Technical Memorandum Environmental Resources Management · Environmental Resources Management 7272 E. Indian School Rd. ... (SAP) for each phase of ... An initial scoping meeting

Technical Memorandum

ERM US MAGNESIUM/0132320 – MARCH 2013

Environmental Resources Management

7272 E. Indian School Rd. Suite 100 Scottsdale, AZ 85251 (480) 998-2401 (480) 998-2106 (fax)

To: Ken Wangerud, USEPA

From: David Abranovic, ERM

CC: David Gibby, US Magnesium Kevin Lundmark, ERM Jill Quillin, ERM Sandra Mulhearn, ERM

Date: 8 March 2013

Subject: EPA-approved Summary of Phase 1A Scoping Discussions– US Magnesium Site, Tooele County, Utah

[EPA final notes/comments italicized]

EPA and ERM Project Coordinators agreed that given the extensive technical discussions which have occurred as follow-up to Scoping Meeting #2 and post-Meeting#2 technical breakout discussions, an Outcome-Notes Summary Memorandum providing a general update and overview of discussions would be advisable.

The US Magnesium (US Mag) facility (Site) is an active magnesium production facility located in Rowley, Tooele County, Utah, approximately 15 miles north of Interstate 80 and 33 miles north of Grantsville, near the southwest edge of the Great Salt Lake. An Administrative Settlement Agreement and Order on Consent for a Remedial Investigation (RI) and Feasibility Study (FS) was entered into by US Mag and the United States Environmental Protection Agency (USEPA) on 4 August 2011.

As noted in the Settlement Agreement, the USEPA envisions that there may be multiple phases of investigation at the Site. During the scoping process, the USEPA described their overall vision/process of the RI phases as follows:

Phase I – a general Site-wide reconnaissance, for a complete assessment of all potential Site-related compounds and affected media, to establish a data-pool for screening level risk assessment, and to establish data gaps that may need to be answered in following phases;

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Phase II – a comprehensive RI “sweep” to fill data gaps needed to finalize baseline risk assessments and position for FSs; and

Phase III – additional sampling to support finalization of the FS. If possible, this would be initiated during Phase II.

EPA recognizes the considerable work that has been undertaken by ERM in preparing for comprehensive discussions with EPA throughout the RI-scoping process (Fall 2011 – Spring 2013), as well as work plan development for conducting pre-Ph1A DMA (Demonstration of Methods Applicability) field and laboratory assessments.

The Settlement Agreement included a requirement for US Mag and the USEPA to convene a scoping meeting as a first step in the development of a Sampling and Analysis Plan (SAP) for each phase of the RI, and the SAP would be developed “based on the outcomes in the final EPA-approved written summary of the scoping meetings” (as outlined in Section 5.1.1 of the Statement of Work, Appendix A to the Settlement Agreement (AOC-SOW excerpt of Sec 5.1.1 and 5.1.2 follows).

EPA appreciates the range and depth of the Scoping Meetings and other technical discussions, which have enabled ERM to have lengthy collaboration and exchange of remedial investigation views and technical recommendations with EPA for the

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conduct of RI work—all of which EPA is taking under consideration in preparing and for issuing Draft SAPs. Accordingly, AOC- SOW Section 5.1.2 is purposefully the stage in the ‘SAP development process’ where ERM/USMag can offer any final comments to EPA on the design-implementation plans for the RI work set forth in the Draft-SAP. These comments will be considered by EPA’s prior to issuance of a Final SAP.

During 2012 scoping meetings, EPA and ERM mutually recognized the importance (given the complex matrix of chemical contaminants and media conditions) of carrying out pre-Phase 1A Demonstration of Methods Applicability (to assess planned field-sampling and laboratory procedures for soils, sediment, solid-waste, and water); this work revealed substantial need to clarify SOP-relevant information in/for the preparation of the Draft Ph1A-SAP. These endeavors, while called for specifically in SOW-5.1.2 have been recognized as having significant implications for the Phase 1A implementation plans; hence, by engaging such work at this stage ERM has accomplished substantial contribution to SAP development and work otherwise required pursuant to the ‘comment’ phase of Sec. 5.1.2.

While such DMA activity was not specifically contemplated or called for in the AOC-SOW, ERM and EPA recognized during scoping meetings the value of this undertaking (recognized as part of the Triad process); carrying out such pre-RI work would serve to greatly enhance the certainty of RI data meeting data-quality and data-usability requirements for subsequent site investigation and risk assessment needs.

Accordingly, ERM and the USEPA have participated in the following meetings and teleconferences related to scoping Phase 1 of the RI:

An initial scoping meeting held from 28 to 30 November 2011 in Salt Lake City, Utah, at which the general Phase I SAP development process was discussed;

An air breakout meeting (1A) held on 22 March 2012 in Salt Lake City;

The second general scoping meeting held from 17 to 20 April 2012 in Salt Lake City, at which details regarding the Phase 1A scope of work were discussed—specifically, the concept of breaking the Phase 1 RI one into Phase 1A and Phase 1B, where Phase 1A would be focused only on selecting contaminants of potential concern (COPC), and

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Phase 1B work would be focus on determining nature and extent. It was agreed that further ‘breakout’ technical discussions to focus on approaches to addressing ‘risk-assessment’ and ‘air-investigations’ were needed.

Risk Assessment breakout discussions were held via teleconference (Feb, 27)

and in Salt Lake City (Mar. 1), and are continuing as part of ERM’s ongoing development of the risk assessment Technical Memoranda.

Air breakout discussions #2 (1 November 2012), #3 (20 November 2012), and #4 (4 March 2013) held via teleconference. This series of air-calls were dealing with issues both for the Ph1A chronic-COPCs sampling plan development, as well as with Air-DMA plan development. With regard to the Ph1A air-plans, EPA advised ERM that it was concerned about the scale of resolution of the AERMOD model predictions (based on 1000 meter nodes) in the near-field areas surrounding the plant. EPA requested that a model run (using the same Nov-Dec met data sets) be undertaken on 250-m grid-node spacing to get a more precise spatial assessment of the predicted near-field sample-station locations that would derive from a denser-grid analysis. EPA-ERM also discussed how to resolve issues related to assessing air data adequacy. In addition, EPA-ERM discussed an alternate statistical approach to guiding sample-location selection. ERM undertook the 250-m grid spacing modeling assessment, and provided EPA with such results, and also with revised sample-station locations. Upon receipt of ERM’s work, EPA requested copies of all AERMOD input and output files so that EPA could independently review and verify ERM’s modeling work, and proceed to complete development of the Ph1A air-plans for the Draft SAP.

A groundwater/PRI-17 breakout discussion held via teleconference on 5 February 2013;

As requested by EPA, a working meeting was held Feb. 20, 2013 in Salt Lake

City to discuss EPA’s evaluation and assessment of post-DMA findings regarding soil, sediment, and waste sample collection and analytical methods, and brief ERM on method-modifications EPA viewed as needing to be incorporated into the SAP, and other recommendations important for ERM to consider in SOP development. (see attached EPA Feb. 20 meeting materials). This meeting noted the merit of follow-up discussions to address (1) particular concerns ERM raised with regard to analytical challenges for

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DLs/TQLs associated with PCBs/DFs, and (2) pertinent SOP details for analytical-chemistry method-modifications.

A post-Demonstration of Method Applicability (DMA) chemistry/analytical technical discussion held via teleconference on 6 March 2013.

During the post-DMA results discussion of Feb. 20, 2013, ERM requested

that EPA-UDEQ engage discussions amongst the risk assessors to ascertain whether opportunity existed to consider refinements to the DL/TQLs that had been targeted as the initial Risk Screening Levels (RSL’s) to be utilized for the Ph-1A sample analyses, and that EPA consider the application/use of less-costly methods for PCB analysis. These discussions have been ongoing and have not yet resolved the extent to which such TQL ‘adjustments’ may be appropriate.

ERM and EPA risk assessors have determined that modification of the Target

Quantification Limits may be sufficient in some cases to justify the use of somewhat higher MDLs that may be associated with the modified Method 680 results. However, this approach would likely only apply to direct exposure of certain receptor/pathway combinations but would not address potential risks to wildlife receptors that would be exposed via the food web. How risk to wildlife receptors will be assessed has not been determined, and depending on how food web exposures are estimated, it is likely that a modified method 680 will at best only partially achieve necessary MDLs.

As noted above, ERM’s raised of the possibility of using a modified Method-

680 approach as a cost-saving means to obtain PCB analyses. Having this proposal emerge at this late planning stage (after the Scoping Sessions, and after the completion of the DMA work), leaves little opportunity to sufficiently engage and resolve these discussions prior to SAP finalization for the planned 2013 field endeavors. These discussions have continued, with some initial materials assembled by ERM and Alpha-Analytics (asserting a Confidential Business Information (CBI) claim) and provided to EPA’s RI-team for initial technical considerations. EPA has advised ERM of the specific manner required for handling materials and discussions for CBI-claimed information. EPA has advised ERM of the above-noted risk assessment concerns and potential limitations with this method for complete and accurate identification of all PCB-congeners, and advised ERM that further technical discussions about the potential use/application of a modified

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Method-680 will require further consideration by expert chemists within the Agency as the use of such analyses for risk-assessment screening and RI purposes. EPA recognizes that there may be merit in pursuing ERM’s method-680 proposal(s), but that such work would at this point need to likely need to be carried on as a site-specific ‘DMA-like’ study in parallel with ongoing Ph-1A work utilizing method 1668 for PCB analyses.

This memorandum (memo) has been prepared to summarize the outcomes of these meetings, particularly as they relate to the scope of work generally agreed to or discussed for EPA consideration for Phase 1A of the RI. General summaries of the discussions and outcomes of the various Phase 1 scoping meetings are summarized in the outcome memos and other correspondence associated with each meeting/teleconference, which are provided as Attachment 1 to this memo 1. Final EPA-approveded outcome notes are to be made a part of the SAP supporting documentation.

GENERAL PHASE I SCOPING

During the initial and second scoping sessions, US Mag/ERM and the USEPA agreed on the following related to general Phase I scoping:

For purposes of project planning during the initial phases of the RI, the Site would be divided into 18 Preliminary RI (PRI) areas, which would be the focus of the Phase I site investigation activities. The surface water in each PRI was combined with the Site-wide groundwater as a single PRI (PRI-17).

The Phase I RI would consist of two data collection events with the following objectives:

1 The USEPA provided comments on the first outcome memo (incorporated into the

version included in the Attachments), but has not provided comments on any of the subsequent outcome memos. A standalone outcome memo was not prepared for the 20 November 2012 air breakout meeting; the outcomes are reflected in the proposed air program scope memo dated 21 December 2012 (Attachment 2). [EPA note: Final EPA-approved outcome notes for the subject meetings, while not on record at the time of this ERM memo, have been completed and attached hereto and for the Draft Ph1A SAP issuance.]

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a. Phase 1A, to collect information necessary for the selection of COPCs via screening risk assessment, and to evaluate if and to what extent historical data were representative;

b. Phase 1B, to conduct a preliminary characterization of chemical nature and extent, and to collect the data necessary to refine the conceptual site model and conduct baseline risk assessments.

Data generated during Phase 1A could be used to determine correlation coefficients between COPCs, which may support the use of indicator compounds as a tool for more efficiently and effectively achieving nature and extent data quality objectives (DQOs).

A DMA field and laboratory event would be performed prior to Phase 1A investigations to assess whether the planned methods for sample collection and preparation, and laboratory analyses could effectively achieve the Phase 1 DQOs

US Mag/ERM and USEPA responsibilities for key elements of the Phase 1A SAP are summarized in Table 1.

The DMA event for soil, sediment, waste, and water was subsequently conducted in accordance with Demonstration of Method Applicability Work Plan for Soil, Sediment, Waste, and Water Preparatory to Phase 1A Remedial Investigation (DMA Work Plan), an initial draft of which was prepared by ERM on behalf of US Mag and issued by the USEPA in September 2012. The DMA Work Plan included the standard operating procedures (SOPs) for use of sampling equipment, sample collection, sample preparation, and laboratory analyses that will be modified as necessary for use in the Phase 1 RI. These SOPs were prepared by ERM at EPA request, in accordance with Section 5.1.2 of the Settlement Agreement Statement of Work, which specifies that US Mag “provide standard operating procedures and other detailed information (e.g., identification of the Respondent’s key project personnel) for incorporation into final EPA-approved SAPs as requested by EPA.”

The results of this DMA were provided to the EPA in technical memos documenting (1) sample collection activities completed at the Site during the DMA and (2) laboratory analytical results (dated November 2012 and January 2013, respectively). ERM’s DMA findings technical memos

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concluded that the field and laboratory procedures evaluated in the DMA performed sufficiently to achieve the Phase 1A RI DQOs, with minor modifications to reflect the DMA findings.

However, as discussed with ERM in the February 20, 2013 meeting , EPA oversight observations identified the presence of interferences that impacted the reliability of results for volatile organics in sediment and water. The presence of volatile organics in water also suggested that volatile analyses are needed in saturated sediment across the Site. EPA perchlorate results from the DMA were inconsistent with ERM results. EPA results were elevated suggesting the need for perchlorate in soil be added to the Phase 1A RI. Reporting limits for semivolatile organics were generally elevated above target quantitation limits. Reporting limits for dioxins, furans, and PCBs in waste samples were elevated because of the need for high dilutions. Spikes were diluted out in many of these samples making the reliability of reported target analyte concentrations less reliable. Hexavalent chromium (Cr+6 )results were also found to be questionable in the EPA data set because of poor spike recoveries. More information is provided in the related EPA-Oversight Report (EPA 2013)

One refinement will be to develop strategies/method-modifications for low-level and high-level contaminated samples collected during Phase 1A. These two categories will be identified based on expected level of known concentrations (target- or matrix-related) in PRIs with historical data or from Site conditions encountered during the DMA investigations.

EPA issued a Draft Air-DMA Workplan in December 2012, and ERM responded with comments. EPA has issued the Final Air-DMA Work Plan (March 2013) and work was commencing by ERM in April 2013.

SCOPE OF SOIL/SEDIMENT/WASTE SAMPLING

The sampling strategy and general scope of work for the Phase 1A soil/sediment/waste RI was agreed upon by US Mag/ERM and the USEPA during the scoping meetings, as detailed in Table 2 for each PRI. The general scope of the sampling approach for PRI-1 through PRI-16 is as follows:

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In general, 14 surface soil/sediment/waste samples will be initially collected from each of the soil/sediment/waste PRIs (PRI-1 through PRI-16) for the purpose of COPC selection. For most PRIs, the sample locations will be random or systematic; however, as noted in Table 2, for certain PRIs, some locations may be biased to address ranges of concentrations or specific Site features. Given its small size, the number of surface soil samples collected from the sanitary lagoon (PRI-3) was reduced to 12.

In PRI-7, limited biased samples may be collected in terrestrial habitat areas, at up to four locations.

Subsurface soil/sediment/waste samples (approximately 35) will be collected from PRI-1, PRI-2, PRI-5 through -7, and potentially PRI-8 and PRI-15. These will include up to four subsurface sediment samples representing historical US Mag waste streams to be collected from PRI-1 (two locations), PRI-5 (one location), and PRI-6 (one location). These sediment samples will be collected from relatively accessible non-submerged areas. EPA Point-of-Clarification: During that meeting EPA reiterated it’s continuing view/opinion about the need to collect ‘deep-sediment’ cores within the waste-lagoons to assess the COPC makeup of ‘early-era’ waste-sludge deposits, and assess/document COPCs and geochemistry reflective of the submerged conditions that have persisted over time in such areas. ERM-USMag reiterated again their objections/issues with the risk/difficulty/cost of obtaining such samples; further noting that the ‘floating-dock’ used during the DMA sampling was not effective. EPA has pointed out design limitations to the dock apparatus that ERM had deployed Other sample access/platform methods could be successfully employed. Since the April 2012 scoping discussions, EPA has recommended that very shallow-draft flat-bottom boats could be used as the base for a ‘large working-area platform’ structure that could be triangularly tether-winched across the lagoons. In addition, EPA has discussed with ERM the deployment of an amphibious ‘mud-buggy’ that would similarly provide a safe working platform with access into and across all lagoon areas. EPA noted that USMag/ERM might consider constructing earthen embankment-roadways out into deeper-water zones to facilitate ‘safe’ coring of sediments (given that USMag did a similar type of fill placement when dealing with the Spring 2012 PRI-5 breach location). USMag’s representative said this was a possibility they could consider for accessing deep-water samples. EPA noted

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this aspect of SAP plan development was still under consideration, and would welcome proactive ideas from USMag/ERM to accomplish acquiring these samples.

Boring samples will be analyzed for volatile organics, semi-volatile organic compounds (SVOCs), polychlorinated biphenyls (PCBs), dioxins/furans, and select metals.

Phase 1A samples from select PRIs may be analyzed for cyanide and perchlorate.

Phase 1A samples from select PRIs may be held for analysis of PCBs and dioxins/furans based on nature and extent and baseline risk assessment data needs.

Only the ditch and subsurface samples will be analyzed for volatile organic compounds (VOCs). EPA further notes that in subsequent sampling/analysis discussions, ERM and EPA recognized that the presence of VOCs noted in all aqueous waste-water samples warrants the need for this analysis in all surface and subsurface aqueous and saturated samples.

Revisions are needed for the soil/sediment/ waste sampling procedures as discussed in EPA’s Field Oversight Report (EPA 2013) and subsequent March 8th and April 4th conference call notes. Acceptable duplicate sample agreement for the majority of target analytes suggests that the field sample homogenization during the DMA appears to have been adequate for the purposes of the Phase 1A RI.

For locations where solid samples will be analyzed for VOCs, the use of Encore sampler and methanol extraction may be used in the event of sediment off-gassing.

Perchlorate may be included in the standard analytical suite for solid samples.

SCOPE OF AIR SAMPLING

The approach to air sampling was discussed during the general scoping meetings. In addition to the general scoping meetings, US Mag/ERM and the USEPA discussed the objectives and scope of the Phase I air RI during

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one breakout meeting and three technical calls, which resulted in the following agreements for the Phase 1A monitoring program:

PM10 is the particulate species that should be monitored during the Phase 1A RI. (Because PM2.5 is included in PM10 sampled weight, it is not necessary to quantify PM2.5 separately.)

EPA understands from ERM/USMag discussions that the primary sources for acute COPCs may be from the Melt Reactor stack and the CBS stack during maintenance and malfunction events.

The acute COPCs from the process sources are limited to chlorine and hydrogen chloride, which will not be screened out as COPCs during the Phase 1A RI.

Unit rate source modeling will be used to identify probable high-impact zones that will be monitored for both acute and chronic COPCs as part of the Phase 1A RI.

Phase 1A DQOs will be revised to allow both quantitative and qualitative criteria (i.e., multiple lines of evidence).

AERMOD concentration predictions versus time and heat maps will be used to guide the selection of Phase 1A sample locations.

To confirm that samples are collected at high-biased locations, multiple lines of evidence will be used for data verification, including use of a statistical test as one of the lines of evidence.

The airborne COPC concentrations at the Site occur randomly, so back-to-back sample collection during Phase 1A is not necessary. [EPA is uncertain about what this statement means.]

EPA requested further information and clarification of the technical basis and data analysis that ERM was proposing for the sampling strategy and sample locations. Accordingly, The EPA agreed that ERM could re-submit such materials to support-upon scope of work for the Phase 1A air monitoring program that incorporates these elements. ERM’s version #3 air-submittal of Dec. 2012 has been included as Attachment 2 to this memorandum.

SCOPE OF GROUNDWATER SAMPLING

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In addition to the general scoping meetings, US Mag/ERM and the USEPA participated in one breakout technical call to discuss the scope of the Phase I groundwater characterization efforts. During these meetings, discussions relative to the scope of work for the Phase 1A groundwater RI were as follows:

During the general scoping sessions, the USEPA agreed with the broad construct of the US Mag/ERM proposed sample strategy for the surface water and groundwater PRI (PRI-17), which included monthly water level measurements and two rounds of sampling and analysis. ERM’s proposed scope included groundwater sampling at 24 existing monitoring wells and surface water sampling at 52 locations (ditches, waste and sanitary lagoons, ponded seasonal water, and canal water). This scope was acknowledged to be broader than that required for COPC selection and was intended to partially achieve the primary Phase 1B DQO of determining nature and extent. The proposed analytical program included analysis for VOCs, SVOCs, PCBs, dioxins/furans, perchlorate, haloacetic acids, metals (including hexavalent chromium), and general water quality (pH, alkalinity, cations/anions).

During the February 2013 breakout call, the USEPA noted that the Phase 1A SAP scope for PRI-17 was in development and that the overall number of sample locations being considered is comparable to the proposal presented by ERM during the April 2012 scoping meeting.

The USEPA further noted that the Phase 1A SAP will focus on achieving the Phase 1 DQO of COPC selection and include the sampling of the wells likeliest to contain chemicals (i.e., in close proximity to facility source areas) and placed in locations to provide coverage of pathway vectors inferred from historic potentiometric surface maps. Accordingly, the draft Phase 1 SAP will likely include eight new monitoring wells and exclude existing wells with historical non-detections.

Based on historical data, the USEPA did not observe significant seasonal variability in chemical concentrations. Therefore, the Phase 1A SAP will include a single round of data collection.

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Table 1 Phase 1A Responsibilities

US Mag/ERM Responsibility USEPA Responsibility Current Status

DQO [EPA note: During scoping consultations ERM reviewed and discussed with EPA draft DQO documents prepared by EPA; EPA DQOs are a Draft-SAP component.]

Discuss preliminary draft DQOs and sample strategy(s) (UFP-QAPP Worksheet 11) for EPA consideration in preparing the Draft Phase 1A SAP

Issue DQOs and sample strategy in Draft-SAP

Task complete

Data Management Plan (DMP)

Prepare draft DMP

Revise DMP to incorporate USEPA comments, finalize

Review and approve DMP

Task complete

SOPs

Prepare draft SOPs for lab analysis and field methods

Revise SOPs to incorporate USEPA comments

Review and approve draft SOPs

ERM to provide USEPA with revised SOPs to reflect recommendations in DMA reports, pending USEPA acceptance/comment

Health & Safety

Discuss health and safety considerations with USEPA for when USEPA/Contractors will be on Site

Discuss health and safety considerations with US Mag/ERM for USEPA oversight

ERM to provide USEPA with revised HASP 2 weeks prior to commencement of Phase 1A fieldwork

Prepare draft Health and Safety Plan (HASP)

Revise draft HASP to incorporate USEPA comments

Review draft HASP and coordinate procedures used by USEPA oversight contractors

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US Mag/ERM Responsibility USEPA Responsibility Current Status

Phase 1A SAP:

Review and comment on draft-SAP

Review/comment on draft SAP

Prepare draft SAP, taking into consideration the above supplemental plans/SOPs, and including COPC field plan

Review/revise draft SAP as appropriate considering US Mag/ERM comments, & issue Final SAP

ERM to provide USEPA with comments on draft SAP 30 days after receipt

Implement Final Phase 1A SAP

Concurrent with Phase1A, prepare risk-assessment Tech-Memo(s) for EPA-UDEQ review

Prepare Phase 1A report

Conduct Screening Level Risk Assessment (pursuant to EPA-approved Risk Tech-Memos)

Conduct oversight, including independent sample-splits, analytics, & data-quality assessment

Review and comment on Phase 1A report

Review/approve Risk Tech Memos

Review/comment on Screening Level Risk Assessment

Table 2 Phase 1A Sampling Strategy [EPA: noted as per consistency with April 2012 Scoping Meeting #2 and follow-up discussions regarding the minimum number of necessary samples has been discussed for meeting statistical requirements for mean and Cmax determinations for COPC evaluations. .]

PRI Identification Sample Types and Number Analytical Program*

PRI-1 Ditches A minimum of 14 surface sediment samples in active

Modified standard suite, depending on COPC

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ditches and in dredge spoil areas; limited subsurface sampling (up to four two locations total, at bridge areas when viable)

14 surface and 14 deep soil samples in former Boron Ditch

selection

VOCs only in active ditches and deep Boron Ditch samples

PRI-2 Landfill A minimum of 14 surface and three borings to native material 14 subsurface soil samples (28 total), to be collected from 14 locations selected based on geophysical survey

Standard Suite, VOCs in subsurface samples

PRI-3 Sanitary Lagoon

12 random surface soil samples and one boring to native material

Standard Suite

PRI-4 Gypsum Pile A minimum of 14 surface soil samples, including one biased location near pipe outlet, and one boring to native material.

Characterize surface material for potential dust generation

Modified standard suite, depending on COPC selection

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PRI-5 SE Ponded Waste Lagoon

A minimum of 14 random systematic surface soil samples, including biased samples to address range of concentrations, including locations near inlet and in topographic lows where sediments expected to settle out; limited subsurface sampling (a single location targeting older deposits) [EPA note: this statement is presumptive and incorrect (see p.9 sediment sampling discussion.)]


PRI-6 NW Ponded Waste Lagoon

A minimum of 14 systematic random surface soil samples, including biased samples to address range of concentrations, including locations near inlet and in topographic lows where sediments expected to settle out; limited subsurface sampling (a single location) targeting older deposits) ) [EPA note: this statement is presumptive and incorrect (see p.9 sediment sampling discussion.)]


PRI-7 NE Ponded Waste Lagoon (OWP)

A minimum of 14 surface soil samples, including biased samples to address range of concentrations, including locations near inlet where historical data suggest elevated concentrations; additionally, collect limited samples in terrestrial habitat representing the 0- to 5-foot depth interval. One boring to native material to be located near the former pond inlet.


PRI-8 NW Lagoon Overflow

A minimum of 14 surface soil samples, including biased samples to address range of concentrations (based on historical analytical results)

Standard suite

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Consider collecting limited samples from selected additional locations in terrestrial habitat, representing the 0- to 5-foot depth interval, with a single boring to native material to be located adjacent to PRI 6.

PRI-9 Smut Area 14 random surface soil samples

Standard suite

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PRI-10 Barium Sulfate Disposal Area

A minimum of 14 surface soil samples, and one boring to native material.

Standard suite

PRI-11 ATI Titanium and USM Parking Lots

A minimum of 14 surface soil samples (unpaved areas)

Standard suite

PRI-12 Ancillary Worker Exposure Area

A minimum of 14 surface soil samples (unpaved areas)

Standard suite

PRI-13 Buffer Area Northeast

A minimum of 14 surface soil samples, including biased samples adjacent to OWP

Standard suite

PRI-14 Buffer Area Southeast

A minimum of 14 surface soil samples

Standard suite

PRI-15 Buffer Area Alluvial Uplands


Consider collecting limited samples from selected additional locations representing the 0- to 5-foot depth interval

Standard suite

PRI-16 Buffer Area Lakeside Mountains


Standard suite

* Standard Suite = SVOCs, PCBs, dioxins/furans, metals

Attachment 1 Scoping Meeting Outcome Memoranda [EPA is unsure for this document what this Attachment

is meant to refer to. Outcome notes are transmitted to ERM and are included in the Draft SAP.]

Attachment 2 Site-Wide Ambient Air PRI – Proposal for Phase 1A Sampling and Analysis Plan [EPA presumes this is referring to the December

2012 ERM Air-Plan version #3 that was provided to EPA following the November 2012 air-breakout teleconferences.]

Documents

Technical Memorandum Environmental Resources Management · Environmental Resources Management 7272 E. Indian School Rd. ... (SAP) for each phase of ... An initial scoping meeting