DSHW-2024-008155

Karen Wallner <[e-mail]>
FW: Investigation Request for Site N002 at the UTTR
1 message
TEVAULT, ELIZABETH A CIV USAF AFMC AFCEC/CZOM <[e-mail]>Thu, Jul 25, 2024 at 8:48
AM
To: Karen Wallner <[e-mail]>
Cc: "TEVAULT, ELIZABETH A CIV USAF AFMC AFCEC/CZOM" <[e-mail]>, "LOUCKS, MARK D CIV
USAF AFMC AFCEC/AFCEC/CZOM" <[e-mail]>, "BURTON, AMANDA C CIV USAF AFMC 75 CEG/CEIE"
<[e-mail]>, "NIEMAN, JOCHIM KARL C CIV USAF AFMC 75 CEG/CEIE"
<[e-mail]>, "DEVORE, DOUGLAS E II CIV USAF AFMC 75 ABW/JA" <[e-mail]>,
"BYRK, MICHAEL J CIV USAF AFMC 75 CEG/CEIEA" <[e-mail]>, Paige Walton <[e-mail]>,
"GUTIERREZ, NEYDA V CIV USAF AFMC AFCEC/CZRX" <[e-mail]>
Hello Karen,
I want to provide an update on the soil piles at N002. Hill AFB 75 CEG has contacted several units that use the UTTR and they have
not been able to determine the source of the soil piles at N002. There was also an aempt to gather informaon about who might
have been near the site between April and August 2023 (based on April 2023 inspecon with no piles and August 2023 Google Maps
satellite imagery showing piles) by reviewing Hill Range Control radio transmission records. However, radio transmission records are
only kept for six months so they no longer exist for this period.

Since AFCEC and Hill 75 CEG have not been able to determine a source, we decided to involve Hill AFB 75th Security Forces (SFS).
The email below is a request for an invesgaon into the soil piles. Aached are photos that were provided with the request. I’ve
also aached a copy of the 75 SFS Bloer Entry. I will let you know as the invesgaon proceeds.

Please let me know if you have any quesons.
Thank you,
Elizabeth

ELIZABETH TEVAULT, P.E., DAF
AFCEC/CZOM Hill Secon / Remedial Project Manager
DSN 777-3804 / Comm [phone]

From: BURTON, AMANDA C CIV USAF AFMC 75 CEG/CEIE <[e-mail]>
Sent: Tuesday, July 16, 2024 2:20 PM
To: COX, DOUGLAS S TSgt USAF AFMC 75 SFS/S2 <[e-mail]>; MOORE, TYLER E Capt USAF AFMC 75 SFS/S3
<[e-mail]>
Cc: FENG, PETER P CIV USAF AFMC 75 CEG/CL <[e-mail]>; BATES, IVONNE M CIV USAF AFMC 75 CEG/CEI
<[e-mail]>; NIEMAN, JOCHIM KARL C CIV USAF AFMC 75 CEG/CEIE <[e-mail]>;
TEVAULT, ELIZABETH A CIV USAF AFMC AFCEC/CZOM <[e-mail]>; DEVORE, DOUGLAS E II CIV USAF AFMC 75
ABW/JA <[e-mail]>; LINFORD, JOSEPH G CIV USAF AFMC 75 ABW/JACE <[e-mail]>
Subject: Invesgaon Request for Site N002 at the UTTR

BLUF: Investigation request for illegal dumping of 42 piles of soil and debris on the Utah Test and Training
Range (UTTR); violation and six-figure fine expected from Utah Department of Environmental Quality (UDEQ) as a
7/25/24, 9:42 AM State of Utah Mail - FW: Investigation Request for Site N002 at the UTTR
https://mail.google.com/mail/u/0/?ik=390e15a6ba&view=pt&search=all&permthid=thread-f:1805562945929753138&simpl=msg-f:1805562945929753138 1/5
result.

SUPPORTING INFO/CONTEXT:

Subject: Violation at RCRA Corrective Action Solid Waste Management Unit (SWMU) 2 (Site N002), Utah
Test and Training Range
Date: 11 July 2024
SUMMARY: On 15 April 2024, during annual inspection of the Hill Air Force Base (AFB) Resource Conservation
and Recovery Act (RCRA) long term management (LTM) solid waste management units (SWMU) located on the
UTTR, the inspection team discovered 42 soil piles had been added to SWMU 2. This is in violation of Site
Management Plan (SMP) land use controls which do not allow for soil disturbance and is in violation of posted
warning signs which specify that dumping is not allowed. We anticipate a violation from the state of Utah as a
result, which will include a fine that we estimate will be in the six figures range.

BACKGROUND: AFCEC CZOM Hill ISS manages 25 RCRA SWMUs representing 35 locations spread across
the UTTR. The SMP stipulates land use controls at all SWMUs including.
· Signage stating no dumping allowed by order of Base Commander,
· Corner markers to define “No Dig” areas.
· Land use restrictions to prevent unauthorized construction, grading, excavation, or other soil
disturbance activities.
· Site inspections to verify site conditions remained unchanged.
· Annual reporting of any findings following site inspections.

On 15 April 2024, an annual UTTR RCRA inspection was conducted accompanied by UDEQ. At location SWMU
2 (site N002, CBU Valley Disposal Trenches), the team encountered 42 soil piles that had been dumped at the
site. The piles could not be immediately examined because of unexploded ordnance (UXO) escort requirements
at this SMWU. On 16 April 2024, the soil piles were examined, along with a UXO escort, and all were within the
boundary of the SWMU’s corner markers. Wood and metal construction/target type debris was observed (i.e.
rebar and lumber) in several piles, as well as indeterminant metal debris. The UXO escort also located a single
live 20 mm round on the surface of one pile.

SWMU 2 was previously inspected on 17 April 2023, and the soil piles were not present at that time. Using a
Google Maps satellite image from August 2023, it can be seen that the soil piles were in place by that time. So it
can be concluded that the soil piles were dumped sometime between April and August 2023.

DISCUSSION: On 22 April 2024, follow-up notice was sent to UDEQ with pictures and a description of the piles,
and steps being taken to identify who dumped the piles and where they came from. In a call with UDEQ, the
parties agreed that the first step in a way ahead is to characterize the piles, preferably by finding out where they
were excavated. If unable to find the source of the soil piles, they will likely need to be sampled for
characterization. Whether the piles will need to be moved off site or if they will become part of the SWMU is yet
to be determined. A notice has also been sent to UTTR personnel not to move/touch the piles until a way ahead
is determined.

Hill AFB 75 CEG has contacted several units (75 CES, 388 FW, UTTR/HQ, 309 MMXG [309 582nd MMXS]) to try
and identify who is responsible for dumping the piles and where the soil was excavated. There was also an
attempt to gather information about who might have been near the site between April and August 2023 by
7/25/24, 9:42 AM State of Utah Mail - FW: Investigation Request for Site N002 at the UTTR
https://mail.google.com/mail/u/0/?ik=390e15a6ba&view=pt&search=all&permthid=thread-f:1805562945929753138&simpl=msg-f:1805562945929753138 2/5
reviewing Hill Range Control radio transmission records. However, radio transmission records are only kept for
six months so they no longer existed for this period.

AFCEC/CZOM and 75 CEG/CEIE are working on preventative actions, such as ways to better educate UTTR
and base personnel about our environmental restoration sites and the associated requirements and restrictions.
Informational slides have been prepared to add to various UTTR and base briefings, such as the UTTR Range
Safety Brief.

This issue will be included in the 2024 RCRA Management Activity Report for annual SWMU inspections, which is
eventually sent to UDEQ. However, AFCEC/CZOM will continue to provide updates to UDEQ leading up to
production/review of that report.

Coordinates: 41.09150050122742, -113.01950262705489 (see aerial image below)

POC: Ms. Elizabeth Tevault, AFCEC/CZOM, DSN 777-3804

Respectfully,

Amanda Burton
Chief, Environmental Branch
75 CEG/CEIE, Hill AFB, UT
DSN: 775-3647
Cell: [phone]

8 attachments
7/25/24, 9:42 AM State of Utah Mail - FW: Investigation Request for Site N002 at the UTTR
https://mail.google.com/mail/u/0/?ik=390e15a6ba&view=pt&search=all&permthid=thread-f:1805562945929753138&simpl=msg-f:1805562945929753138 3/5
Photo from NE Corner Marker looking into N002.jpg
2041K
Photo from NW Corner Marker looking into N002.jpg
1656K
Photo of 20mm Round.jpg
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Photo of Debris Lumber.jpg
1616K
Photo of Debris Rebar.jpg
1524K
7/25/24, 9:42 AM State of Utah Mail - FW: Investigation Request for Site N002 at the UTTR
https://mail.google.com/mail/u/0/?ik=390e15a6ba&view=pt&search=all&permthid=thread-f:1805562945929753138&simpl=msg-f:1805562945929753138 4/5
Photo of No Dump Sign next to Soil Piles.jpg
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Site N002 Aerial Image.png
1702K
75 SFS Blotter Entry Illegal Dumping.pdf
243K
7/25/24, 9:42 AM State of Utah Mail - FW: Investigation Request for Site N002 at the UTTR
https://mail.google.com/mail/u/0/?ik=390e15a6ba&view=pt&search=all&permthid=thread-f:1805562945929753138&simpl=msg-f:1805562945929753138 5/5