JA-16_SAP_Plan.pdf

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ENVIRONMENTAL WORK PLAN

FOR PROJECTS WITH NO KNOWN

CONTAMINATION

Aug 5th, 2013

Prepared By:

United States Air Force Eielson Air Force Base, Alaska ii

TABLE OF CONTENTS

1.0 INTRODUCTION

1.1 BACKGROUND

1.2 RESPONSIBILITIES AND PROJECT PERSONNEL

1.2.1 CEAN Responsibilities

1.2.2 CEO Responsibilties

1.2.3 Working Party Responsibilities

2.0 SAMPLING AND ANALYSIS

2.1 CRITERIA FOR EXCESS SOIL DISPOSAL

2.2 ANALYTICAL SCHEDULE

2.2.1 Areas of Known Contamination

2.2.2 Areas of Unknown Contamination

2.2.3 Health and Safety Field Screening

2.2.4 Hazardous Waste Characterization

2.2.5 Soil Segregation

2.3 ANALYTICAL LABORATORY

2.4 SAMPLE FREQUENCY

2.5 EXCESS SOIL SAMPLE COLLECTION

2.5.1 Qualitative Field Screening

2.5.2 Semi-quantitative Field Screening

2.5.3 Soil Sampling

2.6 DECONTAMINATION PROCEDURES

2.6.1 Soil Sampling Equipment

2.6.2 Construction Equipment

3.0 DATA EVALUATION, SOIL DISPOSITION, AND REPORTING

3.1 DATA EVALUATION

3.2 CONTAMINATED SOIL DISPOSITION

3.2.1 Petroleum-Contaminated Soil

3.2.2 Contaminated Soil Other Than PCS

3.3 REPORTING

4.0 QUALITY ASSURANCE PROCEDURES

4.1 PRECISION

4.1.1 Field Precision Objectives

4.1.2 Laboratory Precision Objectives

4.2 ACCURACY

4.2.1 Field Accuracy Objectives

4.2.2 Laboratory Accuracy Objectives

4.3 COMPLETENESS

4.3.1 Field Completeness Objectives

4.3.2 Laboratory Completeness Objectives

4.4 REPRESENTATIVENESS

4.4.1 Measures to Ensure Representativeness of Field Data

4.4.2 Measures to Ensure Representativeness of Laboratory Data

4.5 COMPARABILITY

4.5.1 Measures to Ensure Comparability of Field Data

4.5.2 Measures to Ensure Comparability of Laboratory Data

5.0 QUALITY CONTROL SAMPLES

5.1 FIELD DUPLICATES

5.2 MATRIX SPIKES AND MATRIX SPIKE DUPLICATES

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5.3 TRIP BLANKS

6.0 HANDLING AND SHIPPING OF SAMPLES

6.1 SAMPLE CONTAINERS

6.2 CUSTODY PROCEDURES

6.3 SHIPPING

6.4 DOCUMENTATION AND SAMPLE IDENTIFICATION

7.0 REFERENCES

8.0 LIST OF ACRONYMS

9.0 TABLES

TABLE 1

TABLE 2

10.0 APPENDIX

Appendix A: Laboratory Control Limits Appendix B: Forms and Records

Environmental Work Plan for Sites with No Known Contamination

1.0 INTRODUCTION

This Environmental Work Plan (EWP) describes the technical approach and procedures for characterizing, handling, and disposing of excess contaminated excavated soil (excess soil) generated from projects at Eielson Air Force Base (AFB) in Fairbanks, Alaska (AK). Eielson AFB developed this generic work plan for use at project sites with no known contamination. Per the IC/LUC Settlement Agreement (16 April 2013) this plan is approved by, and satisfies DEC and EPA review and comment requirements. No further regulator review or approvals of a workplan/sampling plan is necessary prior to commencing work at sites with no known contamination where Eielson AFB elects to use and follow this generic plan, UNLESS a site-specific addendum is required due to possible presence of non-POL contaminants, contamination levels that trigger hazardous waste disposal protocols, use of a different lab, or additional testing not covered in this plan.

1.1 BACKGROUND

Eielson AFB was listed on the National Priorities List (NPL) by the U.S. Environmental Protection Agency (EPA) under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) in November 1989. The Federal Facilities Agreement (FFA) for Eielson AFB was signed in May 1991 by the United States Air Force (USAF), EPA, and the State of Alaska Department of Environmental Conservation (ADEC). The FFA identified 64 potential sources of contamination. Sixty of these sources have been addressed in either a Remedial Investigation/Feasibility Study (RI/FS) under an Operable Unit (OU), or through the Source Evaluation Report (SER) process. Record of Decision (ROD) documents for OU1, OU2 (and some SER sites), and OU6 were signed in 1994. A ROD for OUs 3, 4, 5 (including some SER sites) was signed in 1995. The Sitewide ROD, was signed in 1997. Amendments to the OU3, 4, 5 RODs were completed in 1998. Amendments to the OU2 ROD were completed in 2001.

Areas not covered under the FFA are managed according to the most current federal and state regulations concerning the discovery of contaminated soil.

Excess soil generated following construction projects in areas known or suspected to be contaminated may require characterization to determine appropriate disposal. This EWP presents analytical parameters and test methods, sample-screening methods, sampling frequency, and provisions for characterizing potentially contaminated soil.

A working party prepared project Health and Safety Plan (HASP), provides guidance and procedures to protect the health of personnel involved in the construction activities. The HASP includes safety guidance to workers involved in soil sampling activities. Working party technicians will provide health and safety monitoring under contract for the project. Excess soil characterization described in this EWP, will also be performed by construction personnel.

1.2 RESPONSIBILITIES AND PROJECT PERSONNEL

The Commander, 354 Civil Engineer Squadron (CES), Eielson AFB, has directed that excess soil generated during construction be characterized and a regulatory evaluation be provided to CES at Eielson AFB for proper disposal or treatment. The following sections list the key personnel and describe the responsibilities of the various parties involved in this project.

1.2.1 CEAN Responsibilities

CES is considered the generator of the excess soil and ultimately responsible for treatment and/or disposal.

The working party will provide the Environmental Engineering branch (CEAN) with qualitative and semi-quantitative field screening results, analytical results and assist CEAN with the evaluation of appropriate excess soil disposal/treatment options.

1.2.2 CEO Responsibilities

Operations Flight (CEO) will review and coordinate Base Civil Engineering Work Clearance Requests (AF Form 103s) submitted by the working party. If work is to occur in areas of contamination known to CEAN, the approved Base Civil Engineering Work Clearance Request will indicate the areas where contamination is suspected and list contaminant types.

If previously known contamination exists, this plan no longer applies and a separate SAP will be prepared.

Following characterization of excess soil in unknown contaminated areas and when CEAN requires the working party to sample in known areas, the working party will provide CEO and CEAN with the analytical results and regulatory evaluation of excess soil disposal and treatment options. CEAN will coordinate excess soil treatment/disposal, and ensure that excess soil is treated/disposed in accordance with regulatory requirements.

1.2.3 Working Party Responsibilities

The working party is responsible for the following tasks:

1. Preparation and submission of a Base Civil Engineer Work Request (AF Form 332) and a Base Civil Engineering Work Clearance Request (AF Form 103).

2. Field oversight for Base Civil Engineering Work Clearance Request compliance.

3. Field-screening excess soil using both qualitative (visual, olfactory, etc) and semi-quantitative field screening methods.

4. Reporting contamination when it is encountered per section 2.2.2.

5. Collecting soil samples and submitting them to the laboratory for chemical analysis when required by CEAN.

6. Analyzing the chemical data and providing an analysis of appropriate treatment/disposal option for excess soil. Prior and present laboratory analysis results and field screening methods will dictate the appropriate treatment or disposal.

7. Consulting with CEAN for direction on where to dispose of potentially contaminated soil.

8. Stockpiling and transporting excess soil.

9. Providing analytical services.

10. Appropriate remediation of contaminated soil.

The working party’s principal investigator is responsible for overall management of excess soil characterization activities, including adherence to the procedures described in this plan.

The working party’s quality assurance (QA) officer is responsible for conducting scheduled field audits and providing ongoing review, monitoring, and evaluation of the field and laboratory activities; the QA officer will independently validate all laboratory reports.

Excess soil sampling will be conducted or supervised by “qualified persons” as defined in Appendix A of ADEC’s Underground Storage Tanks (UST) Procedures Manual (ADEC, 2002) and 18 Alaska Administrative Code (AAC) 75.990.

Whenever the working party suspects or has knowledge of a leak, spill, or release of oil, hazardous substances, or regulated substances not previously identified to CEAN, the working party shall immediately notify CEAN at (907) 377-7745. The working party shall also prepare an ADEC Oil and Hazardous Materials Incident Report Form in accordance with ADEC regulations. The working party shall be responsible for delivering by hand, emailing, or faxing the completed form to CEAN, (907) 377-3367, who will be responsible for providing notification to the ADEC as required per 18 AAC 75.300. The working party shall reevaluate the Site Safety and Health Plan and alter as appropriate before proceeding.

In accordance with 18 AAC 75.310, a working party will be responsible for cleanup of all leaks, spills, and releases of oil, hazardous substances, or regulated substances caused by the working party during this project.

2.0 SAMPLING AND ANALYSIS

This section provides the excess soil disposal criteria, analytical schedule, sampling requirements and procedures.

2.1 CRITERIA FOR EXCESS SOIL DISPOSAL

Excess soil generated during this project will be repurposed on base, unless it is deemed to exceed soil clean up levels defined in 18 AAC 75. Applicable compounds are the contaminants of concern (COCs) listed in the records of decision and contaminants previously discovered on Eielson AFB. When a AF103 Base Civil Engineer Work Request is submitted, sites are evaluated under the IC/LUC process to verify that they will not impact contaminated areas, this includes research into past site usage and checking proximity to contaminated sites.

This plan will only cover procedures for POL contaminants in detail. Field screening, sampling, and testing for POL contaminants will follow procedures laid out in the ADEC Field Sampling Guidance. If other possible contaminants are determined during the IC/LUC process, they will be addressed in a site-specific addendum. Applicable contaminant types found on Eielson include, but are not limited to, the following:

1. Petroleum products

2. VOCs

3. SVOCs

4. Halogenated hydrocarbons

5. Organochlorine pesticides

6. Metals

Table 2 lists contaminant types, COCs, and Clean Up Level criteria. The references for Clean Up Level criteria are as follows:

1. Petroleum Hydrocarbons (POL): 18 AAC 75.341, Table B2, “Under 40 Inch Zone”, migration to groundwater.

2. All Contaminants Other Than POL: 18 AAC 75.341, Table B1, “Under 40 Inch Zone,” migration to groundwater.

2.2 ANALYTICAL SCHEDULE

Excess soil will be generated outside areas of known or suspected contamination on Eielson AFB. Excess soil generated outside areas of known contamination that exhibit no indication of contamination during field screening will be disposed of on base. The chemical analyses used to determine whether excess soil is polluted are based on known COCs, previous Eielson AFB site characterization, and qualitative field screening, as described in the following sections. Table 2 shows contaminant groups and cleanup levels for soil in regards to migration to groundwater.

CEAN will provide information about known contamination as part of the Base Civil Engineering Work Clearance Request process. Current practice is for the working party to file Base Civil Engineering Work Clearance Requests with Eielson AFB. As part of the permit approval process, CEAN will review available environmental data to (1) delineate areas where excess soil may require characterization before disposal, (2) list probable/known soil contaminants, and (3) determine if soil samples from excess soils in known contaminated areas will require further laboratory analysis. This information will be provided and attached to the approved Base Civil Engineering Work Clearance Request.

2.2.1 Areas of Known Contamination

Work conducted in areas of known contamination will not be covered under this work plan.

2.2.2 Areas of Unknown Contamination

The working party will use the criteria in this screening plan, approved by CEAN, ADEC, and EPA, to detect contamination in areas of unknown contamination. A photo ionization detector (PID) will be used to screen for contamination using headspace samples.

As contaminated soils or water (odors, free product, sheen, staining, field screening readings greater than 20 ppm) are encountered the working party shall inform the Project Managers (USAF, to include USACE) as soon as safely practicable and implement the management plan for the contaminated materials as indicated in the Work Plan and any adjustments to the safety practices that are needed. The USAF Project Manager will inform Base Environmental, CES/CEAN IRP, and if applicable, the Contracting Officer/Representative. The working party shall proceed with the work unless directed otherwise by a Contracting Officer/Representative or a Project Manager. The intent of the notification is to assess the level of contamination and to assure that the work area is consistent with this Work Plan. Environmental Engineering will contact applicable regulators to inform of discovered contamination.

The Project Manager shall keep personnel from Base Environmental Engineering and 354 CES/CEAN IRP and the Contracting Officer (Representative) informed throughout the project as additional contaminated media are encountered. The CEAN Element personnel will be responsible for regulatory notifications to DEC/PERP (and EPA if applicable) when contamination is discovered.

If PID screening levels in the excavation or in excess soils exceed 20 ppm, the soils will be separately stockpiled by <20 ppm (presumed clean), >=20 ppm to <100ppm (suspected), and >=100 ppm (known).

Analytical samples and testing will be conducted based on the ADEC Field Sampling Guidance Appendix F: Determination of Sampling and Lab Analysis for Petroleum in Soil and Groundwater. Stockpiles will be appropriately placed, covered, and sampled per the Field Sampling Guidance. Contaminated excess soils can ONLY be placed back into the excavation with the approval of ADEC (and EPA if applicable).

If contamination levels exceed the cleanup levels in 18 AAC 75, CEAN will notify the Prevention and Emergency Response Program (PERP) (and EPA if applicable) immediately of the newly discovered contaminated site. (Spill reporting, separate from exceeding cleanup levels, will follow section 1.2.3 Working Party Responsibilities).

2.2.3 Health and Safety Field Screening

The working party will conduct health and safety monitoring to protect workers. Health and safety screening consists of measuring organic vapors in the worker’s breathing zone using a PID, and making visual and olfactory observations during trenching operations. The health and safety action level for organic vapor monitoring is 5 parts per million (ppm).

A working party field representative who is an ADEC ‘qualified person’ and able to field screen will be on-site with excavation crews at all times that the working party is excavating in areas of known or suspected contamination. If organic vapor monitoring health and safety screening levels are exceeded, or visual observations or olfactory observations give working party personnel reason to believe that excess soil might exceed clean up levels, this excess soil will be separately stockpiled on top of 10-mil sheeting for short-term storage and 20-mil sheeting for long-term storage, and covered with 6-mil reinforced polyethylene sheeting. Sheet edges will be rolled to prevent contact of soil with moisture from precipitation runoff and will be sufficiently secured to prevent the covering material to be blown away by seasonal wind action. The working party will evaluate qualitative field screening evidence and existing environmental data, and will select appropriate analytical methods. These analyses may either be in addition to CEAN Base Civil Engineering Work Clearance Request requirements or may stand-alone in areas where the Base Civil Engineering Work Clearance Request does not require analysis.

2.2.4 Hazardous Waste Characterization

Under certain circumstances that are discussed further in Section 3.0, soil exceeding clean up level criteria will require hazardous waste characterization before disposal. In these cases, the analytical requirements will be determined on a case-by-case basis. This would be covered under a site specific addendum.

2.2.5 Soil Segregation

Stockpiled soil will be in accordance with 18 AAC 75.370. Soil will be segregated and stockpiled separately in the following cases:

1. Soil will be segregated based on sampling requirements listed on the Base Civil Engineering Work Clearance Request.

2. Soil will be segregated based on field screening data and or current laboratory analysis.

3. Soil in suspected contaminated areas will be separated into stockpiles by known, suspected, and presumed clean criteria laid out in 2.2.2.

2.3 ANALYTICAL LABORATORY

The prime analytical laboratory will be SGS.

SGS North America Inc. –Alaska Division Environmental Services 200 W. Potter Drive

Anchorage, AK 99518 907-550-3206 UST-005, Expires: Dec 18 2013

If another lab is to be used, it will be identified in a site-specific addendum, including the DEC lab approval number found at the following website:

http://dec.alaska.gov/applications/eh/ehllabreports/USTLabs.aspx

2.4 SAMPLE FREQUENCY

Individual streams of excess soil will be generated under the following conditions or frequencies for purposes of characterization for disposal:

For areas where field screening indicates that soil is contaminated as described in Section 2.5.1, analytical samples will be taken from the stockpile and from the excavation basin in accordance with ADEC Field Sampling Guidance Tables 2A and 2B. In addition to the analytical sample, the working party will qualitative field screen the contamination end points along the excavation.

2.5 EXCESS SOIL SAMPLE COLLECTION

Excess soil samples will be determined by Table 2A and 2B of the ADEC Field Sampling Guidance, in addition to consultation with CEAN to review possible past site uses. Any sampling that does not follow Table 2A and 2B will be discussed in a site specific addendum.

2.5.1 Qualitative Field Screening

Qualitative field screening will be used to delineate areas of suspected contamination not previously identified as a known contaminated site. Visual survey of the area for evidence of staining, sheen, dead or distressed vegetation, or other signs indicating possible contamination will be used. Odors are noticed during site inspection or excavation will also be used for signs of possible contamination.

2.5.2 Semi-quantitative Field Screening

The PID used for health and safety monitoring and described in Section 2.2.2 will be used for semi-quantitative field screening. The semi-quantitative screening methods described here are adapted from the ADEC Field Sampling Guidance. Semi-quantitative field screening samples will be collected at the following frequencies and locations:

1. Areas where qualitative field screening indicate suspect contamination.

2. At regular 20-foot intervals from excess suspect contaminated soils generated along piping runs.

3. Following ADEC Field Sampling Guidance Table 2A and 2B.

Semi-quantitative field screening will use the headspace analytical screening procedure described in the ADEC Field Sampling Guidance. This method is summarized below:

1. Partially fill (one-third to one-half) a clean jar or clean ziplock bag with freshly uncovered excess soil.

2. Quickly close or seal the jar or bag.

3. Shake or agitate sample for 15 seconds.

4. Warm to at least 40F and allow to stand for between 10 and 60 minutes. (To the extent practicable, contractor will try to keep sampling times consistent in the 10-60 minute range, ie 15 minutes of standing for each sample)

5. Shake or agitate sample for 15 seconds.

6. Insert sampling probe to one-half the headspace depth, and minimize the size of the container opening.

7. Record the highest meter reading on the field record, normally between 2-5 seconds after probe insertion

8. Document all field sampling results in the field record or log book.

2.5.3 Soil Sampling

Soil samples will be collected by a working party field representative using the procedures described in 18 AAC 75. This method is summarized here:

1. Estimate the volume of the waste stream and, using Section 2.4 of this plan, determine the necessary number of samples.

2. Select sample locations using the highest semi-quantitative field values as determined using the procedure described in Section 2.5.2. Before sampling, remove a minimum of 18 inches of soil from the surface of the waste pile.

3. Collect all samples with pre-cleaned sampling equipment that has been decontaminated according to the procedures in Section 2.6 of this plan. Disposable gloves must be worn and changed between samples collections.

4. Do not collect composite samples. All samples will be grab samples.

5. Fill sample containers quickly. Fill GRO/BTEX and Volatile Organic Compound (VOC) containers first. Refer to ADEC Field Sampling Guidance Appendix D for additional sample container information. Field duplicate sample containers will be filled alternately.

6. Quickly and adequately seal containers, and clean rims before tightening lids. The GRO/BTEX and VOC analyses are unique and require preservation using methanol, as per ADEC Field Sampling Guidance Appendix F.

7. After filling, promptly place containers into a cooler containing Blue Ice or similar product and cooled to 4C.

Sample identification, chain-of-custody, and sample shipping procedures are discussed in Section 6.0 of this EWP.

2.6 DECONTAMINATION PROCEDURES

This section describes decontamination procedures for equipment used for excess soil sampling and construction.

2.6.1 Soil Sampling Equipment

The following six-step procedure will be used to decontaminate waste soil sampling equipment.

Equipment will be decontaminated before each use.

1. Rinse and pre-clean in potable water.

2. Wash in solution of laboratory grade, non-phosphate-based soap and potable water.

3. Dip rinse in potable water.

4. Rinse with n-propyl alcohol.

5. Rinse with distilled water.

6. Place on clean polyethylene sheeting or within a clean container to drain and air dry.

Solutions will be renewed as needed. Sponges and nylon scrubbers will be used during steps 1 through 3.

Equipment will be air-dried, if possible, and held in clean plastic bags between uses. Decontamination blanks will be collected, in accordance with ADEC Draft Field Sampling Guidance, at a rate of 1 per 20 similar samples, minimum one.

2.6.2 Construction Equipment

Following completion of work in areas of previously unknown contamination, construction equipment may require decontamination at the discretion of CEAN. Areas of previously unknown contamination will be identified by field screening methods. If CEAN requires decontamination, all loose soil will be scraped onto 20 mil liner for collection. The piece of equipment will then be driven or transported to 2832 Flightline Avenue, where it will be pressure washed. Decontamination rinses from unknown contaminated soils will be contained in 55-gallon drums. Rinsates will be segregated according to the area of unknown contamination, stored at the Haz Waste Disposal Facility until characterization is complete, and treated or disposed of based on results of testing.

3.0 DATA EVALUATION, SOIL DISPOSITION, AND

REPORTING

This section provides the technical approach to excess soil data evaluation and disposition. Reporting is also discussed in this section.

3.1 DATA EVALUATION

The working party will evaluate analytical results from individual excess soil stockpiles by comparing them with clean up level criteria shown on Table 2. The following matrix shows guidelines for soil disposition:

Results of Soil Stockpile Characterization Guidelines for Soil Disposition Base Civil Engineering Work Clearance Request has no soil sampling requirements and qualitative field screening indicates that soil is not contaminated.

Soil stockpile pre-approved for disposal or reuse on Eielson AFB.

Chemical analyses show that all samples collected from soil stockpile meet clean up level criteria.

Soil stockpile is acceptable for disposal into Eielson AFB Asbestos Landfill.

Landfill disposal criteria are exceeded for one or more POL compounds (benzene, GRO, DRO, RRO) in at least one sample.

Soil is thermally treated and subsequently disposal into Eielson AFB Landfill. Stockpiling procedures are discussed in Section 3.2later.

Landfill disposal criteria are exceeded for clean up level parameters other than POLs.

Soils will be stockpiled at the designated stockpile area awaiting ultimate disposition. Working party will review analytical results and provide recommendations to CEAN for additional analyses, if appropriate. Following chemical characterization, the working party will provide an evaluation evaluate treatment/disposal options of appropriate excess soil treatment/disposal options to, coordinate with CEAN to gain regulatory clearances (ex:

ADEC Permission to Transport), and dispose of it.

3.2 DISPOSITION OF SOIL EXCEEDING CLEAN UP LEVELS

Excess soil that exceeds the clean up level criteria will be either treated or disposed offsite.

Excess contaminated soil will be stockpiled by the working party according to short term storage requirements listed in 18 AAC 75.370, which are summarized here:

1. Contaminated soil will be stockpiled by the working party at an onsite location agreed upon with

CEAN.

2. Contaminated soil will be placed on a 10-mil thick liner conforming to the applicable specifications listed on Table D of 18 AAC 75.370.

3. Stockpiles will be covered with liner and secured in place by sandbags or pavers.

4. After the stockpiles are covered, the piles will be marked showing original excavated location.

5. Soil stockpiles will be inspected and maintained regularly by the working party to ensure that the cover remains intact until the project is complete.

6. Following soil treatment, soil stockpile liners and covers will be disposed of by the working party as IDW if contamination is present.

Additionally,

1. Stockpiles will be labeled with the name of the working party point of contact and phone number.

2. Stockpiles will be numbered chronologically, labeled with date started, project, and contaminant.

3.2.1. Petroleum-Contaminated Soil

Once regulatory Approval to Transport is obtained, CEAN will make arrangements to thermally treat POL-contaminated soil (PCS) at a local treatment facility. Consequently, while awaiting treatment, PCS generated during the project will be stockpiled by the working party at a location agreed upon by CEAN.

3.2.2 Contaminants Other Than PCS

If soil exceeding clean up level criteria for contaminants other than the PCS compound types (GRO, DRO, RRO, and BTEX) is discovered while working on a site thought to be PCS only, it will require a site specific addendum to coordinate offsite treatment or disposal with the regulators. Excess soil falling into this category will be stockpiled according to the procedures described in Section 3.2 of this plan at an onsite location approved by CEAN.

A determination about appropriate offsite disposal of these excess soil stockpiles will be made on a case-by-case basis, covered in a site specific addendum.

The working party may recommend that additional chemical analysis be performed as appropriate to determine whether the excess soil stockpile is either:

1. A RCRA hazardous waste.

2. A waste under the TSCA. This criterion would primarily apply to soil contaminated with PCBs or polychlorinated dibenzo-dioxins (PCDDs)/polychlorinated dibenzo-furan (PCDFs).

CEAN will coordinate and oversee treatment and/or disposal of RCRA hazardous waste, TSCA waste, and contaminated soil. Disposal of stockpile liners and covers will be the responsibility of the working party.

3.3 REPORTING

Prior to the closeout of project, a final field report that identifies field-screening readings and locations (by GPS coordinates), soil sampling and analytical results detailing limits and level of contamination within the project footprint, and volumes of excess contaminated soil will also be submitted by the working party. If the project spans more than one field season, an interim report submitted at the end of the field season will be required. The working party shall also provide copies of analytical reports which characterize stockpiled contaminated soil and total quantities of soil placed at the stockpile area (to include a record of the dates of placement, quantities placed, and location of stockpiles). A hard copy and one electronic copy will be provided to Eielson AFB for distribution.

4.0 QUALITY ASSURANCE PROCEDURES

The overall QA objective for this project is to develop and implement procedures for field sampling, chain-of-custody, laboratory analysis, and reporting that will provide technically and legally defensible results.

This section discusses QA objectives and procedures for this project.

4.1 PRECISION

Precision is a measure of reproducibility of measurements of the same characteristic, usually under a given set of conditions.

4.1.1 Field Precision Objectives

Field precision will be assessed by the collection and analysis of field duplicates and will be expressed as Relative Percent Difference (RPD).

Duplicate samples are analyzed to check for matrix variability and analytical method reproducibility. At a minimum, one field duplicate will be collected for every 10 investigative samples by media and analyzed for the same parameters listed for other media samples. Field duplicate collection is discussed in Section 5.0.

4.1.2 Laboratory Precision Objectives

Precision may be calculated in terms of RPD. Precision will be assessed by comparing the analytical results between matrix spike (MS) and matrix spike duplicate (MSD) for organic analysis and between laboratory duplicates for inorganic analysis. The RPD will be calculated for each pair of duplicate analyses using the following equation:

%)100( 2/)( 21

XX

XX

RPD

where:

RPD = relative percent difference.

X1, X2 = value of sample 1 and sample 2.

RPDs may be compared with the laboratory-established RPD control limits for the analysis. Appendix A shows SGS precision control limits.

4.2 ACCURACY

Accuracy is the degree of agreement of a measurement or average of measurements with an accepted reference or “true” value and is a measure of bias in the system. The accuracy of a measurement system is affected by errors introduced through the sampling process, field contamination, preservation, handling, sample matrix, sample preparation, and analytical techniques.

4.2.1 Field Accuracy Objectives

The achievement of accurate data in the field will be addressed using trip blanks and through the adherence to all sample handling, preservation, and holding times. Trip blanks are discussed in Section 5.0.

4.2.2 Laboratory Accuracy Objectives

Results for blank, matrix spikes, laboratory control samples, and surrogates will be primary indicators of accuracy. These results will be used to control accuracy by requiring that they meet specific criteria. As spiked samples are analyzed, spike recoveries will be calculated and compared with acceptance limits.

The calculation formula for percent recovery is

21 %)100)((

C

CC

R where:

R% = spike amount recovered.

C1 = concentration of analyte in spiked sample.

C2 = concentration of analyte in un-spiked sample.

C3 = concentration of spike added.

Acceptance limits will be based on previously established laboratory performance for similar samples and shown in Appendix A. In this approach, the control limits reflect the minimum and maximum recoveries expected for individual measurements for an in-control system. Recoveries outside the established limits indicate some assignable cause, other than normal measurement error, and possible need for corrective action. Corrective actions may include recalibration of the instrument, reanalysis of the quality control (QC) sample, reanalysis of the samples in the batch, repreparation of samples in the batch, or flagging the data as suspect if the problems cannot be resolved. For contaminated samples, recovery of matrix spikes may depend on sample homogeneity, matrix interference and dilution requirements for quantitation.

4.3 COMPLETENESS

Completeness is a measure of the amount of valid data obtained from a measurement system compared with the amount expected under normal conditions.

4.3.1 Field Completeness Objectives

Field completeness is a measure of the amount of valid measurements obtained from all the measurements taken in the project. Field completeness for this project will be greater than 90 percent.

4.3.2. Laboratory Completeness Objectives

The project laboratory will provide data meeting QC acceptance criteria for a minimum of 90 percent of the samples tested using the SW-846 and other standard methods. At the completion of sample analysis testing, the percent completeness will be calculated by the following equation:

%)100(% R

S C where C = completeness.

S = number of successful analyses.

R = number of requested analyses.

Successful laboratory analyses can only be accomplished if both the field and laboratory portions of the project are successful. Factors that adversely affect completeness include the following:

1. Receipt of samples in broken containers.

2. Receipt of samples in which chain of custody or sample integrity is compromised in some way.

3. Samples received with insufficient volume to perform initial analyses or repeat analyses, if initial efforts do not meet QC acceptance criteria.

4. Improperly preserved samples.

5. Samples held in the field or laboratory longer than expected, thereby jeopardizing holding time requirements.

6. Samples that have unclear analyses requests.

4.4 REPRESENTATIVENESS

Representativeness is a qualitative parameter, dependent on the proper design of the sampling program and proper choice of extraction and analytical methods. Representativeness qualitatively expresses the degree to which data accurately and precisely represent a characteristic of a population, parameter variations at a sampling point, a process condition, or an environmental condition. Representativeness expresses the degree to which a sample represents a source material, an environmental media, or a geochemical process.

The characteristic of representativeness cannot be quantified. Subjective factors to be taken into account are as follows:

1. Degree of homogeneity of a site.

2. Degree of homogeneity of a sample taken from one point in a site.

3. Available information on which a sampling plan is based.

4.4.1 Measures to Ensure Representativeness of Field Data

Field duplication as defined under precision also is used to assess representativeness. Two samples that are collected at the same location and at the same time are considered equally representative of this condition, at a given point in space and time.

4.4.2 Measures to Ensure Representativeness of Laboratory Data

Within the laboratory, precautions are taken to extract from the sample container an aliquot representative of the whole sample. These precautions include premixing the sample and discarding foreign material (e.g., stones, twigs, pebbles) from soil samples. For samples requiring volatiles analysis, premixing or homogenization is not performed.

4.5 COMPARABILITY

Comparability expresses the confidence with which one data set can be compared with another. The extent to which existing and new analytical data will be comparable depends on the similarity of sampling and analytical methods.

4.5.1 Measures to Ensure Comparability of Field Data

Comparability for the waste soil-sampling program will be ensured by using consistent soil sampling techniques. To ensure consistency, working party field personnel who are responsible for soil collection will frequently confer on sampling techniques.

4.5.2 Measures to Ensure Comparability of Laboratory Data

All chemical analyses for this project will be performed by SGS Laboratory.

5.0 QUALITY CONTROL SAMPLES

This section describes the purpose of QC samples, and discusses how they will be collected and evaluated.

5.1 FIELD DUPLICATES

Duplicate samples are analyzed to check for matrix variability and analytical method reproducibility. One field duplicate will be collected for every ten soil samples. Duplicate samples will be analyzed for the same parameters as the media samples.

5.2 MATRIX SPIKES AND MATRIX SPIKE DUPLICATES

A matrix spike (MS) is an environmental sample to which a known concentration of a target analyte or surrogate compound has been added. MS samples are analyzed to evaluate the effect of the sample matrix on the analytical methodology. A matrix spike duplicate (MSD) is a second aliquot of sample that is spiked with target analyses and analyzed with the associated MS sample.

5.3 TRIP BLANKS

Volatile organic samples are susceptible to contamination by diffusion of organic contaminants through the septum of the sample vial. Trip blanks are analyzed to monitor for possible sample contamination during shipment for benzene and GRO. Trip blanks are prepared in the laboratory by filling preserved VOC vials (with no headspace) with organic-free water for benzene and methanol for GRO. Trip blanks accompany the sample containers during transit from the laboratory to the site, collection, and shipment to the laboratory.

5.4 DECONTAMINATION BLANKS

Samples are susceptible to contamination from equipment decontamination and sample handling procedures. Decontamination blanks are analyzed to monitor for possible sample contamination.

Decontamination blanks are collected in the field. De-ionized water is passed over decontaminated sample equipment and collected in sample containers for transport to the laboratory.

6.0 HANDLING AND SHIPPING OF SAMPLES

6.1 SAMPLE CONTAINERS

Pre-cleaned four-ounce and eight-ounce glass sample containers will be provided by the analytical lab. The containers will be kept closed and in their shipping boxes until used. After sampling, the containers will be labeled, secured with chain-of-custody seals, placed in coolers, chilled to 4C, and shipped to the laboratory. Container requirements are shown on Table 2.

6.2 CUSTODY PROCEDURES

Samples collected during performance and confirmational monitoring represent physical evidence collected from the site or its immediate surroundings. Because of the potential use of these samples as evidence, their possession must be traceable from collection until the data from them are ultimately used. A chain-of-custody protocol will be followed to maintain and document sample possession used. The documentation will include the following:

1. Sample labels and seals.

2. Soil sampling records.

3. Chain-of-custody records.

4. Shipping records.

Chain-of custody procedures are discussed in Appendix A. Each sample will be labeled, and will have a custody seal affixed to its container cap immediately after collection. Each label will include, at a minimum, the following information:

1. Project name and number.

2. Name of collector.

3. Date and time of collection.

4. Number that uniquely identifies the sample and its collection location (the sample numbering sequence will not indicate to the laboratory which samples are duplicates, splits, or field blanks).

5. Preservative (if any).

A custody seal will be affixed to all samples containers to inhibit tampering during shipment to the laboratory. If any custody seals are found broken when the laboratory receives a sample shipment, no analysis will be performed unless there is incontrovertible evidence that the samples were not compromised. Broken or missing custody seals will be noted on the chain-of-custody records by the receiving analytical laboratory.

Samples will be kept in the sampler’s custody until the end of each day, when they will be shipped to the laboratory, if possible.

Samples will be shipped to the analytical laboratory with chain-of-custody records, establishing the documentation necessary to trace sample possession from the time of collection. The chain-of-custody records will contain, at a minimum, the following information:

1. Sampler number.

2. Signature of collector.

3. Date and time of collection.

4. Place of collection.

5. Sample matrix.

6. Signatures of persons involved in the chain of possession.

7. Inclusive dates of possession.

8. Condition of samples.

The chain-of-custody record also will be used to indicate what analyses are required by checking the appropriate boxes on the form. Following proper sealing and labeling, sample containers will be placed on Blue Ice in a cooler. The cooler will be closed and sealed with a custody seal.

6.3 SHIPPING

As described earlier, samples will be accompanied by a properly completed chain-of-custody form. The original and yellow copies will accompany the shipment, and the pink copy will be retained by the sampler for the working party’s project files. When transferring the possession of samples, the individuals relinquishing and receiving will sign, date, and note the time on the record. This record documents transfer of sample custody from the sampler to another person, to the project laboratory, or to or from a secure storage area.

Sample will be properly packaged for shipment and dispatched to the laboratory for analysis, with a separate, signed custody record enclosed in each sample cooler. Shipping containers will be secured with strapping tape, and custody seals will be attached for shipment to the laboratory. The preferred procedure includes use of a custody seal attached to the front right and back left of the cooler. The custody seals are covered with clear plastic tape. The cooler is strapped shut with strapping tape in at least two locations.

Samples will be shipped to SGS via overnight delivery service.

6.4 DOCUMENTATION AND SAMPLE IDENTIFICATION

The Daily Field Investigation Form is the basis of the working party’s documentation. A copy of this form is attached. Entries on it describe the day’s activities. Field measurements and sample data will be recorded on appropriate forms and included as attachments to the Daily Field Investigation Form. If an incorrect entry is made, the information will be crossed out with a single line, initialed and dated by the field representative.

Whenever a sample is collected or a measurement is made, a detailed description of the sample location will be recorded on the Soil Sampling Form. The type of sampling equipment will be noted, along with sample time, sample description, sample depth, and volume and number of containers. Samples will be labeled uniquely and sequentially; as an example 2207-SS-01-07072004, Specific Site Location - Exploration Type - Sample Number - Date, where:

Specific Site Location should utilize the nearest building number or an abbreviation for the project area.

Exploration Type should use SS for soil sample, Sample Number should be chronological starting at 01 for all sites.

Date should be in MMDDYYYY format.

Copies of forms and records that will be used by the working party for this project are reproduced in Appendix B.

7.0 REFERENCES

Alaska Department of Environmental Conservation, 2010, Draft Field Sampling Guidance, May 2010.

Alaska Department of Environmental Conservation, 2002. Underground Storage Tanks Procedures Manual. Guidance for Remediation of Petroleum-Contaminated Soil and Standard Sampling Procedures.

November 7, 2002.

Alaska Department of Environmental Conservation, 2003. Oil and Hazardous Substances Pollution Control Regulations. 18 AAC 75. August 8, 2003.

Alaska Department of Environmental Conservation, 18 AAC 78, Underground Storage Tanks, January 30, 2003.

SGS QUALITY MANUAL.

8.0 LIST OF ACRONYMS

AAC - Alaska Administrative Code ADEC - Alaska Department of Environmental Conservation AFB - Air Force Base AK - Alaska BTEX – Benzene, Ethylbenzene, Toluene, and Xylenes CES - Civil Engineer Squadron CEOE -Maintenance Engineering Flight CERCLA - Comprehensive Environmental Response, Compensation and Liability Act CEAN -Environmental Engineering CFR - Code of Federal Regulations COC - Contaminants of Concern DCA - Dichloroethane DCE - Dichloroethene DDD - dichlorodiphenyldichloroethane DDE - dichlorodiphenyldichloroethylene DDT - dichlorodiphenyltrichloroethane DRO - Diesel Range Organics EPA - Environmental Protection Agency EWP - Environmental Work Plan FFA - Federal Facilities Agreement FID - Flame Ionization Detector GRO - Gasoline Range Organics HASP - Health and Safety Plan IDW - Investigative Derived Waste IRP - Installation Restoration Program MS - Matrix Spike MSD - Matrix Spike Duplicate NPL - National Priorities List OVM - Organic Vapor Meter QA - Quality Assurance QC - Quality Control PAH - Polycyclic Aromatic Hydrocarbon PCB - Polychlorinated Biphenyl PCDD - Polychlorinated Dibenzo-Dioxin PCDF - Polychlorinated Dibenzo-Furan PCS - POL Contaminated Soil PERP - Prevention and Emergency Response Program PID - Photo Ionization Detector POL – Petroleum, Oil, and Lubricants ppm - parts per million RCRA - Resource Conservation and Recovery Act RPD - Relative Percent Difference RRO - Residual Range Organics TCA - Trichloroethane TCE - Trichloroethene TCLP - Toxicity Characteristic Leaching Procedure TSCA - Toxics Substances Control Act USAF - United States Air Force UST - Underground Storage Tank VOC - Volatile Organic Compounds

9.0 TABLES

Table 1 Soil Cleanup Levels Eielson AFB, Alaska

Contaminant Type

Contaminant of Concern

Soil Clean Up Levels Criteria (mg/kg)

Gasoline Range Organics (GRO)

Diesel Range Organics (DRO)

Residual Range Organics (RRO)

Aromatic Hydrocarbons

Volatile Organic Compounds

Metals

Organochlorine Pesticides

Heavy Leaded Aviation Gasoline (AVGAS) Leaded Motor Vehicle Gasoline (MOGAS) Motor Fuels, Unleaded Regular (MUR)

Jet Fuels (Kerosene through JP4) Diesel Fuel, Arctic (DFA)

Engine Oils, All Grades Chassis Lubricants, All Grades

Benzene Toluene Ethylbenzene Xylenes (total)

Trichloroethene (TCE) 1,1-Dichloroethene (1,1-DCE) cis 1,2-Dichloroethene (cis 1,2-DCE) trans 1,2-Dichloroethene (trans 1,2-DCE) 1,1,1 Trichloroethane (1,1,1-TCA) 1,1 Dichloroethane (1,1-DCA) 1,2-Dichloroethane (1,2-DCA) Polychlorinated Biphenyls Vinyl Chloride

Lead

Aldrin Endrin Dieldrin

4,4’-DDE

4,4’-DDD

4-4’-DDT

11,000

0.025 6.5 6.9

0.020 0.03 0.24 0.37 0.82

0.016

0.0085

0.070 0.29

0.0076 5.1 7.2 7.3

Table 2 Sample Containers, Preservation and Analytical Methods Eielson AFB, Alaska

Notes:

Several of the 7000 series methods have been deleted from SW846 but these methods can be approved by ADEC project managers. Check laboratory’s approval status.

1 Unless otherwise noted, all preparation and analytical methods refer to the most current of EPA’s Test Methods for the Evaluating Solid Waste, Physical/Chemical Methods, SW-846, adopted by reference in 18 AAC 78.090(i).

2 Naphthalene can be analyzed by 80221B or 8260C, if naphthalene is the only PAH contaminant of concern; however methods 8270D or 8310 are preferred.

3 HDPE, High Density Polyethylene or amber glass sample collection bottles, certified clean for trace metals analysis.

4 May be analyzed out of AK101 methanol preserved sample, if not, then sample must be preserved with methanol in the field. Alternate volatile collection methods per SW-846 method 5035A must be approved on a site-specific basis by the CS program prior to sample collection.

5 PCBs must be prepared using extraction method 3540C or 3550C † Analytical method 6010C may used be for high contaminant level screening. These results can be used for closure only if laboratory reporting limits meet the site-specific cleanup levels. Analytical method 6020A is acceptable for closure.

* ADEC Analytical Methods AK101, AK102, and AK103 are included in Appendix D of the UST Procedures Manual.

** The AK101 method can be extended for specific determination of volatile aromatics (BTEX) as specified in EPA Method 8021B or 8260B for solids.

TLC = Teflon® lined screw caps TLS = Teflon® lined septa sonically bonded to screw caps

10.0 APPENDIX

Appendix A: Laboratory Quality Manual Appendix B: Forms and Records

Appendix A

Laboratory Quality Manual Attached Separate

Appendix B

Forms and Records

Daily Field Investigation Form

Date:___________________

Location:____________________________________Weather:__________

Today’s Activites:_____________________________________________________

Attendants on Site:

Comments:

Soil Sampling Form

Date:_________________

Field Equipment Used:________________________________________________________

Sample

ID#

Location Description Time Depth Volume # of

Containers