W50S7524B0001_146_CES_Repair_Hangar_Bldg_801_Atch-12_AFFF_SPD_SSFR.pdf

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FINAL

SITE-SPECIFIC FINAL REPORT

AQUEOUS FILM FORMING FOAM (AFFF) REPLACEMENT AND DISPOSAL

AT SOUTH PACIFIC DIVISION

CHANNEL ISLANDS AIR NATIONAL GUARD STATION, CALIFORNIA

Prepared for:

U.S. ARMY ENGINEERING AND SUPPORT CENTER, HUNTSVILLE

Contract W912DY-17-D-0005 Task Order W912DY17F0851

Revision No. 0 August 13, 2019

James Salisbury Project QC Officer: 8/13/2019 (Signature) (Date)

Stephen Ciulla, P.E.

Project Manager: 8/13/2019 (Signature) (Date)

This report has been reviewed and signed by the Project Quality Control Officer and the Project Manager, attesting that the report is accurate and complies with task order requirements.

The views, opinions, and/or findings contained in this report are those of the author(s) and should not be construed as an official Department of the Army position, policy, or decision, unless so designated by other documentation.

i AFFF_SPD_SSFR_Channel Islands_Final.docx Rev. 0 Contract No. W912DY-17-D-0005, Task Order W912DY17F0851 08 2019

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TABLE OF CONTENTS

EXECUTIVE SUMMARY...................................................................................................... ii

CHAPTER 1 – PROJECT ACTIVITIES AND OPERATIONS ................................................1-1

1.1 Project Authorization .................................................................................... 1-1

1.2 Purpose and Scope....................................................................................... 1-1

1.3 Technical Approach ...................................................................................... 1-1

CHAPTER 2 – C8 AFFF REMOVAL, BLADDER REMOVAL, TANK/PIPE RINSING,

BLADDER INSTALLATION, C6 AFFF REPLENISHMENT, AND LEAK VERIFICATION ......2-1

2.1 Introduction ................................................................................................... 2-1

2.2 Work Performed ............................................................................................ 2-1

2.2.1 C8 AFFF Removal and C6 AFFF Replenishment in Bladder

Tanks ................................................................................................ 2-1

2.2.2 Leak Verification and Quality Control ............................................. 2-4

2.2.3 Waste Management ........................................................................ 2-4

2.2.4 Deviations from Work Plan ............................................................. 2-5

CHAPTER 3 – QUALITY CONTROL ACTIVITIES AND RESULTS ......................................3-1

3.1 Introduction ................................................................................................... 3-1

3.2 Field Implementation Worksheets ............................................................... 3-1

3.3 Waste Disposal Records .............................................................................. 3-4

3.4 Daily Status Reports ..................................................................................... 3-4

CHAPTER 4 – QUALITY ASSURANCE ACTIVITIES AND RESULTS ..................................4-1

CHAPTER 5 – SHELL WATER EVALUATION ...................................................................5-1

CHAPTER 6 – EXPOSURE DATA ....................................................................................6-1

APPENDICES

Appendix A Tank-Specific C8 AFFF Removal and C6 AFFF Replenishment Field Implementation Worksheets, Certificate of Leak Test, and DD Form 1354

Appendix B Waste Disposal Records Appendix C Daily Status Reports/Certificates of Destruction Appendix D Project Photographs Appendix E Notice to Mobilize Appendix F Procurement Letter Providing Product Cut Sheets ii

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EXECUTIVE SUMMARY

ES.1 The objective of this task order is to provide environmental support to facilitate transition of the U.S. Air Force fire suppression systems at Channel Islands Air National Guard Station (ANGS), California, from the present use of eight-carbon based (C8) aqueous film forming foam (AFFF) — which contains perfluorooctanoic acid (PFOA) or perfluorooctane sulfonate (PFOS) concentrate — to a more environmentally friendly fire-suppression product called six-carbon based (C6) AFFF.

ES.2 The actions performed to complete the project included the following:

Prepare a general Work Plan to conduct the fire protection support action.

Perform a site assessment to confirm engineering details of the installation’s fire protection system.

Prepare a Site Assessment Report.

Prepare a Site-Specific Work Plan to present how the work would be accomplished.

Perform the fire protection support action.

Prepare a Site-Specific Final Report (this document) to summarize the completion of the fire protection support action.

ES.3 The fire protection support activities were conducted from August 24, 2018 through August 30, 2018, and generally included:

Drain and collect the tank shell water.

Drain and collect the C8 AFFF from the tanks and piping.

Remove the existing bladders from the bladder tanks.

Triple-rinse the piping and collect the rinsate.

Install new bladders within the bladder tanks.

Replenish the tanks and piping with C6 AFFF.

Perform leak testing.

ES.4 The objectives of this project were provided in the accepted Site-Specific Work Plan for Channel Islands ANGS and include removing C8 AFFF from four tanks and replenishing C6 AFFF in the same four tanks.

ES.5 All C8 AFFF concentrate and rinsate/solution generated during the project were managed in accordance with project requirements. Documentation verifying this is included in the report. Table ES.1 summarizes key project information for the installation.

Table ES.1 Installation Key Information Summary Number of Tanks 4 Total Tank Capacity (gallons) 3,600 C8 AFFF Concentrate Removed (gallons)* 1,399 C8 AFFF Solution Removed (gallons) * 2,001 Date(s) of Incineration October 13, 2018 and May 13 and 24, C6 AFFF Replenished (gallons) 3,610 Date(s) of Replenishment August 27 and 28, 2018 Note: Based on the Certificate of Management and Certificate of Destruction.

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ES.6 The U.S. Army Engineering and Support Center, Huntsville accepted the work conducted via inspection of the fire suppression systems to ensure that the systems did not leak because of the C8 AFFF removal and C6 AFFF replacement actions. The C8 AFFF Removal and C6 AFFF Replenishment Field Implementation Worksheets, signed by the Government Representative, are provided in Appendix A and listed in Table ES.2.

Table ES.2 Field Implementation Worksheets Building/Hangar Number, Tank Identification Date of Government

Representative’s Signature Hangar 801, Tank 1 August 29, 2018 Hangar 801, Tank 2 August 29, 2018 Hangar 802, Tank 1 August 29, 2018 Hangar 802, Tank 2 August 29, 2018

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CHAPTER 1 – PROJECT ACTIVITIES AND OPERATIONS

1.1 Project Authorization

1.1.1 Parsons Government Services (Parsons) is serving as the prime contractor to the U.S. Army Engineering and Support Center, Huntsville (CEHNC) under Contract W912DY-17-D-0005, Task Order W912DY17F0851. This task order was established to conduct fire protection support actions at Air Force installations within the South Pacific Division to remove eight-carbon based (C8) aqueous film forming foam (AFFF) from fire protection tanks and replenish the tanks with six-carbon based (C6) AFFF, which has less impact on the environment.

1.1.2 As specified in the task order, this report summarizes the work performed during the fire protection support action at Channel Islands Air National Guard Station (ANGS), California, and presents an account of the volume of C8 AFFF removed and disposed of as well as the volume of C6 AFFF used to replenish the tanks.

1.2 Purpose and Scope

1.2.1 The objective of this task order is to provide environmental support to facilitate transition of U.S. Air Force fire suppression systems at specified bases and stations (installations) from the present use of C8 AFFF — which contains perfluorooctanoic acid (PFOA) or perfluorooctane sulfonate (PFOS) concentrate — to a more environmentally friendly fire suppression product, C6 AFFF. The actions performed to complete the project included the following:

Prepare a general Work Plan to conduct the fire protection support action.

Perform a site assessment to confirm engineering details of the installation’s fire protection system.

Prepare a Site Assessment Report.

Prepare a Site-Specific Work Plan to present how the work would be accomplished.

Perform the fire protection support action.

Prepare a Site-Specific Final Report (this document) to summarize the completion of the fire protection support action.

1.2.2 The Site-Specific Work Plan for Channel Islands ANGS proposed work on four bladder tanks. All tank systems would be drained of C8 AFFF and the piping would be triple-rinsed. The four bladder tanks would receive a new bladder, be replenished with C6 AFFF, and be returned to service.

1.3 Technical Approach

The accepted Work Plan included the plans listed below as required by the CEHNC Performance Work Statement.

Accident Prevention Plan Site Safety and Health Plan Environmental Protection Plan Spill Control Plan Waste Management Plan Work Phasing Plan Quality Control Plan

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Site-specific plans to perform the fire protection support action

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CHAPTER 2 – C8 AFFF REMOVAL, BLADDER REMOVAL, TANK/PIPE RINSING,

BLADDER INSTALLATION, C6 AFFF REPLENISHMENT, AND LEAK VERIFICATION

2.1 Introduction

2.1.1 Field operations to conduct this fire protection support action at Channel Islands ANGS were initiated on August 24, 2018 and were completed on August 30, 2018.

2.1.2 An overall chronology and succession of events is presented in Table 2.1. Project photographs are provided in Appendix D. The Notice to Mobilize was received from CEHNC on August 23, 2018 (Appendix E).

2.1.3 Before starting field operations, cut sheets summarizing the technical characteristics of the replacement bladders and C6 AFFF material were provided in a letter to CEHNC for acceptance (Appendix F). The 3% (Type 3) C6 AFFF was provided by Johnson Controls Inc. (JCI, formerly Tyco) and meets Mil-Spec MIL-F-24385. The bladders were provided by Royal Liner per the Performance Work Statement requirements and using the original tank specifications obtained during the initial site visits. This letter was accepted by CEHNC on August 23, 2018.

Table 2.1 Chronology of Events Mobilization to installation August 24, 2018 Initiation of the fire protection support action August 27, 2018 Completion of fire protection support action August 29, 2018 Shipping of waste C8 AFFF material to the disposal facility August 30, 2018 Demobilization from the installation August 30, 2018

2.2 Work Performed

2.2.1 C8 AFFF Removal and C6 AFFF Replenishment in Bladder Tanks

2.2.1.1 The process steps to perform the fire protection support action for bladder tanks include:

Drain and collect the tank shell water.

Drain and collect the C8 AFFF from the tank and piping.

Remove the existing bladder from the tank.

Triple-rinse the piping and collect the rinsate.

Install a new bladder within the tank.

Replenish the tank and piping with C6 AFFF.

Perform leak testing.

2.2.1.2 Work was performed on two bladder tanks at Hangar 801 and two bladder tanks at Hangar 802 by DCS Testing & Equipment, a specialty fire protection contractor, under supervision of the Parsons Site Safety and Health Officer (SSHO). In addition to the actions listed above, the nuts and bolts on the bottom flanges of Tanks 1 and 2 at Hangar 801 were replaced. The work performed generally conformed to the work procedures outlined in the Site-Specific Work Plan. There was one deviation from the work plan that occurred for two tanks. Deviations from the original scope of work are listed in Table 2.2 and described in Section 2.2.4, Deviations from Work Plan.

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Table 2.2 Tank Details and Tasks Performed

Hangar/Building Number, Tank Identification

Tank Manufacturer/ Model

Tank/Container Type

Individual Tank/

Container Capacity (gallons)

Tasks Required by the Site-Specific Work Plan(1)

Approximate Volume of

C6 AFFF

Replenished (gallons) Notes / Changes from Work Plan (2) Ta sk

A

Ta sk

B

Ta sk

C

Ta sk

D

Ta sk

A

Ta sk

B

Ta sk

C

Ta sk

D

Ta sk

A

Ta sk

B

Ta sk

A

Ta sk

B

Ta

A

Ta sk

B

Ta sk

C

Ta sk

A

Ta sk

B

Ta sk

A

Ta sk

B

Ta sk

Ta sk

1A

1B

1C

1D

2A

2B

Hangar 801, Tank 1

Arrow CCS3-10068HA

SN: RV2202-AT

Horizontal Bladder

1,000 — — — — — — — — — — — — — — — — — — — — — X X — — X X X 1,010 None

Hangar 801, Tank 2

Arrow CCS3- 10068HA

SN: RV2203-AT

Horizontal Bladder

1,000 — — — — — — — — — — — — — — — — — — — — — X X — — X X X 1,010 None

Hangar 802, Tank 1

Arrow CCS3-906VA

SN: RV2878-AT

Vertical Bladder 900 — — — — — — — — — — — — — — — — — — — — — X X O — X X X 895 Deviation: Field team was able to remove and replace the bladder without repositioning the tank.

Hangar 802, Tank 2

Arrow CCS3-706VA

SN: RV2879-AT

Vertical Bladder 700 — — — — — — — — — — — — — — — — — — — — — X X O — X X X 695 Deviation: Field team was able to remove and replace the bladder without repositioning the tank.

Totals 3,600 3,610 Notes:

(1) This list of tasks was derived from the Performance Work Statement and the Site-Specific Work Plan. Tasks completed per the Site-Specific Work Plan are marked with X, and deviations from the Work Plan are marked with O.

Task 2: Atmospheric Tanks Containing C8 AFFF and Associated Piping

Task 2A: Drain Tank and Drain/Rinse Associated Piping Task 2B (Optional): Plastic Atmospheric Tank Replacement Task 2C: Steel Atmospheric Tank Triple Rinse Task 2D (Optional): Plastic Atmospheric Tank Triple Rinse

Task 3: Bladder Tanks Containing C8 AFFF and Associated Piping Task 3A: Drain, Remove, and Dispose of Bladder, and Drain/Rinse Associated Piping Task 3B: Bladder Replacement Task 3C (Optional): Bladder Tank Removal and Reinstallation to Facilitate Bladder Replacement Task 3D: Bladder Tank Replacement

Task 4: C8 AFFF Reserve Bladder Tank Removal and Disposal Task 4A: Drain, Remove, and Dispose of C8 AFFF Reserve Bladder Tanks Task 4B: Remove, Drain, and Dispose of C8 AFFF Reserve Tank Piping

Task 5: C8 AFFF Disposal Task 5A: C8 AFFF Concentrate Disposal Task 5B: C8 AFFF Solution Disposal

Task 6: C6 AFFF Replenishment Task 7 (Optional): TWCF Atmospheric Tanks Containing C8 AFFF and Associated Piping

Task 7A (Optional): TWCF Drain Tank and Drain/Rinse Associated Piping Task 7B (Optional): TWCF Plastic Atmospheric Tank Replacement Task 7C (Optional): TWCF Plastic Atmospheric Tank Triple Rinse

Task 8 (Optional): TWCF C8 AFFF Reserve Atmospheric Tank Removal and Disposal Task 8A (Optional): Drain, Remove and Dispose of C8 AFFF Reserve Plastic Atmospheric Tanks Task 8B (Optional): Remove, Drain, and Dispose of C8 AFFF Reserve Tank Piping

Task 9 (Optional): TWCF C8 AFFF Disposal Task 9A (Optional): TWCF C8 AFFF Concentrate Disposal Task 9B (Optional): TWCF C8 AFFF Solution Disposal

Task 10 (Optional): TWCF C6 AFFF Replenishment Task 11 (Optional): ANG Bladder Tanks Containing C8 AFFF and Associated Piping

Task 11A (Optional): ANG Drain, Remove, and Dispose of Bladder, and Drain/Rinse Associated Piping Task 11B (Optional): ANG Bladder Replacement Task 11C (Optional): ANG Bladder Tank Removal and Reinstallation to Facilitate Bladder Replacement

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Task 11D (Optional): ANG Bladder Tank Replacement Task 12 (Optional): ANG C8 AFFF Disposal

Task 12A (Optional): ANG C8 AFFF Concentrate Disposal Task 12B (Optional): ANG C8 AFFF Solution Disposal

Task 13 (Optional): ANG C6 AFFF Replenishment

(2) Deviations from the Work Plan, if any, are summarized by tank in Section 2.2.4 of this Site-Specific Final Report.

— = Not applicable

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2.2.1.3 The volumes of C8 AFFF and shell water removed from these tanks are documented in the Daily Status Reports (Appendix C). The volume of C6 AFFF replenished in each tank is provided in Table 2.2. All volumes were documented by the SSHO in the C8 AFFF Removal and C6 AFFF Replenishment Field Implementation Worksheets (Appendix A).

2.2.2 Leak Verification and Quality Control

2.2.2.1 A system pressure leak test was performed for Tanks 1 and 2 in Hangar 801 after the fire protection support action was completed. The system pressure gauge read 80 pounds per square inch. The system was observed by the field team after the system had been at that same pressure for 16 hours. No leaks were observed. A Certificate of Leak Test is included in Appendix A.

2.2.2.2 A system pressure leak test was performed for Tanks 1 and 2 in Hangar 802 after the fire protection support action was completed. These tanks are on a pre-action (dry pipe) system. To test the system’s integrity, DCS used a hose bib connected to a float bag and brought the system up to the hose bib pressure (approximately 60 pounds per square inch). No leaks were observed. A Certificate of Leak Test is included in Appendix A.

2.2.2.3 An integrity test was performed on bladder tanks receiving a new bladder by compressing the bladder with a shop vacuum through the tank shell. The test was run for 15 minutes once the bladder was fully compressed. No leaks were observed.

2.2.3 Waste Management

2.2.3.1 Waste C8 AFFF is not hazardous waste as defined in 40 Code of Federal Regulations Part 261, the Resource Conservation and Recovery Act (RCRA). C8 AFFF waste was transported in U.S. Department of Transportation (USDOT)-approved containers to an offsite RCRA-permitted incineration facility for thermal destruction.

Rinsate was also transported to the offsite incineration facility because the rinsate contained C8 AFFF contamination. The removed bladders, C8 AFFF-contaminated debris, and personal protective equipment (solid waste) were packaged into USDOT-approved cubic yard boxes and also transported as nonhazardous debris to the offsite incineration facility for thermal destruction.

2.2.3.2 Waste materials transported offsite for incineration were sent to Heritage Environmental Services, Inc. in Coolidge, Arizona. Waste disposal records documenting transport of the waste to the incineration facility are in Appendix B. Table 2.3 summarizes the field-estimated quantities of waste transported offsite. All waste generated was managed in accordance with project requirements.

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Table 2.3 Field-Estimated Waste Quantities

Hangar/Building C8 AFFF Concentrate C8 AFFF Solution C8 AFFF Debris

Number of Boxes Pounds Gallons Pounds Gallons Hangar 801 1,275 150 14,028 1,670 2 Hangar 802 11,262.5 1,325 3,150 375 2 Installation Total 12,537.5 1,475 17,178 2,045 4

Note: Bolded values are taken from the Daily Status Reports (Appendix C) and Waste Generation Tracking Log (Appendix B). Values not bolded are derived using the density of C8 AFFF concentrate, 8.50 pounds per gallon, and the density of C8 AFFF solution, 8.40 pounds per gallon.

2.2.4 Deviations from Work Plan

At Hangar 802, there was one deviation from the work plan that occurred twice: The work procedures outlined in the work plan for both tanks included Optional Task 3C (temporary removal or repositioning of the tank) to facilitate replacement of the bladder. However, the field team was able to remove and replace the bladders without repositioning the tanks.

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CHAPTER 3 – QUALITY CONTROL ACTIVITIES AND RESULTS

3.1 Introduction

Extensive documentation of the day-to-day operations was required for the fire protection support action. Field operation records were created and retained for submittal with this report. Quality control measures are summarized in Table 3.1.

3.2 Field Implementation Worksheets

The field team documented the details of the fire protection support action performed on each tank on a C8 AFFF Removal and C6 AFFF Replenishment Field Implementation Worksheet (Appendix A). This worksheet provides the details of the work on a standard form that was completed by the Parsons SSHO and verified by the DCS Site Supervisor.

Their signatures verify that the work was conducted pursuant to the Site-Specific Work Plan. The form was then signed by the Government Representative, verifying that the systems did not leak because of the C8 AFFF removal and C6 AFFF replacement actions. The detailed summary information provided on the C8 AFFF Removal and C6 AFFF Replenishment Field Implementation Worksheet includes:

Tank type and volume Volume of shell water removed and how it was disposed of Volume of C6 AFFF replenished Results of leak testing and inspections Quality assurance / quality control verification of work completion and leak testing

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Table 3.1 Project Quality Control Measures Definable Feature of

Work Quality Control Processes/Requirements Pass/Fail Criteria/Explanation Pass/Fail Status/Explanation Perform Removal and Replacement Activities for Tanks Containing C8 AFFF and Associated Piping

Ensure purchased services/materials conform to project requirements.

Purchase order review and acceptance by Fire Protection Engineer is documented in procurement records.

Pass. The purchase order was reviewed and accepted by the Fire Protection Engineer.

Replenishment C6 AFFF is Mil Spec–compliant, and other materials comply with project requirements.

Replenishment C6 AFFF is 3% (Type 3), meeting Mil Spec Mil-F-24385, and is provided from Qualified Product List.

Pass. Specification for replenishment C6 AFFF, noting that it was 3% (Type 3), is included in Appendix E.

Delivered materials (e.g., C6 AFFF, tanks, bladders, pipe, pipe fittings) match the specifications of what was ordered.

Pass. The signed Field Implementation Worksheets (Appendix A) verified that delivered materials met the specifications in Appendix E.

C6 AFFF concentrate quantity is accounted for. The Field Implementation Worksheet was completed appropriately for each tank at project site; all required data recorded.

Pass. The signed Field Implementation Worksheets are included in Appendix A.

Each tank has been addressed according to the accepted site-specific assessment report (requirement from the Quality Control Plan). This requirement has been adjusted to replace the assessment report with the Site-Specific Work Plan based on recommendations from CEHNC and additional information from the installations that superseded the information in the Site Assessment Report.

Site Installation Checklist (Quality Control Plan term; now referred to as Field Implementation Worksheet) completed appropriately for each tank at project site; all required data recorded.

Pass. The signed Field Implementation Worksheets are included in Appendix A.

All specified tanks are accepted by the Government Quality Assurance Representative.

For this AFFF replacement project, the Government Representative elected to verify work completion by signing each tank-specific Field Implementation Worksheet that depicts the detailed work performed on each tank.

Pass. The signed Field Implementation Worksheets are included in Appendix A.

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Definable Feature of Work Quality Control Processes/Requirements Pass/Fail Criteria/Explanation Pass/Fail Status/Explanation

Dispose of C8 AFFF and Related Materials

C8 AFFF concentrate and solutions, and other related waste materials, are accounted for.

Data concerning C8 AFFF concentrate and rinsate recorded on Daily Status Reports match total quantities of waste materials on disposal documents (waste manifests).

Pass. Waste materials documented in the Daily Status Reports (Appendix C) are consistent with quantities of waste material on waste manifest (Appendix B).

Proper disposal of C8 AFFF is verified. Disposal certificates indicate point of origin, type(s) of material destroyed (e.g., C8 AFFF concentrate, C8 AFFF solutions), and volume and/or weight;

documents match wastes and quantities shipped.

Pass. Waste materials documented on the Certificate of Management and the Certificate of Destruction are consistent with quantities of waste material on the waste manifests (Appendix B).

Proper disposal of related materials is verified. Disposal certificates indicate point of origin, type(s) of material destroyed (e.g., C8 AFFF systems components), and volume and/or weight; documents match wastes and quantities shipped.

Pass. Waste materials documented on the Certificate of Management and the Certificate of Destruction are consistent with quantities of waste material on the waste manifests (Appendix B).

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3.3 Waste Disposal Records

3.3.1 Liquid and solid waste generated during the fire protection support action was transported to an offsite RCRA-permitted incineration facility for thermal destruction.

Appendix B contains the waste manifest documenting the approximate quantities of C8 AFFF concentrate and rinsate solution shipped offsite for final disposal by incineration. Appendix B also includes the Certificate of Management and the Certificate of Destruction from the permitted incineration facility, verifying that the liquid and solid wastes were destroyed. A Waste Disposal Volume Worksheet is also included in Appendix B.

3.3.2 The Certificate of Management (Appendix B) lists the total weight of the waste (e.g., C8 AFFF concentrate, C8 AFFF rinsate) plus the weight of the waste containers.

The weights of the containers are 128 pounds per tote, 22 pounds per plastic drum, and 38 pounds per steel drum. After subtracting the weights of the containers from the weights listed on the Certificate of Management, the amount of waste was converted from pounds to gallons using the density of C8 AFFF concentrate, 8.50 pounds per gallon, and the density of C8 AFFF solution, 8.40 pounds per gallon.

Table 3.2 summarizes the final waste disposal quantities based on quantities derived from the Certificate of Management and the Certificate of Destruction.

Table 3.2 Confirmed Waste Disposal Quantities

Hangar/ Building

C8 AFFF Concentrate C8 AFFF Solution C8 AFFF Debris Number of Boxes /

Pounds Pounds Gallons Pounds Gallons

Hangar 801 1,287.5 142.3 14,562 1,634 2 / 388 Hangar 802 11,372.5 1,256.7 3,270 367 2 / 387 Installation Total 12,660 1,399 17,832 2,001 4 / 775

Note: The Certificate of Management and the Certificate of Destruction unit of measure is pounds and includes the weight of the waste and the shipping containers. Values reported in units of gallons were derived by subtracting the weight of the shipping containers and using the density of C8 AFFF concentrate and solution.

3.3.3 The total gallons of waste (C8 AFFF concentrate and solution) are overestimated in the daily reports; however, the volumes of concentrate and rinsate on the manifests and other field documents are consistent and in general agreement with the field estimates, and the number of containers received by the disposal facility matches the numbers of containers shipped offsite. The discrepancy in the number of gallons occurs because the field estimate approximated how full the containers are, which is imprecise because the containers are not graduated. In addition, both the concentrate and rinsate foam expand in volume when handled, which can result in a higher estimate than the actual amount of liquid present in each container.

3.4 Daily Status Reports

3.4.1 The Parsons SSHO prepared Daily Status Reports for submittal to the Parsons Project Manager. These reports summarize the daily operations and include:

Operations completed for the day Operations planned for the next work day Personnel on site Estimated volumes of C8 AFFF drained from tanks and rinsate waste produced Estimated volume of C6 AFFF used to replenish tanks

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Summary of vehicles and equipment on site Any issues requiring resolution

3.4.2 The Daily Status Reports are provided in Appendix C.

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CHAPTER 4 – QUALITY ASSURANCE ACTIVITIES AND RESULTS

4.1 The CEHNC sent a Government Quality Assurance Representative to the installation to witness work and perform quality assurance to ensure that the work was conducted in accordance with the Site-Specific Work Plan.

4.2 The Government Quality Assurance Representative did not request any re-work.

4.3 The project was completed in general accordance with the accepted Site-Specific Work Plan. Although the Work Plan stated that a 1048 Quality Assurance form issued by the CEHNC would be used to document that the work performed at the installation is complete, the Government Quality Assurance Representative elected to verify work completion by signing tank-specific worksheets that depict the detailed work performed on each tank. Appendix A presents the tank-specific C8 AFFF Removal and C6 AFFF Replenishment Field Implementation Worksheet for each tank for which the fire protection support action was completed. Each worksheet was signed by the Government Quality Assurance Representative, verifying that the systems did not leak because of the C8 AFFF removal and C6 AFFF replacement actions, as summarized in Table 4.1.

Table 4.1 Field Implementation Worksheets Building/Hangar Number, Tank Identification Date of Government

Representative’s Signature Hangar 801, Tank 1 August 29, 2018 Hangar 801, Tank 2 August 29, 2018 Hangar 802, Tank 1 August 29, 2018 Hangar 802, Tank 2 August 29, 2018

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CHAPTER 5 – SHELL WATER EVALUATION

The field-estimated 1,955 gallons of shell water drained from the tanks at Hangars 801 and 802 were containerized and shipped offsite for disposal at the direction of the installation’s civil engineering squadron.

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CHAPTER 6 – EXPOSURE DATA

Exposure data for the fire protection support action at Channel Islands ANGS totaled 182 hours and is provided in the monthly reports.

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APPENDIX A – FIELD IMPLEMENTATION WORKSHEETS, CERTIFICATE OF LEAK TEST,

AND DD FORM 1354

This appendix contains the signed C8 AFFF Removal and C6 AFFF Replenishment Field Implementation Worksheet for each tank supported at Channel Islands Air National Guard Station. The worksheets were filled out by the Parsons Site Safety and Health Officer after completing the work at each tank and were verified by the DCS Site Supervisor. Their signatures verify that the work was conducted pursuant to the Site- Specific Work Plan. The Government Quality Assurance Representative then signed each worksheet, verifying that the systems did not leak because of the C8 AFFF removal and C6 AFFF replacement actions. This appendix also includes the Certificate of Leak Test and DD Form 1354.

Hangar/Building Number Tank Number

Hangar 801 Tank 1 Hangar 801 Tank 2 Hangar 802 Tank 1 Hangar 802 Tank 2

FIELD IMPLEMENTATION WORKSHEETS

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1. General

Attachment A CS AFFF Removal and C6 AFFF Replenishment

Field Implementation Worksheet

(1 Form per Tank)

Start Date: ,Z& AUl:-'201 J Installation Name: CN!.,o<\.oJ ::Z:5 tc;.,,..,d A (\.j l:::-

Facility/Hangar Description and Designation: ___,g~OC-'-1 _____________ _

Government QA Representative: __J'j)t::....:t/..::.::.,,<v_,,,c.,.(_,,&=' "-'"':J.Jff"'""b::;""'--'~-'-( __________ _

2. CS AFFF Tanks

Number of Primary Tanks in Hangar/Building: __ 2. __ _ Number of Reserve Tanks in Hangar/Building: _(:)=~-

Number of Tanks to be decommissioned in Hangar/Building _ _,(_)'="''-

This form addresses Tank No,--'---- per assessment report

Tank Manufacturer -~A:~r,r_o_w ____ _

Tank serial number 2o 1, <f~ / f2.V2J..02-fl:7

Tank Type: Bladder X' Tank Material: Steel X Tank Orientation: Vertical A>ft.

or description to identify the tank

Atmospheric /\:,/Ir

Plastic IV fl

Horizontal~><="'---

Gallons from tank data plate or from assessment report

Special Conditions (for example: HI-EX foam in tank) _,Iv'---'-~------------

Size ofTank: \bD2>

Confirm Lockout/Tagout v""A--;rv

3. Additional Containers of CS AFFF

Container Type: 55-gallon Drum /V/1;- 5-gallon Pail Iv/+ Other (specify below)

AJA:

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Number of Containers: 55-gallon Drum (V/'r 5-gallon Pail N'lt Other NP

4. Removal of CS AFFF

Was C8 AFFF Removed from tank and piping? Yt;) Date Completed: ZJAub 2-61-3

See Waste Management Tracking Forms for volumes and container types and sizes

5. Tank Rinsing {Atmospheric Tanks}

Was the tank triple Rinsed? /\J p.. Date Completed: f\J (\-

See Waste Management Tracking Forms for volumes and container types and sizes

6. Pipe Rinsing

Was the piping triple rinsed? Ytf s Date Completed: 2] frv&-z_o1J'

See Waste Management Tracking Forms for volumes and container types and sizes

7. Special Ancillary Work Required to Facilitate Bladder Removal and Replacement

Was any special work required to remove/install bladders?

Report any special work required to facilitate the removal and replacement of bladders:

f<1C,, • h, 1±$. oo bc,tf-o(Y) -he.°rj<"'-' tN,wtd ,wt C:0«1:e oJ:.£ :Tht ~1 i.,,...yc... bm Kt:o o.r-J C41lo c, ...J i,.;,}1,,. (\/lt.J '..-b.,a l.a s <::

I S-k:.-L( CLu k O-N ( bo t ts: -

8. Bladder Removal {Bladder Tanks Only}

Was the bladder removed? Y6' 5 Date Completed: (if not a bladder tank use NA) ZJl!ub'Zol8

Notes on the bladder removal and integrity of the removed bladder: JS Wdo r, f\~(--1-'1 t,...Q.s

'S f::, U ivor-d

9. Bladder Replacement (Bladder Tanks Only}

Was the bladder replaced at this tank? Y~S Date Completed: 'Z)!,f/U&l.OL.g

Confirm new bladder compliance (provide make/model): f/A) 443 '-fq 7 lb()O&t-/ (/.,e,y a. r l. (\.C r

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10. Removal of Shell Water (for bladder tanks only)

Gallons of shell water from bladder tank: Sos Total Gallons of shell water: 80 > Assessment of shell water for likelihood of contamination: Wi..s l'IP'l C,o"'.+a."", ~

Disposition of Shell Water: ./JP. Installation sanitary sewer

)( Transport to offsite waste management facility for incineration

11. Bladder Integrity Test (for bladder tanks only)

L Was the bladder replaced for existing tank?

2. Was the tank replaced by new tank and bladder?

Yes_)£

Yes..A!Ji.

No rJ/Jr No X

If the answer to question 1 above is yes, and question 2 is no, then conduct integrity test. There are 2 acceptable tests. The first test is referred to as the Ansul vacuum integrity test The vacuum integrity test has step by step instructions and is contained in the implementation package. The second test is described below. This second test is prescribed by Chemguard. Use the Chemguard test procedure provided in your installation package as a reference for other test information. The test is conducted by compressing the bladder with compressed air through the tank shell, Once the bladder is fully compressed observe the bladder concentrate valve line to bucket with water and watch for any more air bubbles. Observe for 10 minutes without bubbles to confirm integrity of bladder, Please note that bubbles are expected from valve 5 at the beginning of the test and should go away as the test proceeds.

The following legend should be used to identify the valve on the tank being tested:

• Valve 4 - Shell Vent Valve

• Valve 5 - Bladder Vent Valve

• Valve 6 -Shell Drain Valve

A- <\'3.U I V"l.C. uu"" ,(\~ r:~ k-S~L.J<>..S

Lo<\.duc...l-c.d °"'d r,-s~~d 0(\ '"2.ol'tubco( 3

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BLADDER INTEGRITY VERIFICATION

PROCEDURE

1. Isolate the bladder tank from the system by clos ing both the Water Inlet and Concentrate

Isolation Valves. Drain water from the tank shell by opening shel l drain and shell vent valves.

2. Transfer remaining foam concentrate in bladder to 55 gal lon drums or some other container.

3. When tank is completely drained , the valves on the bladder tank should be in the following posi tions:

Water Inlet Valve . . . . . . Closed

Closed

Closed

Closed

Concentrate Isolation Valve.

Tank Shel l Drain Valve

Tank Shell Vent Valve .

Bladder Vent Valve .

Bladder Drain Valve

....... . . Open

. . ... .... Open

4. Using a Wet/Dry shop vacuum of 2 HP mini mum, attach the vacuum hose to the tank shell vent valve. This may be accomplished by using pipe fitting and securing with duct tape.

5. Connect vacuum hose to shop vacuum and start vacuum. Note the high pitched sound from the vacuum before opening the valve. This is the same sound that should be heard in step #7.

6. Open Tank Shell Vent Valve to pull the air out between the bladder and the tank shell , which will pull the bladder out to the tank shell wall.

7. When the change in pitch from the vacuum is heard, this indicates that bladder is now com pletely pulled out to the tank shell wall.

8 . If no change in pitch is noted after about 15 min utes, then the bladder is damaged and needs to be replaced.

9. If there is a change in pitch, this indicates that the bladder is not damaged, close the Tank Shell

Vent Valve and then turn off the vacuum. The bladder tank can now be ref illed as per the ANSUL Bladder Fill Manual (P/N 74177; 1995 version) , using the vacuum method.

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A

END VIEW

Bladder Integrity Test Setup

NiTROGEf•; OR

COMPRESSED AIR

If the answer to question 1 is no and question 2 is yes, then confirm verification from manufacturer that integrity test has been completed and attach to report.

If answer to question 2 is YES, provide manufacturer's documentation for the "system" of the tank and bladder as certified from the manufacturer.

12. Atmospheric Tank Integrity Test

An inspection is performed on atmospheric tanks to verify that there are no leaks in the tank after C6 is replenished in the tank.

1. Was the tank inspected

2. Were any leaks observed YesJJ..t Yes IV fl(

No VV fr No..AlJL

13. Piping leak Testing (bladder tanks and hydrostatic tanks)

1. Was a tank replaced? Yes IUf\ No~

2. Was a section of pipe replaced? Yes~ No_K_

3. Can the newly installed pipe be isolated? Yes~ No NA-

4. Can all rinsed/removed piping be filled with C6 without running the pump(s)?

Yes1_ No NA--'

If the answer is yes to either question 1 or 2 above, and yes to question 3, conduct a hydrostatic Leak test at 200 psi (13.8 bars) for 2 hours and verify that there are no leaks (NFPA 13).

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If the answer is yes to either question 1 or 2 above, and no to question 3, then perform a Work Pressure

Leak Test to test the system at working pressure after installation of C6. Provide spill containment measures per work plan and relieve pressure if leaking occurs. Repair pipe leak and repeat system working pressure test.

Question 4 would apply to the piping downstream of the pump on an atmospheric tank arrangement where there is a check valve in the re-circulation line that would prevent gravity feed of C6 into the piping downstream of the foam concentrate pump. This section of pipe should be left dry (from pump to proportioner to the check-valve in the recirculation line.

14. Hydrostatic Test

All piping tested at _~i\J~P: ___ psi for /vP,. hours

Observed start time: Nfr ~~~-- Observed stop time: ___,/'yf\=..,_ __ _

Dry piping pneumatically tested? ..Jfes / f~o

Hydrostatic Test Conducted Properly per procedure? -Yes/ tfo

Were any leaks observed during Hydrostatic test? t es 7 No

Were leaks repaired and any leaks detected during a second test? '¥es I ~Je

Do you verify as the installing contractor that additives and corrosive chemicals, sodium silicate, brine, or other corrosive chemicals were not used for testing systems or stopping Leaks? ~·es/ MG

15. Work Pressure Leak Test

All piping tested at _ _,_S~o~--- psi for __ !_«:> ___ hours

Observed start time: li..,oo(28flU/,axJ)observed stop time: OtM> 2C'fAvt:,UJ(€

Pressure Test Conducted Properly per procedure? ~ No

Were any leaks observed during Pressure test? Yes/ tif> Were leaks repaired and any leaks detected during a second test?

Verify C6 Mil Spec compliance /If""!(_,

16. C6 Replenishment

-¥es/ Pdo

Was C6 replenished in this tank? Y6 S Date Completed: zg Au<=.-c 6lO

Volume of C6 replenished --"'lo=..<:.._O=--- Gallons

Verify power resumed and lockout/tagout tags are removed v/r?{_.

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Completed by (Print Name/Company} ~ Los0=-£: p.,.CSO:!\'.)

Signature d::? DATE 2.ct{tVl:W

Verified by (Print Name/Company} ft.... Dr°'H" / .I);::.,.S Signature ~ , DATE "'?: /'2."i/ i~ w,,~ .. "'(Gw. QA .. , .. ~,..,,~, ~-4-f //{,,v? Cfif

Signature#,_ _ _ DATE?f6,/r'

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CB AFFF Removal and CG AFFF Replenishment

Field Implementation Worksheet

(1 Form per Tank)

Start Date: 23 /tU(c e:.o L/3

Installation Name: (:.J'<>--l'N....l -:z:s tc.,,.J /\/.Ji::, Facility/Hangar Description and Designation: __,Ul,c'.'...!_I ______________ _

Government QA Representative: _.,.O=tL=v,~·~J~_,~c..-_'h'--'ff~~=lc.,( ___________ _

2. CS AFFF Tanks

Number of Primary Tanks in Hangar/Building: _?..,__ __ Number of Reserve Tanks in Hangar/Building: 0 Number of Tanks to be decommissioned in Hangar/Building _0=--- This form addresses Tank No. __ c ____ per assessment report

Tank Manufacturer __ A----'r-r;~o~<-J~-----

Ta nk serial number _ _cc2::::..,Vc..Z=2Q"'='-3...L-__,,4-'--'-'7-'-_____ or description to identify the tank

Tank Type:

Tank Material:

Tank Orientation:

Bladder >c Steel X

Vertical /\..I fl--

Atmospheric /ufl.

Plastic IJPr:

Horizontal X Size of Tank: __ {_O_O-'--'D'-_Gallons from tank data plate or from assessment report

Special Conditions (for example: HI-EX foam in tank) _,/Uc_r..P.-___________ _

Confirm Lockout/Tagout /fl::t:L

3. Additional Containers of CS AFFF

Container Type: 55-gallon Drum /1//1-- 5-gallon Pail /\,/ft Other (specify below)

/1/ll-

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Number of Containers: 55-gallon Drum /IJft 5-gallon Pail (t)Ft Other AJA:

4. Removal of CS AFFF

Was C8 AFFF Removed from tank and piping? Yrf 5 Date Completed: ?J1tu&'20lJ

See Waste Management Tracking Forms for volumes and container types and sizes

5. Tank Rinsing (Atmospheric Tanks)

Was the tank triple Rinsed? (V(+- Date Completed: /V p..

See Waste Management Tracking Forms for volumes and container types and sizes

6. Pipe Rinsing

Was the piping triple rinsed? Y{ S Date Completed: '2.JAv&Z.6<,Q

See Waste Management Tracking Forms for volumes and container types and sizes

7. Special Ancillary Work Required to Facilitate Bladder Removal and Replacement

Was any special work required to remove/install bladders?

Report any special work required to facilitate the removal and replacement of bladders:

I$ o H-s Ol\ bl) &vv1 /ftMf;}?s u.>ou (d i\o+: Cfor'\C:.... °'Jr-

8. Bladder Removal (Bladder Tanks Only)

Was the bladder removed? V£s Date Completed: (if not a bladder tank use NA) 'ZS,:,,U6t.Dl,j

Notes on the bladder removal and integrity of the removed bladder: 1?,tc,.JJ._r 11t-1c'ur::fy ~ Sh/( J~

9. Bladder Replacement (Bladder Tanks Only)

Was the bladder replaced at this tank? L(£S Date Completed: -Z8f/Ub 26(,f

Confirm new bladder compliance (provide make/model): //)1\.J 44 J4q7 16/)(){;,H ~ /2oyc,,I L,he..-

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Gallons of shell water from bladder tank: Jo$'

Total Gallons of shell water: -~,2~oc,_,..,S::c......_

Assessment of shell water for likelihood of contamination: l/1/4 S l'tc r Co<'l-/u.,m, ~

Disposition of Shell Water: Nit Installation sanitary sewer

X Transport to offsite waste management facility for incineration

11. Bladder Integrity Test (for bladder tanks only)

1. Was the bladder replaced for existing tank?

2. Was the tank replaced by new tank and bladder?

Yes_K_

Yes //JI/- No /Vlf No____K

If the answer to question 1 above is yes, and question 2 is no, then conduct integrity test. There are 2 acceptable tests. The first test is referred to as the Ansul vacuum integrity test. The vacuum integrity test has step by step instructions and is contained in the implementation package. The second test is described below. This second test is prescribed by Chemguard. Use the Chemguard test procedure provided in your installation package as a reference for other test information. The test is conducted by compressing the bladder with compressed air through the tank shell. Once the bladder is fully compressed observe the bladder concentrate valve line to bucket with water and watch for any more air bubbles. Observe for 10 minutes without bubbles to confirm integrity of bladder. Please note that bubbles are expected from valve 5 at the beginning of the test and should go away as the test proceeds.

The following legend should be used to identify the valve on the tank being tested:

• Valve 4-Shell Vent Valve

• Valve 5 - Bladder Vent Valve

• Valve 6 -Shell Drain Valve

A f\ Su I \J<A...c..utJ<l'\ i (l ~ r' i) +cs+- ~s 0J<ld.uw ~cl pc-...~<;cd on 2Jf/v&-2':Jt8

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PROCEDURE

1. Isolate the bladder tank from the system by clos in g both the Water In let and Concentra te

Isolation Valves. Drain water from the tank shell by opening shell drain and shell vent valves.

2. Transfer remaining foam concentrate in bladder to 55 gallon drums or some other container.

3. When tank is completely drained, the valves on the bladder tank should be in the following posi tions:

Water Inlet Valve

Concentrate Isolation Valve .

Tank Shell Drain Valve

Tank Shell Vent Valve

Closed

Closed

Closed

Closed

Bladder Vent Valve . . . . . . . . . . . . Open

Bladder Drain Valve . . . . . . . . . . . Open

4. Using a Wet/Dry shop vacuum of 2 HP mini mum, attach the vacuum hose to the tank shell vent valve. This may be accomplished by using pipe fitting and securing with duct tape.

5. Connect vacuum hose to shop vacuum and start vacuum. Note the high pitched sound from the vacuum before opening the valve. Th is is the same sound that should be heard in step #7.

6. Open Tank Shell Vent Valve to pull the air out between the bladder and the tank shell , which will pull the bladder out to the tank shell wall.

7. When the change in pitch from the vacuum is heard, this indicates that bladder is now com pletely pulled out to the tank shell wall.

8. If no change in pitch is noted after about 15 min utes, then the bladder is damaged and needs to be replaced.

9. If there is a change in pitch, this indicates that the bladder is not damaged, close the Tank Shell

Vent Valve and then turn off the vacuum. The bladder tank can now be re fi ll ed as per the

ANSUL Bladder Fill Manual (P/N 74177; 1995 version), using the vacuum method.

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W ~~o AlR 81..tB6LES ARE DETECTED· ,t·iCiJC.<, TES

BLAOOER

COMPRl::lSSEtl t,)~

E'1D\/IEW

Bladder Integrity Test Setup

If the answer to question 1 is no and question 2 is yes, then confirm verification from manufacturer that integrity test has been completed and attach to report.

If answer to question 2 is YES, provide manufacturer's documentation for the "system" of the tank and bladder as certified from the manufacturer.

12. Atmospheric Tank Integrity Test

An inspection is performed on atmospheric tanks to verify that there are no leaks in the tank after C6 is replenished in the tank.

1. Was the tank inspected

2. Were any leaks observed

Yes.JYA

Yes~

13. Piping Leak Testing (bladder tanks and hydrostatic tanks)

1. Was a tank replaced? Yes Nft No~

2. Was a section of pipe replaced? Yes W1t No___J{_

3. Can the newly installed pipe be isolated? Yes..Mft_ No /JI(

4. Can all rinsed/removed piping be filled with C6 without running the pump(s)?

YesjL No f\J1A

If the answer is yes to either question 1 or 2 above, and yes to question 3, conduct a hydrostatic Leak test at 200 psi (13.8 bars) for 2 hours and verify that there are no leaks (NFPA 13).

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If the answer is yes to either question 1 or 2 above, and no to question 3, then perform a Work Pressure measures per work plan and relieve pressure if leaking occurs. Repair pipe leak and repeat system working pressure test.

Question 4 would apply to the piping downstream of the pump on an atmospheric tank arrangement where there is a check valve in the re-circulation line that would prevent gravity feed of C6 into the piping downstream of the foam concentrate pump. This section of pipe should be left dry (from pump to proportioner to the check-valve in the recirculation line.

14. Hydrostatic Test

All piping tested at __ LfV~f<' __ psi for --",V"'-"-/1---- hours

Observed start time: -~N~IJ-__ Observed stop time: ~fJ~~fl-" __ _ Dry piping pneumatically tested? ...,'es/ r~u

Hydrostatic Test Conducted Properly per procedure? YES/ lfo

Were any leaks observed during Hydrostatic test? ¥es/ Na

Were leaks repaired and any leaks detected during a second test? ¥es/ fcJo

Do you verify as the…