Attch_2_-__2011_RDM_Landspread_MM_Plan.pdf

MAINTENANCE AND MONITORING

PLAN

PETROLEUM CONTAMINATED SOIL TREATMENT

RED DEVIL MINE, ALASKA

Prepared for:

United States Department of the Interior Bureau of Land Management

By:

Weston Solutions, Inc.

With

Marsh Creek, LLC

March 2011

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Maintenance and Monitoring Plan Petroleum Contaminated Soil Treatment

Red Devil Mine, Alaska

March 2011 Page i

Table of Contents

1.0 Project Objectives

2.0 Multi Increment Sampling Strategy

3.0 Inspection of Landspread Treament Area

4.0 Qualified Personnel

5.0 Schedule and Reporting

List of Figures

Figure 1: Landspread Treatment Cell Layout

Figure 2: Increment Cell Sampling Layout

Red Devil Mine, Alaska

March 2011 Page ii

List of Acronyms

ADEC Alaska Department of Environmental Conservation

DRO diesel-range organics

DU decision unit(s) ft2 square foot (feet) ft3 cubic foot (feet)

MI multi increment

QA/QC quality assurance/quality control

RDM Red Devil Mine yd3 cubic yard(s)

Red Devil Mine, Alaska

March 2011 Page 1

1.0 PROJECT OBJECTIVES

The overall objective of this project is to remediate petroleum contaminated soil stockpiled at the Red Devil Mine (RDM) since 2005-2006, using the newly constructed landspread treatment area (Figure 1) constructed in July 2010. The soil was transported to the landspread area, spread to a measured depth, mixed with fertilizer, and then tilled.

Sampling of the soil has been and will be conducted using multi increment (MI) sampling methods following an Alaska Department of Environmental Conservation (ADEC) approved work plan.

The purpose of this Maintenance and Monitoring Plan is to ensure that the selected remedy for the petroleum contaminated soil remains properly implemented and effective.

The selected remedy for the petroleum contaminated soil was landspread treatment, with MI sampling of the material for cleanup confirmation.

The initial phase of the remediation strategy for the petroleum contaminated stockpiled soil implemented during 2010 included:

Spreading of the material at the landspread treatment area;

Addition of fertilizer to the material;

Tilling of the material;

Application of Hydroseed® to the landspread surface; and

MI sampling of the material for cleanup confirmation.

The next phase for the landspread soil is to implement a Maintenance and Monitoring Plan in order to complete the objective of remediating the petroleum contaminated soil.

The proposed maintenance and monitoring strategy includes:

Annual MI sampling of the material for cleanup confirmation;

Annual inspections of the landspread treatment area with addition maintenance (as needed); and

Annual reporting of the inspection and MI sampling results to the ADEC.

Annual monitoring will continue until it is determined the concentrations are decreasing at which time a reduced monitoring schedule could agreed upon with the ADEC.

2.0 MULTI INCREMENT SAMPLING STRATEGY

The contaminated soil stockpiled during the 2005 and 2006 field activities at the site amounted to approximately 52,500 cubic feet (ft3) [1,945 cubic yards (yd3)] which was spread over approximately 40,000 square feet (ft²) of a 60,000 ft2 unlined landspread treatment area. The treatment area was divided into six 10,000 ft² decision units (DUs).

Only four of the DUs were used to spread and treat the soil as presented in Figure 2. DU 1, 3, and 5 now hold approximately 45,000 ft3 (1,667yd3) of contaminated soil spread at a uniform depth of 1.5 ft. DU 6 holds approximately 7,500 ft3 (278 yd3) spread at a uniform depth of 0.75 ft. Each of the four DU will need to be MI sampled following the ADEC

Red Devil Mine, Alaska

March 2011 Page 2

Draft Guidance on Multi Increment Soil Sampling and Technical Memorandum for Environmental Laboratory Data and Quality Assurance Requirements, both dated March 2009.

The primary goal is to remediate the petroleum contaminated soil to satisfy ADEC regulatory requirements so that the soil is available for unrestricted land use. The cleanup level for diesel range organics (DRO) is 250 mg/kg based upon ADEC 18 AAC

75.340 Method 2, Table B2, October 9, 2008 (Under 40 inch Zone, Migration to Groundwater).

The MI soil samples collected biennial will be analyzed at an ADEC-approved laboratory for DRO by method AK102.

3.0 INSPECTION OF LANDSPREAD TREAMENT AREA

The inspection of the landspread treatment area will occur during the biennial MI sampling event, and will include both visual and olfactory inspections of the site for signs of stressed vegetation, erosion, and ponding. The purpose of the inspection will be to assess the condition and integrity of the landspread treatment area. In addition, the inspection will also help to verify the protectiveness and effectiveness of the remedy at the site.

4.0 QUALIFIED PERSONNEL

As required by 18 AAC 75.355, the individual(s) who will supervise field work, collect the MI soil samples, and perform the landspread inspection will be “Qualified Person(s).”

5.0 SCHEDULE AND REPORTING

Landspread MI sampling will be conducted between July and September annually beginning in 2011 until it is determined the concentrations are decreasing at which time a reduced monitoring schedule could agreed upon with the ADEC. This annual reporting will assess the selected remedy and its effectiveness, and determine whether modifications or adjustments to the selected remedy are needed. A letter report will be submitted for BLM and ADEC’s review after work has been completed. ADEC laboratory data review checklists and an MI Quality Assurance/Quality Control (QA/QC) analysis will be included in the reports as attachments.