DERR-2024-011267

195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144840 • Salt Lake City, UT 84114-4840
Telephone [phone] • Fax [phone] • T.D.D. [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-138-24
September 5, 2024
Jeremy Bell
Crossroads of the West Council of the Boy Scouts of America
1200 East 5400 South
Ogden, Utah 84403
Bryan Torgerson
State of Utah School and Institutional Trust Lands Administration
P.O. Box 215
Monticello, Utah 84535
RE: Moab Base Camp Voluntary Cleanup Site #C133, Moab, Grand County, Utah
Dear Messrs. Bell and Torgerson:
The Division of Environmental Response and Remediation (DERR) has reviewed the following
document as required by the provisions of the Voluntary Cleanup Program (VCP):
Site Assessment, dated April 22, 2024.
This document is considered the Environmental Assessment (EA) for the Site under the VCP.
Based on a review of the document, the DERR has enclosed technical comments to gather additional
information about the Site and associated environmental conditions in advance of evaluating a remedy
for the property.
Please address the comments and submit a Quality Assurance Project Plan, and Site
Characterization Workplan for review. Thank you for your participation in the VCP.
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If you have any questions, please contact me at [phone].
Sincerely,
Allison Stanley, Project Manager
Division of Environmental Response and Remediation
AS/ tt
Enclosure: Technical Comments
cc: Kirk Kyster, MT2
Brady Bradford, Health Officer, Southeastern Utah District Health Department
Orion Rodgers, Environmental Health Director, Southeastern Utah District Health Department
Curtis Page, District Engineer, Utah Department of Environmental Quality
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DERR Comments for Environmental Assessment
Moab Base Camp VCP Site #133
General Comments:
1. Please submit a Quality Assurance Project Plan (QAPP), ensure the QAPP addresses
elements required in EPA’s QAPP guidance and includes a Level 3 Reporting Package for
all analytical data generated for the project. The Level 3 Reporting Package should include
a case narrative, all analytical results and qualifiers, surrogates, and batch Quality Control
(QC) results (Matrix Spike/Matrix Spike Duplicates, Lab Control Samples, Method Blanks,
etc.). Additionally, please ensure that the laboratory reporting limits are below the proposed
screening levels.
2. Since the Site has not been sampled, please submit a Site Characterization Workplan (SCW)
consistent with the fact sheet contained in the link, proposing a strategy to characterize the
Site and define the nature and extent of impacts. Among other locations at the Site, areas of
interest include the berms, firing lines, drainages, and locations of possible lead shot and
clay pigeon fragments. Please note that contamination, if any, associated with the Site, that
goes beyond the Site boundaries will need to be addressed under the VCP.
3. Analytical data in the Voluntary Cleanup Plan (VCP) are typically screened against current
EPA Regional Screening Levels (RSLs), Initial Screening Levels (for TPH and TRPH), and
Maximum Contaminant Levels (MCLs). Please include these criteria in the requested
documents as applicable.
4. Along with lead, other metals can be present in the bullet jacket (zinc, copper) and to
increase the hardness of the bullet (antimony, arsenic, tin, and iron). Additionally, polycyclic
aromatic hydrocarbons (PAHs) can be present in certain types of clay pigeons. Based on the
history of the Site, please include these metals and PAHs in the proposed analytical suite.
5. To help better characterize the Site and the metals concentrations, the DERR recommends
collecting samples away from the shooting areas to help establish background conditions.
This can be pertinent for arsenic.
6. To help justify the sampling from the shotgun range, please provide a map that identifies the
location of clay pigeon fragments and expected distances of the lead shot from the firing
line.
7. Based on the August 1, 2024 site visit, it is possible that lead shot could also be slightly
below the surface since the open field consists of sandy soil. Please propose sampling at
both the surface (0-2 inches) and a little deeper to characterize this portion of the site.
8. To assist with the proposed sampling, please indicate in the SCW if the soil in the rifle range
berm has ever been mixed or rotated during the range’s history. This information may
impact the depth and frequency of the samples along and within the berms.
9. Based on the current land use (scout camp used for approximately two months out of the
year) and lack of nearby targets, the Applicants are proposing to screen the Site against
commercial/industrial screening levels. The commercial/industrial exposure scenario was
memorialized in the Voluntary Cleanup Agreement (VCA) signed by the parties. If the land
use and exposure scenario changes, please notify the DERR as soon as possible so the
screening levels can be adjusted during site characterization.
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10. The VCA memorializes the Site as the entire Moab Base Camp (41.6 acres). It is the DERR’s
understanding that the Applicants intend to only characterize and remediate the portion of
the Site that was formerly a shooting range. If the goal is to amend the VCA, the nature and
extent of contamination should be defined and an updated legal description with metes and
bounds should be provided. The VCA would need to be amended based on this information.
Please work with the DERR regarding this matter.
11. Please keep the DERR apprised of the schedule for field work so the DERR can be on-site
to oversee the work and to collect split samples. Please note that under the VCP, the DERR
will collect split samples, to be analyzed at a separate laboratory from the main laboratory
selected for sample analysis, as an independent quality assurance measure. The Applicant is
responsible to pay for the analytical costs of the split samples. Please designate and set up a
laboratory for analysis of split samples.
12. Please note that agency acceptance and a 30-day public comment period are necessary prior
to implementing any proposed remedial action under the VCP. Public comments, if any,
must be addressed prior to beginning a remedial action. The Site should be sufficiently
characterized prior to proposing a Remedial Action Plan.
End of DERR EA Review Comments