DSHW-2024-005443

Anderson Geneva, LLC United States Steel Corporation
March 21, 2024

Mr. Doug Hansen, Director
Division of Waste Management and Radiation Control
Utah Department of Environmental Quality
P.O. Box 144880
Salt Lake City, UT 84114-4880

RE: Notification Letter for Continued Site Management Plan (SMP) Groundwater Monitoring
at the Former Geneva Steel Facility, Vineyard, Utah

Dear Mr. Hansen:

On behalf of United States Steel Corporation (USS) and Anderson Geneva, LLC (Geneva), this letter is to
notify you that the Site Management Plan (SMP) groundwater monitoring event at the solid waste
management units (SWMUs) shown in the attached table, which are located at the former Geneva Steel
facility in Vineyard, Utah, is planned for the week of April 8th of 2024. This sampling event responds to
the requirements of the approved SMPs for each SWMU. AECOM, a contractor to USS/Geneva, will
conduct the field work. The specific SWMU sample dates shown in the attached table are approximate;
the order of SWMU sampling may be adjusted based on staffing and field conditions.

Specific Planned Activities
Samples will be collected or LNAPL gauged at the SWMUs and from the monitoring wells or
piezometers presented in the attached table. To help evaluate groundwater conditions, the following data
will also be collected at the locations where groundwater is sampled, using field instrumentation:
temperature, dissolved oxygen (DO), pH, conductivity, and oxidation/reduction potential (ORP).

Procedures and Analytical Program
Field methods, including sampling and documentation, will be performed and documented in accordance
with applicable standard operating procedures (SOPs) and requirements listed in the revised Verification
Investigation Work Plan (VIWP). Quality assurance and quality control (QA/QC) protocols for the
investigation, including the number and types of QC samples, are included in the revised Data Collection
Quality Assurance Plan (DCQAP), which is Part 2 of the RCRA Facility Investigation (RFI) Work Plan.

The groundwater samples will be collected in accordance with the revised DCQAP and will be submitted
for the analytical program presented in the attached table. The samples will be analyzed by a
Utah-certified laboratory and the analytical results will be validated in accordance with the DCQAP.

Reporting
Preliminary analytical data will be available approximately four (4) weeks after submittal of samples to
the laboratory. USS/Geneva will document the field work, review and validate analytical data for those
SWMUs where groundwater samples are collected, and submit separate SWMU-specific Letter Reports
of Findings to UDEQ to summarize the results of the groundwater monitoring/LNAPL gauging event
approximately 60 days following receipt of all validated analytical results.

Please contact us at your convenience if you have any questions on this matter.

cc: B. Mustoe, AECOM
T. Messersmith, AECOM

File: Geneva, USS
Anderson Geneva, LLC United States Steel Corporation

Summary of Planned Semi-Annual SWMU SMP Groundwater Sampling
SWMU to be Sampled Planned
Sample Dates
Monitoring Wells/Piezometers to be
Sampled/Measured Analytical Program1,2
SWMU GW-4.2 ORA Benzene Plume 4/8/24 MW-142, MW-143, MW-144 Benzene, toluene, ethylbenzene, xylene,
and naphthalene
SWMU GW-4.14 Former Closed Hazardous Waste
Impoundments Plume 4/8/24 MW-03, MW-05, MW-16 Benzene, ethyl benzene, toluene, xylene,
and naphthalene
SWMU GW-4.8 Nitrogen Plant Plume 4/9/24 MW-118S, NPP-209 Benzene, toluene, ethylbenzene, xylene,
and naphthalene
SWMU GW-4.11 Front End Oil Tank Plume - South 4/9/24 MW-156, MW-157, 3.20A-053 Benzene, toluene, ethylbenzene, and
xylene
SWMU GW-4.9 Rolling Mill Clarifier Area 4/10/24 MW-127R, MW-162, RMC-030 LNAPL Gauging
SWMU GW-4.6 Maintenance Area Plume 4/10/24 MW-136, MW-137, MW-138 Benzene, toluene, ethylbenzene, and
xylene
SWMU GW-4.13 Highline Area Plume 4/11/24 MW-150, MW-151, MW-152,
MS29-006, MS29-009R, MS29-011R
Benzene, toluene, ethylbenzene, and
xylene
Notes:
1 - The proposed analytical program is based on the specifications in the approved SMP for each SWMU.  
2 - Analytical program to be conducted by EPA Method SW846 8260B or equivalent method, unless otherwise noted.  
LNAPL - light non-aqueous phase liquid
SMP - Site Management Plan
SWMU - Solid Waste Management Unit    
VOC - Volatile Organic Compound