DERR-2025-001126

Allison Stanley <[e-mail]>
Moab Base Camp VCP Site
1 message
Allison Stanley <[e-mail]>Wed, Feb 12, 2025 at 1:21 PM
To: Jeremy Bell <[e-mail]>, Bryan Torgerson <[e-mail]>
Cc: Bill Rees <[e-mail]>, Kirk Kyster <[e-mail]>, Trevor Schwaab <[e-mail]>
Hi Everyone,
Thanks again for meeting with us last Tuesday to discuss the draft Site Characterization Workplan (SCW) and Quality
Assurance Project Plan (QAPP). As we mentioned on the call, it’s critical that we start with a strong foundation for
sampling and data quality since we don’t have much information about the site. As SITLA is a co-applicant, we've tried to
align our approach with their VCP site, the Beaver Mountain Gun Range. Due to the number of our comments, we
decided that it would be best to meet, rather than send written comments at this time. As your team is developing the draft
documents, we would highly recommend that you coordinate with us early and often so that we can ensure that we’re all
on the same page and the feedback we provided in the meeting is incorporated. Since we discussed a lot on the call, I’ve
included a summary of our meeting below.
There were several elements missing from the QAPP. Some examples include assessment and oversight, data validation
and the PARCCS parameters (precision, accuracy, representativeness, comparability, completion, and sensitivity). For
your reference, we’ve previously provided an example of another QAPP that we’ve accepted under the VCP, and the EPA
QA Crosswalk, which does well to outline each of the elements. It’s important that these elements are included and
discussed as they ensure that QA/QC is sufficient for the project’s needs. We also discussed including quality control
samples (e.g., MS/MSD, LCS/LCSD, method blanks, etc.), standard operating procedures (SOPs), and a level III data
package that includes a case narrative.
Regarding the SCW, we talked about the need to increase the sampling frequency within the shotgun range, particularly
where lead shot accumulation is expected. All samples should be analyzed for selected metals that are typical for
shooting activities (antimony, arsenic, copper, iron, lead, tin, and zinc). Sampling should also be conducted at the firing
lines for the rifle and shotgun range. PAH analysis should be included where there are clay pigeons.
Additionally, we asked for more details related to the sampling methods and procedures. This should answer questions
such as whether the samples are grab or composite, how the samples will be identified in the field, the use of opportunity
samples, etc. We also discussed some of the advantages of an XRF. While an XRF can be used, our main priority is to
establish procedures to characterize the site. This will then help establish a remedy of which the ECOBOND can be
discussed if that is contemplated.
We originally had this site listed under a commercial/industrial exposure scenario (as memorialized in the Voluntary
Cleanup Agreement); however, from Jeremy’s email, SITLA has requested that the site be screened for a residential land
use. Please have the documents reflect these changes.
We appreciate the time that your team has taken to meet with us. Please feel free to reach out to me if you have any
questions or would like to schedule a follow-up meeting. We will look for the draft documents and begin our review
accordingly.
Best,
Allison
--
Allison Stanley
Environmental Scientist II | VCP/Brownfields Section
P: [phone]
environmentalresponse.utah.gov
2/12/25, 1:21 PM State of Utah Mail - Moab Base Camp VCP Site
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2/12/25, 1:21 PM State of Utah Mail - Moab Base Camp VCP Site
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