Savoonga Final WP_QAPP.pdf

Final Work Plan/UFP‐QAPP

Remedial Action

National Guard Federal Scout Armory

Savoonga, Alaska ADEC File Number 670.38.002

ADEC Hazard ID 3099

Contract W911KB17D0020

June 2022

Prepared for:

U.S. Army Corps of Engineers

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Work Plan/UFP‐QAPP i Savoonga Federal Scout Armory Remedial Action Savoonga, Alaska

TABLE OF CONTENTS

ACRONYMS AND ABBREVIATIONS ...................................................................................................... iii EXECUTIVE SUMMARY ....................................................................................................................... vii WORKSHEET 1/2 – Title and Approval Page WORKSHEET 3/5 – Project Organizational Chart/QAPP Distribution WORKSHEET 4/7/8 – Personnel Qualifications WORKSHEET 6 – Communication Pathways WORKSHEET 9 – Project Scoping Session Participants Sheet WORKSHEET 10 – Conceptual Site Model WORKSHEET 11 – Data Quality Objectives WORKSHEET 12 – Measurement Performance Criteria WORKSHEET 13 – Secondary Data Uses and Limitations WORKSHEET 14/16 – Project Tasks and Schedule WORKSHEET 15 – Project Action Limits and Laboratory‐Specific Detection/Quantitation Limits WORKSHEET 17 – Sampling Design and Rationale WORKSHEET 18 – Sampling Locations and Methods WORKSHEET 19/30 – Sample Containers, Preservation, and Hold Times WORKSHEET 20 – Field Quality Control Summary WORKSHEET 21 – Field Standard Operating Procedures WORKSHEET 22 – Field Equipment Calibration, Maintenance, Testing, and Inspection WORKSHEET 23 – Analytical Standard Operating Procedure References WORKSHEET 24 – Analytical Instrument Calibration WORKSHEET 25 – Analytical Instrument and Equipment Maintenance, Testing, and Inspection WORKSHEET 26/27 – Sample Handling, Custody, and Disposal WORKSHEET 28 – Analytical Quality Control and Corrective Action WORKSHEET 29 – Project Documents and Records WORKSHEET 31/32/33 – Assessments and Corrective Action WORKSHEET 34 – Data Verification and Validation Inputs WORKSHEET 35 – Data Verification Procedures WORKSHEET 36 – Data Validation Procedures WORKSHEET 37 – Data Usability Assessment

REFERENCES

TABLES

Table 4‐1 Personnel Qualifications Table 6‐1 Communication Pathways Table 10‐1 ADEC‐Approved Soil ACLs Table 11‐1 Data Quality Objectives Table 12‐1 Measurement Performance Criteria for Methods AK102 and AK103 Table 12‐2 Measurement Performance Criteria for Method SW8260D Table 12‐3 Measurement Performance Criteria for Method SW8270D SIM Table 13‐1 Secondary Data Uses and Limitations Table 14‐1 Project Schedule Table 15‐1 Project Action Limits and Laboratory‐Specific Limits by Analyte – Soil

TABLE OF CONTENTS (CONTINUED)

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Table 15‐2 Project Action Limits and Laboratory‐Specific Limits by Analyte – Supra‐ permafrost Porewater

Table 17‐1 Excavated Soil Sample Collection Guide Table 17‐2 Surface/Excavation Base and Sidewall Soil Sample Collection Guide Table 18‐1 Sample Locations, Identifiers, Depths, Field QA/QC Samples, and Analytical

Methods Table 19‐1 Sample Containers, Preservation, and Hold Times – SGS North America, Inc Table 21‐1 Field Standard Operating Procedures Reference Table 22‐1 Field Equipment Calibration, Maintenance, Testing, and Inspection Table 23‐1 Analytical Standard Operating Procedure References Table 24‐1 Analytical Instrument Calibration Table – SGS North America Table 25‐1 Analytical Instrument Maintenance, Testing, and Inspection – SGS, Anchorage, AK

Table 26‐1 Sample Management Table 26‐2 Examples of Sample IDs and Corresponding Location IDs Table 28‐1 Analytical Quality Control and Corrective Action Table 29‐1 Project Documents and Records Table 31‐1 Planned Project Assessments Table 31‐2 Assessment Response and Corrective Action Table 31‐3 Reporting Table 34‐1 Data Verification and Validation Inputs Table 35‐1 Data Verification Procedures Table 36‐1 Data Validation Procedures to be Performed Table 36‐2 Validation and Usability Assessment Data Qualifiers Table 36‐3 Data Qualifying Conventions Based on Quantitation of Results Table 37‐1 Data Usability Assessment

FIGURES

Figure 1 Location and Site Vicinity Figure 2 Site Features Figure 3 Savoonga Conceptual Hydrology Model Figure 4 Previous Soil and Porewater Sample Locations and Exceedances Figure 5 Proposed Excavation and Monitoring Well Locations

APPENDICES

Appendix A Community Relations Plan Appendix B Field Standard Operating Procedures Appendix C Laboratory Certifications Appendix D Conceptual Site Model Appendix E Site Safety and Health Plan Appendix F Regulatory Correspondence

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ACRONYMS AND ABBREVIATIONS

°C degrees Celsius °F degrees Fahrenheit % percent %R percent recovery AAC Alaska Administrative Code ACL alternative cleanup level ADEC Alaska Department of Environmental Conservation ADNR Alaska Department of Natural Resources AED automated external defibrillator AKARNG Alaska Army National Guard AKCESCL Alaska Certified Erosion and Sediment Control Lead AOC Area of Concern AST aboveground storage tank ATSDR Agency for Toxic Substances and Disease Registry bgs below ground surface Brice Brice Engineering, LLC BTEX benzene, toluene, ethylbenzene, and xylenes CCV continuing calibration verification CFR Code of Federal Regulations CL control limit Clarus Clarus Environmental Services CoC chain‐of‐custody COC contaminant of concern COPC contaminant of potential concern COR Contracting Officer’s Representative CPR cardiopulmonary resuscitation CSM conceptual site model cy cubic yards DL detection limit DoD U.S. Department of Defense DQI data quality indicator DQO data quality objective DRO diesel range organics EDD Electronic Data Deliverable ELAP Environmental Laboratory Accreditation Program EPA U.S. Environmental Protection Agency ERM Environmental Resource Management FD field duplicate FID flame ionization detector

ACRONYMS AND ABBREVIATIONS (CONTINUED)

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FSA Federal Scout Armory GAC granular activated carbon GC gas chromatography GC/MS gas chromatography/mass spectroscopy GIS geographic information system GNSS Global Navigation Satellite System GPS Global Positioning System HAZWOPER hazardous waste operations and emergency response ICAL initial calibration ICP inductively coupled plasma ICV initial calibration verification IDQTF Intergovernmental Data Quality Task Force IDW investigative‐derived waste IS internal standard ISO International Organization for Standardization LCL lower control limit LCL lower confidence level LCS laboratory control sample LCSD laboratory control sample duplicate LNAPL light non‐aqueous phase liquid LOD limit of detection LOQ limit of quantitation LV low volume MB method blank ME marginal exceedance MED Manual for Electronic Deliverables MeOH methanol mg/kg milligrams per kilogram mg/L milligrams per liter mL milliliter/milliliters MPC measurement performance criteria MS matrix spike MSD matrix spike duplicate N/A or NA not applicable NAD83 North American Vertical Datum of 1983 NAVD88 North American Vertical Datum of 1988 ND non‐detect No. number NS not specified

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OSHA U.S. Occupational Safety and Health Administration oz ounce PA Preliminary Assessment PAH polycyclic aromatic hydrocarbon PAL project action limit PARCCS precision, accuracy, representativeness, completeness, comparability, and sensitivity PID photoionization detector POA Pacific Ocean/Alaska PPE personal protective equipment ppm parts per million PVC polyvinyl chloride QA quality assurance QAM Quality Assurance Manual QC quality control QSM Quality Systems Manual RA remedial action RCRA Resource Conservation and Recovery Act RF response factor RI remedial investigation RPD relative percent difference RSD relative standard deviation RT retention time RTK Real‐Time Kinematic SDG sample delivery group SEDD Staged Electronic Data Deliverable SI site investigation SIM selected ion monitoring SME sporadic marginal exceedance SMS sediment management standard SOP standard operating procedure SP‐16 Screen Point 16 SSHO Site Safety and Health Officer SSHP Site Safety and Health Plan TLC Teflon‐lined cap TLS Teflon‐lined septa TPH total petroleum hydrocarbons UCL upper control limit UFP‐QAPP Unified Federal Policy – Quality Assurance Project Plan USACE U.S. Army Corps of Engineers

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USACE‐POA U.S. Army Corps of Engineers – Pacific Ocean, Alaska USAEC U.S. Army Environmental Center VOA volatile organic analysis VOC volatile organic compound WGS84 World Geodetic System 1984

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EXECUTIVE SUMMARY

This Work Plan describes the project approach and methods that will be used while conducting remedial Action (RA) activities at the Federal Scout Armory in Savoonga, Alaska during the 2022 field season (Figure 1 and Figure 2). This Work Plan was prepared by Brice Engineering, LLC (Brice) in Uniform Federal Policy ‐ Quality Assurance Project Plan (UFP‐QAPP) format in accordance with U.S. Environmental Protection Agency (EPA) guidance, 18 Alaska Administrative Code (AAC) 75 (Alaska Department of Environmental Conservation [ADEC] 2021a); the ADEC Field Sampling Guidance (ADEC 2022); the UFP‐ QAPP Manual (Intergovernmental Data Quality Task Force [IDQTF] 2005, 2012); and the Manual for Electronic Deliverables (MED; USACE 2017). Work will be performed for the U.S. Army Corps of Engineers (USACE), Alaska District, under Contract W911KB‐17‐D‐0020, Task Order W911KB‐18‐F‐0155.

In addition to the UFP‐QAPP Worksheets, the following Appendices are included:

Appendix A – Community Relations Plan

Appendix B – Field Standard Operating Procedures (SOPs)

Appendix C – Laboratory Certifications

Appendix D – Conceptual Site Model

Appendix E – Site Safety and Health Plan (SSHP)

Appendix F – Regulatory Correspondence

In November 2018, as part of this contract, an Accident Prevention Plan (APP) was submitted and approved.

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WORKSHEET 1/2 – TITLE AND APPROVAL PAGE

Project Information

Site Name/Project Name: Remedial Action (RA), Savoonga Federal Scout Readiness Center, Savoonga, Alaska

Site Location/Site Number: Savoonga, Alaska

Contract Number: W911KB‐17‐D‐0020, Task Order W911KB‐18‐F‐0155

Preparer’s Organization

Organization Name: Brice Engineering, LLC (Brice)

Lead Organization Project Manager:

Monica Oakley

Signature and Date:

Contracting Organization

Organization Name: Alaska Army National Guard (AKARNG)

Lead Organization Contracting Officer’s Representative/Project Manager:

Jenna Van Horn

Signature and Date: _________________________________________________________________

Lead Organization

Organization Name: U.S. Army Corps of Engineers (USACE) – Alaska District

Lead Organization Project Manager:

Heidi Long

Signature and Date: _________________________________________________________________

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WORKSHEET 3/5 – PROJECT ORGANIZATIONAL CHART/QAPP DISTRIBUTION

The project organizational chart is presented below.

ADEC (REGULATORY AGENCY)

*Project Manager Flannery Ballard (907) 465‐5368 flannery.ballard@alaska.gov

SUBCONTRACTORS

Analytical Lab SGS Alaska (907) 562‐2343

BRICE

*Project Manager Monica Oakley (907) 275‐2914 moakley@briceenvironmental.com

Field Manager/ Site Safety and Health Officer (SSHO) Monte Garroutte (907) 750‐8688

Geospatial Specialist Dylan Hickey (907) 275‐2893

Project Chemist Victoria Pennick (907) 205‐9892

Safety Manager Jamey Smith (503) 539‐9504 jamey.smith@briceenvironmental.com

USACE (CONTRACTING AGENCY)

*Project Manager Heidi Long (907) 244‐0618 mailto:heidi.l.long@usace.army.mil

*Project Engineer/COR Mike Utley (907) 753‐2691 michael.d.utley@usace.army.mil

*Project Chemist To be determined

Contracting Officer Timothy L. Clapp (907) 753‐2836 timothy.l.clapp@usace.army.mil

AKARNG (LEAD AGENCY)

*Project Manager Jenna Van Horn

(907) 428‐7696 jenna.vanhorn@alaska.gov

Monitoring Archaeologist1 Tom Wolforth

(907) 428‐7184 (Office)

(907) 444‐5622 (Field Cell) tom.wolforth@alaska.gov

Notes: *QAPP Recipient

1The required Section 106 consultation for this project stipulates that an archaeological monitor will be present during all soil‐disturbing activity.

mailto:

mailto:Christy.j.baez@usace.army.mil mailto:michael.d.utley@usace.army.mil

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WORKSHEET 4/7/8 – PERSONNEL QUALIFICATIONS

Table 4‐1 identifies key project personnel performing tasks defined in this QAPP. Resumes are available upon request. Training records and certifications for personnel and subcontractors are on file in the Brice Anchorage office.

Table 4‐1 Personnel Qualifications

Title Name Responsibilities Education/ Experience

Specialized Training/Certifications

Brice PM Monica Oakley Providing direction to the Brice project team to ensure project objectives are achieved, the project budget is tracked, and the project is on schedule.

Monica has over 16 years of experience working on State and Federal environmental projects across Alaska. She holds a BS and an MA from Washington State University and is a Project Management Professional.

40‐hour HAZWOPER

8‐hour refresher per 29 CFR 1910.120(e)

First‐aid certification

Adult CPR/AED certification

USACE Construction Quality Management for Contractors Certification

30‐hour OSHA

Alaska Certified Erosion Sediment Control Lead

Hazardous material shipping

ADEC Qualified Environmental Professional

Brice Project Chemist

Victoria Pennick Coordinating with the analytical laboratory, reviewing analytical data, and ensuring that the data quality objectives (DQOs) are achieved.

Victoria Pennick has over 30+ years of technical and professional experience as an environmental chemist, both in the laboratory and the field. She holds a BS in Biological Sciences from the University of California

– San Diego.

40‐Hour HAZWOPER

8‐hour refresher per 29 CFR 1910.120(e)

ADEC Qualified Environmental Professional

Hazardous material shipping (IATA and DOT)

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Table 4‐1 Personnel Qualifications

Title Name Responsibilities Education/ Experience

Specialized Training/Certifications

Field Manager/ Site Safety and Health Officer

Monte Garroutte Implementing, overseeing, and coordinating safety aspects and objectives of this project. Managing the sampling elements.

Monte Garroutte has 5 years of experience working as a regulator and 4 years working as a consultant on contaminated sites characterization and remediation projects in Alaska.

He holds a BS and MS in Biological Sciences from University of Alaska, Fairbanks.

ADEC Qualified Environmental Professional

40‐hour HAZWOPER

8‐hour refresher per 29 CFR 1910.120(e)

EPA Region 10 RCRA and TSCA Training

NEG‐350 Collaborative Negotiations and Conflict Management for Environmental Professionals

EPA Superfund 101 – Fundamentals of Superfund

EPA Environmental Response Training Program:

Sampling for Hazardous Materials

First‐aid certification

Adult CPR/AED certification

Program Health and Safety Manager

Jamey Smith Developing, implementing, and overseeing all safety and health‐related aspects of the project.

Jamey Smith has 20 years of experience managing Health, Safety, and Environmental functions on construction and mining projects. He holds an MS Leadership and Management and BA Occupational Safety and Health.

40‐hour and 8‐Hour HAZWOPER Instructor

OSHA 10‐ and 30‐Hour Construction and General Industry Trainer

OSHA 4200 Maritime Trainer

Certified Safety Professional (30542)

Certified Mine Safety Professional (989)

MSHA approved instructor (IS, IU, MR)

Notes:

For definitions, refer to the Acronyms and Abbreviations section

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WORKSHEET 6 – COMMUNICATION PATHWAYS

Table 6‐1 describes the communication pathways and modes of communication that will be used during the project after the Work Plan/UFP‐ QAPP has been approved. The communication pathways presented below define the procedures for soliciting and/or obtaining approval between project personnel, contractors, and laboratory staff. These procedures should be followed when an approved project activity requires real‐time modifications to achieve project goals, or a Work Plan/UFP‐QAPP amendment must be obtained. Procedures for stopping work and responsible entities are also identified.

Table 6‐1 Communication Pathways

Communication Drivers

Responsible Entity Name Telephone Number Procedure

Point of contact with the ADEC during project execution

AKARNG Project Manager Jenna Van Horn (907) 428‐7696 Technical, QA, and decision‐making matters concerning project execution (verbal, written, or electronic).

Amendments to the UFP‐

QAPP

USACE COR

USACE Project Manager

Mike Utley

Heidi Long

(907) 753‐2691

(907) 244‐0618

Coordination of the UFP‐QAPP amendment dialog.

Amendments to the UFP‐QAPP prior to initiation of fieldwork will require a Work Plan/UFP‐QAPP Addendum which will be provided to USACE, AKARNG, and ADEC for concurrence prior to making any changes.

Contracting issues requiring coordination between the USACE Project Manager and Brice The USACE will maintain oversight for the overall project action.

Technical review and oversight of RA scope, activities, and process

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Table 6‐1 Communication Pathways

Communication Drivers

Responsible Entity Name Telephone Number Procedure

Tracking progress in the field

USACE COR

USACE Project Manager

Mike Utley

Heidi Long

(907) 753‐2691

(907) 244‐0618

Field progress updates will be provided to the USACE, AKARNG, and ADEC Project Manager daily via email (by COB the following day). Updates on progress will be emailed to ADEC directly from the AKARNG Project Manager.

Planning and preparatory communication and meetings

Brice Project Manager Monica Oakley (907) 275‐2914

Facilitates review meetings, status meetings, and other meetings with the client and stakeholders, as necessary.

Change in field conditions Coordinates with the USACE to adjust approach, if necessary. Contact will be initiated by the end of the next business day.

Changes to fieldwork

Brice Field Manager Monte Garroutte (907) 750‐8688 Notifies Brice Project Manager of fieldwork issue and provides draft Field Change Request forms by close of business the next business day.

Brice Project Manager Monica Oakley (907) 275‐2914 Notifies the USACE Project Manager and COR and provides Field Change Request forms by the end of the next business day.

USACE Project Manager Heidi Long (907) 244‐0618

Evaluates the situation based on information from the Brice Project Manager and selects the recommended solution or an alternate solution. If a significant change to fieldwork will occur based on a recommended solution, the ADEC will be notified prior to implementing the change.

Analytical data results and data quality issues Brice Project Chemist Victoria Pennick (907) 205‐9892

Identifies any data quality issues and works with the laboratory Project Manager to resolve issues. Notifies Brice Project Manager of the issue and resolution. If there is a significant data quality issue, the Project Chemist may immediately notify the Brice Project Manager and the Field Team.

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Table 6‐1 Communication Pathways

Communication Drivers

Responsible Entity Name Telephone Number Procedure

SGS Project Manager Justin Nelson (907) 550‐3205 Identifies data quality issues and provides solutions for the Project Chemist to resolve the issue.

Brice Project Manager Monica Oakley (907) 275‐2914 Notifies the USACE Project Manager of data quality issues and initiates a resolution within one week.

USACE Project Chemist Mike Utley (907) 753‐2691 Evaluates whether actions to resolve data quality issues are adequate, with input from the USACE Project Manager and Brice Project Manager, if necessary.

Accident or unplanned health and safety incident

Brice SSHO Monte Garroutte (907) 750‐8688 Notifies the Brice Project Manager within one hour.

Brice Project Manager Monica Oakley (907) 275‐2914 Notifies the USACE by phone within 24 hours.

Stop work/initiate corrective action

Brice SSHO Monte Garroutte (907) 750‐8688 Stops work and notifies the Brice Project Manager within one hour.

Brice Project Manager Monica Oakley (907) 275‐2914 Stops work and notifies the USACE Project Manager by the end of the next business day. Recommends corrective action.

USACE Project Manager Heidi Long (907) 244‐0618 Notifies the Contracting Officer and ADEC by the end of the next business day with recommendations for corrective action.

Monitoring Archaeologist Tom Wolforth

(907) 428‐7184 (Office)

(907) 444‐5622 (Field Cell)

Notifies AKARNG Project Manager immediately upon encountering potential or actual cultural remains or burials.

AKARNG Project Manager notifies USACE Project Manager.

For definitions, refer to Acronyms and Abbreviations section.

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WORKSHEET 9 – PROJECT SCOPING SESSION PARTICIPANTS SHEET

This worksheet documents a scoping session held for the project and identifies team members who are responsible for planning the project.

Project Name: National Guard Federal Scout Armory Remedial Action Site Location: Savoonga, Alaska Date of Planning Session: 4 October 2018 and 5 December 2018 Brice PM: Monica Oakley, PMP Participants:

Name Title/Role Meeting Dates

Organization and Email 4 October 2018 5 December 2018

Guy Warren Project Manager (former) X X USACE guy.l.warren@usace.army.mil

Heidi Long

AKARNG Project Manager (former, now current USACE Project Manager)

X

USACE

Heidi.l.long@usace.army.mil

Monica Oakley Project Manager X X Brice moakley@briceenvironmental.com

Jamie Oakley Brice President X X Brice joakley@briceenvironmental.com

Monte Garroutte Field Scientist X X Brice mgarroutte@briceenvironmental.com

Mikayla Daigle Engineer X Brice mdaigle@briceenvironmental.com

Danielle Duncan Project Manager (former) X ADEC danielle.duncan@alaska.gov Notes:

For definitions, refer to the Acronyms and Abbreviations section.

* Participated via teleconference

The following activities took place during the meeting conducted on 4 October 2018:

Provided an overview of project objectives and the schedule for the scoping meeting, planning documents, fieldwork, and reporting.

Discussed use of the term “groundwater” versus “supra‐permafrost water”. USACE recommended that a stakeholder meeting be conducted before document submittal to discuss issues surrounding supra‐permafrost water. The meeting should discuss Arctic Zone cleanup levels and the Technical Memorandum, Establishing Arctic Zone Cleanup Levels (ADEC 2017a). The stakeholder meeting was scheduled for 5 December 2018.

Discussed communication pathways.

AKARNG will provide notifications to all villages prior to fieldwork. Brice will provide a notification flier with the AKARNG logo for AKARNG to send to the villages.

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The following activities took place during the meeting conducted on 5 December 2018:

Discussed preliminary technical approach for each of the three sites, including the Arctic Zone Cleanup Levels Technical Memorandum and how it may/may not apply to Savoonga.

ADEC clarified that sites located south of latitude 68 degrees (°) North will be difficult for ADEC to approve Arctic Zone cleanup levels.

USACE mentioned that not applying Arctic Zone cleanup levels will likely require that AKARNG perform long‐term monitoring (LTM); however, LTM results at remote sites underlain by continuous permafrost is likely to be variable depending on seasonal melt and LTM sampling incurs significant costs.

ADEC suggested that the project team provide a multitude of data (borings, profiles, etc.) to support the conclusion that the sites are underlain by continuous permafrost. In addition, the project team should consider excavating contaminated soil, as leaving the source in place slows cleanup efforts.

ADEC mentioned that if the field team conducted multiple investigations over the course of a few years and were not able to collect water samples from LTM wells, this would strengthen the argument for an Arctic Zone determination at the respective site.

Regarding the Savoonga Federal Scout Armory (FSA), the group discussed the 2017 Site Characterization Report and only the southeast portion of the site has not been delineated. The feasibility of arguing that the supra‐permafrost at the Savoonga FSA is impacted by salt water was discussed. This site is only 200 feet from the ocean; however, it may be too far above the ocean level to be impacted and considered surface water.

Action items following this meeting were that Brice would begin drafting the Pre‐Draft Decision Documents for Gambell and Savoonga. The draft Gambell Decision Document would be submitted first to ADEC for review. Following receipt of comments, the draft Savoonga Decision Document would be submitted to ADEC and would incorporate the edits (as applicable) that were requested on the Gambell Decision Document. Then concurrently, the draft‐final versions of both Decision Documents would be submitted by ADEC to management and legal at ADEC.

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WORKSHEET 10 – CONCEPTUAL SITE MODEL

This worksheet includes the background of the site contaminants; site history; describes the climate and environmental setting; describes previous treatability studies; and presents a human health conceptual site model (CSM).

Site Background and Description

The village of Savoonga lies on the north‐central tip of St. Lawrence Island in the Bering Sea, approximately 164 miles west of Nome, Alaska (Figure 1). The Savoonga FSA is an active contaminated site in the ADEC Contaminated Sites Program database, with File Number 670.38.002, Hazard ID 3099, and the site name “AKARNG Savoonga FSA” (Figure 2)

According to the 2010 Census, Savoonga, Alaska has a population of 671. The only other community on St. Lawrence Island is Gambell (population 681), located approximately 39 miles west of Savoonga.

Beyond local access, Savoonga is only accessible by air.

Historically, local natives have relied on a subsistence lifestyle consisting of fish, wildlife, and plants from the region. In addition, many migratory birds pass through the area on a seasonal basis.

Climate

Savoonga has a subarctic maritime climate with some continental influences during winter. Summer temperatures average 40 degrees Fahrenheit (°F) to 51°F. Winter temperatures average ‐7°F to 11°F.

Average annual precipitation is 10 inches, with 58 inches of snowfall (Western Regional Climate Center, 2012). St. Lawrence Island is subject to prevailing winds averaging 18 miles per hour. Typically, the Bering Sea freezes around St. Lawrence Island in mid‐November, with breakup of sea ice occurring in late May.

(Alaska Department of Commerce, Community, and Economic Development, Division of Community and Regional Affairs 2012).

Geology

The dominant soil lithology is a clayey silt containing boulders of bedrock material with most areas featuring a 1‐foot layer of peat and organic material above the soil (Ogden 1998). During a 1998 RI, soil was assessed for physical properties including grain size analysis. It was determined that the material in the active layer is a slightly clayey, silty, gravelly sand with a hydraulic conductivity of approximately 2x10‐ 3 centimeters per second (ERM West, Hart Crowser 1999). The bedrock is Quaternary‐age basalt resulting from a large shield volcano that extends over most of the central part of the island (Waller 1959; Patton et al. 2011). Well logs from 1966 and 1972 document igneous rock at depths of 11 feet below ground surface (bgs) and 17 feet bgs, respectively (Alaska Department of Natural Resources [ADNR] 1966, 1972).

Permafrost is continuous in the subsurface below Savoonga and lies anywhere between 0.5 feet bgs to 4 feet bgs (Ogden 1998; ERM West, Hart Crowser 1999; North Wind, Inc. 2009; Clarus 2006; CH2M HILL 2013; Eagle Eye 2017).

Hydrogeology

Permafrost is present at the site at depths of 2 to 4 feet bgs. An active, seasonally thawed groundwater layer is present above the permafrost layer but is not encountered at all times of the year (Ogden 1998).

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Water for the village is currently obtained from a 195‐foot‐deep well drilled in 1972 located a half‐mile southeast (upgradient) of the FSA (Figure 2). Water is pumped from the well to a 100,000‐gallon storage tank within the village (Clarus 2006). The well house for the village water supply is on the northeast end of the air strip (Ogden 1998). The well was installed through a known thaw bulb associated with Sivuungaq River (Figure 3). The closest extent of the thaw bulb is approximately 1,500 feet from the FSA facility (ERM West, Hart Crowser 1999).

Site History

The Savoonga FSA Property lies adjacent to the main beach access road on the northwestern side of the city, approximately 200 feet south of the Bering Sea. The beach access road acts as the southeastern boundary of the FSA property. The FSA complex is situated on a gravel pad. Infrastructure includes the following:

A 20‐foot by 60‐ foot, wood‐framed building constructed in 1960 (the old FSA building)

A 30‐foot by 40‐foot wood‐framed building constructed in 1985 (the new FSA building)

An elevated walkway connecting the old and new FSA buildings

A 1,500‐gallon aboveground storage tank (AST) near the new FSA

Two 1,500‐gallon ASTs near the old FSA

The Savoonga FSA is a known petroleum‐contaminated soil source area, resulting primarily from an estimated 500‐gallon heating oil spill to the ground surface from a 3,000‐gallon AST. In 1985, 200 gallons of Jet A fuel leaked from drums stored near the AST. In 1992, a leak of an unknown quantity of heating oil from a fuel line.

In 1993, two 1,500‐gallon ASTs replaced one 3,000‐gallon AST near the old FSA building. In 1994, the FSA was deactivated. In 2002, the 3,000‐gallon AST near the new FSA was removed and was replaced by the 1,500‐gallon AST near the new FSA (Eagle Eye 2017). All three 1,500‐gallon ASTs are currently active.

Several investigations have been completed at the Savoonga FSA to determine the nature and extent of contamination (Figure 4). The following subsections present a summary of the investigations at the site.

1996 Preliminary Assessment/Site Investigation

In 1996, a Preliminary Assessment/Site Investigation included sampling in potentially contaminated areas (Ogden 1998). Seven locations were chosen for field screening around areas of suspected or potential contamination; soil was collected from 0.5 feet bgs and screened using an infrared spectrophotometry field screening tool for total petroleum hydrocarbons (TPH). Results of field screening guided selection of analytical sampling locations. Five locations were selected for analytical sampling just outside of areas where field screening indicated contamination. The locations are displayed on Figure 4 and are labeled as “SV” with three digits (e.g., SV021).

Analytical soil samples were collected from 0.5 feet bgs and analyzed for diesel range organics (DRO) and TPH. A DRO concentration of 160 milligrams per kilogram (mg/kg) was detected near the shed between the old and new FSA buildings at SV051 (Figure 4). The four remaining samples, collected from the perimeter around the site, showed a maximum concentration of DRO at 23 mg/kg and all results for TPH were non‐detect (ND). No Further Action was recommended for the site because contaminant concentrations were below the ADEC cleanup criteria applicable at the time.

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1998 Remedial Investigation

In September 1998, to further characterize the site, a remedial investigation (RI) was conducted for the AKARNG (ERM West, Hart Crowser 1999). A total of 19 boreholes were hand‐augered within the extent of the gravel pad and one location was advanced west of the gravel pad in the marshy area. An objective of the hand‐auger boreholes was to determine the extent and depth of permafrost. Within the gravel pad, the advancement of boring holes was limited due to frozen soil and extended to a maximum depth of 2 to 2.5 feet. The borehole advanced west of the gravel pad encountered permafrost at 3.5 feet bgs.

From the 20 locations, 42 soil samples were analyzed for DRO and a select few were analyzed for gasoline range organics (GRO); residual range organics (RRO); benzene, toluene, ethylbenzene, and xylenes (BTEX);

and polycyclic aromatic hydrocarbons (PAHs). Soil samples were collected from the surface, below the organic layer, at a depth of approximately 0.5 feet bgs and at the bottom of the borehole. Additionally, the one active, seasonal water sample was to be collected near the northernmost 1,500‐gallon AST;

however, refusal was met at 2.5 feet bgs and recovery was insufficient. Soil samples from the 1998 RI are presented on Figure 4 and are labeled as “B‐” with two digits (e.g., B‐01).

Analytical soil sample results indicated contamination was present at the south corner of the old FSA building near the ASTs and downgradient (north and west) of the 3,000‐gallon AST by the new FSA building. Near the southern corner of the old FSA, DRO concentrations greater than 1,000 mg/kg were present in two borings with a concentration of 1,100 mg/kg in surface soil and 11,000 mg/kg in subsurface soil in borehole B‐12; and a concentration of 17,000 mg/kg in surface soil and 8,900 mg/kg in subsurface soil in boreholeB‐13. These samples were also submitted for PAH analysis; no PAH compounds were detected at concentrations greater than the Arctic Zone risk‐based cleanup levels applicable at the time of the investigation. These two locations were bounded by samples with concentrations of DRO less than 1,000 mg/kg (B‐10, B‐14, and B‐17). Adjacent to the AST on the north side of the new FSA building, DRO concentrations of 1,300 mg/kg and 1,500 mg/kg were detected in the subsurface in boreholes B‐05 and B‐06, respectively. Downgradient along the edge of the gravel pad at borehole B‐18, DRO concentrations were less than 30 mg/kg in subsurface soil.

The RI Report recommended that DRO be considered the primary contaminant of concern (COC) at this site (ERM West, Hart Crowser 1999). The highest concentration of RRO was 380 mg/kg, GRO was 27 mg/kg, total BTEX was 0.35 mg/kg, and benzene was non‐detect.

Due to the presence of continuous permafrost, the contractor recommended that the site satisfied the Arctic Zone criteria, specifically citing the following:

Via personal communication, the opinion of Mr. Pierre Costello of the U.S. Public Health Service, a design engineer responsible for the sewer and water upgrades completed in Savoonga around 1998 (ERM West, Hart Crowser 1999).

A subsurface investigation conducted by Clarke Engineering in 1994 related to utility upgrades.

This investigation completed 11 borings across Savoonga, including two near the FSA indicating permafrost was between 1 and 3 feet bgs.

A groundwater investigation by Terrasat in 1996.

The RI background boring located approximately 15 feet south of the new armory building.

One soil sample collected during the RI exceeded the current Arctic Zone cleanup level for DRO of 12,500 mg/kg, and it was estimated that 10 to 20 cubic yards (cy) of soil contained DRO concentrations greater than 12,500 mg/kg.

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2004 Alternate Cleanup Level Demonstration Project

In August 2004, on behalf of AKARNG, an investigation was completed to demonstrate the validity of a proposed alternative cleanup level (ACL) (Clarus 2006). The investigation included soil and porewater sampling. Twelve hand‐augered soil borings were advanced to refusal at a depth of 4.5 feet bgs, and two drive‐point well points with 2‐foot screens were installed to approximate depths of 4.5 feet bgs. The soil and porewater sample locations are displayed on Figure 4 and are labeled by “SAV‐ACL‐” followed by three digits (e.g., SAV‐ACL‐006).

Seven soil samples were collected from locations upgradient from the source area. All soil samples were analyzed for DRO, and five samples collected from locations closest to the source area were also analyzed for GRO, BTEX, and Synthetic Precipitation Leaching Procedure‐DRO. Two porewater samples were collected from well points near the former shed and near the old FSA ramp were analyzed for DRO and GRO. Porewater collected from the well point near the former shed (SAV‐ACL‐016) exhibited a petroleum odor and a slight sheen.

Analytical soil sample results for DRO ranged from 33.4 mg/kg to 233 mg/kg, is below the current ADEC Method Two Arctic Migration to Groundwater soil cleanup level. The porewater samples indicated elevated DRO concentrations in SAV‐ACL‐015 and ‐016 of with results of 30.2 milligrams per liter (mg/L) and 4.07 mg/L, respectively. Additionally, concentrations of GRO and BTEX were detected in sample SAV‐ ACL‐015. However, the porewater samples contained significant amounts of suspended solids, which may have biased the contaminant concentrations high. No free product was noted during collection of the samples.

As part of the ACL Demonstration Project, it was proposed that supra‐permafrost porewater was not a reasonable source of drinking water due to the limited quantity and presence of continuous permafrost.

Additionally, it was recommended that porewater cleanup levels for the Savoonga FSA should be 10 times the ADEC Table C groundwater cleanup levels; however, based on this recommendation the DRO concentration in porewater at SAV‐ACL‐015 still exceeded the proposed ACL.

The contractor recommended the following ACLs for soil:

GRO was the maximum concentration allowed in 18 AAC 75.341; 1,400 mg/kg

DRO was a Method Three calculated value based on the ingestion pathway: 10,000 mg/kg total xylenes were based on Method Three calculations for inhalation: 844 mg/kg and benzene, toluene, and ethylbenzene were based on Method Three calculations, Migration to Groundwater pathway, and the 10 times rule. ACLs for benzene, toluene and ethylbenzene were proposed as 0.655 mg/kg, 361 mg/kg, and 490 mg/kg respectively.

2009 Secondary Site Characterization

In June 2009, a site characterization was conducted to both delineate the extent and determine the volume of DRO‐contaminated soil above the ADEC Method Two Migration to Groundwater cleanup level (250 mg/kg; North Wind, Inc. 2009). A total of 48 borings were advanced using a gas‐powered auger between two 5‐foot grid patterns. Twenty‐two (22) borings in Grid 1 were advanced to 0.5 to 1.5 feet bgs to the west of the new FSA buildings, and 26 borings in Grid 2 were advanced to 0.7 to 2.0 feet bgs on the east and south ends of the old FSA. Frozen soil was encountered in every Grid 1 boring between 0.4 and

1.5 feet bgs. Frozen soil was encountered in Grid 2 borings in 10 of the 26 borings between 0.7 and 1.5 feet bgs. The remaining Grid 2 borings encountered refusal at 2.0 feet bgs.

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During the field effort, 90 soil samples were field screened using a photoionization detector (PID) and 22 primary soil samples were collected based on the highest field screening results and submitted to the laboratory for DRO analysis. The analytical results showed DRO concentrations greater than 250 mg/kg in soil on the west side of the new FSA (Grid 1) and less than 250 mg/kg on the southern side of the old FSA (Grid 2). There was limited correlation between field screening and analytical results. The report conclusions included an estimated 11 cubic yards of soil with DRO concentrations greater than 250 mg/kg were present at the site. The 2009 locations are presented on Figure 4 and are labeled “09SAV” followed by six digits (e.g., 09SAV‐01‐G100).

2011 Data Gap Investigation

In July 2011, a data gap investigation (DGI) was conducted to delineate the extent of petroleum‐ contaminated soil and porewater and to support previous remediation recommendations. During the investigation, no new sources of contamination were identified, and no evidence of stained soil or recent spills was observed (CH2MHill 2013).

A total of 21 soil samples were collected from 12 locations at depths between 0 and 3 feet bgs. Initially, samples were to be collected at greater depths; however, permafrost or ground conditions prevented deeper advancement. Four porewater samples were collected from well points on the north and northwest side of the gravel pad. The 2011 locations are presented on Figure 4 and are labeled “11SAVSB” followed by three digits (e.g., 11SAVSB013) and for well points as “11SAVGW” with three digits (e.g., 11SAVGW001); 11SAVSB004 and 11SAVSB007 were soil and porewater sample points.

The soil samples were field screened with a PID prior to collection. Samples were collected from the locations with the highest field screening results and submitted to the laboratory for DRO analysis, with a subset analyzed for BTEXs, PAH, extractable petroleum hydrocarbons (EPH), and volatile petroleum hydrocarbons (VPH). Porewater samples were submitted for DRO analysis, and one sample was also analyzed for BTEX, PAHs, EPH, and VPH.

Analytical soil results confirmed petroleum‐related contamination in the previously identified areas.

Several analytes exceeding the ADEC Method Two Migration to Groundwater cleanup levels were observed, with maximum concentrations detected at sample location 11SAVSB001. Contaminants that exceeded cleanup levels at this location were: DRO (17,000 mg/kg), benzene (3.1 mg/kg), toluene (160 mg/kg), ethylbenzene (48 mg/kg), total xylenes (250 mg/kg), naphthalene (180 mg/kg), 1‐methylnaphthalene (230 mg/kg), and 2‐methylnaphthalene (360 mg/kg).

The analytical porewater results showed an elevated DRO concentration of 18 mg/L at location 11SAVSB004. The three remaining porewater samples had detected DRO concentrations of 0.6 mg/L, 0.81 mg/L and 1.1 mg/L, which were below the current ADEC Table C groundwater cleanup level of 1.5 mg/L.

In a 2017 letter from ADEC, the ACLs that were proposed for DRO and benzene in the 2011 DGI Report (CH2M HILL 2013) were not approved, and it was recommended that the ADEC Method Three ACL calculator be used to calculate soil ACLs.

2016 Site Characterization Investigation

In 2016, a Site Characterization Investigation was conducted (Eagle Eye 2017) to fill data gaps and evaluate the nature and extent of groundwater contamination at the Savoonga FSA. During the investigation, five monitoring wells were installed around the perimeter of the facility (Figure 4, MW‐01 through MW‐05).

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The monitoring wells were installed surrounding the FSA site to maximum depths of 6.5 feet bgs.

Permafrost was encountered at 2 to 4 feet bgs and ice was found in each boring.

Two of five wells (MW‐04 and MW‐05) were installed on the north and northwest side of the facility, and porewater was encountered in these wells after installation between 2.5 and 6.1 feet bgs. In the three wells installed on the south and east side of the facility (MW‐01, MW‐02, and MW‐03), porewater was observed between 3.1 and 3.6 feet bgs. Wells MW‐02, MW‐03, and MW‐04 contained DRO, RRO, and toluene concentrations greater than the ADEC Table C groundwater cleanup levels; DRO exceeded in MW‐ 02 and MW‐03, RRO exceeded in MW‐04, and toluene exceeded in MW‐02 and MW‐04. The maximum DRO concentration was 2.9 mg/L in MW‐03. As a result of the investigation, it was suggested that the extent of porewater contamination was not defined upgradient and crossgradient, particularly on the southeast side of the old FSA building.

2020 Alternative Cleanup Levels Summary

In 2020, soil ACLs for petroleum hydrocarbons, including DRO, RRO, GRO, BTEX, and PAH were calculated using the most current ADEC Method Three cleanup levels calculator and petroleum cleanup levels calculator (Brice, 2021). Site‐specific input values for fraction of organic carbon (foc) and hydraulic conductivity were used to calculate the soil ACLs. All other inputs were the ADEC default values. The foc input value was derived by calculating the 95 percent (%) lower confidence level of the mean of TOC samples collected outside of contaminant source zones during the 1998 Remedial Investigation (ERM West, Hart Crowser 1999) and the 2004 ACL Demonstration Project investigation (Clarus 2006). When using the 10 previous foc values and excluding one outlier result, the calculated site‐specific foc value is

0.01278 grams carbon per gram soil.

A site‐specific hydraulic conductivity value was derived from the 1998 Remedial Investigation (ERM West, Hart Crowser 1999). Results for grain size analysis performed on a soil sample collected from boring location B‐13 at a depth of 1.5 to 2 feet bgs were used in the Hazen equation to calculate a site‐specific hydraulic conductivity value of 2x10‐3 centimeters per second. This boring was chosen to be representative of the conditions in the active layer.

AKARNG submitted the ACL Summary and approval request to ADEC on 25 June 2020. ADEC approved the ACLs in a 30 July 2020 letter. Table 10‐1 presents the soil ACLs.

Table 10‐1 ADEC‐Approved Soil ACLs

COC

ADEC‐Approved ACLs

(mg/kg)1

GRO 1,400

DRO 3,000

RRO 10,000

Benzene 0.13

Toluene 47

Ethylbenzene 1.2

Total Xylenes 13

Chrysene 1,200

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Table 10‐1 ADEC‐Approved Soil ACLs

COC

ADEC‐Approved ACLs

(mg/kg)1

Fluorene 460

Naphthalene 0.43

Pyrene 1,100

1‐Methylnaphthalene 4.9

2‐Methylnaphthalene 15

Notes:

For definitions, refer to the Acronyms and Abbreviations section.

1 Approved by ADEC on 30 July 2020

Human Health Conceptual Site Model

This section describes the contaminants of potential concern (COPCs), COCs, contamination sources and release mechanisms, potentially impacted media, potential contaminant transport mechanisms, and exposure routes and pathways. COPCs for the Savoonga FSA site were determined using site history and known or potential sources of contamination. COCs were determined by comparing results for analytes detected during past investigations against the ADEC approved ACLs (Brice 2021), identified as the Project Action Limits (PALs) on Worksheet 15, Table 15‐1 for soil, and Table 15‐2 for groundwater. The CSM will be updated based on the RA results and documented in the subsequent RA Report.

A CSM is a tool used to describe and evaluate how human receptors might contact site chemicals under current and likely future conditions. The preliminary CSM uses data gathered from previous investigations to assess the potential receptors and exposure pathways at the Savoonga FSA. The CSM was prepared in accordance with the ADEC Guidance on Developing Conceptual Site Models (ADEC 2017b). The preliminary human health graphic and scoping forms are provided in Appendix D.

The CSM includes identification of the following elements:

Sources and chemical type

Affected media

Chemical release and transport mechanisms

Human receptors

Pathways and exposure routes

Sources and Type of Chemicals

The potential contaminant sources at the Savoonga FSA are associated with leaks and spills from ASTs and discarded drums. COPCs under these conditions are petroleum, oil, and lubricants including DRO, BTEX, and PAHs. Previous investigations have confirmed the presence of detectable concentrations of DRO, RRO, BTEX, and PAHs in soil and supra‐permafrost porewater. DRO, BTEX, naphthalene, 1‐methylnaphthalene, and 2‐methylnaphthalene have been identified as COCs for soil; DRO, RRO, and BTEX have been identified as COCs for supra‐permafrost porewater.

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Affected Media

Affected media includes surface soil, subsurface soil, and supra‐permafrost porewater. Potentially affected media includes surface water, indoor air, and outdoor air. Supra‐permafrost porewater at the FSA property has been encountered at depths as shallow as 2.5 feet bgs; in the absence of a determination in accordance with 18 AAC 75.350, supra‐permafrost porewater could be considered a potential future source of drinking water in Savoonga.

Chemical Release and Transport Mechanisms

Compounds released to the environment may undergo physical and chemical processes that can alter their chemical makeup or properties. The fate of metals is influenced by pH, oxygen content, salinity, and the presence of other metals. Interactions can result in both beneficial or adverse effects on ecological receptors and antagonistic or additive effects when it is present with other elements (Agency for Toxic Substances and Disease Registry [ATSDR] 2005, 2007). Petroleum products released to the environment migrate through soil as bulk oil flow infiltrating the soil and/or as individual compounds separating from the bulk petroleum mixture and dissolving in air or water (ATSDR 1999). DRO and PAHs are more likely to biodegrade and adsorb to soil or sediment than inorganic chemicals. The primary fate and transport processes that are of concern for chemicals are: adsorption to soil/sediment, leachability/water solubility, surface runoff/groundwater migration, and bioconcentration/ bioaccumulation potential.

Adsorption and/or Leaching. DRO and PAHs are COPCs. These compounds adsorb to soil or sediment and may leach to supra‐permafrost porewater.

Surface Runoff/Groundwater Migration. Porewater is perched on top of permafrost, making porewater migration/runoff a potential transport mechanism. Surface water is also present; therefore, surface water migration/runoff may also be a potential transport mechanism.

Partitioning to Air. Volatile compounds, including BTEX, have been detected in soil and supra‐permafrost porewater; therefore, volatilization of these compounds may be a potential transport mechanism.

Bioconcentration/Bioaccumulation. Contaminants have the potential to bioaccumulate; however, plants do not significantly take up fuel hydrocarbons and this is not considered to be a potential transport mechanism.

Human Receptors

Access to the Savoonga FSA property is not restricted. The site is located within the Village of Savoonga, and the property boundaries abut to…