WORK PLAN2001 Supplemental Remedial InvestigationGambell, St. Lawrence Island, AlaskaFINALContract No. GS-10F-0061KDelivery Order No. DACW85-01-F-0039MWH Job Number 1850805.010101September 2001Prepared for:Department of the ArmyUnited States Army Engineer District, AlaskaCorps of EngineersP.O. Box 898Anchorage, Alaska 99506-0898Prepared by:MWH4100 Spenard RoadAnchorage, Alaska 99517200-leF10AK069603 03.04 0004 aTABLE OF CONTENTS1.0 INTRODUCTION1.1 Purpose...1.2 Objectives1.3 Applicable and Relevant or Appropriate Requirements1.4 Document Organization1.5 Site History and Previous Investigations1.5.1Site Description1.5.2Investigation History1.6 Project Team Organization and Responsibilities1.6.1Project Manager1.6.2Safety and Health Manager1.6.3Field Team Leader1.6.4Site Health and Safety Officer1.6.5QA/QC Officer1.6.6Project Chemist1.6.7Environmental Sampler1-11-11-11-21-21-31-41-41-61-61-61-61-71-71-71-72.0 INVESTIGATION PLAN2.1 Site 4A - Quonset Huts Near Former USAF Radar Site2.2 Site 4B - Former USAF Radar Site2.3 Site 6 - Military Landfill2.4 Site 7 - Former Military Power Facility2.5 Site 8 - West Beach/Army Landfill2.6 Site 12 - Nayvaghaq Lake Disposal Site2.7 Site 16 - Gambell Municipal building site2.8 Site 25A - Village of Gambell South Housing Units2.9 Site 25B - Suspected Pits2.10 Site 26 - Debris Burial Feature - 19532.11 Site 27 - Drum Storage Area - 19552.12 Site 28 - Ground Disturbance - 19722.13 Discretionary Sampling Locations2-12-12-22-22-32-42-42-52-52-62-62-72-72-73.0 SAMPLING AND ANALYSIS PLAN3.1 General Field Operations3.2 Field Activities3.2.1Site Reconnaissance3.2.2Well Point Installation3.2.3Environmental Sampling3-13-13-13-13-23-24.0 QUALITY ASSURANCE PROJECT PLAN4.1 Analytical Data Quality Objectives4.2 Analytical Levels4.3 Quality Assurance Objectives for Measurement Data4-14-24-34-3• **••:Gambell 2001 Supplemental Remedial Investigation1850805.010101/14.1.2,,-,••........O Page iSeptember 2001i4.4 Sampling Procedures4.5 Field Instrumentation4.6 Sample Identification4.7 Sample Custody4.8 Analytical Methods4.9 Calibration Procedures and Frequency4.10 Preventive Maintenance4.11 Laboratory Internal QC Checks4.11.1 Preparatory Batch QC4.11.2 Analytical Batch QC4.12 Calculation of Data Quality Indicators4.12.1 Precision4.12.2 Accuracy4.12.3 Completeness4.12.4 Method Detection Limits4.13 Corrective Action4.13.1 Response4.13.2 Re-Establishment of Control4.13.3 QA Reports to Management4.14 Laboratory Data Reduction, Review, and Reporting4.14.1 Reduction4.14.2 Data Review4.15 Performance and System Audits4.15.1 Performance Audits4.15.2 System Audits4-54-54-54-64-84-84-94-104-104-114-114-114-124-124-124-134-134-134-144-144-144-164-194-194-205.0 GAMBELL HEALTH AND SAFETY PLAN ADDENDUM5.1 2001 Supplemental RI Project Activities5.2 Occupational Health Exposure Standards5.3 Project Organization5.4 Personal Acknowledgment5.5 Tailgate Safety Meetings5.6 Emergency Assistance Information5-15-15-15-15-25-25-26.0 WASTE MANAGEMENT PLAN6.1 Spent PetroFlag™ Components6.2 Decontamination Water6.3 Disposable Protective Clothing, Supplies and Sampling Equipment6-16-16-16-17.0 SPILL RESPONSE AND REPORTING PLAN7-18.0 REFERENCES8-1Gambell 2001 Supplemental Remedial Investigation1850805.010101/14.1.2Q Page iiSeptember 2001LIST OF TABLES2-12-24-14-24-35-1Gambell 2001 Supplemental RI SitesAnalytical Sampling SummaryArthur D. Little Laboratory Analytical Methods and Target ParametersQA Objectives for Measurement DataContainers, Preservation Techniques, and Holding TimesOccupational Health Exposure Standards2-12-94-214-224-285-3LIST OF FIGURES1-11-21-32-12-22-32-42-52-62-72-82-92-102-114-15-15-2Gambell, Alaska, Location MapGambell Vicinity MapProject Organization ChartGambell 2001 Supplemental RI Study SitesGambell 2001 Supplemental RI Site 4AGambell 2001 Supplemental RI Site 4BGambell 2001 Supplemental RI Site 6Gambell 2001 Supplemental RI Sites 7 and 27Gambell 2001 Supplemental RI Site 8Gambell 2001 Supplemental RI Site 12Gambell 2001 Supplemental RI Site 16Gambell 2001 Supplemental RI Sites 25A and 25BGambell 2001 Supplemental RI Site 26Gambell 2001 Supplemental RI Site 28QA Sample Bottle Request FormMap to Gambell Health ClinicMap to Hospital in Nome, AlaskaGambell 2001 Supplemental Remedial Investigation1850805.010101/14.1.21-81-91-102-102-112-122-132-142-152-162-172-182-192-204-295-45-5£} Page HiSeptember 2001APPENDICESAppendix AFigures from OSCI ReportAppendix BStandard Operating ProceduresSOP-6Sample Management/PreservationSOP-7Soil SamplingSOP-10 SurveyingSOP-13 Operating and Calibration Procedures for Field EquipmentSOP-14 Field DocumentationSOP-15 Site LogbookSOP-28 HydroPunchSOP-30 Field Analytical ProceduresSOP-35 Investigation Derived Waste ManagementAppendix CField FormsTailgate Safety Meeting FormPersonal Acknowledgment FormUnited States Army Corps of Engineers Accident Investigation ReportPostersDischarge Notification and Reporting RequirementsReport All Oil and Hazardous Substance SpillsOSHA Job Safety & Health ProtectionOSHA 200 FormAppendix DGambell 2001 Supplemental Remedial Investigation1850805.010101/14.1.2Q Page ivSeptember 2001ACRONYMS AND ABBREVIATIONSAACA/EACGIHADECADLAKAlaska DistrictARARARIASTMATVbgsBTEXCCVSCDAPCDQRCERCLACFCoCCOCDERPDoDDQODROE&EEDFERFTLFUDSGC/MSGROHASPHTSAEDLHIDWLCSLCSDLIMSMDLmg/Kgmg/Lmicrograms per kilogrammicrograms per literAlaska Administrative Codearchitect/engineerAmerican Conference of Governmental Industrial HygienistsAlaska Department of Environmental ConservationArthur D. Little, Inc.Alaska MethodUnited States Army Engineer District, AlaskaApplicable and Relevant or Appropriate RequirementsAnalytical Resources, Inc.American Society for Testing and Materialsall-terrain vehiclebelow ground surfacebenzene, toluene, ethylbenzene, and xylenescontinuing calibration verification standardChemical Data Acquisition PlanChemical Data Quality ReviewComprehensive Environmental Response, Compensation and Liability Actcalibration factorchain-of-custodycontaminants of concernDefense Environmental Restoration ProgramUnited States Department of Defensedata quality objectivesdiesel range organicsEcology & Environmentelectronic deliverable formatEngineering RegulationField Team LeaderFormerly Used Defense Sitesgas chromatography/mass spectroscopygasoline range organicsHealth and Safety PlanHistorical Time Sequence Analysisimmediately dangerous to life and healthinvestigative-derived wasteslaboratory control samplelaboratory control sample duplicateLaboratory Information Management Systemmethod detection limitmilligrams per kilogrammilligrams per literGambell 2001 Supplemental Remedial Investigation1850805.010101/14.1.2O Page vSeptember 2001mLMSMSDMSDSMSLNIOSHOSCIOSHAPAHPARCCPCBPEPELPIDPLPOLPPEpptPQLQAQA/QCQAPQAPPQCQSMRCRARELRFRIRLRPDRRORSDSAPSARASHMSHSOSIMSOPSPIPSSHASPSWTALTECTLV-TWAUSCmillilitermatrix spikematrix spike duplicateMaterials Safety Data Sheetmean sea levelNational Institute for Occupational Safety and HealthOil Spill Consultants, Inc.Occupational Safety and Health Administrationpolynuclear aromatic hydrocarbonprecision, accuracy, representativeness, completeness, and comparabilitypolychlorinated biphenylperformance evaluationpermissible exposure limitphotoionization detectorPublic Lawpetroleum, oil, or lubricantpersonal protective equipmentparts per trillionpractical quantitation limitquality assurancequality assurance/quality controlQuality Assurance PlanQuality Assurance Project Planquality controlQuality Services ManagerResource Conservation and Recovery Actrecommended exposure limitresponse factorRemedial Investigationreporting limitrelative percent differenceresidual range organicsrelative standard deviationSampling and Analysis PlanSuperfund Amendments and Reauthorization ActSafety and Health ManagerSite Health and Safety Officerselected ion monitoringstandard operating procedureStrategic Project Implementation PlanSite-Specific Health and Safety PlanSolid Waste MethodTarget Analyte ListTopographic Engineering Centerthreshold limit values-time weighted averagesUnited States CodeGambell 2001 Supplemental Remedial Investigation1850805.010101/14.1.2U Page viSeptember 2001URSUS AEDUSAEHAUS AFUSEPAVOCURS CorporationUnited States Army Engineer DistrictUnited States Army Environmental Hygiene AgencyUnited States Air ForceUnited States Environmental Protection Agencyvolatile organic compoundsGambell 2001 Supplemental Remedial Investigation1850805.010101/14.1.2O Page viiSeptember 20011.0INTRODUCTIONPursuant to Contract No. GS-10F-0061K, the United States Army Engineer District, Alaska(Alaska District), contracted with MWH, formerly Montgomery Watson, to address areas atGambell, St. Lawrence Island, Alaska, where collecting data is necessary to resolve the extentof contamination resulting from Formerly Used Defense Sites (FUDS) activities (Figure 1-1).This 2001 Supplemental Remedial Investigation (RI) Work Plan was prepared according tothe guidelines of the Defense Environmental Restoration Program (DERP) of the UnitedStates Department of Defense (DoD).1.1PURPOSEFurther study of some sites at Gambell is necessary because new information that warrantsinvestigation has become available to the Alaska District. Previous information included theresults of Phase I and Phase II RIs performed in the Gambell area in 1994 and 1998,respectively. The objectives of the previous RIs were to gather sufficient chemical,geophysical, and hydrogeologic data to identify and characterize sites requiring remediation.Based on the findings of the 1998 RI, many individual sites were recommended for no furtheraction.New information about sites at Gambell comes primarily from three sources. The first sourceof new information is a document entitled "GIS-Based Historical Time Sequence Analysis"(HTSA), completed in September 2000 by the U.S. Army Topographic Engineering Center(TEC). The HTSA combined information from historical aerial photographs and otherdocuments with current aerial maps of the Gambell area and identified previously unknownlocations of past military equipment and operations. The second source of new information isthe Strategic Project Implementation Plan (SPIP) prepared by Montgomery Watson inDecember 2000. The SPIP included a questionnaire completed by Gambell residents toidentify potentially contaminated areas not identified in previous investigations; many suchsites were identified and investigated via geophysical surveys in 1999. The third source ofnew information is a report of remedial actions performed by Oil Spill Consultants, Inc.(OSCI,) during summer 1999. Samples collected to confirm that contaminated soils had beenremoved indicated that contamination may remain at several sites.1.2OBJECTIVESThe focus of the 2001 fieldwork is to collect sufficient soil and groundwater samples atselected sites in the Gambell area to determine the nature and extent of contamination. Studysites are shown in Figure 1-2, and rationale for selecting these sites is discussed in Section 2.Specific study objectives include:Gambell 2001 Supplemental Remedial InvestigationWork Plan - FinalQ Page 1-1September 2001Soil••Determine the nature and extent of fuel-related contamination at Sites 6, 7, 16, 25A, and25B.Determine the source (military or other) of fuel-related contamination at Sites 7, 16, and25A. The DQO is qualitative evaluation of petroleum hydrocarbons.•Determine the nature and extent of solvent and metal contamination in soils at Sites 6 and7.•Confirm previous sampling results for fuel and metal contamination in soil at Sites 4A,4B, 6, 8, and 12.•Evaluate for the presence of fuel, solvent, and metal contamination in soils at areas notpreviously investigated at new Sites 25B, 26, 27, and 28.•Evaluate for the presence of PCB contamination in soils at Sites 7 and 27.Groundwater•1.3Determine the nature and extent of fuel-related contamination at Sites 6, 7, and 25A.APPLICABLE AND RELEVANT OR APPROPRIATE REQUIREMENTSThis Supplemental RI for Gambell follows the CERCLA process (ComprehensiveEnvironmental Restoration Compensation, and Liability Act of 1980, Public Law [PL] 96510, as amended by the Superfund Amendments and Reauthorization Act [SARA] of 1986,PL-99-499 [codified as 42 USC 9601-9675]). In accordance with CERCLA, the Alaska StateOil and Other Hazardous Substance Pollution Control Regulations (18 AAC 75) that governthe cleanup of contaminated sites in Alaska were identified as applicable and relevant orappropriate requirements (ARAR) for Gambell. The following regulations and standardsapply:•The 18 AAC 75 Alaska Department of Environmental Conservation (ADEC) Method 1matrix levels are used to support recommendations for no further actions wherecontaminant levels in soil fall below matrix levels. For sites where petroleum levelsexceed Method 1 matrix levels, Method 2, under 40-inch zone, migration to groundwatercriteria are used.•Groundwater cleanup criteria are identified in 18 AAC 75.345, Table C.1.4DOCUMENT ORGANIZATIONThis Work Plan includes eight sections and three appendices that describe all field operationsand objectives, appropriate methodology, quality assurance (QA) procedures, health andsafety actions, investigative-derived waste (IDW) handling activities, procedures for spillresponse and reporting, and waste management procedures that will be implemented duringthe 2001 Supplemental RI.••~~.. . . .. . ..........Gambell 2001 Supplemental Remedial InvestigationWork Plan - FinalO Page 1-2September 2001•Section 1 presents a project description, including project purpose and data objectives,ARAR, a brief history of operations and previous investigations at Gambell, projectorganization, and responsibilities of individual project personnel.•Section 2 contains the Investigation Plan, which provides a description of the tasks to beperformed during the 2001 RI and lists objectives for the sampling program.•Section 3 includes the Sampling and Analysis Plan (SAP), which contains a description offield procedures to be used by the field team during the 2001 field program. The SAPreferences the Standard Operating Procedures (SOP) included in Appendix B and detailsdepartures from the SOPs.Section 4 contains the Quality Assurance Project Plan (QAPP), which establishesrequirements for quality assurance/quality control (QA/QC) associated with sampling andanalysis work conducted during the 2001 RI.••Section 5 contains the Health and Safety Plan (HASP) Addendum, which establishes allhealth and safety guidelines that will be followed during field activities at St. LawrenceIsland during the 2001 RI.•Section 6 contains the Waste Management Plan, which details the handling, packaging,and final disposal of chemicals and investigative-derived waste (IDW), if any, to beremoved from site.Section 7 contains the Spill Response and Reporting Plan, which describes the proceduresthat will be performed if a spill should occur during field activities.••Section 8 lists the references used to develop this Work Plan.1.5SITE HISTORY AND PREVIOUS INVESTIGATIONSThe site history and previous investigation information contained in this Work Plan have beensummarized from reports documenting previous investigation results from the Gambell area.More detailed site descriptions and background information, including results of fieldinvestigations, can be found in the documents listed below:•Final Remedial Action Report for Debris Removal and Containerized Hazardous Wasteand Toxic Waste Removal, Gambell, Alaska. Oil Spill Consultants, Inc., February 15,2001.•Strategic Project Implementation Plan, Gambell, St. Lawrence Island, Alaska. Final.Montgomery Watson, December 2000.•GIS-Based Historical Time Sequence Analysis (Historical Photographic Analysis),Gambell Sites, St. Lawrence Island, Alaska. United States Army Corps of EngineersEngineer Research and Development Center, TEC, September 2000.•Site 5 Remedial Investigation, Gambell, St. Lawrence Island, Alaska.Watson, 1999.Gambell 2001 Supplemental Remedial InvestigationWork Plan - FinalMontgomeryO Page 1-3September 2001•Phase II Remedial Investigation, Gambell, St. Lawrence Island, Alaska.Montgomery Watson, December, 1998•Final Investigation of Geophysical Anomaly, Gambell, St. Lawrence Island, Alaska.Final. Montgomery Watson, December 1997.•Remedial Action Alternatives Technical Memorandum, Gambell, St. Lawrence Island,Alaska. Montgomery Watson, November 1995.•Remedial Investigation, Gambell, St. Lawrence Island, Alaska. Montgomery Watson,January 1995.•Chemical Data Acquisition Plan, Site Inventory Update, Gambell, St. Lawrence Island,Alaska. Ecology & Environment (E&E), February 1993.•Site Inventory Report, Gambell Formerly Used Defense Site, St. Lawrence Island, Alaska.E&E, December 1992.1.5.1Final.Site DescriptionGambell is located off the coast of western Alaska on the northwest tip of St. LawrenceIsland, in the western portion of the Bering Sea, approximately 200 air miles southwest ofNome, Alaska, and 39 air miles from the Siberian Chukotsk Peninsula (Figure 1-1). Thevillage of Gambell, at an elevation of approximately 30 feet above mean sea level (MSL), issituated on a gravel spit that projects northward and westward from the island (Figure 1-2).St. Lawrence Island is currently owned jointly by Sivuqaq, Inc., in Gambell, Alaska, andSavoonga Native Corporation in Savoonga, Alaska. Non-Native land on St. Lawrence Islandis limited to state land used for airstrips and related facilities in Gambell (MontgomeryWatson, 1995a).The village of Gambell is inhabited primarily by Native St. Lawrence Island Yupik peoplewho lead a subsistence-based lifestyle. The Gambell area supports habitat for a variety ofseabirds, waterfowl, and mammals that either breed in or visit the area. The area surroundingthe top of Sevuokuk Mountain, above the Village of Gambell, supports a large bird rookery.The birds and bird eggs serve as a subsistence food source for local inhabitants. The oceansurrounding the Gambell area is used extensively for subsistence hunting of whales, walrus,seals, sea birds, and fish.1.5.2Investigation HistoryThe URS Corporation (URS) conducted a file search and preliminary reconnaissance of theGambell area in 1985. The site reconnaissance included an inventory of all materials left bythe military and collection of a limited number of soil and water samples. The samples wereanalyzed for physical, biological, and chemical characteristics. Soil samples were analyzedfor polychlorinated biphenyls (PCBs) and none were detected.Surface water andgroundwater samples from six wells were analyzed for oil and grease, PCBs, volatile organiccompounds (VOCs), metals, and secondary water quality parameters. Oil and grease ingroundwater samples collected from the Communications Facility and the Radar Power•••Gambell 2001 Supplemental Remedial InvestigationWork Plan - Final••*O Page 1-4September 2001Station exceeded groundwater standards; these contaminants were detected at concentrationsof 14 and 115 milligrams per liter (mg/L), respectively. Arsenic, barium, cadmium,chromium, and lead were also detected; however, the elevated concentrations of metalsreported by URS were not substantiated during subsequent investigations.In 1991 and 1992, E&E conducted site reconnaissance visits and interviewed individualsliving at Gambell during the period of DoD occupation. E&E then prepared a Chemical DataAcquisition Plan (CDAP) for further investigation of the areas of concern based oninformation gathered during the interviews and information reported in the URS document(E&E, 1993). Montgomery Watson implemented the CDAP in 1994 as part of a Phase IRI.The objectives of the 1994 RI were to gather sufficient chemical, geophysical, andhydrological data to identify and characterize sites requiring remediation, and to identifyremedial alternatives for those sites. During this RI, elevated concentrations of prioritypollutant metals, including lead concentrations of up to 3,249 milligrams per kilogram(mg/Kg), were detected in soil; the maximum allowable concentration of lead in soil atresidential areas is 400 mg/Kg. PCBs, dioxins, furans, and fuel-related contaminants werealso detected in soils throughout the investigated area. Fuel-related contaminants andsolvents were detected in groundwater. Recommendations were made for further evaluationat several sites (Montgomery Watson, 1995).In 1996, a geophysical survey was performed at Site 5 where transformers were reportedlyburied near the water supply at Gambell. The geophysical survey confirmed the presence ofmetallic debris. This area was investigated in 1997 to confirm if the anomaly was actually thereported transformers and whether any PCBs were associated with any transformers present.The investigation found that the geophysical anomaly was caused by non-hazardous metallicdebris; no transformers were found. The debris was removed from the island in 1997(Montgomery Watson, 1997).A Phase II RI was conducted in 1998 to fill data gaps from the Phase I RI. Soil andgroundwater samples were collected to delineate the extent of contamination at several sites.Results of the Phase II sampling program indicated no significant surface soil or groundwatercontamination at several of the investigated sites; however, cleanup and removal ofcontaminated media were recommended for other sites (Montgomery Watson, 1998).In 1999, OSCI performed remedial actions at several Gambell sites (OSCI, 2001). Followingremoval of contaminated soils, confirmation samples were collected to demonstrate thatcontaminated soils had been removed; however, confirmation samples showed that fuelrelated contamination and metals were still present at some sites. Additionally, low levels ofdioxins were detected in soils. Concentrations of many contaminants exceeded the levelspermitted by ADEC Method 2, under 40-inch zone, migration to groundwater regulations.Geophysical surveys were performed at several Gambell sites in 2000 to aid in developing theSPIP. These sites were identified during a community survey wherein local residentscompleted questionnaires regarding the whereabouts of remaining military debris. BasedGambell 2001 Supplemental Remedial InvestigationWork Plan - FinalO Page 1-5September 2001upon the results of the geophysical surveys and questionnaires, several sites were targeted forfurther investigation (Montgomery Watson, 2000).Potentially impacted sites were also identified in the HTSA (TEC, 2000). The HTSAcombined data from historic aerial photographs with current maps of Gambell to identifyareas of possible former military use. Following review of the HTSA, four new sites weretargeted for investigation. These new sites are listed below, with aerial photograph dates,where applicable:••••Site 25B - Suspected Pits (located immediately west of Site 25A)Site 26 - Debris Burial Feature - 1953Site 27 - Drum Storage Area - 1955Site 28 - Disturbed Ground - 19721.6PROJECT TEAM ORGANIZATION AND RESPONSIBILITIESThe primary personnel involved in the field investigations are the Project Manager, Safetyand Health Manager (SHM), the Field Team Leader (FTL) who serves as Site Health andSafety Officer (SHSO), QA/QC Officer, the Project Chemist, and Environmental Samplers.The field team will perform the tasks described in this plan by following a managementapproach with clear project organization and well-defined authority and responsibilities for allkey personnel. A project organization chart is shown in Figure 1-3.1.6.1Project ManagerThe Project Manager will set and maintain the performance standards for execution of work,including technical project performance, internal QC, and adherence to schedule and budget.The Project Manager will consult with the Alaska District prior to any deviation from thisWork Plan.1.6.2Safety and Health ManagerThe SHM is responsible for developing, instituting, coordinating, and supervising the healthand safety program for the project. The SHM's responsibilities include ensuring that the sitespecific Health and Safety Plan (SSHASP) complies with all federal, state, and local healthrequirements and coordinating with the SHSO on all modifications to the SSHASP.1.6.3Field Team LeaderThe FTL will coordinate all field activities that occur during the project investigations andwill be the primary field contact. The responsibilities of the FTL will include coordinating allfield activities with the Project Manager and laboratory; maintaining a detailed fieldnotebook; establishing and maintaining a field records system; monitoring compliance of thesample custodian within the provisions of all project plans; and performing otherGambell 2001 Supplemental Remedial InvestigationWork Plan - FinalO Page 1-6September 2001responsibilities as directed by the Project Manager. The FTL will communicate with theProject Manager for any necessary fieldwork clarification.1.6.4Site Health and Safety OfficerThe SHSO will direct all personnel with respect to site health and safety. It is theresponsibility of the SHSO to ensure that all requirements and protocols set forth in the HASPare followed by all field personnel.1.6.5QA/QC OfficerThe QA/QC Officer is responsible for overseeing project QA and ensuring that establishedproject QA/QC protocols are followed. The QA/QC Officer will provide an external, andthereby independent, QA function.1.6.6Project ChemistThe Project Chemist will ensure that project samples are analyzed in accordance with theQAPP and that the chain-of-custody (CoC) record is completed for each sample withappropriate Information. The Project Chemist will oversee sample handling and will ensurethat samples are preserved, packed, and shipped according to United States Army Corps ofEngineers Regulation No. 1110-1-263 (USAGE, 1990).1.6.7Environmental SamplerThe Environmental Sampler will work with the Project Chemist to ensure that the CoC recordis completed for each sample with appropriate information and travels with the samples at alltimes. The Environmental Sampler will perform preservation, packing, and shipping ofsamples in accordance with United States Army Corps of Engineers Regulation No. 1110-1263 (USAGE, 1990).Gambell 2001 Supplemental Remedial InvestigationWork Plan - FinalO Page 1-7September 2001JOB No.0000000.OTIME: I7-SEP-200I Ili45FILE: Ei\usace\gombell\200l\WP\flnal\fgl-l.dgnGambell,St, Lawrence IslandO £ T 0 JV--3 Lawence>Island/"""^J'!-n"/Li>ii^J V,;A.A"'i*! t^.-T,r/ "~ /,'MONTGOMERYWATSONAnchorage, AlaskaSOURCE: U.S. Geological SurveyReston, Virginia 22092,1976St. Lawrence, AlaskaN6265 - W16830 /60x210Surveyed 1948, Compiled 1957Minor Revisions 1974Scale 1:250,000 Contour Interval 100'FIGURE 1-1U.S. ARMY ENGINEER DISTRICT, ALASKAGAMBELL, ST. LAWRENCE ISLAND, ALASKAGAMBELL, ALASKA, LOCATION MAPNORTHBEACH3HHMONTGOMERY WATSONAnchorage, AlaskaAREAS OF CONCERN (2001)| GEOPHYSICAL SURVEY LOCATION PERFORMED IN 1994GEOPHYSICAL SURVEY LOCATION PERFORMED IN 1996GAMBELL VICINITY MAP| G | GEOPHYSICAL SURVEY LOCATION PERFORMED IN 2000|FIGURE 1-2U.S. ARMY ENGINEER DISTRICT, ALASKAGAMBELL, ST. LAWRENCE ISLAND, ALASKASTRATEGIC PROJECT IMPLEMENTATION PLANU.S. ARMY ENGINEER DISTRICT,ALASKAPROJECT MANAGERGary BusseQA OFFICERJane WhitsettPROJECT LABORATORYChemical Testing:Arthur D. Little, Inc.Columbia Analytical ServicesSAFETY & HEALTH MANAGERBeth DarnellFIELD TEAM LEADER /SITE HEALTH & SAFETYOFFICERBonnie McLeanPROJECT CHEMIST &ENVIRONMENTAL SAMPLERSSUBCONTRACTORSSURVEYORMullikin SurveysDRILLERHughes DrillingFIGURE 1-3MONTGOMERY WATSONAnchorage, AlaskaU.S. ARMY ENGINEER DISTRICT, ALASKAGAMBELL, ST. LAWRENCE ISLAND, ALASKAPROJECT ORGANIZATION CHART2.0INVESTIGATION PLANSite descriptions, objectives for the 2001 RI fieldwork, and site activities at each arearequiring data collection are briefly described below. Sites that will be investigated during the2001 RI are listed in Table 2-1 and shown in Figure 2-1. A summary of the 2001 RI sitesampling activities is provided in Table 2-2. Approximate sampling locations are shown inFigures 2-2 through 2-11. Actual sample locations will be determined by the field team basedon field observations and using rationale outlined in this Work Plan.Table 2-1Gambell 2001 Supplemental RI SitesSite NumberSite 4ASite 4BSite6Site 7SiteSSite 12Site 16Site 25ASite 25BSite 26Site 27Site 28UnknownSite DescriptionQuonset Huts near Former USAF Radar SiteFormer USAF Radar SiteMilitary LandfillFormer Military Power FacilityWest Beach/Army LandfillNayvaghaq Lake Disposal SiteMunicipal Building SiteVillage of Gambell South Housing UnitsSuspected PitsDebris Burial Feature - 1953Drum Storage Area - 1 955Disturbed Ground - 1972Discretionary SamplesKey:2.1USAF - United States Air ForceSITE 4A - QUONSET HUTS NEAR FORMER USAF RADAR SITESite 4A, located on Sevuokuk Mountain, formerly contained transformers and two Quonsethuts. During the 1994 RI, surface soil samples were collected from Site 4A and analyzed forfuel-related contaminants, PCBs, solvents, and dioxins; no contaminants were detected abovemethod detection limits (MDL). Confirmation samples collected by OSCI following the 1999removal action contained diesel range organics (DRO) in soil at concentrations of up to 1,310mg/Kg. OSCI's 1999 sample locations, including samples 99GAM014, -015 (field duplicate)-016SL (triplicate), -017, -018, and -019, were shown in OSCI's Figure 7 (see Appendix A ofthis Work Plan). The samples were collected from within and outside of the two Quonset hutfootprints, following removal of the frames.The objective for supplemental RI fieldwork at Site 4A is to confirm 1999 sampling results.Thirty-six surface soil samples (nine each from four triangular grids) will be collected andscreened in the field using a photoionization detector (PID) and PetroFlag™ screening kits.The four triangular sampling grids will be established using the approximate locations of theGambell 2001 Supplemental Remedial InvestigationWork Plan - Finala Page 2-1September 20011999 samples as the grid centerpoints. Locations and orientations of the triangular grids willbe decided in the field based on site observations. The four soil samples (one from each ofthe four grids) with the highest field screening results will be submitted for laboratoryanalysis. Two soil samples will be collected from former confirmation sampling locations99GAM018SL and 99GAM019SL; these samples will be screened in the field for hexavalentchromium.Proposed sampling grid locations for Site 4A are shown in Figure 2-2. Sample analyses andlaboratory methods are listed in Table 2-2.2.2SITE 4B - FORMER USAF RADAR SITESite 4B, the Former United States Air Force (USAF) Site, is located on Sevuokuk Mountainand covers an area approximately 375 feet by 500 feet. This site housed buildings that burnedand caused ordnance to explode and scatter debris. Analyses of soil samples collected duringthe Phase IIRI showed elevated levels of metals and dioxins. Soil and debris removal actionswere performed by OSCI in 1999. The OSCI Site 4B map (OSCI Figure 6, shown inAppendix A of this Work Plan) showed an area approximately 29 feet by 37 feet, portions ofwhich had heavy staining, oily substances, and large rocks. This area was excavated in 1999to a depth of approximately 24 inches; following excavation, confirmation soil samples werecollected, including samples 99GAM020, -021 (field duplicate), -022 (triplicate), -023, -024, 025. The excavation confirmation samples showed DRO and dioxin levels in soil of up to13,900 mg/Kg and 1,846 parts per trillion (ppt), respectively.The objective for supplemental RI fieldwork at Site 4B is to confirm 1999 sampling results.Thirty-six surface soil samples (nine each from four triangular grids) will be collected andscreened in the field using a PID and PetroFlag™ screening kits. The four triangularsampling grids will be established using the approximate locations of the 1999 samples as thegrid centerpoints. Locations and orientations of the triangular grids will be decided in thefield based on site observations and field notes from 1999. The four soil samples (one fromeach of the grids) with the highest field screening results will be submitted for laboratoryanalysis.Proposed sampling grid locations for Site 4B are shown in Figure 2-3. Sample analyses andlaboratory methods are listed in Table 2-2.2.3SITE 6 - MILITARY LANDFILLSite 6 is located north of Gambell High School and east of the new housing area. This landfillwas used to dispose of building materials, vehicles, machinery, drums, and miscellaneousdebris. Exposed drums (7,897 pounds) and other metal debris (1,748 pounds) were removedin 1999 by OSCI. A confirmation soil sample (99GAM026SL) collected from theapproximate center of the removed drum stockpile (see OSCI Figure 8 in Appendix A of thisWork Plan) had low levels of residual range organics (RRO) and arsenic; no other fuel-relatedcontaminants, solvents, PCBs, or pesticides were detected.Gambell 2001 Supplemental Remedial InvestigationWork Plan - FinalO Page 2-2September 2001The objectives for supplemental RI fieldwork at Site 6 are to confirm 1999 sampling resultsand to determine the nature and extent of soil and groundwater contamination. To confirmthe 1999 sample results, nine surface soil samples from one triangular grid will be collectedand screened in the field using a PID and PetroFlag™ screening kits. The triangular samplinggrid will be established using the approximate location of the 1999 sample as the centerpoint.The location will be approximated using site photographs, visual indicators such as staining,and input from local residents who worked on the site. The two soil samples with the highestfield screening results will be submitted for laboratory analysis.To determine the nature and extent of soil contamination, 3 soil borings will be advanced to12 feet below ground surface (bgs), or to permafrost if permafrost is encountered within 12feet of the ground surface. Soil boring locations were determined, in part, by the locations ofdepressions identified from 1980 aerial photographs in the HTSA report. Soil samples will becollected for laboratory analysis at the surface and at the bottom of each borehole. Boreholeswill be continuously split-spoon sampled, and each sample will be field-screened using a PID.Two non-surface, non-bottom borehole soil samples at Site 6 with high PID screening levelswill be submitted for laboratory analysis.To determine the nature and extent of groundwater contamination, three well points will beinstalled and sampled; the locations of the well points will be determined in the field after thesoil borings have been completed.Proposed sampling grid and soil boring locations for Site 6 are shown in Figure 2-4. Sampleanalyses and laboratory methods are listed in Table 2-2.2.4SITE 7 - FORMER MILITARY POWER FACILITYThe Former Military Power Facility was demolished and buried north of the present GambellMunicipal Building. The burial site of this former military facility comprises Site 7.Electrical transformers were reportedly disposed of at this site. Additionally, Gambellresidents have reported that the military may have dumped partially full barrels of oil or otherpetroleum products on the ground in the vicinity of this site. During previous investigations,DRO was detected in shallow soils in concentrations of up to 1,950 mg/Kg. Benzene andDRO were also detected in groundwater samples from Site 7.The objectives for supplemental RI fieldwork at Site 7 are to determine the nature and extentof fuel and groundwater contamination and to determine the source of soil contamination. Todetermine the nature and extent of soil contamination, 3 soil borings will be advanced to 12feet bgs. or to permafrost if permafrost is encountered within 12 feet of the ground surface.Soil boring locations were determined, in part, by the locations of pits and buildings identifiedfrom 1955 a.erial photographs in the HTSA report. Soil samples will be collected forlaboratory analysis at the surface and at the bottom of each borehole. The boreholes will becontinuously split-spoon sampled, and each sample will be field-screened using a PID. Twonon-surface, non-bottom borehole soil samples at Site 7 with high PID screening levels willbe submitted for laboratory analysis.Gambell 2001 Supplemental Remedial InvestigationWork Plan - FinalO Page 2-3September 2001To determine the nature and extent of groundwater contamination, three well points will beinstalled and sampled; locations of the well points will be determined in the field followingcompletion of the soil borings.To determine the source of soil contamination, two soil samples from locations with visibleevidence of fuel-related contamination will be collected and submitted for laboratory fuelfingerprinting analyses.Proposed soil boring locations for Site 7 are shown in Figure 2-5. Sample analyses andlaboratory methods are listed in Table 2-2.2.5SITE 8 - WEST BEACH/ARMY LANDFILLThe Army Landfill at Site 8 is located near West Beach, which extends for approximately 3miles from the southwest end of North Beach to Nayvaghaq Lake. The Army Landfill is onthe northwest side of Nayvaghaq Lake. Surface debris removed by OSCI in 1999 includedscattered metal, small quantities of wood and concrete, drums containing tar, and an exposedlayer of metal landing mat approximately 30 feet wide and 4,500 feet long. A confirmationsoil sample collected at the tar drum area (99GAM012SL; see OSCI Figure 3 in Appendix Aof this Work Plan) showed DRO and RRO at concentrations below ADEC cleanup levels.The objective for supplemental RI fieldwork at Site 8 is to confirm 1999 sampling results atthe former tar drum area. Nine surface soil samples from one triangular grid will be collectedand screened in the field using a PID and PetroFlag™ screening kits. The triangular samplinggrid will be established using the approximate location of the 1999 sample as the gridcenterpoint. Location and orientation of the triangular grid will be decided in the field basedon site observations and interviews with Gambell residents who worked at the site and may beable to provide information on the exact location of the 1999 samples. The two soil sampleswith the highest field screening results will be submitted for laboratory analysis.Proposed sampling grid locations for Site 8 are shown in Figure 2-6. Sample analyses andlaboratory methods are listed in Table 2-2.2.6SITE 12 - NAYVAGHAQ LAKE DISPOSAL SITESite 12 is located north of Nayvaghaq Lake on the southwest side of an all-terrain vehicle(ATV) trail. The site is divided into a north area and a south area, both of which wereaddressed during the OSCI 1999 fieldwork. The north area contained approximately 120drums, battery remnants, and household refuse. The south area contained approximately 50drums, 18 of which were full of garbage. Following the 1999 debris removal, confirmationsoil samples were collected. The OSCI map of Site 12 (shown in Appendix A of this WorkPlan) showed confirmation sample locations 99GAM009, -010, and -011SL, which hadconcentrations of DRO and lead of up to 463 mg/Kg and 562 mg/Kg, respectively.The objectives for supplemental RI fieldwork at Site 12 are to confirm 1999 sampling resultsand to evaluatefor the :presence of: contaminationin the disturbed areas. To confirm the 1999:• ••• •• •- - :• •• ••Gambell 2001 Supplemental Remedial InvestigationWork Plan - FinalQ Page 2-4September 2001sampling results, 27 surface soil samples (9 each from 3 triangular grids) will be collected andscreened in the field using a PID and PetroFlag™ screening kits. Because exact locations ofthe 1999 samples were not surveyed or permanently marked, the triangular sampling gridswill be established using the approximate locations of the 1999 samples as the gridcenterpoints. Locations and orientations of the triangular grids will be decided in the fieldbased on site observations. The four soil samples with the highest field screening results (thehighest from each grid plus the next highest) will be submitted for laboratory analysis.Proposed sampling grid locations for Site 12 are shown in Figure 2-7. Sample analyses andlaboratory methods are listed in Table 2-2.2.7SITE 16 - GAMBELL MUNICIPAL BUILDING SITESite 16 consists of an area of stained gravel located immediately west of the GambellMunicipal Building. The stained area is approximately 35 feet wide and 55 feet long andconsists of a dark gray, oily coating on gravels from 0.5 feet to 2.5 feet bgs. The origin of thestain is unknown, but it may be related to former military use of the site or heavy ATV trafficin this area. During previous investigations of this area, DRO was found in the surface soilsin concentrations of up to 16 mg/Kg. Gambell residents believe that presence of thecontaminated soil may hinder further development of the area or pose a risk to local residents.The objectives for supplemental RI fieldwork at Site 16 are to determine the nature and extentof fuel contamination in soil and to determine the source of soil contamination. To determinethe nature and extent of soil contamination, 4 soil borings will be advanced to 12 feet bgs, orto permafrost if permafrost is encountered within 12 feet of the ground surface. Soil sampleswill be collected for laboratory analysis at the surface and at the bottom of each borehole.Boreholes will be continuously split-spoon sampled, and each sample will be field-screenedusing a PID. Three non-surface, non-bottom borehole soil samples at Site 16 with high PIDscreening levels will be submitted for laboratory analysis.To determine the source of soil contamination, two soil samples collected from locations withvisible evidence of fuel-related contamination and submitted for laboratory fuel fingerprintinganalyses.Proposed soil boring locations for Site 16 are shown in Figure 2-8. Sample analyses andlaboratory methods are listed in Table 2-2.2.8SITE 25A - VILLAGE OF GAMBELL SOUTH HOUSING UNITSThe South Housing Units site was identified in the Gambell SPIP as an area that may becontaminated by fuel-related products of military origin. During construction workperformed in 1997 by Alaska Village Safe Water, oily soils were encountered at thepermafrost interface. Gambell residents reported encountering stove oil and an empty 55gallon drum during excavation for installation of a water main in the vicinity of Site 25A.Residents have also expressed concern that the military may have dumped barrels of oilGambell 2001 Supplemental Remedial InvestigationWork Plan - FinalO Page 2-5September 2001directly on the ground at this site. Areas where trenches, pits, or disturbed ground may havebeen located are apparent on historical aerial photographs of Site 25A.The objectives for supplemental RI fieldwork at Site 25A are to determine the nature andextent of soil and groundwater contamination and to determine the source of soilcontamination. To determine the nature and extent of soil contamination, 6 soil borings willbe advanced to 12 feet bgs, or to permafrost if permafrost is encountered within 12 feet of theground surface. Soil boring locations were determined, in part, by the locations ofdepressions, trenches, and disturbed ground identified by Gambell residents and from aerialphotographs in the HTSA report. Soil samples will be collected for laboratory analysis at thesurface and at the bottom of each borehole. The boreholes will be continuously split-spoonsampled, and each sample will be field screened using a PID. Three non-surface, non-bottomborehole soil samples at Site 25A with high PID screening levels will be submitted forlaboratory analysis.To determine the nature and extent of groundwater contamination, three well points will beinstalled and sampled; locations of the well points will be determined in the field after the soilborings have been completed.To determine the source of soil contamination, two soil samples collected from locations withvisible evidence of fuel-related contamination and submitted for laboratory fuel fingerprintinganalyses.Proposed soil boring and well point locations for Site 25A are shown in Figure 2-9. Sampleanalyses and laboratory methods are listed in Table 2-2.2.9SITE 25B - SUSPECTED PITSSite 25B was identified in a 1973 aerial photograph as a series of pits (TEC, 2000). The siteis located immediately west of Site 25A. The purpose of the suspected pits is unknown.The objective for RI fieldwork at Site 25B is to evaluate for the presence of soilcontamination. To identify soil contamination, 2 soil borings will be advanced to 12 feet bgs,or to permafrost if permafrost is encountered within 12 feet of the ground surface. Soilsamples will be collected for laboratory analysis at the surface and at the bottom of eachborehole.The proposed sampling location for Site 25B is shown in Figure 2-9. Sample analyses andlaboratory methods are listed in Table 2-2.2.10SITE 26 - DEBRIS BURIAL FEATURE -1953Site 26 was identified in a 1953 aerial photograph as a possible debris burial site (TEC, 2000).The site is located east of Gambell High School near Site 18 (Former Main Camp). Residentsof Gambell report finding metal debris, machinery, oily debris, and transformers in the area.Gambell 2001 Supplemental Remedial InvestigationWork Plan - FinalO Page 2-6September 2001The objective for RI fieldwork at Site 26 is to evaluate for the presence of soil contamination.To identify contamination, two soil borings will be advanced to 12 feet bgs, or to permafrostif permafrost is encountered within 12 feet of the ground surface. Soil samples will becollected at the surface and at the bottom of each borehole.Proposed sampling locations for Site 26 are shown in Figure 2-10. Sample analyses andlaboratory methods are listed in Table 2-2.2.11SITE 27 - DRUM STORAGE AREA - 1955Site 27 was identified in a 1955 aerial photograph as a drum storage area (TEC, 2000). Thesite is located north of Site 7 (Former Military Power Facility). Drums that were stored at thissite have been removed.The objective for RI fieldwork at Site 27 is to evaluate for the presence of soil contamination.To identify contamination, 3 soil borings will be advanced to 12 feet bgs, or to permafrost ifpermafrost is encountered within 12 feet of the ground surface. Soil samples will be collectedat the surface and at the bottom of each borehole.Proposed sampling locations for Site 27 are shown in Figure 2-5. Sample analyses andlaboratory methods are listed in Table 2-2.2.12SITE 28 - GROUND DISTURBANCE - 1972Site 28 was identified in a 1972 aerial photograph as a ground disturbance (TEC, 2000). Thesite is located south of Troutman Lake and west of an unnamed lake. This area wasreportedly leased by the Army from January 1955 to May 1958; however, the Army's use ofthe land is unknown.The objective for RI fieldwork at Site 28 is to evaluate for the presence of soil contamination.To identify contamination, 2 soil borings will be advanced to 12 feet bgs, or to permafrost ifpermafrost is encountered within 12 feet of the ground surface. Soil samples will be collectedat the surface and at the bottom of each borehole.Proposed sampling locations for Site 28 are shown in Figure 2-11. Sample analyses andlaboratory methods are listed in Table 2-2.2.13DISCRETIONARY SAMPLING LOCATIONSIn addition to the site-specific sampling described in the preceding sections, soil samples willbe collected from five additional locations. These additional .sampling locations will beselected based on guidance from Gambell residents about areas of local concern, siteobservations of staining or other indications of contamination, and comparison of physicalfeatures observed in the field with features identified in the HTSA. The additional samplinglocations may be outside of the specific sites described in the preceding sections. Samplinglocations will be approved by the Alaska District prior to sample collection.Gambell 2001 Supplemental Remedial InvestigationWork Plan - FinalU Page 2-7September 2001The objective for discretionary RI fieldwork is to evaluate for the presence of soilcontamination. To identify contamination, five soil borings will be advanced to 12 feet bgs,or to permafrost if permafrost is encountered within 12 feet of the ground surface. Boreholeswill be continuously split-spoon sampled, and each sample will be field-screened using a PID.Two samples from each borehole will be submitted for laboratory analysis: one sample withhigh PID screening levels and one sample selected at the discretion of the field investigativeteam based on characteristics such as staining, odor, Pro readings, and proximity to thegroundwater interface.Sample analyses and laboratory methods are listed in Table 2-2.Gambell 2001 Supplemental Remedial InvestigationWork Plan - FinalO Page 2-8September 2001Table 2-2 Analytical Sampling SummaryGROUNDWATERSOILSiteNumber4A4B678121625ASite DescriptionQuonset Huts Near Former Radar SiteFormer Radar SiteFormer Military LandfillNumber ol Number ofGridsBoreholes4410Former Military Power Facility130Army Landfill/West BeachNayvaghaq Lake Disposal SiteQambell Municipal Building Site0South Housing Units0033004625BSuspected Pits0226Debris Burial Feature - 19530227Drum Storage Area - 1 9550328Ground Disturbance - 1 97202051330unknown Discretionary BoreholesTOTALSample LocationSurface SoilSurface SoilSurface SoilBorehole Near-SurfaceBorehole High PIDBorehole BottomGroundwaterBorehole Near-SurfaceBorehole High PIDBorehole BottomFuel FingerprintGroundwaterSurface SoilSurface SoilBorehole Near-SurfaceBorehole High PIDBorehole BottomFuel FingerprintBorehole Near-SurfaceBorehole High PIDBorehole BottomFuel FingerprintGroundwaterBorehole Near-SurfaceBorehole BottomBorehole Near-SurfaceBorehole BottomBorehole Near-SurfaceBorehole BottomBorehole Near-SurfaceBorehole BottomBorehole High PIDBorehole DiscretionaryGrid OnlyHeadspaceVolatilesGrid FuelProductsPID (field)PetroFlag™(field)3636932245T OTAL PRIMARY SAMPLESField Duplicates (QC)Trip BlanksMatrix SpikeMatrix Spike DuplicateTOTAL PRIMARY PLUS QC SAMPLESField Triplicates (QA)QA Trip BlanksQA Matrix SpikeQA Matrix Spike DuplicateTOTAL QA SAMPLESTOTAL SAMPLESRCRA Metals: As, Cd, Cr, Pb, Hg, Ag, Se, BaTAL Metals: Al, Sb, As, Ba, Be, Cd, Ca, Cr, Co, Cu, Fe, Pb, Mg, Mn, Hg, Ni, K, Se, Ag, Na, Tl, V, ZnAK - Alaska MethodBTEX - benzene, toluene, ethylbenzene, and xylenesDRO - diesel range organicsHexavalentChromiumHACHColorimetry(field)2BTEXDRO/RROGROAK102/103AK10144232344232332332323323VOCSW8260BSIM SW8260BPCBsSW8082RCRAMetalsTALMetalsFuelFingerprintDRO/RROGRO/BTEXSW6010B SW6010B/7000/7000(see notes) AK102/103AK101/SW8260B44232333332332323927516244342443463663622223322552222332255228698699552433223431324433426332638281171000|90551059290127127211110|2|116114 __,911112126GRO - gasoline range organicsPID - photoionization detectorQA - Quality AssuranceQC -Quality ControlRCRA - Resource Conservation and Recovery ActFingerprinting will consist of the following tests:D PAH GC/MS/SIMn Gasoline range hydrocarbons GC/MSD Brief interpretive report discussing results of the analytical testing, discussion of relationships to various petroleum product types.D Saturated hydrocarbons (SHC) and select isoprenoids in the diesel range (n-C8 to n-C40) by gas chromatography/ flame ionization detection (GC/FID)D Isotopic Carbon Distribution223322554384655336251118702233225533142162465111821120233575114221142411764RRO - residual range organicsSIM - selected ion monitoringSW - Solid Waste MethodTAL - Target Analyte ListVOC - volatile organic compounds36606911112111315Sample LocationSurface SoilSurface SoilSurface SoilBorehole Near-SurfaceBorehole High PIDBorehole BottomGroundwaterBorehole Near-SurfaceBorehole High PIDBorehole BottomFuel FingerprintGroundwaterSurface SoilSurface SoilBorehole Near-SurfaceBorehole High PIDBorehole BottomFuel FingerprintBorehole Near-SurfaceBorehole High PIDBorehole BottomFuel FingerprintGroundwaterBorehole Near-SurfaceBorehole BottomBorehole Near-SurfaceBorehole BottomBorehole Near-SurfaceBorehole BottomBorehole Near-SurfaceBorehole BottomBorehole High PIDBorehole Discretionary91111131111417ISiteNumber4A4B678121625A25B262728unknown3A /SV, FORMER COMMUNICATIONSI FACILrTY BURIAL AREAAREAS OF CONCERN (2001)MONTGOMERY WATSONAnchorage, AlaskaU.S. ARMY ENGINEER DISTRICT, ALASKAGAMBELU, ST. LAWRENCE ISLAND, ALASKAGAMBELL 2001 SUPPLEMENTAL RlSTUDY SITESSITE 4AREA 4AFORMERTRANSFORMERSSURVEYS FROM SPIP REPORT"CONTAMINATED WATER, METALWIRE. MACHINERY, ANDTRANSFORMERS"FORMER DRUMSLEGENDDRODiesel Range Organics,^^Former Stained Area|RROResidual Range Orgartics\ A\1994 Surface SoilSample Location/•£Triangular Sample Grid LocationNQfET. All sample locations are approximate as are thecorresponding triangular grid locations.SCALE IN FEET?—u^^a—10002. All results shown are in milligrams per kilogram.FIGURE 2-2MONTGOMERY WATSONAnchorage, AlaskaU.S. ARMY ENGINEER DISTRICT, ALASKAGAMBELL, ST. LAWRENCE ISLAND, ALASKAGAMBELL 2001 SUPPLEMENTAL Rl SITE 4A-SLANTEDWOODEN POLEELEVATED CONCENTRATIONSOF DIOXINS IN SURFACE SOILS(1994)99GAM024SLSURVEYS IN SPIP REPORT"CONTAMINATED SOIL ANDWATER"99GAM025SL- WESTERN EDGE OFSEVUOKUK MTN. ANDVILLAGE OF GAMBELLLEGENDDRODiesel Range OrganicsNDNot DetectedRROResidLal Range OrganicsASoil SaVnple Location (1994)ELEVATED CONCENTRATIONSOF METALS IN SURFACE SOILS(1994)Stained AreaATriangu ar Sample Grid LocationNOTE1. All sample local >ns are approximate as arethe corresponding triangular grid locations.SCALE IN FEET2. Results shown ire in milligrams per kilogram.0FIGURE 2-3MONTGOMERY WATSONAnchorage, AlaskaU.S. ARMY ENGINEER DISTRICT, ALASKAGAMBELL, ST. LAWRENCE ISLAND, ALASKAGAMBELL 2001 SUPPLEMENTALRl SITE 4B30JOB No. IBSOSOb,iTIME: I4-SEP-2001 13:33BERINGFILE: E!\usace\gambell\200l\WP\flnal\fg2-6.dgnSEA\0SITE 8LEGEND• FORMER LOCATION FORDRUMS CONTAINING TARDRODiesel Range OrganicsNDNot DetectedRROResidual Range Organics/\Triangular Sample Grid LocationNOTE1. All sample locations are approximate as arethe corresponding triangular grid locations.TROUTMAN LAKE2. Results, shown are in milligrams per kilogram.FIGURE 2-6MWHU.S. ARMY ENGINEER DISTRICT, ALASKAGAMBELL, ST. LAWRENCE ISLAND, ALASKAMONTGOMERY WATSON HARZAAnchorage, AlaskaGAMBELL 2001 SUPPLEMENTAL Rl SITE 899GAM009SL,MW1799GAM010SL-j150 DrumsLEGENDDRO Diesel Rafige Organics---"///^Direction of Groundwater Flow (1994)Former DrumLocationFormer Drum AreaMonitoring Well (1994) /99GAM011SLRRO Residual Range OrganicsIZk//Surface Water Sample Location-' (1994)Triangular Sample Grid Location//——••AK Revision 0August 2000•..•..-••-?..•.;..c--:;:...,.^.-...-. _ _ _ _ — : . • • ----- - -^-- :v—-!—•*--..^i——r—,-n-ia::::^:^:^^--f^ • • • ••::::,:::..;z::!-!-"v'"^r7^-- '•"• --"..--"....-..-:---• ••--•.-•:.•:-••-^^i:-'-i::-"••"••'•SOP-14Page 4 of 10•PID readings from inside of well, purged water, and breathing zone•Background PID readings•Well sampling-Number of samples collected and type of containers used-Date and time of sample collection-Type of analyses-QA/QC samples collected; names given to blind samples•Field observations•Problems encountered and corrective actions taken•Deviations from the sampling plan•Site visitors4.2TAILGATE SAFETY MEETINGSTailgate safety meetings are held at the beginning of each day before the initiation of work. Allpersonnel, subcontractors, and others who will be on the job site are required to attend. Themeetings are usually conducted by the FTL, on-site safety officer, or other qualified teammember. The topics discussed at the meeting should include the following:•••••••Protective clothing and equipmentChemical hazardsPhysical hazardsSpecial equipmentEmergency proceduresEmergency phone numbersDirections to the hospitalAll site personnel are required to sign the tailgate safety meeting form. The original form shouldbe kept on site, and a copy should be sent to the home office.4.3DAILY QUALITY CONTROL REPORTThe preparation of DQCRs is the responsibility of the field team leader. DQCRs are completedon a daily basis and should summarize the events of the day and supplement the information thatis already recorded in the field logbook. DQCRs should be completed regardless of the durationof the field effort. Depending on the client, copies of the report should be distributed to theMontgomery Watson Project Manager, Montgomery Watson Project Geologist, Client ProjectManager (depending on the project), field office file, and home office file. Information recordedin this report should include the following.AK Revision 0August 2000SOP-14Page 5 of 10•Date and Weather Information.humidity.•Montgomery Watson Personnel and Time Spent on Site•Subcontractors and Time Spent on Site•Special Equipment on Site. PID, Smeal Water Sampling Rig, Hollow-Stem Auger Rig, pHmeter, conductivity meter, etc.•Work and Sampling Performed. Personnel performing specific site activities, a summary ofsamples collected, and a thorough explanation of the work completed.•Quality Control Activities. Activities such as decontamination procedures, QA/QC samplestaken, calibration of field equipment, etc.•Health and Safety Levels and Activities. Field parameter measurements, includingcalibration of equipment. Includes daily tailgate safety meetings, level of protection used,etc.•Problems Encountered/Corrective Actions Taken. Any technical difficulties, for exampleproblems encountered during drilling or equipment breakdowns. Any problems that couldpotentially affect the quality of the samples should be included.•Special Notes. Any information that does not fit under the categories listed above, but isimportant to record. Information that would be useful for future sampling such as basecontacts made, visitors on site, etc.•Next Day's Expectations•Signature of Individual Completing the Report.4.4Date, daily temperatures, wind speed and direction,BORING LOGSThe preparation of drill logs is the responsibility of the field team members assigned to the drillrig. A detailed description of well logging is provided in the SOP for that subject. Severalexamples of drilling logs are given in the attachments. The exact format is dependent upon thejob and the client; however, the following basic information should be recorded on the logregardless of the format.••Project and site name•Name of driller and drilling company•Well/soil boring ED and location (sketch)•Drilling and backfilling dates and times•Reference elevation for all depth measurements•Total depth of completed soil boring/well•Depth of grouting, sealing, and grout mixes•Signature of the logger.•AK Revision 0August 2000•••••• •- - • • •• • ••• •'- -•••-•• •"•••• - ^••.-..."-;....:.....^.^..........-•>•.• • • . , ; • ....SOP-14Page 9 of 10custody is accomplished through a chain-of-custody record that lists each sample and theindividuals responsible for sample collection, shipment, and receipt. A sample is considered incustody if it is:•In a person's possession.•In view after being in physical possession.•Locked or sealed so that no one can tamper with it after it has been in an individual's physicalcustody.•In a secured area, restricted to authorized personnel.A COC record is used to record the samples taken and the analyses requested. Informationrecorded includes time and date of sample collection, sample number, and the type of sample, thesampler's signature, the required analysis, and the type of containers and preservatives used. Acopy of the COC record should be retained by the sampler prior to release to a second or thirdparty. Shipping receipts should be signed and filed as evidence of custody transfer between fieldsampler(s), courier, and laboratory.The COC Record will be properly signed and the date of collection and shipment recorded, alongwith the sample site identifications and requested analyses for each sample.4.8.4 Sample RegisterThe sample register is a field record book with prenumbered pages. A full description of eachsample is recorded in the book. The information included in the sample register should includethe following:•••••••••••Sample number (identification)Duplicate and split sample numbers (identification)Location of sampleClientProject numberCollection methodNumber and size of bottles for each analysisDestination of the sampleType of analysisDate and time of collectionName of samplerOther observations may be included as the situation dictates for a thorough record that could beused to reconstruct the events concerning that sample. All information should be recorded inindelible ink.5.0REFERENCESNone.•^—T^—-—^FiH-----??'^ •-•-•-••-•-• -^ --•-.--;.-.-..;::::I:L^ V ••- ' •'" -•"••: i r :i™m'TlI;:;.::±^iziii^z_i^__-••;;-.••;•••••.;•• m-jfiri-MiaiMitL^AK Revision 0August 2000SOP-14Page 10 of 10SOP 15Site LogbookMVVHMONTGOMERY WATSON HAftZASTANDARD OPERATING PROCEDURESSOP-15: SITE LOGBOOK1.0INTRODUCTIONThis guideline describes the process for keeping a site logbook. The site logbook is a controlleddocument that records all major on-site activities during a Remedial Investigation/FeasibilityStudy (RI/FS). At a minimum, the following activities/events should be recorded in the sitelogbook:••••••Arrival/departure of site visitorsArrival/departure of equipmentSample pickup (chain-of-custody form numbers, carrier, time)Sampling activities/sample logsheet numbersStart or completion of borehole/trench/monitoring well installation or sampling activitiesHealth and safety issuesThe site logbook is initiated at the start of the first on-site activity (e.g., initial reconnaissancesurvey). Entries are made for every day that on-site activities take place which involve RI/FScontractor personnel. One current site logbook is maintained per site.The site logbook becomes part of the permanent site file maintained in the RI contractor's office.Because information contained in the site logbook may be admitted as evidence in cost recoveryor other legal proceedings, it is critical that this document be properly maintained.2.0DEFINITIONSSite Logbook - The logbook is a bound notebook with consecutively numbered pages that cannotbe removed. Upon entry of data, the logbook requires signature by the responsible site leader.3.0RESPONSIBILITIESLog books are issued to the field team by the field team leader (FTL). It is the responsibility ofthis person (or designee) to keep the site logbook current while in his possession and to return itto the Project Manager or turn it over to another field team. Following the completion of allfieldwork, the site logbook is returned to the Project Manager for inclusion in the permanent sitefiles.4.0GUIDELINESThe cover of each site logbook contains the following information:••Project nameMontgomery Watson project numberProject manager's nameAK Revision 0August 2000SOP-15Page 1 of 2•••Sequential book numberStart dateEnd dateDaily entries into the logbook may contain a variety of information. At the beginning of eachday the following information must be recorded:• Date• Start time• Weather• All field personnel present• Any visitors presentDuring the day, a summary of all site activities and level of personal protection should berecorded in the logbook. The information need not duplicate that recorded in other fieldnotebooks (e.g., sample logbook, site geologist's notebook, health and safety officer's notebook,etc.), but should summarize the contents of these other notebooks and refer to the page locationsin these notebooks for detailed information.The sample logsheet for each sample collected should be referenced. If measurements are madeat any location, the measurements and equipment used must either be recorded in the sitelogbook or reference must be made to the notebook and page number(s) on which they arerecorded. All entries should be made in black pen. No erasures are permitted. If an incorrectentry is made, the data should be crossed out with a single strike mark, and initialed and dated.At the completion of entries by any individual, the logbook must be signed. It must also besigned by the FTL or responsible site leader at the end of each day.5.0REFERENCESNone.AK Revision 0August 2000SOP-15Page 2 of 2SOP 28HydroPunchMWHMONTGOMERY WATSON HARZASTANDARD OPERATING PROCEDURESSOP-28: HYDROPUNCH1.0INTRODUCTIONThis SOP provides an overview of the methods and procedures to collect groundwater samplesusing a HydroPunch sampler. HydroPunch is a patented method for collecting groundwatersamples at precise depths from water-bearing zones in unconsolidated soils without the drilling,installation, and development of monitoring wells. HydroPunch sampling also can be used tocollect samples of non-aqueous phase liquids (NAPL). The HydroPunch sampler is hammeredor hydraulically advanced through the subsurface to the desired water bearing zone from whichthe sample is to be collected. The groundwater or NAPL sample is allowed to enter the samplerand the sample is retrieved. The installation and sampling procedures are discussed in Section4.0 of this SOP.Two types of HydroPunch samplers can be used. The HydroPunch I sampler is removed intactfrom the subsurface to retrieve the sample. HydroPunch n allows an unlimited sample volume tobe collected using a bailer; however, an expendable drive point must be left in the ground.Because the HydroPunch II can collect an unlimited sample volume, it is considered thepreferable sampling method. In the event that regulations do not permit sampling equipment tobe abandoned in the subsurface, the HydroPunch I should be considered.2.0DEFINITIONSBailer: A cylindrical tool designed to remove solid or liquid material from a well or borehole. Avalve at the bottom of the bailer retains the material. The three types of bailers include the flatvalve, the dart-valve, and the sand pump with rod plunger.Blow Count: The cumulative number of impacts of a 140-pound hammer dropped from a heightof 30 inches applied to a sample spoon that is being driven into subsurface soils or rock. Blowcounts are typically tallied for intervals of 6 inches.Borehole: The hole created by drilling or pushing an object through the subsurface.Cone Penetrorneter: An instrument that identifies underground conditions by measuring thedifferences in the resistance and other physical parameters of the strata. The cone penetrometerconsists of a conical point attached to a drive rod of smaller diameter which is advanced by adrill rig.Drive Point: The conical tip of the HydroPunch sampler that penetrates the subsurface as thesampler is advanced.Non-Aqueous Phase Liquid (NAPL): Petroleum liquid that is immiscible with water and floatsatop the water column.AK Revision 0September 2001SOP-28Page 1 of 3Tremie Pipe: A device, usually a small-diameter pipe, that carries grouting materials to thebottom of the borehole and that allows pressure grouting from the bottom up withoutintroduction of appreciable air pockets.3.0RESPONSIBILITIESProject Manager: Selects site-specific HydroPunch installation, sampling, and analysis programwith input from the site hydrogeologist and field team leader. Oversees and preparessubcontracts.Site Hydrogeologist: Selects site-specific installation options, such as sampling depth. Helpsprepare technical provisions of drilling subcontracts.Field Team Leader: Implements HydroPunch installation and sampling program.Drilling Rig Geologist: Supervises and/or performs HydroPunch point installation and sampling.4.0HYDROPUNCH OPERATIONThis section describes the basic operation, installation and sample collection of HydroPunchsamplers, as well as borehole abandonment. The HydroPunch done is not intended to be used toassess the depth and extent of permeable zones; some knowledge of the site lithologies from soilsamples is necessary prior to HydroPunch sampling.4.1BASIC OPERATION OF HYDROPUNCH SAMPLERSThe HydroPunch II sampler consists of a cylindrical, stainless steel sample body with a length of5 feet and a diameter of 2 inches. A disposable, cylindrical filter screen, inlet valve, andexpendable conical drive point are fitted within the sample body so that these internal parts cantelescope from the sample body. The screen and internal parts are sealed from the exterior by anO-ring seal at the base of the drive point when the HydroPunch is in the closed position. Thesampler is driven to the desired sampling depth in the water bearing zone. The body of thesampler is pulled back approximately 4 feet. When the sample body is retracted, the drive pointand attached screen remain at the original depth and are exposed to the formation, allowing thewater to pass through the exposed screen and enter the sampler body. The screen, consisting ofeither stainless steel or polyethylene, filters soil particles from the sample. A bailer can belowered from the surface into the sampler body to collect the groundwater sample. TheHydroPunch I is slightly longer and narrower than the HydroPunch II. For HydroPunch I, thesampler is retracted 18 inches to expose the inlet screen. When the sample chamber has beenfilled, the entire sampling unit is removed from the subsurface. The groundwater sample is heldin the sample body by two Teflon check valve in the sample body.4.2INSTALLATION OF THE HYDROPUNCH SAMPLERPrior to installation, the internal and external parts of the HydroPunch are to be decontaminatedin accordance with SOP-31.••'';':-• •"••AK Revision 0September 2001:r:.±^^_^^_^^_r_ :- - ''. . . .••'- — •••'«SOP-28Page 2 of 3The HydroPunch sampler can be installed using either a cone penetrometer testing (CPT) rig or aconventional drill rig. Using a CPT rig, the HydroPunch sampler is attached to the CPT pushrods and driven from the surface to depth using the rig's hydraulic ram. CPT procedures arepresented in SOP-11. Using a drill rig, the HydroPunch sampler can be attached to standard soilsampling drill rods and either driven to depth using a standard 140-pound hammer orhydraulically driven through the bottom of a borehole drilled into the water bearing zone. As ageneral rule, without damaging the sampler, the HydroPunch sampler can be driven intoformations using the hammer method if blow counts do not exceed 30 per 6 inches. TheHydroPunch should be driven at least 5 feet below the top of the water bearing zone to allowsufficient pressure to fill the sample chamber, which is higher than the intake screen. Careshould be taken to not retract the sample body prior to reaching the desired sampling depth.When the desired depth is reached, the HydroPunch is retracted either 18 inches (HydroPunch I)or 4 feet (HydroPunch n) (as described in Section 4.1) to expose the inlet screen to the waterbearing zone.4.3SAMPLE COLLECTIONWith the HydroPunch II, a groundwater sample can be retrieved from the sample body in siteusing a 1-inch O.D. sample bailer. The sample bailer is to be decontaminated prior to use inaccordance with SOP 3. The sample volume that may be collected using HydroPunch II istheoretically unlimited, but practical experience indicates that the intake screen will tend to siltup over time and the diminishing productivity of the HydroPunch II point sometimes precludescollecting large sample volumes. NAPL sampling may be conducted with HydroPunch II by thesample method described above using the hydrocarbon bailer supplied by the HydroPunchvendor. The hydrocarbon bailer permits sampling of the NAPL layer with minimal disturbanceand mixing, and allows for a more accurate estimation of NAPL layer thickness. With theHydroPunch I, the groundwater sample is collected by removing the entire sampler from thesubsurface. The sample is retained in the sample chamber by two check valves. Upon retrieval,the upper check valve is replaced with a Teflon stop cock valve. The sampler is turned upsidedown, the stop cock is opened, and the sample is decanted into the sample container. TheHydroPunch I sampler will yield 500 ml of sample volume.4.4BOREHOLE ABANDONMENTFollowing sample collection and removal of the HydroPunch from the subsurface, the boreholeshould be backfilled to the surface in accordance with local regulations, which generally requiregrouting the entire length of the borehole to the surface. For HydroPunch points advanced fromthe ground surface, the small diameter of the borehole will likely require using a tremie pipeduring backfilling to prevent bridging of the backfill material.5.0REFERENCESQED Groundwater Specialists. Groundwater Express Equipment Catalog. 1992.AK Revision 0September 2001SOP-28Page 3 of 3SOP 30Field Analytical Procedures (pH,Conductivity, Temperature, OrganicVapor, Water Levels, and TurbidityMVi/HMONTGOMERY WATSON HARZASTANDARD OPERATING PROCEDURESOP-30: FIELD ANALYTICAL PROCEDURES (pH, CONDUCTIVITY,TEMPERATURE, ORGANIC VAPOR, WATER LEVELS, AND TURBIDITY)1.0INTRODUCTIONThis guideline is a general reference for the proper equipment and techniques for groundwatersampling. The purpose of these procedures is to enable the user to collect representative anddefensible groundwater samples and to facilitate planning of the field sampling effort. Thesetechniques should be followed whenever applicable, although site-specific conditions or projectspecific plans may require adjustments in methodology. SOP-1 presents information regardingdevelopment and sampling equipment decontamination for soil drilling operations. SOP-5contains information regarding groundwater sampling and field measurements.To be valid, a groundwater sample must be representative of the particular zone of the waterbeing sampled. The physical, chemical, and bacteriological integrity of the sample must bemaintained from the time of collection to the time of analysis in order to minimize changes inwater quality parameters. Acceptable equipment for withdrawing samples from completed wellsinclude bailers and various types of pumps. The primary considerations in obtaining arepresentative sample of the groundwater are to avoid collecting stagnant (standing) water in thewell, to avoid physically or chemically altering the water due to improper sampling techniques,sample handling, or transport, and to document that proper sampling procedures have beenfollowed.This guideline describes suggested well evacuation methods, sample collection and handling,field measurement, decontamination, and documentation procedures. Examples of sampling andchain-of-custody (COC) forms are attached.2.0DEFINITIONSAnnular Space: The space between casing or well screen and the wall of the drilled hole, orbetween drill pipe and casing, or between two separate strings of casing. Also called annulus.Aquifer: A geologic formation, group of formations, or part of a formation that is capable ofyielding a significant amount of water to a well or spring.Bailer: A long narrow tubular device with an open top and a check valve at the bottom that isused to remove water from a well during purging or sampling. Bailers may be made of Teflon,polyvinyl chloride (PVC), or stainless steel. Disposable bailers are available and are made ofpolycarbonate.Bladder Pump: A pump consisting of flexible bladder usually made of Teflon contained within arigid cylindrical body (commonly made of PVC). The lower end of the bladder is connectedthrough a check valve to the intake port, while the upper end is connected to a sampling line thatleads to the ground surface. A second line, the gas line, leads from the ground surface to theAK Revision!May 2001SOP-30Page 1 of 6annular space between the bladder and the outer body of the pump. After filling, underhydrostatic pressure, application of gas pressure causes the bladder to collapse, closing the checkvalve and forcing the sample to ground surface through the sample line. Gas pressure is oftenprovided by a compressed air tank, and commercial models generally include a control box thatautomatically switches the gas pressure off and on at appropriate intervals.Centrifugal Pump: A pump that moves a liquid by accelerating it radially outward in an impellerto a surrounding spiral-shaped casing.Chain of Custody: Method for documenting the history and possession of a sample from the timeof its collection through its analysis and data reporting to its final disposition.Check Valve: Ball and spring valves on core barrels, bailers, and sampling devices that are usedto allow water to flow in one direction only.Conductivity (electrical): A measure of the quantity of electricity transferred across a unit area,per unit potential gradient, per unit time. It is the reciprocal of resistivity.Datum: An arbitrary surface (or plane) used in the measurement of heads (i.e., National GeodeticVertical Datum [NGVD], commonly referred to as mean sea level [msl]).Decontamination: A variety of processes used to clean equipment that contacted formationmaterial or groundwater that is known to be or suspected of being contaminated.Downgradient: In the direction of decreasing hydrostatic head.Drawdown: The lowering of the potentiometric or piezometric surface in a well and aquifer dueto the discharge of water from the well.Electric Submersible Pump: A pump that consists of a rotor contained within a chamber anddriven by an electric motor. The entire device is lowered into the well with the electrical cableand discharge tubing attached. A portable power source and control box remain at the surface.Electrical submersible pumps used for groundwater sampling are constructed of inert materialssuch as stainless steel, and are well sealed to prevent sample contamination by lubricants.Filter Pack: Sand or gravel that is generally uniform, clean, and well rounded that is placed in theannulus of the well between the borehole wall and the well screen to prevent formation materialfrom entering through the well screen and to stabilize the adjacent formation.Headspace: The empty volume in a sample container between the water level and the cap.HydroPunch: An in situ groundwater sampling system in which a hollow steel rod is driven intothe saturated zone and a groundwater sample is collected.In Situ: In the natural or original position; in place.AK Revision 1May 2001SOP-30Page 2 of 6Monitoring Well: A well that is constructed by one of a variety of techniques for the purpose ofextracting groundwater for physical, chemical, or biological testing, or for measuring waterlevels.Packer: A transient or dedicated device placed in a well or borehole that isolates or seals aportion of the well, well annulus, or borehole at a specific level.Peristaltic Pump: A low-volume suction pump. The compression of a flexible tube by a rotorresults in the development of suction.pH: A measure of the acidity or alkalinity of a solution, numerically equal to 7 for neutralsolutions, increasing with increasing alkalinity and decreasing with increasing acidity. (Originaldesignation for potential of hydrogen.)Piezometer: An instrument used to measure head at a point in the subsurface; a nonpumpingwell, generally of small diameter, that is used to measure the elevation of the water table orpotentiometric surface.Preservative: An additive (usually an acid or a base) used to protect a sample against decay orspoilage, or to extend the holding time for a sample.Static Water Level: The elevation of the top of a column of water in a monitoring well orpiezometer that is not influenced by pumping or conditions related to well installation,hydrologic testing, or nearby pumpage.Turbidity: Cloudiness in water due to suspended and colloidal organic and inorganic material.Upgradient: In the direction of increasing static head.3.0RESPONSIBILITIESProject Manager: Selects site-specific water sampling methods, locations for monitoring wellinstallations, monitoring wells to be sampled and analytes to be analyzed with input from thefield team leader (FTL) or Superintendent and project geologist. Responsible for project qualitycontrol and field audits.Field Team Leader or Superintendent: Implements water sampling program. Supervises projectgeologist/hydrogeologist and sampling technician. Insures that proper chain-of-custodyprocedures are observed and that samples are sampled, transported, packaged, and shipped in acorrect and timely manner.Project Geologist/Hydrogeologist: Insures proper collection, documentation, and storage ofgroundwater samples prior to shipment to the laboratory. Assists in packaging and shipment ofsamples.AK Revision 1May 2001SOP-30Page 3 of 6Field Sampling Technician: Assists the project geologist/hydrogeologist in the completion oftasks and is responsible for the proper use, decontamination, and maintenance of groundwatersampling equipment.4.0FIELD ANALYTICAL PROCEDURESDuring the well development process, the pH, specific conductance, water temperature, andturbidity (in accordance with American Society for Testing Materials [ASTM] D-1889) will beperiodically measured and recorded on a log sheet. The following sections briefly outline theprocedures for measuring these parameters. This SOP is not intended to be all inclusive, but isintended to provide general guidance regarding these procedures. Specific SOPs have applicablemeasurements for the type of field activity and SAPs will contain any deviations or amendmentsto these procedures. All field instruments shall be calibrated according to manufacturer'sinstructions. All field instruments will be calibrated prior to use. Calibration information shallbe recorded in the field logbook. Detailed information regarding maintenance and servicing isavailable in the operation manual for each meter used. Servicing and maintenance informationwill be recorded in the field logbook. SOP 16 contains specific procedures for fieldmeasurements and guidelines on sampling equipment procedures for field measurements.4.1pHPurge the well until pH, temperature, and specific conductance are at equilibrium. Equilibriumis established as follows: pH variation is less than 0.2 pH units, temperature variation is less than0.5 degrees Celsius, and less than 10 percent variation in specific conductance. Equilibrium willbe established by three consecutive readings, where on casing volume is pumped between eachreading.4.2CONDUCTIVITYPurge the well until pH, temperature, and specific conductance are at equilibrium. Equilibriumis established as follows: pH variation is less than 0.2 pH units, temperature variation is less than0.5 degrees Celsius, and less than 10 percent variation in specific conductance. Equilibrium willbe established by three consecutive readings, where on casing volume is pumped between eachreading.4.3TEMPERATUREPurge the well until pH, temperature, and specific conductance are at equilibrium. Equilibriumis established as follows: pH variation is less than 0.2 pH units, temperature variation is less than0.5 degrees Celsius, and less than 10 percent variation in specific conductance. Equilibrium willbe established by three consecutive readings, where on casing volume is pumped between eachreading.AK Revision!May 2001SOP-30Page 4 of 64.4ORGANIC VAPORAn organic vapor analyzer (photoionization detector [PID] or flame ionization detector [FID])will be used to field-screen soil to determine if VOCs are present. Field screening will beperformed by placing the detector within an inch of recently excavated or exposed in-place soil.The highest concentration detected will be recorded on the field notebook. Additional soil will beexcavated if the concentration detected by an OVA is above background. Confirmation sampleswill be collected if the concentration is at background or below detection. Soil conditions, tankand line conditions, and the presence of petroleum odors and stained soils, as well as fieldscreening results, will be used as additional information for decision-making.OVAs will be used only as field screening tools, since they have the following limitations:•OVAs measure the concentration of total organic vapors and serve as a general indicator ofthe level of contamination in soil.•OVAs are not compound-specific and can detect the presence of a wide range of volatileorganic compounds, many of which are not regulated under the IEPA UST regulations (e.g.,the PID detects ammonia compounds and the FID detects methane).•Moisture and cold temperatures can cause inaccurate meter readings during field screening.If more accurate field-screening data are required, a headspace sample can be collected byplacing soil material (in-place or recently excavated soil) into a sample jar or "ziplock"-typeplastic bag. The container is partially filled (50 to 75 percent), leaving an excess space or"headspace" above the soil. The bag is sealed or the top of the sample jar is covered withaluminum foil and sealed with the lid. The sample is heated by placing it in the sun or near aheat source. The seal is broken or the foil is pierced with the detector probe to determine theconcentration of the organic compounds which have volatilized from the soil and into thecontainer headspace. The highest concentration detected is recorded on the field log.4.5WATER LEVELSWater level measurement procedures are described in detail in SOP 6-Monitoring Well Design,Construction, aind Installation.4.6TURBIDITYThe well will be considered adequately developed when the measured parameters are stablized,the necessary quantity of water removed, and the water is visibly clear of sand and sediments.During well development, a turbidity of 5 nephelometric turbidity units (NTUs) will be the goalfor water clarity. In the event that the 5 NTU goal cannot be reached in 4 hours in thedevelopment process, variation in specific capacity values will be used to determine if welldevelopment is adequate. Four consecutive specific capacity readings with 10 percent of eachother will indicate adequate well development. If the specific capacity and the measuredparameters listed above are stablized (no more than 10 percent variance between three•:•-AK Revision 1May 2001•'•'-'•••;,••.:•.•.•....;:•.•- - . - . :---. - • : • • -.....:,..,-. -SOP-30Page 5 of 6.consecutive readings) and the proper amount of water is withdrawn, but the turbidity exceeds 5NTUs, then an additional amount of water equal to two standing water volumes will be removed,at which point the well will be considered fully developed.5.0REFERENCESAller, L., Bennett, T.W., Hackett, G., Petty, R.J., Lehr, J.H., Sedoris, H., and Nielsen, D.M.,1989. Handbook of suggested practices for the design and installation of groundwatermonitoring wells, National Water Well Association, Dublin, Ohio, 397 pp.Driscoll, F.G., 1987. Groundwater and Wells, Johnson Division, St. Paul, Minnesota, 1089 pp.Nielsen, D. ed., 1991. Ground-water Monitoring, Lewis Publishers, Chelsea, Michigan, 717 pp.U.S. Environmental Protection Agency (USEPA), 1987. A Compendium of Superfund FieldOperations Methods, EPA/540/p-87/001USEPA, 1986 SW846, Test Methods for Evaluating Solid Waste, Third Edition USAGE, 1994.EM-200-1-3, Requirements for the Preparation of Sampling and Analysis PlansAK Revision 1May 2001SOP-30Page 6 of 6SOP 35Investigation Derived WasteManagementMWHMONTGOMERY WATSON HARZASTANDARD OPERATING PROCEDURESSOP-35: INVESTIGATION DERIVED WASTE MANAGEMENT1.0INTRODUCTIONThe purpose of this Standard Operating Procedure (SOP) is to describe the policy, organization,functional activities, and investigation-derived waste (E)W) management control to beimplemented for field investigation activities. The plan should be used as a guideline for futurewaste management. More detailed, site-specific information should be presented in theSampling and Analysis Plans (SAPs) prepared for individual investigations conducted at eachsite. The objective of the plan is to describe the procedures required to manage IDW. Inaddition, the SOP establishes the sampling and analytical procedures to be followed to managethe IDW as required by CERCLA, Superfund Amendments and Reauthorization Act (SARA),and Resource Conservation and Recovery Act (RCRA) guidance. Detailed informationpresented in this SOP addresses the following:•Typical types of IDW that will be generated and managed during investigation activities atthe three OUs•Typical specific activities expected to be conducted that may generate IDW.•Specific waste parameters or characteristics that need to be quantified to ensure safe andeffective management of IDWMethods of obtaining necessary data to assess IDW, such as sampling and analysisprocedures••Options for disposal of IDW•Applicable or relevant and appropriate requirements (ARARs) to be considered during theimplementation of the SOP1.1PLAN ORGANIZATIONThe organization of the SOP is designed to facilitate the decision-making process, presenting alogical approach to be used in determining the proper handling and treatment or disposal ofIDW. Section 2.0 presents information on the types, typical volumes, and containment of wastesgenerated during field investigations as well as the field activities that are expected to generateIDW at the three OUs. Section 3.0 outlines the intermediate handling and management of wastesoils, liquid wastes, personal protective equipment, and disposable equipment. Record-keepingpractices, containerization, storage, characterization, and sampling and analysis protocols for theIDW also included in Section 3.0. Section 4.0 details the disposal options available for the IDW.Section 5.0 discusses ARARs to be considered for implementation of the SOP during the fieldinvestigations.AK Revision 0August 2000SOP-35Page 1 of 202.0GENERATION OF INVESTIGATION-DERIVED WASTESDuring field programs, a variety of potentially contaminated EDWs will be generated. Potentialfield activities include drilling, trenching or test pits, groundwater sampling, surface watersampling, aquifer testing, soil-gas surveys, geophysical surveys, and location surveys. TheNational Contingency Plan (NCP), codified in 40 Code of Federal Regulations (CFR) 300,requires that the handling of IDW attains all the ARARs to the extent practicable considering theurgency of the situation.2.1TYPES OF IDWEDW generated during field activities may include the following media and waste types:• Soil• Drilling mud• Groundwater• Decontamination fluids• Personal protective equipment (PPE)• Disposable equipmentThe above wastes may or may not be considered hazardous for the purposes of handling anddisposal. Section 3.6 details how the wastes will be characterized prior to determining theappropriate disposal option. In addition to the IDW listed above, refuse may be generated duringfield activities. This could include, for example, packaging materials and broken or cut-off wellscreening and casing. Typically, this refuse can be treated as nonhazardous material anddisposed of as appropriate, such as in an on-base industrial dumpster.2.2IDW GENERATION ACTIVITIESThe various activities conducted during field investigations will result in the generation of IDW.Field activities may include soil-gas and geophysical surveys; drilling of soil borings; trenchingor test pits; monitoring well installation and development; aquifer testing; collection of soilsurface water and groundwater samples; and location surveys. The IDW generated during theseactivities could potentially be contaminated with various hazardous substances. Estimatedvolumes of IDW generated from various field activities are presented in the sections that follow.As part of the preplanning procedures prior to the initiation of any field effort, the individualcontractors should perform site-specific calculations of the total volumes of IDW expected to begenerated based on the anticipated activities as part of their project planning.An effort should be made to reduce the amount of IDW generated during field activities becausethe quantity of IDW will affect the overall cost of the remedial action and potentially increaseliability or exposure. IDW can be minimized through proper planning of all activities thatgenerate IDW. The sampling equipment and method of decontamination should be selected withconsideration to the volume of IDW that will be generated. Whenever possible, the number ofactivities conducted at a site should be reduced.AK Revision 0August 2000SOP-35Page 2 of 202.2.1Soil-Gas and Geophysical SurveysSoil-gas and geophysical surveys are conducted to identify and locate anomalies, potential "hotspots," and source areas.These activities potentially generate a small volume ofdecontamination fluid and PPE.2.2.2DrillingTwo drilling techniques are typically used for soil boring or monitoring well installation at thehollow-stem auger (HSA) or mud rotary. The preferred method is HSA drilling; however,problems have been encountered using this drilling method for installation of deeper monitoringwells or large diameter extraction wells. To collect shallow soil samples using HSA, a boreholewill typically be drilled using an 8.25-inch outside-diameter (OD) auger to collect soil samples.A minimum of 0.37 cubic feet (cu. ft.) (2.8 gallons) of soil cuttings per linear foot of boreholewill be generated. A 25-foot soil boring would therefore generate a minimum of 9.3 cu. ft. (70gallons) of soil cuttings (filling approximately one and one-half 55-gallon drums). Additionalquantities of soil should be expected when using the HSA due to reworking of the soil duringremoval from the borehole, known as the "fluff factor, and due to slough created during drilling,especially if poorly consolidated materials are encountered. An estimated 30 percent increase insoil-cutting volumes will be generated due to the "fluff factor. Table 2-1 shows the relationshipbetween the diameter of borehole and the potential volume of soil cuttings generated fromdrilling using HSA. The installation of larger diameter soil borings will generate proportionallylarger quantities of soil.The volume of drilling mud generated from the mud rotary drilling method is difficult toestimate because many variables are involved. Mud rotary drilling includes the addition of adrilling fluid, water, to remove the pieces of formation that were broken by the drill bit. Thewater and soil are together referred to as drilling mud. Typically, the drilling mud is separated toremove sand and gravel, and the liquid mud is recycled through the system. The solids (sand andgravel) are deposited in a bin or drum. When the borehole is completed, the mud is flushed outof the borehole and deposited in a tank. The volume of drilling mud generated depends on thestratigraphy encountered, fluid loses during drilling, and solids added to the mud.Drilling by both HSA and mud rotary could also potentially generate large volumes of PPE anddecontamination fluid. These volumes are difficult to estimate because they depend on manysite-specific factors.2.2.3Hand Augering, Surface Soil Sampling ActivitiesTypically, hand augering is conducted using a 3.25-inch inside-diameter (ID) auger. Surface soilsampling is usually completed using hand-held sampling tools. Due to small diameter andlimited drilling depth, a small volume of soil cuttings is estimated to be generated during theseactivities, and a small volume of PPE would also be generated.AK Revision 0August 2000SOP-35Page 3 of 202.2.4Trenches or Test PitsTrenches or test pits may be excavated at sites. Following the soil sampling and visualobservations of the pit, the excavated soil will generally be placed back into the test pit.Depending on specific site conditions, the need may arise to remove the excavated soil from thearea of contamination (AOC). This could potentially generate large volumes of soil to be treatedand/or disposed. Decontamination of the excavation and sampling equipment could potentiallygenerate large volumes of decontamination fluid. PPE will also be generated.2.2.5Location SurveysFollowing the completion of sampling activities, the coordinates and elevations of all samplingpoints, including soil borings, monitoring wells, soil-gas points, and geophysical survey grids,will be surveyed. Small volumes of PPE could potentially be generated.2.2.6Monitoring Well Development, Groundwater Sampling, and AquiferTestingThe volume of groundwater generated through monitoring well development, groundwatersampling, and aquifer testing is dependent upon a number of variables, including well diameter,length of the screened interval, saturated thickness of the well, porosity of the material used asfilter packing, duration and rate of pumping. PPE and decontamination fluid would also begenerated as a result of these activities, but the volume is dependent on the type and duration ofthe activity.Complete well development requires the removal of at least three times the amount of sourcewater used during drilling and construction of the well plus a minimum of three times the volumeof standing groundwater within the well. For example, during the development of a 4-inch-IDwell with 30 feet of standing water, a minimum of 58 gallons of groundwater plus three times theamount of the source water used during drilling and construction of the well would be generated.An additional 58 gallons of groundwater would be generated while purging the well prior togroundwater sampling.Aquifer pump testing will generate much larger volumes of groundwater than well purging.Typical volumes cannot be estimated because they depend on the well construction and theduration of the test.In general, purge water should be segregated by well and containerized in Department ofTransportation (DOT)-approved, 55-gallon drums. If the on-installation treatment system isapproved as a disposal mechanism, an option is to cut costs by consolidating purge water in oninstallation Baker tanks for temporary storage prior to discharge to the treatment system.AK Revision 0August 2000SOP-35Page 4 of 202.2.7Surface Water SamplingSurface water sampling may be conducted to determine the constituents of the surface water atthe site. This activity could potentially generate a small volume of decontamination fluid andPPE.2.2.8Decontamination FluidThe volume of IDW generated as decontamination fluid will be dependent upon a number ofsite-specific factors, and therefore, will vary in quantity. Site-specific factors include the numberand type of field activities per site and the total number of sites being investigated.Decontamination fluid can vary from a few gallons a day for decontamination of instruments toseveral hundred gallons a day for decontamination of large field equipment such as drill rigs.2.2.9PPE and Disposable EquipmentThe volume of IDW generated as PPE and disposable equipment will be dependent upon anumber of site-specific factors and therefore, will vary in quantity. Site-specific factors includethe U.S. Environmental Protection Agency (USEPA) health and safety work level (Level Dversus Levels C or B), number and type of field activities per site, number of people working onsite, total number of sites being investigated, and the amount of disposable equipment that isrequired. PPE waste volumes generated per day will typically account for one-half of a 55gallon drum for a crew of four.2.3IDW CONTAINMENTIDW generated during field activities will be contained at the site of generation or at a designatedcentral location. DOT-approved, 55-gallon drums for the handling of hazardous waste (DOT,USEPA-approved DOT-17-H) should be used for the containment of some of the IDW includingPPE, and disposable sampling equipment. Roll-off boxes and Baker tanks may be used tocontain soil and liquid wastes, respectively. However, DOT-approved, 55-gallon drums may beused to containerize soil and liquid wastes if preferred. The number of each type of containerrequired at each site should be estimated before field work commences.Soil cuttings and/or drilling mud will either be contained in DOT-approved, 55-gallon drums orplaced in roll-off boxes located in the general area of sites being investigated. If soil cuttings aredetermined to be potentially hazardous while in the field (i.e., HNU readings above designatedlevels or visible staining), soil cuttings should be segregated by site or boring, containerized inDOT-approved 55-gallbn drums lined with polyethylene, and immediately secured with lids.Each drum or roll-off box will be labeled as discussed in Section 3.4. Drums or roll-off boxeswill be stored at the site of generation or transported from the AOC following drilling and storedat a central location as instructed by the base environmental coordinator. Drums or roll-offboxes will be held until adequate characterization of the site or the contained soil or drilling mudis completed (Section 3.6.1).AK Revision 0August 2000SOP-35Page 5 of 20Liquid wastes will either be stored within the AOC or transported to a central location. Liquidwastes generated during field investigation activities include fluids generated during wellinstallation, development, purging and sampling, aquifer testing, surface water sampling, anddecontamination of equipment. The base may consolidate liquid wastes in on-installation Bakertanks if the liquids are generated from wells located in areas where previous investigations haveshown no contamination or contaminants at levels that would not adversely affect the existingon-installation groundwater treatment facility. If liquid wastes are determined to be potentiallyhazardous while in the field (i.e., HNU readings above designated levels) or if previousinvestigations have indicated contamination at that location, DOT-approved, 55-gallon drumslined with polyethylene will be used for containment until the liquid can be characterized (seeSection 3.6). Liquid wastes may also be stored in 55-gallon drums if drums are more convenientthan Baker Tanks. Each drum will be labeled as discussed in Section 3.4. Drums will be storedat the site of generation or transported from the AOC and stored at a central location asinstructed by the base environmental coordinator. Liquid wastes will be stored pending IDWcharacterization (Section 3.6).Depending upon the suspected contaminants present, decontamination fluid generated at eachsite may be segregated by site and containerized in DOT-approved, 55-gallon drums or storedwith other liquid wastes generated at the same site. The decontamination fluid will be storedwithin the AOC or a designated central location as instructed by the base environmentalcoordinator. Decontamination fluid will be held until adequate characterization is complete(Section 3.6.2). However, if the on-installation treatment system is approved as a disposalmechanism, decontamination fluid may be transported to Baker tanks for temporary storage andeventual disposal into the system.PPE and disposable equipment produced through field activities will be segregated by site,double-bagged in plastic bags, secured and labeled using a wire tag. The bags will then beplaced in DOT-approved, 55-gallon drums and labeled as discussed in Section 3.4. Partiallyfilled drums will be secured with lids at the completion of field activities or at the end of thework day. PPE and disposable equipment will be held at the site of generation or a designatedcentral location as instructed by the base environmental coordinator. PPE and disposableequipment will be held until adequate characterization of the site or of the containerized PPE anddisposable equipment is completed (Section 3.6).3.0IDW HANDLING AND MANAGEMENT OPTIONSThis section discusses the proper IDW management procedures to be followed in record-keepingpractices, requirements for compliance with storage time limitations, and characterization ofIDW. The protocols established for sampling and analysis of contaminated IDW, if required, arealso presented in this section.Following the field activities, including proper labeling and temporary storage of IDW asappropriate, the first task will be to characterize the IDW generated. Proper characterization isrequired to determine if disposal is necessary and, if so, the appropriate disposal options. Theseoptions include both on-installation and off-installation disposal or treatment and are discussed indetail in Section 4.0. Initially, the IDW will be characterized based on a review of analyticalAK Revision 0August 2000SOP-35Page 6 of 20data generated from environmental samples collected during field activities. This data will becompared to the background data collected during the OU 3 remedial investigation. Based onthis comparison, the characteristics of the IDW will be inferred. In some cases, testingcontainerized IDW may be required to further define disposal options. The management ofinvestigation-derived wastes including containerization and required analyses are presented inSections 3.1, 3.2, and 3.3 for soil, liquids wastes, and PPE, respectively. The methods foraccurately characterizing IDW are presented in Section 3.6.Initially, soil and liquid IDW will be characterized based on the background data. To identifypotential contamination, analytical results should be compared to the 95% Upper ToleranceLevel for the background samples.Proper IDW management requires that the following steps be completed:•Characterize the waste generated•Determine the quantity of waste that is hazardous•Evaluate available on-installation and off-installation disposal/treatment methods•Identify ARARs of concern•Select a disposal option•If off-installation disposal or treatment is required or selected, schedule testing and transportof wastesThe investigation team members will conduct the field activities that generate the IDW (Section2.2), place the IDW in appropriate containers (Section 2.3), and complete record-keepingresponsibilities (Section 3.4). Once the waste has been adequately characterized, theinvestigation team will also arrange for the appropriate treatment or disposal of the IDW.Analytical results of environmental samples and recommended disposal options for EDW will besummarized in a technical memorandum submitted to the Remedial Project Managers (RPMs)and the USAGE by the investigation team. The RPM and USAGE approval will be requiredprior to proceeding with the recommended disposal options. The technical memorandum willdocument the status of containerized IDW with the following information:••••••••A complete list of containers stored at each site of generation or at the central areaUnique identification of each containerContents of each containerAnalytical results of the environmental samplesVolume of potentially contaminated materialPotential contaminant(s) of concernSite maps showing the location of each container at the siteRecommended treatment and/or disposal options for each containerIf off-installation treatment and disposal of containerized IDW is required, the investigation teamwould be responsible for sampling containerized IDW, if required, for further characterization ordisposal. The investigation team should provide documentation to the USAGE. Handling and•"••• :":AK Revision 0August 2000"•; - * • • " : " - ' : * ::-;: ;" :-••;f ;' --'•••'•••;- •••• • • :'•:-:"•• ••••*SOP-35Page 7 of 20managing the off-installation treatment and disposal of IDW after the containers have beencharacterized for off-installation removal would also be required. Additional tasks that would beperformed include, but may not be limited to, preparing manifests, tracking containers, tracking90-day storage limits, arranging the transport of containers, and arranging the ultimate disposalto a RCRA-permitted off-installation treatment, storage, and disposal facility (TSDF).3.1CHARACTERIZATION AND MANAGEMENT OF INVESTIGATION DERIVED SOILSAND DRILLING MUDThe containerization of, and proposed analyses for, investigation-derived soils and/or drillingmud generated during field investigations are described in the following sections. Figure 3-1presents the step by step process that will be followed for characterization of the soils anddrilling mud.3.1.1ContainerizationInvestigation-derived soils and/or drilling mud generated during field activities will becontainerized on-site within individual AOCs. Details for containerization of investigationderived soils and/or drilling mud are presented in Section 2.3 of this document, but in general theIDW soils will be contained in either bins or 55-gallon drums. Possible exceptions to leavingIDW soil and/or drilling mud at the AOC would include areas with a high degree of publicaccess or sites where leaving the IDW on site would result in increased risks to human healthand/or the environment. In such cases, the IDW may be moved to a secured central location.The base environmental coordinator will instruct the field team where to store contained IDW.3.1.2AnalysesAny available information from previous investigations should be reviewed along withbackground samples and analytical results of environmental soil samples collected on site withinthe AOC to determine the potential contaminants of concern and probable characteristics ofcontainerized IDW. If environmental samples are determined to be nonhazardous (see Figure 31), investigation-derived soil and/or drilling mud will be disposed as described for nonhazardoussoils in Section 4.0.If the IDW is characterized as nonhazardous at any level of the characterization process, it willbe disposed as described for nonhazardous soils (Section 4.0). If analyses show contaminantconcentrations of the soil samples collected within the AOC to be above backgroundconcentrations (Table 3-1), results will be compared to Total Threshold Limit Concentrations(TTLC), 10 times the Soluble Threshold Limit Concentration (STLC), and 20 times the ToxicCharacteristic Leaching Procedure (TCLP) regulatory limits. At this point, if soil samples aredetermined to be hazardous (under RCRA or California Code of Regulations [CCR] Title 26),the collection of composite samples from IDW containers for analysis may be necessary.Specific sampling and analysis methods are described in detail in Section 3.7. The samples willbe analyzed by STLC or TCLP procedures to determine if the IDW is hazardous, and to evaluateAK Revision 0August 2000SOP-35Page 8 of 20potential land disposal restrictions (LDRs). If the containerized composite samples are againdetermined to be hazardous, options for disposal need to be considered (Section 4.0).If no environmental samples were taken during the waste generation, composite samples shouldbe collected from IDW containers. The samples will be analyzed by STLC or TCLP procedures.If the containerized composite samples are determined to be hazardous, disposal options need tobe considered (Section 4.0). Additional sampling and testing of IDW may be initiated asappropriate based on the intended method of disposal (Section 4.0) and standards determined byindividual TDU or TSDF locations.3.2CHARACTERIZATIONLIQUID WASTESANDMANAGEMENT OF INVESTIGATION DERIVEDThe containerization of, and proposed analyses for, investigation-derived liquid wastes generatedduring field investigations at the site are described in the following sections. Figure 3-2 presentsthe step by step process that will be followed for characterization of the liquid IDW.3.2.1ContainerizationLiquid wastes generated during field activities may include fluids generated during wellinstallation, well purging and sampling, aquifer testing, and the decontamination of drilling andsampling equipment. These investigation-derived liquid wastes will be containerized and maybe segregated by source or by site, dependent upon the anticipated contamination and volume ofliquids generated. The segregated liquids will remain within the AOC or will be transported to acentral location, pending determination of IDW status with respect to RCRA and other pertinentARARs as well as the disposal methodologies available. Details for containerization ofinvestigation-derived liquid wastes are presented in Section 2.3 of this document, but in general,liquid waste will be contained in either Baker Tanks or 55-gallon drums. Possible exceptions toleaving IDW liquid wastes at the AOC will include public access considerations or if leaving theIDW on site will create increased risks to human health and/or the environment. In such cases,the IDW may be moved to a secured central location. The base environmental coordinator willinstruct field team members where to store contained IDW.3.2.2AnalysesInformation from previous studies, background data, and analytical results of environmentalsamples collected at each site will be reviewed to determine contaminants of concern and thecharacteristics of the containerized IDW (Figure 3-2). If aqueous samples are determined to benonhazardous (analytical concentrations are below the 95% Upper Tolerance Level forbackground samples), the liquid wastes will be disposed as described for nonhazardous liquids inSection 4.0.If contaminant concentrations in the aqueous samples collected within a given AOC are abovebackground concentrations, results will then be compared to STLC and TCLP regulatory limits.At this point, if the samples are determined to be hazardous (under RCRA and/or CCR Title 22),•: • • • ::::'-: —-:^-.------^ —L......UAK Revision 0August 2000' ^—,._.,,,:.....,,~^_^'uv.. ..':-•— u r . : , ^ ^-^ ., —- ........-... :...: ^^,. ..r—,.-::n--T:_.... . ---—-I--..-—-..__._.:..:.....-..-.—_•-—>SOP-35Page 9 of 20the containerized IDW liquid should be sampled according to the procedures described inSection 3.7, and the analytical results should be compared to the STLC and TCLP regulatorylimits. If analytical results of the containerized IDW liquid determine the liquid to benonhazardous (Figure 3-2), the liquid will be disposed of as nonhazardous liquid IDW.However, if samples of the containerized waste are determined to be hazardous, the options fordisposal may be considered as discussed in Section 4.0.If no environmental samples were taken during waste generation, composite samples should becollected from EDW containers. The sample results should be compared to the STLC and TCLPregulatory limits to determine if the waste should be disposed as hazardous or nonhazardousliquid IDW.If the activities that generated the liquid wastes were associated with one of the OUs with atreatment system that is able to handle the types and concentrations of compounds detected, theliquid waste may be discharged to the system for treatment and eventual discharge to thegroundwater recharge basin. If the treatment system is unable to handle the IDW, or if an oninstallation treatment system is not available, required sampling and testing of IDW should beinitiated as appropriate for the intended method of disposal and standards determined byindividual off-installation TDU, TSDF, or POTW locations.3.3CHARACTERIZATION ANDDISPOSABLE EQUIPMENTMANAGEMENTOFDISPOSABLEPPE ANDThe following sections present various options that are available for the management ofinvestigation-derived disposable PPE and disposable equipment. These options are intended tobe considered following a review of all available information concerning the environmentalsamples collected within the AOC where the PPE and/or disposable equipment was generated.3.3.1Decontaminated EquipmentIf disposable PPE and disposable equipment are decontaminated following use and are thereforedesignated as nonhazardous waste, the IDW will be placed in plastic bags and disposed of in anon-installation industrial dumpster. A second option is to remove the IDW to an off-installationSubtitle D landfill. Further details for disposal options of decontaminated disposable PPE anddisposable equipment are presented in Section 4.0.3.3.2Potentially Contaminated EquipmentIf disposable PPE and disposable equipment are not decontaminated following use, they mayrepresent potentially hazardous waste. Disposable PPE and disposable equipment will becontainerized and segregated by individual site (e.g., by boring or site number) and stored withinthe AOC, pending determination of RCRA status and disposal. Possible exceptions to leavingthe row at the AOC include public access considerations or the potential for increased risks tohuman health and the environment.AK Revision 0August 2000SOP-35Page Iff of 20Following a review of pertinent information concerning the site of generation, includinganalytical results and regulatory provisions, the disposal options for the PPE and disposableequipment will be assessed. If the results of environmental samples collected during fieldsampling activities are determined to be nonhazardous, the disposable PPE and disposableequipment will be disposed as nonhazardous IDW. Further details for disposal options ofnonhazardous disposable PPE and disposable equipment are presented in Section 4.0.If the results of environmental samples from the AOC are determined to be hazardous, thecontainers will be disposed of as hazardous IDW. Disposal options for hazardous IDW arepresented in Section 4.0.3.4CONTAINER LABELING AND RECORD KEEPINGContainer labeling and record-keeping requirements include: (1) proper labeling of containers aswaste pending receipt of analytical test results (proper labeling includes information such assource site number, boring or well number, and permissible storage period); and (2) date(s) ofwaste generation and type of IDW stored in the container. Drum labels will be placed on theside of the drum, not on the lid, to reduce breakdown of the label by environmental conditionsand to prevent the possibility of interchanging labels if lids are reused. Plastic bags used tocontain disposable PPE and disposable equipment will be identified with a drum label wrappedaround a piece of wire to produce a wire tag that will be used to seal the bag. An example of acontainer label to be used for identifying containerized IDW is shown on Figure 3-3.IDW containers should be tracked using a form similar to that shown on Figure 3-4. The formshould be completed once each container is filled. Information recorded should include sitename, location identification, storage location, contents, source, dates of operation, and capacityof container. The quantity (volume) of material in each container should be measured andrecorded on the IDW container data sheet prior to sealing the container.In addition to complying with the above requirements, as appropriate, the contractor will notifythe engineer-in-charge (EIC) and provide the USAGE with an inventory of wastes generated,including source, media, storage location, analytical results, and final treatment or disposal.Storage locations for containerized wastes will be designated by the base environmentalcoordinator. Hazardous waste manifests and material safety data sheets will be completed byMontgomery Watson or the generator as appropriate. All manifests will be signed by thegenerator (Installation).Entries will be made by the EIC in a field log book during the waste management activities. Thequantities of wastes generated at each site, visual observations of the wastes, odor characteristics,and HNu readings should be included in the field log book.3.5STORAGE TIME LIMITSSeveral storage and disposal requirements are subject to time limits that begin when the IDW isgenerated. These include: (1) removal of waste from the site (unless wastes will be stored on siteAK Revision 0August 2000SOP-35Page 11 of 20within the AOC); (2) notification of the USAGE by the contractor following initialcharacterization of the IDW; and (3) final treatment or disposal of the K>W.Within 60 days of waste generation, the investigation team should provide a memorandum to theUSAGE documenting the initial characterization of the IDW. Sixty days is required to receiveanalytical results from the laboratory, review the data, interpret the data, and prepare thememorandum. The memorandum will assist the USAGE in RI/FS planning and compliance withenvironmental regulations. Documentation should contain information on quantity of waste,type (soil, water, etc.), site, source (borehole, monitoring well, etc.), contaminants detected, andconcentrations. This information will be used to make an initial classification of waste(potentially hazardous, designated, or nonhazardous). The memorandum should includeproposed actions to be taken concerning additional sampling and disposal.As discussed in Section 3.6, if IDW is characterized to be potentially hazardous, additionalsampling of IDW containers will be required to determine if the IDW is hazardous. If thematerial is defined as RCRA hazardous waste, RCRA regulations (40 CFR 262.34) requires thewaste to be transported off site in 90 days. In addition, RCRA regulations (40 CFR 262.34)require that, unless IDW will be stored within the AOC, IDW will be transported to thedesignated storage area within 3 days. If additional sampling is performed, it is likely that the90-day limit on RCRA waste will be exceeded. CERCLA-derived wastes may be stored at anarea longer than 90 days as long as the storage area complies with RCRA substantive storagerequirements (the administrative process for obtaining a permit is not required). The intent of thewaste management program will be to dispose of IDW as soon as is practicable. Factors thatmay influence the length of time of storage include laboratory turnaround time, duration ofinvestigations at the site, storage area volume limitations, time requirements to arrange for offsite disposal, and the degree of risk that the IDW poses to human health and the environment. IfIDW is generated that is deemed by the USAGE, regulatory agencies, or the contractor to presenta high degree of risk by storing the IDW, arrangements will be made for immediate transfer ordisposal.3.6IDW CONTAINER SAMPLING AND ANALYSIS METHODSAnalytical samples collected during field activities will be analyzed and the results compared tobackground and regulatory limits before IDW container sampling occurs. Data collection effortscompleted during the field investigation should be sufficient for determining whether IDW ispotentially hazardous. The basic objective of IDW sampling is to produce a set of samplesrepresentative of the contained IDW media under investigation and suitable for subsequentanalysis, if required. Containerized soil and liquid wastes can be returned to the source at anytime during the investigation, contingent upon compliance with ARARs. ARARs are discussedin Section 5.0. PPE and disposable equipment found to be potentially hazardous will bedisposed as hazardous materials. The methods, techniques, and analyses used for testinghazardous field-generated wastes that will be disposed of off-installation to a RCRA-permittedfacility or Class I disposal facility are presented in the following sections.The sampling technique chosen for sampling activities will, in part, be dependent upon thephysical state of the IDW media to be sampled. The physical state of the IDW will affect most•••••••••••'•• •-•••• - -•-•--—••; ••• •• -•• •••AK Revision 0August 2000SOP-35Page 12 of 20aspects of the sampling effort. The sampling technique will vary according to whether thesample is liquid, solid, or multiphasic. The generation of decontamination fluids through IDWsampling should be minimized and should be a factor considered in the final choice of samplingtechnique. The decontamination fluids will be minimized through selection of appropriatetechnique to sample the media in question and ease of cleaning. Care should be exercised toavoid the use of sampling devices plated with chrome or other materials that might contaminatethe sample.If IDW is characterized to be potentially hazardous after review of analytical data generatedduring field activities, IDW container sampling will be conducted. Testing is required prior toon- or off-installation treatment, storage, or disposal of contaminated material. However, IDWcontainer testing is not required if the IDW is determined to be nonhazardous. Criteria fortesting protocol are presented in Sections 3.1 through 3.3. The description of samplingtechniques for containerized media is divided into two sections, which address soil and drillingmud, and containerized liquids.3.6.1Containerized Soil and Drilling Mud SamplingAvailable options for sampling devices suitable for soil and drilling mud sampling includescoops, thin-walled tube samplers, hand augers, core samplers, and sampling triers. Thepresence of rocks, debris, or other sampling-specific considerations will dictate the most suitablesampling method. The sampling technique will also vary according to whether the solid is hardor soft, powdery or clay-like (USEPA, 1986).If the soil or drilling mud is stored in bins, one composite sample should be collected from eachbin. If the IDW is stored in drums, one composite sample should be collected from the cuttingsfrom each boring or from each site.3.6.2Containerized Liquid Waste SamplingBeakers, glass tubes, extended bottle samplers, and Composite Liquid Waste Samplers(COLIWASA) are devices that may potentially be used to sample containerized liquid media.Site-specific conditions may necessitate a variety of sampling options. Site-specific conditionswill include the homogeneity or heterogeneity of the liquid to be sampled and stratification andthe physical nature of the liquid such as viscosity. Sampling techniques will be chosen based onproperties of the liquid medium and ease of decontamination of sampling equipment. Surfacewater samples from drums can also be readily collected by merely submerging a sample bottle.If the liquid waste is stored in Baker Tanks, one composite sample should be collected from eachBaker Tank. If the liquid waste is stored in drums, one composite sample should be collectedfrom the drums for each sampling event.AK Revision 0August 2000SOP-35Page 13 of 204.0DISPOSAL OPTIONS FOR IDWDisposal alternatives for IDW include: (1) on-installation land disposal, (2) off-installation landdisposal, (3) on-installation treatment, (4) off-installation treatment, and (5) on-installationstorage and disposal within the AOC. Choosing one of these alternatives is dependent upon thetype of IDW; concentrations of contaminants as determined by sampling and analysis (seeSection 3.7); and federal, state, or local regulations and ARARs (discussed in Section 5.0). Thedisposal option should be determined prior to site investigation activities to assess the siteinvestigation costs and minimize on-site waste storage. Specific IDW disposal options arepresented in the following sections and are shown in Table 4-1 and on Figures 4-1 through 4-3.Ultimately, the PPE and disposable equipment will be transported to dumpsters for disposal ateither a sanitary landfill, a TDU, or a RCRA-permitted TSDF as discussed in this section.4.1ON-INSTALLATION LAND DISPOSAL FOR NONHAZARDOUS WASTESA significant amount of the solid waste generated during any field program will be considerednonhazardous. There are no RCRA ARARs concerning the disposal of nonhazardous solidwastes; therefore, nonhazardous solid wastes (as determined by environmental samples) may bedisposed at an appropriate location on base. PPE and disposable equipment will be stored indumpsters but will not be disposed on the base.A significant fraction of solid waste generated during field investigations will be investigationderived soil and drilling mud. Disposal options for soils found to be nonhazardous may includespreading around the source areas (such as spreading around borings), or transporting to adesignated area on base. Soil disposal around the boring or source area within the AOC may notbe feasible due to public access considerations, the location of the AOC (such as borings in oradjacent to roads or other developed areas), or more stringent, non-RCRA ARARs. If it is notfeasible to spread the soil around the source area, the soil must be sent to a designated locationon the site selected by the USAGE, or sent to a suitable Subtitle D landfill or an off-installationTDU or TSDF.Investigation-derived liquids that are determined to be nonhazardous would have the same oninstallation disposal options as soils. However, disposal of liquids by pouring them around thesource area may not be prudent due to the potential to mobilize contaminants by infiltration ofwater or due to public access considerations. Nonhazardous liquid wastes may also be disposedby surface discharge to a groundwater recharge basin. If it is determined that the environmentalsamples are nonhazardous but treatment and disposal is controlled by more stringent, non-RCRAARARs, alternate methods of disposal would be required.Nonhazardous trash and decontaminated PPE and disposable equipment generated during fieldactivities can be disposed in an on-installation industrial dumpster for disposal aftercharacterization.AK Revision 0August 2000SOP-35Page 14 of 20On-site disposal can significantly decrease the volumes of wastes that must be transported and/ortreated, thus decreasing costs of the field program. Any on-base disposal should be coordinatedwith the appropriate base agencies.4.2OFF-INSTALLATION LAND DISPOSALOne potential alternative for IDW disposal is at an off-installation TDU or TSDF municipallandfill. The waste that is disposed at off-installation facilities may include soil, drilling mud,liquid wastes, PPE, or disposable equipment. Once waste is characterized, as discussed inSection 3.6, the appropriate "Class" of disposal unit (as defined in Title 26 of the CCR) must beselected. Class I facilities may accept hazardous, designated, and nonhazardous wastes; Class IIfacilities may accept designated wastes; and Class in facilities accept nonhazardous solid wastes.Selection of a particular disposal unit (hazardous or nonhazardous) is dependent on the wastetype, contaminant concentration, facility acceptance criteria, geographic location, and cost.The disposal facility should be selected prior to the instigation of the site activities. The disposalfacility must be contacted prior to arriving at the TSD facility with waste to ensure acceptance ofthe waste by the landfill operator and to check that the facility's requirements have not changed.The contractor should obtain verification that the disposal facility is in compliance with alloperational permits prior to receiving wastes from the site. Additional sampling and testing ofthe IDW required by the disposal facility should be initiated prior to disposal. The generatormust either obtain an EPA identification number and manifest form for IDW, or prepare a bill oflading for RCRA nonhazardous IDW prior to transporting.4.3ON-INSTALLATION TREATMENTOn-installation treatment will be considered, as appropriate, to minimize the volume of liquidand solid waste to be sent to off-installation facilities and to reduce costs. Liquid wastesincluding surface water, groundwater, and decontamination fluids may be transported to an oninstallation groundwater treatment system for treatment as appropriate. The treated liquidswould then be discharged along with treated groundwater from the treatment system. Currently,treated water from the treatment system is discharged into the arroyo. Future dischargealternatives may include discharge to the former sewage treatment plant percolation ponds orreinjection to groundwater. Care must be taken that contaminated liquids sent to the existingtreatment system do not contain contaminants that the system is not capable of removing or thatwill disrupt the operation of the system. On-installation treatment of contaminated solid wouldentail establishing centralized treatment units in compliance with applicable regulatoryrequirements.4.4OFF-INSTALLATION TREATMENTTreatment of IDW (including soil, liquid wastes, PPE, and disposable equipment) may berequired for hazardous waste that does not meet the requirements for land disposal facilities.Landfills may specify treatment to certain levels prior to acceptance of wastes. In some cases,off-installation treatment may be more cost-effective than off-installation land disposal or oninstallation treatment.AK Revision 0August 2000SOP-35Page 15 of 204.5DISPOSAL OF HAZARDOUS WASTES WITHIN THE AOCIn some cases, IDW may be left on site within the AOC even if waste is considered hazardous.The decision to implement this option depends on the waste characteristics, media type, anddegree of threat posed by the waste to human health and the environment. If IDW consists ofhazardous soils that pose no immediate threat to human health and the environment, it may beleft on site within the delineated AOC unit if approved by the site RPMs. Generally, the returnof soil cuttings and/or drilling mud to the location from which they were taken will comply withARARs based on the implication that the site will be further evaluated and treated duringsubsequent activities at the site. If this option is selected, the following actions must be taken:•Delineate the AOC using markers such as flagging or fencing.•Determine locations close to the soil source, such as a boring or test pit, in the AOC for wasteburial or spreading.•Place the hazardous IDW soil in pits and cover the pits with surficial soil to preventdispersion.Following waste disposal at the site, the containers used to contain the soil will bedecontaminated and reconditioned for further use. IDW should not be disposed within the AOCif the following conditions apply:•IDW is hazardous water or other aqueous liquid.•IDW is hazardous soil that may pose a substantial risk to human health and the environmentif left on site.•IDW is PPE or disposable equipment.5.0COMPLIANCE WITH ARARSThe NCP requires that handling of IDW meet all ARARs to the extent practicable consideringthe urgency of the situation. Applicable requirements are standards or criteria promulgatedunder federal or state law that specifically address a hazardous substance, pollutant containment,remedial action, location, or other circumstance at a project site (USEPA, 1988a). Relevant andappropriate requirements are standards or criteria promulgated under federal or state laws thatare suited to a particular site because they address site scenarios sufficiently similar to those onwhich the regulations are based. Identification of ARARs first dictates the determination ofwhether a given requirement is applicable; then, if it is not applicable, a determination ofwhether it is both relevant and appropriate. This evaluation compares a number of site-specificfactors with those addressed in the statutory or regulatory requirements. Factors consideredinclude the hazardous substance present at the site, physical site features, or the type of remedialaction.A given requirement might be relevant, but not appropriate, for the project site; therefore, such arequirement would not be an ARAR for the site. When a requirement is deemed both relevantAK Revision 0August 2000SOP-35Page 16 of 20and appropriate in a given case, this requirement must be complied with to the same degree as ifit were applicable.To-be-considered (TBC) criteria are nonpromulgated advisories or guidance issued by federal orstate government that are not legally binding and do not have the status of potential ARARs. Inmany circumstances, TBC criteria will be reviewed along with ARARs in determining an IDWlevel that is sufficiently protective of human health and the environment.There are several different types of ARARs, including chemical-specific, action-specific, andlocation-specific ARARs. Chemical-specific ARARs are usually health- or risk-based numericalvalues or methodologies applied to site-specific conditions. These values establish theacceptance concentration of a chemical substance that may be found in or discharged to theambient environment. Action-specific ARARs are technology- or activity-based requirements orlimitations on actions taken with respect to hazardous substances. Location-specific ARARs arerestrictions placed on the concentration of hazardous substances or the conduct of activitiessolely because they occur in special locations.Environmental laws and regulations that are potential ARARs for IDW at CERCLA sites includeRCRA, including LDRs, the Toxic Substances Control Act (TSCA), the Clean Water Act(CWA), the Safe Drinking Water Act (SOWA), and existing state ARARs.5.1RESOURCE CONSERVATION AND RECOVERY ACTRCRA was passed by Congress in 1976 to meet three goals: (1) The protection of human healthand the environment; (2) the reduction of waste and the conservation of energy and naturalresources; and (3) the reduction or elimination of the generation of hazardous waste asexpeditiously as possible. The Hazardous and Solid Waste Amendments (HSWA) of 1984significantly expanded the scope of RCRA by adding new corrective action requirements, landdisposal restrictions, and technical requirements (USEPA, 1988b).RCRA is the most important federal ARAR for IDW generation and management, because itspecifically regulates all aspects of transportation, treatment, storage, and disposal of hazardouswastes. The determination of whether a waste is or is not hazardous may be made on the basis ofknowledge of the IDW and associated suspected or known contamination, rather than by directtesting (USEPA, 1991). RCRA has ten discrete sections (subtitles) that address specific wastemanagement activities. Two of these subtitles and their implementing regulations may beARARs for IDW handling: Subtitle C (Hazardous Waste Management) and Subtitle D (SolidWaste Management).Under RCRA Subtitle C, wastes are defined as hazardous on the basis of their source or methodof generation ("listed" wastes) or their chemical constituents or characteristics ("characteristic"wastes). For example, xylene is a listed waste, and based on the "contained-in-interpretation"(USEPA, 1986) soil or groundwater contaminated with this waste would also be consideredhazardous. Characteristic hazardous wastes include those wastes that have (1) extremely high orlow pH, (2) high reactivity, (3) ignitability, or (4) toxicity as measured by a leaching proceduresuch as TCLP, or other criteria, as listed in 40 CFR 261.AK Revision 0August 2000SOP-35Page 17 of 20One of the most significant provisions of RCRA, with respect to the disposal of IDW, is theprovision for LDRs, which are defined by RCRA Section 3004. LDRs limit the types of wastesthat may be disposed to land (such as landfills and surface impoundments). An importantconsideration in evaluating the applicability or relevance and appropriateness of LDRs iswhether land disposal of RCRA-hazardous IDW has occurred. The AOC can be used todetermine whether or not LDRs are applicable; however, the AOC concept applies only tocontaminated soil or sediments from the site. Contaminated PPE, disposable equipment, ordecontamination fluid that may be generated by investigation activities at the site are notincluded in the LDR approach to AOCs. Based on the delineation of an AOC, LDRs do notoccur when hazardous IDW is:••••••Stored in a container within the AOC and then returned to its sourceMoved within the AOC unit, as defined for a specific siteCapped in placeTreated "in situ"Processed within the AOC to improve structural stabilityLeft in place, moved, or stored within a single AOC unitHowever, LDRs do occur when hazardous IDW is:•Composed of wastes from different AOCs which have been consolidated into one AOC•Moved outside of an AOC for treatment and storage and returned to the same or a differentAOC•Excavated from an AOC, removed to a separate unit such as a tank, surface impoundment, orincinerator that is within the AOC, and then redeposited into the AOCLDRs prohibit the storage of hazardous waste beyond specified time limits, unless the purpose ofstorage is to accumulate sufficient quantities of waste to promote proper disposal, treatment, orrecovery. However, storage of IDW until a final disposal option is selected in a record ofdecision (ROD) may be considered allowable storage under the LDR storage prohibition.Conditions under which such storage occurs should comply with substantive regulationspertaining to storage of hazardous waste in containers (such as the provision of secondarycontainment for drums containing liquid wastes). The USEPA does not require thatadministrative requirements such as permits of ARARs be met, as long as substantive issues areaddressed (USEPA, 1988b).All LDRs must be followed to the extent practicable if hazardous IDW cannot be held within thedelineated AOC. For example, if leaving hazardous IDW within the AOC would significantlyincrease risks to human health and the environment through fire, explosion, or toxicity, or otherhazard, the IDW should be disposed of at an off-installation RCRA Subtitle C TSDF.Hazardous decontamination fluids, PPE, and disposable equipment will be containerized andultimately disposed off installation, unless a properly permitted TSDF is available on theinstallation for such disposal. IDW storage practices are described in Section 2.3, IDWAK Revision 0August 2000SOP-35Page 18 of 20management options are discussed in Section 3.0, and disposal options are discussed in Section4.0. Once hazardous wastes are taken outside the AOC, such wastes are subject to both thesubstantive and administrative requirements of RCRA.Nonhazardous PPE or disposable equipment will be disposed of in facilities such as municipallandfills (RCRA Subtitle D). Nonhazardous IDW, such as soil cuttings, drilling mud, orsediment will be disposed of within the AOC if all other ARARs are met.5.2TOXIC SUBSTANCES CONTROL ACTThe TSCA was passed by Congress in 1976. This act establishes new requirements andauthorities for identifying and controlling toxic chemical hazards to human health and theenvironment. Regulations associated with this act affect the handling and disposal of wastescontaining polychlorinated biphenyls (PCBs) and asbestos. The potential impacts of theseregulations on IDWs are noted below:•Nonhazardous IDW containing PCBs or asbestos at concentrations greater than specifiedlimits must be disposed of at facilities regulated under the TSCA (see 40 CFR 761.60).Options include incineration or disposal at TSCA chemical waste facilities.•PCB-contaminated material such as IDW, with concentrations less than 50 parts per million(ppm), is not generally regulated under TSCA and may be disposed of in acceptable SubtitleD landfills. However, the PCB action level for the State of California is 5 ppm.5.3CLEAN WATER ACTThe CWA of 1977 addresses site-specific pollutant discharge limitations and performancestandards for specific industries to protect surface water quality. The CWA also regulatescriteria for selecting POTWs and sets Ambient Water Quality Criteria (AWQC). During fieldinvestigations, the most likely situation where the CWA will be applicable involves the indirectdischarge of IDW water, regulated under CWA, to a POTW for treatment and disposal (USEPA,1991). Prior to discharge of IDW waters to POTWs, the contractor will ensure thatPOTW/CWA standards are met.5.4STATE REQUIREMENTSOther states have specific regulations for waste management. These regulations for wastemanagement. These regulations will be addressed in site specific SAPs.California regulations are provided here as an example. California Hazardous WasteRegulations - Title 26 (Toxics) of the CCR may contain ARARs for IDW managementdecisions. Title 26 regulations promulgate TTLCs and STLCs as potential ARARs for thehandling and disposal of IDW. Hazardous wastes (characteristic or listed) defined in Title 26would be treated in the same manner as RCRA hazardous wastes.AK Revision 0August 2000SOP-35Page 19 of 20The State Water Resources Control Board regulates and promulgates applicable water qualityobjectives that are potential ARARs for IDW soil and water handling. ARAR waivers may beavailable for state requirements specifically aimed at CERCLA sites or for state ARARs that areinconsistently applied (CERCLA section 121[d][4][E] and 40 CFR 300.430[f][l][ii][C][5]).Nonhazardous IDW which contain trace levels of contaminants will not be disposed of on site ina manner which may impact groundwater quality. Disposal of California restricted,nonhazardous wastes will be performed in accordance with Title 26.6.0REFERENCESU.S. Environmental Protection Agency (USEPA), 1984. Waste Analysis Plans. Prepared by theOffice of Solid Waste, October 1984.USEPA, 1986. Test Methods for Evaluating Solid Waste, Third Edition SW-846. Prepared bythe Office of Solid Waste and Emergency Response, November 1986.USEPA, 1988a. Guidance for Conducting Remedial Investigations and Feasibility StudiesUnder CERCLA, Interim Final. Prepared by the Office of Emergency and RemedialResponse, October 1988.USEPA, 1988b. CERCLA Compliance with Other Laws Manual. Draft Guidance. Prepared bythe Office of Emergency and Remedial Response, August 1988.USEPA, 1990. CERCLA Compliance with the RCRA Toxicitv Characteristics (TO Rule: PartII. Prepared by the Office of Solid Waste and Emergency Response, October 1990.USEPA, 1991. Management of Investigation-Derived Wastes During Site Inspections. Preparedby the Office of Emergency and Remedial Response, Publication 9345.3-02FS, May1991.AK Revision 0August 2000SOP-35Page 20 of 20APPENDIX CField FormsMWHMONTGOMERY WATSON HARZATAILGATE SAFETYMEETING FORMMWHMONTGOMERY WATSON HARZADate:Client:Time:Project Number:1850805.010102Job Number:United States Army Engineer District - Alaska Site-Specific Location:Gambell, AlaskaSafety Topics PresentedProtective Clothing/Equipment:Chemical Hazards:Physical Hazards:Special Equipment:Other:Emergency Procedure:Hospital:Norton Sound Regional Hospital, NomeProvidence Hospital, AnchorageHospital AddressAnd Route'Phone:(907) 443-3311 (or 3353)(907)562-2221Air service from Gambell to hospital for serious injuries- Lifeguard Alaska 800-478-5433911/MedevacATTENDEESNAME PRINTEDSIGNATUREMeeting Conducted By:Project SafetyOfficer:Name PrintedBonnie McLeanProject Manager:SignatureGary BussefflS) MWH^IfrMONTGOIUtinYWATSONPERSONAL ACKNOWLEDGEMENT FORMHARZ 1Project: Gambell 2001 Supplemental RIProjectJ Number:1 850805. 010102Client: USAEDProject Manager: Gary BusseAs a component of the Safety and Health Plan (HASP) designed to provide personnel safety during thisRI, you are required to read and understand the HASP. When you have fulfilled this requirement, pleasesign and date this personal acknowledgement.NAME (PRINTED)SIGNATUREDATEUSACOEACCIDENT REPORTINGImportant Things to Remember• All incidents are reportable (mishap that caused or could havecaused injury or damage)• Incidents classified as accidents are recordable (incidents thatresult in medical treatment, lost time, or >$2K damage)• Ensure casualty treated• IMMEDIATELY notify SAAO. If AE/DAE/RE/OE is not availablethen you will contact Chief, CONORS (753-2768)• After notification IMMEDIATELY prepare and submit 265-R toSAAO Safety Officer (all incidents) within 24 hours. If SafetyOfficer is not available then FAX the former to District SafetyOffice on Fort Richardson (753-2591)• Prepare and submit ENG FORM 3394 to SAAO within 48 hours(only if incident = accident)• Use as much detail as possible when describing incident• Submit ORIGINAL copy of ENG FORM 3394 to SAAO SafetyOfficer• If you are not sure, ask the Safety OfficerCEPOO-SOPOD AMDIMMEDIATE REPORT OFACCIDENTTO:SQHP USE OKI.YDate Reed'Tinc Rccd,FROM:DATE:(COE OFFICE)l.Name of Person Reporting:Phone No.:_(Print)2.Location of Accident:.'-3.Date and Time of Accident:•If this accident is being reported late, (24*-hrs) Why?4.Name of Injured (If any) :5.Nature of Injury:6.Occupation (Injured Person):7.Age (Injured Person):8.Estimated Lost Time (Days):Was, return to light duty emphasized to the doctor?9.Estimated Property Damage:lO.Contrator & Contract No.:".Board of Investigation Required?Yes1.Fatal?No ________ 2. Three or more admitted to a hospital?3. Property damage of $200,000 or more?If yes, was immediate phone notifications to the Commander, Directorate and safety made?12.Description of Accident: (continue on back if needed) Provide a narrative (Where, what,why. How it Happened) so the Commander can get a understanding of the situtation.Who Investigated This Accident (Name) :Signature of Person Making Report:Title of Person Making Report:Location of Person Making Report:POD Form 265-R (REV)1 Jun 98Print Name:Phone No. to Reach:EDITION OF 1 MAR 95 IS OBSOLETEftrREPORTHO.T|f«"UNITED STATES ARMY CORPS OF ENGINEERS"ACCIDENT INVESTIGATION REPORTHJURY/ttiNESS/MTALPERSONAL CLASSIFICATIONCONTROL SYMBOLCEEC-S-MR2)MOTOR VEHICLE NVQLVED«OP0m DAMAGE[DIVMGGOVERNMENT"3 CIVILIAND MILITARYQ CONTRACTORD PUBLICn FATALOTHB1nD SVOI.VED^DD JfmvEDD «™D OTHERDaDD^7X17ZI— ----••""^"^"•"•-----l-—.2k-AGEi. Him tat Ait MPQ MALE[]]FEMALEg. DUTY STATUS AT TIME OF ACCIDENTf. JOB SERIESmTLE[|]ON DUTYQ3.i. DATE OF ACCIDENTImmtMnty"'!•.GRADEi. SOCIAL SECURITY NUMBERc-SEX[]] TOYOFF DUTYfe^^^^^W^^KBWPJB5l|^^^^^^^^^^-^*^Si::^^^TO^^:^tSS^>?SGEHERAL IHFORMATIOKc. EXACT LOCATION OF ACCIDENTk. TIME OF ACCIDENTMttrytaatlt. CONTRACTOR'S NAME11) PIRIME:hrsnDCIVIL WORKSDOTHER lUpKifrJg. HAZARDOUSrTOXIC WASTEACTOITYf. TYPE OF CONTRACT•.CONTRACT NUMBERDMIUTARYCONSTRUCTIONQ SERVICEDAJEDDREDGEQOTHER Sfmafrl_ ._ .._,COHSTRUCTIOII ACTIVITIES DULY /»/» Si»iHlc4.i. CONSTRUCTION ACTIVITY|CODE)QSUPERFUNDQ»PQI2*5UBCONTRACTOR:Q DERPOTHER GpKfYlma»*lH>tc«l,mm*ritto*ir,mfn-Br*toiimQSIDESWIPEQHE AD OND~"UBROADSIDEQROLLOVERQ]REAR ENDICODE)1DUSEDNwNOT USEDNOT AVAILABLE(11 FRONT SEAT0 REAR SEATOTHER ffA»WPROPERTY/MATERIAL HVOLVED8.a. NAME OF ITEMB. OWNERSHIPC.*AM DUNT OF DAMAGE(1)001VESSEL/FLOATMG PLANT ACCIDENT IFim tin tad amteanhxt tub nomttrin tar fnmitt-sn Mo mailICODE)k. TYPE OF COLLISION/MISHAP9.l. TYPE OF VESSEIffLOATHG PLANTIfICODE)1*1ACCIDENT DESCRIPTION Ha uHHiual MB*. HttnainlSee attached page.ENG FORM 3394, MAR 93Version 2EDITION OF SEP 88 B OBSftFIEttSOl11.CAUSAL FACTONS) f***ttnctimWn tn+ti+>CHEMCALAND PHYSICAL AGENT FACTORS: HopunH1|~~1DESIGN: Hu do** •HraKr.wwfcitoaM•uionwil • fictor^1''1'—OFFCE FACTORS: DM itfa »rtM •dlM.ittimtfci^iletartj'1'j~~1'—SUPPORT FACTORS: Wnm^nprittttMUniNreMOPERATMG PROCEDURES: Wm fMittBi pnadrai litlir?\'1I -I1 "—JPERSONAL PROTECTIVE EQUIPMENT: Did tWmpraMriMctiM.m tc •«•!»•••» it ftnfttl fnttemt n»i»iiiilJOB PRACTICES: W«»Miyj»b«.fif»ftMltli»r«elie«.«itf»lo»rt,'•