01_18382348_Specs_Attachment 11 Base Kodiak Generic EMP_12032021.pdf

Final Environmental Management Plan for Minimally Intrusive Projects and Sites with No Known Contamination

U.S. Coast Guard Base Kodiak Kodiak, Alaska

Prepared for:

U.S. Coast Guard

Civil Engineering Unit Juneau

PO Box 25517 Juneau, Alaska 99802-1747

December 2021

Prepared By:

Brice Engineering, LLC 3700 Centerpoint Drive, Suite 8223

Anchorage, Alaska 99503

907.275.2896 PH

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Environmental Management Plan for Minimally Intrusive Projects and Sites with No Known Contamination i USCG Base Kodiak, Kodiak, Alaska

TABLE OF CONTENTS

ACRONYMS AND ABBREVIATIONS .................................................................................................... III

1.0 INTRODUCTION ................................................................................................................. 1-1

1.1 Background ...................................................................................................................... 1-1

1.2 Objectives ........................................................................................................................ 1-2

1.3 Responsibilities and Project Personnel ............................................................................ 1-3

1.3.1 Civil Engineering Unit Juneau and Base Kodiak Environmental Division Responsibilities ................................................................................................... 1-4

1.3.2 Contractor Responsibilities ................................................................................. 1-4

2.0 SAMPLING AND ANALYSIS .................................................................................................. 2-1

2.1 Project Considerations ..................................................................................................... 2-1

2.1.1 Working in Areas of Known Contamination ....................................................... 2-1

2.1.2 Working in Areas of Unknown Contamination ................................................... 2-1

2.2 Procedures for Handling Excavated Soil .......................................................................... 2-2

2.2.1 Qualitative Soil Screening ................................................................................... 2-3

2.2.2 Semi-Quantitative Soil Screening ....................................................................... 2-3

2.2.3 Health and Safety Field Screening ...................................................................... 2-3

2.2.4 Soil Segregation and Stockpile Construction ...................................................... 2-4

2.2.5 Soil Analytical Sampling ...................................................................................... 2-4

2.2.6 Hazardous Waste Characterization .................................................................... 2-7

2.3 Procedures for Handling Groundwater and Surface Water ............................................ 2-7

2.3.1 Dewatering Monitoring Procedures ................................................................... 2-8

2.3.2 Effluent Analytical Sampling ............................................................................... 2-8

2.3.3 Unexpected Groundwater and Surface Water Encounters ................................ 2-9

3.0 DECONTAMINATION PROCEDURES ..................................................................................... 3-1

3.1 Soil Sampling Equipment and Small Tools ....................................................................... 3-1

3.2 Construction Equipment .................................................................................................. 3-1

4.0 DATA EVALUATION, SOIL DISPOSITION, AND REPORTING ................................................... 4-1

4.1 Data Evaluation ................................................................................................................ 4-1

4.2 Disposition of Soil Exceeding Cleanup Levels .................................................................. 4-2

4.2.1 Contaminants Other Than POL Compounds ....................................................... 4-2

4.3 Reporting ......................................................................................................................... 4-3

5.0 QUALITY ASSURANCE/QUALITY CONTROL .......................................................................... 5-1

6.0 QUALITY CONTROL SAMPLES .............................................................................................. 6-1

6.1 Field Duplicates ................................................................................................................ 6-1

6.2 Matrix Spikes and Matrix Spike Duplicates ...................................................................... 6-1

6.3 Trip Blanks ........................................................................................................................ 6-1

7.0 SAMPLE HANDLING AND SHIPPING .................................................................................... 7-1

7.1 Sample Containers ........................................................................................................... 7-1

7.3 Custody Procedures ......................................................................................................... 7-2

7.3.1 Sample Labels ..................................................................................................... 7-3

TABLE OF CONTENTS (CONTINUED)

Environmental Management Plan for Minimally Intrusive Projects and Sites with No Known Contamination ii USCG Base Kodiak, Kodiak, Alaska

7.3.2 Chain-of-Custody ................................................................................................ 7-3

7.4 Packing and Shipping ....................................................................................................... 7-3

8.0 REFERENCES ...................................................................................................................... 8-1

TABLES

Table 2-1 Excavated Soil Sample Collection Guide (Table 2A from ADEC Field Sampling Guidance) ......................................................................................................................... 2-6

Table 2-2 Surface/Excavation Base and Excavation Sidewall Soil Sample Collection Guide (Table 2B from ADEC Field Sampling Guidance) .............................................................. 2-6

Table 4-1 Soil Disposition/Reuse Based on Characterization .......................................................... 4-1 Table 5-1 Measurement Performance Criteria for Analytical Methods in Solid Matrices .............. 5-5 Table 5-2 Measurement Performance Criteria for Analytical Methods in Aqueous Matrices ........ 5-6 Table 6-1 Field Quality Control Samples .......................................................................................... 6-1 Table 7-1 Sample Container Requirements ..................................................................................... 7-1 Table 7-2 Field Quality Control Samples .......................................................................................... 7-2

FIGURES

Figure 1 Location and Boundaries of USCG Base Kodiak Property

APPENDICES

Appendix A USCG Base Kodiak Design/Contracting Team Pre-Award Environmental Flow Chart

Appendix B ADEC Forms Appendix C Field Forms

Environmental Management Plan for Minimally Intrusive Projects and Sites with No Known Contamination iii

ACRONYMS AND ABBREVIATIONS

°C degrees Celsius % percent %R percent recovery AAC Alaska Administrative Code ADEC Alaska Department of Environmental Conservation AK Alaska Method APDES Alaska Pollutant Discharge Elimination System Brice Brice Engineering, LLC CERCLA Comprehensive Environmental Response, Compensation, and Liability Act CEU Civil Engineering Unit CGP Construction General Permit CoC chain-of-custody CS-LAP Contaminated Sites Laboratory Approval Program cy cubic yards DL detection limit DoD Department of Defense DRO diesel range organics ELAP Environmental Laboratory Accreditation Program EMP Environmental Management Plan EPA U.S. Environmental Protection Agency eV electron-volts ft feet ft2 square feet GAC granular activated carbon GC gas chromatography GC/MS gas chromatography/mass spectrometry GPS Global Positioning System GRO gasoline range organics HSP Health and Safety Plan HWMU Hazardous Waste Management Unit L liters LCS laboratory control sample LCSD laboratory control sample duplicate LOD limit of detection LOQ limit of quantitation LUC land use control LUCAP Land Use Control Assurance Plan LUCIP Land Use Control Implementation Plan mL milliliters

ACRONYMS AND ABBREVIATIONS (CONTINUED)

Environmental Management Plan for Minimally Intrusive Projects and Sites with No Known Contamination iv USCG Base Kodiak, Kodiak, Alaska

MPC measurement performance criteria MS matrix spike MSD matrix spike duplicate ND non-detect oz ounces PAH polycyclic aromatic hydrocarbons PARCCS precision, accuracy, representativeness, completeness, comparability, and sensitivity PCB polychlorinated biphenyl PID photoionization detector POL petroleum, oil, and lubricant(s) ppm parts per million QA quality assurance QC quality control QEP Qualified Environmental Professional QSM Quality Systems Manual RCRA Resource Conservation and Recovery Act RPD relative percent difference RRO residual range organics SIM selected ion monitoring SOP standard operating procedure SW Solid Waste Method SWMU Solid Waste Management Unit TAH total aromatic hydrocarbons TAqH total aqueous hydrocarbons TLC Teflon-lined cap TLS Teflon-lined septa TSCA Toxic Substances Control Act USCG U.S. Coast Guard VOA volatile organic analysis VOC volatile organic compound

Environmental Management Plan for Minimally Intrusive Projects and Sites with No Known Contamination 1-1

1.0 INTRODUCTION

This Environmental Management Plan (EMP) describes the technical approach and procedures for characterization, handling, and potentially disposal and treatment of previously undocumented contaminated soil and/or water generated for minimally intrusive projects and projects where documented areas of soil and/or groundwater contamination are not located within the project area on U.S. Coast Guard (USCG) Base Kodiak in Kodiak, Alaska. This document is referred to as the “Generic EMP” throughout this text. Brice Engineering, LLC (Brice) prepared this Generic EMP for USCG Civil Engineering Unit (CEU) Juneau and Base Kodiak Environmental Division to supply to contractors performing work at Base Kodiak project sites that meet the conditions described in Section 1.2.

Once finalized, this Generic EMP will be approved by, and will satisfy Alaska Department of Environmental Conservation (ADEC) and U.S. Environmental Protection Agency (EPA) review and comment requirements.

No further regulator review or approvals of a work plan/sampling plan are necessary prior to commencing work for minimally intrusive projects or sites with no known contamination where CEU Juneau Environmental Management Branch and Base Kodiak Environmental Division elect to use and follow this Generic EMP, unless a site-specific addendum is required due to possible presence of contaminants not covered by this Generic EMP, contamination levels that trigger hazardous waste disposal protocols, or additional testing requirements not covered in this Generic EMP.

1.1 Background

The USCG operates Base Kodiak on the northeastern coast of Kodiak Island, Alaska. Environmental and construction activities and historical records have revealed areas of environmental contamination (sites) at Base Kodiak, the extent of which is presented on Figure 1. These sites are areas where hazardous substances and/or Resource Conservation and Recovery Act (RCRA) hazardous wastes or constituents were released into the environment as a result of activities conducted over the history of the facility. Sites may be regulated under RCRA; Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA); or State of Alaska Contaminated Sites Program, Underground Storage Tank, or Solid Waste regulations.

A majority of the contaminated sites on Base Kodiak are managed under the RCRA Hazardous Waste Management Facility Permit (Permit) Number AK9 69033 0742, which contains provisions for corrective actions at 37 Solid Waste Management Units (SWMUs) including post-closure actions at three SWMUs classified as Hazardous Waste Management Units (HWMUs), and provisions for land use controls (LUCs) at 16 sites. The EPA Region 10 re-issued the Permit to USCG Base Kodiak on 1 April 2021; it will remain in effect until 31 March 2031 (EPA 2021). LUCs are incorporated into the RCRA Permit as a Land Use Control Assurance Plan (LUCAP), the objective of which is to establish and institutionalize a process to ensure appropriate long-term maintenance of LUCs implemented as part of remedial selection for any contaminated site on the facility. The LUCAP contains Land Use Control Implementation Plans (LUCIPs) for 16 sites at Base Kodiak with LUCs in place.

Not all contaminated sites on Base Kodiak property are managed by the LUCAP or RCRA permit; however, all known extents of previously identified contamination as well as the LUC boundaries are presented in the Kodiak and Base Kodiak Mapbook (USCG 2021). Areas not covered under the RCRA permit are managed according to the most current federal and state regulations concerning the discovery of contaminated soil.

Environmental Management Plan for Minimally Intrusive Projects and Sites with No Known Contamination 1-2

1.2 Objectives

The purpose of this Generic EMP is to be the guiding document for contractors to characterize, handle, and potentially dispose and treat previously undocumented contaminated soil and/or water that may be encountered during construction projects on Base Kodiak. This Generic EMP will be implemented and provided to the contractor when USCG CEU Juneau project designers determine a project meets the conditions below and Base Kodiak Environmental Division provides final acceptance. This Generic EMP will be implemented in the following situations:

• The project has a buffer of at least 200 feet from the extent of a known contaminated site and is not expected to encounter groundwater or contaminated surface water, and/or dewatering is not required.

• The project requires dewatering, but the groundwater removed is unlikely to be contaminated based on proximity to a contaminated site, hydrogeologic conditions, topography, and proximity of marine or surface waters.

• The project is located in a known contaminated area, but the work consists of minimally intrusive construction activities, such as concrete pads, parking lots, and re-leveling surfaces.

This rule excludes Sites 3 and 23.

Excess soil or water generated during construction projects requires proper handling and disposal, which necessitates characterization. Reuse of soil on the project minimizes the generation of excess soils.

Characterization determines if reuse and dewatering are acceptable or if other disposal or treatment is required. This Generic EMP presents analytical parameters and test methods, sample and screening methods, sampling frequency, and provisions for characterizing potentially contaminated soil or water on Base Kodiak.

This Generic EMP will only cover procedures for reporting and monitoring for petroleum, oil, and lubricant (POL) contaminants in detail. Field screening, sampling, and testing for POL contaminants in soil will be conducted in accordance with the ADEC Field Sampling Guidance (ADEC 2019a). If other possible contaminants are determined during the pre-award project approval process, they will be addressed in a site-specific addendum or separate site-specific EMP. Applicable contaminant types found on Base Kodiak include, but are not limited to, the following:

• POL contaminants

• Volatile organic compounds (VOCs)

• Chlorinated VOCs

• Polychlorinated biphenyls (PCBs)

• Polycyclic aromatic hydrocarbons (PAH)

• Pesticides

• Metals

This Generic EMP will also cover procedures for reporting and monitoring suspected POL contaminants in groundwater and/or dewatering effluent. Qualitative field screening and effluent monitoring will be conducted in accordance with the most recent versions of the ADEC Field Sampling Guidance (ADEC 2019a) and the Alaska Pollutant Discharge Elimination System (APDES) General Permit for Excavation Dewatering (ADEC 2019b).

Environmental Management Plan for Minimally Intrusive Projects and Sites with No Known Contamination 1-3

The soil cleanup levels applicable to this project are the most conservative of the criteria listed in 18 Alaska Administrative Code (AAC) 75 Table B1 (Over 40 Inch Zone or Migration to Groundwater) or Table B2 (Over 40 Inch Zone) (ADEC 2020a). The applicable monitoring criteria for effluent dewatering are the water quality criteria presented in Tables 3 and 4 of the APDES General Permit for Excavation Dewatering (ADEC 2019b).

1.3 Responsibilities and Project Personnel

CEU Juneau and Base Kodiak Environmental Division have directed that potentially contaminated excess soil and water generated during construction be characterized and a regulatory evaluation be provided to USCG for proper disposal or treatment. The following organization chart presents key project personnel and identifies relationships between all organizations involved. The sections following the organization chart list the key personnel and further describe the responsibilities of the various parties involved in this project.

ADEC CONTAMINATED SITES PROGRAM

(Regulatory Agency)

Project Manager Mr. Curtis Dunkin

(907) 269-3053

EPA REGION 10

(Regulatory Agency)

Project Manager Ms. Jan Palumbo

(206) 553-6702

PRIME CONTRACTOR

(To Be Determined)

Project Manager To Be Determined

*ANALYTICAL LABORATORY

(To Be Determined)

Laboratory Project Manager *The laboratory must be DoD ELAP and ADEC CS-LAP certified.

SUBCONTRACTOR

(To Be Determined)

*Qualified Environmental Professional *QEP may be a member of the Prime Contractor’s organization, rather than a subcontractor.

USCG

(Lead Agency)

USCG CEU Juneau Environmental Branch Chief Mr. Mark Ridgway

(907) 463-2407

USCG Base Kodiak Environmental Division Chief Ms. Jennifer Nutt

(907) 487-5320 ext. 6698

USCG CEU Juneau Construction Project Manager/ Contracting Officer’s Representative

To Be Determined

USCG CEU Juneau Environmental Branch Representative To Be Determined

Environmental Management Plan for Minimally Intrusive Projects and Sites with No Known Contamination 1-4

1.3.1 Civil Engineering Unit Juneau and Base Kodiak Environmental Division Responsibilities

The USCG is considered the generator of the excess soil and water on Base Kodiak construction projects and is ultimately responsible ensuring proper handling, treatment, or disposal. Prior to contract award, the CEU Juneau contracting and design team is responsible for identifying if projects planned for Base Kodiak may result in excess soil and water generation. The CEU Juneau project contracting and design team will complete the USCG Design/Contracting Team Pre-Award Environmental Flow Chart (Appendix A) to determine if ground-disturbing work is to occur near or in areas of known contamination and identify the proper project requirements. The contracting and design team is then responsible for coordinating with the CEU Juneau Environmental Management Branch, which will review construction project requests. If the contracting and design team determine that the project likely only requires this Generic EMP, CEU Juneau will relay the project information to Base Kodiak Environmental Division for final verification and approval to use the Generic EMP on a project.

During the pre-award phase, CEU Juneau Environmental Management Branch will review construction project requests and provide the final determination on whether the project meets the criteria to use this Generic EMP. If work is to occur in areas of known contamination, the approved project request will indicate the areas where contamination is suspected and list contaminant types. It will also be made clear that a site-specific EMP must be generated.

If previously known contamination exists and the work is not minimally intrusive, this Generic EMP no longer applies and a site-specific EMP will be prepared.

Prior to beginning construction, the USCG administers digging permit applications on the Base. According to the LUCAP, the USCG digging permit reviewer must identify whether ground-intrusive activities have a risk of encountering contaminated soil or groundwater and receive Base Kodiak Environmental Division approval for the permit. If so, the digging permit reviewer must communicate to the permittee (contractor) that they must develop a Health and Safety Plan (HSP), conduct environmental monitoring, and dispose of contaminated media, as appropriate.

Following characterization of excess soil in unknown contaminated areas and when CEU Juneau Environmental Management Branch and Base Kodiak Environmental Division requires the contractor to sample in known areas, the contractor will provide Base Kodiak Environmental Division and CEU Juneau Environmental Branch with the analytical results and regulatory evaluation of excess soil disposal and treatment options. Stockpile and disposal locations must be approved by Base Kodiak Environmental Division. The contractor will be responsible for offsite treatment and/or disposal. However, CEU Juneau Environmental Management Branch and Base Kodiak Environmental Division will coordinate and oversee treatment and/or disposal of hazardous waste and hazardous contaminated soil, including RCRA hazardous waste and Toxic Substances Control Act (TSCA) waste.

1.3.2 Contractor Responsibilities

The contractor is responsible for implementing this Generic EMP, preparing the appropriate planning documents, obtaining the services of an analytical laboratory meeting the qualifications identified in Section 2, and providing a Qualified Environmental Professional (QEP), as defined in 18 AAC 75.333 (ADEC 2020a), to be onsite during ground-intrusive field activities to conduct field screening and sampling as described in this Generic EMP. The contractor is responsible for ensuring all subcontractors also work in accordance with this Generic EMP.

Environmental Management Plan for Minimally Intrusive Projects and Sites with No Known Contamination 1-5

One required document is a contractor-prepared project HSP, which provides guidance and procedures to protect the health of personnel involved in the construction activities. The HSP includes safety guidance to workers involved in construction and characterization activities. Contractor technicians will provide health and safety monitoring under contract for the project. The contractor’s HSP (or related document) must include field standard operating procedures (SOPs) to account for unanticipated but potential encounters with structures; debris; health and environmental hazards such as asbestos-containing material, lead-based paint, PCB-containing material; underground storage tanks; pipelines or sewer lines;

contaminated soil or free product; and groundwater. Excess soil and water characterization described in this Generic EMP will be performed by contractor (or subcontractor) personnel; therefore, the health and safety hazards associated with these activities must be covered in the contractor’s HSP.

The contractor is also responsible for the following tasks associated with environmental monitoring:

1. Preparation of a Base Kodiak digging permit.

2. Submittal of a Notice of Intent for authorized coverage under the APDES Construction General

Permit (CGP) (ADEC 2020b) or the APDES General Permit for Excavation Dewatering (ADEC 2019b); the contractor is responsible for preparation of the appropriate supporting documentation required as part of the CGP or General Permit for Excavation Dewatering. The Notice of Intent and supporting documentation must be reviewed and approved by USCG prior to submittal to ADEC.

3. Preparation of applicable supporting environmental documentation including an HSP with appropriate SOPs and a Waste Management Plan. The Waste Management Plan must include proposed locations of soil storage areas, equipment decontamination methods, and procedures for characterizing, storing, and disposing of decontamination fluids and waste.

4. Field oversight for compliance.

5. Field-screening excess soil using qualitative (such as visual or olfactory) field screening methods and qualitative field screening of water in accordance with the APDES CGP.

6. For projects within the 200-foot buffer of a known site, or minimally intrusive projects within a known site, field screening of excess soil using semi-quantitative methods (such as using a photoionization detector [PID]).

7. Reporting contamination to the USCG Environmental Division as soon as it is encountered.

8. Collecting soil and/or water samples and submitting them to the laboratory for chemical analysis when required by CEU Juneau Environmental Management Branch and Base Kodiak Environmental Division.

9. Reviewing the chemical data and providing an analysis of appropriate treatment/disposal options. Prior and present laboratory analysis results and field screening methods will dictate the appropriate treatment or disposal.

10. Consulting with Base Kodiak Environmental Division for direction on where to dispose of or treat potentially contaminated soil and water.

11. Stockpiling and transporting excess soil.

12. Preparation of the ADEC Contaminated Media Transport and Treatment or Disposal Approval

Form (Appendix B) to gain regulatory approval for transport if off-Base transportation is required.

Environmental Management Plan for Minimally Intrusive Projects and Sites with No Known Contamination 1-6

13. Preparation of appropriate transportation manifests for review and signature by the responsible government official. Manifests may only be signed by a government representative.

14. Treatment and disposal of contaminated media.

15. Providing copies of all manifests and certificates of treatment or disposal to USCG

Environmental Division.

The contractor’s Project Manager is responsible for overall management of excess soil and water characterization activities, including adherence to the procedures described in this Generic EMP. The contractor’s quality assurance (QA) officer is responsible for conducting scheduled field audits and providing ongoing review, monitoring, and evaluation of the field and laboratory activities; the QA officer will independently validate all laboratory reports.

Whenever the contractor suspects or has knowledge of a leak, spill, or release of oil, hazardous substances, or regulated substances not previously identified to USCG, the contractor shall immediately notify the Base Kodiak Environmental Division Chief and USCG Project Manager. The contractor shall also prepare an ADEC Oil and Hazardous Materials Incident Report Form (Appendix B) in accordance with ADEC regulations. The contractor shall be responsible for delivering by hand, emailing, or faxing the completed form to Base Kodiak Environmental Division, who will be responsible for providing notification to ADEC as required per 18 AAC 75.300. In accordance with 18 AAC 75.310, the contractor will be responsible for cleanup of all leaks, spills, and releases of oil, hazardous substances, or regulated substances caused by the contractor (or subcontractor) during the project.

Environmental Management Plan for Minimally Intrusive Projects and Sites with No Known Contamination 2-1

2.0 SAMPLING AND ANALYSIS

This section provides the excess soil disposal criteria, dewatering criteria, analytical schedule, sampling requirements, and procedures. The contractor is responsible for identifying and procuring the analytical laboratory. The laboratory must be able to achieve reporting limits below the applicable cleanup levels and must be Department of Defense (DoD) Environmental Laboratory Accreditation Program (ELAP) and ADEC Contaminated Sites Laboratory Approval Program (CS-LAP) certified, and USCG must approve the selection of the laboratory prior to implementation.

2.1 Project Considerations

Excess soil may be generated outside areas of known or suspected contamination on Base Kodiak. Excess soil generated outside areas of known contamination that exhibit no indication of contamination during field screening may be disposed of on-Base or re-used as applicable. If excess soil exhibits signs of contamination during field screening, analytical samples will be used to confirm the presence of contamination and evaluate the appropriate reuse or treatment/disposal options. The analytical methods used for sampling are based on known contaminants of concern, previous Base Kodiak site characterization, and qualitative field screening, as described in the following sections.

For projects outside of known or suspected contamination, construction activities may encounter groundwater or surface water that requires dewatering. Effluent water generated from dewatering will be monitored in accordance with the dewatering permit and may be discharged to land or waters of the United States if water quality criteria are met (ADEC 2020b). The contractor is responsible for effluent monitoring procedures in accordance with the permit. Procedures for reporting suspected contamination in groundwater, as well as the sample collection and chemical analyses that must be initiated if sheen is observed when discharging to waters of the United States, will be described in this Generic EMP.

CEU Juneau Environmental Management Branch will provide information about known contamination as part of the pre-award construction project process. As part of the post-award and dig permit process, Base Kodiak Environmental Division will review available environmental data to (1) delineate areas where material may require characterization before disposal, (2) list probable/known contaminants, and (3) determine if soil samples from excess soils in known contaminated areas will require further laboratory analysis. This information will be provided and attached to the approved work request.

2.1.1 Working in Areas of Known Contamination

This Generic EMP outlines field screening, analytical sampling, and soil handling for minimally intrusive construction projects, including concrete pads, parking lots, and re-leveling surfaces in areas of known contamination. As with all other projects, Base Kodiak Environmental Division must approve use of this Generic EMP. USCG may consult with ADEC during the pre-award project phase to determine whether a project qualifies as minimally intrusive.

All other work conducted in areas of known contamination will not be covered under this Generic EMP.

2.1.2 Working in Areas of Unknown Contamination

The contractor will use the methods and criteria covered in this Generic EMP, which has been approved by Base Kodiak Environmental Division, ADEC, and EPA, to detect contamination in areas of unknown contamination.

Environmental Management Plan for Minimally Intrusive Projects and Sites with No Known Contamination 2-2

If potentially contaminated soils or water (e.g., odors, free product, sheen, staining, field screening readings greater than 10 parts per million [ppm]) are encountered, the contractor shall (1) inform the USCG Project Manager as soon as safely practicable, and (2) implement the management plan for the contaminated materials as indicated in this Generic EMP as well as any necessary adjustments to the safety practices. The USCG Project Manager will inform the Base Kodiak Environmental Division Chief, and if applicable, the USCG Contracting Officer’s Representative. The contractor shall proceed with the work unless directed otherwise by the USCG Project Manager or Base Kodiak Environmental Division Chief. The intent of the notification is to assess the level of contamination and to assure that the work area is consistent with this Generic EMP. The Base Kodiak Environmental Division will contact and inform applicable regulators of discovered contamination.

The USCG Project Manager shall keep personnel from Base Kodiak Environmental Division, CEU Juneau Environmental Management Branch, and the Contracting Officer’s Representative informed throughout the project as additional contaminated media are encountered. Base Kodiak Environmental Division personnel will be responsible for regulatory notifications to ADEC and EPA when contamination is discovered. The Base Kodiak Environmental Division Chief will notify the ADEC and EPA contacts listed in the organization chart in Section 1.3. In accordance with RCRA permit condition IX.D, Base Kodiak Environmental Division must also notify the RCRA permit administrator (EPA) in writing within 15 days of discovery of newly encountered contamination.

If it is determined through analytical sampling that contamination levels exceed the most-stringent 18 AAC 75 Table B1 or B2 cleanup levels, Base Kodiak Environmental Division will notify the ADEC Prevention and Emergency Response Program and EPA immediately of the newly discovered contaminated site. (Spill reporting, separate from exceeding cleanup levels, will follow Section 1.3.3 Contractor Responsibilities).

2.2 Procedures for Handling Excavated Soil

Soil contamination may be encountered outside of areas of known contamination during ground-disturbing construction activities. This section outlines field screening, proper soil stockpiling, and analytical soil sampling procedures for handling excavated soil. Soil handling will be conducted in a manner that prevents the release of contaminants to surface water. The contractor will develop mitigation techniques in the project Storm Water Pollution Prevention Plan; techniques may include covering soil stockpiles, re-directing surface water flows, and limited the extent of open excavations or trenches, if possible.

Soil field screening and analytical samples will be determined by Table 2A (Excavated Soil Sample Collection Guide) and 2B (Surface/Excavation Base and Excavation Sidewall Soil Sample Collection Guide) of the ADEC Field Sampling Guidance (ADEC 2019a), in addition to consultation with Base Kodiak Environmental Division to review possible past site uses. Any sampling that does not follow Table 2A and 2B will be discussed in a site-specific addendum. Tables 2A and 2B from ADEC Field Sampling Guidance are included as Tables 2-1 and 2-2 of this plan, respectively.

It is assumed that the identification of potentially contaminated soil will not result in a stop work order.

Construction will be halted temporarily to implement agency notification and analytical sampling procedures.

Environmental Management Plan for Minimally Intrusive Projects and Sites with No Known Contamination 2-3

2.2.1 Qualitative Soil Screening

Qualitative field screening will be used to delineate areas of suspected contamination not previously identified as a known contaminated site. Visual and olfactory screening will be conducted and recorded in the field notes if observed. A visual survey of the area for evidence of staining, sheen, dead or distressed vegetation, or other signs indicating possible contamination will be used. Odors noticed during site inspection or excavation will also be used for signs of possible contamination.

2.2.2 Semi-Quantitative Soil Screening

For projects within the 200-foot buffer of a known site, or minimally intrusive projects within a known site, semi-quantitative field screening will be conducted using a PID. The semi-quantitative screening methods described have been adapted from the ADEC Field Sampling Guidance (ADEC 2019a).

Semi-quantitative field screening samples will be collected at the following frequencies and locations:

• Areas where qualitative field screening indicate suspect contamination

• At regular 20-foot intervals from excess suspect contaminated soils generated along piping runs

• Following ADEC Field Sampling Guidance (ADEC 2019a) Tables 2A and 2B (Tables 2-1 and 2-2 of this plan) to characterize excavated soil

Semi-quantitative field screening will be conducted following heated headspace procedures per the ADEC Field Sampling Guidance (ADEC 2019a). The PID will be equipped with an 11.7-electron-volt (eV) lamp; the

11.7 eV will analyze a broad response of volatiles. The PID field screening method is summarized below:

1. Partially fill (one-third to one-half) a clean jar or clean re-sealable bag (container must have at least 8-ounce capacity) with freshly uncovered excess soil.

2. Quickly close or seal the jar or bag.

3. Shake or agitate sample for 15 seconds.

4. Allow sample to heat to at least 40 degrees Fahrenheit and sit for at least 10 minutes and no more than 60 minutes. To the extent practicable, each sample time should be kept consistent in the 10- to 60-minute range (e.g., 15 minutes of standing for each sample).

5. Shake or agitate sample for 15 seconds.

6. Insert sampling probe to one-half the headspace depth and take care to avoid water droplets or soil particles.

7. Record the highest meter reading on the field record, normally observed 2 to 5 seconds after probe insertion.

8. Document all field sampling results in the field record or logbook.

Prior to field screening, a blank sample must be collected if using re-sealable polyethylene bags (Ziploc or similar) to identify potential interferences from the bag that may bias field samples. The PID will be calibrated daily in accordance with the user manual. Daily calibration readings and all field screening data will be recorded in a logbook.

2.2.3 Health and Safety Field Screening

When semi-quantitative soil screening is required, the contractor will also conduct health and safety monitoring to protect workers. Health and safety screening consists of measuring organic vapors in the worker’s breathing zone using a PID and making visual and olfactory observations during operations. The

Environmental Management Plan for Minimally Intrusive Projects and Sites with No Known Contamination 2-4 contractor is responsible for developing a project-specific HSP to address health and safety concerns. The HSP must establish a health and safety action level for organic vapor monitoring.

2.2.4 Soil Segregation and Stockpile Construction

Excavated soil will be stockpiled separately based on indicated levels of contamination; excavated soil will be classified as presumed clean, potentially contaminated, and contaminated. If PID screening or observations indicate contamination in the excavation or in excess soils, the soils will be stockpiled separately by less than 10 ppm (presumed clean); greater than or equal to 10 ppm to less than 100 ppm (potentially contaminated); and greater than or equal to 100 ppm and/or the presence of free product or other obvious signs of contamination (contaminated). Stockpiles will be appropriately placed, covered, and sampled. Disposal and treatment options will be implemented in accordance with procedures outlined in Section 4. POL-contaminated excess soils (exceeding 18 AAC 75 human health criteria) can only be placed back into the excavation with the approval of ADEC and EPA.

Stockpiled soil will be managed in accordance with 18 AAC 75.370 (ADEC 2020a). The contractor will provide the USCG Project Manager, CEU Juneau Environmental Management Branch, and Base Kodiak Environmental Division a figure showing the proposed location of stockpile areas. Stockpiles must not be placed within 100 feet of surface water. All excavated soil shall be placed directly on a minimum 10-mil liner, for further screening, sampling, and characterization. Stockpiles will be covered with a 6-mil liner to prevent precipitation run-off from or onto the stockpile. The stockpiles will be inspected weekly and maintained until the soil is placed back into the excavation or transported for disposal.

2.2.5 Soil Analytical Sampling

Analytical soil samples will be collected from excavated material if there is visual or olfactory indication of contamination and/or a PID reading of 10 ppm or greater is recorded. Soil samples will be collected by the contractor’s QEP using the procedures described in 18 AAC 75. The soil collection method for excavated material is summarized here:

1. Estimate the volume of excess soil and determine the necessary number of samples using ADEC Field Sampling Guidance Table 2A (Table 2-1 of this plan) (ADEC 2019a). One analytical sample will be collected if the stockpile is 10 cubic yards (cy) or less; two analytical samples will be collected if it is 11 to 50 cy; and three analytical samples will be collected if it is 51 to 100 cy of stockpiled soil. For stockpiles greater than 100 cy, three analytical samples will be collected from the first 100 cy, plus one additional sample for each additional 200 cy or portion thereof.

2. Select sample locations using the highest semi-quantitative field screening values as determined using the procedure described in Section 2.2.2. Before sampling, remove a minimum of 18 inches of soil from the surface of the stockpile.

3. Collect all samples with decontaminated or disposable sampling equipment. A new pair of disposable gloves must be worn for collection of each sample.

4. Do not collect composite samples. All samples will be grab samples.

5. Fill the sample jars in the order specified in ADEC Field Sampling Guidance, starting with VOCs and if applicable, gasoline range organics (GRO)/benzene, toluene, ethylbenzene, and xylenes (BTEX), containers first. Refer to ADEC Field Sampling Guidance Appendix D for additional sample container information. Field duplicate sample containers will be filled alternately.

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6. Quickly and adequately seal containers, and clean rims before tightening lids. GRO/BTEX and VOC analyses require preservation using methanol.

7. After filling, promptly place containers into a cooler containing gel ice or similar product and chill to 0 to 6 degrees Celsius (°C).

Analytical soil sampling may be conducted for minimally intrusive work at known contaminated sites if requested by Base Kodiak Environmental Division or CEU Juneau Environmental Management Branch.

Sampling will be limited to the contaminants of concern at the specific site. For minimally intrusive work, the exposed surface will be treated like the base of an excavation; the number of samples will be determined by Table 2B (Table 2-2 of this plan) in ADEC Field Sampling Guidance (ADEC 2019a). Samples will be collected for surface soil approximately 6 inches below ground surface. Sampling procedures will follow the collection method described above.

Sample identification, chain-of-custody (CoC), and sample shipping procedures are discussed in Section 7.

Quality control (QC) samples will be collected at the frequencies listed in Section 6.

Horizontal positions of sample locations will be surveyed with a handheld Global Positioning System (GPS) unit; the coordinates will be provided to USCG. The contractor will be responsible for a project report prepared for USCG as described in Section 4.3.

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Table 2-1 Excavated Soil Sample Collection Guide (Table 2A from ADEC Field Sampling Guidance)

BY VOLUME NUMBER OF SCREENING

SAMPLES

ASSOCIATED NUMBER OF LABORATORY SAMPLES

0-10 5 1

11-50 5 2

51-100 1 per 10 cy 3

More than 100 1 per 10 cy, or as the ADEC Contaminated Sites Program determines necessary

3 samples, plus 1 sample for each additional 200 cy, or portion thereof or as the Contaminated Sites Program determines necessary

Notes:

For definitions, refer to the Acronyms and Abbreviations section.

From ADEC Field Sampling Guidance - The Table is appropriate for characterizing the levels of petroleum contamination in soil suitable for management onsite subject to 18 AAC 75.325(i) or for transport to a treatment or disposal facility.

Consult with Contaminated Sites Program for determining the appropriate numbers of field screening and laboratory soil samples for characterizing maximum petroleum concentrations in soil for on-site treatment.

Table 2-2 Surface/Excavation Base and Excavation Sidewall Soil Sample Collection Guide (Table 2B from ADEC Field Sampling Guidance)

BASE OR

SIDEWALL

BY SURFACE

AREA (FT2)

NUMBER OF SCREENING SAMPLES ASSOCIATED NUMBER OF LABORATORY

SAMPLES

Base 0-50 5 1

51-24 5 2

125-250 1 per 25 ft2 2

More than 250 10 plus 1 per additional 100 ft2, or as the ADEC Contaminated Sites Program determines necessary

2 samples, plus 1 sample for each additional 250 ft2 or portion thereof; or as the ADEC Contaminated Sites Program determines necessary

Sidewalls Any For each excavation sidewall, 1 per 10 ft2 (depth and length), or portion thereof, with field screening sample collection focused on soil horizon(s) demonstrated as most likely to be contaminated. *

Minimum 1 per each sidewall plus 1 additional sample for each sidewall area over 250 ft2, or portion thereof at the highest field screening reading in all soil horizons; or as the ADEC Contaminated Sites Program determines necessary. For example, a 12 ft x 30 ft sidewall (360 ft2 total) would require 2 laboratory sidewall samples. *

Notes:

For definitions, refer to the Acronyms and Abbreviations section.

* Field screening samples and laboratory samples are to be collected within a soil horizon at the area most likely to be contaminated, such as on top of confining layers, at the base of more porous layers, at the groundwater interface, or along any other preferential pathways identified in the field. Consult with the ADEC project manager for sampling frequency of sidewalls of 2 feet or less in depth

From ADEC Field Sampling Guidance - This Table may not be appropriate for identifying the number of field screening or laboratory soil samples of a landspread, landfarm, or other soil treatment facility. For guidance on landfarming, please refer to Contaminated Site Program’s Technical Memorandum Landfarming at Sites in Alaska.

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2.2.5.1 Laboratory Analytical Methods

The contractor will submit soil samples to the selected DoD ELAP and ADEC CS-LAP certified analytical laboratory for analysis by Alaska Method (AK) 102/103 for diesel range organics (DRO)/residual range organics (RRO), EPA Solid Waste Method (SW) 6010C for metals, SW8081B for pesticides, SW8082A for PCBs, SW8260D for VOCs, and SW8270DSIM for PAH.

The sample container requirements and methods that meet ADEC Field Sampling Guidance (ADEC 2019a) are presented in Section 7. Containers and methods may vary slightly by laboratory; other acceptable methods are listed in Table 7-1.

2.2.6 Hazardous Waste Characterization

Under certain circumstances that are discussed further in Section 4, soil exceeding cleanup level criteria will require hazardous waste characterization before disposal. In these cases, the analytical requirements will be determined on a case-by-case basis. This would be covered under a site-specific addendum.

2.3 Procedures for Handling Groundwater and Surface Water

Water encountered during construction activities will be dewatered in accordance with the APDES CGP (ADEC 2020b) so long as it meets the criteria for authorized non-storm water discharges . The contractor must submit a Notice of Intent for authorized coverage under the APDES CGP and prepare the appropriate documentation. If the project dewatering does not meet non-storm water discharge criteria as defined in Section 1.4.3 of the CGP (ADEC 2020b), or the project is located within 1,500 feet of a contaminated site or groundwater plume, it will require additional permit coverage under the APDES General Permit for Excavation Dewatering (ADEC 2019b). Note that, although excavation dewatering projects within 1,500 feet of a contaminated site will be required to follow the submittal requirements in the APDES General Permit for Excavation Dewatering, those projects may not need a site-specific EMP if the groundwater to be removed is unlikely to be contaminated based on proximity to a contaminated site, hydrogeologic conditions, topography, and proximity of marine or surface waters. CEU Juneau Environmental Management Branch will assist in determining whether a site-specific EMP is needed for dewatering projects within 1,500 feet of a contaminated site.

Monitoring of effluent from excavation dewatering will be conducted and reviewed in accordance with the criteria presented in Tables 3 and 4 of the APDES General Permit for Excavation Dewatering and may be discharged to land or waters of the United States if water quality criteria are met (ADEC 2019b). The contractor is responsible for effluent monitoring procedures in accordance with the permit.

Construction activities that are candidates for using this Generic EMP may encounter groundwater or surface water outside areas of known contamination that requires dewatering. The minimum depth to water in the project area will be identified using the Kodiak and Base Kodiak Mapbook (USCG 2021) during project design and pre-award to determine if dewatering will be required. The following subsections describe procedures for effluent monitoring where dewatering is expected and also procedures for handling unexpected groundwater or surface water encounters.

It is assumed that the identification of potentially contaminated groundwater or surface water will not result in a stop work order. Construction will be halted temporarily to implement agency notification and analytical sampling procedures.

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2.3.1 Dewatering Monitoring Procedures

Effluent water generated from dewatering will be monitored in accordance with the APDES General Permit for Excavation Dewatering and may be discharged to ground surface or waters of the United States if water quality criteria are met (ADEC 2019b).