DERR-2024-008871

195 North 1950 West
Mailing Address: P.O. Box 144840 Salt Lake City, UT 84114-4840
Telephone [phone] ) 359-8853 [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor
DEIDRE HENDERSON
Lieutenant Governor
Department of
Environmental Quality
Kimberly D. Shelley
Executive Director
DIVISION OF ENVIRONMENTAL
RESPONSE AND REMEDIATION
Brent H. Everett
Director
ERRC-007-23
January 20, 2023
Ryan Dunham
Site Assessment Manager
U.S. EPA Region 8 (8EPR-B)
1595 Wynkoop Street
Denver, Colorado 80202-1129
Dear Mr. Dunham:
Enclosed for your review is a Sampling and Analysis Plan (SAP) for the Parowan Mine
Tailings located in Parowan, Iron County,
Approximately 47 tons of mine tailings are present at the Site, uncovered, and located on
top of uncovered ground. Samples collected from the tailings revealed concentrations of arsenic
(2,370 mg/kg), lead (48,900 mg/kg), and nickel (11.9 mg/kg) exceeding industrial soil Regional
Screening Levels (RSLs) of 3 mg/kg, 400 mg/kg, and 3.6 mg/kg, respectively. The Site does not
appear to have any active custodian or engineering controls in place to mitigate the migration of
contaminants off-site through windblown dust and surface drainage.
The Division of Environmental Response and Remediation recommends collecting
additional data through a limited sampling event to evaluate the need for EPA removal action. The
sampling event will include the collection of photographs, field measurements, and multi-point soil
composites in order to characterize the volume and composition of the piles.
Page 2
Thank you for your attention to this matter. If you have any questions, please contact me at
[phone], or via email at [e-mail].

Sincerely,

Wes Sandlin, Site Assessment Project Manager
Division of Environmental Response and Remediation

WS/lg

Enclosure(s): Parowan Mine Tailings Preliminary Assessment

ecc: Jeremy Roberts, Environmental Health Director, Southwest Utah Public Health Department
Paul Wright, District Engineer, Utah Department of Environmental Quality

SAMPLING AND ANALYSIS PLAN

Parowan Mine Tailings
Iron County, UT
UTN000821103

January 2023

SAMPLING AND ANALYSIS PLAN
Parowan Mine Tailings
Iron County, UT
UTN000821103
Utah Department of Environmental Quality
Division of Environmental Response and Remediation
Prepared by: Wes Sandlin
Approved: _______________________________________ Date: _________
Wes Sandlin, Project Manager
Approved: _______________________________________ Date: _________
Thomas Daniels, Site Assessment Section Manager
Approved: _______________________________________ Date: _________
Ryan Dunham, Site Assessment Manager, EPA Region 8

Sampling and Analysis Plan i
Parowan Mine Tailings UTN00821103
Table of Contents
1.0 INTRODUCTION AND BACKGROUND........................................................................... 1
2.0 OBJECTIVES ......................................................................................................................... 2
3.0 SAMPLING STRATEGY AND METHODOLOGY .......................................................... 2
3.1 Schedule of Work ................................................................................................................. 2
3.2 Safety .................................................................................................................................... 2
3.3 Site Access and Logistics ..................................................................................................... 2
3.4 Sampling Methods ................................................................................................................ 3
3.4.1 Composite Soil Sampling .............................................................................................. 3
3.4.2 Sub-Sampling ................................................................................................................. 4
3.4.3 Opportunity Samples ..................................................................................................... 4
3.5 Investigation Derived Wastes ............................................................................................... 5
4.0 QUALITY CONTROL AND ASSURANCE PROCEDURES ........................................... 5
5.0 REFERENCES ........................................................................................................................ 5

Sampling and Analysis Plan ii
Parowan Mine Tailings UTN00821103
LIST OF FIGURES
Figure 1
Figure 2
Figure 3
Figure 4
Figure 5
Figure 6
Figure 7
Site Location Map
Detailed Site Map
Proposed Sampling Locations
Tailings Piles A-B Aliquots
Tailings Pile C Aliquots
Tailings Pile D-F Aliquots
Background Aliquots
LIST OF TABLES
Table 1 Sample Summary
Table 2 Sample Analyses Checklist

Sampling and Analysis Plan
Parowan Mine Tailings UTN00821103 1

1.0 INTRODUCTION AND BACKGROUND
Under authority of the Comprehensive Environmental Response, Compensation and Liability
Act (CERCLA) of 1980, the Superfund Amendments and Reauthorization Act (SARA) of 1986,
and in accordance with the National Oil and Hazardous Substances Pollution Contingency Plan
(NCP), the Utah Department of Environmental Quality (UDEQ) Division of Environmental
Response and Remediation (DERR) has prepared this Sampling and Analysis Plan as part of a
limited sampling event for the Parowan Mine Tailings site (herein refe in
Parowan, Iron County, Utah. This limited sampling event will be conducted under a cooperative
agreement between the DERR, the United States Environmental Protection Agency - Region 8
(EPA), and the Tetra Tech, Inc. Superfund Technical Assessment and Response Team (START).
The Site includes one 1.48-acre property (Parcel ID: A-002-009-001) located at 385 East
Highway 271 in Parowan, Utah (Figure 1) (Iron County 2021). GPS coordinates for the Site are
approximately 37.854843 north, 112.821891 west. Elevation at the Site is approximately 5,920
feet above mean sea level (U.S. Geological Survey 2020). The property is located on the
northeast outskirts of Parowan, between the Parowan Airport and the Utah Department of
Transportation (Figure 2). Other nearby properties include the Parowan Senior Center, Harris
Custom Cabinets & Flooring Design Center, and a few residential homes.
In 2016, it was reported that 47 tons of mine tailings were transported from the Tennessee Mine
in Chloride, Arizona to the Site (Utah DEQ/DERR 2019). The transporter alleges that he was
originally solicited to deliver one million tons of material, but became concerned with the
legality of the operation on-Site and the potential environmental effects. Additionally, the
transporter claims that a metals processing facility may have operated at the Site without a
permit and without an approved hazardous waste management plan since 2015. It is unclear if
any refining or reprocessing has occurred at the Site. Following disputes between the transporter
and the solicitor, the transporter contacted the Parowan City attorney about the mine tailings,
who then filed an Environmental Incident Report (#14048) with the DERR in 2019 (Utah
DEQ/DERR 2019).
In June 2020, the UDEQ, Division of Waste Management and Radiation Control (DWMRC)
collected two samples from the tailings piles for analysis. Results show that antimony, arsenic,
cadmium, copper, lead, mercury, and nickel are present at elevated levels in the tailings, along
with traces of cyanide. These results, along with the Environmental Incident Report, initiated a
Preliminary Assessment (PA) for the Site that was completed by the DERR in July 2022 (Sandlin
2022). The PA concludes that there does not appear to be any active custodian or engineering
controls in place to mitigate the migration of contaminants off-Site. The fine-grained materials
can react with rainwater and leach hazardous metals and chemicals into soil and groundwater, be
carried off-Site via surface drainage in storm events, and generate metal-rich dusts that can be
transported by the wind.

Sampling and Analysis Plan
Parowan Mine Tailings UTN00821103 2

Currently, the tailings remain on-Site and continue to pose a risk to nearby residents. Further
sampling and inspection at the Site are needed to characterize the tailings piles and determine if
further assessment or EPA removal action is necessary.
2.0 OBJECTIVES
The objectives of the Sampling and Analysis Plan include the following:
Collect limited soil samples to characterize the composition the tailings piles on-Site;
Collect photographs and field measurements of the tailings piles to estimate the total
volume of tailings on-Site;
Inspect the Site for evidence of off-Site migration of contaminants via the surface water
and air pathways and collect photographs of any findings;
and, Determine if further assessment or EPA removal action may be necessary.
3.0 SAMPLING STRATEGY AND METHODOLOGY
3.1 Schedule of Work
Field work is tentatively scheduled for the s
approval of this sampling plan. Field activities are expected to last one day. Coordination with
the landowner/lessee, laboratories, and local health authority is ongoing and concurrent with this
sampling plan. All logistical functions will be arranged by the Project Manager in cooperation
with the EPA in advance of sampling.
3.2 Safety
Site sampling personnel will avoid direct dermal contact, inhalation, and ingestion with
potentially contaminated materials. Sampling will be conducted in Level D personal protective
equipment (PPE) unless the Site Health and Safety Officer, upon evaluation of Site conditions,
deems an upgrade necessary. A tailgate safety meeting will be conducted with all personnel prior
to the start of activities on the day of sampling. In the event of an accident, the nearest hospital is
the Cedar City Hospital located about 20 minutes away at 1303- N Main St, Cedar City, UT
84721.
3.3 Site Access and Logistics
Site access and logistical functions will be arranged by the Project Manager in advance of
sampling. Provisions for Site access will be arranged and the property owner will be asked to
obtain split-samples if requested. Coordination with the EPA contract laboratory and the local
health department will be arranged prior to Site activities. Sampling equipment and supplies will
be arranged by the Project Manager.

Sampling and Analysis Plan
Parowan Mine Tailings UTN00821103 3

3.4 Sampling Methods
Sampling will proceed according to methods outlined in the DERR CERCLA Quality Assurance
Project Plan (QAPP) of January 2020 and other relevant EPA guidance documents. Sampling
will include the collection of seven multi-point (10 aliquots) composite soil samples from six
piles located on-Site and one background location. From these composite samples, eight sub-
samples will be collected for laboratory analysis of target analyte list (TAL) metals and mercury
analysis (including one field duplicate), and eight sub-samples will be collected for toxicity
characteristic leaching procedure (TCLP) analysis (including one field duplicate). Up to ten
opportunity soil samples for TAL metals and mercury analysis may also be collected. Additional
sample volumes are not necessary for laboratory Matrix Spike/Duplicates. All sampling events
will be recorded in a field log book. All sample collection will proceed following strict chain-of-
custody procedures.
Additional field activities will include taking photographs and height measurements of the
tailings piles to assist with volume estimations. Since the tailings piles are roughly pyramid-
shaped, the volume of each pile can be estimated using the formula: . The surface
area of the base of the pyramid () can be calculated using the footprints of polygons in
ArcMap, and the height () of the pyramid can be measured in the field. These calculations will
be included in the Analytical Results Report.
3.4.1 Composite Soil Sampling
The DERR will collect multi-point composite soil samples to characterize the composition of the
tailings piles. Using imagery from Google Earth and observations from the field, the six piles
were outlined in ArcMap to generate polygon shapefiles. The Create Random Points tool was
then used to generate 10 aliquots within each polygon. Polygons and aliquot locations are shown
in Figures 2 7. Aliquot locations will be digitally loaded onto a phone or tablet for use during
field activities. Sampling personnel will use the phone or tablet linked to global positioning
system (GPS) equipment to navigate to each aliquot location.
One composite sample from each of the piles, and one composite from the background location,
will be produced from soil collected 0
location. All samples will be collected using single-use stainless steel spoons and will be forced
through a 2-millimeter sieve bag and into a one-gallon resealable plastic bag. The sample bags
will be labeled as follows:
TP-A-COMP
o TP = Tailings Pile (other option includes BGD (Background))
o A = Tailings Pile ID (other options include B F or no letter for Background)
o COMP = Composite sample

Sampling and Analysis Plan
Parowan Mine Tailings UTN00821103 4

Specific aliquot locations may be modified from the initial proposed location based on visual
observations during field activities (e.g., proposed aliquot location is on road fill). Sample-
specific observations will be recorded and photos may be taken. Composite samples will be
stored in the UDEQ Technical Support Center until the project is complete.
3.4.2 Sub-Sampling
Eight sub-samples will be collected from the soil composites for TAL metals and mercury
laboratory analysis, including one field duplicate. In addition, eight sub-samples will be collected
from soil composites for TCLP laboratory analysis, including one field duplicate. All samples
will be placed in 8-oz. glass jars and labeled as follows:
TP-A-COMP-TAL
o TP = Tailings Pile (other option includes BGD (Background))
o A = Tailings Pile ID (other options include B F or no letter for Background)
o COMP = Composite sample
o TAL = Target analyte list metals (other option includes TCLP)
All collected sub-samples will be shipped according to strict chain-of-custody procedures to a
contract laboratory where they will be analyzed for TAL metals and mercury using EPA Method
6010/6020/7471 and for TCLP analysis using EPA Method 1311. Standard detection limits and
turnaround times will be used.
3.4.3 Opportunity Samples
The DERR will bring an XRF analyzer in the field to screen the tailings piles and the property
. Up to ten opportunity soil samples (discrete grab samples from 0 s) may be
collected for TAL metals and mercury laboratory analysis. The GPS coordinates for each
opportunity sample will be recorded in a field log book and photographs will be taken at each
location. All samples will be placed in proper containers. The sample containers will be labeled
as follows:
OPP1-TAL
o OPP1 = Opportunity sample 1 (other options include OPP2 OPP10)
o TAL = Target analyte list metals (other option includes TCLP)
All collected opportunity samples will be shipped according to strict chain-of-custody
procedures to a contract laboratory where they will be analyzed for TAL metals and mercury
using EPA Method 6010/6020/7471. Standard detection limits and turnaround times will be
used.

Sampling and Analysis Plan
Parowan Mine Tailings UTN00821103 5

3.5 Investigation Derived Wastes
Investigation-derived wastes (IDW) are expected to consist of disposable sampling equipment
(e.g., stainless steel spoons, latex gloves, etc.) and will be removed from the Site and disposed of
as non-hazardous wastes.
4.0 QUALITY CONTROL AND ASSURANCE PROCEDURES
Samples will be handled as per the criteria of the QAPP (Palmer et al. 2020). Two field duplicate
samples will be collected for soil samples: one for TAL metals and mercury analysis and one for
TCLP analysis. Samples will be shipped to a contract laboratory registered under EPA's Certified
Laboratory Program (CLP) and analyzed as listed in the Sample Analysis Checklist (Table 2).
The chain-of-custody forms will be developed using SCRIBE software. Samples will be handled
and delivered to the CLP laboratory in accordance with chain-of-custody protocols and within
the appropriate holding times as defined by the QAPP.
The data package delivered from the CLP laboratory will be validated by an EPA contactor. The
analytical data will be compared to the appropriate benchmark values in the EPA Regional
Screening Levels table. This data will be used to determine whether the Site should be
recommended for further assessment or if EPA removal action is necessary. All data and
observations collected as part of this sampling plan will be included in the draft Analytical
Results Report and submitted to the EPA Region 8 for review and approval.
5.0 REFERENCES
https://www.arcgis.com/apps/webappviewer/index.html?id=4b8e40e3c17d45d282a2b151
5fbdd160.
lity Assurance
Program Plan for Environmental Data Operations for the CERCLA Branch, Final Plan -

-
U.S -
Topographic Quadrangles. 7.5-Minute Series.
- Parowan - Contaminated Mine

FIGURES

TABLES

Table 1. Sample Summary

No. of
Samples Matrix Location Purpose Depth(s) Analysis Sampling Method Analytical Method
7 Soil Aliquot locations Parent composites for sub-
sample collection 0- None Multi-point
composite None
7 Soil Sub-sample from soil
composites Evaluate metals composition 0- TAL
Metals/Mercury
Sub-sample of
composite
EPA Methods
6010/6020/7471
1 Soil (field
duplicate)
Sub-sample from soil
composites
Measure precision of field
sampling 0- TAL
Metals/Mercury
Sub-sample of
composite
EPA Methods
6010/6020/7471
7 Soil Sub-sample from soil
composites Evaluate leaching potential 0- TCLP Sub-sample of
composite EPA Method 1311
1 Soil (field
duplicate)
Sub-sample from soil
composites
Measure precision of field
sampling 0- TCLP Sub-sample of
composite EPA Method 1311
0-10 Soil TBD 0- TAL
Metals/Mercury Opportunity/Grab EPA Methods
6010/6020/7471

Table 2. Sample Analyses Checklist

TP = Tailings Pile
BGD = Background
COMP = Composite sample
TAL = Target Analyte List metals and mercury
TCLP = Toxicity Characteristic Leaching Procedure
02 = Field duplicate
OPP = Opportunity sample
Sample ID Matrix
Analyses QA/QC Other
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TP-A-COMP-TAL Soil X
TP-B-COMP-TAL Soil X
TP-C-COMP-TAL Soil X
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TP-A-COMP-TAL-02 Soil X X
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TP-A-COMP-TCLP Soil X
TP-B-COMP-TCLP Soil X
TP-C-COMP-TCLP Soil X
TP-D-COMP-TCLP Soil X
TP-E-COMP-TCLP Soil X
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TP-A-COMP-TCLP-02 Soil X X
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OPP1-TAL Soil X X
OPP2-TAL Soil X X
OPP3-TAL Soil X X
OPP4-TAL Soil X X
OPP5-TAL Soil X X
OPP6-TAL Soil X X
OPP7-TAL Soil X X
OPP8-TAL Soil X X
OPP9-TAL Soil X X
OPP10-TAL Soil X X