DSHW-2024-004143

DSHW-2024-004143
_6479884.2
Site Management Plan and
Groundwater Monitoring Plan for
Recycled Earth South Property
Project No. 117-9187001
January 17, 2024
PREPARED FOR PRESENTED BY
Recycled Earth LLC
C/O Tyler R. Cahoon
Dentons Durham Jones Pinegar P.C.
111 S. Main St., Ste. 2400
Salt Lake City, UT 84111
[phone]
[e-mail]
Tetra Tech, Inc.
4750 West 2100 South
Suite 400
Salt Lake City, UT 84120
(801)-736-7451
Fax [phone]
tetratech.com
Prepared by:
David S. Wilson, P.E., P.G.
Principal Engineer & Project Manager
[e-mail]
01/17/2024
Anna Rasmuson, Ph.D., P.E., P.G.
Geological Engineer
[e-mail]
01/17/2024
Site Management Plan Recycled Earth
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TABLE OF CONTENTS
1.0 INTRODUCTION ................................................................................................................................................. 1
Purpose and Organization ............................................................................................................................ 1
Site Description ............................................................................................................................................. 2
Background ................................................................................................................................................... 2
2.0 SITE CHARACTERIZATION AND REMEDIATION SUMMARY ....................................................................... 4
Site Characterization Results ........................................................................................................................ 4
Remedial Actions and Verification Results ................................................................................................... 5
3.0 GROUNDWATER MONITORING PLAN ............................................................................................................ 7
Additional Background Wells ........................................................................................................................ 7
Groundwater Sampling ................................................................................................................................. 7
Groundwater Evaluation................................................................................................................................ 8
4.0 SITE MANAGEMENT ......................................................................................................................................... 9
Land Use Control .......................................................................................................................................... 9
Environmental Covenant ............................................................................................................................... 9
Site Access and Authorizations .................................................................................................................. 10
Modification and Termination ...................................................................................................................... 10
5.0 IMPLEMENTATION SCHEDULE ..................................................................................................................... 12
6.0 REFERENCES .................................................................................................................................................. 13
LIST OF FIGURES
Figure 1 Site Location Map
Figure 2 Site Map
Figure 3 Monitoring Well Locations
APPENDICES
Appendix A Site Legal Description
Appendix B Standard Operating Procedures (SOPs)
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LIST OF ACRONYMS/ABBREVIATIONS
Acronyms/Abbreviations Definition
DRO Diesel Range Organics
DWMRC Division of Waste Management and Radiation Control
EPA Environmental Protection Agency
MS4 Ogden City Municipal Storm Sewer System
NOV Notice of Violation
RSL Regional Screening Level
SMP Site Management Plan
SOP Standard Operating Procedure
TPH Total Petroleum Hydrocarbons
UAC Utah Administrative Code
UDEQ Utah Department of Environmental Quality
UGPS Utah Groundwater Protection Standard
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1.0 Introduction
On behalf of Recycled Earth LLC, Tetra Tech, Inc. (Tetra Tech) has prepared this Site Management Plan (SMP)
for the Recycled Earth South Property located at 3025 South 1500 West in Ogden, Utah (Site) in accordance with
the recommendations presented in the Site Characterization Completion Report (Report) prepared for this Site
(Tetra Tech, November 3, 2023). Site characterization and remediation were performed during 2023 based on
regulatory actions described as background information in Section 1.2. The Utah Department of Environmental
Quality, Division of Waste Management and Radiation Control (DWMRC) approved the Report in a letter to
Recycled Earth dated November 20, 2023, and reiterated the requirement for a SMP for the Site. This SMP has
been prepared in accordance with relevant sections of the Utah Cleanup Action and Risk-Based Closure Standards
under Utah Administrative Code (UAC) R315-101-8, which outlines the required contents for a SMP.
PURPOSE AND ORGANIZATION
The results from site characterization and remedial action were approved by the DWMRC, and no further
remedial action is anticipated for the Site. Recognizing that this is an industrial site, and the characterization
results were compared to regulatory industrial standards, it was recommended that a SMP be prepared and
implemented in accordance with UAC R315-101-7. The SMP is to specify controls and conditions to manage
potential risks to human health and the environment to the acceptable levels considered for the current and
reasonably anticipated future industrial land use. The SMP includes the following elements in tandem with an
environmental covenant as directed by the DWMRC:
Restrict land use of the Site to only industrial or commercial uses.
Present and implement a groundwater monitoring plan that includes supplemental groundwater
monitoring and analysis, with further evaluation to determine whether arsenic and manganese (metals) in
groundwater represent background conditions or are related to Site impacts.
Restrict the use of, and require worker protection and management during work in, shallow groundwater
until the metals issue is resolved to satisfy regulatory acceptable criteria.
This SMP is organized as follows:
Section 1.0: Introduction – Provides the Plan purpose and organization and background information,
including a Site description and regulatory history.
Section 2.0: Site Characterization and Remediation Summary – Summarizes the results from the site
characterization and preliminary remedial actions.
Section 3.0: Groundwater Monitoring Plan – Presents the next steps for supplemental groundwater
monitoring and evaluation of the results.
Section 4.0: Site Management – Outlines the steps to be taken to maintain the land use as industrial or
commercial and protect Site workers.
Section 5.0: Implementation Schedule – Presents a preliminary schedule for implementation of the
activities described in this SMP.
Section 6.0: References – Provides a list of references included in this Plan.
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SITE DESCRIPTION
The Site is located at 3025 South 1500 West in Ogden, Utah as shown on Figure 1. The Site covers approximately
11 acres and includes vehicle maintenance, concrete crushing operations, and composting operations, as depicted
on the Figure 2 Site Map. Vehicle maintenance for Recycled Earth’s vehicles and equipment is performed in the
building located on the north side of the Site, and the concrete crushing and composting operations occur on the
south side of the Site. The legal description for the Site is presented below and the Site Plat Map and recorded
deed are provided in Appendix A in accordance with the requirements of UAC R315-101-8.
“ALL OF LOT 5, MIDLAND INDUSTRIAL SUBDIVISION, OGDEN CITY, WEBER COUNTY, UTAH.”
The Site was constructed in 2015 by Recycled Earth and was developed over prior agricultural lands. The Site was
excavated two to four feet below the original land surface and earth berms were established around the perimeter
of the Site to obscure operations from Midland Drive per Ogden City requirements. During development, shallow
groundwater was encountered near the native soil surface on the south side of the Site. Groundwater levels were
lowered by installing a trench filled with gravel and a perforated pipe (land or french drain) to redirect shallow
groundwater to the stormwater system. The french drain was disconnected from the stormwater system as part of
the remedial actions performed during 2023, which precludes shallow groundwater from discharging to the Ogden
City municipal stormwater sewer system (MS4). The shallow groundwater is being held on the south side of the
Site in a temporary pond that serves as a groundwater sink. The stormwater system on the north side of the Site
was reconnected to the MS4 in November 2023, following demonstration through the site characterization study
that Site conditions are suitable for surface water discharges under the Utah General Industrial Storm Water Permit
(UTG790000).
BACKGROUND
A detailed description of the regulatory agency actions pertaining to Recycled Earth are presented in the referenced
Report and the full history is not repeated in this SMP. Rather a summary of key dates and milestones is presented
as context for this SMP.
DWMRC issued to Recycled Earth a Request for Voluntary Action on August 26, 2022. The Request was
not a notice of violation or administrative order but was intended to provide Recycled Earth with a
preliminary notice and an opportunity to take certain actions voluntarily to stop receiving
wastes/wastewater and develop a plan for site characterization. These items were addressed previously
except for revision of the plan of operations which will be provided separately by Recycled Earth.
Recycled Earth received a Notice of Violation (NOV) from Ogden City on September 30, 2022 titled “Notice
of Violation and Order of Compliance with Municipal Code 9-7D at property address: 3025 S 1500 W Ogden
84401.” According to Ogden City, the NOV was in response to complaints of odors leaving the Site and
correspondence between the City, Recycled Earth and Beck’s Sanitation, Inc. (a disposer of wastewater at
the Site). Recycled Earth was ordered in the NOV to cease discharges to the City MS4 and complete
activities to characterize the Site as described in the Report.
Recycled Earth received a second notice of violation (Second NOV) from Ogden City on January 19,
2023 alleging that Recycled Earth had reinstated access to the MS4 and illegally discharged pollutants
therein, following an event in which the pressure from the detained water on the Site blew out a
temporary plug in one of the on-Site catch basins. The released water flowed into Recycled Earth's
detention pond on the north side of the Site and overflowed into the City’s MS4. Recycled Earth took
immediate action to repair/improve the plug and immediately contacted Ogden City. The Second NOV
included a penalty of $1,000. Recycled Earth appealed the Second NOV, and the appeal is currently
pending before the Ogden City Mayor.
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Recycled Earth completed the required Site characterization and preliminary remedial activities presented
in the approved Site Characterization Plan for Recycled Earth South Operations (Plan, Tetra Tech,
December 29, 2022), which was approved by DWMRC on January 25, 2023. The results from these
actions and the recommendation for this SMP are derived from performance of the tasks outlined in the
Plan and presented in the Report. The DWMRC accepted the Report in its correspondence to Recycled
Earth dated November 20, 2023, which reiterated the requirement for a SMP. Section 2 presents a
summary of the Site characterization and remediation work performed by Recycled Earth during 2023,
which establishes the basis for this SMP.
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2.0 SITE CHARACTERIZATION AND REMEDIATION SUMMARY
The activities to meet the regulatory requirements of Ogden City’s NOVs and DWMRC’s Request were performed
throughout 2023, based on access to the Site amid flooding caused by the disconnection from the MS4 and
subsequent detention of stormwater within the Site. The work performed included preliminary remedial actions
and sampling of select on-site and off-site areas to further characterize sources and migration of hydrocarbons
and other constituents in surface water, soil, and groundwater. The sections below summarize the Site
characterization and remediation activities, respectively.
SITE CHARACTERIZATION RESULTS
Site characterization included collection, analysis, and evaluation of the results for the following environmental
media in accordance with the Plan:
Detained stormwater to evaluate options for water management.
Shallow groundwater and soil samples collected along the french drain.
Soil samples collected from representative on-site locations.
Concrete samples collected from the broken concrete materials on the southern side of the Site, and one
processed (crushed) concrete sample from one of the piles in the center of the Site.
Off-site surface water and soil samples from along the stormwater conveyance flow path from the Site to
the Ogden City limits
Subsurface soil and groundwater samples collected from six borings and monitoring wells completed at
the Site.
The soil and surface water samples were collected in accordance with the Plan and sent to Pace Analytical for
analysis of the parameters described in the Plan (unless indicated otherwise herein). Groundwater samples were
analyzed for constituents listed in UAC R315-308-4 as directed by the DWMRC. The Site characterization results
showed that the soil and water at the Site contain no constituent levels above regulatory standards, background
levels, or other relevant standards except for the following observations:
Catch basin samples CB-2 and CB-8 exceeded the established background concentration for arsenic (15
mg/kg) with concentrations of 53 and 18 mg/kg, respectively. Sample CB-4 exceeded the U.S.
Environmental Protection Agency (EPA) Industrial Regional Screening Level (RSL) for total petroleum
hydrocarbon diesel range organics (TPH-DRO) with a concentration of 946 mg/kg. The catch basins were
cleaned out by Recycled Earth with oversight by Tetra Tech, and the materials were disposed of off Site
at a commercial solid waste landfill. No further action is required for the catch basins.
Arsenic was originally detected in one soil sample (FD-1) at a concentration of 151 mg/kg (Table 6). The
soil from this location was subsequently removed for off-site disposal, and confirmation samples from the
excavation floor and sidewalls showed remaining soil to be below the established background
concentration of 15 mg/kg for arsenic. No further action is required for this location.
Arsenic was detected in all groundwater samples collected along the french drain and from four of the six
monitoring wells with concentrations ranging from 0.015 to 0.63 mg/L. These levels exceed the Utah
Groundwater Protection Standard (UGPS) for arsenic set at 0.01 mg/L. Importantly, arsenic was detected
in the background well at the Site (MW-1) at a concentration of 0.018 mg/L, suggesting that arsenic
detections above the UGPS in groundwater may be naturally occurring. No remedial action is required for
groundwater because it is not used for any purpose currently nor is it expected to be used in the
foreseeable future. However, additional groundwater monitoring is required and demonstration that the
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arsenic (and manganese) are related to elevated background conditions is required by DWMRC as
described in Section 3.
Well MW-3 showed the presence of TPH-DRO in groundwater at 1.8 mg/L. However, all groundwater
results were below the EPA Tap Water RSLs for the indicator compounds for TPH directed for
comparison by DWMRC except for arsenic and manganese. Supplemental groundwater sampling and
evaluation were recommended in the Report to monitor the metal concentrations at this location, as
described in Section 3.
Groundwater elevations were surveyed at each well, and interpolated groundwater contours and the interpreted
direction of groundwater flow from southeast to northwest are shown on Figure 3. This information is provided to
support the Groundwater Monitoring Plan presented in Section 3.
REMEDIAL ACTIONS AND VERIFICATION RESULTS
Verification soil samples were collected for each area where preliminary remedial actions were performed to
address observed and probable sources of petroleum hydrocarbon and select metals impacts at the Site. These
actions were based on findings from preliminary inspections and analysis of environmental samples described in
the Plan. The primary objective of these actions was to eliminate known and/or probable sources of
environmental impacts, thereby preventing potential migration to surface water or groundwater and safeguarding
environmental media. The remedial actions performed and the results from verification sampling are summarized
below for each area.
Soil was excavated from near the cement pad on the south side of the Maintenance Building to remove
residual petroleum hydrocarbon impacts. The earthwork associated with this remedial action was
performed by Recycled Earth with observation and oversight provided by Tetra Tech. It is estimated that
six cubic yards of soil were excavated to complete this remedial action. After the additional excavation
was completed, five confirmation samples were collected with all five samples exceeding the EPA RSL for
arsenic; all other detections were below applicable EPA RSLs. The arsenic concentrations were all below
the established background threshold value of 15 mg/kg established through correspondence between
Recycled Earth and DWMRC as described in the Report.
The french subdrain system, running beneath the existing concrete pile from south to north, was
disconnected from the storm water drainage system. Recycled Earth cut off and sealed the outlet from
the french drain by excavating and cutting off the pipe south of catch basin CB-8 shown on Figure 2.
Both the terminated pipe and the inlet to CB-8 were sealed with mechanical plugs to permanently
disconnect the french drain from the storm water collection system. A temporary groundwater detention
basin (or sink) was developed at the north end of the concrete pile concurrently with the french drain
cutoff to provide an on-site reservoir for storage and evaporation of groundwater to minimize flooding of
site operations. The location of this temporary basin is shown on Figure 2.
The South Trench was cleaned out via excavation by Recycled Earth with observation and oversight
provided by Tetra Tech. The excavation process was guided by visual observations and a handheld
photoionization detector instrument. The quantity of soil removed from the South Trench is estimated to
be 60 cubic yards based on field dimensions. A total of seven verification samples were collected, with
samples being obtained approximately every 20 feet along the trench excavation. The South Trench soil
verification samples showed all results to be below the EPA Industrial RSLs, and the South Trench
excavation was considered complete having achieved the target remediation levels.
The on-site catch basins containing sediment were cleaned out by Recycled Earth at various times during
the site characterization activities with final cleanout and inspection on August 16, 2023, with verification
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by Tetra Tech. The catch basin sediment traps were hand shoveled and pumped out to remove
potentially impacted media. The quantity of solids removed from the catch basins was relatively small and
these materials were disposed of with other solid wastes. Prior to cleaning, soil samples were obtained
from each catch basin. All samples exceeded the EPA Industrial RSL for arsenic set at 3 mg/kg; and one
sample (CB-4) exceeded the EPA Industrial RSL for TPH DRO at a concentration of 3,600 mg/kg.
However, all impacted sediment was removed from the catch basins and properly landfilled off Site, and
no risk is posed to the environment or future surface water discharges. No further action is required for
the catch basins.
The surface water detained on Site was sampled to evaluate management options. The results were
compared to the UTG790000 Effluent Limitations and Sector N Benchmark Limitation as directed by
Ogden City. Select samples showed elevated levels of total suspended solids, pH, aluminum, copper,
iron, zinc and TPH-DRO, indicating that Recycled Earth could not discharge the detained water to the
MS4 without prior treatment. The water was detained at the Site until ambient temperatures increased
and the water levels were reduced through evaporation. Sample detections for the temporary
groundwater detention pond were collected for comparison to the results for the South Trench water
sample; all results were below the UTG790000 Effluent Limitations and Sector N Benchmark limitations.
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3.0 GROUNDWATER MONITORING PLAN
This section presents a groundwater monitoring plan that includes installation of additional background wells,
supplemental groundwater monitoring and analysis, comparison of results to those obtained during Site
characterization, plus further evaluation to determine whether arsenic and manganese (metals) in groundwater
represent background conditions or are related to Site impacts.
ADDITIONAL BACKGROUND WELLS
Two additional monitoring wells will be installed in order to establish background concentrations for arsenic and
manganese in groundwater. The number of background wells was determined based on the DWMRC Technical
Guide for Risk Assessments (Utah Admin Code R31-1010) and the EPA Guidance for Performing Site
Inspections Under CERCLA (OSWER Directive 9345.1-05). The number of samples to establish background
concentrations for a focused site investigation is one per three “release” assessment samples. The Site currently
has one background well and five wells downgradient from the release point at the prior South Trench source
area. Two additional background monitoring wells will be installed at the locations shown on Figure 3 and
described below:
MW-7: Upgradient from the historical release along the center of the southwest property boundary.
MW-8: Upgradient from the historical release areas at the southeast corner of the property boundary.
Boreholes for the wells will be installed using direct push drilling method and will extend to at least five feet below
the water table. A Blue Stakes utility clearance will be performed prior to well installations. The wells will be
installed using five-foot PVC well screens with four feet screened below the water table and one foot above the
water table. Permeable filter pack material (i.e., sand or pea gravel) sized to match the well screen slot size will
be placed to the top of the well screen. Well installation procedures will be consistent with the methods used to
install the existing wells and are described in SOP 030 (Appendix B). The uppermost foot of the borehole will be
sealed using cement and a flush mount cover will be installed to protect the well and allow access for future
sampling. The new wells will be developed after allowing them to sit for a minimum of 24 hours. A surge block will
be used to force water into the surrounding soil formation and loosen sediments. Surging will be followed by low
flow pumping for a minimum of three casing volumes to complete well development. The elevations of the well
casings will be surveyed to enable water level measurements and assessment of depths to water and the
groundwater flow direction.
GROUNDWATER SAMPLING
An additional round of groundwater sampling will be conducted upon approval of the SMP for the existing wells
and the two new background wells. Groundwater elevations will be measured for all wells prior to sampling and
the water levels will be tabulated and used to evaluate the direction of groundwater flow, which was previously
documented to flow from southeast toward the northwest.
Groundwater samples will be collected from the eight wells using the procedures described in SOP 011
(Appendix B). The samples will be packaged using the procedures described in Section 2.1. Groundwater
samples will be analyzed only for arsenic and manganese by method 6010B because these are the only
constituents determined during the Site characterization to exceed UGPS and EPA RSLs for tap water as
applicable.
If an existing groundwater monitoring well is lost, abandoned, destroyed, or needs to be relocated for
development purpose, Recycled Earth will replace the wells in an area that provides the groundwater data
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required for continued monitoring. Potential proposals to replace groundwater monitoring wells will be submitted
for review and approved by the DWMRC prior to replacement.
GROUNDWATER EVALUATION
Groundwater sample results will be compared to the results obtained during the Site characterization to determine
whether concentrations of arsenic and manganese are increasing, steady, or decreasing and whether they
exceed UGPS or EPA RSLs for tap water as applicable.
As requested by the DWMRC, Recycled Earth will evaluate background concentrations using the statistical
corrective action methods described in the EPA "Statistical Analysis of Groundwater Monitoring Data at RCRA
Facilities, Unified Guidance." Published data on regional groundwater quality, local surveys conducted by the US
Geological Survey and/or Utah Geological Survey, and data from local universities may also be relied upon in
accordance with EPA OSWER Directive 9345.1-05. A student t-test will be used to compare release samples to
background concentrations, wherein a p-value greater than 0.05 indicates the two datasets are statistically the
same and the concentrations within the site downgradient from the historical release location are within
background concentrations. If the comparison shows on-site groundwater results for arsenic and manganese to
be statistically similar to the concentrations of these metals in the background wells, then the detections of these
metals, even if above the UGPS and EPA RSLs for tap water, will be considered background conditions and no
further action will be recommended. Background concentrations for arsenic and manganese will be calculated
using the 95% confidence interval for the three background well results, plus published background groundwater
data if available and applicable to the Site.
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4.0 SITE MANAGEMENT
This section presents the Site management methods to restrict land use to only industrial or commercial uses,
and to restrict the use of, and require worker protection and management during work in, shallow groundwater
until the metals issue is resolved to satisfy regulatory acceptable criteria as described in Section 3.
LAND USE CONTROL
The current and future land use for the Site shall be limited to industrial and commercial uses consistent with the
application of EPA Industrial RSLs for evaluation of Site characterization results as presented in the Report. The
proposed land use controls are applicable to sites where cumulative carcinogenic risk exceeds a level of 1x10-6
but is less than 1x10-4 as is the case when EPA Industrial RSLs are applied for comparison of characterization
results.
The Site is zoned for industrial or commercial use, and modification of the zoning is not anticipated by Recycled
Earth. If plans arise for future development of the Site for another purpose, then the developer shall demonstrate
to the DWMRC that the level of risk present for the proposed use shall not exceed the applicable risk levels under
Utah R315-101-5.
The following land use controls shall be maintained and implemented to protect human health and the
environment consistent with the findings of the Site characterization results presented in the Report:
Access to the Site shall remain restricted to workers and commercial customers as provided by perimeter
fencing and a north access gate that is closed during non-operating hours.
Recycled Earth management will notify present and future workers at the site of the risk at the Site
associated with metals in the groundwater and the existence of this SMP. This includes site workers
present for a typical work week and construction workers who may be temporary. If Site work is required
that brings workers into contact with groundwater then prior to the work applicable exposure training and
personal protective equipment will be provided by Recycled Earth to minimize the potential for exposure.
No groundwater wells shall be installed, and groundwater shall not be used for any purposes at the Site.
The diversion of shallow groundwater for site drainage with discharge from the Site shall only be
developed after implementation of the Groundwater Monitoring Plan described in Section 3, and after
demonstration that elevated metals concentrations in the groundwater are due to background levels and
not Site conditions.
An Environmental Covenant (EC) will be prepared to document the land use and groundwater use
limitations presented herein.
These land use controls are designed to assure that pathways of potential exposure to residual impacts remain
incomplete for as long as impacts remain that could pose unacceptable risks to human health or the environment.
The land use controls shall be enforceable pursuant to UAC Section 57-25-111 and consistent with the land uses
presented in the Report and this SMP. Recycled Earth or subsequent landowners will be responsible for
maintaining the land use controls and reimbursing the agency for reasonable costs associated with periodic
administrative oversight to ensure that land use controls are maintained. Agency costs shall not exceed the
authorized statutory rate for technical oversight at the time of service.
ENVIRONMENTAL COVENANT
An EC pursuant to UAC Sections 57-25-101 through 57-25-114 is required for the Site and shall be enforceable
until it is demonstrated that the contaminants of interest are at or below background levels or the risk-level
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requirements under UAC R315-101-8(f) are achieved, including remaining risks less than or equal to 1x10-6 for
carcinogens and the hazard index is less than or equal to one for non-carcinogens for an unrestricted (e.g.,
residential) land use exposure scenario.
The EC will be prepared consistent with this SMP after approval by the DWMRC and will include the following
elements in accordance with UAC R315-101-8(g):
Brief narrative description of the impacts and remedy
List of the constituents of potential concern
List of the exposure pathways
Limits of exposure
Locations and extent of the impacts
Brief narrative description of land use limitations
Groundwater use limitations
Ground surface use limitations
Worker safety limitations.
The EC will inform all legal interests in the Site initiated after recording of the EC that persons with legal interest
are required to maintain compliance with the SMP. The EC will include provisions that representatives of the
DWMRC may at any reasonable time and upon presentation of appropriate credentials, have access to the Site to
monitor, sample or determine compliance with the SMP or EC. The terms and conditions of the land use controls
presented in the SMP are consistent with the EC. Restrictions, controls, and conditions specified in the SMP and
EC are enforceable by the DWMRC director under UAC 57-25-111 and Rule R315-101-
SITE ACCESS AND AUTHORIZATIONS
Recycled Earth will be responsible for implementation of the SMP and EC requirements. Coordination for Site
access by other parties shall be made through Recycled Earth having the following contact details:
Recycled Earth
Mr. David Rawson
President
Email: [e-mail]
Phone: [phone]
3025 South 1500 West
Ogden, Utah 84401
Utah DWMRC and Ogden City have rights of reasonable access to the Site at any time after the effective date of
this SMP for activities such as monitoring and compliance assessment. Representatives of these agencies may at
any reasonable time and upon presentation of appropriate credentials, have access to the site to monitor, sample
or determine compliance with the SMP or EC.
MODIFICATION AND TERMINATION
The SMP is subject to review and may be terminated or modified under the following conditions in accordance
with UAC R315-101-8(d).
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 If groundwater sampling data within the Site indicate that approved groundwater corrective action levels
found in Subsections R315-101-4(f)(15), R315-101-6(a)(3)(i), and R315-101-7(k)(4), as applicable, have
been met for the site, Recycled Earth may request modification or termination of the groundwater
monitoring program, as follows:
o groundwater data shall be evaluated using a statistical corrective action test in accordance with the
"Statistical Analysis of Groundwater Monitoring Data at RCRA Facilities, Unified Guidance," US EPA,
or the "Groundwater Statistics and Monitoring Compliance Guidance Document," Interstate
Technology Regulatory Council (ITRC), as incorporated by reference in Section R315-101-12;
o a demonstration that future levels of contamination will not exceed the approved groundwater
corrective action levels; and
o land use controls, either engineering or institutional or both, shall be relied upon to ensure protection
of human health and the environment if the approved corrective action levels are more than the
drinking water standards, maximum contaminant levels.
 If soil sampling data indicate corrective action levels as found in Section R315-101-6 have been met for
the soil portion of the Site, Recycled Earth may request a modification or termination of the section of the
SMP addressing soil management or land use restrictions based on soil management.
 If Recycled Earth satisfies Subsections R315-101-8(d)(1) and R315-101-8(d)(2) and, in addition, meets
the requirements defined in Subsection R315-101-7(a), the owner may request a corrective action
complete without controls determination or a no further action determination.
 If Subsection R315-101-8(d)(3) is satisfied, a request for termination of the SMP and EC may be
submitted to the DWMRC director for approval.
Recycled Earth understands that the DWMRC director may require public comment on modifications or
termination of the approved SMP and EC. The director may also require a re-evaluation of the risk assumptions,
the SMP and EC upon receipt of new information or data that brings into question the protectiveness of the
existing SMP.

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5.0 IMPLEMENTATION SCHEDULE
This SMP is being submitted to DWMRC within 60 days of agency approval of the Report (DWMRC approval
received on November 20, 2023) in accordance with UAC R315-101-7. The EC will be prepared after agency
approval of the SMP and will be submitted to the DWMRC for approval. Upon acceptance of the SMP and EC by
the DWMRC, the director shall provide public notice for public comment periods and public hearings as described
in UAC R315-101-10.
Upon completion of the agency review and public comment period, and within 30 days of the director signing the
EC, Recycled Earth shall record the approved EC with the Weber County Recorder's Office, and within 30 days of
recording shall submit a copy of the recorded document to the DWMRC director.
Upon approval of the SMP, Recycled Earth will begin the supplemental groundwater monitoring and
demonstration regarding the presence of select metals in the groundwater above regulatory criteria as described
in Section 3. A report of the groundwater results and the background evaluation for metals will be provided to
DWMRC upon completion of that work for review and approval by the agency. 
Site Management Plan Recycled Earth
Ogden, Utah
13 January 17, 2024

_6479884.2
6.0 REFERENCES
EPA. September 1992. Guidance for Performing Site Inspections Under CERCLA. OSWER Directive 9345.1-05.

EPA. March 2009. Statistical Analysis of Groundwater Monitoring Data at RCRA Facilities. EPA 530/R-09-007.

EPA. 2022. Regional Screening Level (RSL) Summary Table (TR=1E-06, HQ-1), May 2022.

UDEQ Utah Ground Water Quality Protection Program, accessed by web 12/05/2022: https://deq.utah.gov/water-
quality/standards-utah-ground-water-quality-protection-program.

UDEQ, March 15, 2023. Utah Department of Environmental Quality, Division of Waste Management and Radiation
Control. Utah Administrative Code R315-101, Cleanup Action and Risk-Based Closure Standards.

UDEQ, November 20, 2023. Letter from Utah Department of Environmental Quality, Division of Waste Management
and Radiation Control to Recycled Earth. Approval of Revised Site Characterization Report, Recycled Earth LLC South
Property.
Tetra Tech, December 29, 2022. Site Characterization Plan for Recycled Earth South Property. Prepared
for Recycled Earth LLC by Tetra Tech Inc.

Tetra Tech, November 3, 2023. Site Characterization Completion Report for Recycled Earth South Property.
Prepared for Recycled Earth LLC by Tetra Tech Inc.

Site Management Plan Recycled Earth
Ogden, Utah

_6479884.2

Figures

Figure 1 : Site Location Map
Site Management Plan
Recycled Earth LLC
3025 S 1500 W, Ogden, UT 84401
Date 8/11/2023
Legend
Ogden
Maxar
k k
Recyled Earth Site Boundary
Ogden Municipality Boundary
0 0.12 0.23 0.35 0.460.06
Miles
0 0.71 1.42 2.13 2.840.35
Miles
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Figure 2 : Site Map
Site Management Plan
Recycled Earth LLC
3025 S 1500 W, Ogden Utah
Date : 10/24/2023
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Maxar, Microsoft, Esri Community Maps Contributors, Ogden City, Utah Geospatial
Resource Center, © OpenStreetMap, Microsoft, Esri, HERE, Garmin, SafeGraph,
GeoTechnologies, Inc, METI/NASA, USGS, Bureau of Land Management, EPA, NPS,
US Census Bureau, USDA
Figure 3 : Monitoring Well Locations
Site Management Plan
Recycled Earth LLC
3025 S 1500 W, Ogden, UT 84401
Date 11/22/2023
Legend
Existing Groundwater Monitoring Wells
Proposed Groundwater Monitoring Wells
Grounwater Elevation Countour
0 0.02 0.04 0.06 0.080.01
Miles
Groundwater Flow Direction
4,183 ft
4,280 ft
4,279 ft4,275 ft
4,277 ft
4,269 ft ¯
Site Management Plan Recycled Earth
Ogden, Utah

_6479884.2

Appendix A
Site Legal Description

Site Management Plan Recycled Earth
Ogden, Utah

_6479884.2

Appendix B
Standard Operating Procedures

TETRA TECH, INC.
Standard Operating Procedure No. 011
Revision Date: 10/24/2022
Created by: Anthony Camacho
Project name: Recycled Earth
Page 1 of 6
Groundwater S ampling
1. PURPOSE
The purpose of this procedure is to obtain representative groundwater samples from groundwater
monitoring wells or piezometers with a bailer, peristaltic, or submersible pump. Site-specific
groundwater sampling requirements, if necessary, will be described in work plans or field
sampling plans.

2. PROCEDURE

2.1 FIELD PREPARATION
Notify client, property owner prior to sampling date in case there is any requirement to reach
property.

2.1.1 Forms
Gather proper field forms necessary for field sampling such as:
Water Level Data Sheet
Daily Report Sheets
Chain of Custodies
Water Quality Data Sheet
Field Service Request
Tailgate Health and Safety

2.1.2 Equipment
Gather necessary equipment required for sampling:
Laboratory provided containers and labels
Laboratory-cleaned cooler
Well keys

TETRA TECH, INC.
Standard Operating Procedure
Revision Date: 10/24/2022
Created by: Anthony Camacho
Project name: Recycled Earth
Page 2 of 6

Electronic water level indicator
Interface probe (if free-product is expected at the site)
Calculator
Latex or nitrile gloves
Tools to access wells
Knife, or scissors
Garbage bags
Two graduated 5-gallon pails to collect purge water
pH, temperature, and specific conductivity meter

Decontamination equipment including:
Deionized or distilled water
Alconox
graduated cylinders
paper towel

One of:
Disposable high-density polyethylene sampling bailers and bailer rope
Peristaltic pump and sufficient disposable Silicon (approximately 10 inches per sample) and
tubing (length measured from pump head to sampling depth)
Submersible pump and tubing
If needed:
DOT-approved sealed drums for storage of purged well water, or a suitable location to disperse
of liquid (i.e., on-site treatment system)
Quantab TM and HachTM Titration kits

TETRA TECH, INC.
Standard Operating Procedure
Revision Date: 10/24/2022
Created by: Anthony Camacho
Project name: Recycled Earth
Page 3 of 6

2.1.3 Documents

Any field documents that will help with sampling:
Well Construction Log
Well location map/site map
Work Plan
Health and Safety Plan
Signed site access agreement

2.1.4 Other

Cellular phone
Replacement locks
Writing implements and an indelible marker
Crushed ice
Bubble wrap if required to protect samples during shipment to the laboratory
First aid kit
Personal comfort items
Machete or other vegetation-clearing tool

2.2 FIELD ACTIVITIES

2.2.1 Well Purge

Don a new pair of latex or nitrile gloves. First sample those wells with the lowest historical or
suspected concentrations, then advance to the wells more likely to be contaminated. Set plastic
sheeting or a garbage bag near the well to set sample bottles on and to rest sampling equipment.
Obtain the water level measurement, noting any occurrence of LNAPL or DNAPL. Calculate three

TETRA TECH, INC.
Standard Operating Procedure
Revision Date: 10/24/2022
Created by: Anthony Camacho
Project name: Recycled Earth
Page 4 of 6

or five times the volume of groundwater present in the well casing, as indicated on the Field
Service Request Form.
Purge the well using a dedicated HDPE disposable bailer and a new length of clean rope, a
peristaltic pump with new Teflon and tubing, a submersible pump with new tubing. Purge the
groundwater monitoring well of a minimum of 3 to 5 well casing volumes prior to collecting the
samples. Measure the volume of purged water using a graduated pail, or other container of known
volume. Purging and sampling should be conducted using slow and steady motions to avoid
excessive agitation, increased sample turbidity, and sample volatilization. Empty purge water onto
the ground, away from the well, or in the event containerizing is required, transfer purged water
from the pail into the appropriate storage container for storage until disposal is arranged.

NOTE: If well goes dry before 3 well volumes can be purged from the well, allow groundwater to
recharge, then collect sample.

2.2.2 Field Measured Parameters

After at least 3 well volumes have been purged from the well, measure temperature, pH,
conductivity, and any other field parameters as specified in the Field Service Request Form. Once
three measurements are obtained within 10-percent of each other, the groundwater quality may
be considered representative of the groundwater as it exists in the formation.
If well goes dry before 3 well volumes can be purged from the well, a single round of field
parameter measurements will be obtained following recharge of a sufficient amount of
groundwater to complete the sampling activities.

2.2.3 Bottle Preparation

Prior to sample collection, label all appropriate fields on the sample container labels with an
indelible marker. Apply labels to appropriate containers.

TETRA TECH, INC.
Standard Operating Procedure
Revision Date: 10/24/2022
Created by: Anthony Camacho
Project name: Recycled Earth
Page 5 of 6

2.2.4 Sample Collection

2.2.4.1 Bailers
Samples will be collected using the same HDPE disposable bailer used for purging. Transfer
groundwater samples from the bailer to their appropriate sample bottle, minimizing turbulent flow
between the bailer and the sample bottles. Place samples in the appropriate containers in
decreasing order of volatility (e.g., purgeables and aromatics first, then PNAs and phenols, then
cyanides, and lastly, nitrate, sulfate and metals). Samples for dissolved metals analysis may be
field filtered. If there is insufficient sample volume to provide all sampling needs, retrieve
additional bailer volumes until all samples are collected.

2.2.4.2 Peristaltic, submersible

Samples for laboratory analysis of parameters, other than VOCs, will be collected directly from
the pump tubing following purging of 3 to 5 well volumes, and stabilization of field parameter
measurements. A 0.45 µm filter will be used to field filter samples for dissolved metals into a
preserved laboratory container.

2.2.5 Sample Preservation

Tighten lids of sample containers and place in coolers
Wrap all glass containers in bubble wrap or foam; then place into large 1-2 gallon zip-lock bags,
label the outside of the bag, and place into the coolers.
Completely fill out the Chain-of-Custody. When shipping samples, seal Chain-of-Custody in a
watertight zip-lock bag and attach to the underside of the cooler lid with packaging tape. Ship
coolers or arrange delivery to the laboratory as soon as possible and before the sample “hold-
time” expires.

TETRA TECH, INC.
Standard Operating Procedure
Revision Date: 10/24/2022
Created by: Anthony Camacho
Project name: Recycled Earth
Page 6 of 6

2.2.6 Decontamination

Decontaminate electronic water level indicator, pH, temperature, and specific conductivity meter
between sampling points. If peristaltic pump is used, dispose used flow-through tubing and filters.
If submersible pump is used, place pump in a graduated cylinder filled with a solution of Alconox
and deionized or distilled water. Allowing the soap and water solution to re-circulate through the
pump and tubing for a maximum of five minutes. Rinse cylinder and outside of pump and tubing
with deionized or distilled water. Fill cylinder with deionized or distilled water and allow at least 4
liters to run though the pump and tubing and onto the ground away from the well.

NOTE: During pump use and decontamination, take care to assure tubing and pump does not
come in contact with the ground or other surfaces. Following sampling of the last well, remove
and throw away submersible pump tubing prior to decontamination of the pump. Dispose of all
gloves, bailers, rope/string, tubing, and filters used to collect the sample prior to accessing the
next well.

3. QUALITY ASSURANCE

Avoid cross-contamination of wells with the water level indicator, and sampling equipment by
conducting proper decontamination procedures described above. Take care in labeling the
samples, and the corresponding Chain-of-Custody with the correct sample date, time and well
identification. All labeling must be consistent between samples and the Chain of Custody. Keep
samples on ice following collection and be conscience of “hold-times” for the samples. It is
imperative that samples are submitted to the laboratory prior to the exceedance of hold times.
TETRA TECH, INC.
Standard Operating Procedure
030
Revision Date: 4/21/2023
Created by: Anthony Camacho
Project name: Recycled Earth
Page 1 of 12
Ground monitoring well installation
1. Purpose
The purpose of this Standard Operating Procedure (SOP) is to delineate the quality control
measures required to ensure the accurate installation of groundwater monitoring wells. The term
monitoring well is used to denote any environmental sampling well.
2. Procedure
2.1 FIELD PREPARATION
Notify client, property owner prior to sampling date in case there is any requirement to reach
property.
2.1.1 Forms
Gather proper field forms necessary for field sampling such as:
Daily Report Sheets
Field Service Request
Tailgate Health and Safety
Excavation Permits
Utility clearances
Borehole logging form
Well completion forms
Appropriate work plan
2.1.2 Drilling Equipment
Appropriately sized drill rig adequately equipped with sampling equipment, bits, drill stem, etc.
Steam cleaner and water obtained from an approved source for decontaminating
drilling equipment
TETRA TECH, INC.
Standard Operating Procedure
Revision Date: 4/21/2023
Created by: Anthony Camacho
Project name: Recycled Earth
Page 2 of 12

Water level indicator
LEL-oxygen monitor
Steel drums for investigation derived waste (drill cuttings, contaminated PPE, decon
solution) (if necessary)
Source of approved water
Heavy plastic sheeting
Decontamination area

2.1.3 Well installation materials
The specifications for the following materials are included in the well construction:
Well screen
Riser pipe
Plugs/caps
Filter pack
Bentonite
Portland cement
Steel protective casing
Submersible pump
Surge block
Concrete

Decontamination equipment including:
Deionized or distilled water
Alconox
graduated cylinders
paper towel

2.1.4 Personal Equipment
Appropriate PPE (see HASP)
Munsell color chart
Hand lens
Folding rule
First aid kit
Fire extinguisher

2.2 WELL DRILLING PROCEDURE

2.2.1 Rationale
Sound groundwater sample integrity is dependent primarily on strict adherence to properly
conceived monitor well construction and development procedures. In addition, it is equally
important that boreholes (i.e., soil borings, wells, and piezometers) be abandoned properly, when
necessary, to preclude the possibility of cross-contamination of water-bearing zones. To ensure
that these goals are met, the following monitoring well drilling, and completion procedures will be
utilized.
2.2.2 Preliminary procedures
Never assume the rig will arrive on-site completely decontaminated from the previous job.
Always inspect it. Road dust can have elevated levels of organics and inorganics attached to it. It
is always a good idea to have the drillers lay out all the tools from their side tool panels and wash
both the tools and the storage compartments. Between holes and on-site locations, ensure that
dirty tools are decontaminated before being returned to these compartments

The following standard field procedures should be followed at each borehole location:
Check the location and number of the drilling location against a map and against the flag or stake.
A good rule of thumb is to measure twice, and drill once.
TETRA TECH, INC.
Standard Operating Procedure
Revision Date: 4/21/2023
Created by: Anthony Camacho
Project name: Recycled Earth
Page 3 of 12
TETRA TECH, INC.
Standard Operating Procedure
Revision Date: 4/21/2023
Created by: Anthony Camacho
Project name: Recycled Earth
Page 4 of 12

Make sure you have a utility clearance for that location.
Back the rig into position so you do not have to drive over the finished hole.
Set up the work area (and sample holding area) to be upwind of the rig exhaust. This
may require the work area to be moved several times during the day.
Check the condition of the driller’s downhole measuring device. Often these devices are missing
several inches, tenths of inches, or feet, and, if used, will result in contradictory hole and well
completion information.
Remove any electrical tape or materials from any devices that, if lost downhole, could result in
possible contamination of groundwater.
Ensure that the measuring device is decontaminated each time it is used.
Drilling is a team effort that includes personnel and the driller. Arrange with the driller before
activities begin to keep you informed of what he/she sees or believes is happening downhole.
For example, the driller can often tell you when the soil is getting harder or softer, or when
he/she is losing or gaining fluids (the hole is making water). These comments often may be
related later to lithologic and hydro stratigraphic changes and, therefore, may verify logs.

2.2.3 Direct Push Technology
Direct push methods use up to 40,000 pounds of hydraulic force to push a steel
instrumented cone or a sampling device into the ground. No material comes to the surface
unless soil or groundwater samples are being collected.
2.2.3.1 Advantages
This method is generally cleaner than other drilling techniques that require a water supply and
may result in the need to containerize drilling fluids (e.g., muds) as well as cuttings. No material
comes to the surface unless soil or groundwater samples are being collected. Because no drilling
muds introduced to the hole, soil and groundwater samples are considered more accurate and
representative. Sample moisture content is more likely to be representative of the formation.
Small-diameter monitoring wells can be installed quickly and efficiently.

2.2.4.2 Limitations
Limited in depth of penetration to approximately 100 feet depending on the materials encountered
and the size of the drill rig. Can smear a layer of fine-grained soil on the side of borehole that may
prevent groundwater from entering. The finer the matrix, the greater the chance for smearing the
side of the hole.
2.2.3.3 Procedures
Once the rig is in place, ensure that it is level by insisting that the driller use a
carpenter’s level on each rig. Unaided visual assessment of plumbness is not acceptable.
Using the direct push drill rig, advance a carbon steel core sampler containing a 2 or 3-
foot clear acetate sample tube to the desired depth into the soil. This is referred to as a sampling
interval. Carefully watch the progression of the core sampler while recording blow counts and
note irregularities in the penetration rate. Upon removal of the sampler from the borehole, the
acetate sample tube will be removed and the ends will be
capped to prevent volatilization from the sample. Sample tubes will be marked with the
depth interval and the sample orientation. Place acetate sample tubes on clean polyethylene
sheeting for inspection/sampling. Each sample tube will be inspected for the presence of
groundwater. The tube will be cut lengthwise using a decontaminated closed blade knife, and the
soil will be logged. These steps will be repeated until the desired boring depth is reached.
Record observations of:
- Sampler penetration rates.

- Characteristics of sample (i.e., moisture content, color, and texture),
including changes in the nature (behavior) of the sample. For example, if the soil
begins to form balls or rope, moisture in the soil has probably increased at that
depth.
- Gravel, boulders, and competent bedrock will make the rig bounce, or vibrate.
- Remember that the samples appear at the surface after a time lag, and that this lag
increases with the depth of the hole; therefore, it is not possible to correlate
cuttings with the exact depth being drilled.
TETRA TECH, INC.
Standard Operating Procedure
Revision Date: 4/21/2023
Created by: Anthony Camacho
Project name: Recycled Earth
Page 5 of 12
Running, heaving, or flowing sands occur when the carbon steel core intercepts a saturated soil
unit whose fluid or formational pressure pushes its materials out into the boring and up the
augers.
Document all refusals,), rig gyrations, and physical conditions of samplers.

2.3 Well Construction

2.3.1 Casing/Screen
Typically, only polyvinyl chloride (PVC), Teflon (polytetrafluoroethylene or PTFE), and/or
stainless steel will be used.
All well screens will be commercially fabricated, slotted or continuously wound, and have an inside
diameter (ID) equal to or greater than the ID of the well casing. An exception may be needed in
the case of continuously wound screens because their supporting rods may reduce the full ID.
Stainless steel screens may be used with PVC or PTFE well casing. No fitting will restrict the ID
of the joined casing and/or screen. All screens, casings, and fittings will be new. Screens will have
the largest open area per unit length that is practical for the adjacent aquifer and available filter.

Couplings within the casing and between the casing and screen will be compatibly threaded.
Thermal or solvent welded couplings on plastic pipe will not be used. This also applies to
threaded or slip-joint couplings thermally welded to the casing by the manufacturer or in the
field.

Each cap will be constructed to preclude binding to the well casing due to tightness of fit,
unclean surface, or frost, and secure enough to preclude debris and insects from entering the
well. Caps and risers may be threaded; however, sufficient annular space will be allowed
between the well and protective casing to enable one to thaw any frosted shut caps. Preferably,
unfiltered vents will not be placed in these caps or in the well riser/stickup. Unfiltered vents may
compromise water sample integrity by allowing foreign materials to enter the well between
sampling events. Caps will be loose enough to allow equilibration between hydrostatic and
TETRA TECH, INC.
Standard Operating Procedure
Revision Date: 4/21/2023
Created by: Anthony Camacho
Project name: Recycled Earth
Page 6 of 12
atmospheric pressures or have filtered vents. Special cap (and riser) designs will be provided for
wells in floodplains and those instances where the top of the well may be below grade, e.g., in
roadways and parking lots.

The use of well centralizers will be considered for wells deeper than 20 ft. When used, they will
be of PVC, PTFE, or stainless steel and attached to the casing at regular intervals by means of
stainless steel fasteners or strapping. Centralizers will not be attached to the well screen or to
that part of the well casing exposed to the granular filter or bentonite seal. Centralizers will be
oriented to allow for the unrestricted passage of the tremie pipe(s) used for filter pack and grout
placement.

2.3.2 Filter Pack
All granular filters will be approved prior to drilling and will be discussed in the work plans.
Discussions will include composition, source, placement, and gradation. If the actual gradation is
to be determined during drilling, then more than one filter pack gradation will be on hand so that
well installation will not be unnecessarily delayed.
Granular filter packs will be visually free of material that would pass through a No. 200 (75-
micrometer (µm)) sieve, inert, siliceous, composed of rounded grains, and of appropriate size for
the well screen and host environment. The filter material will be packaged in bags by the
supplier and therein delivered to the site.

2.3.2 Bentonite Seal
Bentonite is the only material that is allowed for sealing or as drilling mud under normal
circumstances. This includes any form of bentonite (powders, granules, or pellets) intended for
drilling mud, grout, seals, etc. Chips or pellets of an appropriate size depending on the annular
space available will be used to form the well seal. If chips are used, they should be sieved to
remove fine-grained material. Organic additives will not be used in drilling mud. An exception
might be made for some high yield bentonites, to which the manufacturer has added a small
quantity of polymer. The use of any bentonite will be discussed in the work plans. Bentonite will
TETRA TECH, INC.
Standard Operating Procedure
Revision Date: 4/21/2023
Created by: Anthony Camacho
Project name: Recycled Earth
Page 7 of 12
only be used if absolutely necessary to ensure that the borehole will not collapse or to improve
cuttings removal.

2.3.3 Grout
Grout, when used in monitor well construction or borehole/well abandonment, will be composed
of Portland cement, bentonite (0-10% dry bentonite per 94-lb sack of dry cement), and a maximum
6 to 7 gallons of approved water per sack of cement. The amount of water per sack of cement
required for a pumpable mix will vary with the amount of bentonite used. The amount of water
used will be kept to a minimum. Neither additives nor borehole cuttings will be mixed with the
grout. All grout materials will be combined in an aboveground rigid container or mixer, and
mechanically (not manually) blended on-site to produce a thick, lump-free mixture throughout the
mixing vessel. The mixed grout will be recirculated through the grout pump prior to placement.
Grout will be placed using a grout pump and pipe/tremie. The grout pipe will be of rigid
construction for vertical control of pipe placement. Drill rods, rigid PVC, or metal pipes are
suggested stock for tremie pipes. If hoses or flexible plastics must be used, they may have to be
fitted with a length of steel pipe at the downhole end to keep the flexible material from curling and
embedding itself into the borehole wall. This is especially true in cold weather when the coiled
material resists straightening. Grout pipes will have side discharge. The side discharge will help
to maintain the integrity of the underlying material (especially the bentonite seal).
2.4 Water Source
To the extent practical, the use of drilling water will be held to a minimum. When water usage is
deemed necessary, the source of any water used in drilling, grouting, sealing, filter placement,
well installation, well decommissioning/abandonment, equipment washing, etc. will be approved
prior to arrival of the drilling equipment on-site and specified in the work plans. If a suitable
source exists on-site, that source will be used. The drilling subcontractor will have the
responsibility to procure, transport, and store the water required for project needs in a manner to
avoid the chemical contamination or degradation of the water once obtained. The drilling
subcontractor will also be responsible for any heating, thermal insulation, or agitation of the
water to maintain the water as a fluid for its intended uses.
TETRA TECH, INC.
Standard Operating Procedure
Revision Date: 4/21/2023
Created by: Anthony Camacho
Project name: Recycled Earth
Page 8 of 12
2.5 Delivery, storage, and handling of materials
Materials will be delivered to the site and stored in a secure area. Subcontractors are generally
responsible for scheduling delivery and ordering those supplies pertaining to the installation of
wells. An inventory will be kept to track the materials. Perishable materials will be covered with
tarps and secured to prevent water damage. All materials will be handled in a safe manner and
in accordance with health and safety protocols
3. WELL INSTALLATION
3.1 Preparation
Every morning before entering the field, the field team and drilling subcontractor will meet to
discuss the location and construction criteria for the day’s activities. The field geologist will also
ensure that the drilling subcontractor obtains all necessary supplies for the day’s work (e.g.,
bentonite, Portland cement, and screen and riser), and has decontaminated all equipment and
manmade construction materials to be used downhole (e.g., PVC or stainless-steel screen and
riser). All available areal data (e.g., borehole logs) should be reviewed to determine expected
formation depths prior to the day’s drilling.

3.2 Documentation
During any activities pertaining to well construction, abandonment, or development, the field
geologist will note in the GEOLIS logbook the following information:
Length of time required to perform all drill rig activities (e.g., overdrilling, well construction,
abandonment/grouting, development times, and pumping rates).
All well construction/abandonment supplies used (e.g., bentonite, Portland cement, filter sand,
and screen/riser footage).
Any difficulties in well construction, development, or abandonment. This information may be
used to substantiate a change of scope or explain anomalous sampling data.
Exact measurements (using a tape measure) of screen, end cap trap, and riser lengths.
A completed well construction diagram.

TETRA TECH, INC.
Standard Operating Procedure
Revision Date: 4/21/2023
Created by: Anthony Camacho
Project name: Recycled Earth
Page 9 of 12
4. WELL COMPLETION
4.1 Background
Elements of well protection are intended to protect the monitoring well from physical damage, to
prevent erosion and/or ponding in the immediate vicinity of the monitoring well, and to enhance
the validity of the water samples. The potential for physical damage is lessened by the
installation of padlocked, protective iron/steel casing over the monitor well and iron/steel posts
around the well (when needed for protection). The casing and posts will be new. The protective
casing diameter or minimum dimension will be 2 in. greater than the nominal diameter of the
monitor well, and the nominal length will be 5 ft. The concrete/cement filled posts will be at least
3 in. in diameter and the top modified to preclude the entry of water. Nominal length of the posts
will be 6 ft. Special circumstances necessitating different materials will be addressed in the work
plan. Erosion and/or ponding in the immediate vicinity of the monitoring well may be prevented
by assuring that the ground surface slopes away from the monitor well protective casing by the
installation of a 2-ft by 2-ft coarse gravel blanket around the well. Wells will contain a locking
cover on the protective casing. The cover will be hinged or telescoped, but not threaded. All
locks on these covers should be opened by a single key, if possible.

4.2 Aboveground well completion
Aboveground wells will be completed as follows:
Extend the well casing 2 to 3 feet above ground surface.
Provide an end plug or casing cap for each well. Use a filtered vented cap or drill a small (0.125-
inch) hole into the PVC riser just below the PVC cap or into the PVC cap to allow air circulation
in the well.
Shield the extended well casing with a carbon steel protective casing that is set over the well
casing and cap and extends to a depth of 3 ft bgs.
Grout the annular space between the borehole and the protective casing with cement/bentonite
grout to a depth of 4 ft bgs.

TETRA TECH, INC.
Standard Operating Procedure
Revision Date: 4/21/2023
Created by: Anthony Camacho
Project name: Recycled Earth
Page 10 of 12
Fill the annular space between the well casing and the protective casing with pure sodium
bentonite slurry to protect the well casing from frost heave.
Construct a 2- by 2-foot by 4-inch coarse gravel blanket at the surface, sloped away from the
protective casing.
Drill a small diameter hole (0.25- to 0.375-inch) in the protective casing (weep hole) near the top
of the cement pad to allow for drainage and mark a survey location on the inner casing (mark
with an indelible marker or cut a small notch in the PVC on the side toward the hinge).
Install a lockable cap or lid on the protective casing.
Mark the well number clearly on the protective casing cap using impact lettering.
Install three 3-inch-diameter, concrete-filled steel guard posts, if directed to do so by the on-site
geologist.
The guard posts will be 6 feet in total length and installed radially from each well head.
Recess the guard posts approximately 2 feet into the ground outside of the cement pad and set
in concrete approximately 3 to 5 feet from the protective casing.
Fill each guard post with concrete.
All wells will be secured as soon as possible after drilling. Corrosion-resistant locks will be used
for both flush and aboveground well assemblies. The locks must have extended shanks.

4.3 Flush-mounted well completion
Groundwater monitoring wells will be completed aboveground at most locations. Where well
stickup is of concern, the well will be completed as a flush mount, level with the ground surface.
Flush-mounted wells will be completed as follows:
Cut the casing 2 to 3 in. bgs and install a protective locking lid consisting of a cast iron valve box
assembly or manhole cover.
Center the lid assembly in a 3-foot-diameter concrete pad sloped away from the valve box.
Provide a cap with a filtered vent for equilibrium and to prevent infiltration of surface water.
Maintain a minimum of 1 foot of clearance between the casing top and the bottom of the valve
box. Clearly mark the well number on the valve box lid and well casing using an impact-labeling
method, and mark a surveying point on the inner casing.
TETRA TECH, INC.
Standard Operating Procedure
Revision Date: 4/21/2023
Created by: Anthony Camacho
Project name: Recycled Earth
Page 11 of 12

5. MAINTENCE
Wells need to be examined periodically (normally during sampling) to determine if they have
been damaged, vandalized, or otherwise compromised, and to check for evidence of
disintegration such as cracked casing, pads, or surface seals, and to check the security of the
well (locked cap).
TETRA TECH, INC.
Standard Operating Procedure
Revision Date: 4/21/2023
Created by: Anthony Camacho
Project name: Recycled Earth
Page 12 of 12

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