B.08.02.02 Attachment 2 - PWS ATT A_Bldg 5012 Site Characterization Plan_EN_final.pdf

Site Characterization Plan – Bldg. 5012 – USAG Italy

DMC

Remediation Engineering Management Support, USAG

Italy Darby Military Community W912PF-17-C-0005, Option 3

USAG Italy Darby Military Community

Project Number: 60633452

November, 22 2021

Site Characterization Plan – Bldg. 5012 – USAG Italy DMC

AECOM Remediation Engineering Management Support, USAG Italy DMC

AECOM

Prepared for:

USAG Italy Darby Military Community

Prepared by:

AECOM URS Italia S.p.a.

20143 - Via Giacomo Watt 27

Milano

Italia

T: +39 02 4225561 aecom.com

© 2021 AECOM URS Italia S.p.a.. All Rights Reserved.

This document has been prepared by AECOM URS Italia S.p.a. (“AECOM”) for sole use of our client (the “Client”) in accordance with generally accepted consultancy principles, the budget for fees and the terms of reference agreed between AECOM and the Client. Any information provided by third parties and referred to herein has not been checked or verified by AECOM, unless otherwise expressly stated in the document. No third party may rely upon this document without the prior and express written agreement of AECOM.

Table of Contents

1 Introduction and Scope of Work

2 Site description

2.1 Geographical sett ings

2.2 Description of the Site and summary of past activit ies

2.3 Summary of past environmental investigations

2.4 Excavation for hotspot removal

3 Preliminary Conceptual Model

3.1 Geological sett ings

3.2 Hydrogeological settings

3.3 Lithostratigraphy of the Site area

3.4 Primary Source of contamination

3.5 Potential secondary contamination sources

3.6 Contaminant transport mechanism

3.7 Potential receptors and exposure pathways

4 Investigation Plan

4.1 Methodology

4.2 Preliminary activit ies

4.3 Soil bor ings and monitoring wells installation

4.3.1 Soil bor ings

4.3.2 Monitoring wells installation

4.3.3 Decontamination procedures

4.4 Soil gas probes

4.4.1 Location of soil gas probes

4.4.2 Soil gas probes installation

4.5 Soil sampling

4.6 Groundwater sampling

4.7 Soil gas monitoring

4.8 Samples shipping and preservation

4.9 Chemical analyses

4.9.1 Soil samples

4.9.2 Groundwater samples

4.9.3 Soil gas samples

4.10 Hydraulic conductivity test

5 Waste management

6 Reference documents

Figures

Figure 1. Location of Bldg. 5012 in Livorno Supply & Maintenance (Depot) Figure 2. Geological map Figure 3. Hydrogeological map

Figures attached

Figure 1 Site location map

Figure 2 Location of proposed site investigations

Annexes

Annex 1 Soil results of preliminary investigations

Annex 2 Spill Incident Report

Annex 3 Technical Data Sheet of spilled Diesel Fuel

Annex 4 Drinking water wells characteristics

Acronyms and Abbreviations

ASA Ammunition Storage Area

B.g.l. Below Ground Level

Bldg. Building

CSC Concentrazione Soglia di Contaminazione / Contaminant Threshold Concentration

D. Lgs. Legislative Decree

DMC Darby Military Community

EWC European Waste Code

IBC Italian Base Commander

LNAPL Light Nonaqueous-phase liquids

LTM Long Term Monitoring

NAPL Non-aqueous-phase liquids

ORP Oxidation Reduction Potential

PE Polyethylene

PID Photoionization Detector

PVC Polyvinyl chloride

SNPA Sistema Nazionale per la Protezione dell'Ambiente / Italian National System for Environmental

Protection

USAG United States Army Garrison

VOC Volatile Organic Compounds

1 Introduction and Scope of Work

This Characterization Plan has been prepared by AECOM URS Italia S.p.A. (hereinafter “AECOM”) for the United

States Army Garrison (USAG) Italy Darby Military Community (DMC) as per Task 4 of contract # W912PF-17-C-

0005, Option 3.

On 11 November 2020, the accidental spill of approximately 528 gallons (equal to approximately 2000 liters) of diesel fuel from an underground pipeline located in the area between the above ground diesel tank (hereinafter

AST) and building 5012 (hereinafter Bldg. 5012), was discovered. The area is located at the Livorno Supply and

Maintenance Area (Depot), USAG Italy DMC. Immediate prevention measures were taken to absorb the diesel fuel identified through absorbent sand and absorbent pads that afterwards were sent for disposal in accordance with applicable regulations. The site is in a paved parking area and no other immediate preventive measures were taken through excavation. A report about the accidental spill was forwarded on the same date to the Italian Base

Commander (IBC).

The notification of potential contamination pursuant to Article 242 of Legislative Decree No. 152 of 3 April 2006

(D.Lgs. 152/06) was sent on 18 November 2020.

During the preliminary investigations conducted in December 2020 and January 2021, exceedances of the

Contamination Threshold Concentrations (CSC) for light (C≤12) and heavy (C> 12) hydrocarbons defined for sites for commercial and industrial use were detected in the TP1, TP2, TP5 and TP6 excavations.

In the following chapters, in order to comply with Article 242 of D.Lgs. 152/06 and subsequent amendments and with Annex 2 of Part IV of the same decree for the writing of a characterization plan, the Historical Reconstruction of Activities (together with the description of past investigation activities), the Preliminary Conceptual Model and the Investigation Plan are detailed.

2 Site description

2.1 Geographical settings

The USAG Italy DMC is located in the central-coastal side of the Tuscany region, in the “Pianura Pisana” (Pisa

Plain), 15 kilometers (km) southwest from the center of the city of Pisa and 4 km east of the coastline (at Tirrenia locality). More specifically, the U.S. Army installation is located between the Pisa municipal territory (“San Piero a

Grado” locality), the “Canale Scolmatore” canal (Stagno locality, Livorno munic ipal territory), and west of the national road #1 “Aurelia”. Its area falls under the Natural Park of Migliarino – San Rossore – Massaciuccoli.

Historically this area of Tuscany was part of the “Tombolo” landed property, which is located in a vast plain cr eated by sedimentary processes in a transitional environment and by anthropic processes of land reclamation and leveling. The human interventions changed the fluvial system into an artificial drainage system. The average elevation ranges approximately from 2 - 3 m above sea level in the eastern part of the U.S. Army installation area, to an elevation below sea level (even more than 1 m below sea level) in the western part; the inclination of the terrain is about 0.0005 percent in a south, southwest direction. The area surrounding USAG Italy DMC is mainly rural/wooded.

Within the USAG Italy DMC property, three different areas are included: “Camp Darby”, “Livorno Supply &

Maintenance Area – Depot”, and “Ammunition Storage Area – ASA”.

Bldg. 5012 is in Livorno Supply & Maintenance Area (see Figure 1 below).

Figure 1. Location of Bldg. 5012 in Livorno Supply & Maintenance (Depot)

2.2 Description of the Site and summary of past activities

Diesel fuel used for heating purposes spilled from underground pipe joints located in the area between the above-ground diesel tank (hereafter AST) and Bldg. 5012 (see Figure 2 attached hereto). Specifically, diesel fuel was found by DMC personnel in an inspection manhole located alongside the AST on November 11, 2020. Immediate prevention measures were put in place to absorb the detected diesel fuel through absorbent sand and absorbent pads, which were subsequently sent for disposal in accordance with applicable regulations.

According to information provided by the USAG Italy, it is possible that the spill from the joints of the diesel fuel piping (No. 2 previously active supply pipes) occurred in the period between the previous leak test (positive - no leakage) in July 2020 and November 11, 2020, when another leak test was performed on the piping and leaks were found.

Bldg.5012

Based on the received information, an estimated amount of 2,000 liters of diesel fuel spilled into the ground.

Subsequent investigations and the removal of the manhole and part of the buried piping, have made it possible to verify that the leakage occurred exclusively in the joints of the piping, located in the manhole, and that the diesel fuel infiltrated the ground through the manhole itself.

The Spill Incident Report is included in Annex 2. Specifications of the spilled diesel fuel, which were provided by the USAG Italy DMC contractor, are included in Annex 3.

2.3 Summary of past environmental investigations

In order to define the potential contamination of the soil, the below-listed activities were performed by the USAG

Italy and supervised by AECOM in December 2020 and January 2021:

✓ Investigations conducted at the site on December 2 and 3, 2020 included the following activities:

▪ Removal of the inspection manhole alongside the AST where diesel fuel had been detected on November

11, 2020.

▪ Excavation to determine the exact course of the Bldg. 5012 boiler feeding pipe.

▪ Safely draining of the pipeline from the diesel fuel content.

▪ Removal of the pipeline, in the section located under the asphalted parking area.

▪ Execution of n. 4 trial pits (TP1, TP2, TP3 and TP4) and collection of samples for chemical analysis.

✓ Investigations conducted at the site on January 18 and 19, 2021 included the following activities:

▪ Execution of n. 2 trial pits (TP5 and TP6) and collection of samples for chemical analysis.

▪ Execution of an excavation to remove the contamination hotspot detected around TP1.

▪ Collection of n. 2 samples of the excavation bottom for chemical analysis.

Laboratory analysis results show exceedances of regulatory limits for:

▪ light hydrocarbons (C≤12) in sample TP1 (2-2.4) and in the FS2 excavation bottom sample.

▪ heavy hydrocarbons (C>12), in trial pits TP1, TP2, TP5, and TP6, with a maximum of 91,000 mg/kg in sample TP1 (2-2.4) and a minimum, for the exceedances, of 1,400 mg/kg in sample TP2 (2-2.4).

The distribution of concentrations shows high concentrations in the area where the spill occurred, i.e. around the inspection manhole, which was later removed, with maximum concentrations in TP1 (located under the manhole) and gradually lower concentrations moving away (TP2, TP5 and TP6). Instead, the farthest trial pits, TP3 and TP4, show no traces of contamination.

In addition, the excavation bottom (at 1.5 m from p.c.) in the contamination hotspot removal zone also shows in samples FS1 and FS2 concentrations in the order of thousands of mg/kg of total hydrocarbons.

It should be underlined that the unsaturated horizon between 0 and 1.5 meters from p.c., interested by the trial pits

TP1, TP2, TP5 and TP6 has been entirely removed through the prevention measures conducted in January 2021.

For detailed results see Annex 1.

2.4 Excavation for hotspot removal

As a prevention measure to limit the spread of contamination, excavation operations were conducted to remove the contamination hotspot located around the trial pit TP1.

The operations were carried out with excavators and qualified personnel of the USAG Italy, while AECOM personnel supervised all field activities, which were performed on January 18 and 19, 2021.

The excavation has been carried out on a plan area of 7 x 4 meters and has been deepened up to the detection of groundwater, at a depth of 1,5 meters below ground level. It should be underlined that, due to heavy winter rainfalls , there has been a considerable rise in the elevation of the groundwater table, which, at the beginning of December

2020, was locally about 2.4 meters below ground level.

Two soil samples (FS1 and FS2) were collected to verify the bottom of the excavation, as detailed in the following sections. All excavated materials were collected separately (asphalt, sub-base layer and contaminated natural soil) to be characterized as waste for proper disposal in accordance with applicable regulations.

3 Preliminary Conceptual Model

3.1 Geological settings

The “Pisa Plain” is a coastal and fluvio-deltaic plain, located on the last portion of the Arno and Serchio rivers. It is the result of sedimentary processes in continental and transitional environments. Alluvial, deltaic, beach and aeolian dunes depositional environment processes were active in the plain formation.

A structural depression, created starting from the upper Miocene, was filled by Miocene, Pliocene and Quaternary deposits, which are placed on the same litological complex that outcrops on the hills that surround the plain:

Tuscany Series (middle Trias–lower Miocene) and Liguria Series (upper Jurassic–Eocene) carbonate and arenaceous rocks. The extensional tectonic activity is well-documented until Middle Pleistocene.

In this structural depression were first accumulated marine, continental and transitional sediments linked to the

“Messiniano” event, followed by sea transgressive clays “Argille Azzurre”, alternations of clays and sands (“Sabbie

Gialle”). These sediments were followed by the sands and clays “ad Arctica”, dated to Lower Pleistocene and eventually, at the end of Lower Pleistocene, the shallow water and transitional sands (“Sabbie di Nugola Vecchia”) indicating a sea regression.

The upper part of the plain is made of sediments settled after the Lower Pleistocene in conditions of changing sea level and sediment transport in rivers accordingly to climate variations during the Pleistocene Glaciation. A clastic, continuous level (known as “Arno e Serchio da Bientina” conglomerates) is present at a depth of 50-145 m (80–

100 m under the USAG Italy DMC area). This level of conglomerates was created during the Würm I (or Würm II) phase (Upper Pleistocene), during which a considerable lowering of sea level took place (due to a change in the terrestrial ice volume) and its thickness is of about 5-10 m.

Fluvial-marsh silt materials (“Limi Fluvio-Palustri del Sottosuolo”) had progressively accumulated on the conglomerates during the subsequent eustatic sea level rise. Along the coastline, shoreline sediments and aeolian dunes had taken shape during a dry climate phase (e.g., dunes of “Isola di Coltano”). Dune formation and the progressive rise of the eustatic level, have limited the outflow of the rivers at sea, with the subsequent formation of marshlands and lagoons, which allowed the deposition of silt, clay and peat.

Above these sediments lie the fluvial-marsh silt materials named “Limi Fluvio-Palustri di Superficie”. These are mainly Holocene sediments, outcome of the aggradation of Arno and smaller rivers. Along the coastline, beaches and shoreline aeolian dunes sediments have been accumulating during the Holocene. In the aeolian dune depositional environment is remarkable the presence of interdunal wetlands where silt, silty sands and sometimes organic clays and peat have accumulated. This gave rise to lithological alternations with a pattern parallel to the shoreline as visible in the military installation area (Figure 2).

Figure 2. Geological map: The Site is indicated with a red circle, in brown - sandy sediments of shorelines and dunes, in yellow - interdunal sediments, in light blue - reclaimed marshes, in beige- alluvial deposits, in dark red -

Coltano Dunes (from “Piano Strutturale del Comune di Pisa, 1997”).

3.2 Hydrogeological settings

In the Pisa Plain, underneath a discontinuous phreatic aquifer, there is a multi-strata confined aquifer, which consists of:

• Confined aquifer in sands (I Artesian Aquifer in Sands).

• Confined aquifer in gravels (I Artesian Aquifer in Gravels).

Above the confined aquifers, a phreatic aquifer is present under the USAG Italy DMC area. Within the area between the coast and the coastal dunes eastward limit, the phreatic aquifer, with a thickness of approximately 20 m, lies within sand deposits with good permeability. In the internal plain areas, the thickness rarely exceeds 10 m and the aquifer is poorly productive.

Regarding the phreatic aquifer, the coastal plain morphology, changing from flat to a slightly curved surface, created a uniform regional groundwater gradient. The groundwater table morphology is strongly influenced by the draining pumps of the land reclamation consortium and by heavy rain events. Without human interventions, the groundwater flow would be heading west or southwest (see Figure 3).

The groundwater flow direction of the phreatic aquifer (based on the measurements performed during the LTM program and other environmental investigations), is currently east-northeast, to be verified through the characterization activities. Expected groundwater depth varies seasonally in the area and is approximately 1,5 -

2.5 m below ground level.

Figure 3. Hydrogeological map: The Site is indicated with a red circle, the red lines are the isophreatic contour lines (from “Piano Strutturale del Comune di Pisa, 1997”).

3.3 Lithostratigraphy of the Site area

The stratigraphy found during the excavations made during the preliminary investigations, up to the maximum depth reached (2.4 m from c.p.) can be summarized as follows:

▪ From 0 to 0.1 m below ground level: asphalt.

▪ From 0.1 to 0.4 m below ground level: sub-base layer.

▪ From 0.4 to 2.4 m below ground level: slightly silty sand, loose.

3.4 Primary Source of contamination

The primary potential source of the contamination identified during the preliminary investigations was the diesel fuel contained in the above-ground tank and in the pipes outside of the building, which spilled into the sump due to a leakage later found in the pipe joints. The pipes have been partially removed and the remainder has been emptied and is currently not in use. The tank has proved to be tight and it is correctly in service, connected to the boiler room with temporary external pipes.

Therefore, the primary contamination source is no longer active.

3.5 Potential secondary contamination sources

Potential secondary contamination sources are related to the concentrations of light and heavy hydrocarbons, detected in the soil matrix during the preliminary investigations carried out in December 2020 and January 2021.

These constituents are considered the Contaminants of Concern of the Site.

Currently no data are available regarding the potentially impacted groundwater matrix, nevertheless the presence of hydrocarbons in groundwater cannot be excluded, which consequently could be considered a secondary source.

3.6 Contaminant transport mechanism

From the above-mentioned sources of contamination, the potential transport mechanisms could be:

• volatilization from shallow and deep unsaturated soil and from groundwater.

• leaching in the soil and dilution in groundwater.

• transport and dispersion in groundwater.

Based on the results of characterization activities, the actual contaminant transport mechanisms shall be verified though the risk assessment.

3.7 Potential receptors and exposure pathways

Bldg. 5012 consists of a single floor above ground and it houses offices of the 509th Department. The building is completely fenced.

The Site is in the area between the above ground diesel fuel tank (hereinafter AST) and building 5012.

Near the Site there are the following buildings:

• The Fire Department station (Bldg. 5013) about 40 meters east of the site.

• Building 5138, located about 70 meters north-east of the site, consisting of an above ground floor where offices are located.

• Warehouse 1 (bldg. 5010), used for storage and with offices on the first floor, located about 80 meters west of the site.

• Building 5015, used for storage and with offices on the first floor, located about 130 meters south-east of the site.

• Shop 5010 located about 150 meters southwest of the site.

Based on results of preliminary investigations, potential human receptors are workers.

Potential exposure pathways for human targets are indoor and outdoor vapor inhalation.

Groundwater must be considered a potential receptor, as groundwater at the point of compliance could possibly have concentrations higher than the threshold values. Point of Compliance will be determined based on actual groundwater flow direction (to be verified through characterization results) at the downgradient limit of the Bldg.

5012 area.

The closest drinking water wells are situated in the ASA (N.1 and N.2 wells, Annex 4). In the past, before completing the connection to the aqueduct, these wells were used to provide Camp Darby, Depot and most of ASA with drinking water. As it can be seen from maps and wells stratigraphy contained in Annex 4:

• The site is situated out of the wells buffer zone (200 m from the wells)

• Wells are installed in the deep confined aquifer – not the phreatic one;

• The groundwater flow direction of the phreatic aquifer is east-northeast, whereas wells are located to the north of the site on the other side of the Navicelli channel.

Consequently, based on the above assumptions and hydrogeological characteristics of the area, negative impacts on the quality of the drinking water pumped from no. 1 and no. 2 wells are not expected. The location of the two wells is shown in Annex 4.

Based on results of characterization activities, the exposure pathways shall be revised accordingly.

4 Investigation Plan

4.1 Methodology

Based on the results of the investigations carried out in December 2020 and January 2021, the above-mentioned

Contaminants of Concern (CoCs) must be sought in the soil and groundwater matrices. Additionally, an evaluation of the soil gas quality at the site shall be performed through quarterly soil gas monitoring surveys as per the SNPA guidelines. Planned investigations include:

• drilling of nine (9) boreholes.

• installation of eight (8) monitoring wells.

• installation of seven (7) soil gas probes.

• soil sampling.

• groundwater and possible NAPL sampling (if any).

• execution of four (4) quarterly soil gas monitoring surveys.

• chemical analyses of the collected samples.

• performance of hydraulic conductivity tests.

In the following sections, the procedures for the investigations to be performed are detailed.

4.2 Preliminary activities

A Health and Safety Plan for executing the field work, in compliance with the relevant Italian regulations including

D.Lgs. 81/2008 and all other applicable regulations and contract requirements shall be prepared.

Prior to proceed with drilling operations, the points accessibility must be checked with a visual survey. Additionally, for each investigation point an underground utilities check shall be performed in order to prevent interception of services such as cables, pipes or any other structure that could be encountered or damaged during drilling .

Specifically, at least the below-listed activities shall be conducted:

• service plans shall be obtained from USAG Italy.

• a site survey shall be performed in collaboration with a Site representative.

• manholes shall be inspected in the area.

• traces of any pavement repair due to underground utilities installation or maintenance shall be located in the area.

• starter pits shall be advanced to prove the absence of any utilities to a depth of approximately 2.0 meters.

4.3 Soil borings and monitoring wells installation

4.3.1 Soil borings

Nine (9) boreholes (5012_SB1 and 5012_MW1-MW8) shall be drilled using a coring tool to reach the first silty layer that separates the shallow part of the aquifer from the underlying parts. According to information gathered from other drillings in the USAG Italy DMC area, this bed could be reached at a depth of about 8 to 10 m b.g.l.. The borings shall penetrate the silty bed for at least 50 centimeters (cm).

The borings shall be made in continuous coring mode with a hydraulic rotary machine. The corer diameter shall be

101 millimeters (mm). The drilling must be in dry mode, i.e., without adding water, and the single coring manoeuvres shall be no more than 1 m long. The drilling shall be done at low speed in order to avoid soil cores heating up.

Temporary (stainless steel) casing pipes (diameter 127 mm) shall be put in place in order to sustain the borehole and to avoid that possible contamination in shallow soil could reach deeper layers.

Soil cores shall be extruded from the corer without using liquids and shall be put in polyethylene (PE) core boxes where characterization site, date, boring number and depth of the cores shall be indicated.

A geologist shall do a screening for prospective soil contamination using a PID for the detection of volatile organic compounds (VOCs) by headspace analysis after every single meter of core is extracted.

Pictures of all the soil cores extracted shall be taken and a detailed soil stratigraphy shall be written in the field by a geologist. The core boxes should be stockpiled in a sheltered area at the USAG Italy DMC’s disposal.

Location of the planned boreholes is shown in Figure 2 attached hereto.

4.3.2 Monitoring wells installation

Eight (8) monitoring wells shall be installed in nine of the boreholes previously drilled (5012_MW1-MW8) in order to create a network for groundwater monitoring at the site.

The borehole shall be widened by means of drilling with a 178 mm stainless steel casing until reaching the silty bed at the base of the shallow part of the aquifer. During the borehole widening operations, a moderate amount of clean water could be used.

Subsequently a polyvinyl chloride (PVC) 4” pipe shall be inserted with the bottom cap placed inside the silty bed, with a probable length of about 8-10 m. As an indication, slotted pipe (screened) shall be mounted from 1 meter below the top of casing to the bottom cap, in order to sample groundwater or LNAPL. Actual length and depth of the monitoring well screen and casing shall be defined in the field by a geologist on the basis of the encountered geology and of actual depth of groundwater. In the annular hollow space between the casing and the soil, the filter

(gravel) pack shall be put in place, from the bottom (even under the bottom cap) to 50 cm above the screened casing. The gravel must be washed, naturally rounded and have a particle size of 2 to 4 mm. Above the filter pack, a 30 cm thick bentonite seal shall be laid using pellet bentonite to be soaked afterwards. A layer of self-hardening cement/bentonite slurry shall be used to grout in the remaining annulus and a manhole suitable for vehicles and trucks must be put in place. Above-ground manholes will be necessary for monitoring wells placed in non-paved areas.

After installation, monitoring wells shall be developed by pumping at least an amount of water equal to 5-7 volumes of water in the well and until water is clear and free of sediments. The development could be made by using an electric submersible pump.

Once the monitoring wells are installed, a topographic survey shall be performed, to measure their location and top of casing elevation above sea level.

For each monitoring well, the following information shall be recorded:

• Well diameter.

• Constructional diagram.

• Location and type of well slots.

• Location of filter pack and seals (bentonite and grout).

• Top of casing elevation obtained by a topographic survey.

• Groundwater level below top of casing.

4.3.3 Decontamination procedures

Below are the decontamination procedures for drilling equipment:

• To prevent cross-contamination of samples, the coring equipment (corer, rods) must be properly decontaminated before and after every single coring maneuver by means of a pressure washer and clean hot water.

• To assure that water and moisture on inner and outer equipment sides could naturally vaporize, two corers must alternate in drilling operations.

• At the end of drilling operations, the equipment must be kept in such a way as to prevent its contamination .

• While handling equipment clean gloves must be used and, to prevent the contact with the contaminated material, disposable gloves must be used.

4.4 Soil gas probes

4.4.1 Location of soil gas probes

For the location of the monitoring points, the indications contained in the SNPA 15/2018 guidelines are taken as a reference. Therefore, a reasoned location of the sampling points is provided. This proposed location considers the potential sources of contamination where the exceedances of the CSCs and the identified targets were detected.

For the verification of the risk from indoor and outdoor inhalation from soil and groundwater, for on-site receptors, it is proposed to install seven (7) soil gas probes near the investigation points. Four probes are placed at a distance of 1.5-3 meters from the building in order to check indoor inhalation.

The location of the soil gas probes points is shown in Figure 2 attached hereto.

4.4.2 Soil gas probes installation

In order to install the probes a borehole up to about 1,50 m b.g.l. shall be obtained. The probe will be put in a 20 cm thick bed made of selected gravel and connected to a 1.30 m long rilsan tube. The gravel will be poured up to cover the probe with a thickness of about 0.15 m of material. Subsequently, two layers will be made up respectively of anhydrous and hydrated bentonite: the first, about 20 cm thick, is laid down in order to prevent the hydrated bentonite from percolating and obstructing the filter; the second is placed dry in 2-3 consecutive layers, each a few centimeters thick, subsequently hydrated with clean water, to create a minimum thickness of 30 cm.

Finally, the remaining thickness will be sealed to the surface with self-hardening cement/bentonite slurry. The sampling points must be completed with the installation of valves which simplify the sampling activities and prevent the entry of ambient air into the sampling point. In addition, to protect the sampling point from rainwater and accidental damage or vandalism a manhole suitable for vehicles and trucks must be put in place.

4.5 Soil sampling

In total, at least eighteen (18) soil samples shall be collected from the nine planned soil borings following the below indicated scheme:

• One sample from 0 to 1 m b.g.l. (shallow soil).

• One sample of the 1 m interval above the groundwater table, including the capillary fringe (deep unsaturated soil).

• If possible, depending on the local groundwater depth, one intermediate sample of a 1 m interval shall be collected from each soil boring.

In addition, samples of every evidence of possible contamination shall be collected, provided that the probable evidence is in a layer thicker than 50 cm.

Soil sampling must be conducted immediately after core extrusion. Due to high volatility of some of the investigated compounds, the dedicated sample shall be collected from the inner part of the core and shall be immediately put inside a hermetic seal container (i.e., glass vials). No homogenization shall be made because it helps the compounds to vaporize.

For the other compounds, a homogenized sample from the relative interval shall be collected and put in a glass jar, separated in the field of particles larger than 2 cm by an adequate sieve.

Every samples shall be collected in split samples, one to be shipped to the lab while the other shall be stored and preserved at low temperature (~4°C) and kept available to the Authorities. A possible third split sample, if requested, can be collected in the presence of the Authorities. It must be sealed up, the Authorities must sign the seal, and a record of its collection must be filled in.

Additionally, specific samples for performing analysis required for risk assessment shall be collected:

• For pH and total organic carbon (TOC) analysis for the saturated zone, three additional homogenized samples shall be collected in the saturated zone and put in a glass jar, separated in the field of particles larger than 2 cm by an adequate sieve.

• For particle size analysis three samples from surface soil (0-1 m b.g.l.), three samples from deep unsaturated soil (1 m - groundwater table b.g.l.) and three samples from saturated soil shall be collected. Samples could be disturbed but must be unsorted (i.e., not sieved).

To prevent cross contamination, disposable gloves and clean equipment shall be used for sampling.

4.6 Groundwater sampling

Groundwater monitoring shall be performed on every installed monitoring well (5012_MW1 – MW8).

Prior to sampling the following activities will be performed:

• Groundwater level measurement using a water level meter.

• Checking the occurrence of non-aqueous phase liquids (LNAPL) using an interface probe.

• Well purging using a submersible pump, by pumping at least an amount of water equal to 3-5 volumes of water in the well.

• Measuring the groundwater physical-chemical parameters:

- temperature (°C).

- pH.

- conductivity (mS/cm).

- dissolved oxygen (mg/l).

- Oxidation Reduction Potential – ORP (mV).

At the end of purge activities, a dynamic sample can be collected using a submersible pump in low flow mode and pumping nearly 1 m above the bottom of the piezometer. The samples for volatile compounds shall be put in glass vials, because they are hermetic seal containers.

For every monitoring well two identical samples must be obtained, one to be shipped to the lab while the other shall be stored and preserved at low temperature (~4°C) and kept available to the HN authorities. A possible third identical sample, if requested, can be collected in the presence of the HN authorities. It must be sealed up, the HN authorities must sign the seal, and a record of its collection must be filled in.

In order to prevent cross-contamination:

• For the sampling activities, only HDPE or Rilsan® disposable sampling tubes could be used and shall be replaced after sampling each well.

• The submersible pump must be properly decontaminated after sampling each well by using an adequate cleaning detergent (e.g., alconox®) and rinsing with abundant clean water.

Due to the disturbance of the aquifer during the development phase of the monitoring wells installation, at least 24 hours should pass before proceeding with groundwater monitoring

The samples must be kept at low temperature (~4°C) and must be shipped to the lab daily while respecting the holding time for the analyses.

4.7 Soil gas monitoring

Pursuant to what indicated in the guideline SNPA no. 17/2018, in order to obtain data that are representative of the seasonal conditions, 4 quarterly campaigns for one year shall be conducted.

The interstitial gas sampling methods incorporate the indications provided by the SNPA Guideline no. 15/2018.

The sampling shall always be preceded by the measurement of the concentrations of VOCs and of O2, CO2 and

CH4, respectively using portable PID and Infrared instruments. The measurements shall be followed by purge of the soil gas probe, which shall be carried out for 3 minutes with a flow equal to 0.02 liter/min; subsequently, the concentrations will be measured again in order to verify their possible variation. Finally, a third measurement will be conducted at the end of the sampling, with the aim of comparing the initial and final concentrations of VOCs and gases.

To avoid the stripping of substances and/or the entry of ambient air, the sampling flow rate (Q) will be low, approximately between 0.02 liter/min and 2 l/min (ISO 18400-204, 2017).

The limits of quantification will be equal to the minimum value among those reported in Appendix 1 to the SNPA

Guideline no. 17/2018 for indoor inhalation for industrial / commercial receptors, for outdoor inhalation for industrial

/ commercial receptors and for outdoor inhalation for recreational receptors.

For the determination of naphthalene and hydrocarbon fractions C ≤ 12 (aliphatic and aromatic fraction), sampling will be carried out at each point using a XAD-2 vial and an activated carbon vial. The volume to be sampled and the sampling times will be assessed in the field on the basis of the PID measurements, in relation to the volumes and times shown in Table 1, Appendix A to the SNPA Guideline no. 15/2018.

4.8 Samples shipping and preservation

Every sample for chemical analysis shall be labeled and kept at low temperature (~4°C) in an isothermal container.

The labels shall contain at least the following information:

• sample name.

• site.

• kind of environmental matrix.

• Date.

• sampler name.

• project number/code.

Specifically, the samples shall be preserved and shipped to the lab daily with a Chain of Custody form filled in, which include the following information besides what will be written on the samples’ labels:

• sample type.

• analyses to be made.

The Chain of Custody will be countersigned by the lab when the samples will be checked-in.

The chosen chemical laboratory must be credited by ACCREDIA for all the below-mentioned analytes

4.9 Chemical analyses

4.9.1 Soil samples

In each soil sample collected from surface and subsurface unsaturated soil, the following compounds must be sought, as per D.Lgs 152/06:

• Light hydrocarbons (C≤12).

• Heavy hydrocarbons (C>12).

• Naphtalene.

For the purpose of risk assessment:

• pH and TOC must be analysed on all the unsaturated soil samples and also in three additional saturated soil samples, to be collected only for pH and TOC analyses.

• In case of detection of HC concentrations exceeding CSC, the samples with exceedances must be tested for the determination of MADEP fingerprinting.

The results of the analyses will be compared against the CSC values included in the D.Lgs. 152/06 Part IV, Title V, Annex 5, Table 1, Column B for industrial and commercial sites.

Furthermore, particle-size analyses will be performed on soil samples collected specifically for this purpose (see section 4.5)

4.9.2 Groundwater samples

In each collected groundwater sample, the following constituents must be sought, as per D.Lgs 152/06:

• Total Petroleum Hydrocarbons (TPH).

• Naphtalene.

For the purpose of risk assessment:

• In case of detection of TPH concentrations exceeding CSC, the samples with exceedances must be tested for the determination of MADEP fingerprinting.

The results of the analyses will be compared against the CSC values included in the D.Lgs. 152/06 Part IV, Title V, Annex 5, Table 2.

4.9.3 Soil gas samples

Soil gas samples analyses shall include the volatile constituents, as defined by Italian National Health Institute

(ISS), according to the criteria reported in the supporting document to the database of chemical-physical and toxicological properties, issued in March 2018 and as reported in Annex 1 to SNPA Guideline no. 15/2018, that based on results of conducted investigations, will potentially show exceedances of CSRs related to vapor inhalation pathways:

• Hydrocarbons fingerprinting:

- aliphatic C5-C8.

- aliphatic C9-C12.

- aromatic C9-C10.

- aromatic C11-C12.

• Naphtalene.

4.10 Hydraulic conductivity test

For the purpose of risk assessment, hydraulic conductivity must be determined for the phreatic aquifer. and at least three Lefranc type tests must be performed during drilling activities in the saturated soil. Constant or variable head

Lefranc tests will be carried out depending on the actual soil texture at each tested point (sandy or silty/clayey respectively).

Prior to testing, the groundwater depth shall be precisely measured. The testing shall be performed according to the procedures included in the Guidelines of the Italian Geotechnical Association. Specifically, the Lefranc test shall be performed using the scheme of the cylindrical filter. For this purpose, the pocket shall be obtained with a proper removal of all the material from the borehole and adding gravel to sustain the testing pocket walls.

For variable head mode, the test shall continue until the water table level is reached or is very close to be reached.

For constant head mode, the test shall continue until the flow of added water is eventually stabilized. In any case the test shall not last for more than two hours.

To avoid cross contamination, only clean water shall be used for the test.

5 Waste management

Waste produced by characterization activities shall be handled according to D.Lgs. 152/06 and all other applicable regulations. Waste shall be collected separately for each waste category with appropriate containers, such as big bags for solid waste and plastic tanks for water.

Waste shall be characterized through sampling and lab analyses in order to identify possible hazard characteristics and correct European Waste Code (EWC). Main categories of waste that can be produced during field activities include: soil, purged water from monitoring wells, asphalt, concrete debris and plastic core boxes.

The below-listed EWCs are expected to be produced during field activities:

• 15 01 02 (plastic packaging);

• 16 10 01 (aqueous liquid wastes containing hazardous substances);

• 16 10 02 (16 10 02 aqueous liquid wastes other than those mentioned in 16 10 01).

• 17 05 03 (soil and stones containing hazardous substances);

• 17 05 04 (soil and stones other than those mentioned in 17 05 03);

• 17 03 01 (bituminous mixtures containing coal tar);

• 17 03 02 (bituminous mixtures other than those mentioned in 17 03 01);

• 17 09 03 (other construction and demolition wastes (including mixed wastes) containing hazardous substances);

• 17 09 04 (mixed construction and demolition wastes other than those mentioned in 17 09 01, 17 09 02 and 17 09 03);

Following waste characterization and, on the basis of what indicated in the lab reports, waste shall be transported and disposed of pursuant to applicable regulations in authorized landfills and treatment plants.

6 Reference documents

Bldg. 5012, Report of Initial Contaminated Site Survey and Assessment - USAG Italy Darby Military Community.

AECOM, February 2021.

Figures

Figure 1 – Site location map

FS2 FS1

400 200m

SCALE_1:4.000

A3

N

Via Watt, 27

I-20143 Milano

Tel. +39.02.422556.1

Fax. +39.02.422556.21

DESCRIPTIONREV. DATE DES. CHK. APP.

ofSheetDRAW N°SCALEPLOTCODE JOB N°

REPRODUCTION OF THIS DOCUMENT IS FORBIDDEN WITHOUT PRIOR WRITTEN PERMISSION BY AECOM URS ITALIA

FIGURE 01 11-1:1606334520302W01

F.A.G.D.S.G.F.14/04/2021-0

SITE LOCATION MAPFIGURE 01:

USAG Italy DPW Environmental Division

USAG Italy DMC

Bldg. 5012, Characterization Plan

SCALE

1:50.000

SCALE

1:1.000

Bldg. 5012

Bldg. 5012

AST

AST

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SUPPLY AND

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CANAL

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KELLY STREET

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NAVIGATIONAL CANAL

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VIA AURELIA (SS1)

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AutoCAD SHX Text 250,000 lbs HC/D 1.1 (3,150 ft)

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WESTBROOK DRIVE

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KELLY STREET

Figure 2 – Location of proposed site investigations

TP2

TP3 TP4

TP6

TP5FS2 FS1

TP1

5012_SG1

5012_SG2

5012_SG3 5012_SG4

5012_MW1

5012_SG5

5012_SG6

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5012_MW3

5012_MW2

5012_MW6

5012_MW5

5012_MW8 5012_MW7

5012_MW4

5012_SB1

A2

30 15m

GRAPHICAL SCALE

N

SOIL GAS

LEGEND

MONITORING WELL

TRIAL PIT

EXCAVATION BOTTOM SAMPLE

EXCAVATION FOR HOTSPOT REMOVAL

EXCAVATION FOR REMOVAL OF PIPES

Via Watt, 27 I-20143 Milano

Tel. +39.02.422556.1 Fax. +39.02.422556.21

DESCRIPTIONREV. DATE DES. CHK. APP.

ofSheetDRAW N°SCALEPLOTCODE JOB N°

FIGURE 02 111:2501:1606334520302W01

F.A.G.D.S.G.F.14/04/2021-0

LOCATION OF PROPOSED SITE INVESTIGATIONSFIGURE 02:

USAG Italy DPW Environmental Division

USAG Italy DMC

Bldg. 5012, Characterization Plan

SOIL BORING

PROPOSED INVESTIGATIONS

PAST ACTIVITIES

Annexes

Annex 1 – Soil results of preliminary investigation

Bldg. 5012 Annex 1

Analytical Soil Results

Preliminary investigations

AECOM

Sample

TP1

(0-1)

TP1

(1-2)

TP1

(2-2.4)

TP2

(0-1)

TP2

(1-2)

Sampling Date 03/12/2020 03/12/2020 03/12/2020 03/12/2020 03/12/2020

Parameter Unit

Threshold values

D.Lgs. 152/06

Residuum at 105°C % - 90,40 86,00 88,70 90,40 89,20

Sieve fraction 2 cm - 2 mm % - 21,50 16,30 < 1 10,60 4,30

Aromatic Organic Compounds

Benzene mg/kg 2 < 0.01 < 0.01 0,14 < 0.01 < 0.01

Toluene mg/kg 50 < 0.05 < 0.05 3,30 < 0.05 < 0.05

Ethylbenzene mg/kg 50 < 0.05 0,07 2,90 < 0.05 < 0.05

Xylenes mg/kg 50 0,07 0,86 21,00 < 0.05 < 0.05

Styrene mg/kg 50 < 0.05 < 0.05 < 0.05 < 0.05 < 0.05

Aromatic Organic Compounds Summation (pursuant to D. Lgs. 152/06) mg/kg 100 0,07 0,93 27,00 < 0.05 < 0.05

Polycyclic Aromatic Hydrocarbons

Benzo(a)anthracene mg/kg 10 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01

Benzo(a)pyrene mg/kg 10 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01

Benzo(b)fluoranthene mg/kg 10 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01

Benzo(k)fluoranthene mg/kg 10 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01

Benzo(g,h,i)perylene mg/kg 10 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01

Chrysene mg/kg 50 < 0.01 0,02 0,09 < 0.01 < 0.01

Dibenzo(a,e)pyrene mg/kg 10 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01

Dibenzo(a,l)pyrene mg/kg 10 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01

Dibenzo(a,i)pyrene mg/kg 10 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01

Dibenzo(a,h)pyrene mg/kg 10 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01

Dibenzo(a,h)anthracene mg/kg 10 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01

Indeno(1,2,3-c,d)pyrene mg/kg 5 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01

Pyrene mg/kg 50 0,03 0,12 < 0.01 < 0.01 < 0.01

PAHs Summation (D.Lgs. 152/06 Ann.5 Tab.1) mg/kg 100 < 0.01 0,02 0,09 < 0.01 < 0.01

Total Hydrocarbons

Hydrocarbons C<=12 mg/kg 250 2,60 67,00 360,00 < 1.0 < 1.0

Hydrocarbons C>12 mg/kg 750 1.500,00 8.400,00 91.000,00 13,00 < 5.0

Annex 1

Analytical Soil Results

Preliminary investigations

AECOM

Sample

Sampling Date

Parameter Unit

Threshold values

D.Lgs. 152/06

Residuum at 105°C % -

Sieve fraction 2 cm - 2 mm % -

Aromatic Organic Compounds

Benzene mg/kg 2

Toluene mg/kg 50

Ethylbenzene mg/kg 50

Xylenes mg/kg 50

Styrene mg/kg 50

Aromatic Organic Compounds Summation (pursuant to D. Lgs. 152/06) mg/kg 100

Polycyclic Aromatic Hydrocarbons

Benzo(a)anthracene mg/kg 10

Benzo(a)pyrene mg/kg 10

Benzo(b)fluoranthene mg/kg 10

Benzo(k)fluoranthene mg/kg 10

Benzo(g,h,i)perylene mg/kg 10

Chrysene mg/kg 50

Dibenzo(a,e)pyrene mg/kg 10

Dibenzo(a,l)pyrene mg/kg 10

Dibenzo(a,i)pyrene mg/kg 10

Dibenzo(a,h)pyrene mg/kg 10

Dibenzo(a,h)anthracene mg/kg 10

Indeno(1,2,3-c,d)pyrene mg/kg 5

Pyrene mg/kg 50

PAHs Summation (D.Lgs. 152/06 Ann.5 Tab.1) mg/kg 100

Total Hydrocarbons

Hydrocarbons C<=12 mg/kg 250

Hydrocarbons C>12 mg/kg 750

TP2

(2-2.4)

TP3

(0-1)

TP3

(1-2)

TP3

(2-2.4)

TP4

(0-1)

03/12/2020 03/12/2020 03/12/2020 03/12/2020 03/12/2020

76,40 91,10 86,20 76,10 85,40

< 1 27,50 13,50 4,70 12,50

< 0.01 < 0.01 < 0.01 < 0.01 < 0.01

< 0.05 < 0.05 < 0.05 < 0.05 < 0.05

< 0.05 < 0.05 < 0.05 < 0.05 < 0.05

< 0.05 < 0.05 < 0.05 < 0.05 < 0.05

< 0.05 < 0.05 < 0.05 < 0.05 < 0.05

< 0.05 < 0.05 < 0.05 < 0.05 < 0.05

< 0.01 < 0.01 < 0.01 < 0.01 < 0.01

< 0.01 < 0.01 < 0.01 < 0.01 < 0.01

< 0.01 < 0.01 < 0.01 < 0.01 < 0.01

< 0.01 < 0.01 < 0.01 < 0.01 < 0.01

< 0.01 < 0.01 < 0.01 < 0.01 < 0.01

< 0.01 < 0.01 < 0.01 < 0.01 < 0.01

< 0.01 < 0.01 < 0.01 < 0.01 < 0.01

< 0.01 < 0.01 < 0.01 < 0.01 < 0.01

< 0.01 < 0.01 < 0.01 < 0.01 < 0.01

< 0.01 < 0.01 < 0.01 < 0.01 < 0.01

< 0.01 < 0.01 < 0.01 < 0.01 < 0.01

< 0.01 < 0.01 < 0.01 < 0.01 < 0.01

0,02 < 0.01 < 0.01 < 0.01 < 0.01

< 0.01 < 0.01 < 0.01 < 0.01 < 0.01

< 1.0 < 1.0 < 1.0 < 1.0 < 1.0

1.400,00 < 5.0 < 5.0 < 5.0 < 5.0

Annex 1

Analytical Soil Results

Preliminary investigations

AECOM

Sample

Sampling Date

Parameter Unit

Threshold values

D.Lgs. 152/06

Residuum at 105°C % -

Sieve fraction 2 cm - 2 mm % -

Aromatic Organic Compounds

Benzene mg/kg 2

Toluene mg/kg 50

Ethylbenzene mg/kg 50

Xylenes mg/kg 50

Styrene mg/kg 50

Aromatic Organic Compounds Summation (pursuant to D. Lgs. 152/06) mg/kg 100

Polycyclic Aromatic Hydrocarbons

Benzo(a)anthracene mg/kg 10

Benzo(a)pyrene mg/kg 10

Benzo(b)fluoranthene mg/kg 10

Benzo(k)fluoranthene mg/kg 10

Benzo(g,h,i)perylene mg/kg 10

Chrysene mg/kg 50

Dibenzo(a,e)pyrene mg/kg 10

Dibenzo(a,l)pyrene mg/kg 10

Dibenzo(a,i)pyrene mg/kg 10

Dibenzo(a,h)pyrene mg/kg 10

Dibenzo(a,h)anthracene mg/kg 10

Indeno(1,2,3-c,d)pyrene mg/kg 5

Pyrene mg/kg 50

PAHs Summation (D.Lgs. 152/06 Ann.5 Tab.1) mg/kg 100

Total Hydrocarbons

Hydrocarbons C<=12 mg/kg 250

Hydrocarbons C>12 mg/kg 750

TP4

(1-2)

TP4

(2-2.4)

TP5

(0-1)

TP5

(1-1,5)

TP6

(0-1)

03/12/2020 03/12/2020 18/01/2021 18/01/2021 19/01/2021

87,20 77,30 92,90 87,50 92,30

22,30 7,70 1,90 7,40 < 1

< 0.01 < 0.01 < 0.01 < 0.01 < 0.01

< 0.05 < 0.05 < 0.05 < 0.05 < 0.05

< 0.05 < 0.05 < 0.05 < 0.05 < 0.05

< 0.05 < 0.05 < 0.05 0,52 < 0.05

< 0.05 < 0.05 < 0.05 < 0.05 < 0.05

< 0.05 < 0.05 < 0.05 0,52 < 0.05

< 0.01 < 0.01 < 0.01 < 0.01 < 0.01

< 0.01 < 0.01 < 0.01 < 0.01 < 0.01

< 0.01 < 0.01 < 0.01 < 0.01 < 0.01

< 0.01 < 0.01 < 0.01 < 0.01 < 0.01

< 0.01 < 0.01 < 0.01 < 0.01 < 0.01

< 0.01 < 0.01 < 0.01 < 0.01 < 0.01

< 0.01 < 0.01 < 0.01 < 0.01 < 0.01

< 0.01 < 0.01 < 0.01 < 0.01 < 0.01

< 0.01 < 0.01 < 0.01 < 0.01 < 0.01

< 0.01 < 0.01 < 0.01 < 0.01 < 0.01

< 0.01 < 0.01 < 0.01 < 0.01 < 0.01

< 0.01 < 0.01 < 0.01 < 0.01 < 0.01

< 0.01 < 0.01 < 0.01 0,08 < 0.01

< 0.01 < 0.01 < 0.01 < 0.01 < 0.01

< 1.0 < 1.0 < 1.0 43,00 < 1.0

< 5.0 < 5.0 < 5.0 2.200,00 120,00

Annex 1

Analytical Soil Results

Preliminary investigations

AECOM

Sample

Sampling Date

Parameter Unit

Threshold values

D.Lgs. 152/06

Residuum at 105°C % -

Sieve fraction 2 cm - 2 mm % -

Aromatic Organic Compounds

Benzene mg/kg 2

Toluene mg/kg 50

Ethylbenzene mg/kg 50

Xylenes mg/kg 50

Styrene mg/kg 50

Aromatic Organic Compounds Summation (pursuant to D. Lgs.