B08_140L6322Q0031_-_Attachment_03_-_Black_Rapids_Airstrip_Characterization_Work_Plan.pdf

TECHNICAL MEMORANDUM

Technical Memorandum 1 Black Rapids Airstrip Characterization and Removal Action Work Plan

Black Rapids Airstrip Characterization and Removal Action Work Plan

Date: 23 April 2020 Contract: W911KB-19-C-0016 Project: Bureau of Land Management Mining Claims Inventory: Black Rapids Removal Action To: Mike McCrum, Bureau of Land Management Copy to: David Jadhon, U.S. Army Corps of Engineers From: Brice Engineering, LLC Revision: Pre-Draft Attachments: Figures

Site Inventory (as provided by the BLM)

This Technical Memorandum (Tech Memo) describes the project approach and methods that will be used while conducting a removal action at the Black Rapids airstrip. Brice Engineering, LLC (Brice) will perform the work described herein for the U.S. Army Corps of Engineers (USACE) and Bureau of Land Management (BLM) under Contract W911KB-19-C-0016.

This Tech Memo was prepared in accordance with 18 Alaska Administrative Code (AAC) 75, Oil and Other Hazardous Substances Pollution Control Regulations (Alaska Department of Environmental Conservation [ADEC] 2018) and ADEC’s Field Sampling Guidance (ADEC 2017). The Tech Memo also references pieces of the Final BLM Mining Claims Survey and Investigation Work Plan (Brice 2019) (main work plan).

The objective of this project is to consolidate and remove abandoned equipment and material from a site near the Black Rapids Glacier. An existing onsite garage structure will be demolished and the debris will be disposed. Two potential contaminant releases were identified in 2017, associated with aboveground fuel tank flow lines and a sump in the garage floor. These potential releases will be characterized, and contaminated soil or other media will be removed and disposed properly.

1.0 PROJECT DELIVERY TEAM

Table 1-1 presents the project delivery team and their roles and responsibilities.

Table 1-1 Project Delivery Team

ORGANIZATION POC/TITLE RESPONSIBILITIES PHONE/EMAIL

BLM Mike McCrum/

BLM PM

Responsible for technical, quality assurance, and decision-making matters concerning project execution (verbal, written, or electronic).

(907) 271-4426 mmccrum@blm.gov

Technical Memorandum 2

Table 1-1 Project Delivery Team

ORGANIZATION POC/TITLE RESPONSIBILITIES PHONE/EMAIL

USACE David Jadhon

USACE PM

Maintains oversight for the overall project. Responsible for technical, quality assurance, and decision-making matters concerning project execution. Evaluates field changes and determines recommended solutions. Coordinates communication with regulators and stakeholders.

(907) 753-2595 David.A.Jadhon@usace.army.mil

USACE Timothy Clapp USACE Contracting Officer

Manages contracting issues requiring coordination between the USACE PM and Prime Contractor.

(907) 753-2836 Timothy.L.Clapp@usace.army.mil

USACE Will Mangano USACE Project Engineer

Ensures technical aspects of the project are carried out as intended and as presented in the approved Work Plan.

(907) 753-5689 William.F.Mangano@usace.army.mil

Brice Bryan Lund Brice PM

Provides direction to the Brice project team to ensure project objectives are achieved, the project budget is tracked, and the project is on schedule.

(907) 561-6440 blund@briceenvironmental.com

Kirk Fisher Brice CSO Coordinates corporate policy with project SSHO, complies with requirements and oversees implementation of the SSHP, conducts periodic audits in coordination with the PM, and participates in incident investigations, corrective action reporting, and other pertinent reporting as required.

(907) 561-6439 kfisher@briceenvironmental.com

Pace Analytical Jared Starkey Identifies data quality issues and provides solutions for the Brice project team to resolve the issues.

(615) 773-9698 jstarkey@pacenational.com

Brice Sara Hadden Technical Lead

Responsible for overseeing production of planning and reporting documents.

(907) 277-2738 shadden@briceenvironmental.com

Brice Robert Melrose Site Supervisor

Responsible for directing removal and sampling activities.

(907) 277-7295 rmelrose@briceenvironmental.com

Brice Erik Dahl Env. Engineer/SSHO

Responsible for removal/sampling activities and site safety.

(907) 275-2911 edahl@briceeng.com

Brice Zachary Rasmussen Env. Scientist

Responsible for sampling and surveying.

(907) 277-2734 zrasmussen@briceenvironmental.com

Brice Heavy equipment operators Operate heavy equipment during removal activities.

To be determined

Notes:

BLM = Bureau of Land Management Brice = Brice Engineering, LLC CSO = Corporate Safety Officer

Env. = Environmental PM = Project Manager SSHO = Site Safety and Health Officer

SSHP = Site Safety and Health Plan USACE = U.S. Army Corps of Engineers

Technical Memorandum 3

2.0 PHYSICAL SETTING AND SITE CONDITIONS

This site is immediately east of the Richardson Highway around Mile 227.5, 38 miles south of Delta Junction, Alaska (Figures 1 and 2, Attachment 1). The Delta River floodplain lies immediately west of the Richardson Highway at this milepost with the main channel of the river approximately 1,300 feet west of the site. The site is vegetated with alder, willow, and cottonwood. The Black Rapids airstrip (5BK) is adjacent to the site and open to general aviation, though the condition of the runway was observed to be fairly overgrown during a recent flight over the site during the 2019 field season. Information about the airstrip is available online at https://airnav.com/airport/5BK.

2.1 Structures and Debris

A 30-foot by 75-foot garage structure, 16 feet tall, sits on a concrete pad on the site (Figure 2, Attachment 1). The garage is steel framed with limited wood framing. It is sheathed in painted plywood and roofed with corrugated steel sheets. Spray-on insulation, rigid foam insulation, and some fiberglass batting are also used. Original fixtures include two 7- to 10-kilowatt generators, 15 fluorescent light fixtures with ballasts and bulbs, a 1,000-gallon aboveground storage tank (AST), a 500-gallon AST, and piping associated with both the tanks and hot-water radiant heating system. Concrete piers or pedestals exist in the vicinity of both tanks. In recent years, this structure has been used for storage and contains a number of appliances and pieces of equipment. Miscellaneous supplies associated with welding and building maintenance are also stored in the structure. A list of items and materials observed onsite is included as Attachment 2.

2.2 Suspected Hazardous Materials and Potential Releases

In 2017, Northwind conducted a limited site investigation of the site and the resulting inventory was provided to Brice (Attachment 2). Based on the features existing onsite, suspected hazardous materials include heating oil, diesel fuel, antifreeze, engine oil, and possibly gasoline. The 2017 site investigation noted petroleum odor in the soil beneath the pipe connection at the 1,000-gallon AST, in soil outside the southeast corner of building where the supply lines for the generators emerge from the ground, and in the sump in the garage floor. The design of the sump is unknown. In 2017, a 4-inch-thick mat beneath the steel grate covering the sump was found to have a 2-foot-deep void beneath it. When the mat was punctured, a strong petroleum odor was observed, apparently coming from the void.

Additionally, the following observations were made during the 2017 limited site investigation:

• The two generators appeared to contain engine oil and antifreeze. Two batteries are connected to the generators.

• The 500-gallon AST appeared to contain several inches of liquid with a diesel odor.

• Dry wall and paint used in the building were tested for asbestos and lead. No asbestos or lead was detected.

• The 15 fluorescent light fixtures with ballasts and bulbs may contain polychlorinated biphenyls

(PCBs). If no label can be found stating that PCBs are not present, these will be considered hazardous and disposed of as PCB Bulk Product waste.

https://airnav.com/airport/5BK

Technical Memorandum 4

3.0 FIELD ACTIVITIES

The following sections describe all activities that will occur during execution of this removal action.

3.1 Permitting and Mobilization

All necessary permits will be obtained by Brice prior to mobilization. Brice staff will mobilize from Anchorage to the Black Rapids site via road. The Brice field crew will consist of a site supervisor, environmental engineer, environmental scientist, and heavy equipment operators. Prior to the arrival of Brice staff members, heavy equipment necessary to perform the task will be staged at the site location by the rental vendor. Equipment will include, but is not limited to, a 300-class excavator (or larger) with demolition and cleanout buckets and a hydraulic breaker implement for concrete; a wheeled loader and all-terrain forklift to be used to load dumpsters; a small 75-class excavator to complete smaller remedial soil excavations; and 30-cubic-yard (cy) roll-off dumpsters for hauling building debris and concrete.

Mobilization is anticipated to take 1 day. Personnel will lodge in Delta Junction for the duration of field activities.

3.2 Site Inventory

Upon arrival at the site, Brice staff will inventory, photograph, survey, and document the nature and locations of all debris to be removed from the site. Building corners will be surveyed to represent the location of all items contained within the garage. Any items outside the garage designated for removal will be surveyed individually. All surveying activities will be carried out with survey-grade Global Navigation Satellite System (GNSS) equipment and the appropriate procedures for its use as described in Appendix C (Survey Plan) of the main work plan (Brice 2019).

3.3 Removal Activities

Removal and site characterization activities are anticipated to take 4 days and are described in further detail below. For details about waste management and waste characterization sampling referenced in these sections, please see Section 3.5.

3.3.1 Segregation and Containerization of Hazardous Materials

The metal grate covering the sump in the garage floor will be removed, and the nature of the materials at the bottom will be assessed with hand tools. Throughout the assessment, air monitoring will be conducted with a four-gas meter. If air monitoring during the assessment indicates that an unsafe atmosphere may exist, ambient air will be introduced into the sump using an air compressor. Personnel will not enter the sump. If the sump is open to the ground at the bottom and there is not a layer of petroleum, oil, and lubricant (POL) material above the soil, demolition of the building will proceed; and any contaminated soil will be excavated after the foundation is removed. If a POL layer is present above the soil, it will be sampled for waste characterization, then removed with hand tools until soil is uncovered. If the sump is found to have a concrete base, the contents of the sump will be sampled for waste characterization, then removed with hand tools (if solid) or a hand pump (if liquid). Any material removed prior to excavation will be placed in a U.S. Department of Transportation (DOT)-approved container and staged for transport while awaiting analytical results.

All remaining light bulbs and ballasts will be removed from the garage and containerized for disposal.

Technical Memorandum 5

At no time during the decommissioning of the tanks will personnel put any part of their body inside the tanks, including hands and arms. The interiors of tanks are considered confined spaces, and no entry will be permitted. Breaking the plane of the interior space qualifies as entry.

Prior to beginning decommissioning of the tanks, the interior of the tanks will be purged with compressed air for 5 minutes. While working around the tanks during the purging process, breathing zone air will be monitored continuously for percent (%) of the Lower Explosive Limit (LEL) and % oxygen with a four-gas meter, and for benzene with a photoionization detector (PID) fitted with a separator tube for benzene.

Once the tank has been purged for 5 minutes, the interior atmosphere will be tested with a four-gas meter to confirm that the atmosphere inside does not pose a risk of ignition before proceeding with fluid pumping and decommissioning. Procedures and criteria for air monitoring in the breathing zone and assessing the interior atmosphere of an enclosed space are described in Section 4.1, including actions required in the event that air monitoring in the breathing zone indicates that a hazardous atmosphere may exist. If air monitoring indicates that an unsafe atmosphere exists inside the tank, ambient air will continue to be introduced into the tank using an air compressor.

When the atmosphere in the tank has been rendered inert, both ASTs will be pumped with either an electric pump or a hand-operated bailer pump to remove any residual liquid contents, which will be placed in DOT-approved 55-gallon steel drums. Radiators and other mechanical equipment will be drained of any fluids, to the extent possible, before being removed. During emptying of the tanks and fluid reservoirs, plastic sheeting will be laid under the tank or generator and the container receiving the pumped fluids.

Sorbents will be readily available throughout the process to absorb any liquids that drip and to wipe off equipment that comes into contact with the fluids. Orifices that are known or suspected to be connected to fluid reservoirs will be blocked with the original plugs or with sorbent material to prevent leakage of fluids during removal of the equipment. Sorbent material will be removed before the equipment is transported offsite and will be disposed of with the investigation-derived waste (IDW). The used plastic sheeting will also be included with the IDW. The fluids will be segregated by type, sampled for characterization, and staged for disposal. Waste characterization analyses and analytical methods are presented in Section 3.5.

3.3.2 Building Demolition

After all potentially hazardous materials and non-structural equipment and materials have been removed from the garage, building demolition will proceed with the external sheeting and structural support being removed and loaded directly into open-top dumpsters. Due to the use of spray foam insulation, all metal exterior sheeting will be disposed of as general construction debris and not recycled. After the walls of the building have been cleared, demolition of the concrete foundation will be conducted using the excavator’s breaker implement, demolition bucket, and/or finish bucket as needed. Special care will be taken to not overload the 30-cy dumpsters to allow for safe and reliable loading onto roll-off trucks.

Based on an informal site visit conducted by Brice in 2019 and information provided by the BLM, an estimated maximum of 197 tons of concrete debris and 50 tons of general debris will be generated.

3.4 Site Characterization and Soil Removal Activities

Two previously identified suspected contaminant releases in the vicinity of the garage structure were associated with AST pipe connections and flow lines, and with the sump in the garage floor. As site progress and work flow allow, an estimated combined volume of 10 cy of contaminated soil will be removed from these areas. Excavation boundaries will be screened with a PID as described in 18 AAC 75 (ADEC 2018), ADEC’s Field Sampling Guidance (ADEC 2017), and Section 2.1 of the Sampling and Analysis

Technical Memorandum 6

Plan (SAP) included in the main work plan (Brice 2019). One sample will be collected from each of the two excavation areas associated with AST piping and analyzed for gasoline-range organics (GRO), diesel-range organics (DRO)/residual-range organics (RRO), volatile organic compounds (VOCs), semi-volatile organic compounds (SVOCs), and Resource Conservation and Recovery Act (RCRA) metals; and one sample will be collected from the area associated with the sump and analyzed for GRO, DRO/RRO, VOCs, SVOCs, RCRA metals, and PCBs. All sampling and subsequent analysis will be conducted in accordance with the SAP (Brice 2019) and the tables in this Tech Memo. Table 3-1 summarizes analytical methods, sample containers, and holding times.

Table 3-1 Soil Sample Analytical Methods, Containers, and Holding Times

PARAMETER ANALYTICAL

METHOD CONTAINER PRESERVATION HOLDING TIME

GRO AK101 (1) 4-oz pre-tared amber glass jar, TLS Methanol, 0-6°C 28 days

VOCs SW8260D (1) 4-oz pre-tared amber glass jar, TLS Methanol, 0-6°C 14 days

SVOCs SW8270D (1) 4-oz amber glass jar, TLC Unpreserved, 0-6°C 14 days

DRO/RRO AK102/AK103 (1) 4-oz amber glass jar, TLC Unpreserved, 0-6°C 14 days

RCRA Metals SW6020/7471B (1) 4-oz amber glass jar, TLC Unpreserved, 0-6°C 180 days/28 days

PCBs 8082A (1) 4-oz amber glass jar, TLC Unpreserved None for extractions, 40 days to analysis

Notes:

°C = degrees Celsius DRO = diesel-range organics GRO = gasoline-range organics oz = ounces PCB = polychlorinated biphenyl RCRA = Resource Conservation and Recovery Act

RRO = residual-range organics SVOC = semi-volatile organic compound TLC = Teflon-lined cap TLS = Teflon-lined septum VOC = volatile organic compound

Once the final excavation limits have been reached, the sample locations and excavation outlines will be surveyed, and the depth of the excavation will be documented with field sketches and photos. All removed soil will be placed in 1-cy supersacks, sampled for waste characterization, and staged to await analytical results.

3.5 Waste Management and Disposal

All waste handling, transportation, and disposal will be conducted in accordance with regulations put forth by the State of Alaska, the U.S. Environmental Protection Agency, and the DOT. Waste disposal will be performed in coordination with the BLM.

Building debris, concrete, metal mechanical equipment, decommissioned ASTs, and any other inert site debris listed in the statement of work (Attachment 2) and found to be present onsite will be transported in the roll-off dumpsters to the Delta Junction Solid Waste Facility, 44 miles north of the Black Rapids site.

Once waste characterization sample results have been received, containerized sump contents, drained fluids, and excavated soil will be transported to NRC in Fairbanks for proper disposal. Light fixture ballasts and bulbs will be packaged properly and taken to NRC.

Technical Memorandum 7

Table 3-2 summarizes the anticipated waste streams, estimated quantities, waste characterization analyses, and disposal locations for each. Delta Trucking will transport waste from the site to the final disposal facility. Table 3-3 summarizes media, analytical methods, sample containers, and holding times for waste characterization samples. For sampling procedures to be used for waste characterization sampling, see Section 2.2 of the SAP, Appendix B of the main work plan (Brice 2019).

Table 3-2 Waste Management Summary

MATERIAL TRANSPORT

DOCUMENT

WASTE

DESIGNATION

WASTE

CHARACTERIZATION

ANTICIPATED

VOLUME DISPOSAL FACILITY

Petroleum- Contaminated Soils and/or Sludge

ADEC Permit to Transport Non-Hazardous Waste Manifest

Non-Hazardous Waste, Solid

1 sample to be analyzed for GRO, DRO/RRO, VOCs, SVOCs, and RCRA metals

9 cy NRC, North Pole, Alaska

General Construction Debris and

IDW

Bill of Lading Non-Hazardous Waste, Solid None 50 tons Delta Landfill, Delta

Junction, Alaska

Concrete Debris Bill of Lading Non-Hazardous

Waste, Solid None 197 tons Delta Landfill, Delta Junction, Alaska

Petroleum- Contaminated Liquids (drained from equipment or tanks)

ADEC Permit to Transport Non-Hazardous Waste Manifest

Non-Hazardous Waste, Liquid

1 sample to be analyzed for GRO, DRO/RRO, VOCs, SVOCs, and RCRA metals

Up to 200 gallons

NRC, North Pole, Alaska

Antifreeze (drained from equipment)

Non-Hazardous Waste Manifest

Non-Hazardous Waste, Liquid (ethylene glycol)

None Up to 200 gallons

NRC, North Pole, Alaska

Fluorescent light fixtures (assumed to contain PCBs)

Hazardous Waste Manifest

PCB Bulk Product Waste None 1 cy NRC, North Pole, Alaska

Fluorescent light bulbs

Non-Hazardous Waste Manifest

Universal Waste

– Waste Lamps None 1 cy NRC, North Pole, Alaska

Batteries Non-Hazardous Waste Manifest

Universal Waste

– Batteries None 1 cy NRC, North Pole, Alaska

Notes:

ADEC = Alaska Department of Environmental Conservation cy = cubic yards

IDW = investigation-derived waste PCB = polychlorinated biphenyls

Technical Memorandum 8

Table 3-3 Waste Characterization Sample Media, Analytical Methods, Containers, and Holding Times

PARAMETER MEDIA ANALYTICAL

METHOD CONTAINER PRESERVATION HOLDING TIME

GRO Soil/Solid AK101 (1) 4-oz pre-tared amber glass jar, TLS Methanol, 0-6°C 28 days

DRO/RRO Soil/Solid AK102/AK103 (1) 4-oz amber glass jar, TLC Unpreserved, 0-6°C 14 days to extraction, 40 days to analysis

TCLP VOC Soil/Solid SW1311/SW8260C

(1) 8-oz pre-tared amber glass jar, TLS (minimum headspace)

Unpreserved, 0-6°C 14 days to TCLP extraction, 14 days to analysis

TCLP SVOC Soil/Solid SW1311/SW8270D (1) 8-oz amber glass jar, TLC Unpreserved, 0-6°C

14 days to TCLP extraction, 7 days for leachate prep, 40 days to analysis

PCB Soil/Solid 8082A (1) 4-oz amber glass jar, TLC Unpreserved None for extraction, 40 days to analysis

RCRA

Metals Soil/Solid SW6020/7471B (1) 4-oz amber glass jar, TLC Unpreserved, 0-6°C 180 days/28 days

GRO Liquid AK101 (3) 40-mL VOA, TLS HCl, 0-6°C 14 days

DRO/RRO Liquid AK102/AK103 (2) 1-L amber glass jar, TLC HCl, 0-6°C 14 days to extraction, 40 days to analysis

VOC Liquid SW8260D (3) 40-mL VOA, TLS HCl, 0-6°C 14 days

SVOC Liquid SW8270D (2) 1-L amber glass jar, TLC

Unpreserved, 0-6°C

7 days to extraction, 40 days to analysis

RCRA

Metals Soil/Solid SW6020/7471B (1) 4-oz amber glass jar, TLC Unpreserved, 0-6°C 180 days/28 days

Notes:

°C = degrees Celsius DRO = diesel-range organics GRO = gasoline-range organics HCl = hydrochloric acid L = liters mL = milliliters oz = ounces PCB = polychlorinated biphenyl

RCRA = Resource Conservation and Recovery Act RRO = residual-range organics SVOC = semi-volatile organic compound TCLP = toxicity characteristic leaching procedure TLC = Teflon-lined cap TLS = Teflon-lined septum VOA = volatile organic analysis VOC = volatile organic compound

3.6 Site Restoration

After all demolition and soil removal activities are complete, the site will be regraded to minimize the potential for pooling of water and to flatten any mounds created by heavy equipment operation. Clean fill will be brought to the site to fill areas where the depth of excavation exceeds 2 feet. Woody vegetation displaced in the course of the removal action will be cut into manageable sizes and left onsite; small slash (small brush and woody material that has been cut in the process of clearing) will be spread on the graded and filled former building site, and larger pieces will be placed just inside the edge of the nearest wooded area without blocking any road or access trail.

Technical Memorandum 9

3.7 Demobilization

All heavy equipment will be dry-decontaminated and staged onsite for pickup by the vendor. All waste will be removed and disposed properly before the field team leaves the site for the final time. The team will return to Anchorage by road.

4.0 HEALTH AND SAFETY

Appendix A of the main work plan (Brice 2019), including an Accident Prevention Plan (APP), Site Safety and Health Plan (SSHP), and accompanying documents serves as the basis for safety and health procedures to be followed during the 2019 and 2020 field activities. These plans describe the safety measures to be employed during site inventory activities through preliminary hazard evaluations. The APP/SSHP comply with 29 Code of Federal Regulations 1910.120 and 1926.65; Office of the Federal Register (OFR) Hazardous Waste Operations and Emergency Response (OFR 2005); and the USACE Safety and Health Requirements Manual EM 385-1-1 (USACE 2014). Figure 3 (Attachment 1) provides the route to the nearest medical facility for this work.

The scope of the work to be performed under the main work plan (Brice 2019) does not include air monitoring in the breathing zone, assessment of atmospheres inside enclosed spaces, or demolition;

therefore, the following sections dealing specifically with atmosphere assessment with a four-gas meter and PID with benzene separator tubes, demolition activities, and heavy equipment operations supplement the project APP/SSHP.

4.1 Air Monitoring in the Breathing Zone and Assessment of Interior Atmospheres

The following sections outline the equipment, materials, procedures, and criteria to be used to assess the breathing zone for % LEL, % oxygen, hydrogen sulfide (H2S), and benzene, and interior atmospheres of enclosed spaces for % LEL and % oxygen, two key indicators of atmosphere ignitability. A four-gas meter will be used to measure % LEL and % oxygen, and a PID will be used to measure benzene concentrations.

The following equipment and materials will be required:

• Two four-gas meters with the ability to measure % LEL, % oxygen, and H2S, at a minimum

• The complete user’s manual for the selected model of four-gas meter

• A PID fitted with the capability to install separator tubes that allow for direct measurement of benzene

• Separator tubes for benzene that are compatible with the selected PID

• The complete user’s manual for the selected model of PID

• Single gas span calibration gas for each of the sensor functions that will be required in the field appropriate to the selected four-gas meter, or pre-mixed four-gas span calibration gas

• Benzene span calibration gas

• If clean ambient air with 20.9% oxygen will not be available at the work site, zero calibration gas for each of the compounds that will be measured in the field appropriate to the selected four-gas meter and PID

• Regulators that fit the calibration gas cylinders

• Moisture filters that fit the selected four-gas meter and PID

Technical Memorandum 10

• 10 feet of flexible tygon tubing and the compatible connection to the four-gas meter to allow for assessment of atmospheres in interior spaces that cannot be entered (Note: The ability to extend the tubing up without any body part breaking the plane of the interior space may be needed if there is no access to the top of the space to be assessed.)

• A logbook or field form for documenting stabilized readings from the four-gas meter during calibration, bump-testing, atmosphere assessments, and air monitoring

4.1.1 Calibration

The four-gas meters and PID should be inspected by a qualified technician prior to use. Any routine or required maintenance shall be performed by a qualified technician before using the instrument in the field. The user manuals for both instruments will be present during field activities and will be in the custody of the SSHO. The SSHO will be responsible for performing or delegating the task of calibration and bump-testing in the field.

Each day of use, and at shorter intervals if deemed necessary by the SSHO, the four-gas meters and PID should be span-calibrated and bump-tested for each parameter that will be measured during the day. The user manual will be made available to the individual performing this task. The results of the calibration and bump test must be within the tolerance specified by the manufacturer for correct functioning of the meter, confirmed by achieving a “PASS” notification during the test. All calibration and bump test results shall be recorded in the field logbook or on an appropriate field form.

4.1.2 Air Monitoring in the Breathing Zone

The SSHO shall be responsible for monitoring wind direction throughout the duration of work activities for which air monitoring is required. The SSHO shall designate and communicate to the field team the locations of designated evacuation areas that are at least 50 feet from the work area, upwind, and as uphill from the work area as possible. A minimum of two areas shall be identified that correspond to the two most probable upwind directions based on historical wind-direction data. In the event of the atmosphere becoming unsafe, the field team will immediately cease work and evacuate to the most upwind of the designated evacuation areas under the direction of the SSHO.

Air monitoring in the breathing zone shall be performed continuously during all work activities related to decommissioning of the two ASTs and during initial assessment of the sump. The personnel working nearest to the tank or sump should be wearing a properly maintained and calibrated four-gas meter and PID affixed in their breathing zone. An individual shall be dedicated to the sole task of continuously monitoring the measurements on both instruments and verbally notifying the worker and the field team if any single parameter is not within the thresholds listed in Table 4-1. Concentrations and the time of the measurement shall be recorded in the field logbook or on an appropriate field form every 2 minutes and each time a new peak reading is observed. In the event that a parameter is measured outside the thresholds listed in Table 4-1, the team will immediately evacuate the work area to one of the designated evacuation areas. The SSHO will direct the team to the most upwind area. Air monitoring shall continue throughout the evacuation, and if the criteria below are not met, the team will continue to move away in an upwind direction until readings indicate a safe atmosphere.

Technical Memorandum 11

Table 4-1 Criteria for Establishing a Safe Atmosphere in the Breathing Zone

PARAMETER READING

% LEL Less than 10%

% Oxygen Between 19.5% and 23%

H2S Less than 10 ppm

Benzene Less than 0.5 ppm Note:

This table is applicable to locations where diesel or heating fuel is the primary constituent of concern.

% = percent H2S = hydrogen sulfide LEL = Lower Explosive Limit ppm = parts per million

After a period of time deemed sufficient by the SSHO, re-entry of the workspace will be attempted.

An individual wearing the four-gas meter and PID with benzene separator tube will begin to approach the workspace in increments of 10 feet with a minimum of a 30-second pause for observing the four-gas meter and PID readings. If the readings violate the criteria for a safe atmosphere as listed in Table 4-1, all personnel must return to the upwind location selected by the SSHO, and repeat the re-entry procedure until the work area can be reoccupied with all parameters measured at safe levels.

4.1.3 Assessment of Interior Atmospheres

The interiors of enclosed spaces that are known or suspected to have contained petroleum products will be assessed with a four-gas meter to ensure that the interior atmosphere is not ignitable, nor in danger of becoming so. A non-hazardous, non-ignitable atmosphere shall meet the criteria listed in Table 4-2, below, as measured with a properly maintained and calibrated four-gas meter.

Table 4-2 Criteria for Establishing a Non-Hazardous, Non-Ignitable Atmosphere

PARAMETER READING

% LEL Less than 10%

% Oxygen Less than 21%

Notes:

This table is applicable to locations where diesel or heating fuel is the primary constituent of concern.

% = percent LEL = Lower Explosive Limit

Technical Memorandum 12

The interior space shall be tested as follows:

1. The tygon tubing will be extended into the tank or sump until the intake point is positioned in the bottom of the air space. The intake point shall be held in this position until readings on the four-gas meter stabilize, and for a minimum of 30 seconds. Percent oxygen and % LEL readings shall be recorded in the logbook or field form.

2. The intake point shall be moved to a position in the middle of the air space. It shall be held in this position until readings on the four-gas meter stabilize, and for a minimum of 30 seconds.

Percent oxygen and % LEL readings shall be recorded in the logbook or field form.

3. The intake point shall be moved to a position in the top of the air space. It shall be held in this position until readings on the four-gas meter stabilize, and for a minimum of 30 seconds.

Percent oxygen and % LEL readings shall be recorded in the logbook or field form.

If all readings meet the criteria for a non-ignitable atmosphere as listed in Table 4-2, decommissioning activities may proceed.

4.2 Demolition Activities

No personnel shall be permitted in any area being affected by demolition. Only those personnel necessary for specific tasks shall be permitted in the demolition zone. The area affected by demolition and the demolition zone shall be defined by the site supervisor in consultation with the equipment operator and communicated to all site personnel on the day the demolition is to occur. If necessary, cones, caution tape, or snow fencing will be placed to create a visible boundary.

Demolition shall proceed in the manner described in Section 3.3.2 of this Tech Memo, unless the site supervisor determines that an alternative procedure improves the safety and efficiency of the demolition.

Deviations from this plan will be fully communicated to all site personnel involved in demolition activities before the deviations are enacted.

Personal protective equipment (PPE) for various activities shall be donned in accordance with the APP/SSHP of the main work plan (Brice 2019). For demolition activities, face shields and goggles MUST be worn when working in the vicinity of flying debris from tasks such as grinding, chipping, hammering, scraping, sawing, drilling, chiseling, riveting, or sanding. The site supervisor and SSHO are responsible for communicating to site personnel when levels of required PPE are elevated beyond Level D.

All site personnel have “Stop Work” authority. If unsafe conditions causing an imminent threat to life or limb are observed, the site supervisor and the equipment operator will be signaled to stop. Appropriate signals for stopping work will be communicated with all site personnel in each morning meeting on days when heavy equipment operation is scheduled to occur.

4.3 Heavy Equipment Operation

Heavy equipment will be selected based on operating capacity, suitability to the task to be performed, and availability. Equipment for this removal action is planned to include, but is not limited to:

• A 300-class excavator (or larger) with demolition and cleanout buckets and a hydraulic breaker implement

• A wheeled loader

• An all-terrain forklift

• A small 75-class excavator

Technical Memorandum 13

Hazards associated with heavy equipment include roll-overs, collisions, crushing, pinch points, and fire.

Each piece of equipment will be inspected for suitability of use and physical condition prior to work. Skill levels of equipment operators will be monitored by the site supervisor during activities. Any operator found unqualified for a piece of equipment will not be allowed to operate that equipment until appropriate training has been completed by said operator(s). The following safe work practices should be followed when operating or working around heavy equipment:

• All personnel operating or interacting with motorized equipment will be briefed on basic hand signals used to communicate visually with equipment operators. This briefing must, at a minimum, include the signal that indicates “Stop Work.”

• Operators must inspect their equipment prior to the start of each shift and document any deficiencies found. This inspection should include brakes, tires, horn, back-up alarm, steering, operating controls, seat belts, and coupling devices.

• Each piece of equipment will have a minimum 5-pound A-B-C portable fire extinguisher in the cab and in reach of the operator. All site personnel will be familiarized with the location of fire extinguishers in equipment.

• Hardhats are to be worn while operating the equipment if it is not equipped with a rollover protective structure.

• Functional backup alarms are required on all equipment (unless a spotter is used).

• Digging implements will be in the lowered position when equipment is not in actual use, and the parking brake will be set whenever parked. If parked on an incline, wheels must be chocked.

• When equipment is left unattended, power must be shut off, brakes set, digging implements set on ground, and transmission put in park.

• Due to the elevated risk of wildfires during recent summers, particular attention will be paid to the proximity of hot engines and vehicle exhaust to ignitable materials like vegetation or structural timber. Vegetation will be cleared from areas where equipment will be running in a single location for extended periods of time. Structural timber will be not be stockpiled in a location that may cause a fire hazard.

Discussion of hazards associated with daily activities will be discussed during the morning safety meetings.

Some general safe practices are listed below.

• Ground personnel must remain alert at all times.

• High-visibility apparel will be worn at all times by ground personnel.

• Equipment and vehicle operators should be encouraged to drive with their lights and beacons on.

• Slips, trips, and falls can occur from uneven ground, debris, open holes or trenches.

• Falls can occur while getting on or off equipment. Practice the three-point rule while climbing up and down stairs and ladders.

• Equipment must not be used to lift personnel.

• Loads must not be lifted over the heads of personnel.

Technical Memorandum 14

5.0 REPORTING

After completion of the field activities and receipt of all applicable analytical laboratory data, a report documenting all removal, sampling, and surveying activities will be prepared. All project activities including mobilization, equipment and personnel employed, removal techniques and waste-handling procedures, sampling approach and methodology, excavation methods, waste disposal, and demobilization will be illustrated and described. All analytical results will be presented and original laboratory reports will be attached to the report. All permits obtained for the purposes of performing the work will be included. Documentation of final disposal of all equipment, material, debris and contaminated material removed from the property will be provided. The final condition of the property and the environmental impacts of the project will be documented with photos, survey data, analytical results, and illustrated using figures and sketches.

6.0 REFERENCES

Alaska Department of Environmental Conservation (ADEC). 2017. Field Sampling Guidance. Division of

Spill Prevention and Response. Contaminated Sites Program. August.

ADEC. 2018. 18 Alaska Administrative Code (AAC) 75. Oil and Other Hazardous Substances Pollution Control Regulations. October.

Brice Engineering, LLC (Brice). 2019. Final Mining Claims Survey and Investigation Work Plan. October.

Office of the Federal Register (OFR). 2005. Hazardous Waste Operations and Emergency Response.

National Archives and Records Administration. 29 CFR 1910.120 and 1926.65. October.

U.S. Army Corps of Engineers (USACE). 2014. Safety and Health Requirements Manual. EM 385-1-1.

November.

ATTACHMENT 1

FIGURES

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3/26/2020

DATE:

0 21

SCALE IN MILES

p

STATE AND SITE VICINITY

BLM MINING CLAIM REMOVAL ACTION

SOUTH OF DELTA JUNCTION, ALASKA

PROJECT LOCATION

FAIRBANKS

BETHEL

KODIAK

JUNEAU

ANCHORAGE

PROJECT LOCATION

D oc um en t P at h:

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Basemap Source: Copyright:© 2013 National Geographic Society, i-cubed

560301

K.T.

1 INCH

FIGURE:

3800 Centerpoint Dr. Ste. 400

Anchorage, AK 99503

DRAWN:

PROJECT No.:

63.5299°

-14 5.8

5°

LO

NG

ITU

DE

LATITUDE_̂

Service Layer Credits: Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User Community

Garage Structure to be Demolished

The Lodge at Black Rapids

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IC

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AR

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SO

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IG

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1 INCH

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J.A.

560301 FIGURE:PROJECT No.: DATE:

DRAWN:

K.T.

4/10/2020

P.M.:

BLACK RAPIDS SOLID WASTE REMOVAL

Legend Alaska DOT & PF Road System

Project Area

0 100 20050

SCALE IN FEET

º

References:

1. Image provided by ESRI and was taken August 15, 2010.

BLM MINING CLAIM REMOVAL ACTION

ALASKA

!(PROJECT LOCATION

FAIRBANKS

BETHEL

KODIAK

JUNEAU

ANCHORAGE

ALASKA STATE PLANE COORDINATE SYSTEM ZONE 3, US SURVEY FEET

HORIZONAL DATUM: NAD83 (2011) | VERTICAL DATUM: NAVD88

!(PROJECT LOCATION

FAIRBANKS

BETHEL

KODIAK

JUNEAU

ANCHORAGE

Service Layer Credits: Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User Community

Location of Black Rapids Remedial Action Distance to Clinic is 39 miles, estimated drive time via Richarson Highway is 44 minutes

RI

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ON

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ROUTE TO CLINIC

1 INCH

Interior Alaska Medical Clinic 2730 Alaska Hwy, Delta Junction, AK 99737

907-895-6233 Hours: 9 a.m. - 5 p.m.

Open: Monday through Friday

ALASKA HIGHWAY

RICHARDSON HIGHWAY

800 0 800 1,600400

Feet Detail A

º

Notes:

1. Imagery from Vivid Maxar; 9/6/2017.

2. Road System shapefile downloaded from Alaska Department of Transportation & Public Facilities.

3. Map produced using ESRI ArcMap v. 10.7.

ALASKA STATE PLANE COORDINATE SYSTEM ZONE 3, US SURVEY FEET

HORIZONAL DATUM: NAD83 (2011) | VERTICAL DATUM: NAVD88

20,000 0 20,00010,000

SCALE IN FEET

DRAWN:P.M.:

Legend Clinic_Route

Alaska DOT&PF Road System

BLACK RAPIDS SOLID WASTE REMOVAL

065401 PROJECT No.:

J.A.

DATE:

4/10/2020

K.T.

FIGURE:

BLM MINING CLAIM REMOVAL ACTION

ALASKA

ATTACHMENT 2

BLACK RAPIDS SOLID WASTE INVENTORY

Attachment 2

Task 4: Black Rapids Solid Waste Inventory

Garage is approx. 156 feet from historic roadhouse. Garage dimensions are: 30’x75’x16’H. The lower 6’ walls are 2x6 sheathed in plywood on all sides. The upper 10’ is Quonset hut corrugated metal on steel frame. The wood walls are painted light green on the sides and the front and rear walls had a dark red/brown paint under layer. XRF analysis of paint chips indicate that none of the paint contains lead.

Dry wall was sampled and results indicate no asbestos containing material present.

Outside of Sides and roof coated with 2” layer foam. Interior has est 200 square feet 2” Styrofoam panels on inside, front and rear walls. Occasional wads of fiberglass bat insulation indoors.

Poured concrete slab has a 2’x5’ steel grate covered sump. Sump characteristics, including depth are unknown. There is a 4” mat covered in dirt and leaves in the sump, below which is a void that extends down about 2’. No standing liquid was observed in the sumep 7/1/17. Strong petroleum fuel odor emitted from the void when the mat was punctured.

Hot water radiators at either side of garage door opening, and they’re mounted 8’ from floor. The radiators are connected together by pipe that runs above door opening, but neither is connected to a boiler in another area of the garage. Fuel supply line, assumed for boiler, enters garage on south wall. Copper pipe lead beneath the slab - suspect radiant heated floor at least near garage door.

Est 1,000 gal fuel tanker on concrete piers mounted outside north side of bldg. with connected steel pipe leading to suspected boiler. North wind soil sampling 2017. Faint odor present under pipe connection at bottom of tank. Tank appear empty, maybe some residual oil in water sump on pipe. Drained gravity fed pipe indoors and removed fuel filter, recovered about .25 gal oil.

15 fluorescent light fixtures with bulbs. 3 single build, rest have two. Partial box of 48” bulbs on shelf with 6 bulbs in it. Says contains mercury. Removed 40 unused light ballasts 2017, disposed as PCB because not marked No PCB. Suspect each light fixture has PCB ballast also.

No fuel lines enter through north side wall adjacent to three 3’x3’x1’ high concrete pedestals. Suspect a large generator was to be mounted here. 500 gal AST outside. AST has several inches liquid in it, odor of diesel. AST is resting on the ground next to a wood cradle - does not appear to have been mounted or connected. North wind collected soil sample 2017.

Eight 2’x6’x2”sheets of blue Styrofoam attached to wall next to above concrete piers

Two 7-10 KW generators located inside bldg. at NE corner. Generators may hold oil. Radiators present -antifreeze. Two batteries connected. Fuel supply lines dry except for small amount of oil in filers.

Drained 2017. Several small oil stains on floor in the room. Supply and return pipes run under slab to emerge from below ground outside SE corner of bldg. Pipes extend 4 & 6 feet above ground surface. No AST present, but soil exhibits faint odor at about 6” depth. North wind collected soil sample 2017.

Suspect fuel release at tank and under slab.

Gen room has GWB. 2 panels on ceiling of room, 5 on south wall. No sound insulation on any wall.

Panels are 4’x8’. Two Samples for PLM collected 2017 with results negative for asbestos.

Two exterior light fixture appear to not have intact bulbs, one was halogen and other unknown bulb screw-in bulb type.

24’x20’ wood frame loft at east end. 5 spools welding wire and approx. 1 ton misc. metal and wood including welder, 5 5-gal pails of black welding sand, water pump, generator winding, and Est 60 each 12”x12” double layer accustom tiles. Two PLM samples collected 2017.

Total NHSW inside garage is est 7 tons. Include boiler, 4 washer and dryers, two 6’ soft drink coolers, two wall mount hot water heaters, display case and steel rack, 2 welders, commercial stove, steel double sink unit, wood stove, air compressor, pile of gen and mechanical parts, loose nuts and bolts, and loft materials.

Outside: Two tanks described above, 2’MT drums, heavy duty engine stand, misc. parts and rotten wood.

Est 1 ton NHSW besides the tanks.

On date of inspection ski-doo snow machine and several totes of personal effects, plastic ice-chests and totes, 5-6 washers & dryers, two 6’ soft-drink coolers, and a Wolf brand gas kitchen stove with oven remain present. I understand from Joe Hart lodge owners will have them removed this weekend. He intends to board-up the bldg. in 2 weeks and post as US Property No Trespassing.

Photographs

Back of Garage, Black Rapids Airstrip

Fuel tank outside of Garage, Black Rapids Airstrip

Line under fuel tank with soil staining, Black Rapids Airstrip

Empty 500 gallon tank outside garage, Black Rapids Airstrip

Distribution lines emerging from ground outside garage, Black Rapids Airstrip

Garage interior, Black Rapids Airstrip

Garage interior as viewed from loft, Black Rapids Airstrip

Additional photographs of items included in site inventory are available.