 2003 by the SLCDPU (Ref. 15). This survey documented numerous defects in most of the 

sewer line sections, including cracks, root penetrations, offsets, and a pipe sag, as well as evidence of historic 

breaks, repairs and replacements of the clay pipe (Ref. 15). Waste water, free-phase solvent, and solvent 

vapors can leak from sewer lines through cracks, joints or breaks (Refs. 10, p. 16; 32, pp. 3-4; 33, pp. 4-5).

There is no liner situated between the sewer line and the underlying in-situ soils (Ref. 31).

Soil gas above the sanitary sewer line was sampled for PCE in 1996 and again in 2006 (Refs. 12, 13). Despite 

the tests being conducted at least 12 and 22 years, respectively, after the dry cleaner was removed from service, 

and that PCE vapors tend to sink rather than rise through soil (Ref. 32, p. 6), PCE was detected in soil gas at 
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some locations above the sanitary sewer line. The highest concentrations were detected at locations closest to 

Building 7 (Refs. 12, pp. 6, 7, 13-16; 13, pp. 4, 6, 7, 9, 14). 

The source area (i.e. the site of the historic disposal at the dry cleaner) is located on the western edge of the 

primary recharge area, where there are no continuous layers of fine-grained material to impede the downward 

movement of water to the principal aquifer (Refs. 20, pp. 40-57; 38, p. 7; 41, pp. 5, 8; 42, pp. 4, 5). The 

springs are located in the secondary recharge area where confining layers are thin and discontinuous (Refs. 24, 

p. 1; 38, pp. 7, 9, 10). All areas of the site, in particular the source area, are underlain by the principal aquifer 

as the ground water beneath the site is interconnected with the principal aquifer; there are no continuous layers 

of fine-grained material to impede flow (Refs. 20, pp. 40-57; 24, p. 1; 38, pp. 7, 9, 10).

PCE is very mobile, with relatively low solubility and vapor pressure (Refs. 32, p.5; 48, p. 4). Once it enters 

the soil vadose zone (the unsaturated zone), PCE travels downward to ground water (Ref. 32, p. 4). In its 

liquid state, PCE is heavier and less viscous than water and will sink through it (Ref. 32, pp. 5, 6). When PCE 

encounters an aquitard (i.e. a layer of clay that creates a perched zone) that is discontinuous (e.g. such as those 

beneath the site) it is able to flow around the sides of the discontinuous layer in all directions, including in the 

upgradient direction (depending upon the flow gradient and the topography of the layer) (Ref. 17, pp. 2, 3). 

Ground water and springs downgradient of Building 7 and the sanitary sewer line contain PCE at 

concentrations significantly above background levels (Refs. 20, p. 13, 25, 27, 67, 69, 79; 21, pp. 6, 11, 15; 22, 

pp. 18, 45, 47; 23, pp. 6, 38, 40, 42, 48; 24, pp. 5-33; 25, pp. 2-5; 26, p. 17, 19; 27, pp. 2-4, 7, 10, 13, 18, 21, 

24, 29, 32, 35, 38, 41, 44; 28, pp. 6, 8, 9, 14, 16, 18, 19, 27, 28, 29, 33, 35-37, 58, 73, 79, 83, 85, 103, 105, 

142; 29, pp. 18-22). Ground water collected from the well EPA-MW-05 located immediately upgradient of the 

former dry cleaner location is not contaminated with PCE (Refs. 23, pp. 1, 3, 4, 6, 31, 32, 35, 49, 50, 64-66; 

26, pp. 1-7, 16, 17, 27, 58; 28, pp. 15, 25, 33, 35, 81). The well EPA-MW-01D is contaminated with PCE and 

is located directly downgradient of the source (Refs. 23, pp. 37, 38, 64; 28, pp. 14, 15, 19, 27, 29, 33, 35, 139). 

A hydraulic connection between EPA-MW-01D and the municipal well SLCWS Well #18 has been 

established through aquifer testing (Ref. 29, p. 30).

In 2012, the EPA engaged Toeroek Associates, Inc. (Toeroek) to conduct a survey of businesses or facilities 

that have operated in the area of the site (Ref. 6, p. 1). The purpose of the survey was to identify any current or 

historic businesses or facilities in the area that may be of potential environmental concern (Ref. 6, pp. 1-3). 

The area searched included a one mile buffer around the current known extent of PCE contamination in ground 

water (Ref. 6, pp. 1, 59, 60). In addition to businesses known to use PCE (e.g. dry cleaners), any business that 

had the potential to handle and/or release wastes into the environment (as identified based on Standard 

Industrial Classification (SIC) codes) was listed in the search results as a business ‘...with potential to impact 

the site plume’ (Ref. 6, p. 3). These businesses were not limited to those that used chlorinated solvents, let 

alone PCE (Ref. 6, p. 3). A separate database (Environmental Data Resources, Inc. [EDR]) that compiles

regulatory listings and violations (such as from the CERCLIS and Resource Conservation and Recovery Act 

(RCRA) databases) was also searched in order to identify business that potentially used, generated, or received 

PCE specifically; or used PCE in their products (Ref. 6, p. 3). Businesses such as dry cleaners and auto repair 

facilities that were deemed to have used chlorinated solvents and parts cleaners were also identified from this 

database as potential contributors to the contamination (Ref. 6, p. 3). Relevant businesses were linked to 

addresses through Salt Lake County parcel data and plotted on maps (Ref. 6, pp. 3, 59, 60). 

Toeroek subsequently performed additional research (e.g. of the UDEQ LUST and UST databases) on a 

smaller number (40) of facilities located in or within close proximity to the contamination, or upgradient of the 

contamination, an attempt to obtain more detailed information about the facilities’ operations and waste 

streams (Ref. 6, pp. 30-58). 
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The VA Medical Center is identified as Map ID # 19 in the report, and the location of the former VA Medical 

Center dry cleaner is denoted on the reports figures by a blue star (Ref. 6, pp. 9, 36, 49, 59, 60). The former 

name of the site itself, the ‘Mount Olivet Cemetary [sic] Plume’ is shown as Map ID #1 (Ref. 6, pp. 5, 59, 60).

The results of the survey indicated that no relevant businesses or facilities of potential environmental concern 

exist between the former dry cleaner at the VA Medical Center Building 7 and the downgradient contaminated 

wells EPA-MW-02, EPA-MW-04, EPA-MW-03, EPA-MW-01D and EPA-MW-01S (Ref. 6, pp. 59, 60). In 

addition, no dry cleaners were identified upgradient of Building 7 and the sewer line (Ref. 6, pp. 59, 60). 

Businesses or facilities located upgradient of Building 7 and the sewer line

Eleven businesses or facilities located between 0.5 and 1 miles upgradient of Building 7 were identified as 

being of potential environmental concern (Map ID #’s 34, 35, 64, 65, 66, 67, 68, 69, 70, 118, 119) (Ref. 6, pp. 

12, 18-20, 35, 37-39, 42, 51, 54-60). Of these eleven, eight of the businesses (Map ID #’s 34, 64, 65, 66, 67, 

68, 118 and 119) were listed in the search results based on SIC codes (Ref. 6, pp. 8, 18, 19, 35, 37-39, 50, 54-

56, 58-60). Upon further research, all eight of these businesses were considered to be unlikely sources of 

contamination (Ref. 6, pp. 35, 37-39, 50, 54-56, 58).

The remaining three (Map ID #’s 35, 69 and 70) were included based on regulatory listings and are discussed 

in further detail below (Ref. 6, pp. 3,12, 19, 20, 37, 42). 

The Underground Storage Tank (UST) Branch of the UDEQ has records concerning the suspected release of 

diesel from a UST located at the University of Utah Heartport Research Center (Ref. 34, pp. 12-13). The 

University was required to conduct an investigation of the suspected release (Ref. 6, p. 13). Upon review of 

the information submitted by the University to the UDEQ, the UDEQ issued a letter stating that any detected 

petroleum contamination at the site was not a threat to human health or the environment and recommended that 

no further action be taken (Ref. 34, p. 12). No records of the tank also holding PCE or solvents were located in 

UDEQ records. 

University of Utah Heartport Center (Map ID # 35) (Refs. 6, pp. 12, 37, 51, 59, 60; 34, pp. 12, 13)

The University of Utah acquired land from the Fort Douglas Military Reservation beginning in 1948 (Ref. 61, 

p. 7). Building 515 was used by the University as a hazardous waste storage area between 1980 and 1993 

(Ref. 61, p. 7). 

University of Utah Building 515 (formerly the Fort Douglas Military Reservation) (Map ID #’s 69, 70) (Refs. 

6, pp. 19, 20, 42, 57, 59, 60; 34, pp. 1, 2, 5; 61, pp. 1, 7)

During a soil gas investigation conducted by EPA START in November, 1996, PCE contamination was noted 

in a soil gas sample collected from near Building 515 (Ref. 13, pp. 3, 4, 6, 7, 14). Due to the limited scope of 

the investigation, the UDEQ performed additional soil gas sampling in July and August, 2001 (Ref. 61, p. 5). 

Ground water sampling was not performed (Ref. 61, p. 13). The results of this subsequent investigation 

showed the presence of various VOCs, including PCE, at numerous sampling locations around the building 

(Ref. 61, pp. 13-15, 25-39). 1,1,1-Trichloroethane (TCA) was the most widespread contaminant found (Ref. 

61, p. 13). 

The location of Building 515 is approximately one mile up-gradient of the VA Medical Center Building 7

(Refs. 13, p. 6; 61. P. 16). Although this study did not collect ground water samples, it is concluded in the 

report that the analytical results from the soil gas sampling indicate the presence of chlorinated solvents in 

ground water (Ref. 61, p. 15). Nevertheless, the permanent ground water monitoring well EPA-MW-05, being 

situated between Building 515 and the VA Medical Center (and immediately upgradient from Building 7), and 

having always shown an absence of PCE contamination, eliminates Building 515 as a potential source of PCE 
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to the contaminated ground water documented immediately downgradient of the VA Medical Center Building 

7 (Figure 3, Refs. 23, pp. 1, 3, 4, 6, 31, 32, 35, 49, 50, 64-66; 26, pp. 1-7, 16, 17, 27, 58; 28, pp. 15, 25, 33, 

35, 81). In addition, if contaminated ground water from beneath Building 515 was present and has travelled as 

far as SLC Well #18 (whether under natural gradient or by being pulled into the well during pumping, or both), 

PCE should be detectable in the well on a more continuous basis. Rather, PCE has only been detected in the 

well after continued pumping, which ground water modeling has shown is due to the well pulling 

contamination cross-gradient from the site (Refs. 25, pp. 1-7; 29, pp. 20-22, 28, 33).

The UST Branch of the UDEQ has a number of records concerning releases from various USTs on other parts 

of the Fort Douglas facility (Ref. 34, pp. 1-8, 35). The records indicate the closure of a number of tanks 

containing gasoline, diesel, heating oil or kerosene, and waste oil and that releases of gasoline, diesel and waste 

oil had occurred (Ref. 34, pp. 3, 6, 7). No record of any of the tanks holding PCE or solvents were located in 

UDEQ records. Following various clean up and removal actions for the releases, the UDEQ issued letters 

determining that no further action was needed at each release site in 1992, 1994, and 2002 (Ref. 34, pp.1, 2, 5, 

8).

In addition to the dry-cleaning facility, the VA Medical Center has also maintained a clinical laboratory, boiler 

plant building, and a plant maintenance building that reportedly use solvents in small quantities to support 

regular operations (Ref. 8, pp. 2-3). It has been reported that the clinical laboratory used xylene for tissue 

processing and, as of 2005, recycled approximately 1 gallon of xylene per month (Ref. 8, p. 2). As of 2005, 

the Maintenance and Operations staff stored approximately 30 gallons of various solvents. Most solvent was 

recycled, and if any was unable to be recycled it was disposed of as hazardous waste (Ref. 8, p. 2). These other 

potential sources of PCE contamination located on the VA Medical Center have been eliminated as viable 

sources for the PCE contamination due to the reported small quantities of solvent used (particularly in 

comparison to the quantity of PCE stored for the dry-cleaning operation), the apparent high recycle and 

appropriate disposal rates, and that, given there were a variety of solvents used, that PCE (if used at all) likely 

only made up a smaller overall proportion of this small quantity.

Other activities associated with the VA Medical Center (Map ID # 19) (Refs. 6, pp. 59, 60; 8, pp. 2-3; 34, pp. 

9-11, 35).

The Underground Storage Tank (UST) Branch of the UDEQ has records concerning the closure of six USTs 

from VA Medical Center Building 6 (located west and adjacent to Building 7) in 1993 (Ref. 34, pp. 9-11, 35). 

The USTs held fuel oil, diesel and gasoline (Ref. 34, p. 11). No record of the tanks having held PCE or other 

solvents were located in UDEQ records. Soil contaminated with diesel-range total petroleum hydrocarbons 

was noted during the removal and approximately 57 tons of soil were removed as part of the UST closure (Ref. 

34, p. 10). On November 7, 1994, the UDEQ issued a letter to the VA Medical Center recommending that no 

further action was required at the release site (Ref. 34, p. 9).

Businesses or facilities located downgradient of Building 7 and the sewer line, but proximate to the area of 

highest concentrations of PCE in ground water

The Toeroek research also identified six businesses or facilities located downgradient of Building 7 and the 

sewer line, but proximate to the area of highest concentrations of PCE in ground water (Map ID #’s 1, 2, 3, 16, 

17, 18) (Ref. 6, pp. 5, 30-32, 39, 43, 59-60). Given their location downgradient of the source area of the site 

(and the contamination noted in monitoring well EPA-MW-02), none of these businesses or facilities is 

considered to be the primary source of contamination at the site. However, given their location proximate to 

the area of highest PCE concentrations in ground water found at the site, further discussion of these businesses 

or facilities is warranted (Ref. 6, pp. 59, 60). 
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As noted above, Map ID #1 is the site itself, as identified by a previous name (the ‘Mount Olivet Cemetary 

[sic] Plume’) within CERLCIS (Ref. 6, pp. 5, 59, 60). 

Mount Olivet Cemetary [sic] Plume (Map ID #1, Ref. 6, pp. 5, 59, 60).

Map ID #2 is the United States Department of Agriculture (USDA) Forest Service, Interagency Fire Center. 

This was a heliport and vehicle fueling facility run by the Forest Service (Refs. 6, pp. 5, 39, 43, 59, 60; 34, pp. 

20-23). The Forest Service operated three USTs at the site, two containing gasoline and one containing 

aviation gasoline (Refs. 6, pp. 5, 39, 43, 59, 60; 34, pp. 20-23). All three tanks were closed in the early 1990’s 

(Ref. 34, pp. 20-23). While no correspondence between UDEQ and the Forest Service regarding further action 

at the site was found, given the contents of the tanks (petroleum products, not solvents), it is not considered 

that this facility is a likely contributor to the PCE contamination in ground water. According to Toeroek, no 

information suggesting that activities such as heavy machinery repair or engine rebuilding occurred at the 

facility was found (Ref. 6, pp. 39, 43).

United States Department of Agriculture (USDA) Forest Service, Interagency Fire Center (Map ID #2, Refs. 6, 

pp. 5, 39, 43; 34, pp. 20-23).

The Organizational Maintenance Shop 5 (OMS-5) Motor Pool (Map ID# 3) and Combined Support 

Maintenance Shop (CSMS) were both situated on Utah Army National Guard property located along 

Guardsman Way (Ref. 6, pp. 59, 60). The address for OMS-5 has been variously recorded as 720 Guardsman 

Way, 780 Guardsman Way and 1543 Sunnyside Avenue (Refs. 6, pp. 5, 32; 34, p. 15) and the address for the 

CSMS is recorded as 580 Guardsman Way (Ref. 6, p. 39). These shops were initially considered the likely 

source of the PCE contamination first discovered in the Mount Olivet irrigation well (Refs. 18, p. 4; 19, p. 4). 

While various solvents were used at the shops, including Stoddard’s solvent (which according to the UANG 

did not contain PCE) and Safety Kleen 105 (which could have contained up to 0.5% PCE (Ref. 35, pp. 8, 12)), 

subsequent investigation determined that PCE-contaminated ground water was also located upgradient of the 

UANG property (in the direction of the VA Medical Center) (Refs. 20; 23). 

Utah Army National Guard (UANG) (Map IDs #3 and #18, Refs. 6, pp. 5, 8, 32, 39, 43, 49, 59, 60; 19, p. 4; 

34, pp. 35).

 

Waste solvents at the UANG property were stored in tanks located on site (Ref. 35, pp. 8, 9, 12). According

to the UANG, the Stoddard’s solvent was recycled by filtering and reuse (Ref. 35, p. 12). Beginning in the 

mid- to late 1980’s, the UANG enlisted the Safety Kleen Corporation to provide solvent recycling services 

(Ref. 35, pp. 8, 12).

The UST Branch of the UDEQ has a number of records concerning a diesel release from a UST at the OMS-5 

shop (Ref. 34, pp. 15-19). In 1992, following a removal action to excavate petroleum-contaminated soil, the 

UDEQ issued a letter determining that no further action at the release site was needed (Ref. 34, p. 15).

Given that waste solvent used on the UANG property was apparently stored in tanks and recycled either on 

(prior to 1984) or off site, as opposed to being disposed of into the sanitary sewer as has been documented at

the VA Medical Center, and that PCE-contaminated ground water has been identified upgradient of the 

property, the UANG shops are not considered the primary source of the PCE contamination documented at the 

site. 

Toeroek identified an historic ‘carpet and furniture cleaner’ facility (Map ID #16) at 923 Greenwood Terrace, 

approximately 1⁄2 mile southwest of Building 7 (Ref. 6, pp. 8, 41, 48, 59, 60). Toeroek did not specify whether 

or not dry cleaning with PCE occurred at the location. This address is outside of the known extent of ground 

water contamination and is approximately 1,000 feet downgradient, and 1,600 feet cross-gradient from the 

Carpet and Furniture Cleaner (Map ID# 16) (Ref. 6, pp. 8, 41, 48, 59, 60).
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UTD981548985 45

contamination noted in monitoring well EPA-MW-02 (Ref. 6, p. 60). Given its location, it is not considered 

likely that this facility is the primary source of the PCE contamination documented at the site. 

Map ID # 17 has been identified as a mistaken listing within the CERCLIS database. According to Toeroek,

this site was used as a place to dump grass cuttings, trees, and shrubs from the nearby cemetery (Mount 

Olivet). 

Old Dump/ Fill at 800 S Sunnyside Avenue (Map ID #17) (Ref. 6, pp. 8, 39, 49, 59, 60).

The Sugar House Park Plume (UT0000987776) is a separate area of ground water contaminated with PCE that 

has been identified within the TDL of site (Ref. 36). Discovered in the late 1980’s, the Sugar House Park 

Plume is located in a mixed commercial and residential area approximately 2.25 miles south of the 700 South 

1600 East PCE Plume site, at an elevation of approximately 4,430 feet amsl (Ref. 36, pp. 6, 9). As of 2009, 

the source of the contamination had not been identified (Ref. 36, p. 5). Ground water flow direction in the area 

of the Sugar House Park site is towards the west-southwest (Ref. 36, pp. 8, 9). As this site is cross-gradient 

from the contamination at the 700 South 1600 East PCE Plume, and the Sugar House Park site is located over 

200 feet lower in elevation than the 700 South 1600 East site, it is considered that the PCE contamination at 

the two sites is not related (Ref. 36, pp. 6, 8, 9).

Other PCE ground water contamination within in the TDL

3.2 WASTE CHARACTERISTICS (Ref. 1, p. 51601) 

3.2.1 TOXICITY/MOBILITY (Ref. 1, p. 51601) 

TABLE 11: Ground Water Toxicity/Mobility

Hazardous 

Substance

Source 

No.

Toxicity 

Factor 

Value

Mobility 

Factor 

Value

Does Hazardous 

Substance Meet 

Observed Release? 

(Yes/No)

Toxicity/

Mobility

(Ref. 1, 

Table 3-9)

References

PCE 1 100 1 Yes 100 2, p. 2

Toxicity/Mobility Factor Value: 100 

(Ref. 1, Section 3.2.1.3) 
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3.2.2 HAZARDOUS WASTE QUANTITY (Ref. 1, p. 51602)

TABLE 12: Hazardous Waste Quantity

Source Source Type Source Hazardous Waste Quantity 

 (Ref. 1, Section 2.4.2.1.2) 

Disposal of PCE to sewer Other Undetermined, but greater than zero

The hazardous constituent quantity for the source has not been adequately determined. The hazardous waste 

quantity is undetermined, but greater than zero. According to Section 2.4.2.2 of the HRS (Ref. 1, p. 51592), if 

any target for the migration pathway under consideration is subject to Level I (or Level II) concentrations, 

assign either the value from Table 2-6 (Ref. 1, p. 51591) or a value of 100, whichever is greater, as the 

hazardous waste quantity factor value for that pathway. Because Level II concentrations are present in a 

drinking water well at the site, a hazardous waste quantity factor value of 100 is assigned.

Hazardous Waste Quantity Factor Value: 100 

(Ref. 1, Table 2-6, p. 51591) 

3.2.3 WASTE CHARACTERISTICS FACTOR CATEGORY VALUE (Ref. 1, pp. 51592, 51602) 

Toxicity/Mobility Factor Value: 100

Hazardous Waste Quantity Factor Value: 100

Toxicity/Mobility Factor Value X Hazardous Waste Quantity Factor Value: 10,000

Waste Characteristics Factor Category Value: 10 

(Ref. 1, Table 2-7, p. 51592) 

3.3 TARGETS (Ref. 1, p. 51602)

The municipal water supply system in Salt Lake City is one of the most complex in the world (Ref. 49, p. 1). 

According to UDEQ Division of Drinking Water (UDDW) records, there are 30 active community water 

systems in Salt Lake County, serving system populations that range from 50 to 915,500 persons through the 

use of 185 active drinking water points of diversion (wells, springs, surface water intakes, and water purchased 

from other systems) (Ref. 52, pp. 2-5). This number does not include inactive systems, or systems serving noncommunity or non-transient populations such as school, churches, or industries. Nor does it include individual 

wells and springs that serve individual residences. The Utah Division of Water Rights (UDWR) database, 

which contains both drinking and non-drinking water sources, has records for nearly 1,500 domestic and 

municipal wells within 4 miles of the site (Ref. 52, p. 6). 

According to the most current records from the UDDW, there are six municipal water systems that have wells 

within the 4-mile radius TDL (as measured from the source area at the VA Medical Center) (Ref. 52, pp. 7, 8).

Of these six systems, four serve less than 60 people, are considered ‘inactive’, do not have water use records in 

the UDWR database, and/or are not located within the primary aquifer (Ref. 52, p. 8). One of these ‘inactive’ 

water systems, the ‘Eighth South Well’, is an artesian well that supplies a public drinking fountain; a transient 

source that is not used for scoring purposes (Ref. 52, p. 8). Given the lack of water use data, that the wells 

from these four systems would only be scored on potential contamination and would not contribute 

significantly to the overall site score, these four water systems will not be considered further. 
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The two remaining municipal water systems that have wells within the TDL are the Salt Lake City Water 

System (SLCWS) and the South Salt Lake City Water System (S-SLCWS). The SLCWS is the water utility 

within the Salt Lake City Department of Public Utilities (SLCDPU) and currently serves approximately 

400,000 persons (Refs. 46; 49, p. 1; 52, pp. 4, 8, 10, 11). SLCWS Well #18 belongs to the SLCWS and is the 

only well subject to actual contamination (Level II) (Refs. 29, p. 1; 46). The S-SLCWS currently serves 

approximately 18,000 persons (through approximately 3,300 connections (Refs. 52, pp. 5, 8, 68; 53, p. 2). 

The SLCWS utilizes approximately 42 different sources, although the input from each source into the water 

system can vary greatly by year or season, with surface water intakes generally providing more water during 

spring runoff and wells contributing more to the systems during the summer months (e.g. Ref. 52, pp. 15, 28, 

37). No one source supplies greater than 40% of the municipal supply in any typical year and water in the 

system is blended (Refs. 46; 49, p. 1; 50, pp. 3, 4; 52, pp. 10, 11, 68). The S-SLCWS is much simpler, with 

produced water being supplied by three wells, and purchased water being acquired from one source (Refs. 52, 

pp. 5, 67-82; 53, p. 2). All of the water supplied by the three wells along with the purchased water is blended 

during distribution (Ref. 63, p. 1). 

As some governmental records are unavailable or incomplete, particularly for the S-SLCWS, a variety of 

references, including data from the UDWR, the UDDW, the City of South Salt Lake, and the Salt Lake City 

Department of Public Utilities, have been used to produce a best estimate of the population served by target 

wells for the principal aquifer. The latest fiscal year that well production data is available for the Salt Lake 

City Water System is 2011, and for the South Salt Lake City Water System is 2010 (Ref. 52).

Salt Lake City Water System (SLCWS) 

The SLCWS currently serves approximately 400,000 persons (Refs. 49, p. 1; 52, p. 4, 8, 10, 11). The figure 

presented by the UDDW, 387,506 persons, will be used as it is the minimum number (Ref. 52, pp. 4, 8, 10, 

11). For HRS scoring purposes, the population served by the SLCWS in 2004 must be identified in order to 

determine the Level II population value for SLCWS Well #18, which was shut down due to site related PCE 

contamination in October 2004 (Refs. 23, pp. 6, 47, 64; 29, p. 41; 40, p. 9; 46; 52, p. 42). However, the most 

current available population data will be used in order to score the remaining wells subject to potential 

contamination.

According to records from the UDDW, in 2004, the SLCWS sourced water from three surface water intakes on 

Wasatch Front creeks(Big Cottonwood Creek, Parleys Creek, and City Creek), approximately 20 deep ground 

water wells, at least four springs, and from the Metropolitan Water District, which at that time received all of 

its water from the Deer Creek Reservoir on the Provo River (Refs. 50, p. 2; 52, pp. 10-66). [Note that 

Reference 52 pages 2-5 show system facilities (wells, springs, intakes) for water systems in Salt Lake County 

and does not include system facilities located outside the County. Reference 52, pages 10 and 11 show all 

system facilities, regardless of their location]. According to the SLCDPU, the approximate breakdown of 

water supply sources for the SLCWS in 2004 was: surface water intakes on Wasatch Front creeks = 51%; base 

wells (i.e. flowing artesian wells) and springs = 8.8%; peaking well (standby wells pumped on an as-needed 

basis, usually in the summer (e.g. SLCWS Well #18) = 12.7%; and water sourced from the Metropolitan Water 

District (i.e. the Deer Creek Reservoir) = 27.5% (Ref. 50, p. 3). 

Actual contamination well

Similar percentages are found for different years in other references (Refs. 49, p. 1; 55, p. 2). Although the 

input from each source into the system can vary greatly by year or season, in a typical year, no one source 

supplies greater than 40% of the municipal supply in any one year (Refs. 46; 49, p. 1; 50, pp. 3, 4; 52, pp. 10-

66). It should be noted however, that in fiscal year 2011, the Big Cottonwood Creek intake supplied 
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approximately 42,517.6 acre feet or 46% of the total water in the SLCWS (Ref. 52, pp. 10, 11, 15). However, 

according to records collected since 1979, this source typically supplies an average of less than 24,000 acre feet 

(Ref. 52, p. 15). Given this anomalous contribution (e.g. its contribution for calendar year 2011 was 

approximately 33% of that for calendar year 2010), and the fact that the HRS specifies to use the “average 

annual pumpage or capacity,” for HRS scoring purposes this source is not considered to supply > 40% (Refs. 

1, p. 51603; 52, p. 15). 

Specific data on the number of persons served in 2004 could not be found, but would be expected to be only 

slightly lower than the 2010 data presented in References 49 and 52, as the population of Salt Lake City only 

increased 1.9% from 2000 to 2010 (Ref. 54, p. 2). To reflect a minimum possible number, the estimated 

population served by the system in 2000 (using the UDDW data) will be used for the 2004 estimated

population served: [387,506 persons - (387,506 persons x 0.019)] = 380,143 persons served)] (Refs. 52, pp. 4, 

8, 10, 11; 54, p. 2). 

Available records from the UDWR for 2004 are not complete, but show a similar breakdown of source supply

as in 2010: surface water intakes on Wasatch Front creeks = 59.6%; wells = 12%; springs = 4.6%; and water 

sourced from the Metropolitan Water District (i.e. the Deer Creek Reservoir) = 23.9% (Refs. 50, p. 3; 52, pp. 

8, 10, 13). No one source supplied greater than 40% of all water in the SLCWS in 2004 (Refs. 46; 52, pp. 10, 

11). The largest source was Parley’s intake, which supplied 31.3 % (Ref. 52, pp. 10, 11, 18, 19).

In 2004, there were approximately 42 individual sources of drinking water in the SLCWS listed as ‘active’ 

(Ref. 52, pp. 10, 11). The actual number of actively contributing source of water is likely lower than this, as 

source use records are missing or not complete for some of these sources, and at least a few appear to be 

abandoned (Ref. 52, pp. 10-66). The input from each source into the system can vary greatly by year or 

season, although no one source supplied greater than 40% of the municipal supply in 2004 (Refs. 46; 49, p. 1; 

50, pp. 3, 4; 52, pp. 15, 28, 37). In order to reflect the minimum possible number, it will be assumed that all 

42 individual sources are active each year, including in 2004. 

As no one source supplied greater than 40% of the supply in 2004 to the SLCWS and the sources were blended 

(Refs. 46; 52, pp. 10, 11), according to Section 3.3.2 of the HRS, it is assumed that each source in the water 

system contributes equally to the system and population served by the system is apportioned equally among the 

sources (Ref. 1, p. 51603). The estimated population served by SLCWS in 2004 was 380,143 (Refs. 52, pp. 4, 

8, 10, 11; 54, p. 2). Therefore, the population served by SLCWS Well #18 in 2004, and subject to actual 

(Level II) contamination was 9,051 persons (380,143 / 42 = 9,051).

Potential contamination wells

There are three SLCWS wells subject to potential contamination. Two of these wells, the 4th Avenue Well and

the 13th East Well, were active in fiscal year 2011 (Ref. 52, pp. 10, 11, 37, 45). A third well, the 1900 East 

2700 S Well, was not active in 2011 (Refs. 51; 52, pp. 7, 8, 10, 48). These wells are standby wells that are 

maintained on a regular basis (Refs. 1, p. 51603; 52, pp. 37-42, 45-50). These wells will be scored using 

current population numbers. All three wells are located within 2 to 3 mile target distance category of the 4-

Mile TDL. 

In a typical year, no one source supplies greater than 40% of the municipal supply in any one year (Refs. 46; 

49, p. 1; 50, pp. 3, 4; 52, pp. 10-66). However, in fiscal year 2011, the Big Cottonwood Creek intake supplied 

approximately 42,517.6 acre feet or 46% of the total water in the SLCWS (Ref. 52, pp. 10, 11, 15). However, 

according to records collected since 1979, this source typically supplies an average of less than 24,000 acre feet 

(Ref. 52, p. 15). Given this anomalous contribution (e.g. its contribution for calendar year 2011 was 

approximately 33% of that for calendar year 2010), and the fact that the HRS specifies to use the “average 
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700 South 1600 East PCE Plume

UTD981548985 49

annual pumpage or capacity,” for HRS scoring purposes this source is not considered to supply > 40% (Refs. 

1, p. 51603; 52, p. 15). The population currently served by SLCWS is 387,506 persons (Ref. 52, p. 4, 10, 11). 

In 2011, there were approximately 42 individual sources of drinking water in the SLCWS listed as ‘active’ 

(Ref. 52, pp. 10, 11). The actual number of actively contributing source of water is likely lower than this, as 

source use records are missing or not complete for some of these sources, and at least a few appear to be 

abandoned (Ref. 52, pp. 10-66). In order to estimate the minimum population, it will be assumed that all 42 

individual sources are active each year, including in 2011.Therefore, the population served by each well is

9,226 (387,506 / 42 = 9,226). 

South Salt Lake City Water System (S-SLCWS) 

The proportion of water produced and purchased by the City of South Salt Lake varies significantly year to 

year (Ref. 53, p. 2). For fiscal year 2010 (12 months ending June 30, 2010, the latest complete fiscal year for 

which well production water is available from the UDWR) the S-SLCWS supplied 958 million gallons of 

water (approximately 2,940 acre feet) to 3,323 service connections serving approximately 18,000 people (Refs. 

52, p. 5, 67, 68; 53, pp. 2). Of this total, the City of South Salt Lake purchased 297 million gallons of water 

(31 percent (%) or 911.5 acre feet) of its water from the Jordan Valley Water Conservancy District and 

produced 661 million gallons (69 % or 2,028.5 acre feet) of its own water (Ref. 53, p. 2). According to records 

from the UDWR, in fiscal year 2010 (the latest fiscal year for which S-SLCWS well production data from 

UDWR is available) the S-SLCWS produced water from three wells: the 300 East Replacement well (945.5 

acre feet), the 700 East Replacement well (224.7 acre feet), and the Davis Replacement well (843.8 acre feet); 

totaling 2,014 acre feet (Ref. 52, pp. 5, 67, 68, 71, 75, 80, 81). [Note that Ref. 53 states a similar total of 

2,028.5 acre feet of water was contributed from wells. The figure of 2,014 acre feet is used as it taken from 

UDWR records which are considered more accurate]. The Davis Replacement well is used year-round, while 

the 300 East Replacement well and the 700 East Replacement well are currently both standby wells that are 

maintained on a regular basis (Refs. 1, p. 51603; 52, pp. 5, 67, 68, 71, 75, 80, 81).

The Jordan Valley Water Conservancy District sources the majority of its water from numerous surface water 

sources, including the Provo River and its tributaries, several mountain lakes, and two reservoirs (Ref. 62, p. 

1). The majority of this water is treated at the Jordan Valley Water Treatment Plant (i.e. blended), which then 

supplies 90% of all water delivered by the JVWCD (Ref. 62, p. 1). 

As the water purchased by the S-SLCWS from the JVWCD can be considered as coming from one source (a 

single main), the contribution of each S-SLCWS source to the system is therefore: water purchased from the 

Jordan Valley Water Treatment Plant = 31.0%, 300 East Replacement Well = 32.2%, 700 East Replacement 

Well = 7.6% and the Davis Replacement Well = 28.7% (Ref. 52, pp. 5, 67, 68, 71, 75, 80, 81; Ref. 63). All 

water produced by the three wells and purchased from the JVWCD is blended during distribution (Ref. 63, p. 

1). As no one source supplies greater than 40% of the supply in any one year to the S-SLCWS, according to 

Section 3.3.2 of the HRS, it is assumed that each source contributes equally to the system and population 

served by each source is apportioned equally (Ref. 1, p. 51603).

Only the S-SLCWS 300 East Replacement Well falls within the TDL, lying within the 3-4 mile target distance 

category (Refs. 51; 52, pp. 11, 12, 16). This well will be scored on potential contamination using current 

population estimates. As the population of 18,000 served by the S-SLCWS is to be apportioned equally 

between all four sources, this well is considered to supply water to approximately 4,500 persons (18,000 / 4 = 

4,500) (Ref. 1, p. 51603).
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UTD981548985 50

TABLE 13: Municipal Drinking Water Wells in the Principal Aquifer within a 4-Mile Radius of the 

VA Medical Center Dry Cleaner

Well ID

Perforated

Interval

(feet amsl)

Distance 

From 

Source

Level I 

Cont. 

(Y/N)

Level II 

Cont. 

(Y/N)

Pot. 

Cont. 

(Y/N)

Population 

Served

References

SLCWS Well #18

(aka 15th East Well 

or 500 South Well)

4,448 – 4,204 1/4-1/2 mile N 

Y 

(Level II)

N 9,051

29, pp. 24;

51; 40, pp. 1, 

9; 52, pp. 10, 

11, 40-42

SLCWS 4th Ave 

Well 4,272 – 4,014 2- 3 miles N N Y 9,226

51; 52, pp. 4, 

10, 11, 37-39

SLCWS 13th East 

Well 4,249 – 3,919 2- 3 miles N N Y 9,226

51; 52, pp. 

10, 11, 45-47

SLCWS 1900 E 

2700 S Well

4,193 – 3,984

(Est.)

2- 3 miles N N Y 9,226

51; 52, pp. 

10, 11, 48-50

S-SLCWS 300 E. 

Replacement Well 3,660 – 3,270 3- 4 miles N N Y 4,500

51; 52, pp. 

68, 75-79

Notes:

Est. Estimated (not recorded on drill log)

3.3.1 NEAREST WELL (Ref. 1, pp. 51602, 51603) 

Concentrations of PCE meeting the observed release criteria found in HRS Table 2-3 have been detected in 

SLCWS Well #18 (Refs. 1, p. 51603; 23, pp. 48, 64; 25, pp. 4, 5). The highest PCE concentrations recorded

in this well have been less than 3 μg/L (Refs. 23, pp. 47, 48, 64; 29, p. 9). As this is below the applicable 

health-based benchmark for drinking water (the MCL, which is 5.0 μg/L), this well is considered to be subject 

to Level II concentrations (Ref. 1, p.51592). In accordance with Table 3-10 and 3-11 within Section 3.3.1 of 

the HRS, a Nearest Well Factor Value of 45 has been assigned (Ref. 1, p. 51603). 

Well ID: SLCWS Well #18 (aka 15th East Well or 500 South Well) 

Level of Contamination (I, II, or potential): II 

If potential contamination, distance from source in miles: Not applicable

Nearest Well Factor Value: 45 

(Refs. 1, p. 51603 Table 3-11) 
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3.3.2 POPULATION (Ref. 1, p. 51603)

3.3.2.1 Level of Contamination (Ref. 1, p. 51603)

3.3.2.2 Level I Concentrations (Ref. 1, p. 51603) 

Not applicable as no Level I concentrations have been identified. 

Total Population Served by Level I Wells: NA 

 

Level I Concentrations Factor Value: 0 

3.3.2.3 Level II Concentrations (Ref. 1, p. 51603) 

Level II concentrations have been identified in SLCWS Well #18 (Refs. 23, pp. 6, 48, 64; 25, pp. 4, 5). The 

principal aquifer is highly transmissive and when Well #18 is pumped, it has sufficient capacity to alter the 

ground water flow regime in the area and draw the PCE contamination into the well (Ref. 29, pp. 19-21, 27, 

33, 46-48). When the well was shut off seasonally, the ground water flow regime returned to static conditions 

and ground water resumed its normal flow direction (to the southwest). 

In addition, when pumping SLCWS Well #18, a strong water level response has been noted within EPA-MW1D, a well 1,600 feet away and nearer to the source, indicating a hydraulic connection across this distance (Ref. 

29, p. 30). 

In October 2004, this municipal well was shut down due to PCE contamination (Refs. 46; 52, pp. 12, 13, 26). 

The assigned population value for actual contamination of ground water targets at Level II concentrations for 

the principal aquifer are presented in Table 14 below.

TABLE 14: Population Subject to Level II Concentrations

Level II Well Distance Category Population Assigned 

Population Value

References

SLCWS Well #18 Greater than 1/4 to 1/2 9,051 9,051 23, pp. 6, 48, 64; 25, 

pp. 4, 5; 29, pp. 19-21, 

27, 33, 46-48; 40, p. 1, 

9; 52, pp. 10, 11

Level II Concentrations Factor Value: 9,051

3.3.2.4 Potential Contamination (Ref. 1, p. 51603) 

Distance-weighted population values for potential contamination ground water targets for the principal aquifer 

are presented in Table 15. 

Ground water moves laterally from the unconfined part of the principal aquifer near the mountains (i.e. at the 

source area of the site) towards the confined part of the aquifer in the valley center (west of the site), therefore 

the two parts of the principal aquifer are interconnected (Refs. 38, p. 7, 9, 10; 41, p. 4, 5; 42, p. 3). The 

principal aquifer is highly transmissive and is an important source of drinking water for Salt Lake Valley, 
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UTD981548985 52

contributing water to about 38% of the population (Refs. 29, pp. 19-21; 38, pp. 7, 8; 41, p. 7; 42, p. 3). The 

Wasatch Mountains located to the north and east of the site form a bedrock aquifer that is different from the 

interconnected unconsolidated basin-fill sediments present in the valley. The principal aquifer present to the 

south and west of the Wasatch Mountains is continuous within the 4-mile radius of the source (Refs. 38, p. 7, 

9, 10; 41, p. 4, 5; 42, p. 3).

TABLE 15: Distance-Weighted Population Values for Potential Contamination Factor

Distance Category Population

Distance-Weighted 

Population Value

(Ref. 1, Table 3-12) References 

Greater than 0 to 1⁄4 mile 0 0 29, pp. 24; 51; 40, pp. 1, 9; 

52, pp. 10, 11, 40-42

Greater than 1⁄4 to 1⁄2 mile 0 0 51

Greater than 1⁄2 to 1 mile 0 0 51

Greater than 1 to 2 miles 0 0 51

Greater than 2 to 3 miles 27,678 2,122 51; 52, pp. 4, 10, 11, 37-39, 

45-50

Greater than 3 to 4 miles 4,500 417 51; 52, pp. 68, 75-79

Calculations (Ref. 1, Section 3.3.2.4, pp. 51603, 51604):

Sum of Distance-Weighted Population Values: 2,539

Sum of Distance-Weighted Population Values/10: 253.9, rounded to 254 

Potential Contamination Factor Value: 254

3.3.3 RESOURCES (Ref. 1, p. 51604) 

It is not known if any well within the four-mile radius is used for irrigation of commercial food or forage crops, 

or if any well may otherwise be considered a resource for scoring purposes.

Resources Factor Value: 0 

3.3.4 WELLHEAD PROTECTION AREA (Ref. 1, p. 51604) 

Wellhead Protection Areas (WPAs) were identified for two wells (Refs. 1, p. 51604; 56; 57). The UDEQ 

Division of Drinking Water has required public water systems to establish Drinking Water Source Protection 

(DWSP) areas under Rule R309-600 (Ref. 56, pp. 1, 2). Under this rule, DWSP plans were created for each 

ground water source of drinking water for each public water system in Salt Lake City (Ref. 56, p. 2). As part 

of each DWSP plan, four zones were delineated for management purposes: zone 1 is a 100 foot radius of the 

wellhead, zone 2 is the area within a 250-day ground water time-of-travel, zone 3 is the area within a 3-year 

ground water time-of-travel, and zone 4 is the area within a 15-year ground water time-of-travel (Ref. 56, p. 4). 
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UTD981548985 53

DWSP zone 4 for the “8th South Well” (aka 8th South artesian well) passes directly beneath the source, which 

has a containment factor of 10 (Refs. 52, pp. 68, 69; 57, pp. 1, 2). In addition, observed ground water PCE 

contamination has been detected within all four DWSP zones established for SLCWS Well #18 (Refs. 23, p. 

48, 64; 25, pp. 2-5; 29, pp. 18, 20-22; 57, pp. 1, 2). The SLCWS Well #18 is completed in the principal 

aquifer (Ref. 52, pp. 40-42). As the 8th South well is artesian and completed to a depth of 130 feet, it is likely 

also pulling water from the principal aquifer (Ref. 52, pp. 83-85).

As per Section 3.3.4 of the HRS, a Wellhead Protection Area Factor Value of 20 has been assigned for the 

principal aquifer (Ref. 1, p. 51604). 

Wellhead Protection Area Factor Value: 20