2012_01_BES_USFWS_Report_2012.pdf

FINAL

BUILDING 413 SOIL AND DEBRIS CHARACTERIZATION

REPORT

BETHEL BIA 27-ACRE PARCEL SITE

YUKON DELTA NATIONAL WILDLIFE REFUGE

BETHEL, ALASKA

Requisition No. 70190114074 Order No. F11PX05149

Bethel Environmental Solutions LLC Project No. 220115006 January 2012 Prepared for:

U.S. Fish and Wildlife Service

OWNER:

US Fish & Wildlife Service - R7 Contracting & General Services 1011 East Tudor Road, Mail Stop 171 Anchorage, Alaska 99503-6199

Prepared By:

GENERAL CONTRACTOR:

Bethel Environmental Solutions LLC 2605 Denali Street, Suite 100 Anchorage, Alaska 99503-2749

Building 413 Soil and Debris Characterization, Bethel, Alaska Requisition No. 70190114074/Order No. F11PX05149 Bethel BIA 27-Acre Parcel Site, Bethel, Alaska Page i

TABLE OF CONTENTS

1.0 INTRODUCTION

1.1 Background

1.2 Physical Setting

1.3 Scope of Work

2.0 SAMPLING AND ANALYSES

2.1 Soil Sample Site Selection

2.2 Ash and Debris Samples

3.0 RESULTS OF ANALYTICAL TESTS

4.0 REFERENCES

LIST OF FIGURES

Figure1-1: Project Vicinity

Figure 1-2: BIA Composite Building 413 Sample Locations

LIST OF TABLES

Table 3-1: Sample Results for GRO, DRO, RRO, BTEX, SVOCs, and Metals

Table 3-2: Sample Results for PCBs and Dioxins/Furans

LIST OF APPENDICES

Appendix A Field Notes

Appendix B Photographic Log

Appendix C Data Validation Report and ADEC Laboratory Data Review Checklist

Appendix D Analytical Reports

Building 413 Soil and Debris Characterization, Bethel, Alaska Requisition No. 70190114074/Order No. F11PX05149 Bethel BIA 27-Acre Parcel Site, Bethel, Alaska Page ii

ACRONYMS AND ABBREVIATIONS

°C ........................ degrees Celsius ACLs .................. Alternate Cleanup Levels ADEC ................. Alaska Department of Environmental Conservation AK ...................... State of Alaska Method AST .................... Aboveground Storage Tank BIA ..................... Bureau of Indian Affairs Bethel .................. Bethel Services, Inc.

bgs ...................... Below ground surface BTEX .................. Benzene, toluene, ethylbenzene, and xylenes DQO ................... Data Quality Objectives DQR .................... Data quality report DRO .................... Diesel range organics EPA .................... Environmental Protection Agency EMPC ................. estimated maximum possible concentration FUDS .................. Formerly Used Defense Site GAC .................... Granulated Activated Carbon GRO .................... Gasoline range organics IDW .................... Investigation Derived Waste mg/kg .................. milligrams per kilogram mg/L ................... milligrams per liter ml ........................ milliliter MRL ................... Method reporting limit oz ........................ ounce PCB .................... Polychlorinated biphenyl PLM .................... Polarized Light Microscopy POL .................... Petroleum, oil, and lubricants PPE ..................... Personnel Protective Equipment QAPP .................. Quality Assurance Project Plan QC ...................... Quality control RCRA ................. Resource Conservation Recovery Act RRO .................... Residual range organics RRS .................... Radio Relay Station SAP ..................... Sampling and Analyses Plan SVOC ................. Semi Volatile Organic Compounds SW ...................... Solid Waste Method TEM .................... Transmission Electron Microscopy TEQ .................... Toxicity Equivalent µg/kg ................... micrograms per kilogram µg/l ..................... micrograms per liter USFWS ............... U.S. Fish and Wildlife Service VOC .................... Volatile organic compound WACS ................ White Alice Communication System WHO .................. World Health Organization WMP .................. Waste Management Plan

Building 413 Soil and Debris Characterization, Bethel, Alaska Requisition No. 70190114074/Order No. F11PX05149 Bethel BIA 27-Acre Parcel Site, Bethel, Alaska Page 1

1.0 INTRODUCTION

This report describes field activities conducted to characterize soil and debris adjacent to and encompassed by the remnants of Building 413 at the 27-Acre parcel at the former Bethel Bureau of Indian Affairs (BIA) Site and analytical testing results. The Bethel BIA site is comprised of two properties near Bethel Alaska, referred to as the 18-acre and 27-acre parcels, which were subdivided from a larger former U.S. Air Force site managed under the Formerly Used Defense Site (FUDS) program. Figure 1-1 shows the location of the Bethel BIA site and the boundaries of the 27-acre and 18-acre parcels.

Two representatives from Bethel Environmental Solutions, LLC (Bethel) sampled soil and ash at Building 413 on September 29, 2011 after give permission to access the site by Mr. Patrick Snow of USFWS. The objective of this sampling effort was to identify and characterize human health and environmental concerns associated with the building materials so that any required abatement or cleanup actions could be planned and implemented prior to building demolition and subsequent land transfer. The USFWS plans to transfer ownership of the 27-acre parcel to the Yukon-Kuskokwim Health Corporation (YKHC) after cleanup, as mandated by Public Law 102-497 enacted in 1992.

1.1 BACKGROUND

The Bethel BIA site, also known as the Bethel BIA Administrative Site, is a FUDS with principle cleanup responsibility resting with the U.S. Army Corps of Engineers FUDS program. The site is listed on the FUDS inventory with FUDS ID: F10AK0510 and Federal Facility ID: AK09799F699900. The Bethel BIA Site currently consists of two parcels of land, a 27-acre parcel and an 18-acre parcel (18.42 acres actual), which were pared down from a 125-acre BIA parcel over the years. Both parcels are managed by the USFWS as part of the Yukon Delta National Wildlife Refuge (YDNWR) and have differing environmental issues, responsible parties for cleanup, and future land status plans. Figure 1-2 shows the approximate boundaries of the 27- and 18-acre parcels as well as previous parcels pared down from the initial 1,467.31 acre U.S. Air Force (USAF) parcel which is shown in Figure 1-1.

The USAF first developed the site in 1957 and constructed facilities as part of the White Alice Communication System (WACS). The WACS facilities included a 60,000-square foot Composite Building (Building 413), numerous support structures, and a Radio Relay Station (RRS) located about 2,500 feet southwest of the Composite Building. The Composite Building was later used by the BIA from the early 1960's to the mid 1980's as their Bethel Administrative Headquarters. Use of the site by the BIA ended in 1990 and the site has remained vacant since that time. The condition of the abandoned facilities has continued to deteriorate over the years. The central portion of the Composite Building was destroyed by fire in August 2001. Unburnt portions of the structure, now exposed to the elements, have deteriorated significantly and, along with other derelict structures on the property, pose a physical hazard.

A number of environmental investigations, assessments, and cleanup actions have been conducted at the BIA Administrative Site and adjacent areas over the years. A review of these can be found in the Preliminary Assessment report prepared by Bethel for the USFWS, dated May 2009. Environmental contaminants and concerns identified in these reports include:

• Petroleum, oil, and lubricants (POLs) - spilled/leaked fuels related to above ground storage tanks (ASTs), bulk storage above ground tanks, associated piping, and fuels, oils, asphalt and other POLs related to drum storage and handling. Specific POL related contaminants include, diesel-range organics (DRO); residual-range organics (RRO); gasoline-range organics (GRO); and benzene, ethylbenzene, toluene, and xylenes

(BTEX).

• Asbestos – primarily within building materials used in the interior and exterior of buildings, now mainly related to Composite Building 413.

• Polychlorinated biphenyls (PCBs) – in and near Composite Building 413, the former Sewage Lagoon, borrow pits/drum storage areas, and other areas.

Building 413 Soil and Debris Characterization, Bethel, Alaska Requisition No. 70190114074/Order No. F11PX05149 Bethel BIA 27-Acre Parcel Site, Bethel, Alaska Page 2

• Lead-based paint (LBP) and potential PCBs in paint – related to Composite Building 413 and possibly other structures.

• Pesticides – dichloro-diphenyl-trichloroethane (DDT), dichloro-diphenyl-dichloro-ethylene (DDE), and dichloro-diphenyl-dichloroethane (DDD) identified near Composite Building 413, the former Sewage Lagoon, and other areas.

• Other non-contaminant hazards include physical hazards associated with abandoned and damaged buildings and other structures.

The 27-acre parcel contains most of the infrastructure constructed by the USAF and later used by the BIA during their occupancy of the site, including the 60,000-square foot Composite Building 413, several abandoned buildings, a closed sewage lagoon, and an undeveloped area impacted by a 1993 106,000-gallon fuel spill.

Several contaminant issues have been identified and addressed as a result of past investigations and remedial efforts.

The site was granted a No Further Remedial Action Required (NFRAR) decision by the State of Alaska Department of Environmental Conservation (ADEC) in 2000; however, the required institutional controls (ICs) have yet to be implemented. A fire occurred in 2001 which partially destroyed Building 413, raising new human health and environmental concerns that were unanticipated at the time of the NFRAR decision.

A 2009 site investigation conducted by Bethel Services, Inc. addressed a number of the environmental issues, including PCBs adjacent to the former septic lagoon, asbestos-containing materials at Building 413, and PCBs in Building 413 paint. High concentrations of PCBs in paint (approximately 50,000 mg/kg) indicate that dioxins, compounds generated when PCBs are combusted, may be present in the burn debris. The relevant site history and data gaps to be addressed by this site investigation are detailed in Section 3.

1.2 PHYSICAL SETTING

The Bethel BIA Site is located approximately 4 miles west of the City of Bethel, Alaska and the Kuskokwim River, as shown in Figure 1-1. Bethel is located near the mouth of the Kuskokwim River and 340 miles west of Anchorage. The city serves as a major air and water transportation hub for the region, with an estimated population of about 6,356 residents as of 2006. According to a 1992 Preliminary Assessment by the USAF 11th Civil Engineering Operations Squadron Operating Engineers (11 CEOS), 23 percent of the residents live within 1 to 2 miles of the Bethel BIA site, and the remainder of residents live more than 2 miles from the site (11 CEOS, 1992, Administrative Record [AR]03). The site is accessible year round by a gravel road that ends approximately 0.5 mile south of the site. Access to the site is currently restricted by signage and an un-manned locked gate; however, snowmobile, 4-wheeler, and foot traffic can easily bypass the gate. Other off-road trails in the area also allow unrestricted access to site.

The 18-acre and 27-acre parcels are located in the west half of Section 14, Township 8 North, Range 72 West, Seward Meridian, Alaska. Average precipitation for the Bethel area is 16 inches a year including 50 inches of snow.

Summer temperatures range from 42° to 62° Fahrenheit (F); winter temperatures average -2° to 19° F.

1.3 SCOPE OF WORK

Soil and debris (ash) sampling at Building 413 was conducted to characterize debris (and soil) primarily to protect future site workers during the planned abatement and demolition of the building, but also to plan for future debris transport and disposal needs. The USFWS provided a plan view of Building 413 with pre-determined sample locations identified, which were the basis for the selection of sample locations. Actual sample locations deviated slightly from the locations indicated on the sampling plan when debris or vegetation inhibited access. Approximate sample locations are shown on Figure 1-2.

Initial Withdrawal Property Boundary 1467 Acres

27-Acre Parcel

18-Acre Parcel

Figure 1-1Project VicinitySource: USGS BETHEL (D-8, C-8) Alaska

Date: 1/25/2012

Created by: K. Russell Building 413 Soil and Debris Characterization Bethel BIA 27-Acre Parcel Site - Bethel, Alaska

Job No:220115006

Requisition No:

70190114074

Bethel

X:\BES (V:)\USFWS\220115006 - Bethel Soil Sampling, Building 413\ACAD or Drawings or Figures\Figures

0 2,300 4,600 6,900 9,2001,150

Feet

Ü

BIA COMPOSITE BUILDING 413

SAMPLE LOCATIONS

APPROVED:

S.P.T.

DATE:

1/25/2012

DESIGNED:

J.T.

SCALE:

1” = Approx. 50’

1-2

FIGURE:

Bethel Environmental Solutions LLC A subsidiary of Bethel Native Corporation

Bethel BIA Building 413 Bethel, Alaska

SOIL SAMPLE

ASH/DEBRIS SAMPLE

N

APPROXIMATE

SCALE IN FEET

0 50

SN

SN

SN

03 SN04

SN05

SW01

SW02

SW03

SW05

AN02

AW01

AW02

SN

AN01

AN03

SW04

SW06

“11BIA” left off sample ID for brevity.

Building 413 Soil and Debris Characterization, Bethel, Alaska Requisition No. 70190114074/Order No. F11PX05149 Bethel BIA 27-Acre Parcel Site, Bethel, Alaska Page 5

2.0 SAMPLING AND ANALYSES

Sampling activities were conducted according to the Sampling Plan, and in accordance with the USFWS scope of work.

Eleven soil samples were collected from the north and west sides of Building 413, and tested for GRO by Alaska Method (AK) 101, DRO by AK 102, RRO by AK 103, BTEX by Environmental Protection Agency (EPA) method 8260B, semi-volatile organic compounds (SVOCs) by EPA 8270D, PCBs by EPA 8082, dioxins/furans by EPA 8290A, Resource Conservation Recovery Act (RCRA) Metals by EPA 6020, and asbestos by Transmission Electron Microscopy (TEM). One field duplicate sample was collected and tested for each analyte except for asbestos.

Four ash/debris samples were collected from the north and west burn areas and tested for PCBs, dioxins/furans, and RCRA metals by methods specified previously and asbestos by Polarized Light Microscopy (PLM). One duplicate ash sample set was collected and tested for PCBs, dioxins/furans, and RCRA metals. The samples were collected by Joe Thomas, a Bethel Environmental Scientist who is an ADEC-Qualified Person (18 AAC 78). Sample collection methods and procedures were performed in accordance with 18 AAC 75.

2.1 SOIL SAMPLE SITE SELECTION

Soil samples were collected from approximately equally-spaced intervals along the burned areas of Building 413.

The distance between the former exterior walls of the building and the sample locations was between 5 and 15 feet.

Sample locations were collected from soils most likely to have been impacted by burn ash or other potential contaminants based on a combination of site-specific observations such as visual evidence of ash, staining, and odor.

When little evidence of ash, staining, or odor was present, sample locations were equally-spaced along the exterior walls of the building where building materials (such as aluminum roofing material) or vegetation did not cover the ground.

Soil samples were collected from freshly exposed soils from the walls of holes advanced with a hand shovel.

Aliquots tested of non-volatile analytes were generally collected from beneath a vegetated mat that covered the ground and less than 6 inches below the ground surface (bgs). The shallow depths attempted to capture potential contaminants that typically remain near the surface or do not volatize. Aliquots for GRO and BTEX were collected from between approximately 18 inches and 24 inches bgs to minimize affects from near-surface volatilization and as suggested by ADEC guidance documents.

A new pair of nitrile sampling gloves and a clean stainless steel spoon were used to collect each sample. Field duplicate samples were collected simultaneously with the primary sample using the same techniques. Soil samples were collected in the appropriate “certified-cleaned” laboratory-provided glass sample jars with Teflon-lined lids.

Sample containers were filled as required by the analytical method. For field-preserved methods, such as GRO and BTEX, 25 milliliters (mL) of laboratory-provided methanol with surrogate was added to each pre-tarred 4-ounce jar immediately prior to sample collection. Next, approximately 50 grams of soil was quickly placed in each jar, making sure that the soil was completely covered in methanol. Samples analyzed for volatile components were collected first, followed by semi-volatiles, then non-volatile analytes. For unpreserved samples, the sample containers were filled to the top with care taken to prevent soil from remaining in the lid threads prior to being sealed to prevent potential contaminant migration from the sample.

Pertinent data and observations made during sampling, such as date and time collected, proper sample identification (ID) number, analyses requested, presence of odor or staining, collection depth, and soil type were recorded in the field logbook, included in Appendix A. Samples were stored in a cooler as soon as possible after collection. The sample cooler’s temperatures was maintained between 0° and 6° Celsius (C) during storage and transportation to the laboratory within the specified holding times.

Building 413 Soil and Debris Characterization, Bethel, Alaska Requisition No. 70190114074/Order No. F11PX05149 Bethel BIA 27-Acre Parcel Site, Bethel, Alaska Page 6

2.2 ASH AND DEBRIS SAMPLES

Four samples plus one duplicate were collected from ash and burn debris within the north and west burn areas of Building 413, and tested for PCBs, dioxins/furans, and RCRA Metals.

Asbestos samples were submitted to White Environmental Consultants of Anchorage, Alaska. Samples for the remaining analytes were submitted to SGS North America of Anchorage, Alaska with aliquots for dioxin/furans tested by SGS Wilmington, North Carolina.

Building 413 Soil and Debris Characterization, Bethel, Alaska Requisition No. 70190114074/Order No. F11PX05149 Bethel BIA 27-Acre Parcel Site, Bethel, Alaska Page 7

3.0 RESULTS OF ANALYTICAL TESTS

A summary of analytical results are provided in Tables 3-1 and 3-2. The laboratory’s analytical reports can be found in Appendix C. The results are compared with the ADEC 18 AAC 75.340 Table B1 and B2 soil cleanup levels. Table 3-1 presents the results for GRO, DRO, RRO, BTEX, SVOCs, and Metals. Note that the only SVOC compounds shown on the table are ones where the laboratory detection limit is greater than the regulatory cleanup level and that no SVOCs are detected. Table 3-2 shows results for PCB and dioxin/furan analyses.

As indicated by Table 3-1, Samples 11BIASW01 through 11BIASW03 have elevated concentrations of DRO.

These three samples were collected in the area addressed in the USAF Interim Remedial Action conducted in 1994 and potentially in the area that was excavated for off site remediation. Every soil sample, with the exception of Sample 11BIASW5, had a concentration of arsenic that exceeds the regulatory cleanup level. This may be attributable to naturally-occurring background levels, but one sample in particular (11BIASW03) had a notably high concentration. This sample was collected from dark brown and black ashy soil as shown in Photos 3 through 5 of the Photo Log (Appendix B).

Each of the ash samples collected from the raised floor of the building had concentrations of arsenic and chromium that exceeds the ADEC soil cleanup level. One ash sample also exceeds the cleanup level for lead. Since these are ash samples are from a raised floor surface and not the ground, they may not be regulated in the same manner as the other soil samples. Precautionary measures should be taken during the planned demolition of the building to prevent the ash from contaminating the surrounding ground.

Table 3-2 shows analytical results for asbestos, PCBs and dioxin/furans. One sample (11BIASW03) was measured with aroclor-1260 (a PCB compound) at a concentration slightly higher than the regulatory limit of 1,000 micrograms per kilogram (µg/kg). Four other samples had detections of aroclor-1260, but at concentrations well below the cleanup level. Analytical results indicate asbestos was not detected in the collected soil samples.

In 2005 the World Health Organization (WHO) re-evaluated the established international toxic equivalency (TEQ) factors for dioxins and furans. These TEQ values were set higher than previous WHO values in order to develop a more conservative risk assessment of the dioxin furan toxicity. The TEQs are multiplicative factors used to relate dioxin and furan congeners to the toxicity of the congener 2,3,7,8 TCDD. The ADEC regulates dioxin and furans relative to this congener, 18 AAC75 Table B1. Method Two Soil Cleanup Levels.

The dioxin and furan results are presented as the highest summation possible. The calculation included the product of the TEQ-2005 and results, the estimated maximum possible concentration (EMPC) when given, and the estimated detection limit (EDL) when not given. This ensures the worst possible case for the dioxin/furan results are compared with the ADEC regulatory limit of 58 picograms per gram (pg/g) for 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD). The results of the calculations are shown on the bottom row of the table, documenting that none of the samples have concentrations of dioxin/furans greater than the ADEC cleanup level.

Table 3-1: Sample Results for GRO, DRO, RRO, BTEX, SVOCs, and Metals

11BIASN01 11BIASN02 11BIASN03 11BIASN04 11BIASN05 11BIASN06 11BIASW01 11BIASW02 11BIASW03 11B1ASW05 11BIASW04 11BIASW06 † 11BIAAN01 11BIAN03 † 11BIAN02 11BIAAW01 11BIAAW02 Total Solids; (SM20 2540G) % 88.1 94.2 92.4 77.1 90.0 91.0 81.0 90.4 62.0 90.9 80.8 84.7 GRO; (AK 101) mg/Kg 260 1.74 J 1.16 J 1.47 J 2.30 J 1.55 J 2.37 J 4.28 1.76 J 16.3 1.50 J 2.37 J 2.79 J NS NS NS NS NS DRO; (AK 102) mg/Kg 250 74.8 47.0 30.2 215 8.22 J 7.58 J 12,100 362 570 17.0 J 13.7 J 17.8 J NS NS NS NS NS RRO; (AK 103) mg/Kg 10,000 231 159 159 1,350 89.9 64.5 304 2,420 2,310 172 133 222 NS NS NS NS NS Benzene; (SW8260B) ug/Kg 25 <10.52 <8.68 <9.12 <19.64 <14.14 <17.46 <11.2 <9.96 <22.8 <9.16 <14.54 <15.7 NS NS NS NS NS Ethylbenzene; (SW8260B) ug/Kg 6,900 <21 <17.36 <18.26 <39.2 <28.2 <35 <22.4 <19.92 <45.4 <18.34 <29 <31.4 NS NS NS NS NS o-Xylene; (SW8260B) ug/Kg <21 <17.36 <18.26 <39.2 <28.2 <35 <22.4 <19.92 <45.4 <18.34 <29 <31.4 NS NS NS NS NS P & M -Xylene; (SW8260B) <40.4 <33.4 <35.2 <75.6 <54.4 <67.2 <43 <38.4 <87.4 <35.2 <56 <60.4 NS NS NS NS NS Total xylenes; (SW8260B) ug/Kg 63,000 <61.4 <50.76 <53.46 <84.8 <82.6 <102.2 <65.4 <58.32 132.8 <53.54 85 91.8 NS NS NS NS NS Toluene; (SW8260B) ug/Kg 6,500 <21 <17.36 <18.26 <39.2 <28.2 <35 <22.4 <19.92 <45.4 <18.34 <29 <31.4 NS NS NS NS NS SVOCs; (SW8270D) mg/Kg 1,2,4-Trichlorobenzene 0.85 NS NS NS NS NS NS <3.78 NS <1.116 NS <0.1928 <0.1804 NS NS NS NS NS 1,3-Dichlorobenzene 0.28 NS NS NS NS NS NS <3.78 NS <1.116 NS <0.1928 <0.1804 NS NS NS NS NS 1,4-Dichlorobenzene 0.64 NS NS NS NS NS NS <3.78 NS <1.116 NS <0.1928 <0.1804 NS NS NS NS NS 2,4,6-Trichlorophenol 1 NS NS NS NS NS NS <3.78 NS <1.116 NS <0.1928 <0.1804 NS NS NS NS NS 2,4-Dichlorophenol 1 NS NS NS NS NS NS <3.78 NS <1.116 NS <0.1928 <0.1804 NS NS NS NS NS 2,4-Dinitrophenol 0.54 NS NS NS NS NS NS <45.4 NS <13.44 NS <2.32 <2.18 NS NS NS NS NS 2,4-Dinitrotoluene 0.0093 NS NS NS NS NS NS <3.78 NS <1.116 NS <0.1928 <0.1804 NS NS NS NS NS 2,6-Dinitrotoluene 0.0094 NS NS NS NS NS NS <3.78 NS <1.116 NS <0.1928 <0.1804 NS NS NS NS NS 2-Chlorophenol 1.5 NS NS NS NS NS NS <3.78 NS <1.116 NS <0.1928 <0.1804 NS NS NS NS NS 3&4-Methylphenol (p&m- 1.5 NS NS NS NS NS NS <15 NS <4.44 NS <0.766 <0.718 NS NS NS NS NS Bis(2-Chloroethyl)ether 0.0022 NS NS NS NS NS NS <3.78 NS <1.116 NS <0.1928 <0.1804 NS NS NS NS NS Hexachlorobenzene 0.047 NS NS NS NS NS NS <3.78 NS <1.116 NS <0.1928 <0.1804 NS NS NS NS NS Hexachlorocyclopentadiene 1.3 NS NS NS NS NS NS <9.68 NS <2.86 NS <0.494 <0.462 NS NS NS NS NS Hexachloroethane 0.21 NS NS NS NS NS NS <3.78 NS <1.116 NS <0.1928 <0.1804 NS NS NS NS NS Nitrobenzene 0.094 NS NS NS NS NS NS <3.78 NS <1.116 NS <0.1928 <0.1804 NS NS NS NS NS N-Nitrosodimethylamine 0.000053 NS NS NS NS NS NS <3.78 NS <1.116 NS <0.1928 <0.1804 NS NS NS NS NS N-Nitroso-di-n-propylamine 0.0011 NS NS NS NS NS NS <3.78 NS <1.116 NS <0.1928 <0.1804 NS NS NS NS NS Pentachlorophenol 0.047 NS NS NS NS NS NS <30 NS <8.86 NS <1.532 <1.434 NS NS NS NS NS Other SVOCs Various NS NS NS NS NS NS ND NS ND NS ND ND NS NS NS NS NS Metals; (mg/Kg) SW6020 Arsenic 3.9 14.9 5.26 6.45 8.49 5.14 4.78 4.75 8.66 235 3.58 7.72 6.93 85.3 68.8 103 438 77.7 Barium 1100 94.0 68.5 103 87.5 78.4 83.6 83.1 85.6 194 77.5 70.9 70.5 20.3 21.5 76.4 68.1 79.0 Cadmium 5 0.682 0.311 0.211 0.490 0.0923 J 0.102 J 0.0989 J 0.505 1.13 0.0834 J 0.0797 J 0.0712 J 0.729 0.778 2.54 1.32 0.371 Chromium 25 20.5 14.3 14.8 16.1 15.8 16.0 14.0 16.9 48.6 16.3 18.2 17.4 94.4 111 142 317 268 Lead 400 20.2 18.0 18.7 22.1 3.62 3.90 6.35 386 189 3.47 3.88 3.68 723 148 90.7 390 1030 Selenium 3.4 <0.336 <0.314 <0.31 0.245 J 0.211 J 0.228 J 0.274 J <0.322 <0.482 <0.324 0.267 J 0.342 J <0.292 <0.28 <0.292 <1.404 0.179 J Silver 11.2 0.0440 J <0.065 <0.064 0.0570 J 0.0369 J 0.0403 J 0.0502 J 0.0682 J 0.0961 J <0.067 0.0530 J 0.0429 J 0.141 0.125 1.75 0.678 0.481 Mercury; (SW7471B) ug/Kg 1,400 38.7 J 23.7 J 32.9 J 53.3 17.7 J 19.2 J <29.6 219 70.5 <26 39.6 J 31.1 J 27.5 J 28.0 J <23.6 70.2 <23.8

1 18 AAC 75.340 Table B1 or B2 for Under 40 Inch Zone J Estimated value; see data validation report for additional details

362 Shaded values indicate regulatory exceedance <3.78 Bold values indicate that ananlyte not detected, but deteciton limit is greater than cleanup level

† Duplicate of previous sample

* World Health Organization 2005 Toxicity Equivelent assuming non-detect values equal detection limit with Estimated Maximum Potential Concentrations

ND Not Detected NS Not Sampled

Analyte; (Method) unit Cleanup Level 1

Soil Samples Ash Debris Samples

Table 3-2: Sample Results for Asbestos, PCBs and Dioxins/Furans

11BIASN01 11BIASN02 11BIASN03 11BIASN04 11BIASN05 11BIASN06 11BIASW01 11BIASW02 11BIASW03 11B1ASW05 11BIASW04 11BIASW06 † 11BIAAN01 11BIAN03 † 11BIAN02 11BIAAW01 11BIAAW02 Total Solids; (SM20 2540G) % 88.1 94.2 92.4 77.1 90.0 91.0 81.0 90.4 62.0 90.9 80.8 84.7 NS NS NS NS NS Asbestos; (PLM EPA 600/R- 93/116) presence/absence ND ND ND ND ND ND ND ND ND ND ND NS ND NS ND ND ND

PCBs; (SW8082A) ug/Kg Aroclor-1016 <34 <31.8 <32 <38.6 <33.4 <32.8 <36.8 <33.2 <125 <32.8 <37 <35.4 NS NS NS NS NS Aroclor-1221 <34 <31.8 <32 <38.6 <33.4 <32.8 <36.8 <33.2 <125 <32.8 <37 <35.4 NS NS NS NS NS Aroclor-1232 <34 <31.8 <32 <38.6 <33.4 <32.8 <36.8 <33.2 <125 <32.8 <37 <35.4 NS NS NS NS NS Aroclor-1242 <34 <31.8 <32 <38.6 <33.4 <32.8 <36.8 <33.2 <125 <32.8 <37 <35.4 NS NS NS NS NS Aroclor-1248 <34 <31.8 <32 <38.6 <33.4 <32.8 <36.8 <33.2 <125 <32.8 <37 <35.4 NS NS NS NS NS Aroclor-1254 <34 <31.8 <32 <38.6 <33.4 <32.8 <36.8 <33.2 <125 <32.8 <37 <35.4 NS NS NS NS NS Aroclor-1260 <34 <31.8 <32 <38.6 109 75.5 191 174 1,330 <32.8 <37 <35.4 NS NS NS NS NS Dioxins/Furans; (SW8290A) pg/g 2,3,7,8-TCDD 58 <0.0844 <0.0692 <0.147 <0.11 <0.0893 <0.114 <0.113 <0.0974 <0.148 <0.0705 <0.0846 <0.116 <0.54 <0.309 1.21 <0.834 <0.0894 1,2,3,7,8-PeCDD <0.504 J 0.633 J <0.811 J <0.21 <0.0699 <0.695 J <0.119 7.29 <0.211 <0.0659 <0.0578 <0.0674 10.0 J 5.39 J <0.55 <4.00 J <0.0953 1,2,3,4,7,8-HxCDD <0.704 J 1.21 J 0.958 J <0.107 <0.0984 <0.539 J <0.158 13.5 7.71 <0.0646 <0.0626 <0.0942 <0.464 J <4.05 J 2.87 J 2.37 J <0.0921 J 1,2,3,6,7,8-HxCDD 4.49 4.13 8.12 2.02 J <0.104 <2.03 J <0.712 J 35.3 21.2 <0.0682 <0.0662 <0.0994 31.5 J 13.1 J 4.11 J <6.44 J <0.366 J 1,2,3,7,8,9-HxCDD <2.18 J <0.0798 2.69 1.16 J <0.105 <1.28 J <0.764 J 31 18.5 <0.0686 <0.0666 <0.1 23 J 9.75 J 4.05 J <5.61 J <0.295 J 1,2,3,4,6,7,8-HpCDD 83.6 60.6 161 44.1 6.17 51.2 8.47 644 359 <0.15 <0.0925 <0.208 668 J 330 J 87.2 51.4 5.79 OCDD 420 239 907 227 45.5 472 35.1 2550 1670 <1.11 J 1.69 J 2.19 J 5560 3450 498 142 17.6 2,3,7,8-TCDF 0.422 J 0.378 J 0.504 J <0.138 <0.343 J <0.332 J 0.405 J 1.74 <0.227 <0.295 J <0.286 J <0.0735 5.24 3.22 9.72 4.12 0.452 J 1,2,3,7,8-PeCDF <0.138 J 0.445 J <0.192 J <0.0751 <0.0745 <0.228 J <0.271 J 0.980 J 1.7 J <0.0478 0.145 <0.0458 <2.64 J <2.04 J 8.52 2.19 J <0.0609 2,3,4,7,8-PeCDF 0.496 J 0.58 J 0.393 J 0.370 J <0.072 <0.288 J <0.619 J 2.52 J 4.7 <0.0461 <0.0242 <0.0442 4.43 J 3.55 J 17.1 3.42 J <0.0588 1,2,3,4,7,8-HxCDF 2.09 J 1.51 J 1.7 J <1.25 J <0.0943 <0.472 J <1.15 J 6.92 10.1 <0.0576 <0.044 <0.0611 7.59 J <4.25 J 13 <2.42 J <0.0598 1,2,3,6,7,8-HxCDF <1.99 J 1.47 J 1.9 J 0.590 J <0.0904 0.307 J <0.557 J 6.71 8.29 <0.0552 <0.0422 <0.0585 4.01 J 3.21 J 14.2 <2.82 J <0.0574 2,3,4,6,7,8-HxCDF 2.20 J <1.72 J 2.48 J <0.954 J <0.0953 <0.288 J 0.429 J 10.3 10.1 <0.0582 <0.0446 <0.0616 5.26 J 3.68 J 16.3 3.24 J <0.0604 1,2,3,7,8,9-HxCDF <0.141 <0.105 <0.199 <0.16 <0.108 <0.105 <0.127 <0.43 <0.238 <0.0661 <0.0505 <0.07 1.45 J 0.913 J <2.24 J <0.29 <0.0685 1,2,3,4,6,7,8-HpCDF 51 30.2 77.5 27.6 1.60 J 4.02 3.66 293 180 <0.0674 <0.235 J <0.0958 127 J 45.5 J 56.6 7.48 J <0.441 J 1,2,3,4,7,8,9-HpCDF 2.08 J <1.64 J 4.53 <1.85 J <0.345 J <0.0933 <0.181 19.3 9.65 <0.0856 <0.0785 <0.121 10.3 J 3.30 J <2.42 J <0.431 <0.0915 OCDF 97.3 45.5 159 97.9 6.17 6.97 <5.98 J 930 444 <0.133 <0.109 <0.161 462 J 107 J 26 <4.70 J <0.112 WHO-2005 TEQ w/EMPC * 58 3.69 3.27 5.69 1.9 0.384 2.13 0.991 30 21.9 0.228 0.225 0.265 32.2 17 20.6 9.29 0.418

1 18 AAC 75.340 Table B1 or B2 for Under 40 Inch Zone 1,330 Shaded values indicate regulatory exceedance

J Estimated value; see data validation report for additional details † Duplicate of previous sample

* World Health Organization 2005 Toxicity Equivelent assuming non-detect values equal detection limit with Estimated Maximum Potential Concentrations

ND Not Detected NS Not Sampled

1,000 (total of PCBs)

Analyte; (Method) unit Cleanup Level 1 Soil Samples Ash Debris Samples

Building 413 Soil and Debris Characterization, Bethel, Alaska Requisition No. 70190114074/Order No. F11PX05149 Bethel BIA 27-Acre Parcel Site, Bethel, Alaska Page 10

4.0 REFERENCES

[11 CEOS] USAF 11th Civil Engineering Operations Squadron Operating Engineers, 1992. Preliminary Assessment, Bureau of Indian Affairs, Bethel, Alaska. Prepared for Bureau of Indian Affairs Facilities Management and Construction Center, Albuquerque, New Mexico. March 1992 [AR03].

[611 CES] USAF 611th Civil Engineering Squadron, 1994. Asbestos Abatement Activity, Bureau of Indian Affairs Site, Bethel Agency, Bethel, Alaska. July 1994 [AR08].

ADEC. 2008, Oil and Other Hazardous Substance Pollution Control Regulations: Title 18, Alaska Administrative Code, Chapter 75. October 9, 2008.

ADEC. 2003. Underground Storage Tank Regulations: Title 18, Alaska Administrative Code, Chapter 78. January 30.

[Bethel] Bethel Services, Inc., 2009. Final Preliminary Assessment Report Contaminant Investigation Bethel BIA Site, Yukon Delta Wildlife Refuge, Bethel, Alaska. Prepared for the USFWS. April 2009.

[EMCON] EMCON Alaska, Inc., 1996a. Final Site Characterization Report, Bethel BIA Administrative Site, Bethel, Alaska. Prepared for the USAF 611th CES/CEVR, Elmendorf AFB, Alaska. February 1996 [AR28].

EMCON, 1996b. Technical Memorandum for Sampling Activities Conducted Under Modification No. P003, Delivery Order 018, September 1995, Bethel BIA Administrative Site, Bethel, Alaska. Prepared for the USAF 611th CES/CEVR, Elmendorf AFB, Alaska. February 1996 [AR29].

EMCON, 1998. Record of Decision Bureau of Indian Affairs Administrative Site, Bethel, Alaska. Prepared for the USAF 611th CES/CEVR, Elmendorf AFB, Alaska. 69 pages. July 1998 [AR56].

[Phukan] Phukan, Inc., 2002a. Assessment of Burned BIA Complex, Bethel, Alaska. Prepared for U.S. Fish and Wildlife Service, 1011 E. Tudor Road, Anchorage, Alaska. February 2002.

APPENDIX A

Field Notes

APPENDIX B

Photographic Log

PHOTOGRAPHIC LOG – BETHEL BIA BUILDING 413

SOIL AND ASH CHARACTERIZATION, BETHEL, ALASKA

B - 1

Photo 1: Sample 11BIASW01. Photo taken facing south (August 29, 2011).

B - 2

Photo 2: Sample 11BIASW02. Photo taken facing south (August 29, 2011).

B - 3

Photo 3: Sample 11BIASW03. Photo taken facing south (August 29, 2011).

B - 4

Photo 4: Sample 11BIASW03. Photo taken facing west (August 29, 2011).

B - 5

Photo 5: Sample 11BIASW03 was collected from dark brown and black burned material. Photo taken facing west (August 29, 2011).

B - 6

Photo 6: Duplicate Sample 11BIASW04 and 11BIASW06. Photo taken facing south (August 29, 2011).

B - 7

Photo 7: Sample 11BIASW05. Photo taken facing east (August 29, 2011).

B - 8

Photo 8: Second photo of Sample 11BIASW05. Photo taken facing east (August 29, 2011).

B - 9

Photo 9: Sample 11BIASN01. Photo taken facing west (August 29, 2011).

B - 10

Photo 10: Sample 11BIASN02. Photo taken facing west (August 29, 2011).

B - 11

Photo 11: Second photo of Sample 11BIASN02. Photo taken facing south (August 29, 2011).

B - 12

Photo 12: Photo of Sample 11BIASN03. Photo taken facing south (August 29, 2011).

B - 13

Photo 13: Photo of Sample 11BIASN04. Photo taken facing southeast (August 29, 2011).

B - 14

Photo 14: Second photo of Sample 11BIASN04. Photo taken facing south (August 29, 2011).

B - 15

Photo 15: Photo of Sample 11BIASN05. Photo taken facing southeast (August 29, 2011).

B - 16

Photo 16: Photo of Sample 11BIASN06. Photo taken facing south (August 29, 2011).

B - 17

Photo 17: Second photo of Sample 11BIASN06. Photo taken facing southwest (August 29, 2011).

B - 18

Photo 18: Photo of Ash Sample 11BIAAW01. Photo taken facing north (August 29, 2011).

B - 19

Photo 19: Second photo of Ash Sample 11BIAAW01. (August 29, 2011).

B - 20

Photo 20: Photo of Ash Sample 11BIAAW02. Photo taken facing south (August 29, 2011).

B - 21

Photo 21: Photo of location of duplicate ash Samples 11BIAAN01 and 11BIAAN03. Photo taken facing northeast (August 29, 2011).

B - 22

Photo 22: Location Ash Sample 11BIAAN02. Photo taken facing south (August 29, 2011).

APPENDIX C

Data Validation Report and ADEC Laboratory Data Review Checklist

DATA VALIDATION REPORT

Date: December 6, 2011

Project: Bethel Building 413 Laboratory: SGS Environmental Services, Anchorage, Alaska

SDG#: 1114774

Receipt date: September 30, 2011 Analysis: GRO/BTEX, DRO/RRO, PCBs, SVOCs, Dioxins/Furans, Total Lead

The following tables list the field sample numbers, corresponding laboratory numbers, and requested analyses:

Field Sample ID Lab Sample ID Analyses requested QC

11BIASW01 1114774001

GRO/BTEX, DRO/RRO, PCBs, SVOCs, Dioxins/Furans, Lead

11BIASW02 1114774002

GRO/BTEX, DRO/RRO, PCBs, Dioxins/Furans, Lead

11BIASW03 1114774003

SVOCs, Dioxins/Furans, Lead

11BIASW04 1114774004

SVOCs, Dioxins/Furans, Lead

11B1ASW05 1114774005

11BIASW06 1114774006

SVOCs, Dioxins/Furans, Lead

Dup of 11BIASW04

11BIASN01 1114774007

11BIASN02 1114774008

11BIASN03 1114774009

11BIASN04 1114774010

11BIASN05 1114774011

11BIASN06 1114774012

11BIAAW01 1114774013 Dioxins/Furans, Lead

11BIAAW02 1114774014 Dioxins/Furans, Lead

11BIAAN01 1114774015 Dioxins/Furans, Lead

11BIAAN02 1114774016 Dioxins/Furans, Lead

11BIAAN03 1114774017 Dioxins/Furans, Lead Dup of 11BIAAN01

11BIATB01 1114774018 GRO/BTEX Trip Blank

The Alaska State Methods AK101, AK102, and AK103 were used for the analysis of gasoline-range organics (GRO), diesel-range organics (DRO), and residual-range organics (RRO), respectively. Environmental Protection Agency (EPA) SW846 Methods 8260B, 8270D, 8082A, 8290A and 6020 were used in the analysis of volatile organic compounds (VOCs/BTEX only), semi-volatile organic compounds (SVOCs), polychlorinated biphenyls (PCBs), dioxins/furans and total lead, respectively.

This QA summary includes a review, where appropriate, of the following parameters:

Data Completeness

Chain of Custody (COC) and Cooler Receipt Forms (CRF)

Holding Times and Preservation

Analytical reporting limits and method detection limits

Blank Analysis Results

Surrogate Recoveries (Organics only)

Duplicates

Laboratory Control Sample/Laboratory Control Sample Duplicate (LCS/LCSD) Results

Matrix Spike/Matrix Spike Duplicate (MS/MSD) Results

Overall Assessment

Each analysis that was performed is evaluated in the following subsections. The data validation was conducted in accordance with:

Department of Defense Quality Systems Manual for Environmental Laboratories, Version 4.2 (DoD QSM) (October 2010), USEPA document “Test Methods for Evaluating Solid Wastes, SW-846, revision 6” (February, 2007 and updates), USEPA Contract Laboratory Program National Functional Guidelines for Inorganic Review (October, 1994), USEPA Contract Laboratory Program National Functional Guidelines for Organic Review (October, 1999), and

TestAmerica Standard Operating Procedures where and when applicable.

DATA QUALIFIER DEFINITIONS

For the purpose of Data Validation, the following code letters and associated definitions are provided for use by the data validator to summarize the data quality.

R – Reported value is “rejected.” Re-sampling or re-analysis may be necessary to verify the presence or absence of the compound.

U – Analyte was not detected and is reported as less than the Limit of Detection (LOD).

The LOD has been adjusted for any dilution or concentration of the sample.

UJ – The reported quantitation limit is estimated because QC criteria were not met.

Element or compound was not detected

J – The reported result is an estimated value. This value is either less than the Limit of Quantitation (LOQ), or estimated because the QC criteria were not met.

NR – Result was not used from a particular sample analysis. This typically occurs when more than one result for an element is reported due to dilutions and reanalysis.

Data Completeness:

All data necessary to complete a level II data validation on this Sample Delivery Group (SDG) was provided.

Note: Although arsenic, barium, cadmium, chromium, lead, mercury, selenium and silver (SW6020/7471A) are reported for all samples (with the exception of the trip blank), only total lead by SW6020 is discussed in this validation report.

Chain of Custody (COC) and Cooler Receipt Forms (CRF)

Samples were hand-delivered by a Bethel employee to SGS Environmental Services (SGS) in Anchorage, Alaska. Custody seals were not present. Eighteen (18) soil samples, including one

(1) trip blank and two (2) field duplicate samples, were submitted on September 30, 2011.

Samples requiring dioxin/furan analysis were forwarded, without custody seals, to SGS in Wilmington, North Carolina.

Sample 11BIASW06 was submitted as a duplicate of sample 11BIASW04. Sample 11BIAAN03 was submitted as a duplicate of sample 11BIAAN01.

A matrix spike/matrix spike duplicate (MS/MSD) sample was not designated for this SDG.

There are no anomalies associated with the COC or sample receipt for these samples at either laboratory.

Holding Times and Preservation:

All holding time criteria were met.

Samples were received at SGS Anchorage cool at 5.7°C. This temperature is within the recommended preservation range of 4 ± 2°C.

Dioxin/furan samples were received at SGS Wilmington at 0.2°C. This temperature is within the recommended preservation range of ≤6°C.

No qualifications were made due to holding times or preservation.

Analytical reporting limits and detection limits:

Results are evaluated to the Detection Limit (DL) by the laboratory. Analytes that are detected at levels below the Limit of Quantitation/Control Limit (LOQ/CL), but greater than two times the Detection Limit (DL) are flagged “J” by the laboratory to indicate a degree of uncertainty. The DLs are adjusted for moisture content and sample dilutions due to matrix interferences.

Numerous 8270D target analytes are not detected, but have DLs greater than the Table B1, Method Two-Petroleum Hydrocarbon Soil Cleanup Levels (18AAC75, Reg. 188, January 2009).

Sample data are usable for characterizing the soil.

Blank Analysis Results:

The method blanks (MBs) and trip blanks (TBs) were analyzed at the required frequencies. No analytes are detected at levels above the Reporting Limit (RL). GRO is detected in the MB and TB above the DL, but less than one half the RL and are flagged “J” by the laboratory.

No data are qualified due to contamination in laboratory or field blank samples.

Field Duplicates:

Two field duplicate pairs (samples 11BIASW04/11BIASW06 and 11BIAAN01/11BIAAN03) were collected to document sampling and analytical precision. The precision was calculated as relative percent difference (RPD) between the detected concentrations and summarized in the following tables (Bold font indicates analytes and RPDs that exceed DQOs):

Detected Field Duplicate Pair Results

11BIASW04 11BIASW06

1114774004 1114774006 RPD

Analyte Method Units Sample Duplicate < 50 Qual Gasoline Range Organics AK101 mg/Kg 2.37 J 2.79 J 16

Diesel Range Organics AK102 mg/Kg 13.7 J 17.8 J 26

Residual Range Organics AK103 mg/Kg 133 222 50 J

Lead SW6020 mg/Kg 3.88 3.68 5

11BIAAN01 11BIAAN03

1114774015 1114774017 RPD

Analyte Method Units Sample EMPC FLAG Duplicate EMPC FLAG < 50 Qual 1,2,3,4,6,7,8-HpCDD SW8290A pg/g 668 330 68 J

1,2,3,4,6,7,8-HpCDF SW8290A pg/g 127 45.5 94 J

1,2,3,4,7,8,9-HpCDF SW8290A pg/g 10.3 3.3 J 103 J

1,2,3,4,7,8-HxCDD SW8290A pg/g ND 8.89 EMPC ND 4.05 J EMPC 75 J

1,2,3,4,7,8-HxCDF SW8290A pg/g 7.59 ND 4.25 J EMPC 56 J

1,2,3,6,7,8-HxCDD SW8290A pg/g 31.5 13.1 83 J

1,2,3,6,7,8-HxCDF SW8290A pg/g 4.01 J 3.21 J 22

1,2,3,7,8,9-HxCDD SW8290A pg/g 23 9.75 81 J

1,2,3,7,8,9-HxCDF SW8290A pg/g 1.45 J 0.913 J 45

1,2,3,7,8-PeCDD SW8290A pg/g 10 5.39 J 60 J

1,2,3,7,8-PeCDF SW8290A pg/g ND 2.64 J EMPC ND 2.04 J EMPC 26

2,3,4,6,7,8-HxCDF SW8290A pg/g 5.26 J 3.68 J 35

2,3,4,7,8-PeCDF SW8290A pg/g 4.43 J 3.55 J 22

2,3,7,8-TCDD SW8290A pg/g ND 2.22 EMPC ND 1.41 EMPC 45

2,3,7,8-TCDF SW8290A pg/g 5.24 3.22 48

OCDD SW8290A pg/g 5560 3450 47

OCDF SW8290A pg/g 462 107 125 J

Total HpCDD SW8290A pg/g 1310 677 64 J

Total HpCDF SW8290A pg/g 463 141 107 J

Total HxCDD SW8290A pg/g 232 251 109 120 72 J

Total HxCDF SW8290A pg/g 126 128 56.3 62 76 J

Total PeCDD SW8290A pg/g 68.2 80.1 27.8 37.6 84 J

Total PeCDF SW8290A pg/g 36.9 46 31.9 38 15

Total TCDD SW8290A pg/g 23.3 34.8 5.06 20.9 129 J

Total TCDF SW8290A pg/g 28 64.3 34.6 59.6 21

EMPC - Estimated Maximum possible Concentration due to ion ratio failure. If flagged “EMPC”, the EMPC value was used to calculate the RPD, and qualified accordingly.

J - The reported result is an estimated value when associated with the sample result (the value is less than the LOQ), or used as a qualifier flag for data that is estimated because the QC criteria were not met.

pg/g – picograms per gram

Laboratory Control Sample (LCS) Results:

The LCS recovery for benzo[g,h,i]perylene in prep-batch 25905 (163%) is above QC limits (40- 125%). The primary samples associated with this batch, 11BIASW01, 11BIASW03 and 11BIASW06 (1114774001, -003, -006, respectively) are all non-detect for this analyte.

The LCS recovery for benzo[g,h,i]perylene in prep-batch 25909 (155%) is above QC limits (40- 125%). The primary sample associated with this batch, 11BIASW04 (1114774004) is non-detect for this analyte.

No field sample results are qualified due to LCS or LCSD results.

Matrix Spike (MS) and Matrix Spike Duplicate (MSD) Results:

Site-specific MS/MSD samples were not collected for project samples. Only the batch associated MS/MSD pairs are provided in the laboratory report. Quality control failures for these comparisons are not applied to the data set as any matrix effects would be from soils not representative of soils from this project.

An MS/MSD analysis was performed on sample 11BIASW04 (1114774004) for 8270D.

Benzo[g,h,i]perylene recovery in the MS, and benzo[g,h,i]perylene, dibenzo[a,h]anthracene and indeno[1,2,3-c,d]pyrene recoveries in the MSD are above QC limits. These analytes are not detected in the un-spiked sample; therefore, no qualifications were made.

No data are qualified due to the MS/MSD results.

OVERALL ASSESSMENT

RRO results in field duplicate pair 11BIASW04 and 11BIASW06 (1114774004/-06) are qualified as estimated (J) due to lack of precision.

1,2,3,4,6,7,8-HpCDD, 1,2,3,4,6,7,8-HpCDF, 1,2,3,4,7,8,9-HpCDF, 1,2,3,4,7,8-HxCDD, 1,2,3,4,7,8-HxCDF, 1,2,3,6,7,8-HxCDD, 1,2,3,7,8,9-HxCDD, 1,2,3,7,8-PeCDD, OCDF, Total HpCDD, Total HpCDF, Total HxCDD, Total HxCDF, Total PeCDD and Total TCDD results in field duplicate pair 11BIAAN01 and 111BIAAN03 (1114774015/-017) are qualified as estimated

(J) due to lack of precision.

All other sample results are considered to be valid with no data qualifiers assigned.

Victoria Yancey Project Chemist Bethel Services, Inc.

Attachments:

ADEC Data Validation Checklist

Page 1 of 7Version 2.7 01/10

Laboratory Data Review Checklist

Completed by: Victoria Yancey

Title: Environmental Scientist Date: Dec 6, 2011

CS Report Name: Bethel Building 413 Report Date: Oct 31, 2011

Consultant Firm: Bethel Services, Inc.

Laboratory Name: SGS Environmental Svcs. Laboratory Report Number: 1114774

ADEC File Number: ADEC RecKey Number:

1. Laboratory

a. Did an ADEC CS approved laboratory receive and perform all of the submitted sample analyses?

Comments:

SGS Anchorage, AK

Yes No NA (Please explain.)

b. If the samples were transferred to another "network" laboratory or sub-contracted to an alternate laboratory, was the laboratory performing the analyses ADEC CS approved?

Comments:

Dioxins/Furans by 8290A subcontracted to SGS Wilmington, NC

NA (Please explain)Yes No

2. Chain of Custody (COC)

a. COC information completed, signed, and dated (including released/received by)?

Comments:NA (Please explain)Yes No

b. Correct analyses requested?

Comments:NA (Please explain)Yes No

3. Laboratory Sample Receipt Documentation

a. Sample/cooler temperature documented and within range at receipt (4° ± 2° C)?

Comments:

5.7°C. D/F 0.2°C, which is <6°C recommended by method.

NA (Please explain)Yes No

Page 2 of 7Version 2.7 01/10

b. Sample preservation acceptable - acidified waters, Methanol preserved VOC soil (GRO, BTEX, Volatile Chlorinated Solvents, etc.)?

Comments:NA (Please explain)Yes No

c. Sample condition documented - broken, leaking (Methanol), zero headspace (VOC vials)?

Comments:NA (Please explain)Yes No

d. If there were any discrepancies, were they documented? - For example, incorrect sample containers/ preservation, sample temperature outside of acceptance range, insufficient or missing samples, etc.?

Comments:NA (Please explain)Yes No

e. Data quality or usability affected? (Please explain)

Comments:

No

a. Present and understandable?

4. Case Narrative

Comments:NA (Please explain)Yes No

b. Discrepancies, errors or QC failures identified by the lab?

Comments:NA (Please explain)Yes No

c. Were all corrective actions documented?

Comments:

Missing notations for LCS (25909) benzo[g,h,i]perylene, and MSD notations for benzo[g,h,i]perylene, dibenzo[a,h]anthracene and indeno[1,2,3-c,d]pyrene (batch XXX25909)

NA (Please explain)Yes No

d. What is the effect on data quality/usability according to the case narrative?

Comments:

Usable as qualified.

Page 3 of 7Version 2.7 01/10

a. Correct analyses performed/reported as requested on COC?

5. Samples Results

Comments:NA (Please explain)Yes No

b. All applicable holding times met?

Comments:NA (Please explain)Yes No

c. All soils reported on a dry weight basis?

Comments:NA (Please explain)Yes No

Comments:

Multiple 8270D limits exceed ADEC limits.

d. Are the reported PQLs less than the Cleanup Level or the minimum required detection level for the project?

NA (Please explain)Yes No

e. Data quality or usability affected? (Please explain) Comments:

no

a. Method Blank

6. QC Samples

i. One method blank reported per matrix, analysis and 20 samples?

Comments:NA (Please explain)Yes No

ii. All method blank results less than PQL?

Comments:NA (Please explain)Yes No

iii. If above PQL, what samples are affected? Comments:

NA

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iv. Do the affected sample(s) have data flags? If so, are the data flags clearly defined?

Comments:NA (Please explain)Yes No

v. Data quality or usability affected? (Please explain) Comments:

NA

i. Organics - One LCS/LCSD reported per matrix, analysis and 20 samples? (LCS/LCSD required per AK methods, LCS required per SW846)

Comments:

b. Laboratory Control Sample/Duplicate (LCS/LCSD)

Yes No NA (Please explain)

ii. Metals/Inorganics - One LCS and one sample duplicate reported per matrix, analysis and 20 samples?

Comments:

LCS, no duplicate

NA (Please explain)Yes No

iii. Accuracy - All percent recoveries (%R) reported and within method or laboratory limits? And project specified DQOs, if applicable. (AK Petroleum methods: AK101 60%-120%, AK102 75%-125%, AK103 60%-120%; all other analyses see the laboratory QC pages)

Comments:

benzo[g,h,i]perylene %R high; all associated samples ND; no qual

NA (Please explain)Yes No

iv. Precision - All relative percent differences (RPD) reported and less than method or laboratory limits? And project specified DQOs, if applicable. RPD reported from LCS/LCSD, MS/DMSD, and or sample/sample duplicate. (AK Petroleum methods 20%; all other analyses see the laboratory QC pages)

Comments:

LCS/LCSD ok; Benzo[g,h,i]perylene in MS, and benzo[g,h,i]perylene, dibenzo[a,h]anthracene and indeno[1,2,3-c,d]pyrene in MSD are high. All associated ND; NQ.

NA (Please explain)Yes No

v. If %R or RPD is outside of acceptable limits, what samples are affected?

None

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vi. Do the affected samples(s) have data flags? If so, are the data flags clearly defined?

Comments:NA (Please explain)Yes No

vii. Data quality or usability affected? (Please explain) Comments:

No

c. Surrogates - Organics Only

i. Are surrogate recoveries reported for organic analyses - field, QC and laboratory samples?

Comments:NA (Please explain)Yes No

ii. Accuracy - All percent recoveries (%R) reported and within method or laboratory limits? And project specified DQOs, if applicable. (AK Petroleum methods 50-150 %R; all other analyses see the laboratory report pages)

Comments:NA (Please explain)NoYes

iii. Do the sample results with failed surrogate recoveries have data flags? If so, are the data flags clearly defined?

Comments:NA (Please explain)Yes No

iv. Data quality or usability affected? (Use the comment box to explain.).

Comments:

NA

d. Trip Blank - Volatile analyses only (GRO, BTEX, Volatile Chlorinated Solvents, etc.): Water and Soil

i. One trip blank reported per matrix,…