B420 Environmental Site Characterization Sampling Analysis Plan.pdf

TAB F

ENVIRONMENTAL SITE CHARACTERIZATION

SAMPLING & ANALYSIS PLAN

Environmental Site Characterization Report

Asbestos, Lead-Bearing Paint, and Hazardous Materials Assessment Report

Environmental Materials Management Plan

Site Characterization Sampling & Analysis Plan

Wisconsin Air National Guard Air Fighter Wing Facility F-35 Beddown: Combined Three

Projects W9133L-16-D-005/W50S9F-21- F-0001

XGFG182019

XGFG182053

XGFG202053

Prepared for:

FRANKFURT-SHORT-BRUZA ASSOCIATES, PC

(FSB)

5801 Broadway Extension, Suite 500 Oklahoma City, OK 73118 Telephone: 405.840.2931

Email nchapman@fsb-ae.com

October 29, 2021 mailto:nchapman@fsb-ae.com

5201 E. Terrace Drive, Suite 200

Madison, WI 53718

608.443.1200 • Fax: 608.299.2184 www.AyresAssociates.com

Ayres Project No. 52-0716.00 File: I:\51\MD\WIANG Sunshade Gun Shop\SAP\Sunshade_SAP.docx

Site Characterization Sampling & Analysis Plan

Wisconsin Air National Guard Air Fighter Wing Facility F-35 Beddown: Combined Three Projects W9133L-16-D-0005/W50S9F-21-F-0001

XGFG182019

XGFG182053

XGFG202053

Truax Field

Madison, Wisconsin

This report prepared by:

Thomas Gaieck, PG Hydrogeologist

This report reviewed by:

Charlie Jensen, PG, CPG Hydrogeologist/Project Manager

Approved by:

Ben Peotter, PE Manager – Development Services Midwest i

Contents Page No.

1.0 Introduction

Site Address and Location

Responsible Party and Project Consultant

2.0 Project Background

3.0 Initial Evaluation

Site Location and Description

Site History and Background

Environmental Concerns

Regional Geology and Hydrogeology

Geology Hydrogeology

Site Conceptual Model

4.0 Sampling Objectives and Rationale

Assessment Tasks

Permitting Soil Samples

Groundwater Samples

Asbestos Survey

Lead Bearing Paint Survey

5.0 Schedule

6.0 Project Team and Management

Organization

7.0 Objectives of Sampling Program

Rationale for Selection of Analytical Parameters

Analytical Data Quality Levels

8.0 Scope of Work

Field Assessment Objectives Field Assessment Activities

Assessment Strategy

Permitting

Soil Assessment

Drilling and Soil Sampling Methods

Borehole Abandonment Groundwater Assessment

Temporary Well Installation ii

Well Development

Monitoring Well Survey

Collection and Analysis of Soil and Groundwater Samples Soil Samples

Groundwater Samples

Data Analysis and Evaluation

Site Assessment Report

Asbestos, Lead Paint, and Hazardous Materials Survey

ACM Assessment Lead-Based Paint Assessment

9.0 Quality Assurance/Quality Control (QA/QC) Samples

10.0 Decontamination Procedures

11.0 Storage and Disposal of Assessment Wastes

12.0 Laboratory Program

13.0 NR 712.09 Submittal Certification

14.0 References

List of Tables

Table 1 Summary of Proposed Sample Locations and Analyses Table 2 Summary of Proposed Monitoring Wells Table 3 Wisconsin Air National Guard Site Characterization Analytical Program Table 4 Sample Bottles, Preservatives, and Holding Times Table 5 Compound List, Quantitation Limits, and Standards (Soil) Table 6 Compound List, Quantitation Limits, and Standards (Groundwater) Table 7 Compound List, Quantitation Limits, and Standards (Lead and Asbestos)

List of Figures

Figure 1 – Site Location Map Figure 2 – Proposed Soil Probe and Monitoring Well Locations Figure 3 – Project Schedule

List of Appendices

Appendix A Ayres Associates Standard Operating Procedures

Appendix B WDNR Site Characterization Technical Memoranda (April 2020)

1.0 Introduction

This document presents the Sampling and Analysis Plan (SAP) for subsurface assessment to be performed at the Sunshade for CT Mission (new)/Sunshade for Deployable Mission (new) and the asbestos and lead bearing paint inspection at the existing Gun Shop – Building B420 at the Wisconsin Air National Guard (WIANG) base located at Truax Field in Madison for the F-35 beddown project. Ayres Associates will conduct this assessment in accordance with NR 700 Wisconsin Administrative Code.

Asbestos inspection will follow the Wisconsin Administrative Code NR 441 and National Emissions Standards for Hazardous Air Pollutants (NESHAP) regulations.

The SAP outlines the policy and organizational structure for completing the assessment, describes the rationale and approach to the project, summarizes the tasks to be performed, and outlines the schedule for implementing the assessment. The SAP outlines the objectives of the sampling program and describes in detail the activities and sampling procedures to be used during the project. Changes required in the procedures described in this SAP due to site conditions, or other constraints, will be properly documented in the site logbook. Significant changes to the SAP, such as the addition or deletion of tasks, will be detailed in a technical memorandum to the client and the Wisconsin Department of Natural Resources (WDNR).

Site Address and Location

Address of Site: F35: Bed Down (Two site locations) Truax Field 3200 Pierstorff Street Madison, Wisconsin

The site is located in the Northeast ¼ of the Northwest ¼ of Section 29, Township 8 North, Range 10 East, Dane County, Wisconsin. WTM Coordinates x: 573861.85115, y: 295690.15869 (See Figure 1.)

Responsible Party and Project Consultant

The project contacts for this site are as follows:

Client: FSB Architects & Engineers 5801 Broadway Extension, Suite 500 Oklahoma City, Oklahoma 73118

Contact: Nicholas Chapman, PE, Project Manager

(405) 840-2931 nchapman@fsb-ae.com

Site Owner: Wisconsin Air National Guard (WIANG) 3200 Pierstorff Street Madison WI 53704

Contact: LtCol Michael Dunlap (115th CE-BASE CIVIL ENGINEER)

(608) 245-4342 michael.dunlap@us.af.mil

Consultant: Ayres Associates 5201 E. Terrace Drive, Suite 200 Madison, WI 53718

Contact: Thomas P. Gaieck, PG

(608) 443-1200 gaieckt@ayresassociates.com mailto:nchapman@fsb-ae.com mailto:Michael.dunlap@us.af.mil mailto:gaieckt@ayresassociates.com

Regulatory Agency: Wisconsin Department of Natural Resources

3911 Fish Hatchery Road Fitchburg, WI 53711

Contact: Issac Ross

(414) 750-7140 Issac.Ross@wisconsin.gov mailto:Issac.Ross@wisconsin.gov

2.0 Project Background

The WIANG installation at Truax Field has been home to the 115th Fighter Wing since 1995. The installation has been home to primarily fighter/attack aircraft, most recently F-16 and RC-26B aircraft. In April 2020, the United States Air Force announced that the 115th Fighter Wing would receive a fleet of F- 35A aircraft. The base will transition from operations involving F-16 aircraft to F-35A aircraft, including upgrading facilities to house the new aircraft.

FSB Architects & Engineers (FSB) has been retained by the WIANG to upgrade their installation to accommodate the F-35A aircraft including the construction of a Sunshade for CT Mission/Deployable Mission and renovation of the Gun Shop-Building B420. Ayres Associates will be partnering with FSB on the project to provide environmental services including assessment of soil and groundwater for volatile organic compound (VOC) and Per- and Polyfluorinated Alkyl Substances (PFAS) which have been previously documented at sites near the proposed location of the Sunshade site. The presence of VOC compounds in soil and groundwater are associated with the use and storage of petroleum and other hazardous substances at the installation. The PFAS contamination detected at the site is attributed to the storage and use of firefighting foams at Hangar 414 and other nearby buildings or firefighting equipment testing areas at the base.

The Wisconsin Department of Natural Resources (WDNR) is requiring assessment of VOC and PFAS concentrations in soil and groundwater at the proposed Sunshade site and submittal of a Materials Management Plan based upon the results of this assessment. In addition to the subsurface investigation and preparation of a Materials Management Plan for the Sunshade site, an asbestos inspection and lead-bearing paint assessment will be conducted on the Gun Shop-Building B420 so that these materials, if present, are properly managed prior to building renovation.

3.0 Initial Evaluation

Site Location and Description

The project site is located in the Northeast ¼ of the Northwest ¼ of Section 29, Township 8 North, Range 10 East, Dane County, Wisconsin. The site (herein referred to as site or property) is located at Truax Field, 3200 Pierstorff Street, Madison, Wisconsin (Figure 1).

With the recent announcement that the base will be transitioning to F-35A aircraft, several buildings and engineering appurtenances will require replacement or retrofitting to accommodate the new mission.

Site History and Background

Background information for the Sunshade site and the Gun Shop-Building B420 was gathered from environmental reports for nearby sites at Truax Field obtained from the WDNR Bureau of Remediation and Redevelopment Tracking System (BRRTS). The “Draft Report, FY 16 Phase 1 Regional Site Inspections for Perfluorinated Compounds (March 2018), prepared by Amec Foster Wheeler under contract to the WIANG was also used as a source of information.

The WIANG installation at Truax Field was originally constructed in 1942 as an Army base. The base was deactivated as an active military base in 1968 when it became occupied by the WIANG. Since 1942 fighter/attack aircraft have been housed at Truax Field. Over the years, the installation has used and stored petroleum and other hazardous materials.

The Department of Defense has conducted environmental investigations at military bases across the country as part of the Installation Restoration Program. The WIANG base at Truax Field was one of the facilities included in the program. According to the WDDNR BRRTS, environmental activities have been conducted on the site since 1990 when a preliminary facility investigation indicated soil and groundwater in the proximity of Hangar 414 was impacted by petroleum. A subsequent investigation conducted by Dames and Moore defined an area of soil and groundwater contamination that resulted in excavation and disposal of petroleum-contaminated soil and operation of a soil vapor extraction system (SVE). The site was closed by the WDNR in 2012 with residual soil and groundwater contamination.

A Perfluorinated Compound Preliminary Assessment Site Visit was conducted on the base by BB&E, Inc.

in 2015. The purpose of the visit was to identify sites with potential perfluorinated compound releases associated with Aqueous Film Forming Foam (AFFF) use and storage. Results of the assessment are documented in the “Final Perfluorinated Compounds Preliminary Assessment Site Visit Report (December 2015) prepared by BB&E, Inc. Findings of the report concluded that Hangar 414 was equipped with a fire suppression system supplied with AFFF and that a site characterization of soil and groundwater was recommended.

A Phase 1 Regional Site Inspection for Perfluorinated Compounds was conducted at the base by Amec Foster Wheeler in 2017. This work included subsurface investigation of soil and groundwater for perfluorinated compounds based upon the recommendations of the 2015 BB&E Site Visit Report. Soil boring were advanced at Hangar 414, Hangar 406, Hangar 400 as well as several other buildings site for collection of soil and groundwater samples. Results of soil sample analysis indicated detectable perfluorinated compound concentrations. Groundwater analysis detected perfluorinated compounds at concentrations exceeding the EPA Drinking Water Health Advisory.

Environmental Concerns

Environmental concerns regarding the Sunshade site are related to the known volatile organic compound (VOC) perfluorinated compound contamination documented at nearby sites at Truax Field. Based upon the age of buildings at Truax field, including the Gun Shop-Building 420, asbestos and lead bearing paint may be present and would require proper handling prior to building renovation.

Regional Geology and Hydrogeology

Geology

Evaluation of the site geology is based on existing published regional information1, and site-specific data collected from borings advanced in the project area. Subsurface information collected during previous assessment activities conducted on the site indicates that the unconsolidated sediments consist primarily of between 3 and 7 feet of clay and silty clay underlain by fine to medium-grained sand to a depth of at least 18 feet below ground surface.

Regional information indicates that surficial unconsolidated deposits consist of off-shore lake sediment consisting of plane-bedded and cross-bedded sand and plane bedded silt and clay. The unconsolidated deposits in the site area are estimated to be nearly 300 feet thick. The uppermost bedrock unit in the area of the site is the Cambrian age Mt. Simon Sandstone.

Hydrogeology

Groundwater aquifers are found within the unconsolidated glacial deposits and underlying sandstone bedrock. These aquifers are the source for domestic, municipal, and industrial water supplies in the Madison area and Dane County. The bedrock aquifer is the principal source for municipal water in Dane County. The City of Madison uses wells completed in the Mount Simon sandstone for its municipal water supply. Truax Field is supplied water from the City of Madison distribution system.

Depth to groundwater is generally less than five feet below ground surface. Previous investigations at the site indicate that shallow groundwater has been interpreted to flow south-southeast or northwest depending on the location at the base.

Site Conceptual Model

A site conceptual model is a preliminary evaluation and description of the natural environment that exists at the site, including hydrogeologic conditions, potential contamination sources, contaminant release mechanisms and migration routes, potential human and ecological receptors that may come in contact with contaminants, and potential exposure pathways. The conceptual model is based on existing published information or knowledge of a site and provides a preliminary framework for planning and implementing site characterization activities.

Based on existing information, the anticipated site stratigraphy in the Sunshade project area will consist of clay and silty clay overlying fine to medium-grained sand to the depth of exploration.

Depth to groundwater is anticipated to be within five feet of ground surface. Recharge to the upper aquifer system is likely through direct infiltration of precipitation and snowmelt. Discharge from the shallow aquifer system likely occurs by evapotranspiration and seepage into Starkweather Creek. Groundwater flow in

1 Clayton, Lee and Attig, J.W. 1997. “Pleistocene Geologic Map of Dane County, Wisconsin, WGNHS Bulletin 95, Plate 1.

the shallow water table is interpreted to be south southeasterly (or northwest depending on location), based on previous investigations performed nearby.

Environmental impacts to be investigated at the Sunshade site, based on information from the Wisconsin Department of Natural Resources (WDNR) and the Wisconsin Air National Guard (WIANG) include volatile organic compounds (VOC) and Per- and Polyfluorinated Alkyl Substances (PFAS) in soil and groundwater. These compounds have been detected during previous investigations conducted at the site.

In addition, site buildings are scheduled for demolition or retrofitting. Therefore, building materials will be assessed for the presence of asbestos and lead-bearing paint.

Likely contaminant release mechanisms and exposure routes include direct contact and ingestion threats from impacted soil by on-site workers and off-site migration of contaminated groundwater. Infiltration of precipitation may also transport contaminants from soil into the groundwater; impacted groundwater could potentially be discharging to Starkweather Creek.

4.0 Sampling Objectives and Rationale

Data Quality Objectives (DQOs) are qualitative and quantitative statements that clearly state the objective of a proposed project, define the most appropriate type of data to collect, determine the appropriate conditions for data collection, and specify acceptable decision error limits that establish the quantity and quality of data needed for decision making. The DQOs are based on the use of the data that will be generated. Different data uses may require different quantities of data and levels of quality.

The need to implement remedial action at the sites identified in this SAP and the type of remedial action that may be required is contingent on the hydrogeologic conditions and other physical and environmental characteristics at the site. Therefore, a complete and accurate assessment of conditions at these sites is essential. The overall goal of this assessment is to provide information for redevelopment.

The following site characterization issues will be addressed to evaluate the potential threat to human health and welfare or the environment:

• Define topography and major geomorphic features

• Define the local geology including the origin, texture, thickness, and distribution of the unconsolidated deposits

• Determine local hydrogeologic conditions including depth to groundwater, groundwater flow directions, and gradients

• Determine the type and distribution of contaminants of concern in soil and groundwater for subsequent preparation of a Materials Management Plan

• Evaluate potential contaminant pathways and the potential for migration in soil and groundwater

The primary objectives of the assessment are to:

• Characterize the hydrogeologic and other environmental conditions

• Determine the presence of potential environmental impacts at the site

• Evaluate the threat, if any, to human health and the environment

• Evaluate the need to implement remedial action at the site regarding site redevelopment

• Assess the concentrations and possible environmental impacts from VOC and PFAS within the area of Sunshade construction

• Evaluate the groundwater flow system to determine the potential for off-site migration

• Characterize the Gun Shop-Building 420 for asbestos and lead paint prior to demolition or alterations.

Assessment Tasks

Tasks to be performed to meet the objectives of the assessment include advancing soil probes, installation of temporary groundwater monitoring wells, collection and laboratory analysis of soil, groundwater, asbestos, and lead paint samples, and evaluation of the data collected.

The number of probes and wells included in the sampling and analysis plan is summarized in Table 1.

The locations of the proposed borings and wells are shown in Figure 2 and are within the zone of construction for the Sunshade. The exact location of these soil probes and borings are contingent on the location of underground utilities, site accessibility, and safety of field personnel.

Permitting

Permit and land access agreements may be required to install and sample monitoring wells on private property or Federal/State Military installations. Ayres Associates will work with FSB and the WIANG to obtain the required permits and resolve site access issues, as necessary.

Soil Samples

The number and types of samples collected for each site are summarized in Table 1, as well as in Table 3: Site Characterization Analytical Program. Shallow probes advanced to evaluate soil type and quality, and for subsequent installation of 1-inch diameter temporary monitoring wells, will be performed using Geoprobe™ System hydraulic push techniques. Continuous samples will be collected from the ground surface to the depth of exploration when advancing the probes. Geologic information obtained from the probes will be documented on Soil Boring Log Information Forms.

Samples of the unconsolidated material will be collected for detailed lithologic description, field screening, and laboratory analysis. Soil (and groundwater) sampling equipment will be decontaminated before use in accordance with Ayres SOP #510 (Appendix A).

Soil samples obtained from the probes will be screened for the presence of total ionizable VOCs. Field screening will be performed using a PID in accordance with standard operating procedure SOP #210.

Samples will be selected for possible laboratory analysis based on visual and olfactory observations and PID screening results. If PID field screening results exceed five instrument units (above background), a co-located sample will be collected immediately from a fresh surface of the soil sample for possible laboratory analysis. Soil samples collected for VOC analysis will be screened and preserved using the procedures outlined for soil vapor screening and methanol preservation of soil samples (VOC analysis) SOP #210 and SOP #240, respectively. Soil sampling and soil vapor screening methodologies are discussed in Section 8.0.

Soil samples at each of the probe locations will be selected for laboratory analysis from the 1-2’ interval and from the interval 1’ above the water table. This methodology is in accordance with previous site characterization projects conducted in proximity of the Sunshade site and as described in WDNR’s Site Characterization Sampling For Contaminated Material Management Purposes memoranda, dated April 13, 2020 (Appendix B), Within those prescribed intervals, the soil sample with the highest PID readings at each sampling location will be selected for laboratory analysis. If no volatile organic contamination is identified above background using the field screening, a sample from each sampling location will be selected based on obvious discoloration or other visible signs of contamination. Soil samples will be submitted to the laboratory and analyzed for PFAS and VOC using EPA Method 537 Mod and EPA Method 8260C, respectively.

Groundwater Samples

Groundwater samples will be collected from each of the temporary monitoring wells installed at the site.

The samples will be collected in accordance with the procedures detailed in Section 8.0 of this document.

The samples will be submitted to a laboratory and analyzed for VOC and PFAS using EPA Method 537 Mod and EPA Method 8260. Information obtained from the wells will be used to evaluate the groundwater flow system and determine the concentration of contaminants in groundwater for subsequent material management purposes during construction.

Asbestos Survey

The asbestos survey will include a physical inspection of the interior and exterior, collecting bulk samples of each homogenous suspect ACM, documenting the locations where samples are collected, determining the friability of suspect materials, and estimating quantities of suspect materials. Sample locations will be determined in the field.

Ayres will collect representative samples of potential ACM from homogenous material types following the Wisconsin Administrative Code NR 441 and National Emissions Standards for Hazardous Air Pollutants (NESHAP) regulations, using wet-sampling methods and clean tools. It is assumed one (1) sample will be collected for 115 square feet of interior space, with a minimum of 8 samples.

Asbestos samples will be submitted under chain-of-custody to a national Voluntary Laboratory Accreditation Program (NVLAP) approved laboratory for analysis of asbestos content by polarized light microscopy (PLM) using EPA Method 600/R-93/116.

Lead Bearing Paint Survey

The lead-bearing paint survey will include collection of representative paint samples from interior and exterior masonry and metal surfaces using clean tools. The number of lead paint samples needed assumes a minimum of two (2) samples and up to 10 samples. The paint samples will be submitted under the chain of custody to a state-certified laboratory for lead analysis using Method 6010C. Paint containing more than 0.5 percent lead by weight or more than 1 milligram of lead per square centimeter is considered lead-bearing.

5.0 Schedule

A project schedule (Figure 3) was developed based upon the estimated duration of the various tasks described in this work plan. Actual start and completion dates and milestones are contingent on regulatory review schedules, work plan negotiations, well installation and access permitting, and the actual scope of work performed. Significant changes in review times or the scope of work outlined in this work plan will necessarily affect the project schedule.

Ayres Associates will manage (shorten or lengthen) the project schedule based upon the clients or project needs. The schedule can be shortened if circumstances prevent critical project milestones from being achieved. If necessary, Ayres Associates will shorten the schedule, where possible, by overlapping project tasks, decreasing lag time between tasks, decreasing task duration, or allocating additional resources.

6.0 Project Team and Management

Organization

Ayres Associates has assembled a project team experienced in the various requirements of this project.

Project management and fieldwork will be directed and performed out of Ayres Associates’ Madison, Wisconsin, office.

Project leadership and primary staff will be comprised of individuals experienced in the activities outlined in the scope of work. Our project team will provide experience in hydrogeologic analysis, geochemistry, risk assessment, environmental engineering, and remedial design.

7.0 Objectives of Sampling Program

The purpose of the sampling program is to characterize the nature and extent of contamination at the site.

This requires obtaining the necessary information regarding the type, distribution, and concentration of chemical contaminants present, as well as site-specific hydrogeologic and other environmental conditions that may affect potential contaminant migration. This information will be used to evaluate the potential health and environmental risks posed by the contaminants identified as they relate to site redevelopment.

The information will also be used to evaluate remedial technologies and alternatives that are appropriate for site conditions, if required, and to complete a Materials Management Plan (MMP) for use during site construction. The following overall site characterization issues will be addressed:

• Define the local geology including the origin, texture, thickness, and distribution of the unconsolidated deposits

• Determine the local hydrogeologic conditions including depth to groundwater, and groundwater flow directions and gradients

• Determine the type and distribution of contaminants of concern in the soil, sediment, and groundwater

• Evaluate potential contaminant pathways and the potential for migration in soil and groundwater

• Determine type and distribution of unconsolidated deposits

• Evaluate groundwater quality

Rationale for Selection of Analytical Parameters

The emphasis of this sampling program is on evaluation of the overall site hydrogeologic characteristics and the concentration and distribution of contaminants of concern in the soil, sediment, and groundwater.

The proposed analytical program includes the collection and analysis of soil, groundwater, and building material samples.

Selection of the probe locations and sampling parameters to be analyzed for at the Sunshade site is based upon recommendations for previous investigations in the area as described by the WDNR in the Site Characterization Sampling for Contaminated Material Management Purposes memorandum dated April 2020. Therefore, the sampling program for this site assessment will include analysis of soil and groundwater for volatile organic compounds (VOC) and per- and polyfluoroalkyl substances (PFAS). Also, buildings materials at the Gun Shop-Building 420 will be inspected and select samples analyzed for asbestos and lead-bearing paint.

The laboratory program for the assessment is discussed in detail in Section 12.0.

Analytical Data Quality Levels

Two analytical levels address the data uses and the QA/QC effort required to achieve the desired level of quality appropriate for this project. These levels are:

Screening (Level 1) – Analytical level 1 provides the lowest data quality but the most rapid results. This level involves the use of field instruments and is used for data collection activities that involve non-rigorous analysis and quality assurance. Portable instruments will be used for health and safety monitoring and preliminary site characterization. A photo-ionization detector (PID) will be used to qualitatively assess environmental media for the presence of potential VOCs. This information will be used to evaluate the need for confirmatory analysis and will provide information on the degree of potential impacts at the site. A PID will also be used to monitor ambient air conditions for health and safety.

Additional field instrumentation will include a flow-through cell and multi-parameter water quality probe to measure pH, temperature, dissolved oxygen, conductivity, and oxidation-reduction potential in the aquifer.

Confirmation (Level 2) – Analytical level 2 involves analysis of sampling media in an off-site certified analytical laboratory. This level of analysis is used to meet data quality objectives that require a high degree of qualitative and quantitative accuracy using rigorous methods of analysis and quality assurance.

Analytical level 2 uses standard, documented USEPA approved procedures for analysis but does not use data validation or documentation procedures required for higher level DQO objectives.

Analytical level 2 analysis will be used to provide confirmed identification and quantification of organic and inorganic compounds in soil and groundwater samples collected at the site. These methods provide detection limits that are sufficiently low to provide data that can be used to support decisions regarding site characterization, risk assessment, and evaluation of remedial alternatives. Detection limits for parameters to be analyzed during this assessment are further discussed in Section 12 (Laboratory Program).

Results obtained from the analytical program will be compared to the State of Wisconsin residual contaminant levels (RCLs) to support decisions regarding site characterization, risk assessment, remedial alternatives, and materials management. Soil concentrations will be compared to the applicable soil standards presented in WDNR NR 720 Wis. Adm. Code look-up tables including Residential Contact and Migration to Groundwater values that were calculated using U.S. EPA's regional screening level (RSL) web calculator. The non-industrial direct contact RCL for both PFOA and PFOS is 1.26 mg/kg. The industrial direct contact RCL for both PFOA and PFOS is 16.4 mg/kg. There is no pre-determined groundwater protective soil RCL for these compounds. These residual contaminant levels (RCLs) will be used to evaluate material management options for soil and groundwater during planned construction activities. These soil standards are presented in Table 5 of this work plan.

The applicable cleanup standards for VOC in groundwater in Wisconsin are presented in NR 140 Wis.

Adm. Code. Groundwater VOC results will be compared with NR 140 standards. State groundwater quality standards have not been established for PFAS compounds. The DNR requested that Wisconsin Department of Health Services (DHS) recommend a PFOA and PFOS groundwater health standard in Wisconsin. The DHS has recommended that an enforcement standard of 20 ng/L and a preventative action limit of 2 ng/L be used for PFOA and PFOS individually and combined. Note that state and federal soil and groundwater standards are periodically updated; results obtained from the assessment will be compared to the most recent standards available. Groundwater results will be compared with the standards presented in Table 6.

8.0 Scope of Work

Field Assessment Objectives

The scope of work detailed in this work plan is designed to meet the objectives of the assessment outlined in Section 7.0. The emphasis of this phase of assessment will be on the evaluation of site hydrogeologic characteristics, soil, and groundwater quality, and to better define the threat to human health and the environment. Information collected during this assessment will be used to prepare a Materials Management Plan for managing environmental media, building materials, and other debris at the site during construction activities.

This phase of assessment will include advancing soil probes, installation of 1-inch diameter temporary wells, collection of building material samples, and laboratory analysis of soil, groundwater, asbestos, and lead-based paint. Data obtained from this phase of assessment will be used to further evaluate geologic characteristics of the site, horizontal groundwater flow directions, gradients, and velocity; and evaluate soil and groundwater quality, and building materials at the site. These data will be used to evaluate remedial options and engineering controls that may be required during construction. The scope of work for subsequent phases of assessment, if any, is contingent on this phase of assessment, and therefore, cannot be determined at this time.

Field Assessment Activities

Assessment Strategy

The purpose of the sampling program is to characterize the presence of VOC and PFAS contamination in soil and groundwater at the Sunshade site and determine the presence of asbestos and lead paint in the Gun Shop-Building 420 which is being proposed for renovation. This requires obtaining the necessary information regarding the type, distribution, and concentration of chemicals of concern identified by others at nearby sites, as well as site-specific hydrogeologic and other environmental conditions that may affect potential contaminant migration. This information will be used to help evaluate the potential health and environmental risks posed by the contaminants identified as they relate to site redevelopment. The information will also be used to prepare a Materials Management Plan for use during Sunshade construction. Sample locations and rationale are summarized in Table 1. Site-specific conditions, as well as overall project objectives, were considered in formulating our project approach. The overall goal of this assessment is to provide information for developing a materials management plan for the site. This will be done by supplementing the information previously gathered for this site to determine if and how this property has been affected by prior site activities. Field assessment tasks are detailed below.

Permitting

Permit and land access agreements may be required to install and sample monitoring wells on private property or Federal/State Military installations. Ayres Associates will work with FSB and the Wisconsin Air National Guard to obtain the required permits and resolve site access issues, as necessary.

Soil Assessment

Drilling and Soil Sampling Methods

The number and types of samples collected for the Sunshade site are summarized in Table 1 below, as well as in Table 3: Site Characterization Analytical Program. Shallow borings advanced to evaluate soil type and quality, and for subsequent installation of 1-inch diameter temporary monitoring wells, will be performed using Geoprobe™ System hydraulic push techniques. Continuous samples will be collected from the ground surface to the depth of exploration when advancing the borings. Geologic information obtained from the boreholes will be documented on WDNR Soil Boring Log Information Form 4400-122.

Samples of the unconsolidated material will be collected for detailed lithologic description, field screening, and laboratory analysis. Soil (and groundwater) sampling equipment will be decontaminated before use to prevent cross-contamination in accordance with SOP #510.

Soil samples obtained from the borings will be screened for the presence of total ionizable VOCs. Field screening will be performed using a PID in accordance with standard operating procedure SOP #210.

Samples will be selected for possible laboratory analysis based on visual and olfactory observations and PID screening results from WDNR prescribed sample intervals. If PID field screening results exceed five instrument units (above background), a co-located sample will be collected immediately from a fresh surface of the soil sample for possible laboratory analysis. Soil samples will be collected and preserved using the procedures outlined for soil vapor screening and methanol preservation of soil samples (VOC analysis) SOP #210 and SOP #240, respectively.

Borehole Abandonment

Each borehole advanced during this assessment, and not converted into a monitoring well, will be properly abandoned. All boreholes requiring abandonment will be abandoned in accordance with Chapter NR 141 Wisconsin Administrative Code. Because the probes are located in a tarmac used by aircraft, each boring will be abandoned with grout and resurfaced with concrete according to specifications provided by FSB. Borehole abandonment will be properly documented using a Well/Borehole Abandonment Form.

Groundwater Assessment

Temporary Well Installation

Temporary monitoring wells will be installed in borings advanced at the Sunshade site. The shallow monitoring wells will be installed at a depth of approximately 15 feet below ground surface, depending on the depth to groundwater. The purpose of the shallow monitoring wells is to evaluate groundwater flow and potential contaminant transport at the water table. Temporary monitoring wells will be constructed of 1-inch inside diameter (ID) schedule 40 PVC riser and screen. Each well will be constructed with a 5-foot length of 0.006-inch to 0.010-inch slot PVC screen, depending on the grain size of the sediments encountered. A summary of proposed temporary wells is presented in Table 2.

Monitoring wells will be installed in accordance with Ayres Associates’ standard operating procedure SOP #110 and NR 141 Wisconsin Administrative Code. Monitoring well casing and screen will be inserted in the boreholes after the target depth is reached. A sand filter pack (#40-#70) will be installed around the well screen and will extend approximately 2 feet above the top of the screen. A filter pack seal will be placed above the sand filter pack. The seal will consist of 2 feet of fine-grained sand placed above the filter pack. Granular or chipped bentonite will be placed above the seal to a depth of approximately 4 inches below the ground surface. The remaining annular space will be filled with native soil. Temporary wells will be removed, and the boreholes abandoned after groundwater samples are collected and water level data are obtained.

Well Development

Monitoring wells will be developed after construction to remove fine-grained materials from within the well screen and filter pack. The well will be developed in accordance with Wisconsin Administrative Code NR

141. The wells will be developed by over pumping with a peristaltic pump until purge water remains clear.

Logs of all well development procedures will be maintained. Purge water will be drummed, or permission will be obtained to discharge the water directly to the sanitary sewer. Well development procedures will be documented on WDNR Monitoring Well Development Form 4400-113B.

Monitoring Well Survey

Monitoring wells will be surveyed to determine their elevations and horizontal locations. At each monitoring well, the elevations of the top of the well casing will be surveyed to the nearest 0.01-foot.

Ground surface elevation will be surveyed to the nearest 0.1-foot. Horizontal locations will be surveyed with respect to site features such as building corners, other site wells, and borings. GPS coordinates for the monitoring wells and soil borings will be obtained with a hand-held device.

Collection and Analysis of Soil and Groundwater Samples

Soil Samples

Soil samples will be collected for laboratory analysis from each of the soil probes advanced during this assessment. Sample locations are within the zone of construction for the Sunshade and the sampling depths will be at intervals consistent with other investigations conducted in the area and as described in the WDNR memorandum dated April 13, 2020 (Appendix B). Sampling depths are summarized in Table 1.

Two discrete soil samples will be collected from each probe for laboratory analysis; one sample from a depth of 1-2 feet below ground surface and a second sample at a depth of approximately 1-foot above the water table. The soil analytical program for this site will include volatile organic compounds (VOCs) and Per- and Polyfluorinated Alkyl Substances (PFAS). Soil sample analysis is further discussed in the Laboratory Program (Section 12).

Samples from the pre-determined depths will be selected for analysis based on visual and olfactory observation, PID field screening results, conditions of the subsurface geology, and results of previous assessments performed at this site. The physical/chemical properties of the analytes will also be considered in selecting soil samples for analysis. Decisions on the exact samples to be analyzed will be made by the field scientist and the project hydrogeologist. Soil samples collected for analysis of non-volatile parameters will be collected from the Geoprobe™ acetate liner and placed directly in the appropriate glassware. Soil samples collected for volatile analysis will be collected and preserved with methanol in accordance with SOP 220.

Groundwater Samples

To effectively evaluate the need for, and or type of, remediation required at the site, a complete and accurate assessment of groundwater quality is required. Data on contaminant types, concentrations, and distribution will be evaluated in conjunction with the physical/chemical properties of the constituents to determine their persistence and mobility within the subsurface.

Temporary wells, consisting of a 1-inch diameter length of sand-packed PVC screen and riser, will be installed in the five soil borings advanced below the water table. A 0.25-inch diameter high-density polyethylene (HDPE) tube will be inserted into the well and attached to a peristaltic pump. One round of groundwater samples will be collected from each of the monitoring wells installed at the site. Groundwater samples will be collected using the procedures detailed in Ayres SOP #310 and SOP #320. Samples obtained for VOC analysis will be collected according to procedures detailed in SOP #350. Samples obtained for PFAS will follow Ayres’ PFAS/PFOA SOP #710 which contains key elements contained within WDNR-referenced PFAS Sampling Procedures on their website.

Prior to sample collection, water levels will be obtained from each of the monitoring wells. Groundwater samples will be collected from the monitoring wells using a peristaltic pump and low flow sampling techniques. Each monitoring well will be equipped with high-density polyethylene (HDPE) dedicated tubing. The tubing will be inserted into the well, so the intake is coincident with the middle of the well screen. Care will be taken to minimize disturbance of the water column and sediments that may be present at the bottom of the well. The pump discharge line will be connected to the flow-through cell for monitoring water quality indicator parameters. The controller will be adjusted to an initial pumping rate of 1-liter/minute (L/min) until the line and pump are purged. The pumping rate will then be decreased to approximately 0.1 L/min. to 0.5 L/min., depending on the permeability of the geologic formation. The well will be purged until water quality parameters (pH, temperature, specific conductance, turbidity) stabilize for three consecutive measurements taken 3 minutes apart. (Note: measurement interval may be decreased based on hydraulic conditions of well [i.e., recharge] to prevent excessive drawdown.)

Stabilization is defined when readings are within 10 percent of the previous reading and turbidity is less than or equal to 20 NTUs. Water levels will also be checked to document drawdown from pumping. Water quality indicator parameters will be recorded on the standard sampling log. Samples will be collected in pre-cleaned containers provided by the laboratory. Groundwater sampling information will be documented on the standard Ayres sampling forms.

The groundwater analytical program is detailed in Section 12 of this field sampling plan. Laboratory analysis for groundwater samples collected during this phase of assessment will include VOC and PFAS.

Real-time data on temperature, pH, specific conductance, dissolved oxygen, and oxidation-reduction (Redox) potential will be collected to complement the analytical data collected from the monitoring wells.

These data will be used to construct a “geochemical model” of conditions at the site to assist in the interpretation and understanding of attenuation and or transformation processes that may be occurring in the aquifer, and the potential fate of the constituents of interest.

Temperature, pH, specific conductance, turbidity, dissolved oxygen, and redox potential will be obtained using an In-Situ®, Inc. Aqua Troll 600 multi-parameter water quality monitoring system, or equivalent.

Simultaneous temperature, pH, specific conductance, turbidity, dissolved oxygen, and redox readings will be taken continuously during pumping until readings have stabilized. Stabilized readings will be recorded on the field sampling form. Water quality field parameters will be collected in accordance with SOP #330.

Data Analysis and Evaluation

Data obtained through the background data review and environmental assessment will be analyzed and interpreted by Ayres Associates. The objectives of the analysis will be to determine the presence and significance of regulated chemical impacts to soil and groundwater-related to historical activities at the site. The analytical data will be evaluated for temporal and spatial trends and compatibility with observations made in the field.

Results obtained from the analytical program will be compared to the State of Wisconsin residual contaminant levels (RCLs) to support decisions regarding site characterization, risk assessment, remedial alternatives, and materials management. Soil concentrations will be compared to the applicable soil standards presented in WDNR NR 720 Wis. Adm. Code look-up tables including Residential Contact and Migration to Groundwater values that were calculated using U.S. EPA's regional screening level (RSL) web calculator. The non-industrial direct contact RCL for both PFOA and PFOS is 1.26 mg/kg. The industrial direct contact RCL for both PFOA and PFOS is 16.4 mg/kg. There is no pre-determined groundwater protective soil RCL for these compounds. These residual contaminant levels (RCLs) will be used to evaluate material management options for soil and groundwater during planned construction activities.

The applicable cleanup standards for VOC in groundwater in Wisconsin are presented in NR 140 Wis.

Adm. Code. Groundwater VOC results will be compared with NR 140 standards. State groundwater quality standards have not been established for PFAS compounds. The DNR has requested that Wisconsin Department of Health Services (DHS) DHS recommend a PFOA and PFOS groundwater health standard in Wisconsin. The Wisconsin Department of Health Services (DHS) has recommended that an enforcement standard of 20 ng/L and a preventative action limit of 2 ng/L be used for PFOA and PFOS individually and combined. Note that state and federal soil and groundwater standards are periodically updated; results obtained from the assessment will be compared to the most recent standards available.

Site Assessment Report

A draft report summarizing findings of the site will be submitted to the WIANG for review and comment.

The report will include a description of site conditions, subsurface geology, results and interpretation of the laboratory analytical data, and an accurate map showing the results and sample locations. A final report will be prepared following WIANG’s review of the draft report. Reporting activities will include the completion and submission of required reports and forms. Project memoranda will also be prepared to keep the WIANG’s project team and regulatory agencies apprised of project activities.

Asbestos, Lead Paint, and Hazardous Materials Survey

The Gun Shop-Building B420 is slated for renovation. The WIANG is requesting that this building be assessed for the presence of asbestos-containing materials (ACM) and lead-bearing paint. Ayres will provide a state-accredited asbestos inspector to conduct the assessment. The inspector will sample and assess the condition of suspect ACM and lead-based paint in conformance with applicable state and federal regulations. If access to any building presents a safety concern, the inspector will evaluate the possibility of any ACM based on professional judgment and experience but will not enter the structure or areas within the structure that he or she deems unsafe.

While on site, Ayres will inventory potentially hazardous materials that will require removal or special disposal before anticipated demolition, additionally, we will collect samples of dried paint from masonry surfaces and submit samples to a state-certified laboratory for lead analysis.

ACM Assessment

The ACM assessment includes the following:

• Review of previous asbestos inspection reports and building plans.

• Collect representative bulk samples of potential ACM from homogenous material types following the Wisconsin Administrative Code NR 441 and National Emissions Standards for Hazardous Air Pollutants (NESHAP) regulations, using wet-sampling methods and clean tools. CONSULTANT proposes to collect an estimated 55 samples to evaluate homogeneous areas that are suspected of containing asbestos that would be necessary to supplement previous assessment activities.

• Assess the physical condition, location, and approximate quantity of ACM.

• Submit asbestos bulk samples under chain-of-custody to a national Voluntary Laboratory Accreditation Program (NVLAP) approved laboratory for analysis of asbestos content by polarized light microscopy (PLM) using EPA Method 600/R-93/116.

• Provide one letter report in portable document format (PDF) that summarizes the scope of services and results of the ACM analysis. The report will indicate the sample ID number, location on a diagram or layout map, and condition of the sample collection area, presence or absence of asbestos, and the estimated square…