DERR-2025-002803

12/14/23, 4:37 PM State of Utah Mail - Limited Soils Removal Plan for Arsenic Exceedances, Chromalox Building Expansion Project
https://mail.google.com/mail/u/0/?ik=75050723fc&view=pt&search=all&permthid=thread-f:1785107871467465076&simpl=msg-f:17851078714674650…1/4
Chris Howell <[e-mail]>
Limited Soils Removal Plan for Arsenic Exceedances, Chromalox Building Expansion Project
4 messages
Ellington, Byron <[e-mail]>Tue, Dec 12, 2023 at 1:05 PM
To: "[e-mail]" <[e-mail]>, Scott Everett <[e-mail]>
Cc: "Craig Bushey (ETS CHX US)" <[e-mail]>, "Paul Reiff (CONS)" <[e-mail]>, "Duke, Michael" <[e-mail]>, "Nate
Meyerhoffer (ETS CHX US)" <[e-mail]>, "Stephanie Lara (ETS CHX US)" <[e-mail]>, "travis.loftus"
<[e-mail]>
Hi Chris and Scott,

Attached is the plan you requested during our last call. The soils acceptance letter from EK Bailey is still being drafted but we hope to have that to you soon.

Specific to the attached plan, we felt we needed an upfront comparison of field XRF performance with lab results for arsenic so that we could develop a correlation
adjustment factor (if needed) between field readings and laboratory analytical results. A description of our approach is on page two of the attached. We are still waiting
on laboratory results to compare to the field XRF, and we will share those with you when received (hopefully tomorrow). As a heads up, our XRF field readings on the
collocated samples were all well below the previous values from June 2023. As you know, collocating of soils samples is always difficult. If the lab results comeback in
alignment with the June 2023 samples, we will develop a correlation factor adjustment that should be acceptable to you, and from there, continue with the implementation
of the arsenic soils removal plan. However, if the lab results are in alignment with the low field XRF values (all being below arsenic of 15 mg/kg), we will request that
those soils be allowed for release to EK Bailey for industrial purposes.

As always, thank you for all of your help during this process and feel free to reach to any of us if you have any questions.

Byron Ellington, CPG, PG (TX, UT)
Director
RPS/Tetra Tech | North America
4801 Southwest Parkway, Parkway 2, Suite 150
Austin TX 78735, USA
D 512.579.3315 M 512.771.0863
E [e-mail]
On 24 January 2023, RPS became a Tetra Tech company. This represents an exciting new chapter for our business. Tetra Tech is a leading provider of consulting and engineering services, and our combined
offering and technical capability is broad and deep.
The level of service and commitment you have come to expect from RPS will continue seamlessly and assuredly. While we will be changing our name to ‘RPS, A Tetra Tech Company’, there will be no change to
our team or your points of contact within the company.
If you have any questions about this news, please don’t hesitate to contact me.
Follow us on: rpsgroup.com | LinkedIn | Facebook | Instagram | YouTube

Final Arsenic Soils Removal Plan.pdf
358K
Ellington, Byron <[e-mail]>Wed, Dec 13, 2023 at 3:33 PM
To: "[e-mail]" <[e-mail]>, Scott Everett <[e-mail]>
Cc: "Craig Bushey (ETS CHX US)" <[e-mail]>, "Paul Reiff (CONS)" <[e-mail]>, "Duke, Michael" <[e-mail]>, "Nate
Meyerhoffer (ETS CHX US)" <[e-mail]>, "Stephanie Lara (ETS CHX US)" <[e-mail]>, "travis.loftus"
<[e-mail]>
Hi Chris and Scott,

As follow up to yesterday’s email, below are the results comparing the field XRF versus laboratory samples. As you can see there is not very good comparisons between
any of the samples (field XRF, June 2023 lab, or December 2023 lab). I looked again at the lab reports and there are no qualifiers or qc issues noted when it comes to
arsenic or the EPA method.

12/14/23, 4:37 PM State of Utah Mail - Limited Soils Removal Plan for Arsenic Exceedances, Chromalox Building Expansion Project
https://mail.google.com/mail/u/0/?ik=75050723fc&view=pt&search=all&permthid=thread-f:1785107871467465076&simpl=msg-f:17851078714674650…2/4

Our intent Friday was to gather enough data on which to build a correlation factor so that the planned removal could occur quickly and verification would be reliant on the
field XRF. However, considering the newest lab data indicating arsenic at concentrations below 15 mg/kg in the suspect areas, Chromalox respectfully request that UDEQ
allow soils from those locations (SB-5, SB-8, SB-10, and SB-11) be handled consistent with our November 30, 2023 letter and ongoing conversations.

Chromalox Arsenic Sampling
XRF Versus Lab Comparison Sampling `June 2023 Soil
Sampling from
Investigation Boreholes
(mg/kg)Date Sampled Time Sampled SB#Sample Id Depth Moisture %
XRF Result
(PPM)(+-)Lab results (mg/kg)
12/8/2023 917 5 A5-SS01-0'-5'2.5'34 LOD 6 6.59 22.2
12/8/2023 925 5 A5-SS02-5.5'5.5'32 LOD 5 8.3 <2
12/8/2023 950 8 A8-SS01-0'-5'2.5'2 LOD 5 8.07 44
12/8/2023 957 8 A8-SS02-5.5'5.5'3 12 6 4.56 <2
12/8/2023 1030 10 A10-SS01-0'-5'2.5'5 14 5 8.6 29.5
12/8/2023 1040 10 A10-SS02-5.5'5.5'10 20 6 4.24 4.12
12/8/2023 1105 11
A11-SS01-
5'-10'7.5'4 15 6 11.2 34.2
12/8/2023 1120 11
A11-SS02-
10.5'10.5'8 LOD 5 7.64 NS
Notes:
LOD=Below Limit of Detection for the XRF Field Analyzer
NS - Interval not sampled in June 2023
Thank you and please let us know if you have any questions.

Sincerely,
[Quoted text hidden]
L1686253.pdf
2586K
Chris Howell <[e-mail]>Wed, Dec 13, 2023 at 4:51 PM
To: "Ellington, Byron" <[e-mail]>
Cc: Scott Everett <[e-mail]>, "Craig Bushey (ETS CHX US)" <[e-mail]>, "Paul Reiff (CONS)" <[e-mail]>, "Duke,
Michael" <[e-mail]>, "Nate Meyerhoffer (ETS CHX US)" <[e-mail]>, "Stephanie Lara (ETS CHX US)"
<[e-mail]>, "travis.loftus" <[e-mail]>
Byron,
Thank you for putting this together. Please let me know when you have the document signed by EK Bailey limiting the use of soil taken from the site.
Regards,
Chris
[Quoted text hidden]
--
Christopher Howell P.G.
Env. Scientist | VCP/Brownfields Section
Cell: [phone]
environmentalresponse.utah.gov
12/14/23, 4:37 PM State of Utah Mail - Limited Soils Removal Plan for Arsenic Exceedances, Chromalox Building Expansion Project
https://mail.google.com/mail/u/0/?ik=75050723fc&view=pt&search=all&permthid=thread-f:1785107871467465076&simpl=msg-f:17851078714674650…3/4
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Ellington, Byron <[e-mail]>Thu, Dec 14, 2023 at 1:26 PM
To: Chris Howell <[e-mail]>
Cc: Scott Everett <[e-mail]>, "Craig Bushey (ETS CHX US)" <[e-mail]>, "Paul Reiff (CONS)" <[e-mail]>, "Duke,
Michael" <[e-mail]>, "Nate Meyerhoffer (ETS CHX US)" <[e-mail]>, "Stephanie Lara (ETS CHX US)"
<[e-mail]>, "travis.loftus" <[e-mail]>, Brent Bailey <[e-mail]>
Chris and Scott,

Attached is the letter from EK Bailey we have been discussing. Please let us know if the letter meets your needs and thank you for working with us through these issues.

Sincerely,

Byron Ellington, CPG, PG (TX, UT)
Director
RPS/Tetra Tech | North America
4801 Southwest Parkway, Parkway 2, Suite 150
Austin TX 78735, USA
D 512.579.3315 M 512.771.0863
E [e-mail]
On 24 January 2023, RPS became a Tetra Tech company. This represents an exciting new chapter for our business. Tetra Tech is a leading provider of consulting and engineering services, and our combined
offering and technical capability is broad and deep.
The level of service and commitment you have come to expect from RPS will continue seamlessly and assuredly. While we will be changing our name to ‘RPS, A Tetra Tech Company’, there will be no change to
our team or your points of contact within the company.
If you have any questions about this news, please don’t hesitate to contact me.
Follow us on: rpsgroup.com | LinkedIn | Facebook | Instagram | YouTube

From: Chris Howell <[e-mail]>
Sent: Wednesday, December 13, 2023 5:52 PM
To: Ellington, Byron <[e-mail]>
Cc: Scott Everett <[e-mail]>; Craig Bushey (ETS CHX US) <[e-mail]>; Paul Reiff (CONS) <[e-mail]>; Duke,
Michael <[e-mail]>; Nate Meyerhoffer (ETS CHX US) <[e-mail]>; Stephanie Lara (ETS CHX US)
<[e-mail]>; travis.loftus <[e-mail]>
Subject: Re: Limited Soils Removal Plan for Arsenic Exceedances, Chromalox Building Expansion Project

[Quoted text hidden]
Christopher Howell P.G.
Env. Scientist | VCP/Brownfields Section
Cell: [phone]
12/14/23, 4:37 PM State of Utah Mail - Limited Soils Removal Plan for Arsenic Exceedances, Chromalox Building Expansion Project
https://mail.google.com/mail/u/0/?ik=75050723fc&view=pt&search=all&permthid=thread-f:1785107871467465076&simpl=msg-f:17851078714674650…4/4
environmentalresponse.utah.gov
[Quoted text hidden]
EK Bailey Construction - Aknowledgement & Agreement Letter.pdf
187K