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HomeMy WebLinkAboutDSHW-1997-002968 - 0901a06880158f0bDEFENSE AND LAUNCH VEHIWES DIVISION P.O. BOX 689 BRIGHAM CITY, UT 84302-0689 801-863.3511 8 May 1997 W110:FY97:53 Mr. Dennis R. Downs, Executive Secretary State of Utah Department of Environmental Quality Division of Solid and Hazardous Waste 288 N. 1460 W. P.O. Box 144880 Salt Lake City, Utah 84114-4880 Dear Mr. Dowois SUBJECT: Response to Comments on Revised pages to the Closure Plan are also replace pages up to and including 25. THMOKOL AEROSPACE & iNDUSIRIAL TECHNOlOGIf S ^f 12 my Closure Plan for Old Open Buming Sites at M-225 Thiokol received comments from your office on the M-225 Closure Plan on 18 March 1997. These comments were reviewed, and a meeting was held with Mr. JefF Vandel and Mr. Bill Wagner to discuss our responses. Through this discussion, the process was expedited and a consensus was reached. Our responses an; included in the enclosed attachment. included to replace those in your copy. Please We request final approval ofthe Plan so that is can be implemented this spring. Questions on this submittal should be addressed to Paul Hancock at 863-3344. Sincerely A. K. Lemon, Manager Facilities, Maintenance & Waste Managerr|ent AKL/bms RESPONSE TO COMMENTS ON BURN SITES THIOKOL THE M-225 OB/OD FACILITY OLD CLOSURE PLAN CORPORATION Ma) 1.0 Introduction A minor correction is needed in the las Solid and Hazardous Wastes Committee" with Utah Solid and Hazardous Waste Control 7,1997 paragraph ofthis section. Please replace "Utah Board. This correction has been made. 1.4 Waste Characterization In this section it is stated that the possi]?le hazardous contaminants, from previous activities at the M-225 facility, are listc d in Table 1.4. It appears that this list is incomplete. Compounds that were reported to be bumed at M-225. but do not appear in the list include RDX. beryllium, cadmium, aluminum, molybdenum and silver. Please add these compounds to Table 1.4. or provide a justification for why they should not be included in the table. 11 RDX has been added to the list and wi Silver has also been added. We do no: to or treated in the M-225 buming grounds the previous investigation, however, it knowledge ofany disposal. Initial infcjrmation indicated that beryllium propellant resipue subsequent investigations have shown nature of the propellant it was treated alt building M-243). The plan has been modified not included because it is not a hazardous nature, it is not determined to be a concem other metals are routinely reported. Thiese 2.1 Closure Performance Standard be analyzed using the same method as HMX. have record of beryllium or cadmium being sent These compounds may have been listed in was part of a complete metal analysis rather than (when the closure plan was first written) was treated at the M-225 site, however, hat this was not he case. Due to the unstable a safer more accessible site (SMUM #20, near to reflect this information. Aluminum is waste constituent, also due to it's ubiquitous to the enviroiunent. Under ICP metal analysis will be available upon request. As in section 1.0. "Utah Solid and Hazardous Wastes Committee" needs to be replaced with Utah Solid and Hazardous Waste Control Board This correction has been made. contamination exists at M-225. the site 2.2 Decision Matrix According to the Decision Matrix shov/n in Figure 2.2. if it is determined that extensive will be closed with the contamination in place and post-closure activities would ensue. Tliis matrix doesn't include the possibility that corrective action may be required baseil on the level of risk present at the site. The level of risk which requires corrective action is outlined in R315-101-6(e). The Decision Matrix has been modified to better clarify this possibility 4.1 Previous Investigation In the second sentence ofthe second pe: units were sampled and found not to contain significant levels of hazardous constituents. ragraph ofthis section, it is stated that the old The Division disagrees with this staten ent because the previous investigation did not adequately demonstrate the nature and extent ofthe contamination. This is the objective ofthe additional sampling. Please eithi;r revise or remove the statement referred to above. In addition, it appears that approval ofthe azide pit excavation was given in order to facilitate the investigation ofthe extent ofcontamination This statement has been revised. 4.2.1 Shallow Boring Program It is stated in this section that the location ofthe proposed background bore hole is shown in Figure 4.2.1. The proposed location ofthe bore hole is not shown in this figure. The figure has been revised to include the background bore hole location. It is also stated in this section that each boring will be advanced to a depth of 20 feet. This depth was selected, it is reported. l)ecause any contamination present is expected to be found within this interval (based on soil characteristics and other factors). The burial ofthe old units with fill material during bore hole depth of 20 feet beneath the old ground surface (prior to filling) should be adequate. However, since the depth of fill material is not addressed, the depth of characterization provided by 20 foot bore holes is unknown. In addition, the depth ofthe the upgrade ofthe facility is not addressed. A azide pit excavation needs to be address ed for the same reason. Twenty feet depth was chosen because greater than 20 feet depth at an operatin|g concems may limit excavation to less to indicate this intent. i)f the physical constraints of removing soil to facility of relatively small dimension. Safety than 20 feet depth. Section 4.2.1 has been modified It is reported that the bore hole soil samples will be analyzed for the constituents listed in Table 4.2.1. Based on the information that Thiokol has provided on the materials that were bumed at the old units, it appears that there are some constituents that should be added to this list. The constituents that should be added are: RDX. beryllium, cadmium, and silver. In addition, the pH ofthe soil samples should be measured in order to fully characterize the samples. Please see the answer to comment 1.4. We will measure the soil pH in two samples at one ofthe bore holes in each pit, one at the surface ofthe native soil and one at the five foot interval. Will the soil samples be analyzed on-site at Thiokol's analytical laboratory? If so. is the laboratory certified for all ofthese constituents? The samples will be analyzed on-site. Thiokol's analytical laboratory is certified for all constituents listed for analysis in the plan. A copy ofthe latest State ofUtah certification for Thiokol Environmental Laboratory is included as an attachment. In the second to last sentence ofthis section, it is stated that the locations ofthe soil borings will be determined by using a random number generator and the grids on Figure 4.2.1. Ifthe old bum units can still be accurately located, it is the Division's opinion that off-setting the previous bore holes at each unit would be a more effective method for characterizing the site. If. however, the old units can not be accurately located, randomly selecting the bore hole locations as proposed would be appropriate. Thiokol believes the random selection of borehole locations within the known pit locations is appropriate to preserve the representativeness ofthe sampling data. However, the sampling grids have been modified to insure that the borehole location is within the pit boundaries. In regard to the grids in Figure 4.2.1 that may be used to select random locations for the bore holes: there is no scale on the figure. Please provide a scale for the Figure or report what the distance will be between the proposed grid lines. The figure has been revised to include the scale for proposed grid lines. Based on the information that the Division currently has, it appears that additional characterization ofthe azide pit may not be necessary. Additional data from the previous investigation and corrective action is needed, however, before a risk-based closure with no fiirther action could be approved. The data needed includes: the depth ofthe azide pit excavation, all ofthe volatile organic compound (VOC) data for the azide pit bore hole samples (we're missing trichloroethene among others), pyridine data from the bore hole samples, and VOC and metal data from the confirmation samples (if it exists). If it is determined that additional sampling ofthe azide pit is not necessary, the Division would suggest utilizing the 2 bore holes plarmed for the pit somewhere else (the detonation pit for example). The azide pit excavation varied from 8-10 feet deep. The Method 8240 VOC data (including trichloroethene) for the original boreholes ofthe azide pit were submitted to the DSHW on 15 April 1997. This data indicated the constituent of concem was pyridine (and azide). Confirmation sampling was accomplished using method 8270, which is more sensitive and appropriate for pyridine analysis than 8240. Metal conformation analyses were not performed because anomalous metal values were not found in the borehole sampling. Thiokol believes both ofthe boreholes planned for the Azide pit should remain at the pit as additional confirmation samples. 4.2.2 Statisfical Methods Due to the possibility that the soil below one ofthe old bum units (the composite pit for example) is contaminated while the soil under the other units is clean, pooling the data collected from the same stratum at each unit would not be appropriate. Each unit will have to be compared to the background data separately. Since samples from different units can not be pooled to make comparisons with background data, the number of samples available for comparisons is reduced to two per stratum per unit (unless the previous bore hole samples are used). In addition, under the proposed closure plan, only one sample per stratum would be available to use as background data (again unless the previous background data is used). Ifthe ANOVA technique is going to be used, more samples are needed in order to make meaningfiil comparisons. Ifthe previously collected background data were used, and possibly the previous data collected from each unit, and the four strata are pooled together (from each unit and the background holes) the ANOVA technique could be used on the pooled data. Thiokol proposes pooling data from the two boreholes ofeach unit rather than from each strata and comparing this with pooled data from the two background boreholes (1990 and 1997). In many cases this will be sufficient to perform ANOVA comparisons. Based on the previous analytical data, it appears there's a good chance that at least 50% ofthe sample results will be non-detect. Please include in your response an outline ofthe procedures that will be followed ifthe test of proportions or control chart (including the type) statistical methods are used. Thiokol agrees that there is a high probability that many ofthe sample data will be less than the detection level. In this case, values of constituents will be assigned a value of one-half the detection level, and ANOVA will be performed. A visual illustration of these relationships may also be prepared. 4.2.3 Risk Assessment There is a typographical error in this secfion. Please replace R315-105 with R315-101 in the first and second sentences. This has been corrected. 4.2.4 Reporting Data Thiokol is proposing that the results of Phase I. the investigative phase, be submitted in the Closure Report after Phase II. Closure Action, is complete. The Division recommends that the bore hole data be submitted for review before a closure action (or no action) is taken. Section 3.6 has been changed to better clarify the reporting procedures to the division after Phase I is completed. It appears that there are a few parameters and methods that should be added to Table 4.2.2 in this section. The parameters are: RDX and HMX (suggested method 8330): lead, beryllium, cadmium, and silver (suggested method 6010. TCLP would not be appropriate): pyridine (suggested method 8260) and sodium azide (method may vary). If the bum units at M-225 are closed in accordance with the risk-based closure standards. the Division recommends that Thiokol ensures that the method detection limits are adequate (low enough) for all ofthe analytes before the analysis is done. This must be done so it can be shown that the levels detected do not present a risk to human health or the environment. Please refer to the response for section 1.4 conceming additional analytical parameters. The method detection limits for the parameters in a soil matrix are adequate for the closure according to residential risk based standards. 4.3 Phase II Closure In paragraph 1 ofthis section it is stated "ifno statistically significant hazardous waste constituents above background are detected or constituents below risk-based levels are detected in the soil, then the site will be closed with no ftirther actions." What land use scenario will these levels be based on? Will standard default parameters for residential land use be used? The statement has been modified to clarify that closure will be to residential parameters. In paragraphs 2 and 3 "R315-105" should he replaced with R315-101. This statement has been corrected. 4.3.1 Closure With No Continued Action As mentioned in section 4.2.2 above, an ANOVA may not be appropriate for the data generated from sampling the separate units at M-225. Therefore, the use of "statistically significant" results may not apply. Please see response to Section 4.2.2. 4.3.2 Closure by Excavation of Wastes It is stated in the third paragraph that the location ofthe background bore hole is identified in Figure 4.2.1. The location ofthe bore hole is not shown on this figure. The figure has been revised to include the scale for proposed grid lines. 4.3.3.4 Groimdwater Monitoring Well Installation If groundwater monitoring is necessary. Thiokol's proposal to use well X-4 and the down gradient springs will have to be evaluated. Thiokol appreciates UDSHW's willingness to consider the proposed approach. 4.3.4 Post Closure It is stated in this section that the post-closure plan, if necessary, will comply with the requirements that apply to surface impoundments. The post-closure plan may need to comply with the post-closure requirements that apply to landfills if hazardous waste or waste constituents are left in place above risk-based levels, and it is shown that groundwater has been impacted by past activites at M-225. The nature ofthe old M-225 pits more closely resembles surface impoundments than landfills, and the closure requirements for surface impoundments is perhaps more appropriate than landfill requirements. The units may contain contaminated soils but no landfill type materials are present in the pits. 5.3 Soil Sampling and Analysis It is stated in this section that fifty two samples and one field blank will be analyzed. The Division generally suggests 1 trip blank and 1 duplicate sample be analyzed for every 10 to 20 samples to ensure QA/QC. The cost estimate may need to be revised to account for additional duplicate and field blank samples. Thiokol will increase the munber of duplicates taken to 3. Since these are soil samples it is difficult, or of little value to take various types ofsoil blanks that are meaningful especially for metals. The SW846 states that" a universal blank matrix does not exist for solid samples, and therefore, no matrix is used." We do find however, that since there can be interferences or false posifives with natural soils there is value in taking duplicates and background soils as QC checks for most parameters. fiPR 02 '97 l,l:48flM THIOKOL R&D Department of Health DIVISION OF EPIDEMIOLOGY AND LABORATORY SERVICES J DEC 06 1996 State of'Utah p. 2/7 MiobadO. Leavitt Governor RodL.BeUt Executive Director Charles D. Brokopp, Dr. PiH. Director DENNIS J FZFS PHS THIOKOL SNVIROMMENTAL IAB M/S 245 PO BOX 707 BRIGHAM CITY UT a4302'0707 RECEIVED DEC t 2 1996 Thiokol Snvlfonmental Laboratory Fraser Laboratory 46 North Medical Drive Salt Lake City, Utah 84113-1106 l^lepbone: (801) 584-8400 Fax: (SOl) 684-8486 cusromer ID: Account NOI THIO 8018633524 On the basis of your most recent audit results and compliance with the SLOP requiremente> tha laboratory listed ie certified for envitonine^tal, nionitoring under the Safe Drinking Na^er Act and authorized to|perfbrm the following analytes, oi groups ]ofi analytea(by oethodi 'f i y CADNIU/4 CHROHIIIH 200. HETALS XNTIMOKY 200.9 ARSENIC 200.7A ARSENIC 200,9^ BARIUM 200.7 BERYLLlUH 200.7 200.9 .7 CHROMIUM 200.9 COPPER 200.7 COPPER 200.9 '•"•iRWli^ 200.7 ;••"•: LEAD 200.9 MANGANESE 200.7 MERCURY 245.1 HICKEL 200.7 SELENIUM 200.9 SILVER 200.7 * THALLIUN 200.9 ZINC SCO.7 MINERALS ALKALl'^ITY 310.1 CALCIL:-: 200.7 CHLORIpS 300.0 CONDUCVIVITY 120.1 0-PH0tip;4ATE 300.OA SODIUM 200.7 NUTRIENTS FLUORIDE 300.0 FLUORIDE 360.2 NITRAT& 300.OA NITRATE/NITRITE 300.OA NITRITE 300.OA SULFATE 37S.4 MISCELLANEOUS FOAKtiNS AQEMTli; «2S.1 PH 150.1 TD6-S0I.IDS '>60.1 TURSICITY ISO.I ORGAN :CC UNRECiULATEO BASE KEUTKAL-ACIDS 52S.1 - UN' CAR3AMA7E0 ^21.1 - UN CHL0R:I'JATED PI^STICIDES SOS-UN VOC "J 324.2 - UN ORGANIC:: nuai':j:-:20 BASE/»SU"fy,L£;';4CID8 S2S-1-RG CARBAIHiTlia S31.1 - RG CHLOR:'!«£ATfi: ?E37ICISE3 308-Rl PCS soa ANij yasA - RG VOC'S :;24.S - SG I * provisioiai certification This labcjratory's certification ie effective NOV 2i 1996. verify the moa: jurrent certificate letter for the The expiration li^ce for thfs leboratory's certification fs APR 30 'i'i^?3. The Utah i Enviroranntal Lniuratery Certification Prosram (ELCP^^e^@^^f;|^i^U.f-.-it3 and satalisers to •iiUI4,M,^r.%%N Pleasa call 801-584-8469. Mi^ ^!3II^ fiPR 02 '97 li:49firi THIOKOL R&D p ^^y Page Two THIOKOL ENVIRONMENTAL LAB DEC 06 1996 Safe Drinking Water Act The analytes or groupa of analytes by method which a laboratory is authorised to perforin at any given time will be those indic&ted in "bhe most recent certificate letter. The most rsoent certification letter supersedes all previous eartification os authorization letters- AiV/ discrepancies must be documented an.i. notice raceivcsd by this Bureau within IS days of receipt. The certification v^ill b@ i^ecalled in the event that your Laboratory's certification is revoked. Respectfully, r Charles .;jrokopp, Or. P.H. Oirector ce. Utar. Department of Environmental Quality Kevin W. Brown - Division of Drinkirig Water Oennis Downs - Division of solid and Hazardous Wasts Don A. Ostler - Divieion of Water Quality U.S. BPA Region viii QAO The expiratfo,-i date fer this laboratory's certification is APR 30 1998. The Utah . Environmental Laboratory Certification Proaram (ELCP) encourages ei;ents an^ data users to verify the meat current certificate letter for the authorized method. Please call 801-584-8469. fiPR 02 '97 ll:49fiM THIOKOL R&D P. 4/7 Utah Department of Health l;l'>-!S:OV 1>1-' L'l'IIJUMIOKiOY ASr> I..\»OR.vTOR.Y )5EH\'lc;I!S AUG 27 1996 State ofUtah Michael O. Leavitt Oiivpmor RodUBetit Bxc-MtivB Diiwiiir Charles a Brokopp, I>r. Rii nin,i.ti;r £cew£^ Bureau of Laboratory Improvement 4(> N'.!Vth Medical Drive Suit Lake Citv, Utah S-iUo-llOS Tek'phune;l801i5S4.84(59 Fii.\;i801i3?4-8501 OENNIS J FIFE PHD THIOKOL ENVIRONMENTAL LAB M/S 245 PO BOX 707 BRIGHAM CITY UT 84302-0707 SW^' «96 •^^^^i Customer ID: Account No: , THIO 8018633524 On the basis of your rscst recent audit results and compliance with the ELCP requirements, the laboratory listed ie certified for environmental monitoring under the Resource Conservation and Recovery Act and authorised to perform the following analytes, or groupa of analytes by methodj METALS j I ALUMINUM 601OA ANTIMONY 6010A ARSENIC 601OA ARSENK 7060 BARIUM 6010A BERYLLIUM 6010A CADMIUM 601QA CADMIUM 7131 CHROMIUM 60IOA COBALT 601OA COPPER 601OA IRON 601OA LEAD 601OA LEAD 7421 MANGANESE 6010A MERCURY 7471 MOLYBDENUM 601OA UIC!CSL"6C1QA SELENIUM 6010A SILVER 6010A THALLIUM 6010A THALLIUM 7841 VANADIUM 60IOA ZINC 6010A MINERALS BORON 6010 CALCIUM 6010A SODIUM 601QA MISCELLAKEOUS AROMATIC VOLATILE ORG 8020 CHLORIDE 9056 CHLORIDES 92S1 CHLORIDSS 92S2 CHLORINATED HERBICIDES Q1S0B CYANIDE TOTAL/AMENABLE 9012 FLUORIDE 9:S6 IGNITA3!L1"',' 1010 NITRAT; 9054 NITRATE 9200 NITRITE 905i OIL 6 GilSASi 9070 ORQANOCHl. ?1'3T 3080 PCB aoso PH 9Ql>0 Pf. 9045 PHENOLICS 9J6a SJMIVOLATUiiS 82703 SPECIFIC CONDUCTANCE 9050 SULFATi 905.i . SULFATES 9033 . SUL f I SSS '}:.i;3 TCL? !^!:TA: 1311 TOLP SiMi-VOLATILE 1311 . TCLP V3LA-;„£ 1311 TOTAL ORG,;;.;: CARBON 9060 The expiration date for this laboratory's certiflcsrfor, is A?R 30 '9?S. The Uiah Envfronmental Laboratory Certification Program (ELCPj-fe.iccursses iLients snd data users to verify the most current certificate letter for the authorized mathod. Plesse call 801-586-8469. fiPR 02 '97 ll:50ftM THIOKOL R&D ) P.5/7 Page Two THIOKOL ENVIRONMENTAL LAB AUG 27 1996 Resource Conservation and Recovery Act HAGNESIUM 6010A VOLATILES 8260A POTASSIUM 6010A This laboratory's certification is effective AUG 26 1996. , The analytes or groups of analytes by method which a laboratory is authorized to perform at any given time will be those indicated in the most recent certificate letter. The most recent certification letter supersedes all previous certification or authorization letters. Any discrepancisB must ba documented and notice received by this Bureau within 15 days of receipt. The certification will be recalled in the event that your Laboratory's certification is revoked. Respectfully, Charles Brokopp, Dr. P.H. Director oe, Utah Department of Environmental Quality Kevin w. Brown - Division of Drinking Water Dennis Downs - Division of Solid and Hazardous Waste Don A. Ostler - Division of Water Quality U.S. EPA Region VIII QAO The expiration date for this laboratory's certification ts APR 30 1998. The Utah Envirornientel.Laboratory Certification Program (ELCP) encourages clients and data users to verify the most current certificate letter for the authorized method. Plaase call 801-5B4-8469. APR 02 '97 ll:50ftM THIOKOL R&D State ofUtah p. 6/7 iUtah Department of Health ;);\ISI(JN or l;PU)):.viiu[,oc;v ANP I.J\1JOR.\TORY SI;R.VICnS AUG 27 1996 Mich^ielO. Leavitt GiivcTTior fiodLBetit ExwuSvft Dilwuir ChiirlQs D. Brokopp, X>r. P.U. DiTWtor DENNIS J FIFE PHD THIOKOL ENVIRONMENTAL LAB M/S 245 PO BOX 707 BRIGHAM CITY UT 84302-0707 RECEIVED SEP O'I 1996 TJiickP' Hnvii'O'inQentai Bureau of Laboratory Improvement 46 North Medical Drive Salt Lake City, Utah 84113-1103 Telephonc;(801 ».'384.84f5i) Fax;!801) 584-8501 Customer ID: Account Mo: THIO 8018633524 On the basis of your most recent audit results and ccmpliance with the ELCP requirements, the laboratory listed is certified for environmental monitoring under the Clean Water Act and authorized to perform the following analytes, or groups of analytes by method: HETALS ALUMINUM 200,7 ANTIMONY 200.7 ANTIMONY 204.2 ARSENIC 200.7 ARSENIC 206.2 BARIUM 200.7 BERYLLIUM 200.7 CADMIUM 200.7 CHROMIUM 200.7 COBALT 200.7 COPPER 200.7 IRON 200.7 LEAD 200.7 LEAD 239.2 MANGANESE 200.7 MERCURY 245.1 NOLYBOENUM 200.7 NICKEL 200.7 SELENIUM 200.7 . SELENIUM 270.2 SILVER 200.7 THALLIUM 200.7 TIN 200.7 VANADIUM 200.7 ZINC 200.7 MINERALS ACIDITY 305.1 NUTRIENTS ANMONIA 350.1 AMMONIA 350.3 NITRATE/NITRITE 353,2 NITRITE 354.1 ORTHOPHOSPHATE 365.1 ORTHOPHOSPHATE 365.2 PHOSPHORUS 365.2 PHOSPHORUS 365.6 SULFATE 375.^ • TICM 351.i RESIDU:- • RESIDUE fILTERABLE TDS 160.1 RESIDUE MONPILT TSS 160.2 RESIDUE TOTAL 160.3 DEMAND BOD 405.1 COO HACH TOC ilS.1 ORGANIC BA5E/HEUTRA> S i ACIDS 625 ORG COMP NONPEST 601 ORG COMP NONPEST 602 ORGAi^JOCHLOR PCS 403 PEST 608 The expiration date for this laboratory's certification is APR 3C 1998. The Utah Environnental Laboratory Certification Pregrani (ELCP) encourages clients and dats users to verify the most current certificate letter for the authorized method, please call 801•584-8669. APR 02 '97 li:50flM THIOKOL R&D p. 7/7 Page Two THIOKOL ENVIRONMENTAL LAB AUG 27 1996 Clean Water Act ALKALINITY 310.1 BORON 200.7 CALCIUM, 200.7 CHLORIDE 325.2 FLUORIDE 360.2 HARDNESS 130.2 HAGNESIUM 200.7 PH 150.1 POTASSIUM 200.7 SODIUM 200.7 SPECIFIC CaNOUCTA.NCE 120.1 SULFIDE'376.1 PURGEABLE AROMATIC 602 PURGEABLE HALOCARBONS 601 PURGEABLES 624 INORGANIC CL TTL RES 4500CL G '•• COLOR 110.2 CYANIDE 335.3 OtL ANO GREASE 413.1 PHENOLS 420.2 SURFACTANTS 425.1 TURBIDITY 180.1 * Provisional Certification This laboratory's certification is effective AUG 26 1996. The analytes or groups of analytes by method which a laboratory is authorized to perform at any given time will be those indicated in the most recent certificate letter. The most recent certification letter supersedes all previous certification or authorization letters. Any discrepancies must be documented and notice received by this Bureau within 15 days of receipt. The certification will be recalled in the event your Laboratory's certification is revoked. Respectfully, Charles Brokopp, Dr. P.H. Director cc. Utah Department of Environmental Quality Kevin W. Brown - Division bf Drinking Water Dennis Downs - Division of Solid and Haaardous Waete Don A. Ostler - Division of Water Quality U.S. EPA Region VIII QAO The expiration date for this laboratory's certification Is APR 30 1998. The Utah Environmental Laboratory Certification Prcgram (ELCP) v'-ncouragps clients and data usars to verify the most current certificate letter for th« authorized method. Please call BOI-S84-B4-j9.