DSHW-2025-000921

From: Paige Walton <[e-mail]>
Date: Tue, Feb 11, 2025 at 4:34 PM
Subject: Additional Questions on SWMUs 1 and 25 TEAD-S
To: Johnson, Brian A CIV USARMY CEHNC (USA) <[e-mail]>, Brown, Lonnie D CIV USARMY JMC (USA) <[e-mail]
>, Erickson, Tyson B CIV USARMY JMC (USA) <[e-mail]>, Johnson, D Troy CIV USARMY JMC (USA) <[e-mail]>, Brad
Lauchnor <[e-mail]>
Cc: Richard, Stephen F CIV USARMY IMCOM (USA) <[e-mail]>, Mcdonald, Heather B CIV USARMY CEHNC (USA)
<[e-mail]>
Hi Brian and Lonny,
The Army and Division had a virtual meeting on February 5, 2025, to discuss the Army’s response (letter dated
January 29, 2025) to the Division’s letter on 08 January 2025 the List of Individual Disposal Features (IDFS)
Proposed for Descoping in the Phase I Corrective Measures Implementation (CMI) at Solid Waste Management
Units (SWMUs) 1 and 25.
The following are outstanding questions that could not be addressed during the meeting.
1.It is the Army’s position that there are safety issues with any intrusive work. Are the safety issues related
to conventional munitions, chemical agents, or both?
2.The SWMUs have undergone extensive work. Detailed records are available from the surface
stabilization project, which indicate what type of munitions and chemicals (agent, ABPs, organics, and
metals) were removed from each IDF. Following the stabilization work, soil gas sampling was conducted to
verify any IDFs that may be off-gassing either agent or organics. In addition, over 2,200 soil samples were
collected in and around each IDF and analyzed for full-suite analytes (organics, inorganics, explosives,
metals, agent, ABP, and dioxin/furans). Geophysical surveys were also conducted over 100% of each
SWMU, including ground surveys and flyover surveys. Based on the extensive investigations that have
occurred on each SWMU, it is unclear how there can still be significant uncertainties regarding where
munitions may be present and where agent is anticipated. Were the results from these investigation reviewed
as part of the determination of safety issues, causing the de-scoping of work?
3.The concern with safety in SWMU 25 is concerning, as this SWMU has little to no history for chemical
agents. The two IDFs where surface soil scraping was proposed were cancelled due to safety issues. The soil
data showed no agent or APBs, no magnetic anomalies were noted in soil, and there are records to show no
agent-related munitions or items were removed during surface stabilization. Clarify specifically what the
safety issues are preventing soil scraping.
4.A clear response as to why a groundwater monitoring well was excluded from the scope due to safety
issues was not provided. Dozens of wells were installed within SWMUs 1 and 25, to include use of sonic
rigs, with no chemical support and no safety issues. If a well can be installed within the SWMUs, why is it
deemed unsafe to drill a well outside of the SWMU. It is noted the Army indicated they thought the SWMUs
had been adequately defined.
5.The Army’s position appears to be centered on safety to personnel. The Division does not want to require
work that is not safe. However, the Division is also tasked with protection of the environment. IDFs have
contaminated groundwater, and it is imperative that work be conducted to limit the potential off-site
migration of contamination from SWMUs 1 and 25. If the Army’s position is that there are insurmountable
safety issues associated with IDFs, then the Division’s position is that all IDFs will require an engineered
cover.
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We look forward to your responses and moving forward with this project.
Thank you,
Paige
--
Paige Walton, PG
Program Manager |Hazardous Waste Cleanup Program |
Division of Waste Management and Radiation Control
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.
2/13/25, 12:36 PM Fwd: Additional Questions on SWMUs 1 and 25 TEAD-S - [e-mail] - State of Utah Mail
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