Attch_3_-_2019_RDM_Landspread_M_M_WP_Rev__1.pdf

May 30, 2019

Alaska Department of Environmental Conservation Attn: Anne Marie Palmieri 410 Willoughby Ave, Suite 303 P.O. Box 111800 Juneau, Alaska 99811-1800

U.S. Environmental Protection Agency Attn: Matt Wilkening 950 W Bannock St, Suite 900 Boise, ID 83702

RE: BLM Contaminated Soil Landspread Area Red Devil Mine, Red Devil, Alaska

Subj: 2019 Sampling Plan Rev. 1

This work plan presents Environmental Management, Inc.’s (EMI) approach to conducting periodic monitoring of the petroleum contaminated soils being treated in the land spread area. EMI will follow the procedures set forth in Weston Solutions’ approved Maintenance and Monitoring Plan for Petroleum Contaminated Soil Treatment, March 2011 (M&M Plan). This plan has been developed by EMI under contract with the U.S. Bureau of Land Management (BLM).

BACKGROUND

The site is an active Alaska Department of Environmental Conservation (ADEC) Contaminated Site identified as the BLM Red Devil Mine site, Alaska Department of Environmental Conservation (ADEC) file No. 2442.38.001, and is in the U.S. Environmental Protection Agency’s (EPA) Superfund Enterprise Management System (SEMS) database as USDOI Red Devil Mine ID number AKD980495618. The Property is known to U.S. Bureau of Land Management (BLM) as the Red Devil Mine (RDM). The RDM is an abandoned cinnabar mine and mercury retorting operation at a remote location near the village of Red Devil, Alaska. In 1987, mercury and arsenic was present in tailings piles, and free mercury was present in site soils associated with a large mercury processing operation that ceased in the early 1970’s. Petroleum hydrocarbon was present in various locations associated with maintenance shops. Other contaminants associated with mercury mining were also present. The site is approximately 10 acres and owned by BLM.

During a 2010 a petroleum contaminated soil treatment facility was established at the RDM. The facility consists of six 100’ x 100’ Decision Units (DU). Three DUs (DU 4 through DU 6) currently hold diesel fuel contaminated soil undergoing “landspread” treatment. Soil in the other DU’s has completed treatment and will not be further monitored. The soil in each DU to be monitored is 0.5 to

1.5 feet deep.

The RDM site is located on the south bank of the Kuskokwim River approximately two miles upstream from Red Devil Village. Access to the RDM and the landspread area is along approximately two miles of pioneer road from the airstrip, or by boat to the mouth of Red Devil Creek. Legal description of the property is: Township 10N, Range 44W, southeast quarter of Section 6, Sleetmute D-4 Quadrangle, Seward Meridian, Alaska. GPS coordinates for the approximate center of the 200’ x 300’ landspread facility are Latitude 61°45'40.78"N and Longitude 157°18'52.53"W.

FIELD ACTIVITIES

The field activities for this summer will include collecting samples of petroleum contaminated soil in DU’s 4, 5, and 6 using ISM procedures in accordance with the approved M&M Plan.

Andy Coulson of EMI will perform the field activities. Mr. Coulson is a Qualified Environmental Professional according to 18 AAC 75.325, and will be escorted while on site by Larry Beck and Crystal Smith of the BLM. Field Activities are planned to take place on June 25, 2019.

Field activities will be to collect representative samples of DUs 4, 5, and 6. The soil treated in other DUs were considered cleanup complete after the last sampling event. The sample increments will be collected along 36 grid points in each DU. Duplicate and triplicate samples will be collected from DU 5 by offsetting the increment locations four feet to the west and north from the primary sample location in DU

5. Samples will be collected according to the methods in Incremental Sampling Methodology (ITRC 2012), as the ADEC no longer publishes their Draft Guidance on Multi Increment Soil Sampling (2009) as referenced in the M&M Plan.

Multi-increment samples will be submitted to SGS Anchorage for sample processing and analysis for DRO using method AK 102.

Investigation derived waste (IDW) may include sampling supplies (i.e., Ziplock bags, gloves). A clean stainless steel spoon will be used for collecting each multi-increment sample so no decontamination water is expected to be generated from the soil sampling. Sampling supplies will be disposed of as solid waste.

REPORTING

EMI will provide a report documenting the field activities. The report will contain a description of field activities, a summary table of the analytical results, and a discussion on the sample results and comparison to ADEC cleanup levels. EMI will also provide figures describing sample locations, photo pages, field notes, the laboratory report and the ADEC Laboratory Data Review Checklist as attachments to the report.

If you have any questions or wish to discuss this project further please do not hesitate to contact the undersigned at (907) 272-9336.

Respectfully, Environmental Management, Inc.

Andy Coulson Environmental Scientist

Encl: Figure 1 – Vicinity Map Google Earth Image Figure 2 – Decision Units Google Earth Image Andy Coulson Resume

Red Devil area

FIGURE 1 VICINITY MAP

DU6

DU5

DU4

DU3

DU1

DU2

RDM Landspread, 2012 Google Earth Image

FIGURE 2 DECISION UNITS

Andy Coulson email: acoulson@emi-alaska.com

Qualified Environmental Professional

EDUCATION:

Whitman College, 2009, Bachelor of Arts in Biology

University of Manitoba, 2015, Master of Science in Biological Sciences

PROFESSIONAL CERTIFICATIONS:

AHERA Inspector

40 Hour HAZWOPER Certification

Alaska Certified Erosion & Sediment

Control Lead

EXPERIENCE AND QUALIFICATIONS:

Mr. Coulson has seven years of experience collecting samples and scientific data in remote locations, including two years in the environmental consulting field. His education for his Bachelors degree included collecting soil samples for an ecology class, and collecting water samples as part of an environmental chemistry class. After receiving his Bachelor’s degree, he spent time supporting contaminated site investigations on the Gulf Coast. He then worked on writing sampling plans and collecting numerous biological samples to study the impact of human-altered environments on wildlife as he worked towards his Master’s Degree.

SELECTED ENVIRONMENTAL SITE CHARACTERIZATION PROJECT EXPERIENCE:

Gulf Coast Restoration Organization (Venice, LA) Natural Resource Advisor Program

(January-July 2011) Mr. Coulson observed, advised, and documented oil spill response activities to minimize their impact to sensitive species. Duties included assisting Shoreline Cleanup Assessment

Teams as they screened shoreline sediments for the presence of petroleum. Shoreline Cleanup

Assessment Teams were made up of personnel who meet the qualifications to be an ADEC qualified sampler. Mr. Coulson also documented locations of observed oiled sediment using GPS.

USACE (Unalaska, AK) Chernofski Harbor Site Investigation (April 2017 – October 2017) Mr.

Coulson assisted EMI’s qualified environmental professionals with preparing sampling and analysis plans and reports on soil sample results for the investigation of the Chernofski Harbor contaminated sites.

Fred Meyer (Anchorage, AK) Fuel Stop Well Decommissioning (May 2017) Under the supervision of EMI’s qualified environmental professionals, Mr. Coulson observed the removal and filling of monitoring wells and prepared the report on the decommissioning at this contaminated site.

Motion and Flow Control Products (Wasilla, AK) Contaminated Soil Removal (May-June

2017) Under the supervision of EMI’s qualified environmental professionals, Mr. Coulson screened and collected samples of stockpiled soil for characterization.

2 Andy Coulson

Neighborworks Alaska (Anchorage, AK) W29th Groundwater Sampling (June 2017-January

2018) Under the supervision of EMI’s qualified environmental professionals, Mr. Coulson collected groundwater samples and prepared reports of groundwater contamination status and trends.

Watterson Construction (Anchorage, AK) ANTHC Fuel Release (August 2017) Under the supervision of EMI’s qualified environmental professionals, Mr. Coulson screened soil samples to confirm the effectiveness of spill response activities. No soils above the project action level requiring sampling were encountered. Mr. Coulson also prepared the report on soil screening activities.

CEI (Anchorage, AK) JBER CHPP Demolition (November 2017-Present) Under the supervision of EMI’s qualified environmental professionals, Mr. Coulson collected analytical soil samples soil borings and from excavations where previously identified contaminated soil had been removed, and assisted preparing plans and reports for this sampling effort. Mr. Coulson also assisted in preparing the SWPPP for the building demolition, and collected concrete and paint samples to characterize building materials.

PRISM Design and Construction (Anchorage, AK) Signature Flight Support Leak (January

2018-Present) Under the supervision of EMI’s qualified environmental professionals, Mr. Coulson screened soils along the path of released fuel, and collected analytical soil samples for the initial release investigation. Mr. Coulson also prepared the preliminary release investigation report.

Décor Industries (Anchorage, AK) UST Closure (March 2018-Present) Under the supervision of

EMI’s qualified environmental professionals, Mr. Coulson collected soil analytical samples by hand and using a drill rig to collect subsurface soils for in-place closure of a regulated UST.

CH2MHill/Jacobs (Deadhorse, AK) Buried Debris Evaluation and Site Characterization (July

2018-Present) Andy served as the QEP and team safety manager for the geophysical survey and environmental site characterization activities on Tract 22. The environmental activities included collecting soil and porewater samples from borings, and collecting sediment and surface water samples from a nearby unnamed water body. Andy also served as the safety manager for EMI, providing health and safety forms/documentation and performing daily tailgate meetings.

Middle Kuskokwim Electric Cooperative (Red Devil, AK) Tank Farm Site Characterization

(July-August 2018) Andy served as the QEP for the site characterization activities associated with the former tank farm, current tank farm, and pipeline in Red Devil. Site activities included collecting soil from test pits across the site to determine the current concentrations and delineate the extent of contamination. Information will be used for developing the scope for future site cleanup activities.

Tanana Commercial Company/BIA (Gallup, NM) Phase II Environmental Site Assessment

(January to August 2018) Andy conducted the Phase II ESA activities associated with an Old

Helium Plant on a Indian Reservation in New Mexico. The plant was no longer in use and had been recently used by transients so many of the building materials had been deteriorated. Andy collected asbestos and lead based paint samples from the buildings. The results of the sampling were used to estimate the cost for demolition of the building and cleanup of the site.