DSHW-2024-005602

[Date]
PROOFREAD….THE DOCUMENT!!
Erin Trinchitella
Director, Base Operations
Tooele Army Depot - South
JMTE-BON, Bldg. 501
1 Tooele Army Depot
Tooele, UT 84074-5003
RE:Comments on TEAD-S Open Detonation 2023 Sampling ReportUT5210090002
Dear Ms. Trinchitella:
On January 22, 2024, Tooele Army Depot - South Area (TEAD-S) submitted the Sampling Report for the2023 compliance sampling conducted at the Open Detonation (OD) range area (DSHW2024004291).
TheDivision of Waste Management and Radiation Control has completed its review of the report and comments based on thisreview are attached. Please respond to the comments and make any
necessaryrevisions to the 2023 AnnualCompliance Sampling Report within 30 days of the date of this letter.
If you have any questions, please call Gabrielle Marinick at 385-499-0172.
Sincerely,
Douglas J. Hansen,Director
Division of Waste Management and Radiation Control
DJH/GEM/[???]
Enclosure:Comments on TEAD-S Open Detonation 2023 Sampling Report
(DSHW-2024-XXXXXXX)
c:Local health Department (go to U:\HW General Folders\Local Health Depts and Dist. Engineers and insert correct health department file)
List all other persons who are to receive copies, including division staff.
List email addresses next to the names of persons who are to receive a copy via email. List mailing addresses next to the names of persons who are to receive a hard copy.
Division of Waste Management and Radiation Control
Comments on 2023 Sampling Report for Open Detonation Range at
Tooele Army Depot South
Section 6.1 – OD Range Exceedances
Benzylbutyl Phthalate is listed, though Table 4 shows the analyte was not detected in any samples. It is also not included in Table 10, which provides the justification for this section.
Please explain why Benzylbutyl Phthalate is included in this section or revise the report accordingly.
According to Table 3 and Table 10, Aluminum was not in exceedance and does not need to be included in this section. See discussion in Table 10 section below. Please explain why Aluminum
is included in this section or revise the report accordingly.
Table 10 - Baseline (2018) and 2023 Data Comparison
The 2023 maximum for 2,4-Dinitrotoluene under “Explosives” is listed as “ND”.The maximum in Table 2 is 0.146 mg/kg (sample DU1-3-112823). Please revise, including necessary color-coding
according to this value.
The 2023 maximum for 2-Amino-4,6-dinitrotoluene is listed as 0.262 mg/kg, Table 2 shows this value carries a “U” qualifier indicating the analyte was analyzed for, but not detected or
is qualified as non-detect because of blank contamination(sample DU2-1-112823).The maximum in Table 2 is0.222 mg/kg (sample DU1-1-112823). Please revise.
HMX is color-coded green indicating that the 2023 max exceeds the baseline max, but the 2023 value is less than the baseline max. Please reviseaccordingly to show this value is between
the baseline minimum and baseline maximum.
Aluminum is color-coded indicating that the 2023 max exceeds the baseline max, but the 2023 value is less than the baseline max. Please revise to show this value is between the baseline
minimum and baseline maximum.Additionally, Section 6.1 of this reportshould be revised as indicated above. 
The 2023 maximum for Antimony is listed as 0.648 mg/kg. The maximum in Table 3 is 0.665 mg/kg (sample DU1-2-112823). Please revise.
The 2023 maximum for Copper is listed as 84.4 mg/kg. The maximum in Table 3 is 114 mg/kg (sample DU2-3-112823).Please revise.
The 2023 maximum for Silver is listed as 0.159 mg/kg. The maximum in Table 3 is 0.16 mg/kg (sample DU2-3-112823).Please revise.
The maximum for Thallium is listed as 0.329 mg/kg. The maximum in Table 3 is 0.332 mg/kg (sample DU2-2-112823). Please revise.
The maximum for Anthracene is listed as 0.012 mg/kg. The result is not listed in Table 5. The maximum in Table 5 is 0.00826 mg/kg (sample DU1-1-112823).
The maximum for Acenaphthylene is listed as 0.005 mg/kg. Table 5shows this value carries a “U” qualifier indicating the analyte was analyzed for, but not detected or is qualified as
non-detect because of blank contamination.The maximum in Table 5 is0.003 mg/kg (sample DU13112823). Please revise.
Table 11 - Maximum Detection Trending Summary, OD Range
The 2023 maximum for 2,4-Dinitrotoluene under “Explosives” is listed as “ND”. The maximum in Table 2 is 0.146 mg/kg (sample DU1-3-112823)Please revise.
The 2023 maximum for 2-Amino-4,6-dinitrotoluene islisted as 0.262 kg/mg. The maximum in Table 2 is 0.222 mg/kg (sample DU1-1-112823). Please revise.
The 2023 maximum for Antimony islisted as 0.648 mg/kg. The maximum in Table 3 is 0.665 mg/kg (sample DU1-2-112823).Please revise.
The 2023 maximum for Copper islisted as 84.4 mg/kg. The maximum in Table 3 is 114 mg/kg (sample DU2-3-112823).Please revise.
The 2023 maximum for Silver islisted as 0.159 mg/kg. The maximum in Table 3 is 0.16 mg/kg (sample DU2-3-112823).Please revise.
The 2023 maximum for Thallium islisted as 0.329 mg/kg. The maximum in Table 3 is 0.332 mg/kg (sample DU2-2-112823).Please revise.
The 2023 maximum for Anthracene is listed as 0.012 mg/kg. The maximum in Table 5 is 0.00826 mg/kg (sample DU1-1-112823). Please revise.
The 2023 maximum for Acenaphthylene islisted as “ND”.The maximum in Table 5 is0.003 mg/kg (sample DU13112823).Please revise.
The 2023 maximum for Benzo(a)anthracene is listed 0.008 mg/kg. The maximum in Table 5 is 0.01 mg/kg. Please revise.
The 2023 maximum for Benzo(g,h,i)perylene is listed as 0.022 mg/kg. The maximum in Table 5is 0.015 mg/kg. Please revise.
The 2023 maximum for Chrysene is listed as 0.018 mg/kg.The maximum in Table 5 is 0.009 mg/kg. Please revise.
The 2023 maximum for Fluorantheneis listed as 0.063 mg/kg. The maximum in Table 5 is 0.039 mg/kg. Please revise.

The 2023 maximum for Fluorene is listed as 0.002 mg/kg. The maximum in Table 5is 0.007mg/kg. Please revise.
The 2023 maximum for Indeno(1,2,3-cd)pyrene islisted as 0.009 mg/kg. The maximum in Table 5 is 0.006 kg/mg. Please revise.
The 2023 maximum for Naphthalene is listed as 0.008 mg/kg. The maximum in Table 5is 0.012 mg/kg. Please revise.
The 2023 maximum for Phenanthrene is listed as 0.088 mg/kg. The maximum in Table 5 is 0.056 mg/kg. Please revise.
The 2023 maximum for Pyrene is listed as 0.161 mg/kg. The maximum in Table 5 is 0.08 mg/kg. Please revise.
Data Validation Report
The quality control summary in the lab data shows that both Antimony and Manganese were detected in the method blank. Section 5.3 of the data validation discusses the presence of antimony
with reasoning as to why the data did not need a qualifier. Please revise the report to include a similar analysis as to why the Manganese data also did not require a qualifier.