19QA019_-_(Attch_4)_WWTP_QAPP.pdf

THE UNITED STATES AIR FORCE

WASTEWATER TREATMENT FACILITY

QUALITY ASSURANCE PROJECT PLAN

Prepared for:

EIELSON AIR FORCE BASE, ALASKA

Delivery Order #FA8903-17-F-0422 Under Contract #FA8903-17-D-0056

April 2018

WWTF QAPP April 2018

Wastewater Treatment Facility

Quality Assurance Project Plan

A1. Approvals:

This QAPP is approved as part of the attached wastewater permit for the Wastewater Treatment Facility (WWTF):

Permit No. 2006DB0045

SIGNATURE ON FILE

ADEC Project Manager Signature Date

ADEC Quality Assurance Officer Signature Date

A2. Table of Contents

A1. APPROVALS:

A2. TABLE OF CONTENTS

INTRODUCTION

A3. DISTRIBUTION LIST

A4. PROJECT/TASK ORGANIZATION

A5. PROBLEM DEFINITION/BACKGROUND

A6. PROJECT/TASK DESCRIPTION

PRETREATMENT PROGRAM

EFFLUENT

GROUNDWATER

A7. DATA QUALITY OBJECTIVES AND CRITERIA FOR MEASUREMENT OF DATA

PROJECT DATA QUALITY OBJECTIVES

CRITERIA FOR MEASUREMENT OF DATA

ACCURACY

PRECISION

REPRESENTATIVENESS

COMPARABILITY

COMPLETENESS

A8. TRAINING AND CERTIFICATIONS

A9. DOCUMENTS AND RECORDS

B1. SAMPLING PROCESS DESIGN

PRETREATMENT PROGRAM MONITORING

EFFLUENT MONITORING

GROUNDWATER MONITORING

MONITORING OF BIOSOLIDS

B2. SAMPLING METHODS

GRAB SAMPLES

COMPOSITE SAMPLES

CLEANING

B3. SAMPLE HANDLING AND CUSTODY

B4. ANALYTICAL METHODS

B5. QUALITY CONTROL

B6. INSTRUMENT/EQUIPMENT TESTING, INSPECTION AND MAINTENANCE

B7. INSTRUMENT/EQUIPMENT CALIBRATION AND FREQUENCY

B8. INSPECTION/ACCEPTANCE OF SUPPLIES AND CONSUMABLES

B9. NON-DIRECT MEASUREMENTS - NOT APPLICABLE

B10. DATA MANAGEMENT

C1. ASSESSMENTS AND RESPONSE ACTIONS

C2. REPORTS TO MANAGEMENT

D1. DATA REVIEW, VALIDATION & VERIFICATION REQUIREMENTS

D2. VALIDATION AND VERIFICATION METHODS

D3. RECONCILIATION WITH USER REQUIREMENTS

REFERENCES

LIST OF TABLES

1 Sample Handling, Preservation, and Holding Times 2 Precision and Accuracy Limits

APPENDICES

APPENDIX A PERMIT

APPENDIX B LABORATORY QUALITY MANAGEMENT MANUALS

(To be added upon laboratory selection)

LIST OF ACRONYMS AND ABBREVIATIONS

oC degrees Celsius ADEC State of Alaska Department of Environmental Conservation AFB Air Force Base APDES State of Alaska Pollutant Discharge Elimination System APHA American Public Health Association CFR Code of Federal Regulations COC chain-of-custody DMR Discharge Monitoring Reports HCl hydrochloric acid L liter mL milliliter MS/MSD matrix spike/matrix spike duplicate PAHs polycyclic aromatic hydrocarbons PARCC precision, accuracy, representativeness, comparability, and completeness PFC Perfluorinated Compounds PCBs polychlorinated biphenyls PFOA Perfluorooctanoic acid PFOS Perfluorooctanesulfonic acid QA quality assurance QAPP Quality Assurance Project Plan QC quality control QMP Quality Management Plan %R percent recovery RPD relative percent difference SOP standard operating procedure SVOCs semivolatile organic compounds USEPA U.S. Environmental Protection Agency WQS State of Alaska Water Quality Standards WWTF Wastewater Treatment Facility VOCs volatile organic compounds

INTRODUCTION

This Quality Assurance Program Plan (QAPP) is a project-specific document developed for the Wastewater Treatment Facility (WWTF) at Eielson Air Force Base (AFB), Alaska. In specific terms, this QAPP presents the policies, organization, functions, and quality assurance/quality control (QA/QC) requirements designed to ensure that the data used in project decision making are scientifically valid and defensible, and establishes the protocols and documentation requirements necessary to ensure that data are collected, reviewed, and analyzed in a consistent manner. In conjunction with the permit conditions presented in Appendix A and the laboratory Quality Management Plan presented in Appendix B, the QAPP will guide the technical and quality aspects of the field and laboratory activities conducted for the monitoring program and ensure that quality and consistency are maintained.

This QAPP is required reading for the personnel participating in the project. The project personnel will comply with the procedures as written and approved in the QAPP to maintain the comparability and representativeness of the data collected in support of this project.

The QAPP is a dynamic document and will be revised or updated to reflect any changes in organization and procedures.

The QAPP was prepared in accordance with the following United States Environmental Protection Agency (USEPA) guidance:

• Policy and Program Requirements for the Mandatory Agency-wide Quality System, USEPA Order 5360.1 A2 (USEPA, 2000)

• EPA Requirements for Quality Assurance Project Plans, EPA QA/R-5 (EPA/240/B-

01/003) (USEPA, 2001)

• Guidance for Quality Assurance Project Plans, EPA QA/G-5 (EPA/240/R-02/009)

(USEPA, 2002)

In addition, the following documents were used as source documents in the preparation of this

QAPP:

• Methods for the Determination of Metals in Environmental Samples, Supplement 1

(EPA/600/R-94/111) (USEPA, 1994)

• Methods for the Determination of Inorganic Substances in Environmental Samples

(EPA/600/R-93/100) (USEPA, 1993)

• Methods for Chemical Analysis of Waters and Wastes (EPA-600/4-79-020) (USEPA, 1983)

• Standard Methods for the Examination of Water and Wastewater, 20th Edition (American Public Health Association [APHA] et al., 1999)

A3. Distribution List

This QAPP will be provided to those responsible for permit implementation. It will remain attached to and be distributed with copies of the wastewater disposal permit.

A4. Project/Task Organization

Duties and responsibilities of key individuals are listed below:

Eielson Air Force Base Project Manager - Responsible for the implementation of permit and certification requirements.

Eielson Air Force Base QA Officer – Responsible for QA/QC of the self-monitoring required under the permit.

Contractor Project Manager - Responsible for the implementation of permit and certification requirements.

Contractor Project Chemist – Responsible for the review of the analytical data generated as specified under the permit.

Analytical Laboratory Project Manager – Responsible for water quality analysis.

Analytical Laboratory QA Officer – Responsible for QA/QC of water quality analyses under federal and state certification.

State of Alaska Department of Environmental Conservation (ADEC) Project Manager – Primary contact regarding permit and monitoring requirements. Receives Discharge Monitoring Reports (DMR) reports.

ADEC, Division of Water Wastewater Discharge Authorization Program 555 Cordova Street Anchorage, AK 99501

(907) 269-6285

ADEC QA Officer – Reviews and approves this QAPP for ADEC along with the ADEC Project Manager. May review data or audit permittee’s monitoring activities.

Water Quality Standards, Assessment, and Restoration 610 University Avenue Fairbanks, AK 99708

(907) 451-2726

ADEC – State of Alaska Pollutant Discharge Elimination System (APDES) permit development and approval. Receives DMR reports.

Compliance Program 555 Cordova Street Anchorage, AK 99501

(907) 269-6285 dec-wqreporting@alaska.gov

A5. Problem Definition/Background

Eielson AFB WWTF accepts domestic and nondomestic influent that receives primary treatment from screens, a seasonal grit trap, and three parallel clarifiers. A series of three aerated lagoons provides secondary treatment. Each lagoon consists of two cells. A mixed oxidizer generation system disinfects secondary treated wastewater before it is discharged into a gravel pit, which provides wastewater polishing as the final step in the treatment process. The gravel pit is maintained as part of the WWTF, including prevention of its overflow and restricting public access. Environmental monitoring will be performed to verify compliance with the most current version of the WWTF Disposal Permit.

This QAPP ensures that the data collected and analyzed under this permit are valid and verifiable. If implemented correctly, this QAPP provides the level of precision, accuracy, and representativeness that yields data to help ensure that State of Alaska Water Quality Standards (WQS) are met and that water quality uses (public health and public resource protection) are protected.

A6. Project/Task Description

The following section describes the monitoring to be performed at the Eielson AFB WWTF in compliance with the permit conditions.

Pretreatment Program Due to the variety and magnitude of non-domestic wastewater contributions to the WWTF, which create a reasonable potential that WQS might be exceeded, a pretreatment program will be implemented to control the flow of toxic substances into the WWTF. Representative sampling and analysis of influent prior to treatment at the WWTF as well as effluent at the discharge line prior to release to the gravel pit will be performed as described in the Pretreatment Plan and the WWTF Disposal Permit.

Effluent Secondary treated, disinfected domestic and non-domestic wastewater will be discharged from the wastewater stabilization ponds at Eielson AFB WWTF. Although groundwater monitoring wells represent compliance points for meeting the WQS, end-of-pipe limits have also been established in the WWTF Permit. Representative effluent samples will be collected from the discharge pipe prior to release into the gravel pit.

mailto:dec-wqreporting@alaska.gov

Groundwater Downgradient monitoring wells constitute compliance points for compliance with the WQS. Groundwater monitoring is performed at four wells, one upgradient and three downgradient. In addition, samples will be collected at the discharge line prior to release to the gravel pit.

A7. Data Quality Objectives and Criteria for Measurement of Data

Project Data Quality Objectives The data quality objective of this QAPP is to ensure that the data collected and analyzed are scientifically verifiable and valid, and can be used to determine compliance with the requirements of the permit.

Criteria for Measurement of Data Criteria for measurements of data are the performance criteria: the precision, accuracy, representativeness, comparability, and completeness (PARCC) parameter evaluations of the tests. These criteria must be met to ensure that the data are verifiable and that project data quality objectives are met.

The objectives for PARCC parameters are summarized in this section. The results will be recorded in field and laboratory logbooks. Additional sampling and analyses will be performed if results fall outside the specified ranges and when data quality objectives are not met. Proposed changes in data quality objectives will be submitted to ADEC for approval before implementation.

Note: The ADEC Water QA Officer keeps copies of the laboratory’s Quality Management Plan (QMP) on file. The QMP describes the laboratory measurement criteria. Therefore, QA/QC measures described in a contracted laboratory QMP are not repeated in this document.

Accuracy Accuracy is a measure of confidence that describes how close a measurement is to its “true” value.

Field accuracy is ensured by field instrument calibration according to the manufacturers’ instructions and by using standards and chemicals that are current (prior to expiration date), and by following proper sampling, sample handling and field analysis protocols.

Laboratory accuracy is normally determined by the percent recovery of the target analyte in spiked samples and also by the recoveries of the surrogates in the field and QC samples.

Accuracy is calculated as follows:

%R = Analyzed value x 100 true value

Where %R = percent recovery

Laboratory accuracy ranges are based upon control charts of historical data and are specified in the contracted laboratory QMP (kept on file at ADEC) and depend on the parameter being measured. The QA Officer will ensure that the analytical laboratory maintains accuracy by review of the laboratory’s in-house %R control limits and the results of QC samples analyzed with project samples.

The analytical laboratory will also maintain records of performance evaluation results on file and these results will be made available for review by ADEC upon request.

Precision Precision is the degree of agreement among repeated measurements of the same characteristic, or parameter, and gives information about the consistency of methods. Precision can be considered a product of the repetitiveness of monitoring.

Precision is expressed in terms of the relative percent difference (RPD) between two measurements (A and B), and is computed as follows:

RPD = A – B x 100

(A + B)/2

Field precision is measured by collecting and analyzing field duplicate samples.

Laboratory precision is ensured by measuring matrix spike/matrix spike duplicate (MS/MSD) samples and by the analysis of laboratory duplicate samples. The laboratory usually performs the analysis of one set of MS/MSD and duplicate samples per matrix measured. The control limit RPD is usually <20% but can vary widely depending on the analytical method. Control charts are a graphical representation showing the limits of acceptable data. The QA Officer will ensure that the analytical laboratory maintains precision by review of the laboratory’s in-house RPD control limits and the results of QC samples analyzed with project samples.

Analysts produce charts to document accuracy and precision in their testing. These charts are kept in the laboratory for data validation purposes. The Laboratory Project Manager will provide accuracy and precision records to ADEC upon request.

Representativeness Representativeness is the extent to which measurements actually represent the true environmental condition. The representativeness of the data collected was considered in the permit development process.

Comparability Comparability is the degree to which data can be compared directly to similar studies. Using standardized sampling and analytical methods and units of reporting with comparable sensitivity ensures comparability. USEPA-approved methods as listed in 40 Code of Federal Regulations (CFR) Part 136.3 will be used for standard measurements.

Completeness The completeness is the comparison between the amount of usable data collected versus the amount of data called for in the permit or certification. The completeness will be determined by comparing sampling and analyses with the requirements in the permit.

A8. Training and Certifications

The field sampling team as well as the analytical laboratory personnel will be trained in sampling methods, sample handling, chain-of-custody documentation, sample transport, and field and/or laboratory measurements. The Project Manager and/or the QA Officer are responsible for the training of staff that performs sampling, sample handling, and analyses activities. Records will be kept on file of these training activities and may be reviewed by ADEC.

A9. Documents and Records

Field logbooks, notebooks and/or data sheets will be filled out using waterproof and indelible ink and should not be erased. Changes must be made by crossing out errors and adding correct information. Logbooks should be bound with numbered pages.

Laboratory data results are recorded on laboratory data sheets, bench sheets and/or in laboratory logbooks for each sampling event. These records as well as control charts, logbook records of equipment maintenance records, calibration and quality control checks, such as preparation and use of standard solutions, inventory of supplies and consumables, check in of equipment, equipment parts, and chemicals are kept on file at the laboratory.

Procedural or equipment problems are recorded along with data results. Deviations from this QAPP are noted. Additional sampling and analyses will be performed when results fall outside the specified range and when DQOs are not met. Data results returned to ADEC will include information on field and/or laboratory QA/QC problems and corrective actions.

Chain-of-custody (COC) records will be kept with the sample transport, and will accompany the data results back to ADEC.

Training records and data review records will be kept on file in the field sampling team’s office as well as at the analytical laboratory and will be made available on request by ADEC.

The project records and documents are kept at least five years at the field sampling team’s office and the analytical laboratory and are available to USEPA and ADEC for inspection at any time.

B. Data Generation and Acquisition

B1. Sampling Process Design

Pretreatment Program Monitoring Monitoring will be performed in accordance with the Pretreatment Plan. The testing to be performed according to the requirements of the Pretreatment Plan include: volatile organic compounds (VOCs) including chlorofluorocarbons, polycyclic aromatic compounds (PAHs) (combustion byproducts), semivolatile organic compounds (SVOCs), pesticides, polychlorinated biphenyls (PCBs), herbicides, metals, cyanide, dioxins and furans, and fluoride.

In April 2018, Perfluorinated Compound (PFC) testing for PFOS and PFOA was added to the WWTF QAPP. As of April 2018, ADEC wastewater discharge monitoring requirements and discharge limits for PFCs are not included in permit requirements, however, they are included in this section for reference. The PFOS and PFOA limits are established in 18 AAC 75 .340 Table C (ADEC 2017) and are included below with footnotes.

Hazardous Substance Groundwater Human Health Cleanup Level2 (micrograms/liter)

Perfluorooctane Sulfonate (PFOS)9 0.40 Perfluorooctanoic Acid (PFOA)9 0.40

2. The “Human Health” exposure pathway is the cumulative exposure pathway through dermal contact, ingestion, and inhalation of volatile compounds from hazardous substances in the water.

9. Toxicity values for PFOS and PFOA were sourced from EPA’s Health Effects Support Document for Perfluorooctane Sulfonate (PFOS) (EPA 922-R-16-002), dated May 2016, and Health Effects Support Document for Perfluorooctanoic Acid (PFOA) (EPA 822-R-16-003), dated May 2016.

The suite of analysis for each source is dependent upon the probable pollutant for each source.

The methods for these analyses are presented in Table 2.

Effluent Monitoring Monitoring will be performed in accordance with the Disposal Permit. Methods will be according to 40 CFR 136.3 or equivalent (See Table 2).

Groundwater Monitoring

Monitoring will be performed in accordance with the Disposal Permit. Methods will be according to 40 CFR 136.3 or equivalent (See Table 2).

Monitoring of Biosolids Monitoring of biosolids will be performed in accordance with the Sludge Management Plan and the Solid Waste Permit No. SWZA020-14.

B2. Sampling Methods

Samples and measurements taken as required by permit must be representative of the volume and nature of the monitored discharge.

When a sample is taken at a discharge line, a volume of water equal to at least ten times the volume of the sample discharge line will first be discharged into a bucket or similar container, to clear the line of standing water and possible contamination. If there is no discharge line faucet, the sampler may take the sample from the final effluent chamber, taking all safety and contamination-prevention precautions.

Samples will be identified as “composite” or “grab” on COC records and in field logbooks and field data sheets.

Grab Samples Bottles will normally be filled to the shoulder of the bottle, leaving a small space for expansion and mixing.

WWTF QAPP June 2011

Composite Samples Composite samples must consist of at least four equal volume grab samples, two of which must be taken during periods of peak flow (7-9 a.m. and 6-8 p.m.). Samples will be composited directly into the sample bottles. Between composite aliquots, bottles will be kept at a temperature of less than 6 degrees Celsius (oC).

The time of the initial portion of the composite, composite intervals, and the final compositing time will be noted on the field data sheets and/or in logbooks. Sample time listed on the COC record and sample bottle will be the time of the final sample composite portion.

Cleaning The sampling equipment and sample containers will be cleaned according to the equipment specifications or the analytical laboratory.

Glassware and plasticware cleaned at the analytical laboratory will implement the following procedure unless otherwise noted.

• Wash glassware and plasticware with phosphate-free detergent and rinse with tap water.

• Rinse with 10% hydrochloric acid (HCl).

• Rinse four times with deionized water.

B3. Sample Handling and Custody

Sample handling, preservation, and holding times will follow those approved by the USEPA in 40 CFR 136.3, as described in Standard Methods for the Examination of Water and Wastewater, 20th Edition, 1999, or most recent edition. Sample container, minimum sample volume, preservation, and maximum storage requirements for each parameter are listed in Table 1 below.

When samples are transferred to an outside contracted analytical laboratory, COC records will be completed. When samples are transferred between personnel, such transfer will be indicated on the form with signature, date, and time of transfer. The COC record will remain with the samples, sealed inside the cooler, until receipt by the contracted laboratory. Samples and sample containers will be maintained in a secure environment from the time the bottles leave the facility until the time the samples are received at the contracted laboratory. The contracted laboratory will maintain custody of bottles and samples using their normal custody procedures, as described in the QMP.

TABLE 1. Sample Handling, Preservation, and Holding Times.

Parameter Container1 Minimum Sample volume Preservation2

Maximum Holding Time3

VOCs G (3) 40 mL VOA vial

HCl to pH<2, cool, <6ºC

14 days

SVOCs G (2) 1-L amber Cool, <6ºC 7 days PAHs G (2) 1-L amber Cool, <6ºC 7 days Organochlorine Pesticides

G (2) 1-L amber Cool, <6ºC 7 days

Organophosphorus Pesticides

G (2) 1-L amber Cool, <6ºC 7 days

PCBs G (2) 1-L amber Cool, <6ºC 7 days Herbicides G (2) 1-L amber Cool, <6ºC 7 days Dioxins and Furans

G (2) 1-L amber Cool, <6ºC 7 days

Cyanide P 500 mL NaOH to pH>12 14 days Fluoride P 100 mL Cool, <6ºC 28 days Total Recoverable Metals (except mercury)

P 200 mL HNO3 to pH<2 180 days

Mercury P 200 mL HNO3 to pH<2 28 days Biochemical Oxygen Demand

P, G, FP 2.5 L Cool, <6ºC, 48 hours

Total Suspended Solids

P, G, FP 200 mL Cool, <6ºC, 7 days

Total Chlorine (residual)

P, G NA NA Analyze immediately in field

Fecal Coliform Bacteria

Sterile Plastic, G 500 ml Cool, <6ºC, Na2 S2 O3

6 hours pH P, G, FP NA NA Analyze immediately

Temperature P, G, FP NA NA Analyze immediately

Ammonia P, G, FP 500 ml Cool, <6ºC, H2 SO4 to pH<2

28 days

Dissolved Oxygen G 300 ml None required Analyze immediately

Anions (chloride, sulfate)

P 200 mL None required 28 days

Nitrate P 200 mL Cool, <6ºC, 48 hours

Total Dissolved Solids

P 200 mL Cool, <6ºC, 7 days

Chemical Oxygen Demand

P 200 mL Cool, <6ºC, H2 SO4 to pH<2

28 days

Total Organic Carbon

G (3) 40 mL VOA vial

HCl to pH<2, cool, <6ºC

28 days

Oil and Grease G (2) 1-L amber Cool, <6ºC, H2 SO4 to pH<2

28 days

PFOS/PFOA5 HDPE (2) 125 ml HDPE

Cool, <6ºC 28 days

Superscripts:

1. Polyethylene (P) or glass (G). Samples are normally collected in polyethylene containers to prevent breakage. (FP) is fluoropolymer (polyfluorotetraethylene (PTFE; Teflon)).

2. Sample preservation should be performed immediately upon collection. For composite chemical samples, each aliquot should be preserved at the time of collection. When use of an automated sampler makes it impossible to preserve each aliquot, then chemical samples may be preserved by maintaining at <6ºC until composite sample splitting is completed.

3. Sample should be analyzed as soon as possible after collection. The times listed are maximum times that samples may be held before analysis and still be considered valid. The term “analyze immediately” usually means within 15 minutes or less of sample collection.

4. Should only be used in presence of residual chlorine..

5. Perfluorinated compounds must be collected in strict conformance with laboratory guidance to avoid contamination with fluorinated materials such as Teflon, Tyvek, Gore-Tex, and blue gel ice.

H2 SO4 =sulfuric acid HCl =hydrochloric acid Na2 S2 O3 =sodium thiosulfate VOA = volatile organic analyte

B4. Analytical Methods

USEPA-approved methods as found in 40 CFR Part 136.3 or its updates (or equivalent) will be used (see Table 2 below). Potential modifications will be discussed with ADEC and will be described in an addendum to this QAPP.

Contracted laboratories will follow test procedures for the analysis of pollutants, which are USEPA-approved methods as cited in 40 CFR Part 136.3 or as such regulations are amended.

Contracted laboratories will provide copies of their standard operating procedures (SOPs) to ADEC as requested. As previously stated, laboratory QMPs are kept on file at the office of the ADEC Water QA Officer. Parameters and approved methods as well as precision and accuracy limits are shown in Table 2, “Precision and Accuracy Limits.”

Table 2. Precision and Accuracy Limits Parameter Approved Test Procedures1

Precision (RPD) Accuracy (% R) VOCs SW8260B See laboratory limits See laboratory limits

SVOCs SW8270C See laboratory limits

See laboratory limits

PAHs SW8270C selected ion monitoring mode

See laboratory limits

See laboratory limits

Organochlorine Pesticides SW8081A See laboratory limits

See laboratory limits

Organophosphorus Pesticides

SW8141B See laboratory limits

See laboratory limits

PCBs SW8082 See laboratory limits

See laboratory limits

Herbicides SW8151A See laboratory limits

See laboratory limits

Dioxins and Furans SW8290 See laboratory limits

See laboratory limits

Cyanide SM4500 series See laboratory limits

See laboratory limits

Fluoride SM4500 series See laboratory limits

See laboratory limits

Total Recoverable Metals (with the exception of mercury)

USEPA 200.7 or 200.8 <20 80-120

Mercury USEPA 245.1 <20 80-120 Biochemical Oxygen Demand

SM5210B <30 NA

Total Suspended Solids SM2540C <20 85-115 Total Chlorine (residual) SM4500 series <30 NA Fecal Coliform Bacteria SM9222D or SM9221C or E NA NA pH SM4500-H+ B 0. 1 pH units NA Temperature SM2550B <10 NA Total Ammonia USEPA 350.1 <30 70-130 Dissolved Oxygen SM4500 <30 NA

Anions (chloride, sulfate) E300.0 See laboratory limits See laboratory limits

Nitrate E300.0, 352.1, or SM4500-NO3 D See laboratory limits See laboratory limits

Total Dissolved Solids SM2540D <20 See laboratory limits Chemical Oxygen Demand SM5220C or D <20 See laboratory limits Total Organic Carbon SM5310C <20 See laboratory limits Oil and Grease 1664A <20 See laboratory limits PFOS/PFOA USEPA 537 Modified See laboratory limits See laboratory limits

Footnotes:

1. "SM" means Standard Methods for Examination of Water and Wastewater, 18th, 19th, 20th or online editions.

"USEPA" means Methods for Chemical Analysis of Water and Wastes, EPA-600/4-79-020, March 1983.

"EPA SW-846" means Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, 3rd Edition.

WWTF QAPP March 2018

B5. Quality Control

Field duplicate samples will be collected for analysis at a minimum frequency of ten percent.

Variation of duplicate values for each parameter must not exceed the range of precision and accuracy discussed in Section A.7, “Data Quality Objectives and Criteria for Measurement of Data,” and Table 2 above. Problems found with data collected are noted on the data sheets and in laboratory logbooks. The Project QA Officer or designee initials any changes to data.

The performance evaluation results are kept on file at the analytical laboratory and will be available for review by ADEC upon request.

B6. Instrument/Equipment Testing, Inspection and Maintenance

Before each sampling and analysis event, instruments and equipment to be used for field monitoring will be inspected prior to use. Testing instruments and equipment will be clean and in good working order before use in monitoring.

The routine maintenance for meters for measuring parameters designated as field tests will be conducted according to schedules and procedures described in manuals provided by the manufacturer and a maintenance log will be kept for each instrument.

A supply of replacement equipment and reagents is kept in the laboratory. This supply includes extras of commonly lost or broken equipment and enough reagents to perform scheduled analysis procedures for at least three months. Reagent stocks are rotated out every four to six months or according the manufacturer’s recommendation.

This information will be recorded on data sheets and in laboratory logbooks and will be available to ADEC for review upon request.

B7. Instrument/Equipment Calibration and Frequency

Field and laboratory instruments and equipment will be calibrated according to the manufacturers’ instructions. Records of calibration dates will be kept on calibration log sheets and will be available for review by ADEC upon request.

B8. Inspection/Acceptance of Supplies and Consumables

Chemicals will be checked for expiration date, sufficient quantity, and discoloration.

Equipment, meters, kits and supplies will be checked upon receipt by the QA Officer or designee to ensure that they are within technical specifications before use. Each reagent will be dated with the expiration date. Documentation including reagent expiration dates will be completed and kept on file in the laboratory. This form will be updated each time new or replacement equipment or reagents are received, and will be available to ADEC for review upon request.

B9. Non-Direct Measurements - Not Applicable

B10. Data Management

The data will be entered onto field data sheets and into laboratory logbooks and bench sheets.

The QA Officer or his designee will enter data into the DMR form after each monitoring event.

The following is a list of data information records that are kept available at the analytical laboratory for ADEC review upon request:

• Training records

• Field equipment and chemicals maintenance, cleaning and calibration records

• Field logbooks and/or field data sheets

• COC records

• Laboratory equipment and reagents maintenance, cleaning, and calibration records

• Laboratory bench sheets, control charts, and SOPs

• Records of QA/QC problems and corrective actions (field and/or laboratory)

• Laboratory data QC records

• Records of data review sheets

• Duplicate, split sample, performance evaluation records and other QA/QC control records (field and laboratory)

• Assessment records

• Data review, verification and validation records

Whenever possible data results will be entered electronically and transferred electronically to avoid transcription errors.

C. Assessment and Oversight

C1. Assessments and Response Actions

The QA Officer or designee will ensure that the field and laboratory forms are complete when checked for any errors. Approximately ten percent of the data sheets or logbook entries will be checked against the DMR entries. If errors are found, the QA Officer or designee will verify correct entry by comparing another ten percent of the sheets.

Should the sampling staff, laboratory personnel, QA Officer, or designee find errors in sampling or analysis, the QA Officer will notify the Project Manager and the party responsible for the error or deficiency, and will recommend methods of correcting the deficiency. The responsible party will then take action to correct the problem and will report corrections to the QA Officer and Project Manager. See above for how this information is recorded and reported.

The QA Officer or designee will monitor the field duplicate sampling and analysis activities and will review these results. The QA Officer will keep these assessment records available for review by ADEC.

Additionally, the facility and the analytical laboratory may be inspected and/or audited regularly by ADEC or USEPA.

C2. Reports to Management

The monitoring results are summarized on the DMR included in the permit and are submitted to ADEC after each event (an example DMR form is found in the appendices to the permit).

Assessment reports will be submitted by the Project QA Officer to the Project Manager as needed. Identified improvements to QA/QC will be implemented as necessary. Records of changes will be available for ADEC review. ADEC will be notified if changes/improvements require an amended QAPP.

D. Data Validation and Usability

D1. Data Review, Validation & Verification Requirements

The QA Officer will perform quality checks of data packages to detect correctable problems.

Problems noted will be immediately brought to the attention of the Project Manager. Items to be checked include data sheets, logbooks, data entry, DMRs, calibration logs, and COC records.

Questions to be considered during these quality checks include:

• Were correct methods used?

• Were holding times met?

• Were accuracy and precision within data quality objectives?

• Were reporting limits correct?

• Were lab qualifiers provided and explanations and corrective actions taken if there were anomalies in the data?

• Was the data package as a whole for each sampling event complete?

D2. Validation and Verification Methods

The QA Officer will check the accuracy and precision of data to ensure that data quality objectives are being met.

Data sheets and/or logbooks must be completely filled out and signed at the time of sampling and analysis. The QA Officer or designee will review data sheets and/or logbooks for accuracy, precision, missing or illegible information, errors in calculation, and values outside the expected range. Any questionable data will be brought to the attention of the field and/or laboratory personnel for resolution. The QA Officer will initial any changes made to the data, and any action taken as a result of the data review will be specifically recorded on the data sheet.

If data quality indicators do not meet specifications (see Section A7., “Data Quality Objectives and Criteria for Measurement of Data” and Table 2), the cause of the failure will be evaluated. If the cause is equipment failure, calibration and maintenance procedures will be reassessed and improved. If the problem is procedural error, the QA Officer will review methods used. If accuracy and precision goals are frequently not being met, QC procedures will be reviewed and, subject to ADEC approval, may be revised.

The QA Officer or his designee will review equipment maintenance logs, sample custody forms and equipment/supply inventory and inspection forms on a regular basis.

The verification of data accuracy will be made by the QA Officer during regular QC checks, replicate analysis, and split sampling checks. The QA Officer will make calculations and determinations for precision and completeness. The results of accuracy, precision, and completeness calculations will be kept on file at the laboratory.

D3. Reconciliation with User Requirements

The Project Manager and QA Officer will review the permit monitoring requirements on an annual basis. Problems with quality sampling and analysis will be discussed with ADEC to ensure that permit requirements and QAPP data quality objectives are met. Modifications to monitoring required by permit will require modifications to the approved QAPP.

REFERENCES

Alaska Department of Environmental Conservation (ADEC), 2018.

18 AAC 75 Oil and other Hazardous Substances Pollution Control. October.

American Public Health Association [APHA], American Water Works Association, and the Water Environment Federation, 1999. Standard Methods for the Examination of Water and Wastewater.

20th Edition. January.

U.S. Environmental Protection Agency (USEPA), 1983. Methods for Chemical Analysis of Water and Wastes. EPA-600/4-79-020. Environmental Monitoring and Support Laboratory. March.

USEPA, 1993. Methods for the Determination of Inorganic Substances in Environmental Samples.

EPA/600/R-93/100. Environmental Monitoring Systems Laboratory. August.

USEPA, 1994. Methods for the Determination of Metals in Environmental Samples, Supplement I.

EPA-600/R-94/111. Environmental Monitoring Systems Laboratory. May.

USEPA, 2000. Policy and Program Requirements for the Mandatory Agency-wide Quality System, USEPA Order 5360.1 A2. May.

USEPA, 2001. EPA Requirements for Quality Assurance Project Plans, EPA QA/R-5. EPA/240/B- 01/003. Office of Environmental Information, Washington D.C. March.

USEPA, 2002a. Guidance for Quality Assurance Project Plans, EPA QA/G-5. EPA/240/R-02/009.

Office of Environmental Information, Washington D.C. December.

APPENDIX A

PERMIT

DEPARTMENT OF ENVIRONMENTAL CONSERVATION

DIVISION OF WATER

WASTEWATER DISCHARGE PROGRAM

FRANK H. MURKOWSKI, GOVERNOR

610 University Avenue Fairbanks, AK 99709-3643

PHONE: (907) 451-2360

FAX: (907) 451-2187

http://www.state.ak.us/dec

November 3, 2006 File: 107.45.001 Lieutenant Colonel David A. Martinson Base Civil Engineer

354 CES/CC

2310 Central Avenue, Suite 100 Eielson AFB, AK 99702-2299

Certified Mail # 7004 1160 0004 2848 7318 Return Receipt Requested

Re: Wastewater Disposal Permit No. 2006DB0045 for Eielson Air Force Base (AFB) Wastewater Treatment Facility

Dear Lieutenant Colonel Martinson:

The Alaska Department of Environmental Conservation (Department) completed its review of the request from Eielson AFB for the renewal of Wastewater Disposal Permit No. 0031-DB067 and hereby issues Wastewater Disposal Permit No. 2006DB0045.

This permit is effective on November 3, 2006 and expires after November 2, 2011. Please review the conditions and stipulations in this permit, and ensure that they are all understood.

Any person who disagrees with this decision may request an adjudicatory hearing in accordance with 18 AAC 15.195 - 18 AAC 15.340 or an informal review by the Division Director in accordance with 18 AAC 15.185. An informal review request must be delivered to the Director, Division of Water, 555 Cordova Street, Anchorage, AK 99501, within 15 days of receipt of the permit decision. An adjudicatory hearing request must be delivered to the Commissioner of the Department of Environmental Conservation, 410 Willoughby Avenue, Suite 303, Juneau, Alaska 99801, within 30 days of the permit decision. If a hearing is not requested within 30 days, the right to appeal is waived.

A fee is required for your wastewater permit, in accordance with 18 AAC 72. A separate invoice will be mailed to your facility.

Sincerely, Sharmon Stambaugh Wastewater Discharge Program Manager enc.: Permit No. 2006DB0045

QAPP

http://www.state.ak.us/dec cc: Frances Isgrigg, EAFB, 354 CES/CC Tim Wingerter, ADEC, Fairbanks

Permit: 2006DB0045 Effective Date: November 3, 2006 Expires After: November 2, 2011

Issued to: United States (U.S.) Air Force

Facility Name: Eielson Air Force Base (AFB) Wastewater Treatment Facility (WWTF) Location of Discharge: 2081 Kijik Loop, Eielson AFB, Alaska

Latitude: 64° 41’ 46” N Longitude: 147° 07’ 17”W

Surface Discharged to:

Maximum Volume:

Treatment System Description:

subsurface discharge through a gravel pit

2 million gallons per day (mgd)

Domestic and non-domestic WWTF influent receives primary treatment from screens, a seasonal grit trap, and three parallel clarifiers. Then, a series of three aerated lagoons provides secondary treatment. Each lagoon consists of two cells. A mixed oxidizer generation system disinfects secondary treated wastewater before it is discharged into a gravel pit, which provides wastewater polishing as the final step in the treatment process. The gravel pit must be maintained as part of the WWTF, including prevention of its overflow and restricting public access. Downgradient monitoring wells constitute compliance points for meeting Alaska Water Quality Standards (WQS). At least four monitoring wells, one upgradient and three downgradient, are required. Due to the variety and magnitude of non-domestic wastewater contributions to the WWTF, which create a reasonable potential that WQS might be exceeded, a pretreatment program must be implemented to control the flow of toxic substances into the WWTF.

This permit is subject to the conditions and stipulations incorporated herein. This Alaska Department of Environmental Conservation (Department) wastewater discharge permit is issued in accordance with AS 46.03 and 18 AAC 15. It may be terminated or modified in accordance with AS 46.03.120.

The following reporting forms are located at the end of the permit: a discharge monitoring report (DMR), a noncompliance notification, and an accidental discharge / sewage spill notification. Submit DMRs to the Department on the enclosed form or using the same format.

Sharmon Stambaugh Wastewater Discharge Program Manager

Eielson AFB WWTF Permit No. 2006DB0045

- 2 -

TABLE OF CONTENTS

1. SPECIFIC PERMIT CONDITIONS

1.1. PRETREATMENT PROGRAM

1.1.1. DISCHARGE RESTRICTIONS

1.1.2. LIMITS & MONITORING

1.1.3. REPORTING

1.2. EFFLUENT LIMITS, MONITORING, & REPORTING

1.2.1. DISCHARGE RESTRICTIONS

1.2.2. LIMITS & MONITORING

1.2.3. REPORTING

1.3. GROUNDWATER LIMITS, MONITORING, & REPORTING

1.3.1. MONITORING WELLS

1.3.2. LIMITS & MONITORING

1.3.3. REPORTING

1.4. OTHER REQUIREMENTS

1.4.1. QUALITY ASSURANCE PROJECT PLAN

1.4.2. COMPLIANCE WITH ALASKA ADMINISTRATIVE CODE

1.4.3. CHANGE IN DISCHARGE

1.4.4. ADDITIONAL MONITORING

1.4.5. REPRESENTATIVE SAMPLING

1.4.6. REPORTING

2. MANAGEMENT PRACTICES

2.1. PROPER OPERATION AND MAINTENANCE

2.2. REMOVED SUBSTANCES

2.3. AIR AND LAND RELEASES

2.4. RECORDS RETENTION

2.5. CHANGE IN DISCHARGE

2.6. TOXIC POLLUTANTS

2.7. ACCIDENTAL DISCHARGE AND SPILL REPORTING

2.8. NONCOMPLIANCE NOTIFICATION

2.9. TRANSFER OF OWNERSHIP

3. GENERAL PERMIT CONDITIONS

3.1. ACCESS AND INSPECTION

3.2. INFORMATION ACCESS

3.3. CIVIL AND CRIMINAL LIABILITY

3.4. ADVERSE IMPACT

3.5. CULTURAL OR PALEONTOLOGICAL RESOURCES

3.6. APPLICATIONS FOR RENEWAL

3.7. OTHER LEGAL OBLIGATIONS

3.8. POLLUTION PREVENTION

DISCHARGE MONITORING REPORT

NONCOMPLIANCE NOTIFICATION

ACCIDENTAL DISCHARGE / SPILL NOTIFICATION

ATTACHMENT A: QUALITY ASSURANCE PROJECT PLAN

- 3 -

1. SPECIFIC PERMIT CONDITIONS

1.1. PRETREATMENT PROGRAM

1.1.1. DISCHARGE RESTRICTIONS

1.1.1.1.

1.1.1.2.

The Permittee must control the flow of toxic substances into the wastewater lagoons through an effectively designed and implemented pretreatment program. The pretreatment program shall target the removal of contaminants in the non-domestic wastewater that may cause problems in the collection system, the WWTF, or the outside environment.

The pretreatment program must comply with the Federal Prohibited Discharge Standards (40 CFR 403.5). These standards have both general and specific prohibitions. The general prohibitions forbid pollutants to be discharged into the sewage system if they can pass through the treatment facility untreated or if they interfere with the facility operations.

Regarding specific prohibitions, the following shall not be introduced to the WWTF:

1.1.1.2.1. pollutants that create a fire or explosion hazard in the collection system or treatment facility,

1.1.1.2.2. pollutants that are corrosive, including any discharge with a pH lower than 5,

1.1.1.2.3. solid or viscous pollutants in amounts that will obstruct the flow in the collection system and treatment facility interfering with operations.

1.1.1.2.4. any pollutant discharged in quantities sufficient to interfere with facility operations,

1.1.1.2.5. heat that interferes with the biological treatment process, including quantities of influent causing the water temperature at the treatment facility to exceed 104o F (40o C),

1.1.1.2.6. petroleum products in amounts that interfere with or pass through the treatment process,

1.1.1.2.7. pollutants that result in toxic vapors, gases, or fumes in quantities that may cause acute worker health or safety problems at the treatment facility, or

1.1.1.2.8. any trucked or hauled pollutants, except at discharge points designated by the treatment facility.

1.1.2. LIMITS & MONITORING

1.1.2.1.

1.1.2.2.

The Permittee shall develop a pretreatment plan identifying all process (non-domestic) wastewater and associated pollutants discharged into the WWTF and develop limits for those pollutants.

Annually, the pretreatment plan shall be reviewed to evaluate changes in non-domestic water contributions to the WWTF and impacts on the

- 4 -pretreatment program. The pretreatment plan shall either be updated to incorporate pollutant impacts of non-domestic water handling changes or appended with a dated statement finding no changes in non-domestic influent impacts.

1.1.2.3.

1.1.2.4.

1.1.2.5.

On a semiannual basis, the Permittee shall sample and analyze wastewater influent and lagoon effluent for priority pollutants1 including standard inorganics2, and total aromatic hydrocarbons3 (TAH). However, an exception is made for two groups of priority pollutants, dioxins and dibenzofurans, which only need to be analyzed annually.

Representative influent samples must be collected prior to treatment at the headworks of the WWTF, and representative effluent samples must be collected from the discharge line prior to release into the gravel pit.

The Permittee must inspect and maintain all oil-water separators at a minimum interval of every calendar quarter. The Permittee shall keep inspection and maintenance records on all of the oil-water separators in use on Eielson AFB

1.1.3. REPORTING

1.1.3.1.

1.1.3.2.

Results of all pretreatment program monitoring under condition 1.1.2.3 shall be submitted to the Department by July 14 for the first six months and January 14 for the second six months of a year. The Permittee must inform the Department immediately if analytical results indicate exceedance of a U.S. Environmental Protection Agency (EPA) Water Quality Criterion.

Pretreatment plan updates or addenda under condition 1.1.2.2 shall be sent to the Department annually by March 31.

1 Aldrin/dieldrin; arsenic; benzene; benzidine; benzo(a)anthracene; benzo(a)pyrene; beryllium; dis(2-ethylhexyl)phthalate;

cadmium; carbon tetrachloride; chlordane; chlorinated dibenzodioxins; chlorinated dibenzofurans; chloroform; chromium;

cobalt; copper; cyanide; DDT/DDD/DDE; 3,3'-dichlorobenzidine; 2,4'-dichlorophenoxy-acetic acid; dimethylnitrosamine;

fluoride; heptachlor; hexachlorobenzene; hexachlorobutadiene; iron; lead, lindane; malathion; mercury; methylene bis-(2-chloroaniline); methylene chloride; methylethyl ketone; molybdenum; nickel; PCBs; pentachlorophenol; phenanthrene;

phenol; selenium; tetrachloroethylene; toxaphene; trichloroethylene; trichlorophenol; tricresyl phosphate; vinyl chloride;

and zinc 2 Arsenic, cadmium, chromium, copper, lead, mercury, selenium, nickel, and zinc 3 Sum of benzene, ethylbenzene, toluene, and the xylene isomers, commonly called BTEX

- 5 -

1.2. EFFLUENT LIMITS, MONITORING, & REPORTING

1.2.1. DISCHARGE RESTRICTIONS

1.2.1.1.

1.2.1.2.

1.2.1.3.

1.2.1.4.

1.2.1.5.

During the period beginning on the effective date of this permit and lasting through the expiration or termination date, the Permittee is authorized to discharge secondary treated, disinfected domestic and non-domestic wastewater from the wastewater stabilization ponds at Eielson AFB, Alaska.

The treated domestic and non-domestic wastewater is discharged from the sixth cell of a six cell wastewater stabilization pond system, which operates in series, into a gravel pit where the wastewater percolates into the ground. Although monitoring wells are the compliance points for meeting WQS, end-of-pipe limits have been specified for this permit.

These end-of-pipe limits must be met at the end of the effluent line, prior to discharge into the gravel pit.

The discharge must not contain additives, such as antifreeze solutions, methanol, solvents, corrosion inhibitors, garbage, toxic substances, grease or oils which produce a surface sheen, any more than trace amounts of foam, or other contaminants.

The discharge must not cause or contribute to a violation of WQS (18

AAC 70).

No other treated or untreated wastewater, sludge, or other material shall be discharged to the lands or water of the state unless otherwise approved by the Department.

- 6 -

1.2.2. LIMITS & MONITORING

Representative effluent samples must be collected from the discharge line prior to release into the gravel pit and meet the following requirements.

Effluent

Parameter Minimum

Value 30-Day

Average Maximum

Value Units Frequency of Analysis Sample

Type Total Flow NA NA 2.00 mgd Daily Measured Benzene NA NA 5 µg/L Semiannual Grab Total Aqueous Hydrocarbons (TAqH)1, 2

NA

µg/L

Semiannual

Grab

Total Aromatic Hydrocarbons

(TAH)1

µg/L

Semiannual

5 Day Biochemical Oxygen Demand NA 30 60 mg/L 2 / Month Grab or

Composite3

Total Suspended Solids NA 45 65 mg/L 2 / Month Grab or

Composite

Fecal Coliform Bacterial

FC

per100 mL

2 / Month pH 6 NA 9 std. units Daily Grab Dissolved Oxygen 2 NA NA mg/L Weekly Grab Total Residual Chlorine NA NA 2 mg/L Weekly Grab 1 Samples must be collected below the surface and away from any observable sheen.

2 TAqH means the sum of dissolved and water-accommodated monoaromatic and polynuclear aromatic hydrocarbons.

3 Composite samples must consist of at least four equal volume grab samples, two of which must be taken during periods of peak flow (7-9 a.m. and 6-8 p.m.).

4 All effluent fecal coliform average results must be reported as the geometric mean. When calculating the geometric mean, replace all results of zero, 0, with a one, 1.

1.2.3. REPORTING

By the 14th of the following month, submit monthly results of required effluent analyses to the Department on page one of the enclosed DMR form or using the same format.

- 7 -

1.3. GROUNDWATER LIMITS, MONITORING, & REPORTING

1.3.1.

1.3.2.

MONITORING WELLS

In order to prevent and detect groundwater contamination, the Permittee is required to monitor contaminant levels in monitoring wells. At least, one upgradient well and three downgradient wells, one shallow, one mid-depth, and one deep, are required for collecting representative groundwater samples. If for any reason a new monitoring well is necessary, its location, depth, and construction must be reviewed and approved by the Department.

OTHER MONITORING

1.3.2.1. Representative groundwater samples must be collected from the monitoring wells and meet the following requirements.

Groundwater Parameter

Upgradient Well Requirement

Downgradient Well Maximum

Units

Frequency of Analysis

Sample Type

Arsenic1 report 50 µg/L Semiannual2

Grab

Cadmium report 0.31 µg /L Semiannual Grab

Chromium report 100 µg /L Semiannual Grab

Copper report 11.94 µg /L Semiannual Grab

Lead report 3.62 µg /L Semiannual Grab

Mercury report 0.05 µg /L Semiannual…