DSHW-2024-008792

Karen Wallner <[e-mail]>
FW: [Non-DoD Source] UTTR N002 Soil Piles Investigation Followup
2 messages
TEVAULT, ELIZABETH A CIV USAF AFMC AFCEC/CZOM <[e-mail]>Thu, Oct 10, 2024 at 3:26
PM
To: Karen Wallner <[e-mail]>
Cc: "NIEMAN, JOCHIM KARL C CIV USAF AFMC 75 CEG/CEIE" <[e-mail]>, "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]>, "BYRK, MICHAEL J CIV USAF AFMC 75 CEG/CEIEA" <[e-mail]>, Paige
Walton <[e-mail]>, "LEAR, CHRISTOPHER R CTR USAF AFMC 75 CEG/CEIE" <[e-mail]>,
"DEVORE, DOUGLAS E II CIV USAF AFMC 75 ABW/JA" <[e-mail]>
Hello Karen,
I have more informaon to provide on the weapons test site in the CBU Valley, the source of the soil piles that were
dumped at SWMU N002. The test site is located about a half mile from SWMU N002. In order to beer understand
the area, Karl Nieman (75 CEG), Chris Lear (75 CEG) and I visited the test site on 25 September 2024. Our team was
given a tour by 582 MMXS, who described the test operaons, and allowed us to view the detonaon of a 1000-
pound bomb.

The CBU valley test site is used to detonate general purpose bombs for aging and surveillance purposes. The site has
been in use for this purpose since 2018, with approximately 100 detonaons occurring since that me. Single bombs
are set up and detonated, with the detonaons analyzed using mulple cameras and sensors. Once a detonaon is
complete, the crater is backfilled, and the area is graded.

In 2023, 582 MMXS determined the test pad needed a new base because of over-compacon due to repeated
detonaons. They asked 75 CEG to dig out the pad and replace the soil with sand. 75 CEG agreed and completed this
task during a me when no tesng was taking place, so the pad was not in use, and 582 MMXS personnel were not in
the area during the movement of soil. This was the first me soil has been removed from the test pad and there has
never been any soil sampling completed associated with the 582 MMXS tesng. A 332 was not submied for the soil
disturbance and the UXO risk was not evaluated by Hill AFB Explosive Ordnance Division (EOD) prior to moving the
soil.

Useful informaon in characterizing the soil piles at N002 is that the only explosives associated with the 582 MMXS
bomb tesng has been Tritonal or PBXN-109. All bomb tesng conducted at the site results in high-order detonaons
iniated with the bomb’s fusing mechanism (unlike a disposal operaon which is usually iniated from outside the
munion’s casing). High-order detonaons result in complete consumpon of the munions propellant. The 582
MMXS has not experienced a low-order detonaon during the tesng at this site. The wood and metal seen in the
soil piles are from stands and sacrificial equipment that are expended during detonaons. The Unexploded Ordnance
(UXO) in the form of a 20 mm round observed on the surface of one pile did not come from the 582 MMX bomb
tesng. There are 20 mm rounds (expended and unexpended) throughout this enre CBU Valley area from tesng
which occurred in the 1990s. The 20 mm round was likely pulled up with subsurface soil when 75 CEG was excavang
the pad, and there is a chance there could be more in the soil piles due to the expanse of the 1990s tesng.

10/15/24, 9:43 AM State of Utah Mail - FW: [Non-DoD Source] UTTR N002 Soil Piles Investigation Followup
https://mail.google.com/mail/u/0/?ik=390e15a6ba&view=pt&search=all&permthid=thread-f:1812563861205457902&simpl=msg-f:18125638612054579…1/7
AFCEC and Hill AFB recommend leaving the soil piles in place at SWMU N002. Aer speaking with Hill EOD, they
agree there is a potenal UXO risk with moving the piles. Moving them also doesn’t reduce risk in general since the
enre CBU Valley has a similar potenal of UXO (20 mm rounds) presence. Regardless of any chemical constuents,
the piles could not be disposed of offsite (i.e. Grassy Mountain) without siing the soil to remove potenal UXO.
Regarding the specific risk evaluated for SWMU N002, the Final Risk Assessment Report (RAR), RCRA Sites, Utah Test
and Training Range – North (May 2023) concluded that the RCRA UXO sites cannot be adequately sampled for a
chemical risk evaluaon, nor would it be safe to remediate the sites, due to the presence of UXO. Therefore, these
sites defaulted to site management. The RAR also noted that UXO at these sites could potenally be comingled with
range and target debris, other metal and chemical materials used in tesng and training at the range (fuels, etc.), and
incidental munions and explosives of concern (MEC) potenally intermingled with the debris. Potenal chemicals
could be metals, organic compounds (volale and semi-volale organic compounds), MEC, and/or munions
constuents (potenally including energecs, metals, and organics). Based on this RAR decision, leaving the soil piles
in place at SWMU N002 would not change the current risk evaluaon.

Please let me know your thoughts on our informaon and recommendaon.
Thank you,
Elizabeth

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

From: Karen Wallner <[e-mail]>
Sent: Tuesday, September 17, 2024 4:06 PM
To: TEVAULT, ELIZABETH A CIV USAF AFMC AFCEC/CZOM <[e-mail]>
Cc: NIEMAN, JOCHIM KARL C CIV USAF AFMC 75 CEG/CEIE <[e-mail]>; LOUCKS, MARK D
CIV USAF AFMC AFCEC/AFCEC/CZOM <[e-mail]>; BURTON, AMANDA C CIV USAF AFMC 75 CEG/CEIE
<[e-mail]>; BYRK, MICHAEL J CIV USAF AFMC 75 CEG/CEIEA <[e-mail]>; Paige
Walton <[e-mail]>; DEVORE, DOUGLAS E II CIV USAF AFMC 75 ABW/JA <[e-mail]>
Subject: Re: [Non-DoD Source] UTTR N002 Soil Piles Invesgaon Followup

Hi Elizabeth,
Based on the information you have provided, it appears that the soil piles may be contaminated with explosivesconstituents, MEC and/or metals as you have stated. However, since the soil piles (that may potentially be characterized
as hazardous waste) have been placed within a closed SWMU, these materials must be removed and properly disposed
of. Once the soil piles have been removed, confirmation sampling will be required to demonstrate that the site risksremain within the risk range established for SWMU N002 at the time of closure. Confirmation sampling may be restrictedto metals and explosives constituents.
This is a brief response to your questions, but I anticipate there will be additional questions and discussions regarding thisissue.
Thanks,
Karen

10/15/24, 9:43 AM State of Utah Mail - FW: [Non-DoD Source] UTTR N002 Soil Piles Investigation Followup
https://mail.google.com/mail/u/0/?ik=390e15a6ba&view=pt&search=all&permthid=thread-f:1812563861205457902&simpl=msg-f:18125638612054579…2/7
On Mon, Sep 16, 2024 at 7:00 AM TEVAULT, ELIZABETH A CIV USAF AFMC AFCEC/CZOM
<[e-mail]> wrote:
Hi Karen,
I have some updates and quesons concerning the soil piles at SWMU N002. 75th Security Forces completed their
invesgaon and were able to find out who dumped the soil piles and where they came from. Determinaons
regarding acons against the dumper are pending. However, with the knowledge of where the soil came from,
AFCEC and Hill have been able to look into the history of the source area. Mike Byrk spoke with the missile
maintenance folks who work in the CBU Valley who said they have used the site (where the soil was excavated) as
an area to detonate general purpose bombs. There have been approximately 100 detonaons over the last five
years. Each bomb tested leaves a crater which is refilled with sand brought in by 75th Civil Engineering (from a
sand pit by the Eagle Range). The general purpose bombs have been filled with either Tritonal or PBXN-109.

Is the above informaon enough to waive the sampling request? Could we assume there is a possibility the soil is
contaminated with explosives constuents, MEC and/or metals, much like N002, and come up with a way ahead
based on that characterizaon? If we need to proceed with sampling, could we limit sampling to just metals and
explosives?

Please let me know your thoughts.
Thank you,
Elizabeth

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

From: Karen Wallner <[e-mail]>
Sent: Tuesday, August 13, 2024 11:02 AM
To: TEVAULT, ELIZABETH A CIV USAF AFMC AFCEC/CZOM <[e-mail]>
Cc: Paige Walton <[e-mail]>; LOUCKS, MARK D CIV USAF AFMC AFCEC/AFCEC/CZOM
<[e-mail]>
Subject: Re: [Non-DoD Source] UTTR N002 Soil Piles Invesgaon Followup

Hi Elizabeth,

In response to your questions:
There isn't a hard deadline for completing the sampling as we know that you will need to determine the contract
mechanism for sampling and schedule support from UXO. However, as you said, the sooner the better.
We don't have any specific requirements for the number of samples for initial characterization, but a 10%
sample size is reasonable to get an idea of what the materials are.
If Security forces is able to determine the source in the next couple of weeks, and there is some documented
history of the source (who and where) area, this could possibly be used in place of initial characterization
10/15/24, 9:43 AM State of Utah Mail - FW: [Non-DoD Source] UTTR N002 Soil Piles Investigation Followup
https://mail.google.com/mail/u/0/?ik=390e15a6ba&view=pt&search=all&permthid=thread-f:1812563861205457902&simpl=msg-f:18125638612054579…3/7
sampling - depending on the quality of the available information.
Please let me know if you have any other questions.
Thanks,
Karen

On Mon, Aug 12, 2024 at 7:50 AM TEVAULT, ELIZABETH A CIV USAF AFMC AFCEC/CZOM
<[e-mail]> wrote:
Hi Karen,
Aer receiving your email last week, I started working on a way ahead for sampling the soil piles at N002. I had
already contacted the US Army Corps of Engineers in May to see if the piles could be sampled under the UTTR
Restoraon Bridge Contract and they informed me this isn’t within the scope of the contract. Therefore, I’ve
been working with the base to see if they have any avenues for sampling the piles. The sampling process will
have to include UXO construcon support (clearing each sampling locaon for potenal munions). The Hill
Explosive Ordnance Division has agreed to support this effort once we determine the contract mechanism for
sampling.

I have a few quesons for you that will help us with figuring out a contract mechanism. Most importantly, is
there a deadline for compleng the sampling? I know the sooner the beer, but if we end up having to get a
new contract in place this could take some me. Do you have any requirements/recommendaons for number
of samples to comply with inial characterizaon (i.e. one sample from 4 or 5 piles to represent a 10% sample
size)?

The base’s invesgaon into where the piles came from is ongoing. If Security Forces is able to determine the
source (who and where) in the next couple of weeks, and there is some documented history of the source area,
could this be used in place of inial characterizaon sampling?

Please let me know if you need addional informaon to help with my quesons.
Thank you!
Elizabeth

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

From: Karen Wallner <[e-mail]>
Sent: Tuesday, August 6, 2024 3:50 PM
To: TEVAULT, ELIZABETH A CIV USAF AFMC AFCEC/CZOM <[e-mail]>
Cc: Paige Walton <[e-mail]>
Subject: [Non-DoD Source] UTTR N002 Soil Piles Invesgaon Followup
10/15/24, 9:43 AM State of Utah Mail - FW: [Non-DoD Source] UTTR N002 Soil Piles Investigation Followup
https://mail.google.com/mail/u/0/?ik=390e15a6ba&view=pt&search=all&permthid=thread-f:1812563861205457902&simpl=msg-f:18125638612054579…4/7

Hello Elizabeth,
The Division acknowledges the ongoing investigation efforts that Hill Air Force Base (Hill AFB) is taking toinvestigate the placement of the soil piles at N002 and determine the source of the materials. As the investigation
proceeds with the involvement of Hill AFB 75th Security Forces, the Division is requesting collection of soil pilesamples to obtain initial information about the characteristics of the waste. The Division is concerned about the level
of potential contamination and whether the constituents could possibly be migrating.
Preliminary information about the nature of the soil pile constituents will be required to determine a timeframe for
action regarding the soil piles – if the contaminant concentrations are high and/or the constituents are potentiallymobile, immediate action may be warranted. The preliminary information may also help Hill AFB formulate asampling plan to fully characterize the nature and extent of potential contamination associated with the soil piles in
the event that the N002 soil piles source investigation does not conclude with definitive information.
Please collect samples from the soil piles for initial characterization. As the source of the soil piles is unknown at thispoint, please include analysis for the full suite of potential contaminants. Please provide the analytical results once
they are available.
Please let me know if you have any questions or concerns.
Thanks,
Karen
--
Karen Wallner, MSPH
Environmental Scientist | Corrective Action Section |
Division of Waste Management and Radiation Control,
Utah Department of Environmental Quality
Office: [phone]
Front Desk: [phone]
wasteandradiation.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
Statements made in this email do not constitute the official position of the Director of the Division of Waste
Management and Radiation Control. If you desire a statement of the Division Director's position,
please submit a written request to the Director, including copies of documents relevant to your request.

10/15/24, 9:43 AM State of Utah Mail - FW: [Non-DoD Source] UTTR N002 Soil Piles Investigation Followup
https://mail.google.com/mail/u/0/?ik=390e15a6ba&view=pt&search=all&permthid=thread-f:1812563861205457902&simpl=msg-f:18125638612054579…5/7

--
Karen Wallner, MSPH
Environmental Scientist | Corrective Action Section |
Division of Waste Management and Radiation Control,
Utah Department of Environmental Quality
Office: [phone]
Front Desk: [phone]
wasteandradiation.utah.gov

Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
Statements made in this email do not constitute the official position of the Director of the Division of Waste
Management and Radiation Control. If you desire a statement of the Division Director's position,
please submit a written request to the Director, including copies of documents relevant to your request.

--
Karen Wallner, MSPH
Environmental Scientist | Corrective Action Section |
Division of Waste Management and Radiation Control,
Utah Department of Environmental Quality
Office: [phone]
Front Desk: [phone]
10/15/24, 9:43 AM State of Utah Mail - FW: [Non-DoD Source] UTTR N002 Soil Piles Investigation Followup
https://mail.google.com/mail/u/0/?ik=390e15a6ba&view=pt&search=all&permthid=thread-f:1812563861205457902&simpl=msg-f:18125638612054579…6/7
wasteandradiation.utah.gov
Emails to and from this email address may be considered public records and thus subject to Utah GRAMA
requirements.
Statements made in this email do not constitute the official position of the Director of the Division of Waste
Management and Radiation Control. If you desire a statement of the Division Director's position,
please submit a written request to the Director, including copies of documents relevant to your request.

Karen Wallner <[e-mail]>Tue, Oct 15, 2024 at 8:32 AM
To: "TEVAULT, ELIZABETH A CIV USAF AFMC AFCEC/CZOM" <[e-mail]>
Cc: "NIEMAN, JOCHIM KARL C CIV USAF AFMC 75 CEG/CEIE" <[e-mail]>, "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]>, "BYRK, MICHAEL J CIV USAF AFMC 75 CEG/CEIEA" <[e-mail]>, Paige
Walton <[e-mail]>, "LEAR, CHRISTOPHER R CTR USAF AFMC 75 CEG/CEIE" <[e-mail]>,
"DEVORE, DOUGLAS E II CIV USAF AFMC 75 ABW/JA" <[e-mail]>
Hello Elizabeth,
Thank you for the additional information regarding the SWMU N002 soil piles. We will take this information into
consideration in formulating our response.
Thanks,
Karen
[Quoted text hidden]
10/15/24, 9:43 AM State of Utah Mail - FW: [Non-DoD Source] UTTR N002 Soil Piles Investigation Followup
https://mail.google.com/mail/u/0/?ik=390e15a6ba&view=pt&search=all&permthid=thread-f:1812563861205457902&simpl=msg-f:18125638612054579…7/7