ATTACHMENT 07 - XGFG182009 F-35 Alter B400 AMXS - Material Management Plan PFAS.pdf

Weihemuller, Wendy - DNR

From: Ales, Stephen M -DNR Sent: Monday, November 1, 2021 10:52 AM To: Dunlap, Mike J - DMA Cc: HINMAN, MICHAEL T GS-12 USAF ANG 115 CES/Architect; Ross, Issac A - DNR; Ales, Stephen M -

DNR

Subject: MMP Approval B400

Mike:

On October 14, 2021 the Wisconsin Air National Guard submitted a Materials Management Plan for potential soil excavation work to be completed near building B400. Boring 02‐AA‐MW‐5 was completed on the southwest side of the building. Soil and groundwater samples were collected from the boring.

PFAS compounds were detected in soil samples collected from 1 ‐ 1.5 feet and 2 ‐ 2.5 feet below ground surface. PFAS compounds were detected in both soil samples. Eleven (11) different PFAS compounds were found in the soil at this location.

PFAS was also detected in the groundwater sample from this location. Sixteen (16) different PFAS compounds were found in groundwater. The PFAS compounds with the highest concentrations were PFOS, PFHxS, 6:2 FTS, PFHxA and PFOA. Numerous VOC compounds were also detected in groundwater. VOC compounds that exceed NR 140 groundwater enforcement standards include 1,2‐dichloroethane, benzene and bromodichloromethane

The information submitted with this MMP did not contain drawings or another description pertaining to soil or groundwater removal at this location. Since both soil samples, and the groundwater sample from this location contains PFAS compounds the WANG must treat all soil and groundwater removed from this location as PFAS containing soil.

In accordance with the materials management plan approved for this site on July 21, 2021, PFAS containing soil will be placed under an impervious surface at the completion of this project. All soil that is removed for this specific project is considered PFAS containing and needs to be handled as such.

The location map for boring 02‐AA‐MW‐5 indicates this boring is located on the southwest side of building B400. Your submittal did not contain a figure showing boundaries of an excavation. Therefore, any soil that is excavated for any reason from this location must be handled as PFAS containing. Until it is used for final placement the soil from the location of boring 02‐AA‐MW‐5 may be kept at this location or may be temporarily placed to the west of building 1209 in accordance with the MMP.

The groundwater at this location is probably on the order of 5.5 – 7 feet below ground surface. If it is necessary to lower the water table to complete construction activities the WANG must contact the DNR prior to starting construction to determine a proper method for containing and treating the water.

Let me know if you have any questions.

Steve

We are committed to service excellence.

Visit our survey at http://dnr.wi.gov/customersurvey to evaluate how I did.

Stephen M. Ales, P.G.

Hydrogeologist Program Coordinator – Remediation and Redevelopment Bureau, Division of Environmental Management Wisconsin Department of Natural Resources Phone: 608‐400‐9187 Stephenm.Ales@wisconsin.gov dnr.wi.gov

Dedicated to Excellence

WISCONSIN AIR NATIONAL GUARD

HEADQUARTERS 115TH FIGHTER WING (ACC) (ANG)

3110 MITCHELL STREET

MADISON WISCONSIN 53704-2529

13 October 2021

MEMORANDUM FOR WISCONSIN DEPARTMENT OF NATURAL RESOURCES

FROM: 115 CES/CC

SUBJECT: XGFG182009 F-35 Alter B400, Truax Field. Materials Management Plan Addendum – BRRTS #: 02-13-585319

1. Pursuant to the 21 July 2021 approved materials management plan, this serves as a project specific addendum for the subject project.

2. Attachment 1 details PFAS sampling results for the subject project. The single sample point within the sampling area contained PFAS compromised soil. For materials removed within the project site, materials will be managed as PFAS compromised soil. Materials removed within these boundaries (vertically and horizontally) will be managed in accordance with the 21 July 2021 letter, BRRTS #: 02-13-585319. The sample boundaries represent the entirety of the construction area.

3. If you have any additional questions, please feel free to contact me at 608-286-0010 or michael.dunlap@us.af.mil at any time. Thank you in advance for your review of this material management plan.

MICHAEL J. DUNLAP, Lt Col, WI ANG Commander, 115th Civil Engineer Squadron Base Civil Engineer, 115th Fighter Wing

Attachment:

1. B400 Sampling Report Results

2. B400 Sampling Plan mailto:michael.dunlap@us.af.mil

B400 Soil sampling results - PFAS

Site Analyte CAS Number Conc. (ng/g) MDL RL Qualifiers

WI RCL NI

(ng/g)

EPA RSL

(ng/g)

02-AA-MW-5 1'-1.5' PFBA 375-22-4 0.434 0.332 0.480 J

02-AA-MW-5 1'-1.5' PFPeA 2706-90-3 0.883 0.382 0.480 02-AA-MW-5 1'-1.5' PFHxA 307-24-4 0.420 0.207 0.480 J 02-AA-MW-5 1'-1.5' PFHpA 375-85-9 0.552 0.459 0.480 02-AA-MW-5 1'-1.5' PFHxS 355-46-4 3.36 0.374 0.480

02-AA-MW-5 1'-1.5' PFOA 335-67-1 2.21 0.451 0.480 1260 1260

02-AA-MW-5 1'-1.5' PFNA 375-95-1 0.620 0.300 0.480

02-AA-MW-5 1'-1.5' PFOS 1763-23-1 6.25 0.413 0.480 Q 1260 1260

02-AA-MW-5 2'-2.5' 6:2 FTS 27619-97-2 1.74 0.631 0.965

02-AA-MW-5 2'-2.5' PFOSA 754-91-6 16.3 0.972 1.45 Q

02-AA-MW-5 2'-2.5' PFOS 1763-23-1 15.9 0.415 0.482 1260 1260

02-AA-MW-5 2'-2.5' 8:2 FTS 39108-34-4 2.87 0.696 0.965

WI RCL NI - Wisconsin DNR Residual Contaminant Level - non-industrial EPA RSL - US EPA Regional Screening Level (AF guidance for soils and sediments) MDL = Method Detection Limit J = The amount detected is below the Reporting Limit/LOQ RL = Reporting Limit Q = The ion transition ratio is outside of the acceptance criteria.

115FW Truax Field

PFAS Soil Boring Locations

XGFG182009 Alter B400

N

July 21, 2021

Lt. Colonel Mike Dunlap

Wisconsin Air National Guard; 115CES/CEIE

Dane County Regional Airport

3110 Mitchell Street, Building 1210

Madison, WI 53704

Subject: Modification of Previously Approved Materials Management Plans; F-35 Construction Projects, Wisconsin Air

National Guard 115CES/CEIE, Dane County Regional Airport, Madison

BRRTs #02-13-585319

Dear Lt. Colonel Dunlap:

The Wisconsin Department of Natural Resources (DNR) received a revised materials management plan (MMP) on July 16, 2021 for construction activities related to base modifications necessary for the placement of F-35 jets to the Wisconsin Air

National Guard (WANG) base located at the Dane County Airport. This MMP outlines a process for WANG to manage soil and groundwater that is generated during construction activities at the base.

WANG had previously submitted, and DNR had approved, MMPs for several individual construction projects. The July 16, 2021 submittal is meant to replace the previous individually approved MMPs with an overall MMP that will cover all the F-

35 construction projects and ensure that contaminated soil is managed in a consistent manner as construction proceeds.

The revised proposal calls for segregating soil that contains PFAS compounds from soil that doesn’t. Soil that doesn’t contain

PFAS compounds could be used as clean fill either in on site projects, or, taken from the WANG base and used at another location. Soil containing PFAS compounds would be used at the project area where it originated, or another F-35 construction project on base. This soil will be placed in an area where groundwater presently contains PFAS compounds and it will be placed at a location of a planned impervious surface (i.e., under a building, asphalt, or concrete) as part of the F-35 construction project.

Included with the July 16, 2021 MMP plan are PFAS analytical results of soil and groundwater samples collected from an area to the west of Building 1209. These data indicate that both soil and groundwater in that area contain very high levels of

PFAS compounds. PFAS concentrations are similar to those collected at the fire station located adjacent and to the north from the area west of building 1209.

This letter will serve as an approval for the overall approach to managing PFAS contaminated soil at the WANG base at

Truax. The WANG will also submit individual maps from each project where soil will be generated. Those maps will present the soil PFAS analytical data gathered at each location and will also present proposed interpretive boundaries between areas of PFAS containing soils and non-PFAS containing soils.

This MMP approval letter is only addressing PFAS contamination in soil. There is PFAS contaminated groundwater throughout the WANG base. Groundwater dewatering is not anticipated for this construction project. This is based on depth to water from the borings completed at this location, and from experience WANG has gained from other construction projects WANG has completed in the past. As such, DNR understands that WANG does not intend to seek a wastewater discharge permit ahead of construction activities. If groundwater is encountered the MMP states that the water will be containerized and sampled. WANG will then either work with the DNR to gain a WPDES permit, or, gain approval from the

Madison Metropolitan Sewerage District for discharging to the municipal sewer system.

Plan Approval

The Materials Management Plan is approved subject to the following conditions:

Tony Evers, Governor Preston D. Cole, Secretary

Telephone 608-266-2621 Toll Free 1-888-936-7463

TTY Access via relay - 711

State of Wisconsin

DEPARTMENT OF NATURAL RESOURCES

101 S. Webster Street Box 7921 Madison WI 53707-7921

1. Management of excavated soil in conformance with the approved materials management plan shall be completed within one year of the effective date of this letter unless a written extension of this condition is obtained from the DNR.

2. The Wisconsin Air National Guard shall manage excavated material in conformance with the approved materials management plan and shall notify the DNR within 24 hours of discovering material that is not consistent with the contaminant characteristics that have been reported to the DNR or if there are visual or olfactory indications of a contaminant discharge. That material must be segregated and tested to determine appropriate disposal options.

3. If areas of unanticipated soil contamination or discovery of underground storage tanks, piping, drums, etc. are encountered, the DNR shall be notified within 24 hours and appropriate actions to investigate, evaluate, and deal with the situation shall be proposed. Notification of discharge shall be submitted to the Department in accordance with s. NR 706.05(1).

4. The Wisconsin Air National Guard is responsible for obtaining any local, federal, or other applicable state permits to carry out this project. If more than one acre of land is disturbed, a stormwater permit may be required. Contact the DNR’s

Stormwater Manager to determine what, if any, permit is needed.

5. The Wisconsin Air National Guard shall comply with requirements of s. NR 718.12(2)(d) and (e) Wis. Adm. Code as needed or appropriate.

6. The Wisconsin Air National Guard shall submit a documentation report to the DNR within 90 days of substantial completion of the redevelopment project. The report shall contain the following items:

a. As-built drawings documenting compliance with the above conditions of approval.

b. A narrative description of how the above conditions were accomplished including relevant documentation.

c. Color photographs documenting construction aspects addressed in this approval.

d. Documentation of excavation and soil placement activities. The report shall include the description of the total volume and final location/disposition of relocated material.

7. If there is contaminated soil remaining in the area west of B1209 at the completion of the F-35 construction projects

WANG shall submit a plan for a permanent resolution for addressing this remaining soil.

The DNR reserves the right to require the submittal of additional information or to modify or revoke this MMP approval if the Wisconsin Air National Guard fails to comply with the requirements of the proposed MMP. The DNR also retains its right to modify or revoke this approval if circumstances or conditions change, or if new information is found which would warrant modification or revocation of this approval.

If you have any questions regarding this approval, please contact Steve Ales at stephenm.ales@wisconsin.gov or 608-400-

9187.

Sincerely, Steven L. Martin, P.G

South Central Region Team Supervisor

Remediation & Redevelopment Program

Cc: Steve Ales – RR/5, GEF 2