A04_-_SoW_Attachment_3-_Kodiak_NWR_Soil_and_GW_Remediation_Report.pdf

Anchorage Seattle 19-062-01R1

SOIL AND GROUNDWATER ASSESSMENT

AND REMEDIATION REPORT

KODIAK NATIONAL WILDLIFE REFUGE TRIPLEX

512 MILL BAY ROAD

KODIAK, ALASKA

ADEC File Number 2601.38.122 ADEC Hazard ID 27197

SEPTEMBER 2020

Submitted to: Charles Grant US Fish & Wildlife Service 1011 East Tudor Road Anchorage, AK 99503

Submitted by: BGES, INC.

1042 East 6th Avenue Anchorage, Alaska 99501 Ph: (907) 644-2900 Fax: (907) 644-2901 www.BGESINC.com

USFWS BGES, Inc.

Assessment and Remediation Report 512 Mill Bay Rd., Kodiak, AK

Page i 19-062-01R1

TABLE OF CONTENTS

INTRODUCTION

SITE BACKGROUND

FIELD ACTIVITIES

3.1 Work Plan Modifications

3.2 Utility Locates

3.3 Test Pit and Remediation Activities

3.4 Soil Disposal

3.5 Monitoring Well Installation Activities

3.6 Survey of Monitoring Wells

EVALUATION OF LABORATORY DATA

LABORATORY DATA QUALITY

CONCEPTUAL SITE MODEL

CONCLUSIONS AND RECOMMENDATIONS

REFERENCES

EXCLUSIONS AND CONSIDERATIONS

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FIGURES (Located at End of report)

Figure 1 Property Vicinity Map

Figure 2 Site Map

Figure 3 Test Pit and Groundwater Monitoring Well Locations and Results

Figure 4 Groundwater Elevation Map (2020)

TABLES (Located at End of Report)

Table 1 Monitoring Well Data (July 2020)

Table 2 Analytical Results – Test Pit MW-3R Soil Samples (July 2020)

APPENDICES (Located at End of Report)

Appendix A Property Photographs

Appendix B Field Notes and Well Completion Logs

Appendix C ADEC-Approved Request to Transport and ASR Disposal Receipt

Appendix D Laboratory Analytical Data

Appendix E Laboratory Data Quality Control Checklist

Appendix F Conceptual Site Model

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ACRONYMS

AAC - Alaska Administrative Code

ADEC - Alaska Department of Environmental Conservation

AK - Alaska Method

ASR - Alaska Soil Recycling

AST - Aboveground Storage Tank bg - Below Grade

BGES - Braunstein Geological and Environmental Services

BTEX - Benzene, toluene, ethylbenzene, and total xylenes

CSM - Conceptual Site Model

DRO - Diesel Range Organics

GRO - Gasoline Range Organics

NWR - National Wildlife Refuge

PAHs - Polynuclear Aromatic Hydrocarbons

PID - Photoionization Detector ppm - Parts Per Million

PVC - Polyvinyl Chloride

QEP - Qualified Environmental Professional

QC - Quality Control

RPD - Relative Percent Difference

SGS - SGS North America, Inc.

USFWS - United States Fish and Wildlife Service

UST - Underground Storage Tanks

VOCs - Volatile Organic Compounds

512 Mill Bay Rd., Kodiak, AK

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INTRODUCTION

BGES, Inc. (BGES) was retained by the United States Fish and Wildlife Service (USFWS) Kodiak National

Wildlife Refuge (NWR) to perform additional site characterization and remediation activities at a former residential triplex building located at 512 Mill Bay Road (Figure 1) in Kodiak, Alaska (hereafter referred to as the subject property). The subject property is listed in the Alaska Department of Environmental

Conservation (ADEC) Contaminated Sites Database as the USFWS Kodiak NWR Triplex with a status of

Active. The subject property is listed under ADEC File Number 2601.38.122 and ADEC Hazard

Identification Number 27197. The purpose of these characterization activities was to define that lateral extent of any remaining contamination and to install additional monitoring wells to further evaluate groundwater contamination. Additionally, the purpose of excavating and disposing of contaminated soil was to remediate some of the petroleum contaminated soils present on the subject property. Field activities were accomplished during July and August of 2020.

SITE BACKGROUND

Diesel soil contamination and two abandoned underground storage tanks (USTs) were discovered to the north of the triplex on the subject property in 2006. Approximately 140 cubic yards of contaminated soils were then excavated and the excavation was backfilled with clean fill material. The excavation was limited by a porch to the west, two aboveground storage tanks (ASTs) to the east, and the triplex building to the south. As such, some contaminated soil was left in place. According to the 2017 Site Characterization

Activities Report, the building was demolished in 2016 and significant evidence of contamination was identified beneath the former building foundation. Subsequent site characterization activities performed by

BGES in 2017 included the advancement of 22 soil borings and installation of 3 monitoring wells. Six of the soil borings, including SB22 which was completed as Monitoring Well MW-1, were advanced on the property to the north of the subject property, and the remaining soil borings and monitoring wells were advanced on the subject property; as shown on Figure 2. Contamination was found to extend to bedrock, which ranged from approximately 4 to 10 feet below grade (bg) across the area. The lateral extent of soil contamination was defined in all directions except to the northwest. At the time of groundwater sampling in 2017, free product was identified within one monitoring well (MW-3). As such, Monitoring Well MW-

3 was not sampled. The groundwater samples collected from Monitoring Wells MW-1 and MW-2 did not exhibit any contaminant concentrations that exceeded the ADEC cleanup criteria. The general direction of groundwater flow was determined to be south-southwesterly. The extent of groundwater contamination

512 Mill Bay Rd., Kodiak, AK

Page 2 of 12 19-062-01R1 appeared to be defined to the west. With this in mind, the following scope of work was performed to assess and remediate the contamination on the subject property.

FIELD ACTIVITIES

Field work for these assessment and remediation activities was performed by a Qualified Environmental

Professional (QEP) as defined by the ADEC, and in accordance with our ADEC-approved work plan dated

September 20, 2019, with the exceptions presented below. Photographs of the field activities are included in Appendix A and field notes, test pit logs, and well installation logs are included in Appendix B.

The excavation of the test pits, installation of the monitoring wells, excavation of contaminated soils, and transporting the contaminated soils to Alaska Soil Recycling (ASR) were completed by Build Alaska, on

July 27, through 30, 2020 and August 7, 2020. Weather conditions at the time of our field activities varied from sunny to mostly sunny with ambient temperatures ranging from 50 to 73 degrees Fahrenheit. Prior to performing any work on site, BGES obtained permission from the respective landowner to access the property for the duration of field activities; however, BGES was unable to obtain access to the property to the north of the site. A discussion of the field activities completed for the subject property are presented below.

3.1 Work Plan Modifications

All field work was performed in accordance with the ADEC approved work plan, referenced above, with the following modifications:

Access to the property located adjacent to, and north of the subject property was not obtained. This necessitated the need to modify the locations of the proposed off-site test pits adjacent to SB21 (a soil boring that was advanced in 2016) that were planned to define the extent of contamination to the north. BGES requested approval from Jamie McKellar, the ADEC Project Manager, to adjust the locations of these test pits and received authorization for these modifications in correspondence from Ms. McKellar dated July 24, 2020.

The work plan stated that the contaminated soils would be placed in super sacks and transported to

ASR for disposal; however, Build Alaska transported the contaminated soils in bulk in dump trucks instead. Approximately 30 cubic yards were transported immediately following excavation activities and the remaining approximately 20 cubic yards were placed in a temporary stockpile on site for later transport to ASR. The contaminated soils were stockpiled on 10-mil liner and covered

512 Mill Bay Rd., Kodiak, AK

Page 3 of 12 19-062-01R1 with 6-mil liner with a berm created around the stockpile using native soils in accordance with

ADEC regulations for short-term storage of contaminated soils as specified in 18 Alaska

Administrative Code (AAC) 75.370. The covering liner was weighed down with non-sharp objects.

BGES requested approval from the Jamie McKellar, ADEC Project Manager, for these work plan modifications and received authorization for these modifications in correspondence from Ms.

McKellar dated July 24, 2020.

When the existing monitoring wells were accessed to obtain depth to water level measurements in order to confirm the direction of groundwater flow prior to the advancement of any test pits, it was determined that Monitoring Wells MW-1 and MW-2 were dry and a shallow obstruction was noted in MW-3 at an approximate depth of 3 feet bg. Based on these results, BGES was not able to determine the general direction of groundwater flow prior to the advancement of test pits and installation of additional monitoring wells.

Groundwater samples were not collected from existing Monitoring Wells MW-1 and MW-2 because these wells did not contain any water.

The work plan called for the installation of five groundwater monitoring wells (including the replacement of MW-3) and excavation of additional two test pits in order to define the extent of contamination. Based on site conditions, four groundwater monitoring wells (MW-3R, MW-4, MW-

5, and MW-6) were installed and three test pits (TP1 through TP3) were excavated. Test Pit TP1 was excavated to groundwater; however, it was determined that the test pit was likely outside of the area of contamination, as it did not exhibit any signs of contamination, and it was likely cross-gradient to the previously determined direction of groundwater flow. A monitoring well was not installed in TP1. Approximately 24 hours after installation of the monitoring wells, all of the newly-installed monitoring wells were accessed and it was discovered that free product was present in all of the newly-installed groundwater monitoring wells. BGES contacted Ms. McKellar at the ADEC and requested approval to not develop and sample these newly-installed monitoring wells. Ms.

McKellar verbally agreed on July 29, 2020 that it was okay not develop and collect samples from the newly-installed monitoring wells.

The remediation activities consisted of the removal of contaminated soils from Test Pits MW-3R, MW-4, MW-5, and MW-6, because an estimated volume of 50 cubic yards were removed from these test pits. Approximately 30 cubic yards of soil were excavated from the vicinity of MW-3R and 20 cubic yards of soil were excavated from the vicinities of MW-4, MW-5, and MW-6. No additional contaminated soils were removed from the subject property because there were no funds available

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Page 4 of 12 19-062-01R1 to remediate additional contaminated soils at this time.

Confirmation soil samples were only collected from the sidewalls of the test pit excavation for MW-

3R because this was the largest excavation for remediation of contaminated soils. Approximately

30 cubic yards of contaminated soils were removed from this excavation.

No well booms were placed in the monitoring wells where free product was observed because the

ADEC did not approve the use of the petroleum remediation powder (PRP) as presented in the original work plan.

3.2 Utility Locates

Prior to mobilizing to the project site, BGES coordinated with the Alaska One-Call Center and local utility companies to request the marking of all underground utilities in the vicinity of the project activities.

3.3 Test Pit and Remediation Activities

BGES mobilized to the site on July 27, 2020, to observe the excavation of test pits, installation of monitoring wells, conduct groundwater monitoring activities, collect heated headspace field screening samples, and collect confirmation soil samples. These activities were performed in order to delineate the lateral extent contamination in soil and groundwater on the subject property and to remediate up to 50 cubic yards of contaminated soil. An effort was made to measure the depths to groundwater and free product in MW-1, MW-2, and MW-3 prior to excavation of the test pits; however, the existing monitoring wells on site did not contain measurable amounts of groundwater and/or free product; therefore, the estimated groundwater flow direction prior to the excavation of test pits and installation monitoring wells could not be completed.

It is noted that a shallow obstruction was encountered in MW-3 when attempting to measure the depth to groundwater and evaluate for the presence of free product. When a test pit was excavated around MW-3 in order to remediate contaminated soils, it was determined that MW-3 had been damaged at approximately 3 feet bg. After removal of approximately 30 cubic yards of contaminated soil, MW-3 was replaced with a new Monitoring Well MW-3R as described below.

A total of seven test pits (TP1, TP2, TP3, MW-3R, MW-4, MW-5, and MW-6) were excavated to define the lateral extent of contamination onsite. Four of the test pits (MW-3R, MW-4, MW-5, and MW-6) were advanced to groundwater for the installation of monitoring wells. Test Pits TP2 and TP3 did not encounter groundwater and were dry. Test Pits MW-3R, MW-4, MW-5, MW-6, TP2, and TP3 all exhibited strong odors and free product was present when groundwater was encountered. Test Pit TP-1 encountered water

512 Mill Bay Rd., Kodiak, AK

Page 5 of 12 19-062-01R1 at an approximate depth of 8 feet bg but did not exhibit any signs of contamination. Because the direction of groundwater flow was previously determined to be towards the southwest a monitoring well was not installed in TP1. Test Pit MW-3R measured approximately 8 feet wide by 10 feet long; Test Pits MW-4, MW-5, and MW-6 measured approximately 3 feet wide by 6 feet long; and the remaining test pits measured approximately 2 feet wide by 6 feet long. The depths of the test pits were approximately 8 to 9 feet bg. The approximate test pit locations are presented on Figures 2 and 3.

Approximately 20 cubic yards of contaminated soil was excavated from the MW-4, MW-5, and MW-6 test pits and approximately 30 cubic yards of contaminated soil was excavated from the MW-3R test pit. Soils removed from Test Pits TP1, TP2, and TP3 were returned to their respective test pit and from the approximate depths from which they originated. No other areas were excavated to remove additional contaminated soil because the total planned volume of 50 cubic yards was removed from these 4 test pits.

These test pits were advanced to depths ranging from approximately 8 feet to 9 feet bg depending upon the depth of groundwater and the subsurface features encountered, such as large rocks. Field screening samples were collected from the sidewalls and/or base of each test pit and were handled as described below. In accordance with BGES’ approved work plan dated September 20, 2019, it was originally planned that samples for laboratory analyses would only be collected from the remedial excavation to document the presence or absence of remaining contamination; however, because contamination was encountered in all of the test pits and the excavation was limited to 50 cubic yards due to budgetary constraints, confirmation samples for submittal to the laboratory were only collected from Test Pit MW-3R Upon retrieval, a portion of the recovered soil samples from the center of the excavator bucket was quickly placed into a laboratory-supplied container utilizing a clean, stainless steel spoon, labeled, and placed in a chilled cooler for submittal for laboratory analysis.

A second portion of each sample (field screening sample) was placed into a sealable plastic bag using a clean, stainless-steel spoon, and labeled with a unique sample number and the time of collection. Soils in each plastic bag were screened with a photoionization detector (PID) that was calibrated prior to use with

100 parts per million (ppm) isobutylene calibration gas. After collection, the samples were agitated for approximately 15 seconds, then allowed to warm in ambient air to at least 40 degrees Fahrenheit for at least

10 minutes, but no longer than 1 hour, and then the plastic bags were re-agitated for approximately 15 seconds. The probe of the PID was then inserted into the bag and the greatest reading was recorded. PID readings for each sample interval are presented in the field notes included in Appendix B. All PID readings for all test pits were 0 ppm. As mentioned above, strong odors and/or free product were observed in all test

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Page 6 of 12 19-062-01R1 pits except for TP1.

The laboratory confirmation soil samples were collected from the smear zone along the sidewalls in MW-

3R test pit, or approximately 9ft bg. A confirmation sample was not collected from the base of this test pit because it was below groundwater. As a quality control measure, a duplicate soil sample was collected from MBR-1-072820 “blindly” identified as MBR-5-072820, and was submitted to the laboratory for analysis. The samples were labeled, placed in chilled coolers, shipped to Anchorage, and then delivered by

BGES personnel under chain of custody protocol to SGS North America, Inc. (SGS) of Anchorage, Alaska.

All soil sampling activities were conducted in general accordance with the work plan, dated September

2019.

The soils across the subject property generally consisted of gravel with silt and sand underlain by clay to the maximum depth of each test pit. The test pit logs with information on the geology encountered during excavation activities and PID readings are included in the field notes in Appendix B. The approximate test pit locations are depicted on Figures 2 and 3.

Approximately 30 cubic yards of soil were placed directly into dump trucks and Build Alaska transported these contaminated soils in bulk to ASR in Anchorage for thermal treatment and disposal on July 30, 2020.

The remaining approximately 20 cubic yards were placed in a temporary stockpile on site and transported to ASR on August 7, 2020. Twenty cubic yards of contaminated soils were temporarily stockpiled on a 10-mil liner and covered with 6-mil liner with a berm created around the stockpile using native soils in accordance with ADEC regulations for short-term storage of contaminated soils as specified in 18 AAC

75.370. The covering liner was weighed down with non-sharp objects.

3.4 Soil Disposal

Potentially contaminated soils that were excavated from the test pits were placed in dump trucks and transported to ASR for thermal remediation and recycling. To prevent the spread of contamination during excavation activities, the following procedures were followed when moving soil from each test pit to the dump truck.

A plastic liner was placed on the ground surface between the test pit and the dump truck so that any spillage was captured on the liner and any spillage was swept up after the last bucket from each test pit and placed with soils in the dump truck.

Each dump truck was covered with a tarp during transportation to ASR.

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The excavator bucket was decontaminated using a dry decontamination method between test pits.

Any residual soil removed during this process was put in the dump truck or stockpile.

Initially, three dump trucks (approximately 30 cubic yards) were loaded with contaminated soils for transport to ASR. The remaining approximately 20 cubic yards of contaminated soils were placed in a temporary stockpile as described above. The soils in the stockpile were then loaded onto dump trucks on August 7, 2020 and transported to ASR for disposal. After removal of the stockpiled soils the native soil berm surrounding the stockpile was graded into the surrounding soils and the plastic was transported offsite for disposal at the landfill.

A total of 74.6 tons (approximately 50 cubic yards) of contaminated soil were transported to ASR for disposal. Following the transportation of contaminated soils, the dump trucks were thermally decontaminated by burning any residual material with a torch. Copies of ADEC-approved Request to

Transport Soils form and the ASR receipt are included in Appendix C.

3.5 Monitoring Well Installation Activities

Four of the seven test pits (MW-3R, MW-4, MW-5, and MW-6) were completed as groundwater monitoring wells using the following methodology. The monitoring well locations were selected to define the lateral extent of contamination to the south and east of MW-3 where free product had been previously identified.

As mentioned above, the test pits located northwest and northeast of MW-3 did not encounter any groundwater; therefore, no monitoring wells were installed in these locations. After completion of the 4 test pits to be completed as monitoring wells, an 8-inch polyvinyl chloride (PVC) pipe was placed in each test pit for use as temporary outer well casing during installation of the test pit monitoring wells. Then the pre-packed 2-inch monitoring well screen and casing was inserted into the 8-inch PVC pipe. The test pit was then backfilled with clean material until the outer temporary 8-inch PVC pipe was stabilized. Sand was added to the annular space between the 8-inch PVC pipe and the 2-inch pre-packed well screening casing until approximately 2-feet above the screened interval of the monitoring well. Hydrated bentonite chips were then added to the annular space to approximately 2 feet bg. Sand was added to the annular space to approximately 6 inches bg. As the annular space was filled with sand or bentonite, the test pit surrounding the well was backfilled with clean material and the 8-inch PVC outer temporary well casing was slowly removed. Once the 8-inch PVC outer temporary casing was removed and the test pit was backfilled, a monument cover was installed over the top of the well and cemented in place to protect the monitoring well.

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A minimum of 24 hours after installation of monitoring wells, the depth to free product and water were measured in each well. Free product was present in all four test pits that were completed as groundwater

Monitoring Wells MW-3R, MW-4, MW-5, and MW-6; therefore, no groundwater samples were collected.

The measured free product thicknesses ranged from 0.05 feet to 0.07 feet (Table 1).

The monitoring well completion logs are included in Appendix B. The monitoring well locations are depicted on Figures 2 and 3.

No decontamination water was generated during these site characterization activities. The electronic interface probe was decontaminated by spraying the probe and tape with an Alconox/water mixture from a spray bottle and then rinsed by spraying the probe again with water. These activities were performed over paper towels and the paper towels were disposed as trash in the local landfill.

3.6 Survey of Monitoring Wells

On July 29, 2020, BGES collected survey measurements of each monitoring well. The tops of each monitoring well casing and the ground surface adjacent to each well were surveyed using a tripod, level, and survey rod. Those measurements were recorded in the field notes and transcribed into Table 1. Those measurements were recorded in the field notes and transcribed into Table 1, where the relative groundwater elevations (after corrected for the presence of free product) within each well were calculated. Then, the calculated groundwater elevations were utilized to create a groundwater elevation contour map, which suggests that the general groundwater flows southerly to southeasterly at an approximate hydraulic gradient of 0.07 foot per linear foot (Figure 4).

EVALUATION OF LABORATORY DATA

Five soil samples (including one duplicate sample) were submitted for laboratory analyses to SGS; an

ADEC-approved laboratory. The samples were analyzed for diesel range organics (DRO) by Alaska

Method (AK) 102.

The soil sample results are compared to the ADEC Method 2 Cleanup Criteria listed in 18 AAC 75.341 –

Table B2, Method 2, Over 40-inch Zone (referring to annual precipitation), Migration to Groundwater values for DRO (October 27, 2018).

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The test pit soil samples collected from the subject property were labeled, for example, MBR-1-072820, where the prefix “MBR” indicates the sample was collected from Mill Bay Road in Kodiak, Alaska; “-1” indicates the sample number; and “-072820” indicates that the soil sample was collected on July 28, 2020.

The test pit soil samples were collected from the smear zone of the MW-3R test pit sidewalls, which was approximately 9 feet bg. No soil samples exhibited contaminant concentrations that exceeded the ADEC cleanup criterion. Analytical results for the soil test pit samples are summarized in Table 2 and Figure 3 and a copy of the laboratory data package is included in Appendix D.

LABORATORY DATA QUALITY

Data quality was reviewed in accordance with ADEC guidance and standard industry practices. An ADEC laboratory data review checklist was completed for the laboratory work order, and is attached in Appendix

E. The checklist provides an overview of the quality of the laboratory data. The following is a discussion of our evaluation of sample conditions and laboratory procedures for the soil samples collected during field activities.

Test Pit Soil Samples – Laboratory Report Number 1203805

The test pit soil samples were shipped to Anchorage and hand-delivered by BGES personnel to SGS’ in

Anchorage under chain of custody protocol. The temperature of the cooler at the time of receipt at the laboratory was 4.3 degrees Celsius, which is within the ADEC-prescribed optimal temperature range of 0 to 6 degrees Celsius.

There were no quality control (QC) failures noted by the laboratory in the case narrative; however, a mistake on the COC was noted on the sample receipt form. The analysis requested was incorrectly labeled as “DRO by AK 101” instead of “DRO by AK 102”. The laboratory contacted BGES personnel to clarify the requested analysis and proceeded to analyze the soil samples for DRO after clarification was received from

BGES.

Sample MBR-5-072820 was a duplicate of Soil Sample MBR-1-072820 and was collected to evaluate field sampling precision. The relative percent difference (RPD) between the reported concentrations of DRO was 16 percent, which is below the acceptable limit of 50 percent, and indicates a good measure of field sampling precision.

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CONCEPTUAL SITE MODEL

A graphic conceptual site model (CSM) detailing various potential exposure media, transport mechanisms, exposure pathways, and human receptors for identified contamination at this site was prepared and is included in Appendix F. The media identified at the site to which the contamination was directly released are subsurface soils and groundwater. The transport mechanisms through which contamination could have mobilized were identified to be direct release to subsurface soils, migration to groundwater, volatilization to air, flow to surface water body, flow to sediment, and uptake by plants or animals.

Potential exposure pathways through which contamination at this site could impact potential current and/or future human receptors were identified to be incidental ingestion of soils, groundwater, and surface water;

dermal absorption of contaminants through contact with soils, groundwater, and surface water; inhalation of indoor and outdoor air, direct contact with sediment, and ingestion of wild or farmed foods.

Potential current and/or future human receptors for this site were identified to be residents, commercial or industrial workers, site visitors and trespassers, construction workers, and subsistence harvesters/consumers.

CONCLUSIONS AND RECOMMENDATIONS

Seven test pits were advanced and four of the test pits were completed as groundwater monitoring wells

(including the replacement of MW-3) to facilitate delineation of the extent of contamination on site. Soil samples collected from the smear zone in the MW-3R test pit did not exhibit concentrations of DRO that exceeded the ADEC cleanup criterion. The approximate extent of soil contamination defined during the

2017 characterization activities appears to be unchanged based on the characterization activities completed during 2020 (Figures 2 and 3).

Groundwater was not encountered in the two northern Test Pits TP2 and TP3; however, strong odors were noted in these test pits. Groundwater was encountered in the remaining test pits during the characterization activities. In the southernmost test pit excavation for TP1, groundwater was encountered but there were no signs of contamination. Strong odors and sheens were encountered in the water and soils of the remaining test pit excavations, which were completed as groundwater Monitoring Wells MW-3R, MW-4, MW-5, and

MW-6. Free product was present in these newly-installed monitoring wells with thicknesses ranging between 0.05 feet and 0.07 feet; therefore, the groundwater monitoring wells were not developed or sampled. The free product plume extends across much of the subject property. The extent of free product

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Page 11 of 12 19-062-01R1 was not been defined by the characterization activities (Figure 3). The approximate depth to groundwater ranged from 6.5 to 8.9 feet bg and general groundwater flows southerly to southeasterly at an approximate hydraulic gradient of 0.07 foot per linear foot.

A total of 74.6 tons (approximately 50 cubic yards) of contaminated soil were excavated from 4 test pits and transported offsite to ASR for thermal remediation and disposal.

Based on these results, we recommend the following activities be conducted at the subject property:

Obtain permission to access the property to the north of the subject property and perform additional site characterization activities to define the extent of soil contamination to the north in the vicinity of Soil Boring SB21 (advanced in 2016). The soil sample from SB21 exhibited a DRO concentration of 384 mg/kg.

Install additional monitoring wells to define extent of free product and groundwater contamination to the west, south, and east of Monitoring Wells MW-4, MW-5, and MW-6.

Evaluate the surface water drainage located along the western property boundary to determine if this area has been adversely-impacted by the groundwater contamination present on the subject property.

Remediate contaminated soil and groundwater and recover free product from the subject property.

Analyze all future soil and groundwater samples for gasoline range organics (GRO); DRO; benzene, toluene, ethylbenzene, and total xylenes (BTEX); polynuclear aromatic hydrocarbons (PAHs); and volatile organic compounds (VOCs) per Appendix F of the ADEC Field Sampling Guidance.

Provide a copy of this report to the ADEC.

REFERENCES

18 AAC 75 – Alaska Administrative Code; Title 18; Chapter 75; Oil and Other Hazardous Substances Pollution Control, October 27, 2018.

Alaska Department of Environmental Conservation, Field Sampling Guidance, October 2019.

Site Characterization Activities Report, Former USF & WS Triplex, 512 Mill Bay Road, Kodiak, Alaska, prepared by BGES, Inc., January 2017.

EXCLUSIONS AND CONSIDERATIONS

This report presents facts, observations, and inferences based on conditions observed during the period of our project activities, and only those conditions that were evaluated as part of our scope of work. Our conclusions are based solely on our observations made and work conducted, and only apply to the immediate

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Page 12 of 12 19-062-01R1 vicinities of the locations where samples were collected. In addition, changes to site conditions may have occurred since the completion of our project activities. These changes may be from the actions of man or nature. Changes in regulations may also impact the interpretation of site conditions. BGES will not disclose our findings to any parties other than our client as listed above, except as directed by our client, or as required by law.

The field work for this project was performed by Vanessa Crandell-Beck, Environmental Scientist of BGES.

This report was prepared by Ms. Crandell-Beck. Ms. Crandell-Beck is a QEP as defined by the ADEC and have performed numerous similar site assessment projects throughout Alaska. This report was reviewed by

Jayne Martin, Senior Environmental Scientist of BGES. Ms. Martin is a QEP and has more than 30 years of professional geological and environmental consulting experience and has conducted and managed thousands of environmental projects involving site characterization and remediation efforts throughout

Alaska and the lower 48 states.

Prepared by: Reviewed by:

Vanessa Crandell-Beck Jayne Martin Environmental Scientist Senior Environmental Scientist

Approximate Property Location

512 Mill Bay Road Kodiak, Alaska

Property Vicinity Map

September 2020 Figure 1

Source: Google Earth Pro©; GINA; USGS DRG

0 ½ 1

Approximate Scale (Miles)

SB 1

SB 2

SB 3

SB 4

SB 5

SB 6

SB 7 SB 16

SB 15

SB 13

SB 12

SB 11

SB 8

SB 9 SB 14

SB 22/ MW-1

SB 17

SB 18

SB 21

SB 19

SB 20

SB 10 N

September 2020 Figure 2

512 Mill Bay Road Kodiak, Alaska

Site Map

Shed #1

Shed #2 Shed #3

LEGEND

= Approximate Soil Boring Location (concentrations were less than ADEC cleanup criteria - 2017)

= Approximate Soil Boring Location (concentrations exceeded the ADEC cleanup criterion - 2017)

= Approximate Soil Boring Location (visually-contaminated, results were less than ADEC cleanup criteria - 2017)

= Approximate Monitoring Well Location (concentrations were less than ADEC cleanup criteria - 2017)

= Approximate Location of MW-3 (MW-3 was replaced by MW-3R in July of 2020)

= Estimated Extent of 2005 Excavation of Contaminated Soils

= Approximate Test Pit Location (excavated - 2020)

= Approximate Test Pit Location (test pit completed as monitoring well - 2020)

= Approximate Former Triplex Building Footprint

ADEC = Alaska Department of Environmental Conservation

Approximate Scale in Feet

0 25 50

MW-2

MW-3R

Approximate Northern Property Boundary

Estimated Extent of Soil Contamination Based on Previous Investigations

MW-5

MW-4

MW-6

TP-1

TP-2

TP-3

MW-3

MW-1

N

September 2020 Figure 3

Kodiak, Alaska

Test Pit and Groundwater Monitoring Well Locations and Results

Shed #3

LEGEND

= Approximate Monitoring Well Location (monitoring wells were dry at the time of 2020 field work)

= Estimated Extent of 2005 Excavation of Contaminated Soils

= Approximate Test Pit Location (excavated - 2020)

= Approximate Monitoring Well Location (test pits completed as monitoring wells – 2020; contained free product)

= Approximate Location of MW-3R (test pit sample results below ADEC criterion for DRO; contained free product)

= Estimated Area of Free Product

= Approximate Former Triplex Building Footprint

ADEC = Alaska Department of Environmental Conservation

Note: Soils that were removed from the test pits for installation of Monitoring Wells MW-3R, MW-4, MW-5, and MW- 6, totaled approximately 50 cubic yards. Therefore, these soils were transported offsite to ASR for thermal remediation and disposal.

Approximate Scale in Feet

0 25 50

MW-2

Approximate Northern Property Boundary

Estimated Extent of Soil Contamination Based on Previous Investigations

MW-3R

MW-5

MW-4

MW-6

TP-1

TP-2

TP-3

N

September 2020 Figure 4

Groundwater Elevation Map (2020)

Shed #3

LEGEND

= Approximate Monitoring Well Location (test pits completed as monitoring wells – 2020; contained free product)

= Approximate Location of MW-3R (test pit sample results below ADEC criterion for DRO; contained free product)

= Approximate Former Triplex Building Footprint

= Groundwater Elevation Contour Line and Elevation (dashed where inferred)

= Approximate Direction of Groundwater Flow (hydraulic gradient = 0.07 foot per linear foot)

ADEC = Alaska Department of Environmental Conservation

GW = groundwater; ft bg = feet below grade; Contour Interval = 1 foot

Approximate Scale in Feet

0 25 50

Approximate Northern Property Boundary Estimated Extent of Soil

Contamination Based on Previous Investigations

MW-6

GW Elevation = 87.48 ft bg (corrected for presence of free product)

MW-5

GW Elevation = 89.08 ft bg (corrected for presence of free product)

MW-3R

GW Elevation = 88.24 ft bg (corrected for presence of free product)

88.0 feet

87.0 feet

MW-4

GW Elevation = 87.26 ft bg (corrected for presence of free product)

89.0 feet

TABLE 1

KODIAK, ALASKA

MONITORING WELL DATA (JULY 2020)

BGES, INC.

Well Number MW-3R MW-4 MW-5 MW-6 Date Sampled N/A N/A N/A N/A Date of Depth and Elevation Measurement 07/29/20 07/29/20 07/29/20 07/29/20 Time of Depth to Water Measurement 12:13 12:11 12:10 12:15 Time Sample Collected N/A N/A N/A N/A Top of Casing Elevation (feet) 95.16 94.81 95.57 95.58 Depth to Product (feet) 6.91 7.55 6.48 8.10 Depth to Water (feet below top of casing) 6.98 7.60 6.55 8.15 Thickness of Free Product (feet) 0.07 0.05 0.07 0.05 Water Elevation (feet) 88.18 87.21 89.02 87.43 Water Elevation Corrected for Free Product (feet) 88.24 87.26 89.08 87.48 Total Depth of Well (feet below top of casing) 9.17 8.10 8.59 8.95 Ground Elevation 95.66 95.34 95.12 95.76 Depth to Water (feet below top of ground surface) 7.48 8.13 6.10 8.33 Well Casing Diameter (Inches) 2 2 2 2 Standing Water Well Volume (gallons) 0.36 0.08 0.33 0.13 Purge Volume-Actual (gallons) N/A N/A N/A N/A Purge Volume During Well Development (gallons) N/A N/A N/A 4.77

Temperature (degrees Celsius) N/A N/A N/A N/A

Conductivity (millisiemans per centimeter) N/A N/A N/A N/A pH (standard units) N/A N/A N/A N/A

Oxidation Reduction Potential (millivolts) N/A N/A N/A N/A

Notes:

Weather conditions on July 29, 2020 were sunny with an ambient temperature of 67 degrees Fahrenheit. Free product was present in all four monitoring wells, the wells were not developed, and groundwater samples were not collected.

Page 1 of 1 19-062-01

TABLE 2

KODIAK, ALASKA

ANALYTICAL RESULTS - TEST PIT MW-3R

SOIL SAMPLES (JULY 2020)

Sample No. Parameter Results (mg/Kg)

LOQ

(mg/Kg) DL (mg/Kg)

ADEC Cleanup Criteria (mg/Kg)1 Analytical Method

MBR-1-072820 DRO 58.5 22.6 7.02 230 AK 102

North Sidewall of Test Pit MW-3R

PID = 0 ppm Depth = 9 feet bg

MBR-2-072820 DRO 48.4 23.5 7.29 230 AK 102

East Sidewall of Test Pit MW-3R

PID = 0 ppm Depth = 9 feet bg

MBR-3-072820 DRO 212 27.0 8.35 230 AK 102

West Sidewall of Test Pit MW-3R

PID = 0 ppm Depth = 9 feet bg

MBR-4-072820 DRO 96.4 25.3 7.83 230 AK 102

South Sidewall of Test Pit MW-3R

PID = 0 ppm Depth = 9 feet bg

MBR-5-072820

Duplicate of MBR-1-072820

RPD = 16% DRO 50.0 24.3 7.54 230 AK 102

1 The soil sample results are compared to Table B2, Method 2, Over 40-inch zone (referring to annual precipitation) human health pathway migration to groundwater for DRO; as stated in 18 Alaska Administrative Code 75.341, as revised on October 27, 2018.

ADEC = Alaska Department of Environmental Conservation; PID = photoionization detector; ppm = parts per million;

DRO = diesel range organics; DL = detection limit; AK = Alaska method; RPD = relative percent difference mg/Kg = milligrams per kilogram

Page 1 of 1 19-062-01

512 Mill Bay Rd., Kodiak, AK

APPENDIX A

PROPERTY PHOTOGRAPHS

Photo 1. MW-4

Photo 4. Former MW-3 Well Casing Photo 3. Former MW-3 Well Casing

Photo 5. Test Pit MW-3R with Contaminated Groundwater

Photo 2. MW-3R Test Pit (facing south-southeast)

Photo 6. MW-3R Installation (facing east)

September 2020 Figure A-1

Property Photographs

Photo 7. MW-4 completed at the surface

Photo 10. Area after site cleanup (facing southeast) Photo 9. Stockpiled soil (facing southeast)

Photo 11. Dump Truck with tarped load (facing east)

Photo 8. MW-5 next to Shed #2 (facing south)

Photo 12. Survey Tripod Location next to Shed #2 (facing south)

September 2020 Figure A-2

Property Photographs

APPENDIX B

FIELD NOTES AND WELL COMPLETION LOGS

APPENDIX C

ADEC-APPROVED REQUEST TO TRANSPORT AND

ASR DISPOSAL RECEIPT

Customer: BGES Project: USFWS - Kodiak Triplex

ASR Account #: 441186-2001

Date Truck # Ticket #

Tare Tare (lbs)

Ticket # Gross

Gross (lbs) Net (lbs) Tons # SS # Drums

7/28/20 FREI 104517 24,660 104517 55,100 30,440 15.22 0 0

INTL 104525 23,100 104525 56,080 32,980 16.49

STER 104527 21,640 104527 53,120 31,480 15.74

8/7/20 INTL 104762 23,100 104762 50,200 27,100 13.55

FREI 104765 24,660 104765 51,860 27,200 13.60

0 0.00 0 0.00 0 0.00

Total 74.60 0 0 Billed

Remaining 74.60 0 0

ASR Received Material Total

ASR

A Division of Anchorage Sand & Gravel Co. Inc.

1040 O’Malley Road, Anchorage, Alaska 99515 Phone (907) 349-3333, Fax (907) 344-2844

1/1 8/18/2020

APPENDIX D

LABORATORY ANALYTICAL DATA

Alexandra Daniel 2020.08.18 11:05:08 -08'00'

Case Narrative

SGS Client: BGES Inc.

SGS Project: 1203805

Project Name/Site: Kodiak MBR

Project Contact: Jayne Martin

Refer to sample receipt form for information on sample condition.

*QC comments may be associated with the field samples found in this report. When applicable, comments will be applied to associated field samples.

Print Date: 08/17/2020 4:37:34PM

Member of SGS Group

SGS North America Inc.

200 West Potter Drive, Anchorage, AK 99518 t 907.562.2343 f 907.561.5301 www.us.sgs.com

Laboratory Qualifiers

Enclosed are the analytical results associated with the above work order. The results apply to the samples as received.

All results are intended to be used in their entirety and SGS is not responsible for use of less than the complete report.

This document is issued by the Company under its General Conditions of Service accessible at

<http://www.sgs.com/en/Terms-and-Conditions.aspx>. Attention is drawn to the limitation of liability, indenmification and jurisdiction issues defined therein.

Any holder of this document is advised that information contained hereon reflects the Company's findings at the time of its intervention only and within the limits of Client's instructions, if any. The Company's sole responsibility is to its Client and this document does not exonerate parties to a transaction from exercising all their rights and obligations under the transaction documents. Any unauthorized alteration, forgery or falsification of the context or appearance of this document is unlawful and offenders may be prosecuted to the fullest extent of the law.

SGS maintains a formal Quality Assurance/Quality Control (QA/QC) program. A copy of our Quality Assurance Plan

(QAP), which outlines this program, is available at your request. The laboratory certification numbers are AK00971

(DW Chemistry & Microbiology) & 17-021 (CS) for ADEC and 2944.01 for DOD ELAP/ISO17025 (RCRA methods:

1020B, 1311, 3010A, 3050B, 3520C, 3550C, 5030B, 5035A, 6020B, 7470A, 7471B, 8015C, 8021B, 8082A, 8260D, 8270D, 8270D-SIM, 9040C, 9045D, 9056A, 9060A, AK101 and AK102/103). SGS is only certified for the analytes listed on our Drinking Water Certification (DW methods: 200.8, 2130B, 2320B, 2510B, 300.0, 4500-CN-C,E, 4500-H-B, 4500-NO3-F, 4500-P-E and 524.2) and only those analytes will be reported to the State of Alaska for compliance.

Except as specifically noted, all statements and data in this report are in conformance to the provisions set forth by the

SGS QAP and, when applicable, other regulatory authorities.

The following descriptors or qualifiers may be found in your report:

* The analyte has exceeded allowable regulatory or control limits.

! Surrogate out of control limits.

B Indicates the analyte is found in a blank associated with the sample.

CCV/CVA/CVB Continuing Calibration Verification

CCCV/CVC/CVCA/CVCB Closing Continuing Calibration Verification

CL Control Limit

DF Analytical Dilution Factor

DL Detection Limit (i.e., maximum method detection limit)

E The analyte result is above the calibrated range.

GT Greater Than

IB Instrument Blank

ICV Initial Calibration Verification

J The quantitation is an estimation.

LCS(D) Laboratory Control Spike (Duplicate)

LLQC/LLIQC Low Level Quantitation Check

LOD Limit of Detection (i.e., 1/2 of the LOQ)

LOQ Limit of Quantitation (i.e., reporting or practical quantitation limit)

LT Less Than

MB Method Blank

MS(D) Matrix Spike (Duplicate)

ND Indicates the analyte is not detected.

RPD Relative Percent Difference

TNTC Too Numerous To Count

U Indicates the analyte was analyzed for but not detected.

Note: Sample summaries which include a result for "Total Solids" have already been adjusted for moisture content.

All DRO/RRO analyses are integrated per SOP.

Print Date: 08/17/2020 4:37:37PM

Member of SGS Group

SGS North America Inc. 200 West Potter Drive, Anchorage, AK 99518 t 907.562.2343 f 907.561.5301 www.us.sgs.com http://www.sgs.com/terms_and_conditions.htm http://www.sgs.com/terms_and_conditions.htm

Sample Summary

Client Sample ID Lab Sample ID Collected Received Matrix

MBR-1-072820 1203805001 07/28/2020 07/31/2020 Soil/Solid (dry weight)

MBR-2-072820 1203805002 07/28/2020 07/31/2020 Soil/Solid (dry weight)

MBR-3-072820 1203805003 07/28/2020 07/31/2020 Soil/Solid (dry weight)

MBR-4-072820 1203805004 07/28/2020 07/31/2020 Soil/Solid (dry weight)

MBR-5-072820 1203805005 07/28/2020 07/31/2020 Soil/Solid (dry weight)

Method DescriptionMethod

Diesel Range Organics (S)AK102

Percent Solids SM2540GSM21 2540G

Print Date: 08/17/2020 4:37:38PM

Member of SGS Group

SGS North America Inc.

200 West Potter Drive, Anchorage, AK 99518

Detectable Results Summary

Client Sample ID: MBR-1-072820

Lab Sample ID: 1203805001 UnitsParameter Result

Diesel Range Organics mg/Kg58.5Semivolatile Organic Fuels

Client Sample ID: MBR-2-072820

Lab Sample ID: 1203805002 UnitsParameter Result

Diesel Range Organics mg/Kg48.4Semivolatile Organic Fuels

Client Sample ID: MBR-3-072820

Lab Sample ID: 1203805003 UnitsParameter Result

Diesel Range Organics mg/Kg212Semivolatile Organic Fuels

Client Sample ID: MBR-4-072820

Lab Sample ID: 1203805004 UnitsParameter Result

Diesel Range Organics mg/Kg94.4Semivolatile Organic Fuels

Client Sample ID: MBR-5-072820

Lab Sample ID: 1203805005 UnitsParameter Result

Diesel Range Organics mg/Kg50.0Semivolatile Organic Fuels

Print Date: 08/17/2020 4:37:39PM

Member of SGS Group

SGS North America Inc.

200 West Potter Drive, Anchorage, AK 99518

Client Sample ID: MBR-1-072820

Client Project ID: Kodiak MBR

Lab Sample ID: 1203805001

Lab Project ID: 1203805

Collection Date: 07/28/20 14:05

Received Date: 07/31/20 10:08

Matrix: Soil/Solid (dry weight)

Solids (%):86.9

Results by Semivolatile Organic Fuels

Results of MBR-1-072820

Location:

Date AnalyzedParameter DFUnitsResult LOQ/CL DL Allowable

LimitsQual

Diesel Range Organics 58.5 mg/Kg 122.6 7.02 08/14/20 17:28

Surrogates

5a Androstane (surr) 89.6 % 150-150 08/14/20 17:28

Batch Information

Prep Batch: XXX43605

Prep Method: SW3550C

Prep Date/Time: 08/10/20 09:17

Prep Initial Wt./Vol.: 30.492 g

Prep Extract Vol: 5 mL

Analytical Batch: XFC15687

Analytical Method: AK102

Analyst: CDM

Analytical Date/Time: 08/14/20 17:28

Container ID: 1203805001-A

Print Date: 08/17/2020 4:37:41PM

Member of SGS Group

SGS North America Inc.

200 West Potter Drive Anchorage, AK 95518

Client Sample ID: MBR-2-072820

Lab Sample ID: 1203805002

Lab Project ID: 1203805

Collection Date: 07/28/20 14:06

Received Date: 07/31/20 10:08

Matrix: Soil/Solid (dry weight)

Solids (%):84.9

Results by Semivolatile Organic Fuels

Results of MBR-2-072820

Location:

Date AnalyzedParameter DFUnitsResult LOQ/CL DL Allowable

LimitsQual

Diesel Range Organics 48.4 mg/Kg 123.5 7.29 08/14/20 17:38

Surrogates

5a Androstane (surr) 63.3 % 150-150 08/14/20 17:38

Batch Information

Prep Batch: XXX43605

Prep Method: SW3550C

Prep Date/Time: 08/10/20 09:17

Prep Initial Wt./Vol.: 30.075 g

Prep Extract Vol: 5 mL

Analytical Batch: XFC15687

Analytical Method: AK102

Analyst: CDM

Analytical Date/Time: 08/14/20 17:38

Container ID: 1203805002-A

Print Date: 08/17/2020 4:37:41PM

Member of SGS Group

SGS North America Inc.

200 West Potter Drive Anchorage, AK 95518

Client Sample ID: MBR-3-072820

Lab Sample ID: 1203805003

Lab Project ID: 1203805

Collection Date: 07/28/20 14:12

Received Date: 07/31/20 10:08

Matrix: Soil/Solid (dry weight)

Solids (%):73.7

Results by Semivolatile Organic Fuels

Results of MBR-3-072820

Location:

Date AnalyzedParameter DFUnitsResult LOQ/CL DL Allowable

LimitsQual

Diesel Range Organics 212 mg/Kg 127.0 8.35 08/14/20 17:48

Surrogates

5a Androstane (surr) 64.4 % 150-150 08/14/20 17:48

Batch Information

Prep Batch: XXX43605

Prep Method: SW3550C

Prep Date/Time: 08/10/20 09:17

Prep Initial Wt./Vol.: 30.209 g

Prep Extract Vol: 5 mL

Analytical Batch: XFC15687

Analytical Method: AK102

Analyst: CDM

Analytical Date/Time: 08/14/20 17:48

Container ID: 1203805003-A

Print Date: 08/17/2020 4:37:41PM

Member of SGS Group

SGS North America Inc.

200 West Potter Drive Anchorage, AK 95518

Client Sample ID: MBR-4-072820

Lab Sample ID: 1203805004

Lab Project ID: 1203805

Collection Date: 07/28/20 14:13

Received Date: 07/31/20 10:08

Matrix: Soil/Solid (dry weight)

Solids (%):78.3

Results by Semivolatile Organic Fuels

Results of MBR-4-072820

Location:

Date AnalyzedParameter DFUnitsResult LOQ/CL DL Allowable

LimitsQual

Diesel Range Organics 94.4 mg/Kg 125.3 7.83 08/14/20 17:58

Surrogates

5a Androstane (surr) 85.4 % 150-150 08/14/20 17:58

Batch Information

Prep Batch: XXX43605

Prep Method: SW3550C

Prep Date/Time: 08/10/20 09:17

Prep Initial Wt./Vol.: 30.334 g

Prep Extract Vol: 5 mL

Analytical Batch: XFC15687

Analytical Method: AK102

Analyst: CDM

Analytical Date/Time: 08/14/20 17:58

Container ID: 1203805004-A

Print Date: 08/17/2020 4:37:41PM

Member of SGS Group

SGS North America Inc.

200 West Potter Drive Anchorage, AK 95518

Client Sample ID: MBR-5-072820

Lab Sample ID: 1203805005

Lab Project ID: 1203805

Collection Date: 07/28/20 14:15

Received Date: 07/31/20 10:08

Matrix: Soil/Solid (dry weight)

Solids (%):82.0

Results by Semivolatile Organic Fuels

Results of MBR-5-072820

Location:

Date AnalyzedParameter DFUnitsResult LOQ/CL DL Allowable

LimitsQual

Diesel Range Organics 50.0 mg/Kg 124.3 7.54 08/14/20 18:28

Surrogates

5a Androstane (surr) 72.1 % 150-150 08/14/20 18:28

Batch Information

Prep Batch: XXX43605

Prep Method: SW3550C

Prep Date/Time: 08/10/20 09:17

Prep Initial Wt./Vol.: 30.078 g

Prep Extract Vol: 5 mL

Analytical Batch: XFC15687

Analytical Method: AK102

Analyst: CDM

Analytical Date/Time: 08/14/20 18:28

Container ID: 1203805005-A

Print Date: 08/17/2020 4:37:41PM

Member of SGS Group

SGS North America Inc.

200 West Potter Drive Anchorage, AK 95518

Blank ID: MB for HBN 1809881 [SPT/11098]

Blank Lab ID: 1573017

QC for Samples:

1203805001, 1203805002, 1203805003, 1203805004

Matr…