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Home My WebLink AboutDERR-2025-003175 Metals Treatment Technologies, LLC (MT2) has prepared this Document to address the specific requirements of the project referenced within this Document and contains proprietary and confidential information. This Document is the sole property of MT2 and must be returned upon demand. By accepting this Document, the recipient agrees to keep confidential the information and concepts contained herein or made in connection with any further investigation of the Company. Any disclosure, copying, distribution or use of the contents of this Document for other than the above stated purpose is prohibited. By accepting this Document the recipient agrees not to disclose copy, distribute or use this information for other than its intended purpose, as stated above, in whole or in part without the prior written consent of MT2. Site Characterization Plan Boy Scouts of America (BSA) Moab Base Camp Prepared for: Boy Scouts of America (BSA) Crossroads of the West Council 1200 East 5400 South Ogden, UT 84403 Prepared by: Metals Treatment Technologies, LLC 14045 W 66th Avenue Arvada, CO 80004 www.mt2.com 888-435-6645 April 2025 Site Characterization Plan BSA Moab Page i MT2 | 14045 W 66th Ave. Arvada, CO 80004 | P: 1-888-435-6645 | www.mt2.com Table of Contents PERSONNEL ................................................................................................................................ 1 OBJECTIVE .................................................................................................................................. 1 BACKGROUND ............................................................................................................................ 3 EQUIPMENT AND PERSONAL PROTECTIVE EQUIPMENT (PPE) .......................................... 3 SAMPLING PROCEDURE ........................................................................................................... 4 SAMPLE LOCATION MAP AND SAMPLING PLAN ................................................................... 4 LABORATORY ANALYSIS ....................................................................................................... 10 RESULTS AND REPORTING .................................................................................................... 10 Site Characterization Plan BSA Moab Page 1 MT2 | 14045 W 66th Ave. Arvada, CO 80004 | P: 1-888-435-6645 | www.mt2.com PERSONNEL  Jeremy Bell, BSA, Camping Director 1200 East 5400 South Ogden, UT 84403 801-645-8916 jeremy.bell@scouting.org  Kirk Kyster, Project Manager 14045 W 66th Ave Arvada, CO 80004 303-994-4948 kkyster@mt2.com  Trevor Schwaab, QC Manager 14045 W 66th Ave Arvada, CO 80004 303-619-2061 tschwaab@mt2.com  Bryan Torgerson School and Institutional Trust Lands Administration (SITLA) Assistant Managing Director 435-259-7417 bryantorgerson@utah.gov  Allison Stanley Division of Environmental Response and Remediation (DERR) Voluntary Cleanup Program (VCP) Project Manager 195 N 1950 W, Salt Lake City, UT 84116 385-391-8134 allisonstanley@utah.gov At least one of the people listed above will be onsite along with a field technician to assist in sampling activities. OBJECTIVE The objective of this study is to determine the extent of the metal and polycyclic aromatic hydrocarbon (PAH) contamination from the firing range located at the Boy Scouts of America (BSA) Moab Base Camp site. Grab samples will be collected from locations outside the range to serve as background samples to assess the natural levels of the metals in the area. Grab samples will be collected around the range boundary to assess if contamination is migrating off of the range area. Grab samples will be collected from strategic locations in the rifle range area, archery range, and shotfall area to determine the extent of the metal contamination. Additionally, grab samples will be collected at the shotgun firing line along with grab samples in strategic locations within 300 ft from the firing line to determine PAH and metal contamination within that zone. All samples will be collected from a depth of 0-3” with some additional samples collected Site Characterization Plan BSA Moab Page 2 MT2 | 14045 W 66th Ave. Arvada, CO 80004 | P: 1-888-435-6645 | www.mt2.com at depth below 3” (see below for sampling details). The samples collected for PAH analysis will be immediately placed in a cooler packed with ice to begin cooling and shipped overnight to Pace National Laboratories (Pace) for PAH analysis via US EPA Method 8270 SIM. The soil collected for PAH will also be analyzed for total metals. The soil samples collected for metals analysis will be taken back to the Metals Treatment Technologies (MT2) laboratory for screening and x-ray fluorescence (XRF) metals analysis. From this analysis, a subset of samples will be selected and sent to Pace for US EPA Toxicity Characteristic Leaching Procedure (TCLP) analysis and US EPA 6010b total metal analysis for lead (Pb), arsenic (As), antimony (Sb), copper (Cu), tin (Sn), zinc (Zn) and iron (Fe). Table 1 is presented below and lists the individual metals and PAH compounds of concern as well as the Regional Screening Levels (RSL) for each compound that will serve as the project criteria. Table 1 – National RSL for PAH and Metals Contaminate of Concern (CoC) Residential Regional Screening Level (µg/kg) Contaminate of Concern (CoC) Residential Regional Screening Level (µg/kg) Acenaphthene 3,600,000 Lead (Pb) 200,000 Anthracene 18,000,000 Arsenic (As) 680 Benzo(a)anthracene 1,100 Antimony (Sb) 31,000 Benzo(a)pyrene 110 Copper (Cu) 3,100,000 Benzo(b)fluoranthene 1,100 Tin (Sn) 47,000,000 Benzo (g, h, i) perylene Not Available* Zinc (Zn) 23,000,000 Benzo(k)fluoranthene 11,000 Iron (Fe) 55,000,000 Chrysene 110,000 Dibenz(a,h)anthracene 110 Fluoranthene 2,400,000 Fluorene 2,400,000 Indeno(1,2,3-cd) pyrene 1,100 Indene Not Available* 1-Methylnaphthalene 180 2-Methylnaphthalene 240,000 Naphthalene 2,000 Pyrene 1,800,000 Phenanthrene Not Available* *These compounds are not listed in the EPA Regional Screening Level list. The state of Utah has requested these compounds for analysis so they will be listed in the results section of the final report. Site Characterization Plan BSA Moab Page 3 MT2 | 14045 W 66th Ave. Arvada, CO 80004 | P: 1-888-435-6645 | www.mt2.com BACKGROUND Moab Base Camp is situated along Gemini Bridges Road and encompasses approximately 41 acres. The camp operates for five weeks each summer, from the beginning of June through the first week of July, offering outdoor education and leadership development programs. The firing range was constructed in 2010 for rifle shooting, with shotgun shooting added in 2015. Both activities ceased operations in 2017, and since then, the range has not been used for any official camp- sanctioned firearms activities. During its active years, the range saw an average of 20 participants per week for rifle shooting, each engaging in less than an hour of shooting per week under a pavilion, using .22 rifles to fire toward a designated berm. The shotgun shooting program, averaging 5-6 participants per week, was conducted southeast of the rifle range, using a hand thrower to launch clay pigeons for 12- gauge shotgun practice. To the west of the rifle range, archery and axe throwing were also part of the program. These activities followed structured safety protocols and were led by trained instructors. Archery and axe throwing were discontinued in 2017 and have not been used since. Beyond the shooting sports program, Moab Base Camp has supported a variety of outdoor activities within the permit boundary, contributing to the overall participant experience. These activities include:  Climbing and rappelling: Participants engage in guided rock climbing and rappelling on natural rock features within the site, emphasizing skill development, safety, and confidence building.  Camping: The camp primarily accommodates participants and staff in tent camping areas. These designated sites provide a structured yet immersive outdoor experience.  Dining and meal preparation: Meals are prepared and consumed on-site. Participants eat in communal gathering areas designed to foster social interaction and team cohesion.  Group games and team-building exercises: The camp hosts various structured and informal activities designed to encourage teamwork, leadership, and problem-solving. Open areas within the camp are used for team challenges, problem-solving exercises, and recreational games. During the off-season and shoulder season, the area is frequently used for livestock grazing under existing permits. Additionally, unauthorized recreational shooting has been observed on the property, with spent ammunition casings and other debris left behind. This mirrors similar challenges seen on other public lands managed by the Bureau of Land Management (BLM) and the U.S. Forest Service (USFS), where dispersed shooting activities by the public are common. EQUIPMENT AND PERSONAL PROTECTIVE EQUIPMENT (PPE) The sampling equipment and PPE required for this project are listed below.  Disposable Nitrile Gloves  Closed Toed Shoes  Sampling Trough  Shovel  Pickaxe  8 oz amber glass sample jars  Sample bags  Cooler packed with ice  Shipping labels to Pace Site Characterization Plan BSA Moab Page 4 MT2 | 14045 W 66th Ave. Arvada, CO 80004 | P: 1-888-435-6645 | www.mt2.com  Field Notebook  Camera SAMPLING PROCEDURE Prior to sample collection, sampling equipment will be cleaned, and new nitrile gloves will be used for each sample. What tools used for digging the samples will vary depending on site conditions. Lead wipes will be sufficient for cleaning equipment between each metal sample. Bleach disinfectant wipes will be sufficient for decontamination of PAH between each sample collected for PAH. Prior to collection, each sample will have the following information collected in the field notebook in addition to being on the sample label:  Sample Collection Location  Sample ID  Date and Time of Sample Collection  Sampling Depth  Initials of who collected the sample All large vegetative debris and larger rocks or stones will be removed from area prior to sampling. All soil dug up will be transferred to the appropriate sampling container at time of sampling. Samples collected for metal analysis will be placed into a properly labeled sealable plastic bag. For PAH samples, soil will be first transferred to a new 1-gallon plastic bag and homogenized. After homogenization, the sample will be transferred to fill an 8 oz amber glass jar. The sample will then be labeled, wrapped in bubble wrap, and placed into a cooler filled with ice. Any remaining material will be dumped back into the sample location. Used bags will be collected and properly disposed of at the MT2 laboratory. The sampling location will be photographed with geolocation turned on for coordinates. Used nitrile gloves and cleaning wipes will be collected and properly disposed of at the MT2 laboratory. SAMPLE LOCATION MAP AND SAMPLING PLAN A map of the property and the proposed sample locations for this characterization are presented below in Figures 1- 4. Samples B1 through B4 are background sampling locations and are collected to determine naturally occurring level of metals in the area. Samples RB1 through RB15 are the range boundary samples. A single duplicate will be collected from the RB sample locations. These samples are to show that no contaminates have migrated off of the range to the rest of the property. Samples A1 through A3 will be collected from the archery range to the west of the rifle range to show that no contamination has migrated into that area. Samples R1 through R10 will be collected from the rifle range and overshot area. Samples R1 and R2 will be collected at the firing line. Sample R4 will be collected from the range floor. Samples R3 and R5 will be collected from the side berms. Samples R6, R7, and R8 will be collected from the backstop berm on the left, center, and right sides of the berm. Sampling height will be determined by the samplers, based on visual conditions. Samples R9 and R10 will be collected past the backstop berm as overshot samples. All of these samples will be taken back to the MT2 laboratory and analyzed for metals via XRF. A single field duplicate will be collected from the rifle range. Site Characterization Plan BSA Moab Page 5 MT2 | 14045 W 66th Ave. Arvada, CO 80004 | P: 1-888-435-6645 | www.mt2.com Samples P1 through P25 will be collected from the clay pigeon debris field from around 30 ft from the firing line to approximately 200 ft out. Of these 25 sample locations, 5 samples plus 1 duplicate will be immediately packed on ice to start the cooling process and sent overnight to Pace National Laboratories for PAH and total metal analysis. These samples will be chosen based on clay debris density. Additionally, based on clay debris density, two samples will be taken at depth for PAH analysis. The remaining 20 sample locations will be taken back to the MT2 laboratory for XRF metals analysis. Two duplicate samples will be collected for PAH analysis, and two duplicates will be collected for metals analysis. For the shotgun shooting area, samples S1 – S3 will be collected from the firing line. Samples S4 through S19 will be collected along transects from around 200 ft from the firing line to approximately 500 ft from the firing line. These samples are used to locate the borders of the shotfall zone. Of these samples, three duplicate samples will be collected. These samples will be taken back to the MT2 laboratory for XRF metals analysis. Samples S20 and S21 will be collected from a potential drainage area to assess if the lead shot is concentrating in this area. Further samples may be collected in locations not listed in this plan, based on sampler discretion. If additional samples are collected, location and reason for the additional samples will be presented in the final report. All sampling containers will be kept in the MT2 vehicle or in a designated dry, sheltered area on the site. No pedestrian traffic on or near the site is anticipated. All sample containers will be visually inspected prior to use to confirm there are no defects or deficiencies. Each metal and PAH sample location will have a surface sample collected from 0-3” depth. Samples collected from the backstop berm at the rifle range, R6-R8, will have an additional sample collected from 3” – 12” depth. All depth samples will be selected based on visual contamination. At least two PAH samples will be collected at depth. Additional samples at depth may be collected, based on visual contamination and at the discretion of the samplers. A table showing the sampling regime is presented in Table 2. Table 2 – Sampling Regime Sampling Area Sample Analysis Type Surface Sample Quantity Depth Sample Quantity Duplicate Sample Quantity Background Metal 4 None None Archery Range Metal 3 None None Rifle Range Metal 10 3 1 Shotgun Clay Field Metal 25 None 2 Shotgun Clay Field PAH 5 2 2 Shot Field Metal 21 None 3 Site Characterization Plan BSA Moab Page 6 MT2 | 14045 W 66th Ave. Arvada, CO 80004 | P: 1-888-435-6645 | www.mt2.com Figure 1: Approximate Property Line Site Characterization Plan BSA Moab Page 7 MT2 | 14045 W 66th Ave. Arvada, CO 80004 | P: 1-888-435-6645 | www.mt2.com Figure 2: Background and Range Boundary Samples Site Characterization Plan BSA Moab Page 8 MT2 | 14045 W 66th Ave. Arvada, CO 80004 | P: 1-888-435-6645 | www.mt2.com Figure 3: Archery and Rifle Range Samples Site Characterization Plan BSA Moab Page 9 MT2 | 14045 W 66th Ave. Arvada, CO 80004 | P: 1-888-435-6645 | www.mt2.com Figure 4: Clay Target Debris and Shotfall Samples Site Characterization Plan BSA Moab Page 10 MT2 | 14045 W 66th Ave. Arvada, CO 80004 | P: 1-888-435-6645 | www.mt2.com The QC manager will verify that all samples were collected and proper documentation is completed. Any deviations or discrepancies will be reported by the QC manager. A chain of custody will be completed and sent with each sample package sent to Pace. A chain of custody will be filled out for all samples taken back to the MT2 laboratory. Copies of these chains of custody will be included in the final report. A custody seal will be attached to each sample package to ensure no tampering occurs. The cooler containing the PAH samples will be shipped overnight to Pace. The samples containing the samples taken for metal analysis will be taken to the MT2 laboratory. LABORATORY ANALYSIS The samples for PAH will be immediately placed on ice in a cooler to cool and will be shipped overnight to Pace for EPA Method 8270 analysis. Upon receipt of the samples, Pace will log them into their system and put them in a cooled location until time for analysis. If samples have not reached the required temperature of less than 4°C by the time of sample receipt, Pace may make the determination if the samples will still be sufficient for analysis. A copy of the login will be included in the laboratory report section of the final report. The samples collected for metals analysis will be taken back to the MT2 laboratory. Once delivered to the MT2 laboratory, the samples will be logged in and air dried (if necessary). Samples will be analyzed for metals via XRF analysis. MT2 utilizes a modified XRF method for analysis. The XRF will not be calibrated to site specific soil standards. MT2 will utilize total metal analysis from Pace to verify the validity of XRF analysis. Up to 10 samples that exceed 75% of any metal RSL via XRF analysis will be selected and sent to Pace for EPA SW 846 Method 1311 TCLP along with Method 6010b for total metals analysis. A minimum of 5 samples will be selected for TCLP analysis. All samples that exceed 75% of any metal RSL via XRF will be sent to Pace for total metals analysis. A minimum of 10% of samples for each area will be sent to Pace for total metals analysis. Sample hold times and requisite containers are presented below in Table 3. Table 3 – Sampling Container, Preservation, and Holding Time Soil Sample Analysis Container Type Preservation Holding Time Total Metals and TCLP Plastic bag None 180 days PAH 8 oz amber glass jar Cooled to ≤ 4° C 14 days RESULTS AND REPORTING All screening and XRF data performed by MT2 will be presented in the final report. All data validation, data packages, laboratory detection limits, and laboratory results performed by Pace National Laboratories will be presented in the final report. All Pace results will be reported via a level 3 data package. A final report will be issued containing all of the data, field notes, pictures, laboratory results, laboratory reports, areas of contamination, depth of contamination, and suggestions for remediation to comply with state and federal regulations.