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State of Utah Mail - Western Zirconium MNA Confirmation Soil SAP-rev3-Draft Final
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Western Zirconium MNA Confirmation Soil SAP-rev3-Draft Final
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Michele Bay <[e-mail]>Mon, Aug 14, 2023 at 12:05 PM
To: "[e-mail]" <[e-mail]>, "[e-mail]" <[e-mail]>
Cc: "Bradford, Kent J" <[e-mail]>, "Dodson, Eric" <[e-mail]>
Hello,
On behalf of Western Zirconium in Ogden, UT, please find attached the 3rd revision – Draft Final version of
the Western Zirconium Monitored Natural Attenuation (MNA) Confirmation Soil Sampling and Analysis Plan.
This version has been revised to reflect suggestions received from Karen Wallner.
Thank you,
~Michele Bay
Michele Bay
Engineer II
406.686.3108 woodardcurran.com
[e-mail]
1015 S. Montana St. Butte, MT 59701
DSHW-2023-207966
State of Utah Mail - Western Zirconium MNA Confirmation Soil SAP-rev3-Draft Final
COMMITMENT & INTEGRITY DRIVE RESULTS
WZ_MNA Confirmation Soil Sampling SAP_rev3-Draft Final.pdf
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WESTINGHOUSE ELECTRIC COMPANY
Western Zirconium Plant

SOIL SAMPLING AND ANALYSIS PLAN

Monitored Natural Attenuation (MNA)
Confirmation Soil Sampling
Western Zirconium Mud Flats Area

Prepared by: Woodard & Curran

July 13, 2023
Revised Aug 8, 2023
2

TABLE OF CONTENTS
SECTION PAGE NO.
1.0 Project Background………………………………………………………………………………. 4
1.1 Sampling Locations…………………………………………………………………………… 4
1.2 Schedule………………………………………………………………………………………. 5
2.0 Sampling Process………………………………………………………………………………… 5
2.1 Field Preparations…………………………………………………………………………….. . 5
2.2 Equipment………………………………………………………………………………………6
2.3 Surficial Soil Sampling Procedure…………………………………………………………….. 6
2.4 Decontamination Procedure…………………………………………………………………… 7
2.5 Quality Assurance/Quality Control Samples………………………………………………….. 7
2.5.1 Temperature Blanks……………………………………………………………………… 7
2.5.2 Equipment/Field Blank……………………………………………………………………7
2.5.3 Blind Duplicates………………………………………………………………………….. 8
2.5.4 Matrix Spike, Matrix Spike Duplicates, and Method Duplicates…………………………8
2.6 Documentation Procedure……………………………………………………………………... 8
2.6.1 Sample Identification and Labeling……………………………………………………….9
3.0 Laboratory Analysis………………………………………………………………………………. 9
3.2 Data Quality…………………………………………………………………………………… 9
4.0 Reporting…………………………………………………………………………………………10
5.0 References………………………………………………………………………………………..11

3

List of Tables
Table 1. Soil Sample Approximate Coordinates
Table 2. Sample Containers, Preservation, and Hold Times
Table 3. Analytical Methods
Table 4. Cleanup Levels for Risk-Based Driver and Historic Analytical Results

Figure
Figure 1. MNA Soil Sample Locations

Appendix
Appendix A: Soil Sample Log Form
Appendix B: EPA Regional Screening Levels Table
Corrective Measures Mud Flats Cleanup Levels Table

4

Monitored Natural Attenuation Confirmation Soil Sampling

Westinghouse Electric Company
Western Zirconium Plant
10,000 West 900 South
Ogden, UT 84404

1.0 Project Background

The Mud Flats area of the Western Zirconium site is located east of the Plant and evaporation ponds. The
area was historically impacted by seepage of evaporation pond water through earthen berms surrounding
the ponds and/or upwelling of contaminated groundwater from the shallow aquifer affected by pond
seepage. During Phase II of the RFI investigation conducted in 2003, soil samples were collected
throughout the Mud Flats Area to determine baseline concentrations of constituents that may pose a risk to
human health and the environment. These findings are presented in the Western Zirconium Ecological Risk
Assessment (URS, 2008). In 2012 the Western Zirconium Corrective Measures Study (URS, 2012) was
conducted to identify appropriate corrective actions and site management activities, of which are described
in the Western Zirconium Site Management Plan (SMP; Westinghouse, April 2022). During 2012-2013,
one of the resulting corrective actions implemented the development and installation of the impermeable
barrier wall that surrounds the evaporation ponds. The barrier wall is designed to capture and contain
contaminated groundwater beneath the evaporation ponds that historically seeped into groundwater within
the Mud Flats area. Following the completion of the barrier wall (2013), contaminants that remain in
groundwater, surface water, and soils throughout the Mud Flats area are predicted to attenuate over time.
According to the SMP, Western Zirconium shall collect monitored natural attenuation (MNA) confirmation
soil samples from ten specific locations within the Mud Flats area to confirm that natural attenuation has
occurred following 10 years after the installation of the barrier wall.

1.1 Sampling Locations

The Mud Flats area of the Western Zirconium site encompasses approximately 110 undeveloped acres
located north, east, and south of the evaporation ponds. Ten sample locations historically identified as SS-
101 – SS-104 and SS-106 – SS-111 will be sampled for this project, and are located within the vicinity of
the northeast, east, and south perimeters of the evaporation ponds. (See Figure 1. MNA Soil Sample
Locations) The approximate coordinates where samples are to be collected are presented in Table 1.

5

1.2 Schedule
Soil sample collection from these locations will be conducted during the scheduled 3rd Quarter Evaporation
Pond Area Monitoring event. This event is scheduled to be conducted during the week of August 28th -
September 1, 2023.
Table 1. Soil Sample Approximate Coordinates

Sample ID Approximate Coordinates
SS-101 41° 15' 58.77" N, 112° 13' 17.58" W
SS-102 41° 15' 57.23" N, 112° 13' 13.40" W
SS-103 41° 15' 53.14" N, 112° 13' 16.27" W
SS-104 41° 15' 48.93" N, 112° 13' 11.32" W
SS-106 41° 15' 40.29" N, 112° 13' 02.54" W
SS-107 41° 15' 35.22" N, 112° 13' 01.15" W
SS-108 41° 15' 21.07" N, 112° 13' 00.65" W
SS-109 41° 15' 16.73" N, 112° 12' 51.26" W
SS-110 41° 15' 17.85" N, 112° 13' 06.81" W
SS-111 41° 15' 19.40" N, 112° 13' 25.44" W

2.0 Sampling Process

The soil sampling process is described in this section. Soil samples will be collected from specific locations
previously sampled during Phase II of the RFI investigation conducted in 2003, before the installation of
the barrier wall that surrounds the evaporation ponds. Analytical data will be used to confirm the natural
attenuation of ammonia as N and arsenic in soil has occurred.

2.1 Field Preparations

The field personnel will ensure that the following activities have been completed prior to mobilizing to the
site:

· Verify with the Project Manager of when the sampling is to be conducted.
· Ensure all field staff conducting the sampling have reviewed the Site-Specific Health
and Safety Plan (SSHASP).
· Ensure that appropriate sample containers have been procured for the required
samples, quality control (QC) sample analyses, and that the analytical laboratory has
been contacted and is prepared to receive the samples.
6

· Obtain appropriate site maps with planned soil sample locations clearly labeled, if
appropriate.

2.2 Equipment
· Personal protective clothing and equipment as required by the Site-Specific Health and
Safety Plan (SSHASP)
· Sample containers and labels
· Sample collection device (stainless steel spoons)
· Stainless steel bowl or aluminum trays for sample compositing
· Decontamination equipment and supplies
· Field logbook and sample collection forms.
· Insulated cooler and ice.
· Global Positioning System (GPS) or similar device

2.3 Surficial Soil Sampling Procedure

Soil samples will be collected using a sample collection device that is appropriate for the environment and
type of sample required. Sampling will be conducted using hand collection techniques (hand augers,
trowels, spoons, etc.) as required by physical characteristics and location of soil. The following steps will
be followed when collecting soil samples from a depth of 0-2” below the ground surface.

· Obtain GPS coordinates and record all applicable data into the field logbook and
sample forms for each individual location.
· Each field team member will don a new pair of nitrile gloves at each sampling location.
· With a clean, decontaminated stainless steel spoon or trowel, clear the area of any
vegetation and surface debris.
· Using a clean, decontaminated stainless steel spoon or trowel, dig to a depth of two
inches and collect the sample by scraping the inner walls of the hole. Place the sample
aliquot from the single location (e.g., SS-101) into the stainless-steel mixing bowl/pan.
Homogenize the sample from the location by dividing the material in the sample pan
into quarters. Mix each quarter, then combine two quarters to form halves. Mix the two
halves to complete homogenization.
· Fill the laboratory provided sample container (s).
· Secure sample container caps.
· Label the sample containers.
· Pack samples in a cooler with ice to reduce temperature.
· Properly decontaminate re-usable equipment before collecting samples from the next
location.

7

2.4 Decontamination Procedure

All re-usable sampling equipment that directly contacts any soil will be decontaminated prior to each use,
between each sample location, and at the end of each sampling event. The following procedure will be used:
· Clean equipment thoroughly with a solution of tap water and non-phosphate, laboratory
grade detergent using brushes as necessary,
· Rinse thoroughly with tap water,
· Rinse thoroughly with deionized (DI) or distilled water, and
· Allow equipment to dry.

Between use, equipment will be stored in dedicated cases or a clean plastic bag to prevent contamination
from soil or dust.

2.5 Quality Assurance/Quality Control Samples
QA/QC samples collected will enable data quality evaluation and validation. In general,
QA/QC samples are collected using the same procedures as those used for collecting
environmental samples, with notable exceptions as described in the following subsections.

2.5.1 Temperature Blanks
Temperature blanks consist of a 40 milliliter (mL) glass vial filled with reagent-grade water.
The temperature of this sample is measured at the time the samples are received by the
laboratory. Temperature blanks will be used to assess whether the preservation criterion of 0-
4°C has been met.

2.5.2 Equipment/Field Blank
Field Blanks will be used to help identify contamination from the sampling environment, from
sampling equipment, or from sample handling. A Field Blank (FB) is a sample clean silica
sand and appropriate preservatives prepared in the field. FB is contained in a sample container
randomly chosen from each lot of containers received from the supplier. Field blanks will be
collected by pouring silica sand over decontaminated sampling equipment and then dispensing
the sand into sample containers. The FB sample will be given its own sample identification,
but will be sealed, handled, shipped, and analyzed in the same manner as native samples.
Analysis will be identical to native samples. Sample identification and labeling can be found
in Section 2.6.1.

8

2.5.3 Blind Duplicates
A blind duplicate sample is a second sample collected at the same location and time as the
original sample. Blind duplicate samples are collected simultaneously or in immediate
succession using identical techniques. Blind duplicates will be collected at select locations to
provide estimates of the total sampling and analytical precision. At least one duplicate sample
will be analyzed from each group of twenty environmental samples of the same matrix. Blind
duplicate samples will be analyzed for all analyses required for the original sample. The blind
duplicates will be managed and analyzed in the same manner as all environmental samples;
however, the COC forms will not indicate which samples are duplicates. A record of the
duplication will be made on the appropriate sampling log form. Sample identification and
labeling can be found in Section 2.6.1.

2.5.4 Matrix Spike, Matrix Spike Duplicates, and Method Duplicates
Samples submitted for matrix spiking will be collected from locations that are known or
assumed to be relatively free of contamination and can produce a sufficient amount of sample
to easily fill all sample containers. At least one matrix spike and matrix spike duplicate sample
or method duplicate sample will be analyzed from each group of 20 environmental samples of
the same matrix. The MS, MSD, and MD samples will be spiked in the laboratory. The
concentrations and compounds that are used for spike testing will be appropriate for the
Western Zirconium site and are discussed in the WZ QAPP. A record of the MS/MSD
collection will be made on the appropriate sampling log form.

Samples will be properly preserved and will be accompanied by a completed chain-of-custody form in a
custody-sealed cooler. The sample containers, preservation, and hold times are presented below in Table 2.

Table 2. Sample Containers, Preservation, and Hold Times

Analyte Container Preservative Holding Time
(days)
Ammonia 4-oz Glass jar w/Teflon lid 0°C - 4°C 28
Arsenic 4-oz Glass jar w/Teflon lid None 180

2.6 Documentation Procedure

All field entries will be recorded in a bound field logbook with consecutively numbered pages.
Additionally, Soil Sampling Log form will be completed for each individual location sampled. An
example of the Soil Sampling Log form is included in Appendix A. Logbook entries and associated
form will be completed prior to proceeding to the next sample location. Specific entries will
include but are not necessarily limited to the following: sample location (sample ID); sample date
9

and time; depth at which sample was collected, sample identification number; sample analysis,
sample field preparation, sample preservative, sampling equipment decontamination, weather
conditions, personnel present and affiliation of personnel, and any deviations from the SAP
protocols.

2.6.1 Sample Identification and Labeling

Soil samples will be identified by their media type, location ID, and the date of sample collection.
The media type will be identified as SS, the location ID will be the identification number, and the
date will be a two-digit month followed by two-digit day, followed by a two-digit year.
Example Natural Sample: Soil sample collected from location SS-101 on
June 1, 2023, would be designated as SS-101-060123.

Example Duplicate Sample: Duplicate soil sample collected from location SS-101 on
June 1, 2023, would be designated as SS-D1-060123.

Example Field Blank Sample: Field blank sample collected on June 1, 2023, would
be designated as SS-FB1-060123.

3.0 Laboratory Analysis

The collected samples, including QA/QC samples, will be analyzed by Chemtech-Ford Analytical
Laboratory located in Sandy, UT. The samples will be analyzed by the following methods presented in
Table 3.
Table 3. Analytical Methods

3.2 Data Quality

Chemtech-Ford will provide analytical results within a level IV quality control/quality assurance data
package(s). The data package(s) will be validated according to level IV data validation guidelines
specified in the Western Zirconium Quality Assurance Project Plan (QAPP; Westinghouse, 2002) and
by USEPA National Functional Guidelines for Superfund Inorganic Methods Data Review (EPA,
2020). Data assessment procedures will be conducted in accordance with precision, accuracy,
representativeness, comparability, and completeness (PARCC) parameters described in detail in
Section 13.0 of the WZ QAPP. All analytical data will be validated, and all decisions and
recommendations will be based upon validated data.
Analyte Method
Ammonia as N EPA 350.1
Total Arsenic SW846 6010B
10

4.0 Reporting

According to the Western Zirconium Site Management Plan (Westinghouse, April 2022) and
Corrective Measures Study Volume II (November 2012), analytical results for ammonia as N and
total arsenic will be evaluated against the Mud Flats Area Cleanup Levels for Future Construction
Worker and analytical results obtained during the Phase II RCRA Facility Investigation (RFI) (See
Table 4. Mud Flats Area Cleanup Levels and Historic Analytical Results). Additionally, analytical
data will be compared to the Regional Screening Level Composite Worker Soil Table (May 2023)
summarized in Table 5 for total inorganic arsenic. Supporting documents can be found in
Appendix B. The confirmation soil samples are predicted to confirm that natural attenuation has
occurred following 10 years after the installation of the barrier wall that surrounds the evaporation
ponds. A report detailing sample collection, laboratory analytical results, data validation, and data
assessment will be prepared and submitted to UDWMRC and UDWQ no later than 60 days after
the completion of the sampling event.

Table 4. Mud Flats Area Cleanup Levels and Historic Analytical Results

Table 5. Regional Screening Levels Composite Worker Soil – May 2023

Ammonia as N mg/kg Soil 250 560 5.4 470 2.8 0.82 6100 19 0.97 150
Total Arsenic mg/kg Soil 5.1 7.1 4 8.2 12 8.8 8.1 8.3 4.9 7
*These cleanup levels are for Site Management with a total carcinogenic risk of 1 x E-06 and a hazard index equal to 1.0
MediaUnitsAnalyte
Historic Analytical Results (2003)
SS-101 SS-102 SS-103 SS-104 SS-106 SS-107 SS-108 SS-109
11*
46.9*
SS-110 SS-111
Future
Construction
Worker
Cleanup Level
Ammonia as N mg/kg Soil NA NA
NA NA NA NA NA NA
Total Arsenic mg/kg Soil 3.6 17 3900 3.0 580 2800 89,000 480
Carcinogenic Target Risk = 1E-06 Noncancer Hazard Index = 1
Analyte Units Media Ingestion
SL
Dermal
SL
Inhalation
SL
Carcinogenic
SL
Injestion
SL
Dermal
SL
Inhalation
SL
Noncarcinogenic
SL
11

5.0 References

EPA, 2002. USEPA RCRA Waste Sampling Draft Technical Guidance. Planning, Implementation,
and Assessment. August 2002.

EPA, 2010. USEPA Contract Laboratory Program National Functional Guidelines for Inorganic
Superfund Methods Data Review. Office of Emergency and Remedial Response, Washington,
D.C. EPA-540-R-10-011. January 2010.

URS, 2003b. Phase II RCRA Facility Investigation Work Plan for Pond Solid Waste Management
Units and Area of Concern Lowlands East of the Plant. May 2003.

URS, 2004b. Phase II RCRA Facility Investigation Report for Pond Solid Waste Management Units
and Area of Concern Lowlands East of the Plant. August 2004.

URS, 2004c. Human Health Risk Assessment Criteria, Western Zirconium Evaporation Ponds Area.
October 2004.

URS, 2007. URS Corporation. Human Health Risk Assessment Western Zirconium Evaporation
Ponds Area. Prepared for Westinghouse Electric Company, LLC. June 2007.

URS, 2008. URS Corporation. Final Ecological Risk Assessment. Prepared for Westinghouse Electric
Company, LLC. January 2008.

URS, 2010. Western Zirconium Plant Corrective Measures Study. Prepared for Westinghouse Electric
Company, LLC. April 2010.
Westinghouse, 2002. Westinghouse Electric Company Western Zirconium Plant Western Zirconium
Quality Assurance Project Plan (QAPP). November 2002.

Westinghouse, 2018. Evaporation Pond Area Ongoing Monitoring Plan. August 2018.

Westinghouse, 2018. Groundwater Quality Discharge Permit UGW570002, Statement of Basis. 2018

Westinghouse, 2022. Site Management Plan. April 2022

12

FIGURE

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SS-101 SS-102
CalciumChloridePond 2(C2)
AmmoniumChloridePond 1(A1)
Ammonium Chloride Pond 2 (A2)
Upset Pond (U1)
Calcium Chloride Pond 1 (C1)
Sodium Chloride Pond 1 (S1)
Stormwater HoldingArea
SWB-7
SWB-8
SWB-3
SWB-9
SWB-10SWB-11
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S5
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Legend ±Ogden UtahSite Management Pla n
Figure Exported: 6/23/2023 By: mbay Using: \\woodardcurran.net\shared\Projects\TREC\7200_Westinghouse\GIS\Project_Files\EvapPonds\Fig1MNA-SoilSampleLocations.mxd
Project #: 0231387.03Map Created: June 20230300600150FeetFigure 1 - MNA Soil Sample Locations
Third Party GIS Disclaimer: This map is for reference and graphical purposes only and should not be relied upon by third parties for any legal decisions. Any reliance upon the map or data contained herein shall be at the users’ sole risk. Data Sources:
!MNA Soil Samples
!(Plume Well
!(Sentry Well
!(SW Body
Barrier Wall
Western Zirconium
Service Layer Credits: Esri, HERE, Garmin, (c) OpenStreetMap contributors, Source: Esri, Maxar, Earthstar Geographics, and the GIS User Community
4
2
1
2
4
2
1
2
SS-104
SS-103
SS-106
SS-107
SS-108
SS-109
SS-110
SS-111
SS-102
SS-101
14

APPENDIX A

Soil Sampling Log

Western Zirconium Evaporation Pond Area
MNA Confirmation Soil Sampling
Soil Sampling Log

General Information

Sample Identification: ________________________________________

Date Sampled:

Sampler (s):

Climate:

Ambient Temperature:

Sampling Information

Sample GPS Location:

Sampling Equipment:

Sampling Method:

Sample Time:

Sample Depth:

QA/QC Sampling:

Observations / Remarks:

16

APPENDIX B
Mud Flats Area Cleanup Levels (CMS Vol. II)
Regional Screening Level (RSL) Composite Worker Soil Table – May 2023

https://19january2021snapshot.epa.gov/risk/regional-screening-levels-rsls-generic-tables_.html