QAM-R 31(

*File: 180D.B.

UNITED STATES AIR FORCE, EIELSON AIR FORCE BASE

DRAFT FINAL REMEDIAL ACTION WORKPLANOU1B SOURCE AREAS ST-20 (E-9), ST-49, SS-50-SS-52

NAPL RECOVERY PROJECT INTERIM REMEDIAL ACTIONEIELSON AIR FORCE BASE, ALASKA

JUNE 1993

11206.1 L1A001

DRAFT FINAL REMEDIAL ACTION WORKPLANOULB SOURCE AREAS ST-20 (E-9), ST-49, SS-50--SS-52

NAPL RECOVERY PROJECT INTERIM REMEDIAL ACTIONELELSON AIR FORCE BASE, ALASKA

Prepared for

Eielson Air Force Basethrough

Armstrong LaboratoryBrooks Air Force Base

San Antonio, Texas

Prepared by

EA Engineering, Science, and Technology3468 Mt. Diablo Boulevard, Suite B-100

Lafayette, California 94549(510) 283-7077

June 1993

CONTENTS

Page

LIST OF FIGURES

LIST OF TABLES

1. INTRODUCTION..................................................i1

2. FIELD SAMPLING PLAN............................................ 2

2.1 INTRODUCTION.............................................. 22.2 MOB ILIZATION AND SETUP....................................2

2.2.1 Field Operations Center..................................... 22.2.2 Equipment Storage, Maintenance, and Calibration................... 22.2.3 Utility Location........................................... 2

2.3 ENVIRONMENTAL SAMPLING.................................. 2

2.3.1 Sample Location and Sample Site Designation..................... 22.3.2 Soil Vapor Sample Protocols.................................. 30 ~~~~~2.3.3 Soil Sampling Protocol...................................... 52.3.4 Soil Analytical Methods..................................... 5

3. QUALITY ASSURANCE PROJECT PLAN............................... 6

3.1 INTRODUCTION.............................................. 63.2 PROJECT DESCRIPTION........................................ 63.3 PROJECT ORGANIZATION...................................... 63.4 QUALITY ASSURANCE OBJECTIVES.............................. 6

3.4.1 Data Quality Objectives..................................... 63.4.2 Quality Assurance Objectives for Measurements.................... 7

3.5 SAMPLING PROCEDURES...................................... 83.6 SAMPLE CUSTODY AND DOCUMENT CONTROL PROCEDURES ........ 83.7 CALIBRATION PROCEDURES AND FREQUENCY....................83.8 ANALYTICAL PROCEDURES.................................... 83.9 DATA REDUCTION, VALIDATION, AND REPORTING ................. 93.10 INTERNAL QUALITY CONTROL................................. 93.11 PERFORMANCE AND SYSTEMS AUDITS S.......................... 93.12 PREVENTIVE MAINTENANCE................................... 93.13 DATA ASSESSMENT PROCEDURES............................... 90 ~ ~~3.14 CORRECTIVE ACTION......................................... 93.15 QUALITY ASSURANCE REPORTS TO MANAGEMENT ................. 9

CONTENTS (Continued)

Page

4. HEALTH AND SAFETY PLAN SUMMARY..............................10

4.1 SITE INFORMATION.......................................... 104.2 DESCRIPTION OF OPERATIONS.................................11t4.3 HAZARD EVALUATION ........................................ 114.4 SAFETY MEASURES AND PERSONAL PROTECTIVE

EQUIPMENT (PPE)........................................... 154.5 EXPOSURE LIMITS AND WARNINGS............................. 184.6 ENVIRONMENTAL HAZARD MONITORING........................ 19

5. PROJECT SCHEDULE INCLUDING CONSTRUCTION SCHEDULE ............ 21

6. REMEDIAL IMPLEMENTATION QUALITY ASSURANCE/QUALITY CONTROL PLAN......................................... 22

7. MONITORING, OPERATION, AND MAINTENANCE PLAN.................23

7.1 NAPL RECOVERY SYSTEMS STARTUP............................237.2 SOIL REMEDIATION SYSThMS STARTUP..........................237.3 SYSTEM MONITORING AND OPERATIONS........................ 247.4 SYSTEM PERIODIC MAINTENANCE .............................. 257.5 DEMONSTRATING SITE CONDITIONS THAT SATISFY

ACHIEVEMENT OF THE TARGET REMEDIAL GOAL ................. 257.6 SHUTDOWN AND DECOMMISSIONING OF SYSTEMS................ 257.7 MANAGEMENT OF RESIDUALS................................. 257.8 DOCUMENTATION AND REPORTING.............................25

REFERENCES....................................................... 27

FIGURES

TABLES

APPENDIX A: Protocol for In Situ Respiration Tests for Bioventing Projects

LIST OF HIGURES

Number Title

1 Location map of Eielson Air Force Base and OULIB source areas.

2 ST-20 (E-9) site plan.

3 ST-49 site plan.

4 ST-50 (SS-50--52) site plan.

5 ST-48 site plan.

6 ST-20 (E-9) proposed soil vapor sample locations.

7 ST-49 proposed soil vapor sample locations.

8 ST-20 (E-9) proposed soil sample locations.

9 ST-SO (SS-50-52) proposed probe locations.

10 NAPL recovery project organization chart.

11I NAPL recovery decision tree.

12 NAPL recovery system monitoring checklist.

13 Example field report.

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I. LIST OF TABLES

Number Title

I Chemical contaminants of potential concern.

I11206.11 (5)[RAW693 DFILOTr.0

1. INTRODUCTION

This Remedial Action Workplan provides a comprehensive description of the standards ofpractice for the investigation and remediation work proposed for the non-aqueous-phase liquid(NAPL) Recovery Project Interim Remedial Action (IRA) at three source areas (ST-20 [E-9],ST-49, SS-50--SS-52) in Operable Unit lB (QUIB) at Eielson Air Force Base (EAFB)(Figure 1). NAPL has entered the subsurface at the source areas within OU1B (ST-20 [13-7],ST-20 [E-9], ST-48, ST-49, SS-50-SS-52 [ST-5O]) by leaks from or overspills to the fueldistribution systems at the source areas. The goal of the remediation is to reduce sourceconcentrations to mitigate impacts to the groundwater at the source areas:

* ST-20 (E3-9), Refueling Loop 13-9 Complex; site plan shown in Figure 2

* ST-49, Building 1300; site plan shown in Figure 3

* ST-50, Blair Lakes Facility (including S5-50, Vehicle Maintenance Building;SS-51, the ditch along the underground diesel fuel line; and SS-52, the diesel spillnear the generator building); site plan shown in Figure 4

Work to characterize the extent and mobility of the NAPL will also be conducted at sourcearea ST-48, the power plant fuel leak; the site plan is shown in Figure 5. The work at ST-48will be documented in a separate series of remedial workplans.

* ~~The work standards described here will be followed for field work during the 1993 fieldseason, anticipated to begin in June 1993. The proposed activities are described in the DraftFinal Workplan, EAFB OULB NAPL Recovery Project (EA 1993), completed in June 1993.The work described in the Draft Final Workplan includes definition of the area of NAPL andimplementation of a NAPL recovery system at each of the source areas. The primary methodof NAPL recovery will be pumping or skimming separate-phase NAPL only from thegroundwater via recovery wells and/or interception trenches. Site characterization and NAPLrecovery from wells and/or trenches was implemented in 1992 and is currently beingconducted at all three source areas.

At ST-20 (E3-9), soil remediation will also be conducted, using bioventing.

These work efforts will support the OUI RI/FS which is being conducted by Battelle-PNL.Standards of practice adopted for the EA work will be similar to those to be used by Battellefor the RI/Fs (Battelle-PNL 1992) so that the data will support both programs.

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2. FIELD SAMPLING PLAN

2.1 INTRODUCTION

This Field Sampling Plan (FSP) describes procedures for environmental sampling and otherfield work tasks to be completed for the NAPL recovery project at OUlB source areas asdescribed in the Draft Final Workplan, EAFB OU1B NAPL Recovery Project.

2.2 MOBILIZATION AND SETUP

2.2.1 Field Operations Center

HA will conduct the 1993 field program from the HA Fairbanks office on Van Horn Road atInternational Way. The office is fuilly equipped with communication and documentproduction systems and is attached to a warehousing space suitable for storing equipmentrequired for the project.

HA will also maintain a trailer on base, equipped with copies of the project documents andplans, field supplies and tools, phone and fax equipment, safety equipment, and potable water.

2.2.2 Equipment Storage, Maintenance, and Calibration. ~~All field equipment will be stored and maintained in proper working condition at either theFairbanks office or the site trailer.

2.2.3 Utility Location

HA will coordinate with the appropriate UJSAF personnel to obtain digging permits prior toconducting any subsurface work. Digging permits obtained in advance of the 1992 work haveidentified the utilities in the areas of the proposed work.

2.3 ENVIRONMENTAL SAMPLING

2.3.1 Sample Location and Sample Site Designation

The project plan includes collection and analysis of soil vapor samples and soil samples (asdescribed in the Draft Final Workplan, EAFB GUIB NAPL Recovery Project). Soil vaporsamples will be collected at ST-20 (E-9) and ST-49 to identify locations for additional NAPLprobes. Soil vapor samples will not be collected at SS-50-SS-52 because the soil vaporprobes could not penetrate the gravel pad at the Blair Lakes Facility. Soil samples will becollected at ST-20 (E-9) to obtain a record of the concentrations of petroleum hydrocarbons inthe soil prior to the beginning of remnediation by bioventing.

Soil samples will not be collected at ST-49 or SS-50-SS-52 because no soil remediation is. ~~currently planned at these source areas. Proposed soil vapor sampling sites for ST-20 (E-9)

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* ~~are shown in Figure 6; proposed soil vapor sampling sites for ST-49 are shown in Figure 7.Proposed soil sampling sites for ST-20 (E-9) are shown in Figure 8.

The soil vapor samples will be collected and analyzed to obtain field screening levelinformation that will be used to select locations for wells or probes to be used for NAPLthickness monitoring or NAPL recovery. The number of sample sites may be adjustedaccording to the results of the survey. Additional vapor samples may be added to any of thesurveys to obtain more information as the site conditions warrant. The sample sites shown inFigures 6 and 7 are approximately 50 feet apart. One or more vapor samples will becollected from each sample site at depths between 3 feet below ground surface (bgs) and1 foot above the depth to water.

Soil samples will be collected from selected borings at ST-20 (E-9), as shown in Figure 8.The locations of the soil samples will be selected to be generally representative of the soilconditions within the area to be remediated. It is not necessarily the intent of the sampling todocument "hot spots." Up to three soil samples will be collected from each boring, fromapproximately 3-5 feet bgs, from approximately 5-7 feet bgs (and above the static water atthe time of sampling), and from 6-9 feet bgs (and below the static water at the time ofsampling). The results of analysis of these soil samples will be used as a data qualityobjective Level III (off-site analytical laboratory) record of the petroleum hydrocarbonconcentrations in the soil prior to the beginning of the bioventing remnediation.

. ~~Samples will not be collected from ST-SO (SS-50-SS-52); probes will be installed at theST-5O locations shown in Figure 9.

Each sample site will be assigned a unique number, using the following general format:

(source area number) (station type) (station number)-(sample depth)

The sample designation 49PPI20-8--8.5 would apply to a sample from ST-49, taken from theboring for probe 120 at a depth between 8 and 8.5 feet bgs.

2.3.2 Soil Vapor Sample Protocols

Soil vapor samples will be collected at ST-20 (E-9) (Figure 6) and ST-49 (Figure 7). EA'sprotocol for soil vapor sample collection and analysis is described below.

To collect and analyze a soil vapor sample, a 5/8-inch-diameter hollow steel sampling probewith a slotted tip is driven into the soil to a specified depth and a vacuum pump is attached topurge approximately 5 probe volumes of vapor. Purging vapors ensures that the vapor sampleis not affected by vapors collected higher in the probe and that the sample represents vaporobtained from the soil at that depth. The inside diameter of the probes used to sample soilvapor is 1/4-inch and hence the probes have a capacity of 3.41E-4 ft3/ft . The vacuum pumpused to extract vapors from the probes operates at 1.3 CFM at atmospheric pressure. At a

* ~~rate of 1.3 CFM, 5 probe volumes can be purged from a 20-foot length of probe in

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1.6 seconds. The extraction rate of vapors through the probes is dependent on the vacuumrequired to move vapors through the soils. The probes are purged for 1 to 20 minutesdepending on the vacuum measured during purging and the length of probe used to ensurethat a minimum of 5 probe volumes are purged prior to sampling. A vacuum gauge on thesampling apparatus measures the vacuum between the tip of the probe and the pump. Afterthe appropriate purging period, a valve is closed and the vacuum in the probe decays. Thevacuum reading during the purge and the vacuum release time are recorded on a field datasheet.

In general, the soil's relative permeability to gas is indicated by the vacuum during purge andthe vacuum release time. A short vacuum release time suggests that soil gases flow freelythrough the vadose zone; a long vacuum release time indicates a high resistance to soil gastransport. In most situations, vacuum release is rapid (within three minutes), and the sampleis considered to be representative of the soil vapor at the sampled depth.

Samples are collected through a septum with a microliter syringe and injected into aPhotovac LOS50 gas chromatograph (GC) for analysis. The Photovac 10S50 is a portable,programmable, integrating gas chromatograph with a photoionization detector (PID). The PIDis a nondestructive flow-through detector that uses high-energy ultraviolet radiation as itsionization source. Vapor samples are injected into the gas chromatograph; the constituentsare separated on an analytical column and sensed by the detector. The high-energy radiationionizes compounds, generating an energy increase in the detector which appears as anelectrical signal measured in volts; this is integrated across time by the instrument to give avalue for the peak in volt-seconds (V-sec). Blanks are run to verify that the system is free ofhydrocarbons. Standards are run every 8-12 samples to ensure system reproducibility.

The instrument is calibrated with a multicomponent standard consisting of benzene, toluene,o-xylene, m- and p-xylenes, ethylbenzene, n-pentane, n-hexane, and isooctane. Theconcentrations of each of the components is accurate to within 5 percent for each compound.During calibration the integrator calculates and stores the response ratio, V-sec:ppm, for eachof these constituents. Those ratios are used to quantify the concentrations of identifiablevapors in field samples according to their V-sec values.

The concentrations of unidentified compounds in vapor samples are estimated in a similarmanner. The table of survey results includes a column titled "Peaks Prior to Benzene,representing the sum of the responses in V-sec for all peaks eluting before benzene,proportioned to the calibrated V-sec response for pentane. Similarly, a column titled"Unidentified Peaks after Benzene" represents the sum of V-sec responses for unidentifiedcomponents eluting after benzene, proportioned to the average V-sec response of all calibratedcompounds. A column titled "Total Volatile Hydrocarbons" represents the sum of estimatedand measured values (ppm) for all detected components. The accuracy of a result is thereforedependent on the composition of the field sample.

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2.33 Soil Sampling Protocol

Soil samples will be collected from several sites at ST-20 (E-9) (Figure 8). The protocol forsoil sample collection will be as follows.

All samplers will be cleaned by scrubbing in water and detergent and rinsing with deionizedwater before drilling begins and between boreholes.

Soil samples will be collected at designated intervals using either a split-spoon sampler on thedrill rig or a manually-operated drive sampler. The split-spoon sampler will be cleaned byscrubbing in water and detergent and rinsing with deionized water after use at each samplinginterval. The sampler will be driven ahead of the augers or beyond the bottom of the pilotboring into undisturbed soil. When the sampler is retrieved, the split spoon will he brokenopen and the soil quickly loaded into a clean glass sample jar, packed to leave a minimum ofheadspace. The jar will be labeled with the location, sample number, date and time, depth,initials of the sampler, and borehole number. The samples will be placed in zip-lock bagsand stored in a cooler containing ice.

Soil remaining in the sampler will be examined and classified according to the Unified SoilClassification System.

Soil samples will be delivered under chain of custody to EA Laboratories.. ~~2.3.4 Soil Analytical Methods

The soil samples will be analyzed using Alaska Department of Environmental Conservation(ADEC) modified Method 8015 for Gasoline Range Organics and Diesel Range Organics(ADEC 1992) and EPA SW-846 Method 8020 for benzene, toluene, ethylbenzene, andxylenes. The holding times for these methods are 14 days.

11206.11l(5yIRAW693TrX.2 5

3. QUALITY ASSURANCE PROJECT PLAN

3.1 INTRODUCTION

The objective of the NAPL recovery project is to remove NAPL from the groundwater atQUIB source areas at EAFB. The project work will be conducted with close coordinationand sharing of data between EA and the ongoing OUI RI/FS by Battelle-PNL. This QAPPfor the NAPL recovery project is based on the Eielson AFB Sitewide Management PlanQAPP, Revision 2 (SMP QAPP, Revision 2), that covers the RI/FS work for EAFB.

3.2 PROJECT DESCRIPTION

The NAPL recovery project and site background for the QUIB source areas are described inthe Draft Final Workplan, EAFB QUID NAPL Recovery Project.

3.3 PROJECT ORGANIZATION

The management and reporting structure of the project personnel is shown in Figure 10.

EA's project manager has overall responsibility for work performed for the Air Force underthis contract and for the production of project deliverables. The project manager will also beresponsible for managing subcontractors (including EA Laboratories) and for managing

* ~~technical staff involved in data management, field testing, and data analysis.

The senior members of the project staff are EA's Federal Program Manager and SeniorEngineer. They assist the project manager by monitoring the technical execution of taskorders, identifying experts to solve special technical problems, and coordinating reviews ofproject deliverables. They are assisted by technical specialists chosen on the basis of specificwork assignment requirements. They ensure that comprehensive reviews are conductedexpediently and that all review comments are appropriately addressed.

For laboratory work, BA Laboratories, in Baltimore, Maryland, is identified as the primaryanalytical laboratory. BA Laboratories has been accepted by ADEC for participation in the

-State of Alaska UST Program. BA Laboratories will submit a Quality Assurance Manual andother information requested in ADEC's "membership package.'

3.4 QUALITY ASSURANCE OBJECTIVES

3.4.1 Data Quality Objectives

The investigation tasks proposed to determine and monitor the extent of the NAPL arediscussed in the Draft Final Workplan, EAFB OUlB NAPL Recovery Project. Three types offield measurement and sample analysis measurement are planned for this work. The dataquality objectives and the intended use for each of the data types is discussed here.

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NAPL apparent thickness in gauging points (wells and probes) will be measuredwith a NAPL/water interface probe, an electric/optical device manufactured byORS, or an equivalent measuring tool. The interface probe has a detection limit of0.01 feet of NAPL thickness, and is accurate and precise to this level. Thepresence of NAPL may be verified by partially filling a clear bottom-filling bailerwith liquid from the top of the liquid in the well, but this is only possible in wellswhere the casing diameter is 2 inches or larger, and is not possible in 1.25-inchprobes. The presence of NAPL may be verified in the probes by using water-sensitive and fuel sensitive paste on a stick. These measurements will be treated asdata quality objective Level I information (field measurements).

The intended use of the apparent NAPL thickness data is to determine whether ornot NAPL is present in the gauging points. The presence or absence of the NAPLwill determine if the target remedial goal has been achieved. The areal extent ofthe NAPL will define the area to be remediated.

Soil vapor samples will be collected and analyzed using protocol and instruments asdescribed in the FSP for this project. The results of the soil vapor survey will betreated as data quality objective Level I (field screening level) information.

The intended use of the soil vapor data is to choose locations for NAPL monitoringprobes or NAPL recovery wells. The soil vapor data will be used by EA for theNAPL recovery IRA and by Battelle-PNI, to select locations for wells and probesto be used for the RI/FS.

Soil samples will be collected and analyzed using protocol and methods asdescribed in the FSP for this project. The results of the soil analysis will be treatedas data quality objective Level III (laboratory level) information.

The intended use of the soil data is to document concentrations of hydrocarbons insoil samples prior to the startup of the NAPL recovery systems. The soil data mayalso be used by Battelle-PNL for the RIIFS for OUL.

3.4.2 Quality Assurance Objectives for Measurements

The quality assurance objectives for the NAPL thickness measurement results and soil vaporresults will be defined by the measurement methodologies as described in the FSP. For thesoil vapor sample analyses, method blanks and standards are run to ensure that the results arenot in systematic error and the GC is in calibration.

The quality assurance objectives for the soil sample laboratory analyses will be thosespecified for the standardized testing using ADEC modified Method 8015 for Gasoline RangeOrganics and Diesel Range Organics and EPA SW-846 Method 8020 for benzene, toluene,ethylbenzene, and xylenes.

1 1206.1 I(5fR AW693/T.2 7

. ~~The table below shows the method detection limits (MDLs), precision, and accuracy ofMethod 8015 as executed by EA Laboratories and the soil vapor analytical method asexecuted by EA's standard field protocol for soil vapor analyses.

Method 8015 Gas Diesel

MDLs 4.3 pg/kg 3.5 mg/kg

Precision ± 15 percent ± 15 percent

Accuracy 80-104 percent 78-102 percent

SVCA BTEX TVH

MDLs I ppmv 10 ppmv

Precision ± 40 percent of calibration ± 40 percent

Accuracy depends on composition of depends onfield sample composition of field

Isample

3.5 SAMPLING PROCEDURES. ~~Sampling procedures will be as described in the FSP.

3.6 SAMPLE CUSTODY AND DOCUMENT CONTROL PROCEDURES

Sample custody and document control procedures will be as described in Section 5 of EALaboratories Quality Assurance Manual.

3.7 CALIBRATION PROCEDURES AND FREQUENCY

Cal ibration procedures and frequency for the soil vapor analytical instruments will be asdescribed in the FSP.

Calibration procedures and frequency for the soil sample analytical instruments are describedin Section 6 of EA Laboratories Quality Assurance Manual.

3.8 ANALYTICAL PROCEDURES

Soil samples will be analyzed using ADEC modified Method 8015 for Gasoline RangeOrganics and Diesel Range Organics and EPA SW-846 Method 8020 for benzene, toluene,ethylbenzene, and xylenes, as described in the FSP.

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O ~3.9 DATA REDUCTION, VALIDATION, AND REPORTING

Data reductioji and reporting procedures are described in Section 10 of EA LaboratoriesQuality Assurance Manual.

3.10 INTERNAL QUALITY CONTROL

The internal sample quality control procedures are described in Section 8 of EA LaboratoriesQuality Assurance Manual.

3.11 PERFORMANCE AND SYSTEMS AUDITS

Performance and systems audits are described in Section 12 of EA Laboratories QualityAssurance Manual.

3.12 PREVENTIVE MAINTENANCE

Preventive maintenance procedures are described in Section 9 of EA Laboratories QualityAssurance Manual.

3.13 DATA ASSESSMENT PROCEDURES

Data assessment procedures are described in Section 10 of EA Laboratories QualityAssurance Manual.

3.14 CORRECTIVE ACTION

Corrective action procedures are described in Section 11I of EA Laboratories QualityAssurance Manual.

3.15 QUALITY ASSURANCE REPORTS TO MANAGEMENT

Quality assurance reports are provided to EA Management Staff on a monthly schedule asdescribed in Section 2 of EA Laboratories Quality Assurance Manual.

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4. HEALTH AND SAFETY PLAN SUMMARY

The NAPL recovery project proposed 1993 field work is described in the Draft FinalWorkplan, EAFB QUIB NAPL Recovery Project. The health and safety program for EApersonnel working at Bielson AFB in 1993 will include a master Health and Safety Plan(HSP) and task-specific appendixes to the master HSP. The following is a summary of theinformation to be included in the HSP to be used at the QUIB sites to govern health andsafety practices. This summary document is not to be used as a stand-alone health and safetyplan for site work. A separate HSP will be produced for use at the field sites; the HSP willinclude the information enclosed here and training certificates for the site personnel.

4.1 SITE INFORMATION

Site and Project Information

Sites: Blair Lakes Facility. Building 1300. and Refueling Loop Site E-9Location: Eielson Air Force Base, Fairbanks, Alaska

EAFB Information Number: (907) 377-1 110

Client Project Manager: Ms. Sam Gibboney Phone: (907) 377-1923

O L~~A Project Number: 11206.11.A001

Scheduled Work Date: Periodically between 15 May 1993 - Mid-October

Site Safety and Health Supervisor(s): To be named

LA Site Personnel: To be named

EA Site Trailer: Phone: (907) 372-XXXXFax: (907) 372-XXXX

Subcontractors: To be named

LA Project Managers: Dougz Oramn, Dave Beistel

EA Fairbanks Office: Phone: (907) 456-4751

Hazardous Waste Operations Coordinator: Lynn Wood Phone: (206) 869-2194

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. ~4.2 DESCRIPTION OF OPERATIONS

EA will be conducting field investigation and implementing systems to remove NAPL fromthree source areas on Eielson Air Force Base property. Two source areas are on the basenear the runway, Building 1300 and the Refueling Loop Site E-9, and one source area isapproximately 25 miles southwest of the main base at the remote Blair Lakes Facility (seeFigures 1-4).

The NAPL recovery systems will involve installation of interception trenches, recovery wells,and/or well points. The work will involve the use of heavy machinery, including thefollowing: drill rigs, concrete saws, corers, backhoes, loaders, cement mixers, and dumptrucks. Electric heating equipment and aboveground PVC piping and insulation will beinstalled in the project area. Once the NAPL system is in place it will be enclosed in trailersor containers, except for a few emerging pipes.I

The Building 1300 and Refueling Loop E-9 sites are both located on an active runway. Aflight line permit must be obtained prior to working on these sites. Work may be performedwithin 100 feet of moving aircraft. Hearing protection may be necessary in these areas, andshould be carried by all personnel. The Site Safety and Health Supervisor will use discretionto determine when use of hearing protection is mandatory.

The Blair Lakes Target Range Facility is a remote and swampy site approximately 25 miles. ~~south of the main base. There are no roads leading to this site, and helicopter travel will berequired. Ice roads across the Tanana River are constructed in the winter and may be usedfor maintenance of the NAPL system. BA will be subcontracting helicopter transportationservices and will fly out of Fairbanks from the Fairbanks airport. The Blair Lakes facility islocated in a swampy area and consists of two helipads and approximately five buildings.Mosquitoes and other insects will be a problem; bug repellant is suggested.

Animals such as bears, foxes, and moose may be seen while working on this project. Someof these animals may be dangerous and should be avoided. Air Force security should becalled during animal incidents.

4.3 HAZARD EVALUATION

Chemical Hazards

Based on previous sampling, the NAPL at the sites consists of either diesel fuel or JP-4 jetfuel. Although variable in composition, these petroleum products can be characterized in ageneral manner. Jet fuels (Jet A, Jet B, and JP-4) are composed of paraffins (alkanes) in theC5 to C20 range, less than 25 percent aromatics, and very low levels of olefins (alkenes).Diesel contains paraffins and cycloparaffins in the C,, to C24 range and very low levels ofaromatic hydrocarbons.

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Although the composition of the fuels varies, the acute health effects of exposure are reportedto be similar for all blends. Exposure to JP-4 can occur by inhalation and dermal contact.Inhaled JP-4 generally acts as an anesthetic and mucous membrane irritant. Dizziness,headache, nausea, palpitation, and pressure in the chest, are the most commonly observedsymptoms of overexposure. Diesel fuel is not sufficiently volatile to constitute an acuteinhalation hazard in unconfined spaces. It is not readily absorbed through intact skin, but itcan penetrate abraded skin. Dermal contact with diesel or jet fuel can dry the skin, which canlead to skin irritation, infection, and dermatitis.

The risks and hazards associated with the major classes of petroleum hydrocarbons present injet fuels and diesel are described below:

PARAFFINS (alkanes) include n-butane, n-hexane, isobutane, isopentane, andcyclopentane. There is no evidence that these compounds are mutagenic (chemicalswhich cause changes of the genetic material in reproductive cells, resulting indeformed offspring), teratogenic (substances which cause deformities in unbornoffspring that have already been conceived), or carcinogenic (substances whichcause cancer). Exposure to hexane can cause peripheral nerve damage. In general,these compounds have low human toxicity and the potential toxicity tends todecrease with increasing carbon chain length. Cycloparaffins are less toxic thantheir equivalent straight-chain paraffins.

* OLEFINS (alkenes) include trans-2-pentene and 2-methyl-2-butene. Thesecompounds have little inherent human toxicity, although adverse health effects canresult from exposure to high levels of some olefins.

* AROMATICS of greatest concern are benzene, toluene, xylenes, and ethylbenzene.Benzene is a human carcinogen, but the others have not been identified ascarcinogens. Adverse effects of the aromatics include renal failure, liver damage,central nervous system damage, and respiratory tract damage. Benzene and otheraromatics can be absorbed through the respiratory tract and the skin, so bothinhalation and dermal contact are potential routes of exposure.

Flammability and Explosion Hazards

Flammability is a primary hazard associated with NAPL petroleum hydrocarbons. The lowerexplosive limits of jet fuel, gasoline, and diesel are 0.6-1.3 percent (6,000-13,000 ppim),1.4 percent (14,000 ppm), and 0.9 percent (9,000 ppim), respectively.

Underground Obstacles

The majority of underground obstacles which pose a threat during drilling or excavation areburied utility lines. Contact with buried utilities during drilling presents potential acutehazards to site personnel. At a site, buried lines may include:

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* electrical lines* natural gas/petroleum lines• product and vapor recovery lines* communication cables* sewer, water, air, and irrigation lines

The hazards of contacting each type of line vary, but the most serious are electrical lines,which can result in electrocution; fuel and gas lines, which can result in releases of toxic andflammable chemicals; and water lines, which can be under pressure.

Heavy Equipment Hazards

Heavy construction equipment such as bulldozers and front loaders will be used during theproject operations. Accidents with this equipment can cause serious injury. Field personnelshould STOP, LOOK, and LISTEN before moving around active construction equipment.Field personnel should make sure operators know their location at all times.

Drilling involves the use of large, heavy pieces of equipment, especially augers. Specialvigilance is needed when this equipment is pulled overhead. Loose clothing and other itemsmay become entangled in the rigging and can result in injury. High wind conditions mayoccur anytime of the year. These winds can cause difficulties in working with a drill rigwhen the mast is raised and can cause overhead wires to contact the mast if the clearance is

* ~~not sufficient.

Overhead electric and telephone lines and other overhead obstacles can create hazards whenthe drill rig mast is raised. The most serious of these hazards is contact with high voltageoverhead electric lines. Overhead utilities are not expected to be a problem on this project.

First Aid - Before treating someone with an electrical burn,make sure the power source is disconnected (thepower company may need to be called). CALLFOR HELP IMMEDIATELY. Cover burned areawith loose, dry, sterile dressing and bandage; treatfor shock.

Noise and Dust Hazards

Traffic, heavy equipment, and machinery operating in the vicinity can create high levels ofnoise and airborne dust. Exposure to high noise levels can cause health effects ranging fromdiscomfort (short exposure times) to a permanent ringing in the ears and hearing loss (long,continued exposure).

Inhalation of dust can result in increased exposure to soil-bound chemicals andpneumoconiosis. Overexposure may occur when the dust becomes visible in normal light.

11 206 11 (5RAW693MT.2 13

Symptoms of potential overexposure to dust are congestion of the nasal passages and irritationof the eyes and respiratory system.

First Aid - If severe exposure to noise or dust occurs, removeperson from noise/dust area. GET MEDICALATITENTION. If noise exposure is mild, hearingprotection should be worn to prevent severedamage. GET MEDICAL ATTENTION IFOVEREXPOSURE TO DUST OR NOISE ISSEVERE.

Weather and Temperature Hazards

Soil sampling will be conducted outdoors in various weather conditions during the spring andsummer months. The field team may work in warm or possibly hot temperatures, which canresult in heat stress. Work may also occur during rain or unseasonably cold temperatures,which can contribute to hypothermnia and discomfort.

The symptoms of heat stress and heat exhaustion are pale, clammy skin, profuse perspiration,extreme tiredness or weakness, cramps of the limbs and/or abdominal muscles, and irritability.

First Aid - If a worker shows signs of heat exhaustion, theyshould rest in a cool (but not cold) location, withfeet elevated. If the person is conscious, give1/2 glass of water every 15 minutes, as tolerated.

If heat stress is ignored it can progress to heat stroke, a life-threatening condition. Heatstroke is charactenized by red or flushed skin, hot skin, dry skin, lack of perspiration,dizziness, headache, nausea, rapid pulse, and unconsciousness.

First Aid - When heat stroke is suspected, the person'stemperature should be cooled as quickly aspossible by wetting down clothes or coveringthem with moist sheets or towels. TREAT FOR.SHOCK AND GET HELP. Do not give anythingby mouth.

Hypothermiia can occur when the air temperature is low, when there is a potential for windchill, and during wet weather. Hypothermia is a life-threatening condition. The symptoms ofhypothermia are sleepiness, numbness, failing eyesight, lack of coordinated movement,staggering, and unconsciousness.

First Aid - Exposure to cold temperatures should beimmediately terminated for any worker who hassevere shivering. When entering a heated shelter,

11206 1 (5Y/RAW693/TX 2 14

the outer layer of clothing should be removed and'0 ~ ~~~~~~~the remainder of the clothing loosened to permitsweat evaporation, or a change of dry workclothing should be provided. The body should beslowly warmed. If the person is fully conscious,they should be given warm non-alcoholic drinks.

4.4 SAFETY MEASURES AND PERSONAL PROTECTIVE EQUIPMENT (PPE)

Underground and Overhead Utility Precautions

To minimize the risk of contacting underground lines and cables, the following steps shouldbe done prior to drilling:

* Obtain current and previous site map and bluepnints.

* Contact the underground utility clearance service in advance of field work. Marklocations of proposed borings prior to the utility clearance.

* Walk the site to look for indications of lines (e.g., pavement cuts and utility pullboxes).

* Inspect the site to identify overhead obstacles: a minimum 10 feet of clearance isrequired for all overhead lines; a greater distance may be required. The specificdistance should be determined with the assistance of the utility company. Theinfluence of wind should be considered when evaluating the location of a rig mastin relationship to overhead lines.

* Use a pipe and cable locator when feasible.

* If there is doubt about the location of a utility line, probe the first three to five feetof depth with hand tools.

Traffic Hazards

Traffic may present a hazard to personnel involved in installing the NAPL recovery system.Both injury and equipment destruction can be caused by a traffic accident. Two recoverysystems will be installed on an active flight line, and extreme caution should be taken toalways be aware of moving aircraft.

Bafflers must be used to demarcate the work zone. Standard traffic cones are not generallyadequate due to their low vertical profile. The taller, 28-inch high, cones should be used.Optionally, warning flags and barricade tape can be used with the cones. If boreholes areopen during non-working hours, they must be adequately decked or barricaded.

1 1206.1II(5)/RAW693rrX.2 15

* ~~In high-traffic areas, safety pennants and plastic or steel "A" frame type barricades may beused. When working on the active flightline or in streets adjacent to a site, traffic vestsshould be worn to increase visibility.

Noise and Dust Hazards

Drilling, especially with rotary drills using air or air percussion and excavation, can createhigh levels or noise and airborne dust. The results of exposure to high levels of noise varyfrom discomfort to a permanent ringing in the ears and hearing loss.

Inhalation of dust can result in increased exposures to soil-bound chemnicals andpneumoconiosis. Overexposure may occur when the dust becomes visible in normal light.Signs of potential overexposure are congestion of the nasal passages and irritation of the eyesand respiratory system.

It is the Site Health and Safety Supervisor's responsibility to determine when dust conditionsbecome hazardous, and if work should be suspended or a water truck used to settle the dust.

Trenching Hazards

Applicable OSHA standards (29 CFR 1926) for excavation are summarized below:

a. Excavations greater than 5 feet deep should be protected by a system of shoringor sloping of the ground if an employee is to enter the excavation.

b. Excavated soil should be placed at least 2 feet from the trench area.

C. A convenient and safe access to enter and leave the excavated area, such as aramp or a ladder, should be provided.

d. A check should be made for potential worker hazards before excavating under afountain, building, or wall.

e. The excavation should be cordoned off to prevent workers and mobile equipmentfrom inadvertently entering the excavation.

f. Ditches or dikes should be used to prevent surface water from entering theexcavation.

g. If water accumulates in the excavation and poses a hazard to worker safety, thewater should be controlled before further work progresses.

h. Special safety precautions (e.g., additional bracing) should be provided forexcavations adjacent to streets, railroads, or other sources of external vibrations

I11206.11(5YRAW69A3nX.2 16

or superimposed loads and similar support provided for excavating in areas thathave previously been filled.

i. Shoring should be installed from the top of excavation downward.

j. If the excavation is greater than 20 feet deep, then a registered civil engineershould prepare detailed plans for shoring.

k. The maximum shored trench slope should be 15 degrees from vertical.

1. Air monitoring equipment (an explosimeter or organic vapor monitor) should bepresent at all times when working in the excavation. This equipment will becalibrated for detecting the types of chemicals that constitute the fluid beingstored.

Personal Protective Equipment (PPE)

Level D protective equipment and clothing should be used in most field settings where heavy

equipment is present or exposure to NAPL is expected:

MANDATORY

* nitrite or solvex gloves when handling soil* steel-toed shoes* hard hat* safety glasses or face shield

OPTIONAL

* cotton/polyester coveralls or tyvek suit* hearing protection (ear plugs or ear muffs)

If the total organic vapor (TOV) concentration increases in the breathing zone to greater than10 ppm, or above a chemical-specific TLV, the PPE should escalate to Level C. Theadditional equipment needed for Level C protection includes:

* air-purifying respirator with combination organic vapor filter and high-efficiencyparticle filter (HEPA) (FIELD PERSONNEL MUST BE PROPERLY FIT-TESTEDFOR RESPIRATORS PRIOR TO BEGINNING FIELD WORK)

* saran-coated tyvek coveralls

* boot covers

It1206.11 (5)/RAW69317X.2 17

. ~Other Safety Equipment

The following safety equipment must be present on the site at all times:

* ABC-type fire extinguisher* eye wash kit* first aid kit* drinking water

Personnel must be trained in the proper use of all safety equipment.

Work Zones

Optimally, the exclusion zone should encompass at least the area within 100 feet of activeremediation. This area may have to be changed based on site conditions, but always will bemade as large as possible. The exclusion zone should be clearly demarcated by yellowwarning tape, barriers, and/or cones.

Training

Site personnel should have successfully completed a 40-hour Hazardous Waste OperationsTraining Course, including CPR and first aid. Training for respirator use and maintenance. ~~must be completed prior to field work. All EA personnel working at the EAFB sites willhave completed the appropriate training. The Site Safety and Health Supervisor hascompleted the 8-hour supervisor training course.

Safe Work Practices

Smoking, eating, drinking, and chewing either tobacco or gum are prohibited in the exclusionzone.

Potential ignition sources must be minimized. EA and subcontractor vehicles must not beparked in locations which block fife hydrants, access to emergency equipment, or exits frombuildings.

Prescription drugs must not be taken unless specifically approved by a physician whounderstands the nature of the work exposure.

First aid treatment will be administered only by trained personnel.

When respirators are required, facial hair that interferes with the face-to-facepiece seal mustbe trimmed or removed.

During hot or cold weather, regular rest breaks should be taken to avoid temperature-related. ~~stress. Non-alcoholic beverages should be consumed regularly to avoid dehydration.

II 206.11 (5y(RAW693r-rX.2 1 8

O ~4.5 EXPOSURE LIMITS AND WARNINGS

Detectable amounts of benzene and some other chemicals known to cause cancer, birthdefects, or other reproductive harm may be found in and around the area where remediation,construction, and NAPL handling is to be conducted. Adherence to the safety and healthprocedures and standard safety practices addressed here will minimize the potential forexposure to these chemicals.

The American Conference of Governmental Industrial Hygienists (ACGIH) has established arecoimnended Threshold Limit Value (TLV) for gasoline of 300 ppm (a TLV is a time-weighted average concentration for a nornal 8-hour workday and a 40-hour workweek, towhich nearly all workers may be exposed day after day without adverse effects). Further,ACGIH recommends that an airborne concentration of 500 ppm gasoline not be exceeded foreven short periods of time (i.e., 15 minutes). The U.S. Occupational Safety and HealthAgency (OSHA) has established an 8-hour Time Weighted Average Exposure Limit (TWA)of 300 ppm for gasoline.

OSHA's PEL standard for benzene is 1 ppm. Other applicable PELs are: 200 ppm toluene,100 ppm xylenes, 100 ppm ethylbenzene, and 500 ppm hexane. The PEL for nuisance dust is10 mglrnQ. See Table I for additional chemical contaminants of potential concern where fuelor waste oil NAPL may be encountered.. ~4.6 ENVIRONMENTAL HAZARD MONITORING

Organic Vapor Monitoring

When work is performed where exposure to NAPL is expected, organic vapor monitoring willbe conducted. At the beginning of the day and approximately every 30 minutes during theday, the site health and safety supervisor will measure the total organic vapor (TOV)concentration in the breathing zone (the breathing zone is approximately the area from I footabove to I foot below the level of the nose). An Organic Vapor Analyzer (OVA) utilizing aflame ionization detector (FID) will be used, and the monitoring results will be recorded inthe field notes. If the TOV level increases above the background level and levels approachthe TLV or PEL for any of the suspected contaminants, the Site Safety and Health Supervisormust determine whether the level of personal protective equipment and/or frequency ofmonitoring should be increased, and must notify site personnel immediately.

PERSONAL PROTECTIVE EQUIPMENT (i.e., RESPIRATORS) MUST BE WORN IFBREATHING ZONE CONCENTRATIONS OF CHEMICALS EXCEED THE THRESHOLDLIMIT VALUES OR PERMISSIBLE EXPOSURE LIMITS.

The calibration of the OVA will be checked at the beginning of each day of use. Ifappropriate, the power source of the instrument (e.g., rechargeable batteries) will be checkedthe day before use.

11 206. II 5YRAW693MT.2 19

. ~~Flammability and Explosion Hazards

The TOV concentration must be measured in the vicinity of the contaminated soils at groundlevel with the OVA at regular intervals. Results will be recorded in the field notes. If theTOV level is below 10 percent of the lower explosive limit (LEL) for suspected contaminants,sampling operations may continue.

If the TOV concentration is between 10 percent and 25 percent of the LEL (approximately700 to 1,750 ppm for jet fuel), sampling may continue with caution and with increasedmonitoring.

IF THE CONCENTRATION OF TOTAL ORGANIC VAPORS EXCEEDS 25 percent OFTHE LOWER EXPLOSIVE LIMIT (approximately 1,750 ppm for jet fuel), SAMPLINGACTIVITIES MUST CEASE AND ALL PERSONNEL MUST WITHDRAW FROM THEAREA.

1 1206.1 I(5YR AW693rfX.2 20

0 5~~. PROJECT SCHEDULE INCLUDING CONSTRUCTION SCHEDULE

I1 206.11I(5YRAW693YlX.2 21

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6. REMEDIAL IMPLEMENTATION QUALITY ASSURANCE/

QUALITY CONTROL PLAN

Shop Drawing QAIQC Shop drawings used to construct proposed remediation systems willbe subject to EA's internal review process, consisting of review by a practicing engineer anda registered geologist and an overall review by EA's chief engineer. Shop drawings will alsobe reviewed by Eielson AFB engineering and maintenance personnel.

Construction Oversight Construction of the remediation systems will be supervised by afield engineer or geologist. All installations will be checked for materials and quality toensure that they comply with the manufacturer's specifications to validate equipmentwarranties. All equipment performance specifications will be checked by the field engineerafter installation to ensure proper operation and safety.

Use of the NAPL Recovery Decision Tree The decisions to implement a remedialtechnology will be based on the NAPL recovery decision tree described in the Draft FinalWorkplan, EAFB OU1B NAPL Recovery Project, and shown in Figure 11. The selection ofa remedial implementation scheme will be based on the mobility, estimated volume, andvolatility of the NAPL determined during the field season. The decision to implement aparticular remedial technology will be discussed and agreed upon by the USAF, EPA, and,ADEC before implementation.

* ~~Change Order Approval Process Experience has shown that field conditions are oftendifferent than anticipated and consequently decisions must be made to deviate from actionsproposed in the workplan. The Air Force will verbally notify the EPA and ADEC of anymajor changes in scope or omissions of remedial activities due to changing field conditions asthey occur. Consensus of the remedial project managers will be required for major changesand will be discussed via conference call and documented by official letter. Major changesinclude: change in remedial technology, downsizing of area to be remediated, change inschedule of construction completion, changes in remedial waste management, decrease innumber of recovery wells, extraction wells, injection points, etc. Minor modifications to theworkplan will not require approval of the EPA and ADEC so as not to inhibit completion ofthe field work. The EPA and ADEC will be kept informed of field activities with a monthlysynopsis of events including minor modifications to be provided by the Air Force. Minormodifications include: changes in equipment, piping, and mechanical construction that do notsignificantly alter the function of the system; installation of product probes or soil vaporsurvey in order, to delineate the area of contamination; slight change in placement of recoverywells, extraction wells, or injection points that do not significantly change the size of the areato be remediated or the function of the system.

1 1206 I I(5)/RAW693ITX 2 22

7. MONITORING, OPERATION, AND MAINTENANCE PLAN

7.1 NAPL RECOVERY SYSTEMS STARTUP

NAPL will be recovered at some of the wells by operation of passive skimmers or NAPL-only pumps. NAPL will be removed from the wells and will be held in temporary storagevessels such as drums or tanks before being removed by the EAFB Hazmat facility. Startupof the NAPL pumping systems will consist of the following steps:

1. All pneumatic and liquid lines and NAPL storage containers will be checked forleaks by visual inspection during normal operation before installation of theNAPL recovery system is considered complete. Any holding tanks will betightness-tested by pressurizing with air and observing the interior pressure for atleast three hours. Suspected leaks will be located using "soap-down" testing.

2. Before and after NAPL active recovery is initiated, monitoring points near thearea of the recovery trench or wells will be gauged (using an optical interfaceprobe) to monitor changes in NAPL apparent thickness that might be attributed tothe recovery operation. Additional depths to the NAPL and water levels will bemeasured at appropriate intervals after NAPL removal is started.

3. NAPL pumping rates will be adjusted based on gauging data; drawdown of theNAPL within the recovery structures will be moderated to maintain movement ofNAPL into the trench or wells and to not isolate the recovery structures from theNAPL by water intrusion.

4. All system operating parameters will be checked against manufacturerspecifications and recorded on a system monitoring and operation form describedin the system monitoring and operation section.

7.2 SOIL REMEDIATION SYSTEMS STARTUP

Startup of any bioventing system to be installed will be done in stages.

1. All monitoring wells and product probes within the area of the bioventing systemwill be gauged to detemnnine depths from the top of the well casing to the NAPLand water levels to the nearest 0.01 feet using an optical interface probe or awater level meter and a clear plastic bailer. Baseline soil vapor concentrationswill also be measured in the vadose monitoring wells. At a minimum, the vadosemonitoring wells will be sampled and vapors analyzed under the same protocol asused for the existing ST-20 (E-7) bioventing demonstration project(Battelle-Columbus 1992) (Appendix A). In addition, the samples may beanalyzed with a portable gas chfromatograph following the protocols used duringthe pilot testing (BA 1993).

112061 I(5)/RAW693=T.2 23

2. Startup of the bioventing system will consist of balancing air flow rates to all0 ~ ~~~~wells to be used for air injection, measuring 02 and CO2 concentrations in thesubsurface using the vadose monitoring probes, and monitoring subsurfacepressure to confirm empirically that the radius of influence of the biovenfingsystem covers the impacted area.

3. The surface heating will be started when the subsurface soil temperaturedecreases to 50 degrees F.

7.3 SYSTEM MONITORING AND OPERATIONS

NAPL system monitoring, operation, and routine maintenance for NAPL pumping systemswill be done every other week using a checklist similar to the checklist shown in Figure 12.This form is used to record the pump control settings and recovery well and NAPL storagetank gauging measurements and to prompt the system operator to conduct routinemaintenance tasks. The gauging data are used to adjust the system pumping rates to optimizeperformance and monitor the approach of compliance with the IRA goal.

Monitoring and operation of the bioventing system will be done every other week and consistof measuring 02 and CO 2 concentrations from the vadose monitoring wells to determinedistribution within the subsurface. The monitoring information will be used to adjust thenumber of injection wells and flow rate of air into each well. All system parameters will be

* ~~monitored. In addition, in situ respiration tests will be conducted on a quarterly basis usingthe same protocol as that for the existing bioventing demonstration project at ST-20 (E-7)(Battelle-Columbus 1992) (see Appendix A).

Monitoring and operation of the surface heating systems will be done every other week ormore frequently as needed during the winter. Subsurface temperatures will be measured usingthe temperature monitoring probes. Adjustments will be made to seek a minimum subsurfacetemperature of 40 degrees F.

The concentrations of hydrocarbons inside buildings [such as Building 1305 at ST-20 (E-9)]will be monitored for the presence of dangerous vapors both before the system is started andwhile the system is operating. An organic vapor analyzer (using a flame ionization detector)or a 'Lower-Explosive Limit" meter will be used to obtain readings inside the building atdifferent times during the day before the system is started to observe the range of"background" concentrations of hydrocarbons that are present as a consequence of the use ofthe buildings (Building 1305 is a fuel purnphouse.

After the system is started and depending on the results of the "background" study, amonitoring program appropriate to the building use will be developed and implemented. Ifdangerous concentrations of vapors are observed, the system will be modified to mitigate thehazard.

11 206 11 (5)RAW693JrX.2 24

. ~7.4 SYSTEM PERIODIC MAINTENANCE

NAPL pumping system periodic maintenance is required for the system compressor andpumps. Compressor oil will be changed on a schedule specified by the manufacturer. TheNAPL recovery pumps will be cleaned quarterly, and the pump bladder will be changed on aschedule specified by the manufacturer.

Periodic maintenance for the bioventing system will consist of lubricating pressure blowers asspecified by the manufacturer for each system.

7.5 DEMONSTRATING SITE CONDITIONS THAT SATISFY ACHIEVEMENT OFTHE TARGET REMEDIAL GOAL

If gauging indicates that NAPL thicknesses are less than or equal to 0.01 feet in all wells andgauging points, the recovery pumps will be stopped. Gauging of the recovery wells andprobes will continue, to determine if NAPL reappears. If NAPL does reappear, the NAPLrecovery system will be restarted.

The bioventing system will be operated to achieve compliance with the soil remedial goal, tobe established during the OUI RI/FS.

7.6 SHUTDOWN AND DECOMMISSIONING OF SYSTEMS. ~~After compliance with the target remedial goal has been achieved, the systems will bepermanently shut down and disassembled. All process piping and equipment that has been incontact with NAPL will be cleaned using soap and water prior to disposal or reuse. All wellsused for remnediation or monitoring will be destroyed using applicable State of Alaskaguidelines.

7.7 MANAGEMENT OF RESIDUALS

Liquid NAPL recovered by the remediation system will either be reused or disposed of by theEielson AFB Hazmnat facility.

All soil generated during construction activities on the base will be either left on the surfaceof the site or transported to the existing bioremnediation cell at EAFB. At Blair Lakes, thesoil will be added to the existing composting soil at the Blair Lakes Target Range.

7.8 DOCUMENTATION AND REPORTING

Daily field work reports: All field workers will complete daily a brief narrative report offield activities completed that day. This report will be logged into the project file and used togenerate monthly reports. An example of the form to be used to complete the daily report isshown in Figure 13.

H 1206.1 L(5)1RAW693/T'X.2 25

. ~~Monitoring point data: All gauging data will be recorded in hardbound field notebooks andwill include well identification number, depth to NAPL, depth to water, and date and time.The gauging data will be periodically entered into spreadsheets that automatically calculateNAPL thickness and groundwater equivalent elevation. These records will become part ofregular monthly reports and the final summary report.

System Monitoring: A "checklist" form specific to the system at each site will be completedat the time of the regular monitoring.

Monthly progress reports describing operation of the systems and NAPL recovery over thepast month will be provided to EAFB.

I11206.1 I(5Y/RAW693/TX.2 26

REFERENCES

ADEC (Alaska Department of Environmental Conservation). 1992. Letter report fromR. Grabbe, ADEC Laboratory, Juneau, Alaska, to D. Gibler, ADEC, Fairbanks, Alaska.16 March.

Battelle-Columbus (Battelle Columbus Division). 1992. Annual Report for Environics TOCTask 3, Bioventing Feasibility Study: Eielson Air Force Base, Alaska. August.

Battelle-PNL (Battelle Pacific Northwest Laboratory). 1992. Operable Unit 1 ManagementPlan, Eielson Air Force Base, Alaska. December.

EA (BA Engineering, Science, and Technology). 1993. Eielson Air Force Base OUIBNAPL Recovery Project 60 Percent Document. February. Prepared for ArmstrongLaboratory, Brooks Air Force Base, San Antonio, Texas. EA, Lafayette, California.

I 1 206.Il(SYRAW693JT'X.2 27

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EA Senior OAIQC

Charlie Flynn. PH (Anchorage)Dave Santoro, PE (Baltimore)j

EA Fairbanks Liaison

Dave Beistel

* ~~~~~~~~~~~~EA Project Manager

Gloria McCleary (Baltimore)Doug Cram, PhD (Fairbanks/San Francisco)

EA Technical Staff Subcontractors

Hydrogeology Construction

Engineering Helicopter

Figure-10. Project Organization Chart for OUlB NAPL RecoverylInterim Remedial Action.

SITE CHARACTERIZATION

site: I. Gradient NAPt.: 1. Type of NAPL2. Groundwater Elevation Range 2. Volatility of NAPL.3. Lit1hology 3. Mobility of NAPL4. ExtentIofINAPL 4. Apparent Thickness

IMMOBILE NAPIL At. MOBILE NAPL

Mobluit

LOW NAPL HIGH~~~~~~~~~~~~~~~~~~Istl NP

Evaluate Bioventing Evaluate 6 enung with~perte ad Moito

and Resp Tests - ~~Recovery anductuPL

struct, erate a COperate andeatBeginwith apor robesMMonitoringVaprforoesAttainment Mnioocl Resi.Soil-base RemeialPoalsATesNAts Recovery antoP

PTuicvingess

Sol]-based Remedial Goal ~ ~ ~ ~ ~ ~ Some

NORECOVERY

Figurel11. NAPL recovery decision tree, OUlSBSource Area ST-20 (E-9I),ST-49, ST-50, Eielson Air Force Base, Alaska.

BLAIR LAKES NAPL RECOVERY MONITORING CHECKLIST

Date: JJInitials: _ __

CONTROL SETTINGSLOW 0 HIGH1. Pump level indicator (indicate reading graphically): 1 1 I I I

2. Discharge timer setting: _______

3. Refill timer setting: _______

4. Input pressure (psi): _______

5 . Output pressure (psi):

WELL ANDTAKGUIGMAUENS

WELL DTP DTW

RW- 1I__

RW-2 _ _

RW-3 _ _

PP-2 ___

PP-3 ___

MO-I __

Depth of product in tank (inches): ________

ROUTINE MAIJNTENANCEr

1. Is air dryer alternating purge cycles? YES - systemn operating properly

NO - report system failure to Kim Grandy(377-1668) or Doug O0mm

2. Drain air dryer pre and post filters (-0-8-07

3. Drain compressor tank

4. Is liquid discharging into holding tank? YES - keep system operating

NO -- turn system off by closing ball valveat hose reel and turning off breaker#14 in the breaker panel located nearequipment panel (see map reverse side)

Figure 1 2. Example system monitoring checklist.

U~~E ENGINEERING.SCIENCE. ANDTECHNOLOGY

DAILY FIELD REPORT

Date:__________________Project Number:____________

Site Personnel:________________ Site Conditions:______________

Major Activity:___________________________

Summary.

Figure 1 3. Example field report.

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TABLES

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APPENDIX A

Protocol for In Situ Respiration Tests for Bioventing Projects;Excerpt from "Annual Report Environics TOC Task 3 Bioventing Feasibility Study,

Eielson AFB, December 1992," by Battelle-Columbus

0

0

6.5In ~tu 426.5In ituRepirtIlon Testing

In Situ respliatOion tests are conducted monthly. These tests are based on the me thod descrbeby lincebe and Ong (1992). A full In situ respiration test involving all sOil gas points and intensivesampling is conducted quarterly. During other months, an abbreviated in situ respiration test isconducted. This test generally Involves sampling only 21 Select points, which are monitored at alower frequency. The soil gas monitoring points that are monitored vary depending on whether It ispossible to draw a good soil gas sample. In general, all soil gas monitoring points titat can besampled La the active warming test plot are sampled, and two three-level soil gas monItoring pointsfrom each of the other test plots are sampled.

The in situ respiration testing consisted of monitoring soil gas oxygen and carbon dioxideconcentrations during ai injection, then turning off air injection and monitoring oxygen and carbondioxide concentrations periodically over time. From these measurements, oxygen consumption andcarbon dioxide production can be determined. The experiment was usually terminated when theoxygen concentration of the soil gas fell below 5% or after 5 to 7 days, whichever occurred sooner.Carbon dioxide and oxygen concentrations are measured using a Gastechtor Model 32520X. Oxygenutilization rates are typically calculated as zero order, based on the Initial linear portion of the decay

0 ~~~~curve.

To relate respiration rates and resulting biodegradation rates to active bioventingmeasurenments and other sites in the literature, a stoichiornetric relationship of the oxidation of the fuelis requlred,' h-lxane (C61-114) will be used as the representative hydrocarbon for the jet fuel for th~epurpose~ of comparing the carbon dioxide and oxygen rates. The stoichiometrlc relationship is givenby:

C4 H,4 * 9.50o 6C02 *71120 1

Based on oxygen utilization rates (p~ercentlday), biodegradation rates in termis of' mg/kg/daycan be estimated by assuming a soil bulk density of 1.440 kg/rn 3 and an air-tilled porosity of 0.30 andusing the following equation:

0 ~~~~~~~~~~~~~~43

100%* dayw (2)

where:Ye6 - biodegradation rate (mg/kg/day)

K0 - Oxygen utilization rate (%Ihr)

A - Volume of air/kg of soil (LI/cg) In this case 300/1,440 = 0.21

D 0 = density of oxygen gas (ig/L), assumed to be 1,330 mg/L

C Mass ratio of hydrocarbon to oxygen required for mincralizatin sue ob :.fro m E q u a tio n I 0 1 as u e t o b 1 3 5

Full In situ respiration tests were conducted during October 1991, January 1992, August1992, and October-November 1992. Oxygen and carbon dioxide concentrations measured during boththe full and the abbrevIated tests are presnted in Appendix G. A summary of the oxygen utilizationrates in the atctive warming, passive warmlng, and control test plots is shown in Tables 6 through S.Figure 19 illustrates average biodegradation in the four test plots over a one-year period.

In the active warming test plot, high soil moisture content consIstently reduced the number ofsoil gas monitoring points that could be sampled. In general, the deeper soil gas monitoring pointswere the most difficult to monitor. The Inability to measure soil gas concentrations at the deepermonitoring points could lead to calculating lower average biodegradation rates for the active warmingtest plot, since the contamination is higher at the deeper depths and higher biodegradation rates aregenerally recorded.

A comparison of the oxygen utilization rates observed throughout the year In the activewarming test plot generally has shown similar rates, with the exception of a decrease during January1992 (FIgure 19). RespIration rates were 20% to 80% lower in January than in October 1991,Because soil temperatures were approximately the same, this difference cannot be attributed todifference in soil temperature. The only significant change appears to be In the soil moisture contentand the Inability to measure the deeper probes during January. As stated previously, this could leadto lower averages calculated for the entire test plot.

* ~~~~~~~~~~~~~~44

IA ND MNS 0.42 H

lB 0.69 0.18 NS 0.41 H

IC MM 0.023 NS NS HM

2A HM HM NS NS5 HM

2B 04 0.24 NS NS HM

2C 0.233 0.087 NS NS HM

3A 0.241 M4M 0.47 NS HM

3B 14M 0.095 0,12 NS EM

SC 0.J54 0.11 INS NS HM

4A HM H4M NS NS HMM

4E 0.80 0.051 NS NS5 HM

4C ND2 HM 0.21 NS5 EM

___A____ HM HM INS NS BN1

.S1 0.3 13 0.024 NS NS HNM1

50 HIM 0.039 0.21 NS HM

6A 0.14 0.032 0.24 0.25 14 N

6B 0.16 HNM 0.22 0.24 H M

G C ND2 H M 0.15 NS JiM

7A NS NS j NS NS 0.41

HM - High moisture content prevented sampling.ND) - Not determined.NS - Not sarnpled.

- Perimeter probes which are not listed had poor flow and inconsistent Samples.- Concentration <c5% at beginning of test.

3 Certain data appeared to be due to sampling error. Data analyzed from 0 to 33 hours.4 Data analyzed from 0 to 33 hours. Little activity after 33 bours,

* ~~~~~~~~~~~~~~45

_____________Table 7. Biodegradation Rlates In the Passive Warming Test Plot

Soil Gas fOxygen Utilization Rate (%/hr)Monitoring

Point October 1991 January 1992 April 1992 August 1992 November 199

IA 0.048 0.024 NS 0.11 0.057lB ~~~0.037 0.022 NS 0.13 0.045

IC 0.030 0.017 NS 0.23 0.020

__________ 0.028 0.027 NS NS 0.0-48r 2B 0.041 0.021 NS 0.22 0.053

2C 0.014 0.017 NS 0.16 0.022

3A 0.023 0.025 NS 0.20 0.072

F 38 0.034 0.024 NS 0.22 0.075

* r ~~~3C 0.016 0.015 NS 0.17 0.021

4A 0.040 0.025 N'S 0,14 0.0646

4B 0.049 0.030 0.040 0.27 0.11

4C ~~~0.03 ~ 0.0 20 0.024 NS 0.028

5A 0.038 0.025 0.030 0.012 0.05!

58 0.056 0,027 NS 0.3! 0.0935C 0,045 0.023 NS 0.19 0.093

6,4 0.035 0.023 0.028 NS 0.0444

68 0.070 0.030 0.025 0.13 0.068

6C 0.053 0.021 0.016 0.22 0.030

7 7A NS NS NS NS 0.044.

[NS Not sam~pled.

* ~~~~~~~~~~~~~~~46

Table 8. Biodegradation Rates In the -Control- Test plot

Oxygen UtIlization Rate (%lhr)

Monitoring Oaohwe 19911Jnay92 19April August 1992 Novnmb&Ippz9 .______________ 0.096 0.038 INS 230.063

lB ~~~0.073 0.040 0.089 0.29 0.077IC HM MM NS 0.11 0.31

2A 0.07! 0.029 0.047 0.0720.523 N~ ~~M NMM NS NS

20 N HM NS 0.11 0.032.3A 0.040 ~~~~~0.037 NS NS NSSB MM ~~~~~~~0.12 NS 0.31 NS30 MM M~ ~ ~~~~~M NS 0.13 0.027

4A ~~~0.065 0.031 NS NS NS43 ~~~0.0321 0.086 NS 0.28 NS

40 MM H M NS 0.11 0.041F S A ~ 0. 09 9 H NS NS INS

SD MMI tim NS NS 0.053SC HM 0.4 1W NS 0.12 0.0376A 0.11 0.036 0.033 NS 0.060613 MMI HM NS 0.19 0.042160 MH M NS 0.14 0.02SA NS NS S NS O.03SBM M S S0.4

NS- Not sampled.HM - High moisture content prevented sampling.

Certain data points were eliminated as they appeared to be due to sampling error.

* ~~~~~~~~~~~~~~47

Zw

C14 0~~~~~~~~~~~~~~~~~~~.

(SUP/2)[/21u) O~~vqj Uopupei~opolff

48The full in situ respiration test conducted during January 1992 produced Interesting results inthe Other test Plots (Table 9). DespIte low temperaturas In the passive warming and control test plots,microbia] activity was observed at most sampling points, In general, oxygen utilization rates werelower during January mn these test plots. However, some oxygen utilization rates were equivalent orslightly higher than those observed during warmer months, and actual reductions In oxygen utilizationrates were not as great as might be expected, with reductions in respiration rates of 5% to 70% fromthose measured In October 1991.

An abbreviated In situ respiration test was conducted in June 1992. Due to the melting snow,the soil moisture content was quite high In all three test plots and little data could be collected.especially for the active warming and the control test plots. However, the data available from thepassive warming test plot showed that oxygen utilization rates had increased by nearly an order ofmagnitude since the winter months. It is evident that the plastic mulch on the soil greatly increasedsoi.I temperatures, which resulted in significantly higher microbial activity. The in situ respiration testconducted hi August 1992 confirmed these results, with average oxygen utilization rates of 0.18s%oxygen per hour compared to average oxygen utilization rates of 0.023 % oxygen per hour (January1992) to 0.055% oxygen per hour (November 1992) (Table 8).

Soil temperatures in the passive warming test plot in November 1992 were a faw degreeshigher overall than at the same time In 1991 due to the plastic mulch that covered the test plot duringthe summer. Slightly higher respiration rates also have been observed during November 199, withan average respiration rate of 0.055% oxygen per hour as compared to an average rate of 0.039%oxygen per hour during October 1Q9)1.

Respiration rates measured in the control test plot during August 1992 were nearly as high asthose measured In the passive warming test plot. It would be expected that due to the differences insoil temperature, respiration rates would be higher in the passive warming test plot; however,respiration rates in the control plot generally have been comparable to or higher than those measuredIn the passive warming test plot. Differences In the level of contamination between the two test plotsmay cause the differences in respiration rates,Respiration rates in the surface warming test plot wer e measured for the first time inNovember 1992. Respiration rates ranged from 0.044 up to 0.36% oxygen per hour, with an averag4respiration rate of 0. 15% oxygen per hour (Table 10). This rate is comparable to that observed in tinactive w&Saring test plot, Indicating that the use of beat tape may prove to be a more useflil methodfor soil warming, eliminating the problem of high soil moisture content.

* ~~~~~~~~~~~~~49.

Table 9. Biodegradation Rates During In Situ Respiration Tests:_________________ January 28 to February 8, 1992

Oxygen Utilization Rate (%Ihr)Sail Gas

Monitoring Point Active2 Passive Control

IA NDI 0.024 0.0381 H 0.18 0.022 0.040

IC 0.023 0.017 NDI

2A ND' 0.027 0.029

22 0.24 0.021 ND1

2(2 0.087 0.017 NDI

3A NDI 0.025 0.037

39 0.095 0.024 0.123C 0.11 0.015 ND'

4A ND' 0.025 0.03 I

4___________0.051 0.:O030008

4C ND' 0.020 ND'

__ _ _ A___ _ __ _ND' 0.025 NDI'

53) 0.024 0.027 NDI

5(2 0.039 0.023 0.043

61A 0.032 0.023 0.036

62 ND' 0.030 ND'

6(2 ND' 0.021 ND'

ND - Not determined.I Moisture content too high to permit adequate sampling.

2 - Data anadyzed from 0 to 54 hours. Little activity after 54 hours.

so

Monitoring Point xgnUiiainRt ¶/r (megrk/ay)o fA ~~~~~0.265.

12 ~~~~~~~0.36 6.9IC ~~~~~0.0671.

2A ~~~~~~0.14 2.7(b 22 ~~~~~~~~~~~~0.12 2.33A 0~~~~~~.057 U1

4A 0.122.

49 ~~~~~~0.12 2.340 0.044s 0.84

6A ~~~~~~0.21 4.0

Section (5), Page (P), etc. Comment (C) and Response (R)

General R2: The Air Force agrees that it is important toassure that high-quality data is being obtainedfrom the optical interface probes. The quality ofthe data collected from the optical interfaceprobes is discussed in Section 3.4.1 of the DraftFinal Workplan, OU1B Source Areas ST-20(E-9), ST-49, SS-50-SS-52, NAPL RecoveryProject, Eielson Air Force Base, Alaska (DraftFinal Workplan for ST-20 [E-9], ST-49, andSS-50-SS-52). The concerns about the qualityof the data obtained over the last field seasonfrom the optical interface probes are discussed inthe USAF response to EPA comments attachedto the Draft Final Workplan; the suspect datapoints were not caused by poor quality data fromthe probes. The data quality obtained from theoptical interface probe is appropriate for theintended use on this project. The NAPLthicknesses measured with the probe will bechecked with water- and fuel-sensitive paste on aa ~~~~~~~~~~~~~stick at the beginning of the field season.

W ~~General C3: The field sampling plan describes the proceduresfor tasks to be completed for the NAPL recoveryproject as presented in the 60 percent documentEAFI3 GUIB recovery project (EA 1993).However the 60 percent document describes thedata gap investigation and the remedial strategiesonly for ST-20, ST-48, and ST-49.

The remedial strategies define only the tasks tobe performed during the 1993 field season. Thedata quality objectives (DQOs) of the proposedsoil and soil gas sampling are not presented ineither the 60 percent design document or theremedial action work plan. Identifying DQOs isessential to developing an effective samplingplan; DQOs should be included in thisdocument.

R3: The EA Draft Final Workplan for ST-20 (E-9),ST-49, SS-5G-SS-52 describes field work forboth site characterization and remediation systemdesign proposed for 1993 at ST-20 (E-9), ST-49,and SS-50-SS-52. Field work proposed for sitecharacterization and remediation design at ST-48

j . ~~~~~~~~~~~~~will be presented in a separate workplan to becompleted by BA under separate cover.

I1[206.II(5yfRAW693.DF/R2C 6 Page 2

. ~~Section (5), Page (P), etc. Comment (C) and Response (R)

General R3: (continued)

Field work proposed for site characterization andremnediation design at ST-20 (E-7) will also bepresented in a separate workplan, to becompleted by EA under separate cover.

The Draft Final Workplan for ST-20 (E-9),ST-49, SS-50-SS-52 describes proposed tasks tobe completed in 1993 to determine the remedialstrategy that will be implemented at each of thesource areas. Maintenance and monitoringactivities to continue past 1993 will depend onthe remedial alternative that is selected and arediscussed in the Draft Final Remedial ActionWorkplan for ST-20 (E-9), ST-49, andSS-50-SS-52.

The Data Quality Objectives (DQOs) arepresented in Section 3.4.1 of the QualityAssurance Project Plan portion of the Draft FinalRemedial Action Workplan.

General C4: The plan does not specify monitoring locationsor sampling protocols for achieving target goalsfor the vadose zone soils for protection of thegroundwater.

R4: Soil sampling is not planned to monitorperformance of the NAPL remediation. Gaugingof NAPL thickness will be used to monitorprogress. Bioventing systems will be monitoredusing respiration tests and soil vaporconcentrations. Soil sample analysis may bemore appropriate after operation of thebioventing system for 1-2 years.

General C5: Referenced sampling protocol (Battelle-Columbus 1992) for the existing bioventingproject has not been reviewed by EPA andshould be provided in the draft final document.

R5: The sampling protocol will be provided asAppendix A in the Draft Final Remedial ActionWorkplan for ST-20 (E-9), ST-49, andSS-50~-SS-52.

11206.1 i(5y/RAW693 DRFIRC.6 Pag 3

. ~~Section (5), Page (P), etc. Comment (C) and Response (R)

S2.3.1, P3, ¶2 C6: The text indicates that soil samples will becollected from selected well locations at ST-20as shown on Figure 8 (wells AM-, Al-2, Al-3,AlA4, Al-5, Al-6, and SW5). However therationale for collecting soil samples during theinterim remedial measure for NAPL recovery orfor selecting soil sampling locations is notexplained. The locations seem to correspond toareas where NAPL has been previously detected,except well AL-4, which is next to probe PP10l,where NAPL has not been detected. If hot-spotsampling is proposed, well location SW3 shouldbe substituted for sampling location ALA4, since5W3 is closer to probe PPI108 were NAPL hasbeen observed.

Soil sampling depths are proposed from 3 to5 feet below ground surface (bgs) and from 5 to7 feet bgs. Groundwater table fluctuations arereported to be approximately between 6 to 8 feetbgs. The 5-to-7-foot bgs sample location shouldbe changed to 6 to 8 feet bgs to allowcomparison of the vadose zone (3 to 5 feet bgs)and the "smear zone" (6 to 8 feet bgs).

R6: The rationale for collecting soil samples isexplained in Section 2.3.1 of the Draft FinalRemedial Action Work-plan for ST-20 (E-9),ST-49, and SS-50-SS-52.

Up to three samples will be collected from eachboring, at depths from 3-5 feet bgs, from5-7 feet bgs (and above the static water at thetime of sampling), and from 6-9 feet bgs (andbelow the depth to static water at the time ofsampling). These sample locations will helpestablish the distribution of the petroleumhydrocarbons in the "smear zone."

S2.3.2, P3, 12 C7: Prior to soil vapor sampling, the sampling probewill be purged of approximately five probevolumes. The sampling plan should identify thevolume per foot capacity of the sampling probeand the method for estimating purge volumes.

R7. The soil vapor probe purging is more thoroughlydiscussed in Section 2.3.2 of the Draft FinalRemedial Action Workplan for ST-20 (E3-9),ST-49, and SS-50-SS-52.

11 206.1 I(5)/RAW693.DF/R2C.6 Page 4

. ~~Section (5), Page (P), etc. Continent (C) and Response (R)

S3, P6 and P7 C8: This section describes DQOs for NAPLrecovery, and refers to Alaska Department ofEnvironmental Conservation (ADEC) modifiedmethods 8015 and 8100, and EPA SW-846method 8020. On page 5, ADEC modifiedmethod 8015 is specified for gasoline rangehydrocarbons, and ADEC modified method 8100is specified for diesel range hydrocarbons. Themethods for hydrocarbon detection (bothgasoline and diesel) are modifications of EPASW-846 method 8015. EPA SW-846method 8100 is a method used for detection ofpolynuclear aromatic hydrocarbons (PAHs). Inthis case, it is assumed that the methods desiredare those appropriate for the detection of dieseland gasoline range hydrocarbons rather thanPAHS.

A review of the site management plan qualityassurance project plan (QAPP), revision 2(CH2M Hill 1992), shows that DQOs arediscussed for methods 8100 and 8020, althoughit is unclear whether this refers to the ADECmethods or to the EPA methods. Precision andaccuracy for the method to be used should beclearly specified either in this work plan or inthe site management plan QAPP.

In addition, method 8015 is not mentioned in thesite management plan QAPP. DQOs such as thedetection limit, precision, and accuracy shouldbe specified.

If the modifications to method 8100 and 8015are actually further modifications of the ADECmethods, these modifications should bedescribed.

Method detection limits for soil samples are:gasoline range organics (Alaska method),0.5 milligrams per kilogram (mg/kg)(EPA 1986); diesel range organics (Alaskamethod), 1.6 mg/kg (EPA 1986); method 8020,1.0 maicrogramns/kg (CH2M Hill 1992). Since thepurpose of soil samnples analysis is to documentconcentrations of hydrocarbons in soil samplesbefore startup of NAPL recovery systems, thesedetection limits appear to be adequate.

11206.11 (5(R AW693.DFtR2C.6 Page 5

. ~~Section (5), Page (P), etc. Comment (C) and Response (R)

S3, P6 and P7 C8: (continued)

The detection limits, precision, and accuracystandards for soil vapor analyses do not appearto be described in the field sampling plan in thisdocument. The purpose of these soil vaporanalyses is to select locations for NAPL probesand recovery wells. The adequacy of themethod described is uncertain without thisinformation.

R8: Soil analytical methods are discussed inSections 2.3.4 and 3.4.3 of the Draft FinalRemedial Action Workplan for ST-20 (E-9),ST-49, and SS-50-SS-52.

56, P22, ¶1 C9: The shop drawings used to construct theproposed remediation systems and systemspecifications should be included in the100 percent design document.

R9: The shop drawings to be used for constructionwill be modifications of the process andinstrumentation diagram and the plan viewdiagrams shown in Figures 30-34 of the DraftFinal Workplan for ST-20 (E-9), ST-49, andSS-50-SS-52. These drawings will be finalizedto "as-builts" after the system is constructed.

56, P22, ¶3 CIO: The decision to implement a particular remedialtechnology is subject to agreement by EielsonAFB, EPA, and ADEC.

RIO: The decision to implement a particular remedialtechnology will be discussed and agreed upon bythe USAF, EPA, and ADEC in advance of theimplementation.

56, P22, ¶4 Cli1: The change order approval process describedneeds to be more specific. The change controlprocess should identify persons who can initiateand approve a change order, and should specifythe required time frame for change ordersubmittal and approval. The process should beconducted in accordance with Part XX of theEielson AFB Federal Facility Agreement.

11 206.11 (5)fRAW693.DF1R2C.6 Page 6

. ~~Section (5), Page (P), etc. Comment (C) and Response (R)

S6, P22, ¶4 RI 1: The change order approval process is describedmore specifically in Section 6. Eielson AFBwill lead communication with the EPA andADEC to communicate changes to the projectplan.

S7, P23, ¶1 C12: The monitoring, operation, and maintenance planshould specify how pneumatic lines, liquid lines,and NAPL storage containers will be checked forleaks.

R12: Leak detection is discussed in Section 7.1 of theDraft Final Remedial Action Workplan forST-20 (E-9), ST-49, and SS-50-SS-52.

S7.1, P23, ¶6 C13: The work plan states that air injection andheating systems will be started when the averageambient air temperature drops below 400 F. Thedescription of the system startup (bulletnumber 5 on page 24) specifies that thesesystems will be started when the subsurface soiltemperature decreases to 500 F. These twocriteria should be reconciled. Either onecriterion should be specified in both places, orthe relationship between ambient air temperatureand subsurface soil temperature should be furtherexplained.

R13: The soil heating system will be started when thesubsurface soil temperature drops below50 degrees F. The target soil temperature thatwill be maintained by the heating is40 degrees F. These criteria are described in theDraft Final Remedial Action Workplan forST-20 (E-9), ST-49, and SS-50-SS-52.

S7.2, P24 and P25 C 14: NAPL pumping system design and constructionmethods were not described in the work plan.The locations of vapor extraction wells, recoverywells, aquifer air sparging wells, and airinjection wells were not specified for each site.These locations should be specified.

R 14: A NAPL pumping system will be implemented ifand where appropriate by installing NAPL-onlypumps powered by compressed air. The designwill be based on this "stock" pumping systemand will be tailored to the specific site.

11206 II(5YRAW693 DFIR2C.6 Page?7

. ~~Section (5), Page (P), etc. Comment (C) and Response (R)

S7.2, P24 and P25 R14: (continued)

Complete plan details will not be available foreach site until the site characterization tasks arecompleted.

11206.1I(5yfRAW693.DFI2C.6 PageS