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Draft Human Exposure Survey Work Plan David Abranovic to: Ken Wangerud 12/21/2012 12:26 PM "[email protected]", Wendy OBrien, Dan Wall, "'Bill Brattin' Cc: ([email protected])", Robert Edgar, "'[email protected]' ([email protected])", "'Scott Everett' ([email protected])", "R. History: This message has been forwarded. Ken Please find attached the Draft Human Exposure Survey Work Plan for your review. I have included both a pdf of the entire document and a word file of the text. Feel free to contact me or Mark Jones at (916) 924-9378 anytime if you have any questions regarding this document. david _____________________________________ David J. Abranovic P.E. Partner ERM West, Inc. 7272 E. Indian School Road, Suite 100 Scottsdale, Arizona 85251 T: 480-998-2401 F: 480-998-2106 M: 602-284-4917 [email protected] www.erm.com One Planet. One Company. 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Please visit ERM's web site: http://www.erm.com - USMag HE Survey WP Draft to USEPA.docx - Draft_HE_Survey_WP.pdf Draft Human Exposure Prepared for: Survey Work Plan US Magnesium, LLC Remedial Investigation/Feasibility Study US Magnesium Site Rowley, Utah December 2012 The world’s leading sustainability consultancy US Magnesium, LLC Draft Human Exposure Survey Work Plan Remedial Investigation/Feasibility Study US Magnesium Site Rowley, Utah December 2012 Project No. 0132320 David Abranovic Partner Project Manager Jennifer Holder, Ph.D. Partner Risk Assessment Leader Mark Jones Program Director ERM-West, Inc. 7272 E. Indian School Road, Suite 100 Scottsdale, AZ 85251 T: 480-998-2401 F: 480-998-2106 TABLE OF CONTENTS TABLE OF CONTENTS i LIST OF FIGURES iii LIST OF TABLES iii LIST OF ACRONYMS iv 1.0 INTRODUCTION 1-1 1.1 SITE BACKGROUND 1-2 1.2 STUDY AREA 1-2 1.3 CONCEPTUAL SITE MODEL AND IDENTIFICATION OF HUMAN RECEPTORS 1-4 1.3.1 Current and Future Land Use 1-4 1.3.2 Relevant Exposure Scenarios – Receptors and Routes 1-4 2.0 SURVEY GOALS AND OBJECTIVES 2-1 2.1 STEP 1: STATE THE PROBLEM 2-1 2.2 STEP 2: IDENTIFY THE GOALS OF THE STUDY 2-2 2.3 STEP 3: IDENTIFY INFORMATION INPUTS 2-2 2.4 STEP 4: DEFINE THE BOUNDARIES OF THE STUDY 2-3 2.5 STEP 5: DEVELOP THE ANALYTICAL APPROACH 2-3 2.6 STEP 6: SPECIFY PERFORMANCE OR ACCEPTANCE CRITERIA 2-3 2.7 STEP 7: DEVELOP THE PLAN FOR OBTAINING DATA 2-5 3.0 LITERATURE REVIEW 3-1 4.0 EXPOSURE SURVEY DESIGN 4-1 4.1 STUDY POPULATION 4-1 4.1.1 On-Site US Magnesium Worker 4-2 i 4.1.2 Off-Site Workers at Adjacent Facilities 4-3 4.1.3 Federal and/or State Resource Managers 4-4 4.1.4 Off-Site Recreational Visitors 4-4 4.1.5 Ranchers 4-5 4.1.6 Seasonal Brine Shrimp Workers 4-6 4.2 CHARACTERIZATION OF RECREATIONAL VISITORS 4-6 4.3 SAMPLING METHODS 4-7 4.3.1 Small, Defined Subgroups (i.e., fewer than 30 People) 4-7 4.3.2 Large Subgroups 4-8 4.4 SURVEY IMPLEMENTATION 4-11 4.4.1 Pilot Survey 4-11 4.4.2 Survey Methods 4-11 4.4.3 Recruiting Strategy 4-12 4.4.4 Survey Team and Training Requirements 4-13 4.5 DRAFT SURVEY QUESTIONS 4-14 4.6 DATA PROCESSING 4-14 4.6.1 Data Entry 4-14 4.7 DEVELOPMENT OF EXPOSURE PARAMETERS 4-16 5.0 SUMMARY 5-1 6.0 REFERENCES 6-1 APPENDIX A — DRAFT HUMAN EXPOSURE SURVEY QUESTIONS ii LIST OF FIGURES Figure 1- 1 Human Exposure Survey Flowchart Figure 1-2 Site Location Map Figure 1-3 Preliminary Remedial Investigation Areas Figure 1-4 Conceptual Site Model Figure 4-1 Camping and ATV Locations Figure 4-2 Box Elder Hunting Unit Figure 4-3 Fishing Locations LIST OF TABLES Table 4-1 US Magnesium Hourly Worker Schedules Table 4-2 Desired Sample Sizes for On-Site Workers Table 4-3 Desired Sample Sizes for ATI Employees iii LIST OF ACRONYMS ATV All-terrain vehicle BLM Bureau of Land Management CSM Conceptual site model CTE Central tendency exposure DQO Data quality objective DWR Department of Wildlife Resources ERM ERM-West, Inc. FS Feasibility study HHRA Human health risk assessment MWH Montgomery Watson Harza PRI Preliminary remediation investigation RI Remedial investigation RME Reasonable maximum exposure RSE Relative standard error SLC Salt Lake City US Mag US Magnesium, LLC USEPA United States Environmental Protection Agency iv 1.0 INTRODUCTION ERM-West, Inc. (ERM) has been retained by US Magnesium, LLC (US Mag) to perform remedial investigation and feasibility study (RI/FS) services at the US Mag Site (the “Site”) located in Rowley, Utah. This Human Exposure Survey Work Plan (Work Plan) has been prepared by ERM and McDaniel Lambert, Inc., in accordance with the requirements of the Administrative Settlement Agreement and Order on Consent, which governs the performance of the RI/FS. The objective of the Work Plan is to develop a plan for collecting human exposure parameter data for specific receptors in the vicinity of the Site. This data will then be used to develop Site-specific exposure parameters for use in the baseline human health risk assessment (HHRA). It is also expected that survey responses will supply important qualitative information on the characteristics of the receptor groups and where and how they utilize the Site that can be used in the baseline HHRA to refine the conceptual site model (CSM) and exposure areas, if appropriate. The human exposure survey discussed in this Work Plan meets the quality objectives for the RI/FS, and is consistent with Section VIII, Paragraph 27 of the Administrative Settlement Agreement and Order on Consent (USEPA 2011a). The structure of this Work Plan is outlined below: Section 1 – Introduction; Section 2 – Survey Goals and Objectives; Section 3 – Literature Review; Section 4 – Exposure Survey Design; Section 5 – Summary; Section 6 – References; and Appendix A – Draft Survey Questions. As outlined in Figure 1-1, the development of human exposure data will be based on two main efforts: (1) a literature review to identify exposure parameters for populations similar to those at the Site, and (2) a survey of the human receptor populations that use the area within the 5-mile buffer around the Site. It is expected that the information collected from both efforts will be integral in developing the exposure parameters that will be used in the baseline HHRA. ERM 1-1 US MAGNESIUM/0132320 – DECEMBER 2012 1.1 SITE BACKGROUND The Site is in northwestern Utah (Tooele County) in the Basin and Range Province of the Western United States (Figure 1-2). The Site is located in the Lakeside Valley, approximately 1 to 3 miles west of the Great Salt Lake shoreline and approximately 5 miles east of the Lakeside Mountains (Figure 1-2). Elevation at the Site is approximately 4,220 feet above mean sea level, or about 8 feet above the maximum-recorded extent of the high lake elevation (Montgomery Watson Harza [MWH] 2003). US Mag is a commercial producer of magnesium and magnesium alloys derived from brine evaporated from Great Salt Lake water. The facility has been in production since 1972 and remains active. Operations at the US Mag facility utilize solar concentration of lake brine (approximately 0.4 percent magnesium chloride) followed by several chemical treatment steps designed to remove impurities and residual oxygen content. Following this initial process, the product then undergoes electrolysis to separate magnesium and chlorine. The chlorine gas byproduct is captured and reused or sold. Wastewaters from these processes are conveyed to an evaporation pond/lagoon at the facility. This wastewater has a low pH and is not returned to the Great Salt Lake. 1.2 STUDY AREA Based on discussions with the United States Environmental Protection Agency (USEPA) Region 6, the RI/FS study area includes the area within a 5-mile radius centered on the Site. Within this study area, the following preliminary remediation investigation (PRI) areas have been identified (Figure 1-3): PRI 1: Ditches; includes the Western Ditch, Central Ditch, Chlorine Ditch, Main Ditch, and former Boron Ditch. These ditches were constructed during the initial plant construction in the early 1970s. PRI 2: Landfill; approximately 36 acres, with 11 acres currently being used for disposal of municipal and construction waste from the Site.