A.02.17 ATT A_Bldg 725 Site Characterization Plan_EN_Final.pdf

Site CCPL117 - Bldg. 725 Site Characterization Plan

Remediation Engineering Management Support, USAG Italy Darby Military Community W912PF-17-C-0005, Option 3

USAG Italy Darby Military Community

Project Number: 60601991

August 7 2020

Site CCPL117 - Bldg. 725 Site Characterization Plan

AECOM Remediation Engineering Management Support, USAG Italy DMC

AECOM

Prepared for:

USAG Italy Darby Military Community

Prepared by:

AECOM URS Italia S.p.a.

20143 - Via Giacomo Watt 27

Milano

Italia

T: +39 02 4225561 aecom.com

© 2020 AECOM URS Italia S.p.a.. All Rights Reserved.

This document has been prepared by AECOM URS Italia S.p.a. (“AECOM”) for sole use of our client (the “Client”) in accordance with generally accepted consultancy principles, the budget for fees and the terms of reference agreed between AECOM and the Client. Any information provided by third parties and referred to herein has not been checked or verified by AECOM, unless otherwise expressly stated in the document. No third party may rely upon this document without the prior and express written agreement of AECOM.

Table of Contents

1 Introduction and Scope of Work

2 Site description

2.1 Geographical settings

2.2 Description of the Site and summary of past activities

2.3 Summary of past environmental investigations

3 Preliminary Conceptual Model

3.1 Geological settings

3.2 Hydrogeological settings

3.3 Lithostratigraphy of the Site area

3.4 Primary Source of contamination

3.5 Potential secondary contamination sources

3.6 Contaminant transport mechanism

3.7 Potential receptors and exposure pathways

4 Investigation Plan

4.1 Methodology

4.2 Preliminary activities

4.3 Soil borings and monitoring wells installation

4.3.1 Soil borings

4.3.2 Monitoring wells installation

4.3.3 Decontamination procedures

4.4 Soil gas probes

4.4.1 Location of soil gas probes

4.4.2 Soil gas probes installation

4.5 Soil sampling

4.6 Groundwater sampling

4.7 Soil gas monitoring

4.8 Samples shipping and preservation

4.9 Chemical analyses

4.9.1 Soil samples

4.9.2 Groundwater samples

4.9.3 Soil gas samples

4.10 Hydraulic conductivity test

5 Waste management

6 Reference documents

Figures

Figure 1. Location of Bldg. 725 in Camp Darby Figure 2. Geological map: The Site is indicated with a red circle, in brown - sandy sediments of shorelines and dunes, in yellow - interdunal sediments, in light blue - reclaimed marshes, in beige- alluvial deposits, in dark red -

Coltano Dunes (from “Piano Strutturale del Comune di Pisa, 1997”) Figure 3. Hydrogeological map: The Site is indicated with a red circle, the red lines are the isophreatic contour lines (from “Piano Strutturale del Comune di Pisa, 1997”)

Figures attached

Figure 1 Site location map

Figure 2 Location of proposed site investigations

Annexes

Annex 1 Soil results of preliminary investigations

Annex 2 Drinking water wells specifications

Annex 3 Spill Incident Report

Annex 4 Technical Data Sheet of spilled Diesel Fuel

Acronyms and Abbreviations

ASA Ammunition Storage Area

B.g.l. Below Ground Level

Bldg. Building

CSC Concentrazione Soglia di Contaminazione / Contaminant Threshold Concentration

D. Lgs. Legislative Decree

DMC Darby Military Community

EWC European Waste Code

IBC Italian Base Commander

LNAPL Light Nonaqueous-phase liquids

LTM Long Term Monitoring

NAPL Non-aqueous-phase liquids

ORP Oxidation Reduction Potential

PE Polyethylene

PVC Polyvinyl chloride

PX Post Exchange

SNPA Sistema Nazionale per la Protezione dell'Ambiente / Italian National System for Environmental

Protection

USAG United States Army Garrison

VOC Volatile Organic Compounds

1 Introduction and Scope of Work

This Characterization Plan has been prepared by AECOM URS Italia S.p.A. (hereinafter “AECOM”) for the United

States Army Garrison (USAG) Italy Darby Military Community (DMC) as per Task 4 of contract # W912PF-17-C-

0005, Option 3.

On the 2nd of December 2019, a spill of approximately 343 gallons (equal to about 1,300 liters) of diesel fuel occurred in the heating room of Building 725 (hereinafter the “Site”), located in Camp Darby, USAG Italy DMC. The spill emergency response actions were performed, and a detailed notification was submitted to the Italian Base

Commander (IBC). Subsequently, on 11 December 2019, the Host Nation Authorities were notified.

During the preliminary investigations carried out in January 2020, exceedances of the Contaminant Threshold

Concentrations (CSCs) for light hydrocarbons (C≤12) and heavy hydrocarbons (C>12) for the commercial and industrial sites were detected in all the samples collected in the trial pit excavated inside the building.

In the following chapters, in order to comply with Article 242 of Legislative Decree No. 152 of 3 April 2006 (D.Lgs.

152/06) and subsequent amendments and with Annex 2 of Part IV of the same decree for the writing of a characterization plan, the Historical Reconstruction of Activities (together with the description of past investigation activities), the Preliminary Conceptual Model and the Investigation Plan are detailed.

2 Site description

2.1 Geographical settings

The USAG Italy DMC is located in the central-coastal side of the Tuscany region, in the “Pianura Pisana” (Pisa

Plain), 15 kilometers (km) southwest from the center of the city of Pisa and 4 km east of the coastline (at Tirrenia locality). More specifically, the U.S. Army installation is located between the Pisa municipal territory (“San Piero a

Grado” locality), the “Canale Scolmatore” canal (Stagno locality, Livorno municipal territory), and west of the national road #1 “Aurelia”. Its area falls under the Natural Park of Migliarino – San Rossore – Massaciuccoli.

Historically this area of Tuscany was part of the “Tombolo” landed property, which is located in a vast plain created by sedimentary processes in a transitional environment and by anthropic processes of land reclamation and leveling. The human interventions changed the fluvial system into an artificial drainage system. The average elevation ranges approximately from 2 - 3 m above sea level in the eastern part of the U.S. Army installation area, to an elevation below sea level (even more than 1 m below sea level) in the western part; the inclination of the terrain is about 0.0005 percent in a south, southwest direction. The area surrounding USAG Italy DMC is mainly rural/wooded.

Within the USAG Italy DMC property, three different areas are included: “Camp Darby”, “Livorno Supply &

Maintenance Area – Depot”, and “Ammunition Storage Area – ASA”.

Bldg. 725 is located in Camp Darby Area (see Figure 1 below). As written above, the Site is one of the heating rooms of the building and is located centrally on its eastern side.

Figure 1. Location of Bldg. 725 in Camp Darby

2.2 Description of the Site and summary of past activities

The subject site is the heating room of Bldg. 725, which is currently not in use. The room hosts only the boiler, while the associated diesel fuel Tank is external. No previous spill incidents are reported at the site before the spill of

December 2019.The spill of the diesel fuel, which was caused by a leakage in the fuel filter and pipe, was discovered on 2 December 2019 and immediate emergency response actions were put in place. A Spill Incident

Bldg.725

Report was prepared by the USAG Italy DMC and the IBC was subsequently notified. AECOM was informed of the occurred incident in order to provide support for the ongoing spill response.

On the basis of the received information, approximately 343 gallons (equal to about 1,300 liters) of diesel fuel spilled inside the heating room and outside, in front of the door, on a paved area. Inside the containment basin of the heating room a sump was discovered and part of the spilled fuel, about three hundred gallons (equal to about

1,100 liters), as calculated, managed to seep in the ground below through this sump. Also, some fuel seeped in a grounding rod manhole, located outside the heating room.

The Spill Incident Report is included in Annex 3. Specifications of the spilled diesel fuel, which were provided by the USAG Italy DMC contractor, are included in Annex 4.

2.3 Summary of past environmental investigations

In order to define the potential contamination of the soil, the below-listed activities were performed by the USAG

Italy and supervised by AECOM in January 2020:

• Excavation of two (2) trial pits, one inside the heating room (at a depth of 1.9 m b.g.l.) and one outside the building (at a depth of 2.0 m b.g.l.), where the grounding rod manhole is located;

• Collection of 14 soil samples;

• Execution of lab analyses on the collected samples.

The soil samples were collected by AECOM, following the scheme indicated below:

• 1 composite sample from 0 to 1 meter b.g.l. for each excavation (shallow soil);

• 1 composite sample (of unsaturated soil) from 1 meter b.g.l. to 1.9 m b.g.l. (inside the heating room) and to

2.0 m b.g.l. outside the building;

• 1 sample of the bottom of each excavation;

• 1 composite sample for each wall of the excavations (totaling 8 samples).

The results of the lab analyses showed exceedances of the CSCs, as reported by Table 1, Column B, Annex 5 to

Title V, Part IV of D.lgs, 152/06 for light hydrocarbons (C≤12) and heavy hydrocarbons (C>12) set for the commercial and industrial sites (respectively of 250 mg/kg and 750 mg/kg) in all the samples collected in the trial pit excavated inside the heating room, with concentrations ranging from 290 to 400 mg/kg for light hydrocarbons and from 11,000 to 15,000 mg/kg for heavy hydrocarbons.

In the samples collected in the trial pit excavated outside the heating room, concentrations of all the constituents analyzed were below the CSCs with the exception of heavy hydrocarbons detected in the sample collected from the bottom of the excavation which showed a concentration of 3,700 mg/kg.

For detailed results see Annex 1.

3 Preliminary Conceptual Model

3.1 Geological settings

The “Pisa Plain” is a coastal and fluvio-deltaic plain, located on the last portion of the Arno and Serchio rivers. It is the result of sedimentary processes in continental and transitional environments. Alluvial, deltaic, beach and aeolian dunes depositional environment processes were active in the plain formation.

A structural depression, created starting from the upper Miocene, was filled by Miocene, Pliocene and Quaternary deposits, which are placed on the same litological complex that outcrops on the hills that surround the plain:

Tuscany Series (middle Trias–lower Miocene) and Liguria Series (upper Jurassic–Eocene) carbonate and arenaceous rocks. The extensional tectonic activity is well-documented until Middle Pleistocene.

In this structural depression were first accumulated marine, continental and transitional sediments linked to the

“Messiniano” event, followed by sea transgressive clays “Argille Azzurre”, alternations of clays and sands (“Sabbie

Gialle”). These sediments were followed by the sands and clays “ad Arctica”, dated to Lower Pleistocene and eventually, at the end of Lower Pleistocene, the shallow water and transitional sands (“Sabbie di Nugola Vecchia”) indicating a sea regression.

The upper part of the plain is made of sediments settled after the Lower Pleistocene in conditions of changing sea level and sediment transport in rivers accordingly to climate variations during the Pleistocene Glaciation. A clastic, continuous level (known as “Arno e Serchio da Bientina” conglomerates) is present at a depth of 50-145 m (80–

100 m under the USAG Italy DMC area). This level of conglomerates was created during the Würm I (or Würm II) phase (Upper Pleistocene), during which a considerable lowering of sea level took place (due to a change in the terrestrial ice volume) and its thickness is of about 5-10 m.

Fluvial-marsh silt materials (“Limi Fluvio-Palustri del Sottosuolo”) had progressively accumulated on the conglomerates during the subsequent eustatic sea level rise. Along the coastline, shoreline sediments and aeolian dunes had taken shape during a dry climate phase (e.g., dunes of “Isola di Coltano”). Dune formation and the progressive rise of the eustatic level, have limited the outflow of the rivers at sea, with the subsequent formation of marshlands and lagoons, which allowed the deposition of silt, clay and peat.

Above these sediments lie the fluvial-marsh silt materials named “Limi Fluvio-Palustri di Superficie”. These are mainly Holocene sediments, outcome of the aggradation of Arno and smaller rivers. Along the coastline, beaches and shoreline aeolian dunes sediments have been accumulating during the Holocene. In the aeolian dune depositional environment is remarkable the presence of interdunal wetlands where silt, silty sands and sometimes organic clays and peat have accumulated. This gave rise to lithological alternations with a pattern parallel to the shoreline as visible in the military installation area (Figure 2).

Figure 2. Geological map: The Site is indicated with a red circle, in brown - sandy sediments of shorelines and dunes, in yellow - interdunal sediments, in light blue - reclaimed marshes, in beige- alluvial deposits, in dark red -

Coltano Dunes (from “Piano Strutturale del Comune di Pisa, 1997”).

3.2 Hydrogeological settings

In the Pisa Plain, underneath a discontinuous phreatic aquifer, there is a multi-strata confined aquifer, which consists of:

• Confined aquifer in sands (I Artesian Aquifer in Sands);

• Confined aquifer in gravels (I Artesian Aquifer in Gravels).

Above the confined aquifers, a phreatic aquifer is present under the USAG Italy DMC area. Within the area between the coast and the coastal dunes eastward limit, the phreatic aquifer, with a thickness of approximately 20 m, lies within sand deposits with good permeability. In the internal plain areas, the thickness rarely exceeds 10 m and the aquifer is poorly productive.

Regarding the phreatic aquifer, the coastal plain morphology, changing from flat to a slightly curved surface, created a uniform regional groundwater gradient. The groundwater table morphology is strongly influenced by the draining pumps of the land reclamation consortium and by heavy rain events. Without human interventions, the groundwater flow would be heading west or southwest (see Figure 3).

The groundwater flow direction of the phreatic aquifer (based on the measurements performed during the LTM program and other environmental investigations), is currently southeast, to be verified through the characterization activities. Expected groundwater depth is approximately 2 - 2.5 m below ground level.

Figure 3. Hydrogeological map: The Site is indicated with a red circle, the red lines are the isophreatic contour lines (from “Piano Strutturale del Comune di Pisa, 1997”).

3.3 Lithostratigraphy of the Site area

Based on the previous investigations carried out in the Camp Darby Area the lithostratigraphy of the Site can be approximately described as follows:

• 0 - 1 m b.g.l. – filling material, consisting of medium sand, with sporadic bricks and pebbles;

• 1 - 8 m b.g.l. – medium to fine sand, silty sand at intervals;

• 8 - 12 m b.g.l. – slightly sandy silt, sometimes slightly clayey;

• 12 - 21 m b.g.l. – well-graded medium to fine sand;

• underneath 21 m b.g.l. – clay.

3.4 Primary Source of contamination

The potential primary source of the contamination detected in the preliminary investigations was the diesel fuel contained in the tank outside the building, which spilled inside the heating room due to leakage from defective fuel filter and tubing connected to the boiler. Heating room was cleaned and currently is not in use and also access is not permitted, therefore the primary contamination source is no longer active.

3.5 Potential secondary contamination sources

Potential secondary contamination sources are related to the concentrations of light and heavy hydrocarbons, detected in the soil matrix during the preliminary investigations carried out in January 2020. These constituents are considered the Contaminants of Concern of the Site.

Currently no data are available regarding the potentially impacted groundwater matrix, nevertheless the presence of hydrocarbons in groundwater cannot be excluded, which consequently could be considered a secondary source.

3.6 Contaminant transport mechanism

From the above-mentioned sources of contamination, the potential transport mechanisms could be:

• volatilization from shallow and deep unsaturated soil and from groundwater;

• leaching in the soil and dilution in groundwater;

• transport and dispersion in groundwater.

Based on the results of characterization activities, the actual contaminant transport mechanisms shall be verified though the risk assessment

3.7 Potential receptors and exposure pathways

Bldg. 725 hosts in its southern part the housing warehouse and associated offices at the first floor. Post Exchange

(PX) shop is in the central part of the building. Some shops/services (Barber Shop, Car Rental, etc.) are in the northern part of Bldg. 725, around a courtyard. Also, on the western site of the courtyard there are barracks that provide accommodation for Garrison personnel.

The Site (heating room of Bldg. 725) is currently not in use and access is not permitted. The heating room of Bldg.

725 is located between the PX shop and the housing warehouse and is potentially accessible only from the road through a door, with no direct connection to the remainder of the building.

In the neighboring area, the following buildings are present:

• A hotel (Casa Toscana – Bldg. 202) is located approximately 90 meters to the north east from the heating room;

• A sports ground at a distance of 50 m to the East from the Site, on the other side of Harmon Avenue;

• The Elementary School (Bldg. 201) is located about 100 m to the south east;

• A bank (Bldg. 206) is located about 80 m to the south east;

• The Child Development Center is located about 80 m to the south west;

• A launderette and a shop selling used clothing are located inside Bldg. 724, about 50 m to the south.

Based on results of preliminary investigations, potential human receptors are workers and children.

Potential exposure pathways for human targets are indoor and outdoor vapor inhalation.

Groundwater must be considered a potential receptor, as groundwater at the point of compliance could possibly have concentrations higher than the threshold values. Point of Compliance will be determined based on actual groundwater flow direction (to be verified through characterization results) at the downgradient limit of the Bldg.

725 area.

The nearest drinking water wells are located in the ASA (Wells #1 and #2, see Annex 2). These wells were used in the past to supply Camp Darby, Depot and the most part of the ASA with drinking water before connection with the aqueduct was completed. As can be seen from the maps and the wells stratigraphic logs reported in Annex 2:

• The site is outside the “Zone of Respect” of the wells (200 m from the wells);

• The wells are installed in the underlying confined aquifer and not in the shallow aquifer;

• The groundwater direction in the phreatic aquifer is actually southeast while the wells lie to the west of the

Site.

Consequently, based on the above reported assumptions, negative impacts on the quality of drinking water possibly pumped from Wells #1 and #2 are not expected.

Based on results of characterization activities, the exposure pathways shall be revised accordingly.

4 Investigation Plan

4.1 Methodology

Based on the results of the investigations carried out in January 2020, the above-mentioned CoCs must be sought in the soil and groundwater matrices. Additionally, an evaluation of the soil gas quality at the site shall be performed through quarterly soil gas monitoring surveys as per the SNPA guidelines. Planned investigations include:

• drilling of eight (8) boreholes;

• installation of seven (7) monitoring wells;

• installation of 5 soil gas probes;

• soil sampling;

• groundwater and possible NAPL sampling (if any);

• execution of four (4) quarterly soil gas monitoring surveys;

• chemical analyses of the collected samples;

• performance of hydraulic conductivity tests.

In the following sections, the procedures for the investigations to be performed are detailed.

4.2 Preliminary activities

A Health and Safety Plan for executing the field work, in compliance with the relevant Italian regulations including

D.Lgs. 81/2008 and all other applicable regulations and contract requirements shall be prepared.

Prior to proceed with drilling operations, the points accessibility must be checked with a visual survey. Additionally, for each investigation point an underground utilities check shall be performed in order to prevent interception of services such as cables, pipes or any other structure that could be encountered or damaged during drilling.

Specifically, at least the below-listed activities shall be conducted:

• service plans shall be obtained from USAG Italy;

• a site survey shall be performed in collaboration with a Site representative;

• manholes shall be inspected in the area;

• traces of any pavement repair due to underground utilities installation or maintenance shall be located in the area;

• starter pits shall be advanced to prove the absence of any utilities to a depth of approximately 2.0 meters.

4.3 Soil borings and monitoring wells installation

4.3.1 Soil borings

Eight (8) boreholes (725_MW1 - 725_MW7 and 725_SB1) shall be drilled using a coring tool to reach the first silty layer that separates the shallow part of the aquifer from the underlying parts. According to information gathered from other drillings in the USAG Italy DMC area, this bed could be reached at a depth of about 8 to 10 m b.g.l.. The borings shall penetrate the silty bed for at least 50 centimetres (cm).

The borings shall be made in continuous coring mode with a hydraulic rotary machine. The corer diameter shall be

101 millimetres (mm). The drilling must be in dry mode, i.e., without adding water, and the single coring manoeuvres shall be no more than 1 m long. The drilling shall be done at low speed in order to avoid soil cores heating up.

Temporary (stainless steel) casing pipes (diameter 127 mm) shall be put in place in order to sustain the borehole and to avoid that possible contamination in shallow soil could reach deeper layers.

If it will not be feasible to drill the internal planned boreholes with a rotary drilling machine, these borings shall be made with a direct push machine (e.g. Geoprobe) or manual tools (e.g. pneumatic drill), with reduced diameters.

Borehole 725_SB1 shall be drilled deeper than 2 m b.g.l. only if the chosen feasible method allows to collect soil samples.

Soil cores shall be extruded from the corer without using liquids and shall be put in polyethylene (PE) core boxes where characterization site, date, boring number and depth of the cores shall be indicated.

A geologist shall do a screening for prospective soil contamination using a PID for the detection of volatile organic compounds (VOCs) by headspace analysis after every single meter of core is extracted.

Pictures of all the soil cores extracted shall be taken and a detailed soil stratigraphy shall be written in the field by a geologist. The core boxes should be stockpiled in a sheltered area at the USAG Italy DMC’s disposal.

Location of the planned boreholes is shown in Figure 2 attached hereto.

4.3.2 Monitoring wells installation

Seven (7) monitoring wells shall be installed in seven of the boreholes previously drilled (725_MW1 - 725_MW7) in order to create a network for groundwater monitoring at the site.

The borehole shall be widened by means of drilling with a 178 mm stainless steel casing until reaching the silty bed at the base of the shallow part of the aquifer. During the borehole widening operations, a moderate amount of clean water could be used.

Subsequently a polyvinyl chloride (PVC) 4” pipe shall be inserted with the bottom cap placed inside the silty bed, with a probable length of about 8-10 m. As an indication, slotted pipe (screened) shall be mounted from 1 meter below the top of casing to the bottom cap, in order to sample groundwater or LNAPL. Actual length and depth of the monitoring well screen and casing shall be defined in the field by a geologist on the basis of the encountered geology and of actual depth of groundwater. In the annular hollow space between the casing and the soil, the filter

(gravel) pack shall be put in place, from the bottom (even under the bottom cap) to 50 cm above the screened casing. The gravel must be washed, naturally rounded and have a particle size of 2 to 4 mm. Above the filter pack, a 30 cm thick bentonite seal shall be laid using pellet bentonite to be soaked afterwards. A layer of self-hardening cement/bentonite slurry shall be used to grout in the remaining annulus and a manhole suitable for vehicles and trucks must be put in place.

In case the indoor investigation points will be performed with a reduced borehole diameter, a micro piezometer shall be installed in the point 725_MW2 with a ¾ inch diameter.

After installation, monitoring wells shall be developed by pumping at least an amount of water equal to 5-7 volumes of water in the well and until water is clear and free of sediments. The development could be made by using an electric submersible pump.

Once the monitoring wells are installed, a topographic survey shall be performed, to measure their location and top of casing elevation above sea level.

For each monitoring well, the following information shall be recorded:

• Well diameter;

• Constructional diagram;

• Location and type of well slots;

• Location of filter pack and seals (bentonite and grout);

• Top of casing elevation obtained by a topographic survey;

• Groundwater level below top of casing.

4.3.3 Decontamination procedures

Below are the decontamination procedures for drilling equipment:

• To prevent cross-contamination of samples, the coring equipment (corer, rods) must be properly decontaminated before and after every single coring maneuver by means of a pressure washer and clean hot water;

• To assure that water and moisture on inner and outer equipment sides could naturally vaporize, two corers must alternate in drilling operations;

• At the end of drilling operations, the equipment must be kept in such a way as to prevent its contamination;

• While handling equipment clean gloves must be used and, in order to prevent the contact with the contaminated material, disposable gloves must be used.

4.4 Soil gas probes

4.4.1 Location of soil gas probes

For the location of the monitoring points, the indications contained in the SNPA 15/2018 guidelines are taken as a reference. Therefore, a reasoned location of the sampling points is provided. This proposed location considers the potential sources of contamination where the exceedances of the CSCs and the identified targets were detected.

For the verification of the risk from indoor and outdoor inhalation from soil and groundwater, for on-site receptors, it is proposed to install five (5) soil gas probes near the investigation points as below indicated:

• Two (2) probes inside the building, in the housing warehouse, one close to monitoring well 725_MW2 and one close to soil boring 725_SB1;

• One (1) probe inside the heating room, where the spill incident occurred, and the trial pit was performed in

January 2020;

• Two (2) probes outside the building, close to monitoring wells 725_MW3 and 725_MW4.

The location of the soil gas probes points is shown in Figure 2 attached hereto.

4.4.2 Soil gas probes installation

In order to install the probes a borehole up to about 1,50 m b.g.l. shall be obtained. The probe will be put on a 20 cm thick bed made of selected gravel and connected to a 1.30 m long rilsan tube. The gravel will be poured up to cover the probe with a thickness of about 0.15 m of material. Subsequently, two layers will be made up respectively of anhydrous and hydrated bentonite: the first, about 20 cm thick, is laid down in order to prevent the hydrated bentonite from percolating and obstructing the filter; the second is placed dry in 2-3 consecutive layers, each a few centimeters thick, subsequently hydrated with clean water, to create a minimum thickness of 30 cm.

Finally, the remaining thickness will be sealed to the surface with self-hardening cement/bentonite slurry. The sampling points must be completed with the installation of valves which simplify the sampling activities and prevent the entry of ambient air into the sampling point. In addition, to protect the sampling point from rainwater and accidental damage or vandalism a manhole suitable for vehicles and trucks must be put in place.

The monitoring of the interstitial gases will take place at a depth of 1.30 m from p.c.

4.5 Soil sampling

In total, at least sixteen (16) soil samples shall be collected from the eight planned soil borings following the below indicated scheme:

• One sample from 0 to 1 m b.g.l. (shallow soil);

• One sample of the 1 m interval above the groundwater table, including the capillary fringe (deep unsaturated soil);

• If possible, depending on the local groundwater depth, one intermediate sample of a 1 m interval shall be collected from each soil boring.

In addition, samples of every evidence of possible contamination shall be collected, provided that the probable evidence is in a layer thicker than 50 cm.

Soil sampling must be conducted immediately after core extrusion. Due to high volatility of some of the investigated compounds, the dedicated sample shall be collected from the inner part of the core and shall be immediately put inside a hermetic seal container (i.e., glass vials). No homogenization shall be made because it helps the compounds to vaporize.

For the other compounds, a homogenized sample from the relative interval shall be collected and put in a glass jar, separated in the field of particles larger than 2 cm by an adequate sieve.

Every samples shall be collected in split samples, one to be shipped to the lab while the other shall be stored and preserved at low temperature (~4°C) and kept available to the Authorities. A possible third split sample, if requested, can be collected in the presence of the Authorities. It must be sealed up, the Authorities must sign the seal, and a record of its collection must be filled in.

Additionally, specific samples for performing analysis required for risk assessment shall be collected:

• For pH and total organic carbon (TOC) analysis for the saturated zone, three additional homogenized samples shall be collected in the saturated zone and put in a glass jar, separated in the field of particles larger than 2 cm by an adequate sieve;

• For particle size analysis three samples from surface soil (0-1 m b.g.l.), three samples from deep unsaturated soil (1 m - groundwater table b.g.l.) and three samples from saturated soil shall be collected.

Samples could be disturbed but must be unsorted (i.e., not sieved).

To prevent cross contamination, disposable gloves and clean equipment shall be used for sampling.

4.6 Groundwater sampling

Groundwater monitoring shall be performed on every installed monitoring well (725_MW1 - 725_MW7).

Prior to sampling the following activities will be performed:

• Groundwater level measurement using a water level meter;

• Checking the occurrence of non-aqueous phase liquids (LNAPL) using an interface probe;

• Well purging using a submersible pump, by pumping at least an amount of water equal to 3-5 volumes of water in the well;

• Measuring the groundwater physical-chemical parameters:

- temperature (°C);

- pH;

- conductivity (mS/cm);

- dissolved oxygen (mg/l);

- Oxidation Reduction Potential – ORP (mV).

At the end of purge activities, a dynamic sample can be collected using a submersible pump in low flow mode and pumping nearly 1 m above the bottom of the piezometer. The samples for volatile compounds shall be put in glass vials, because they are hermetic seal containers.

For every monitoring well two identical samples must be obtained, one to be shipped to the lab while the other shall be stored and preserved at low temperature (~4°C) and kept available to the HN authorities. A possible third identical sample, if requested, can be collected in the presence of the HN authorities. It must be sealed up, the HN authorities must sign the seal, and a record of its collection must be filled in.

In order to prevent cross-contamination:

• For the sampling activities, only HDPE or Rilsan® disposable sampling tubes could be used and shall be replaced after sampling each well;

• The submersible pump must be properly decontaminated after sampling each well by using an adequate cleaning detergent (e.g., alconox®) and rinsing with abundant clean water.

Due to the disturbance of the aquifer during the development phase of the monitoring wells installation, at least 24 hours should pass before proceeding with groundwater monitoring

The samples must be kept at low temperature (~4°C) and must be shipped to the lab daily while respecting the holding time for the analyses.

4.7 Soil gas monitoring

Pursuant to what indicated in the guideline SNPA no. 17/2018, in order to obtain data that are representative of the seasonal conditions, 4 quarterly campaigns for one year shall be conducted.

The interstitial gas sampling methods incorporate the indications provided by the SNPA Guideline no. 15/2018.

The sampling shall always be preceded by the measurement of the concentrations of VOCs and of O2, CO2 and

CH4, respectively using portable PID and Infrared instruments. The measurements shall be followed by purge of the soil gas probe, which shall be carried out for 3 minutes with a flow equal to 0.02 liter/min; subsequently, the concentrations will be measured again in order to verify their possible variation. Finally, a third measurement will be conducted at the end of the sampling, with the aim of comparing the initial and final concentrations of VOCs and gases.

To avoid the stripping of substances and/or the entry of ambient air, the sampling flow rate (Q) will be low, approximately between 0.02 liter/min and 2 l/min (ISO 18400-204, 2017).

The limits of quantification will be equal to the minimum value among those reported in Appendix 1 to the SNPA

Guideline no. 17/2018 for indoor inhalation for industrial / commercial receptors, for outdoor inhalation for industrial

/ commercial receptors and for outdoor inhalation for recreational receptors.

For the determination of naphthalene and hydrocarbon fractions C ≤ 12 (aliphatic and aromatic fraction), sampling will be carried out at each point using a XAD-2 vial and an activated carbon vial. The volume to be sampled and the sampling times will be assessed in the field on the basis of the PID measurements, in relation to the volumes and times shown in Table 1, Appendix A to the SNPA Guideline no. 15/2018.

4.8 Samples shipping and preservation

Every sample for chemical analysis will labeled and kept at low temperature (~4°C) in an isothermal container. The labels contain at least the following information:

• sample name;

• site;

• kind of environmental matrix;

• date;

• sampler name;

• project number/code.

Specifically, the samples shall be preserved and shipped to the lab daily with a Chain of Custody form filled in, which include the following information besides what will be written on the samples’ labels:

• sample type;

• analyses to be made.

The Chain of Custody will be countersigned by the lab when the samples will be checked-in.

The chosen chemical laboratory must be credited by ACCREDIA for all the below-mentioned analytes

4.9 Chemical analyses

4.9.1 Soil samples

In each soil sample collected from surface and subsurface unsaturated soil, the following compounds must be sought, as per D.Lgs 152/06:

• Light hydrocarbons (C≤12);

• Heavy hydrocarbons (C>12);

• Naphtalene.

For the purpose of risk assessment:

• pH and TOC must be analysed on all the unsaturated soil samples and also in three additional saturated soil samples, to be collected only for pH and TOC analyses;

• In case of detection of HC concentrations exceeding CSC, the samples with exceedances must be tested for the determination of MADEP fingerprinting.

The results of the analyses will be compared against the CSC values included in the D.Lgs. 152/06 Part IV, Title V, Annex 5, Table 1, Column B for industrial and commercial sites.

4.9.2 Groundwater samples

In each collected groundwater sample, the following constituents must be sought, as per D.Lgs 152/06:

• Total Petroleum Hydrocarbons (TPH);

• Naphtalene.

For the purpose of risk assessment:

• In case of detection of TPH concentrations exceeding CSC, the samples with exceedances must be tested for the determination of MADEP fingerprinting.

The results of the analyses will be compared against the CSC values included in the D.Lgs. 152/06 Part IV, Title V, Annex 5, Table 2.

4.9.3 Soil gas samples

Soil gas samples analyses shall include the volatile constituents, as defined by Italian National Health Institute

(ISS), according to the criteria reported in the supporting document to the database of chemical-physical and toxicological properties, issued in March 2018 and as reported in Annex 1 to SNPA Guideline no. 15/2018, that based on results of conducted investigations, will potentially show exceedances of CSRs related to vapor inhalation pathways:

• Hydrocarbons fingerprinting:

─ aliphatic C5-C8;

─ aliphatic C9-C12;

─ aromatic C9-C10;

─ aromatic C11-C12.

• Naphtalene.

4.10 Hydraulic conductivity test

For the purpose of risk assessment, hydraulic conductivity must be determined for the phreatic aquifer. and at least three Lefranc type tests must be performed during drilling activities in the saturated soil. Constant or variable head

Lefranc tests will be carried out depending on the actual soil texture at each tested point (sandy or silty/clayey respectively).

Prior to testing, the groundwater depth shall be precisely measured. The testing shall be performed according to the procedures included in the Guidelines of the Italian Geotechnical Association. Specifically, the Lefranc test shall be performed using the scheme of the cylindrical filter. For this purpose, the pocket shall be obtained with a proper removal of all the material from the borehole and adding gravel to sustain the testing pocket walls.

For variable head mode, the test shall continue until the water table level is reached or is very close to be reached.

For constant head mode, the test shall continue until the flow of added water is eventually stabilized. In any case the test shall not last for more than two hours.

To avoid cross contamination, only clean water shall be used for the test.

5 Waste management

Waste produced by characterization activities shall be handled according to D.Lgs. 152/06 and all other applicable regulations. Waste shall be collected separately for each waste category with appropriate containers, such as big bags for solid waste and plastic tanks for water.

Waste shall be characterized through sampling and lab analyses in order to identify possible hazard characteristics and correct European Waste Code (EWC). Main categories of waste that can be produced during field activities include: soil, purged water from monitoring wells, asphalt, concrete debris and plastic core boxes.

The below-listed EWCs are expected to be produced during field activities:

• 15 01 02 (plastic packaging);

• 16 10 01 (aqueous liquid wastes containing hazardous substances);

• 16 10 02 (16 10 02 aqueous liquid wastes other than those mentioned in 16 10 01).

• 17 05 03 (soil and stones containing hazardous substances);

• 17 05 04 (soil and stones other than those mentioned in 17 05 03);

• 17 03 01 (bituminous mixtures containing coal tar);

• 17 03 02 (bituminous mixtures other than those mentioned in 17 03 01);

• 17 09 03 (other construction and demolition wastes (including mixed wastes) containing hazardous substances);

• 17 09 04 (mixed construction and demolition wastes other than those mentioned in 17 09 01, 17 09 02 and 17 09 03);

Following waste characterization and, on the basis of what indicated in the lab reports, waste shall be transported and disposed of pursuant to applicable regulations in authorized landfills and treatment plants.

6 Reference documents

Bldg. 725, Report of Initial Contaminated Site Survey and Assessment - USAG Italy Darby Military Community.

AECOM, February 2020.

Figures

Figure 1 – Site location map

4000 2km

SCALE 1:40.000

A3

N

Via Watt, 27 I-20143 Milano

Tel. +39.02.422556.1 Fax. +39.02.422556.21

DESCRIPTIONREV. DATE DES. CHK. APP.

ofSheetDRAW N°SCALEPLOTCODE JOB N°

FIGURE 01 11-1:1606019910301W01R1

D.D.G.F.A.G.F.04/22/2020-0

SITE LOCATION MAPFIGURE 01:

USAG Italy DPW Enviromental Division Site Characterization Plan Site CCPL117 - Bldg. 725, USAG Italy DMC, ItalyLEGEND

SITE BOUNDARY

USAG Italy DMC, Livorno

SCALE

1:50.000

SCALE

1:2.000

Bldg. 725

Bldg. 725

HEATING ROOM

Figure 2 – Location of proposed site investigations

TP1

TP2

725_MW2

725_MW1

725_MW4

725_MW3

725_MW5

725_MW7

725_MW6

725_SB1

725_SG1

725_SG3

725_SG2

725_SG4

725_SG5

A3

40 20m

SCALE 1:400

Via Watt, 27 I-20143 Milano

Tel. +39.02.422556.1 Fax. +39.02.422556.21

DESCRIPTIONREV. DATE DES. CHK. APP.

ofSheetDRAW N°SCALEPLOTCODE JOB N°

FIGURE 02 11-1:1606019910301W01R1

D.D.G.F.A.G.F.04/22/2020-0

LOCATION OF PROPOSED SITE INVESTIGATIONSFIGURE 02:

USAG Italy DPW Enviromental Division Site Characterization Plan Site CCPL117 - Bldg. 725, USAG Italy DMC, Italy

LEGEND

HEATING ROOM

EXECUTED TRIAL PIT

MONITOTING WELL

SOIL BORING

SOIL GAS

HEATING ROOM

0 10 50m

SCALE 1:1.000

Annexes

Annex 1 – Soil results of preliminary investigation

Site CCPL117 - Bldg. 725 Site Characterization Plan Annex 1 - Soil results of preliminary investigations

Sample INT - PAR. Nord INT - PAR. Ovest INT - PAR. Est INT - PAR. Sud INT - Bottom

Sampling date 8-Jan-20 8-Jan-20 8-Jan-20 8-Jan-20 8-Jan-20

Constituent Unit

Regulatory limits

D.Lgs. 152/06

Residue at 105 °C % 93,4 94,8 93,6 95,6 95,4

Sieve fraction 2 mm - 2cm g/kg 3,4 < 1 9 1,6 1,9

AROMATIC ORGANIC COMPOUNDS (BTEXS)

Benzene mg/kg 2 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01

Toluene mg/kg 50 1,1 0,74 1,5 0,81 0,63

Ethylbenzene mg/kg 50 3,3 2,7 3,3 2,8 3,4

Xyleni (summation) mg/kg 50 7,4 6,6 < 0.05 < 0.05 < 0.05

Styrene mg/kg 50 < 0.05 < 0.05 < 0.05 < 0.05 < 0.05

Aromatic Organic Compounds Summation (D.Lgs. 152/06 All. 5 Tab 1 Col B) mg/kg 100 12 10 4,8 3,6 4

POLYCYCLIC AROMATIC HYDROCARBONS

Benzo(a)anthracene mg/kg 10 0,0139 < 0.01 0,0267 0,0145 0,0107

Benzo(a)pyrene mg/kg 10 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01

Benzo(b)fluoranthene mg/kg 10 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01

Benzo(k)fluoranthene mg/kg 10 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01

Benzo(g,h,i)perylene mg/kg 10 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01

Chrysene mg/kg 50 0,0141 0,014 0,0344 0,0194 0,0136

Dibenzo(a,e)pyrene mg/kg 10 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01

Dibenzo(a,l)pyrene mg/kg 10 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01

Dibenzo(a,i)pyrene mg/kg 10 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01

Dibenzo(a,h)pyrene mg/kg 10 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01

Dibenzo(a,h)anthracene mg/kg 10 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01

Indeno(1,2,3-cd)pyrene mg/kg 5 < 0.01 < 0.01 < 0.01 < 0.01 < 0.01

Pyrene mg/kg 50 0,25 0,217 0,285 0,245 0,204

PAHs Summation (D.Lgs. 152/06 All. 5 Tab 1 Col B) mg/kg 100 0,028 0,014 0,0611 0,0339 0,0243

TOTAL HYDROCARBONS

Hydrocarbons C<=12 (C5÷C12) mg/kg 250 400 380 390 370 400

Hydrocarbons C>12 (C12÷C40) mg/kg 750 15.000 13.000 15.000 12.000 12.000

Site CCPL117 - Bldg. 725 Site Characterization Plan Annex 1 - Soil results of preliminary investigations

Sample

Sampling date

Constituent Unit

Regulatory limits

D.Lgs. 152/06

Residue at 105 °C %

Sieve fraction 2 mm - 2cm g/kg

AROMATIC ORGANIC COMPOUNDS (BTEXS)

Benzene mg/kg 2

Toluene mg/kg 50

Ethylbenzene mg/kg 50

Xyleni (summation) mg/kg 50

Styrene mg/kg 50

Aromatic Organic Compounds Summation (D.Lgs. 152/06 All. 5 Tab 1 Col B) mg/kg 100

POLYCYCLIC AROMATIC HYDROCARBONS

Benzo(a)anthracene mg/kg 10

Benzo(a)pyrene mg/kg 10

Benzo(b)fluoranthene mg/kg 10

Benzo(k)fluoranthene mg/kg 10

Benzo(g,h,i)perylene mg/kg 10

Chrysene mg/kg 50

Dibenzo(a,e)pyrene mg/kg 10

Dibenzo(a,l)pyrene mg/kg 10

Dibenzo(a,i)pyrene mg/kg 10

Dibenzo(a,h)pyrene mg/kg 10

Dibenzo(a,h)anthracene mg/kg 10

Indeno(1,2,3-cd)pyrene mg/kg 5

Pyrene mg/kg 50

PAHs Summation (D.Lgs. 152/06 All. 5 Tab 1 Col B) mg/kg 100

TOTAL HYDROCARBONS

Hydrocarbons C<=12 (C5÷C12) mg/kg 250

Hydrocarbons C>12 (C12÷C40) mg/kg 750

INT (0 - 1) m INT (1 - 1,9) m EXT - PAR. Nord EXT - PAR. Ovest EXT - PAR. Est

8-Jan-20 8-Jan-20 8-Jan-20 8-Jan-20 8-Jan-20

93,4 94,7 94,8 94,4 93,3

18,2 2,2 < 1 < 1 13,3

< 0.01 < 0.01 < 0.01 < 0.01 < 0.01

0,95 < 0.05 < 0.05 < 0.05 < 0.05

2 2,7 < 0.05 < 0.05 < 0.05

< 0.05 < 0.05 < 0.05 < 0.05 < 0.05

< 0.05 < 0.05 < 0.05 < 0.05 < 0.05

3 2,7 < 0.05 < 0.05 < 0.05

0,0114 < 0.01 < 0.01 < 0.01 < 0.01

< 0.01 < 0.01 < 0.01 < 0.01 < 0.01

< 0.01 < 0.01 < 0.01 < 0.01 < 0.01

< 0.01 < 0.01 < 0.01 < 0.01 < 0.01

< 0.01 < 0.01 < 0.01 < 0.01 < 0.01

0,0141 < 0.01 < 0.01 < 0.01 < 0.01

< 0.01 < 0.01 < 0.01 < 0.01 < 0.01

< 0.01 < 0.01 < 0.01 < 0.01 < 0.01

< 0.01 < 0.01 < 0.01 < 0.01 < 0.01

< 0.01 < 0.01 < 0.01 < 0.01 < 0.01

< 0.01 < 0.01 < 0.01 < 0.01 < 0.01

< 0.01 < 0.01 < 0.01 < 0.01 < 0.01

0,186 0,123 < 0.01 < 0.01 < 0.01

0,0256 < 0.01 < 0.01 < 0.01 < 0.01

290 370 5,2 < 1.0 20

11.000 12.000 120 < 5.0 290

Site CCPL117 - Bldg. 725 Site Characterization Plan Annex 1 - Soil results of preliminary investigations

Sample

Sampling date

Constituent Unit

Regulatory limits

D.Lgs. 152/06

Residue at 105 °C %

Sieve fraction 2 mm - 2cm g/kg

AROMATIC ORGANIC COMPOUNDS (BTEXS)

Benzene mg/kg 2

Toluene mg/kg 50

Ethylbenzene mg/kg 50

Xyleni (summation) mg/kg 50

Styrene mg/kg 50

Aromatic Organic Compounds Summation (D.Lgs. 152/06 All. 5 Tab 1 Col B) mg/kg 100

POLYCYCLIC AROMATIC HYDROCARBONS

Benzo(a)anthracene mg/kg 10

Benzo(a)pyrene mg/kg 10

Benzo(b)fluoranthene mg/kg 10

Benzo(k)fluoranthene mg/kg 10

Benzo(g,h,i)perylene mg/kg 10

Chrysene mg/kg 50

Dibenzo(a,e)pyrene mg/kg 10

Dibenzo(a,l)pyrene mg/kg 10

Dibenzo(a,i)pyrene mg/kg 10

Dibenzo(a,h)pyrene mg/kg 10

Dibenzo(a,h)anthracene mg/kg 10

Indeno(1,2,3-cd)pyrene mg/kg 5

Pyrene mg/kg 50

PAHs Summation (D.Lgs. 152/06 All. 5 Tab 1 Col B) mg/kg 100

TOTAL HYDROCARBONS

Hydrocarbons C<=12 (C5÷C12) mg/kg 250

Hydrocarbons C>12 (C12÷C40) mg/kg 750

EXT - PAR. Sud EXT - Bottom EXT (0 - 1) m EXT (1-2) m

8-Jan-20 8-Jan-20 8-Jan-20 8-Jan-20

94,5 88,6 94 95

1,3 7,9 7,8 < 1

< 0.01 < 0.01 < 0.01 < 0.01

< 0.05 0,7 < 0.05 < 0.05

< 0.05 1,3 < 0.05 < 0.05

< 0.05 < 0.05 < 0.05 < 0.05

< 0.05 < 0.05 < 0.05 < 0.05

< 0.05 2 < 0.05 < 0.05

< 0.01 < 0.01 < 0.01 < 0.01

< 0.01 < 0.01 < 0.01 < 0.01

< 0.01 < 0.01 < 0.01 < 0.01

< 0.01 < 0.01 < 0.01 < 0.01

< 0.01 < 0.01 < 0.01 < 0.01

< 0.01 < 0.01 < 0.01 < 0.01

< 0.01 < 0.01 < 0.01 < 0.01

< 0.01 < 0.01 < 0.01 < 0.01

< 0.01 < 0.01 < 0.01 < 0.01

< 0.01 < 0.01 < 0.01 < 0.01

< 0.01 < 0.01 < 0.01 < 0.01

< 0.01 < 0.01 < 0.01 < 0.01

< 0.01 0,0843 < 0.01 < 0.01

< 0.01 < 0.01 < 0.01 < 0.01

< 1.0 230 3,4 < 1.0

14 3.700 78 < 5.0

Annex 2 – Drinking water well specifications

U.S. ARMY Camp Darby - Tirrenia (PI), Italy ANALISI DEL SISTEMA IDROPOTABILE

Pagina 30 di 79

La totale protezione di tali aree è, inoltre, garantita da severissime procedure militari che interdicono l’accesso all’ASA e che lo rendono possibile solo per motivi prioritari e comunque sotto stretta sorveglianza (accesso costantemente scortato da personale militare).

Zone di rispetto

Le zone di rispetto relative ad entrambi i pozzi si estendono per un raggio di 200 m da questi e soddisfano i requisiti previsti dall’art.94 del D.Lgs. 152/06.

Nella seguente Figura 13 si riporta la disposizione planimetrica di tali zone, ribadendo, come appena evidenziato in relazione alle zone di tutela assoluta, che esse risultano completamente interne all’installazione militare, che sono ricompresse all’interno dell’area naturale protetta “Selva Pisana” e che l’accesso all’intera area ASA, peraltro completamente recintata, non può avvenire se non per motivi prioritari e comunque sotto costante scorta di personale militare.

Figura 13 – Rappresentazione grafica delle zone di rispetto afferenti ai pozzi n.1 e n.2 e della zona di protezione relativa a entrambi i pozzi

Zona di rispetto Pozzo 1

Zona di rispetto Pozzo 2

Zona di protezione

ZONA DI RISPETTO

POZZO 1

ZONA DI RISPETTO

POZZO 1

ZONA DI

PROTEZIONE

HEATING ROOM

Annex 3 – Spill Incident Report

Digitally signed by RENATO

VAIRA

Date: 2019.12.11 14:52:05 CET

USAG-FES 5W

Where: Camp Darby, Bldg. 725, PX Warehouse/Shops

When: 2 December 2019 at 1935 hours

Who: Engine 3 (4 Personnel), Command 3 (1 Personnel), Military Police (1 Personnel), DPW (4 personnel), Environmental (2 Personnel)

What: Via DPW AC/Heating personnel, diesel fuel lines and filter for the boiler in Bldg. 725 (PX Warehouse/Shops) broke causing large amounts of fuel (approx. 343 gallons /1,300 liters) to free flow and collect within the boiler room and surrounding areas.

1. UPON ARRIVAL: Upon arrival Eng-3 established command, assured scene safety and made contact with DPW personnel. Large amounts of diesel fuel had collected within the walls of the boiler room and the fuel was beginning to seep into the surrounding public service grounding rod connection points. DPW cut power to the fuel pump before FES arrived, stopping the flow and also cutting electrical power to the boiler room itself.

2. ACTIONS TAKEN: Fuel pads were quickly distributed to collect the fuel that had been flowing from under the boiler room walls. E-3 crews monitored the fuel removal operation and assisted in removing manhole covers and provided on-scene manpower and light. DPW and Environmental were contacted and both sent representatives to the scene. Once on scene, DPW used a portable suction pump to reclaim as much fuel as possible but it is estimated that several hundreds of gallons managed to seep into adjoining rooms and in the ground below. The facility manger was also contacted and arrived on scene to allow personnel to check surrounding adjacent rooms. Several adjacent drains were removed to check water runoff and sewer piping, all areas appeared to be clear.

3. CAUSE: The cause of the leak was due to faulty piping and a break in the fuel filter which allowed the fuel to flow freely for an extended period of time.

4. OUTCOME: A portable suction pump was used to reclaim as much as possible. More than 50 gallons/

189.27 liters were reclaimed.