DSHW-2018-003265 - 0901a068807ea4c5

Anderson Geneva Development, inc. United States Steel Corporation
P.SRW _201e-0032 (05
April 3, 2018
Mr. Scott T. Anderson, Director
Division of Waste Management and Radiation Control
Utah Department of Environmental Quality
P.O. Box 144880
Salt Lake City, UT 84114-4880
RE: Notification Letter for Continued Site Management Plan (SMP) Groundwater Monitoring
at the Former Geneva Steel Facility, Vineyard, Utah
Dear Mr. Anderson:
On behalf of United States Steel Corporation (USS) and Anderson Geneva, LLC/Ice Castle Retirement
Fund L.L.C. (Anderson Geneva), this letter is to notify you that the Site Management Plan (SMP)
groundwater monitoring event at the solid waste management units (SWMUs) shown in the attached
table, which are located at the former Geneva Steel facility in Vineyard, Utah, is planned for the week of
April 9, 2018. This sampling event responds to the requirements of the approved SMPs for each SWMU.
AECOM, a contractor to USS/Anderson Geneva, will conduct the field work.
Specific Planned Activities
Samples will be collected at each of the SWMUs and from the monitoring wells or piezometers presented
in the attached table. To help evaluate groundwater conditions, the following data will also be collected
at each location, using field instrumentation: temperature, dissolved oxygen (DO), pH, conductivity, and
oxidation/reduction potential (ORP).
Procedures and Analytical Program
Field methods, including sampling arld documentation, will be performed and documented in accordance
with applicable standard operating procedures (SOPs) and requirements listed in the revised Verification
Investigation Work Plan (VIWP). Quality assurance and quality control (QA/QC) protocols for the
investigation, including the number and types of QC samples, are included in the revised Data Collection
Quality Assurance Plan (DCQAP), which is Part 2 of the RCRA Facility Investigation (RFI) Work Plan.
The groundwater samples will be collected in accordance with the revised DCQAP and will be submitted
for the analytical program presented in the attached table. The samples will be analyzed by a Utah-
certified laboratory and the analytical results will be validated in accordance with the DCQAP.
Reporting
Preliminary analytical data will be available approximately four (4) weeks after submittal of samples to
the laboratory. USS/Anderson Geneva will document the sampling, review and validate analytical data,
and submit separate SWMU-specific Letter Reports of Findings to UDEQ to summarize the results of the
groundwater monitoring event approximately 60 days following receipt of all validated analytical results.
Please contact us at your convenience if you have any questions on this matter.
cc: B. Mustoe, AECOM
T. Messersmith, AECOM
File: AG, USS
Anderson Geneva Development, inc. United States Steel Corporation
Summary of Planned Semi-Annual SWMU SMP Groundwater Sam lin
SWMU to be Sampled Planned
Sample Dates Monitoring Wells/Piezometers to be Sampled Analytical Program1'2
SWMU GW-4.2 ORA Benzene Plume 4/9/2018 MW-142, MW-143, MW-144 Benzene, toluene, ethylbenzene, xylene, and naphthalene
SWMU GW-4.5A Parish Geneva Area 4/12/2018 MW-124S / GPW-0180R, PC-213 VOCs and SVOCs3
SWMU GW-4.6 Maintenance Area Plume 4/11/2018 MW-136, MW-137, MW-138 Benzene, toluene, ethylbenzene, and xylene
SWMU GW-4.7 Pipe Mill Area Plume 4/9/2018 MW-140, MW-141 TCE, DCE, and vinyl chloride
SWMU GW-4.8 Nitrogen Plant Plume 4/12/2018 MW-118S / NPP-209 Benzene, toluene, ethylbenzene, xylene, and naphthalene
SWMU GW-4.11 Front End Oil Tank Plumes - South 4/10/2018 MW-156, MW-157 / 3.20A-053 Benzene, toluene, ethylbenzene, and xylene
SWMU GW-4.12 Front End Oil Tank Plumes - North 4/10/2018 MW-158, MW-159, MW-161 / 3.20A-094 TCE, DCE, and vinyl chloride
SWMU GW-4.13 Highline Area 4/11/2018 MW-150, MW-151, MW-152 /
MS29-006, M529-009R, MS29-011R
Benzene, toluene, ethylbenzene, and
xylene
Notes:
1 - The proposed analytical program is based on the specifications in the approved SMP for each SWMU. For SWMU GW-4.5A, SVOCs are
included in the sampling program, even though they are not specified in the SMP; this is to assess for bis-2-chloroethyl ether, which has been previously identified in this area.
2 - Analytical program to be conducted by EPA Method 5W846 8260B or equivalent method, unless otherwise noted. 3 — SVOC analysis to be conducted by EPA Method 5W846 8270C or equivalent method.
DCE - dichloroethene
TCE - trichloroethene
SMP - Site Management Plan
SVOC - Semi-volatile Organic Compound
SWMU - Solid Waste Management Unit
VOC - Volatile Organic Compound