DSHW-2007-004782 - 0901a06880156f2d

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ASSOCIATES
February 8, 2007
Mr. Dennis R. Downs, Executive Secretary
Division of Solid and Hazardous Waste
Utah Department of Environmental Quality
P.O. Box 144880
Salt Lake City, UT 84114-4880
RE: Work Plan for Investigation of TCE Source Area, Nature, and Extent, in the
Vicinity of Buildings H-3 through H-7, Freeport Center, Clearfield, Utah
Dear Mr. Downs:
Freeport Center Associates (FCA) is submitting this letter to notify the Utah Department of
Environmental Quality (UDEQ) of a pending investigation planned for the above-referenced
facility in Clearfield, Utah (Figure 1). FCA is working in conjunction with ATK Launch Systems
(ATK) to investigate the source area(s), nature and extent of chemicals in soil and groundwater.
ATK has accepted responsibility for 1,1,1-trichloroethane (1,1,1-TCA), its daughter product 1,1-
dichloroethene (1,1-DCE), and related compounds. Based on previous property use, we believe a
different former tenant is responsible for tetrachloroethene (PCE) impacts at the south end of
Building H-5.
As property owner and landlord, FCA is seeking to identify the source area(s) and responsible
tenant(s) for trichloroethene (TCE) impacts. This work plan outlines efforts to be undertaken by
FCA to investigate the source, nature, and extent of TCE impacts.
Background
Although not the primary contaminant of concern in the subject plume area, TCE has been noted
in some of the samples, and is primarily found in the northem portion of the area. Sample
locations where TCE has been detected in groundwater to date are shown in Table 1, along with
maximum detected concentration and frequency of detects. TCE appearing in wells U-1 through
U-12 after the initial round of sampling may have been the result of improper purging and
decontamination procedures used in subsequent rounds. Due to potential cross-contamination, the
detected concentrations in wells U-1 to U-12 are suspect and were not included on a map of TCE
distribution (Figure 2). The source of, and responsible party for, the TCE plume are unknown.
P.O. Box 160466 Clearfield, Utah 84016-0466 [phone]
FAX [phone]
Work Plan for TCE Investigation
Vicinity of Buildings H-3 Through H-7
Freeport Center, Clearfield, Utah
February 8, 2007
Page 2 of 4
Project Objectives
Specific objectives ofthe proposed investigation are as follows:
Investigate potential source area(s) and potentially responsible parties of TCE impacts by
collecting and analyzing limited additional soil and groundwater samples.
• Investigate nature and extent of TCE impacts by collecting and analyzing additional
groundwater samples.
Specific Planned Investigation Activities
The following investigation activities are planned for the additional investigation:
• Conduct direct-push soil and groundwater sampling at 11 locations in or up gradient from
the trailing edge ofthe known plume (Figure 2) to assess potential TCE source areas.
• Conduct direct-push groundwater sampling at 2 locations down gradient from the leading
edge of the known plume (Figure 2) to assess the nature and extent of TCE impacts in
groundwater.
• Compile and interpret all TCE information from previous studies, this study, and ATK's
current studies to assess source area(s), namre, and extent of TCE impacts.
Sampling and Analysis Plan
Sample Locations
Figure 2 shows the proposed general locations for the 13 direct-push sampling locations. These
locations will be marked in the field and will be surveyed using a real-time submeter-accuracy
Global Positioning System (GPS).
Direct-Push Sampling
All 13 borings will be logged according to soil types penetrated, using the Unified Soil
Classificafion System field identification methods. The depth to the first occurrence of
groundwater will also be noted on the field logs.
Soil samples will be obtained confinuously in 1.5" x 4' clean disposable sample liners to a depth
of 8-12 feet in up-gradient locations and to a depth of 16-20 feet in down-gradient locafions.
Work Plan for TCE Investigation
Vicinity of Buildings H-3 Through H-7
Freeport Center, Clearfield, Utah
February 8, 2007
Page 3 of4
Each liner will be opened, and the soil will be immediately screened with a photoionizafion
detector (PID) to qualitafively measure the presence of volafile organic compounds. Soil samples
for analysis will be collected from any impacted interval, based on PID, olfactory, or visual
evidence. If impacts are not observed, the sample will be taken from 0-2 feet below ground
surface in the up-gradient locafions to assess potential source areas, and at the capillary fiinge in
down-gradient locafions. A total of 13 soil samples will be obtained, plus two duplicate samples
for quality assurance puiposes.
Each boring will be extended into groundwater and a groundwater sample will be obtained using
a peristahic pump and disposable mbing inside a direct-push groundwater sampling screen. After
sampling, the borings will be filled with bentonite chips or bentonite grout and patched to match
existing surface cover. A total of 13 groundwater samples will be obtained, plus two duplicate
samples for quality assurance purposes.
Quality Assurance Samples
Two duplicate soil and two duplicate groundwater samples will be collected. In addifion, one trip
blank per cooler will be submitted.
Sample Preservafion, Handling, and Shipping
Soil samples will be packed in laboratory-supplied glass jars to minimize headspace, capped with
a Tefion-lined lid, and placed immediately on ice for preservation. Groundwater samples will be
placed in 40-ml vials with zero headspace, preserved with hydrochloric acid to pH less than 2,
and placed immediately on ice. Chain-of-custody documentafion will be initiated as each sample
is collected and will accompany the samples through analysis at the laboratory. All samples will
be shipped via ovemight courier to Sevem Trent Laboratories (STL) in Arvada, Colorado for
analysis.
Decontamination
All direct-push probing equipment that enters the subsurface will be decontaminated according to
the following general procedures:
1. Steam clean with potable water or pressure wash with non-phosphate detergent.
2. Rinse with potable water.
All non-disposable sampling equipment will be decontaminated according to the following
general procedures:
1. Wash with non-phosphate detergent and potable water.
2. Rinse with potable water.
Work Plan for TCE Investigation
Vicinity of Buildings H-3 Through H-7
Freeport Center, Clearfield, Utah
February 8, 2007
Page 4 of4
Rinse with distilled or deionized water.
Analytical Program
All soil and groundwater samples will be analyzed for volafile organic compounds (VOCs) by
SW846 Test Method 8260B.
Reporting
FCA will document the investigation in a letter report to the Utah Department of Environmental
Quality (UDEQ). The report will include work perfonned, results, analysis, and discussion.
Boring logs, figures, and tables will also be provided.
Schedule
This work will begin within 3 weeks of receipt of approval ofthis Work Plan from UDEQ. Field
work will take up to 4 weeks to complete, depending on subcontractor availability. Analytical
data will be available 3 weeks after the last samples are collected. The report will be finalized 4
weeks after receipt of all analytical data. FCA will complete the work in conjunction with ATK.
Please contact me at your convenience ifyou have any questions on this matter.
Sincerely,
FREEPORT CENTER ASSOCIATES
\S^ Q. YliyL^
Betty J. Parker
Property Manager
Attachments:
Table 1 - TCE Detected in Groundwater
Figure 1 - Freeport Center Map
Figure 2 - TCE Invesfigation Area
cc: Brett Mustoe - URS
Paul Hancock - ATK
Figure 1.
Location IVlap
Freeport Center
Clearfield, Utah
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