December 22, 2014 Mr. Ken Wangerud U.S. Environmental Protection Agency, Region 8 Office of Ecosystems Protection and Remediation 1595 Wynkoop Street Denver, CO 80202-1129 Project: US Magnesium NPL Site Tooele County, Utah EPA Site ID No. UTN000802704 U.S. EPA Contract No. EP-W-06-006, Work Assignment No. 130-RSBD-08PU Subject: Phase 1A Air Monitoring Program Field Oversight Dear Mr. Wangerud:

Under Work Assignment No. 130-RSBD-08PU, Pacific Western Technologies, Ltd. and team partner Tetra Tech Inc. (PWT3) conducted oversight of the Phase 1A air RI monitoring program field activities at the US Magnesium NPL Site (US Mag). PWT3 personnel were on-site from August 18-21, 2014 to oversee the implementation of the Phase 1A RI air monitoring program and ensure that ERM is conducting the sampling in accordance with the Phase 1A Remedial Investigation Sampling and Analysis Plan for Operable Unit 2 – Ambient Air (Phase 1A Air SAP) (ERM 2014).

This Phase 1A Air Monitoring Program Field Oversight Report provides a summary of the field oversight activities, deviations from governing documents, observations, issues and resolutions, and decisions. Copies of field oversight checklist, field logbook notes, and a photograph log are provided as attachments.

The duration of the Phase 1A RI air monitoring program was expected to last approximately one month. During this time period ERM proposed to collect 10, 72-hour (hr) continuous samples at each of 3 monitoring stations (30 total samples). PWT3 personnel were originally tasked with overseeing the initial installation of sampling and monitoring equipment, an entire sample “life cycle” of a 72-hr sample event, and final calibrations and shut down of equipment after the final 72-hr event. Pursuant to Record of Oversight QAPP Modification 14C-2-4, the final event oversight visit was deemed not necessary. The PWT3 personnel were present for the initial calibration and the first 72-hr sample event.

The project-specific governing documents associated with this work are listed below:

Governing Documents EPA/PWT • Phase 1A Remedial Investigation Oversight Quality Assurance Project Plan, Revision 0, US

Magnesium NPL Site, (PWT3, October 2013) • Record of Oversight QAPP Modification 14C-2-2 • Record of Oversight QAPP Modification 14C-2-4

ERM/US Magnesium • Phase 1A Remedial Investigation Sampling and Analysis Plan for Operable Unit 2 – Ambient Air

US Magnesium RI/FS Rowley, Utah, Revision 1, July 2014 • Final Air Demonstration of Methods Applicability Work Plan Preparatory to Phase-1A Remedial

Investigations for US Magnesium NPL Site EPA Site Identification No. UTN000802704 Tooele County, Utah, March 2013

US Mag Phase 1A Air Monitoring Program OS Report Page 1 of 5

• Specification for “Stage 2” Demonstration of Methods Applicability for the Ambient Air Preliminary Remedial Investigation (PRI) 18 - Revised, March 3, 2014

General Narrative of Site Activities: The Phase 1A RI air monitoring program consisted primarily of the following key activities:

• Initial equipment calibration and programming prior to sample collection • Receipt and documentation of clean sample media from respective ERM-subcontracted

laboratories • Preparation of sample media and insertion into respective cassettes prior to sampling • Sampling and analysis for Contaminants of Potential Concern (COPC) proposed in Phase 1A Air

SAP • Daily checks on sampling and monitoring systems during sample events • Final removal and documentation of samples after 72-hr sample collection period • Equipment calibrations, maintenance, and sample removal and insertion of clean sample media

for subsequent sample event • Processing and documentation of all sample media at the completion of sampling • Preparation of Chain of Custody (COC) forms and final shipment of all sample media to

respective ERM-subcontracted laboratories.

From August 18 through 21, 2014, Doug Herlocker, PWT3 Field Team Leader, was on-site to oversee air monitoring field activities. Additional details of these activities as they occurred on each day and associated timeframes for days activities are presented below.

August 18, 2014: PWT3 mobilized to the main parking lot, proceeded to the ERM site trailer, and conducted oversight for equipment calibration, programming and initiation of the first 72-hr sample event at the location designated as PRI-18-003 (Site 3) near the entrance to Hill Brothers. Site activities for this date also included receipt, documentation, and preparation of clean sample collection media. PWT3 closely monitored ERM’s activities to ensure that all procedures were in compliance with the Phase 1A Air SAP.

At the end of the workday, ERM had successfully completed all necessary steps to begin sample event 1 at Site 3. The following equipment was programmed, calibrated, and began operating at Site 3:

• Tisch Environmental Inc. (Tisch) PUF High Volume (Hi-Vol) Sampler (TO-9 sample collection) • Tisch PUF Hi-Vol Sampler (TO-4/TO-13 sample collection) • Tisch PM10 Hi-Vol Sampler • Tisch TSP Hi-Vol Sampler • One (1) 6-liter Summa canister with low volume flow orifice (TO-15 sample collection) • Two (2) IS BM25 HCl and Cl2 monitors

Health and Safety: Completed tailgate meeting with ERM personnel; No low or high levels alarms on IS MX6 air monitor detected; PWT3 downloaded and screened one minute data to PWT3 on-site laptop computer.

Issues or Equipment Failures: PWT3 personnel did not observe any deviations from the Phase 1A Air SAP or equipment failures.

Time frame for day’s activities: • 07:05 – PWT3 arrive on-site; complete health and safety tailgate meeting with ERM personnel • 07:45 – ERM begin sample media documentation and preparation • 09:00 – ERM/PWT3 arrive at Site 3; begin programming, calibration, and testing of monitoring

equipment listed above • 10:00 – ERM begin sample event 1 at Site 3 and recording starting parameters for all samplers

US Mag Phase 1A Air Monitoring Program OS Report Page 2 of 5

• 10:20 – ERM/PWT3 depart Site 3 and arrive at site trailer; ERM prepared IS BM25 unit and cal gas for deployment to Site 3

• 11:05 – ERM/PWT3 arrive at Site 3; ERM transported two (2) BM25 monitors and calibration gas to site; both monitors calibrated

• 11:50 – ERM place BM25 monitors into operation • 12:05 – ERM/PWT3 depart Site 3; proceed to ERM site trailer • 13:15 – ERM/PWT3 complete final discussion on day’s events, schedule for tomorrow, and

technical issues • 13:45 – PWT3 depart US Magnesium facility

Weather: Sunny and warm with light winds out of west and southwest.

August 19, 2014: PWT3 mobilized to the main parking lot and proceeded to ERM site trailer to conducted oversight for second day of Phase 1A air sampling. Activities included the calibration, programming, and initiation of the first 72-hr sample event at PRI-18-002 (Site 2) near the ATI fence line. ERM recorded sample parameters on ERM field sheets. PWT3 closely monitored ERM’s activities to ensure that all procedures were in compliance with the Phase 1A Air SAP.

During the PUF cartridge sample preparation PWT3 observed some slight shifting of XAD media (see top right photo, page 7 of Attachment); however, shifting was minimal and not as extreme as witnessed during the Stage 2 DMA sampling. ERM successfully calibrated all samplers at Site 2 and began second sample event. During the calibration of the BM25 monitors at Site 2, one of the monitor’s Cl2 sensor failed calibration and as a result did not collect Cl2 data.

ERM also completed a daily check at Site 3 after completing activities at Site 2. Upon arrival, PWT3 personnel noted that all samplers were running as normal. All four (4) Hi-Vol samplers were running with normal flows and Summa canister vacuum was recorded in normal range. Both BM25 monitors displayed 0.0 and 0.1 PPM Cl2 and HCl, respectively.

At the end of the workday, ERM had successfully completed all necessary steps to begin the first 72-hr sample event at Site 2. Daily equipment checks were completed at Site 3 and demonstrated that the first sample event had run continuously for approximately 26.5 hours. The following equipment was programmed, calibrated, and began operating at Site 2:

• Tisch Environmental Inc. (Tisch) PUF Hi-Vol Sampler (TO-9 sample collection) • Tisch PUF Hi-Vol Sampler (TO-4/TO-13 sample collection) • Tisch PM10 Hi-Vol Sampler • Tisch TSP Hi-Vol Sampler • One (1) 6-liter Summa canister with low volume flow orifice (TO-15 sample collection) • Two (2) IS BM25 HCl and Cl2 monitors; one unit had faulty HCl sensor

Health and Safety: Completed tailgate meeting with ERM personnel; no low or high levels alarms on IS MX6 air monitor detected; PWT3 downloaded and screened one minute data to PWT3 on-site laptop computer.

Issues or Equipment Failures: PWT3 personnel did not observe any deviations from the Phase 1A Air SAP; however, BM25 calibration failed at Site 2 effectively invaliding HCl data.

Time frame for day’s activities: • 07:05 – PWT3 arrive on-site; complete health and safety tailgate meeting with ERM personnel • 08:00 – ERM begin sample media documentation and preparation • 09:45 – ERM/PWT3 arrive at Site 2; begin programming, calibration, and testing of monitoring

equipment listed above • 10:30 – ERM begin sample event 1 at Site 2 and recording starting parameters for all samplers • 11:15 – ERM calibrate BM25 units using 2 separate cylinders of Cl2 and HCl calibration gas

US Mag Phase 1A Air Monitoring Program OS Report Page 3 of 5

• 11:45 – ERM complete calibration on BM25 units and discover faulty HCl sensor • 11:50 – ERM place BM25 monitors into operation • 12:00 – ERM/PWT3 depart Site 2 and arrive at site trailer; ERM drop off supplies, proceed to

Site 3 • 12:25 ERM/PWT3 arrive at Site 3; ERM/PWT3 complete visual assessment; ERM complete

daily checks on equipment • 13:05 – ERM/PWT3 depart Site 3; proceed to ERM site trailer • 13:15 – ERM/PWT3 complete final discussion on day’s events, schedule for tomorrow, and

technical issues • 13:55 – PWT3 depart US Magnesium facility

Weather: Sunny and overcast with possible thunderstorm and related showers; intermittent winds out of west.

August 21, 2014: PWT3 mobilized to the main parking lot and proceeded to ERM site trailer to conducted oversight for fourth day of Phase 1A air sampling. Activities included the collection of samples from sample event 1 at Site 3 and initiation of sample event 2 at Site 3. ERM also completed daily checks at Site 1 (PRI-18-001) and Site 2. ERM recorded sample parameters on ERM field sheets. PWT3 closely monitored ERM’s activities to ensure that all procedures were in compliance with the Phase 1A Air SAP.

Upon arrival at Site 3 for sample collection and exchange, PWT3 personnel noted that all PUF samplers had stopped running approximately 13 hrs prematurely due to a tripped GFCI breaker from the generator. Samples were removed from all four (4) Hi-Vol samplers and one-point flow audits were completed on each unit. Summa canister pressure was noted, valve closed, and removed. All four (4) Hi-vol samplers were then loaded with new sample media and a new Summa canister was deployed. The fourth sample event was started at approximately 10:10AM.

Upon arrival at Site 1 for daily equipment checks, PWT3 personnel noted that all samplers were running as normal. All four (4) Hi-Vol samplers were running with normal flows and Summa canister vacuum was recorded in normal range.

Upon arrival at Site 2 for daily equipment checks, PWT3 personnel noted that all samplers were running as normal. All four (4) Hi-Vol samplers were running with normal flows and Summa canister vacuum was recorded in normal range. BM25 unit Cl2 sensor still not functional.

ERM personnel successfully removed all sample media at Site 3 (including two PUF cartridges and filter, one PM10 filter, one TSP filter, and one summa canister) from sampling modules and prepared samples for shipment to respective laboratories. ERM completed Chain of Custody documentation.

ERM and PWT3 personnel attempted to visit ATI meteorological station but were denied access.

At the end of the workday, ERM had successfully completed all necessary steps to retrieve samples from sample event 1 and begin sample event 2 at Site 3. Daily equipment checks were completed at Sites 1 and 2.

Health and Safety: Completed tailgate meeting with ERM personnel; no low or high levels alarms on IS MX6 air monitor detected; PWT3 downloaded and screened one minute data to PWT3 on-site laptop computer.

Issues or Equipment Failures: The GFCI breaker at Site 3 tripped causing sample event 1 to terminate 12.97 hrs prior to the target 72-hr sample period. The BM25 unit Cl2 sensor at Site 2 is still not functional.

Time frame for day’s activities: • 07:20 – PWT3 arrive on-site; complete health and safety tailgate meeting with ERM personnel • 08:00 – ERM begin sample media documentation and preparation

US Mag Phase 1A Air Monitoring Program OS Report Page 4 of 5

• 08:50 – ERM/PWT3 arrive at Site 3; ERM remove samples and complete one point audit on all Hi-Vol samplers; complete calibration and programming for sample event 2

• 11:05 – ERM/PWT3 depart Site 3 • 11:10 – ERM/PWT3 arrive at Site 1; ERM complete daily checks • 11:40 – ERM/PWT3 depart Site 1 • 11:50 – ERM/PWT3 arrive at Site 2; ERM complete daily checks; ERM calibrate BM25 monitor;

Cl2 sensor still not functional • 12:25 – ERM/PWT3 depart Site 2 and proceed to site trailer • 13:00 – ERM process samples and COC for shipment to respective laboratories • 14:30 – ERM/PWT3 depart site trailer and proceed to ATI to inspect meteorological tower • 14:35 – ERM/PWT3 denied access at ATI front gate; return to site trailer • 14:45 – ERM/PWT3 complete final discussion on day’s events and technical issues • 15:05 – PWT3 depart US Magnesium facility

Weather: Sunny and overcast with possible thunderstorm and related showers; intermittent winds out of southwest.

NOTE: This Phase 1A Air Monitoring Program Field Oversight Report is written from the perspective of the conclusion of the PWT3 field oversight activities. Statements below are accurate as of August 21, 2014 and issues noted below were resolved after August 21, 2014.

Proposed Schedule for Remaining Air Monitoring:

As discussed above PWT3 completed oversight for one complete 72-hr sample event to confirm that ERM was closely following methods described in the Phase 1A Air SAP. The remainder of the Phase 1A air monitoring program is expected to continue uninterrupted for the next 30-45 days.

Description of Deviations from PWT’s Oversight QAPP:

No deviations from the PWT Oversight QAPP were noted.

Description of Deviations from the Phase 1A SAP:

As previously discussed, all four Tisch (4) Hi-Vol samplers during sample event 1 at Site 3 prematurely terminated due to a tripped GFCI breaker. EPA was notified of this issue and discussions are underway with the EPA team to determine the minimum required duration for a Phase 1A sample event to be considered valid. Sample event 1 ran for 59.03 hours.

Summary and Conclusions

The objective of the Phase 1A air monitoring program is to collect a valid dataset of sufficient quantity and quality to support the evaluation of chronic COPCs in air. ERM completed all tasks observed by PWT3 in accordance with the Phase 1A Air SAP. ERM allowed PWT3 personnel to observe and document all aspects of the monitoring program including: sample preparation, pre-sampling field calibrations and programming, daily field checks, final sample retrieval and post-sampling field calibrations, sample handling, and COC preparation. It is the assessment of PWT3 that the success of this approach for air monitoring will be dependent on management and maintenance of equipment, careful filter handling and documentation, and adequately trained field personnel.

Attachments

Attachment A: PWT3 Field Checklist and logbook notes (Electronic PDF copies)

Attachment B: Field Oversight Photographic Documentation

US Mag Phase 1A Air Monitoring Program OS Report Page 5 of 5

Attachment A

PWT3 Field Checklist and Logbook Notes

Attachment B

Field Oversight Photographic Documentation