Waste Management Plan

Transcription

1 Final July 31, 2009 Waste Management Plan Annual Monitoring and Inspections Operable Unit A Former Naval Complex Adak, Alaska Department of the Navy Naval Facilities Engineering Command Northwest 1101 Tautog Circle, Suite 203 Silverdale, WA

2 CONTRACT NO. N D-4005 LTM/O / TASK ORDER 02 FINAL WASTE MANAGEMENT PLAN LONG-TERM MONITORING LONG-TERM OPERATIONS AT OPERABLE UNIT A FORMER NAVAL COMPLEX, ADAK, ALASKA SEALASKA ENVIRONMENTAL SERVICES, LLC July 31, 2009 Prepared by: Cara Alferness Project Quality Control Manager ( ) Approved by: Annette Franzen Task Order Manager ( )

3 CONTENTS 1. INTRODUCTION MANAGEMENT OF WASTE STREAMS FIELD TEST KIT WASTE PURGE WATER AND DECON WATER Decontamination Water Purge Water from Petroleum Sites Purge Water from CERCLA Sites LIQUID-PHASE HYDROCARBON (LPH) LPH-CONTAMINATED ABSORBENTS, RAGS, SAMPLING DEBRIS, AND PPE COMMON TRASH PROJECT ORGANIZATION SPILL PREVENTION AND REPORTING SPILLS AND RELEASES SPILL RESPONSE AND EMERGENCY EQUIPMENT SPILL PREVENTION TRAINING AND RECORDKEEPING REQUIREMENTS SITE-SPECIFIC ORIENTATION TRAINING REFERENCES WASTE MANAGEMENT PLAN CERTIFICATION 7-1 APPENDICES APPENDIX A NAVFAC NORTHWEST SOP I -A-7 (September 2006 Version; Revised May 2009 by Sealaska for Adak LTM/O) TABLES Table 4-1. Contact List and Telephone Numbers for Spills 4-3 FIGURES Figure 1-1. Location Map 1-3 Figure Long-Term Monitoring Sites 1-4 iii

4 ACRONYMS AND ABBREVIATIONS ADEC APP BTEX CERCLA CIH CMP decon DOT DRMO DRO FOL GAC GCI GRO HAZWOPER IATA IDW LPH LTM/O MAUW MSDS NAVFAC NW Navy NMCB non-haz Alaska Department of Environmental Conservation Accident Prevention Plan Benzene, toluene, ethyl benzene, and total xylenes Comprehensive Environmental Response Compensation and Liability Act Certified Industrial Hygienist Comprehensive Monitoring Plan decontamination U.S. Department of Transportation Defense Reutilization Marketing Office Diesel range organics Field Operations Lead granular activated carbon General Communications Inc. Gasoline range organics Hazardous Waste Operations and Emergency Response International Air Transport Association investigation-derived waste liquid-phase hydrocarbon Long-Term Monitoring/Operations Modified Advanced Underwater Weapons material safety data sheet Naval Facilities Engineering Command Northwest U.S. Navy Naval Mobile Construction Battalion non-hazardous iv

5 ACRONYMS AND ABBREVIATIONS (continued) NORPAC NRC NTR OU-A PPE PQCM PAH RCRA ROICC RPM RRO SA Sealaska SIM SOP SSHO SSHP SWMU TCLP TO TOM TSDF UST VOC WMP North Pacific National Response Center Navy Technical Representative Operable Unit A personal protective equipment Project Quality Control Manager polynuclear aromatic hydrocarbons Resource Conservation Recovery Act Resident Officer in Charge of Construction Remedial Project Manager Residual range organics Source Area Sealaska Environmental Services, LLC selected ion monitoring standard operating procedure Site Safety and Health Officer Site Safety and Health Plan Solid Waste Management Unit toxicity characteristic leaching procedure Task Order Task Order Manager treatment, storage, and disposal facility underground storage tank volatile organic compound Waste Management Plan v

6 1. INTRODUCTION This Waste Management Plan (WMP) addresses the procedures and controls that will be implemented by all Sealaska Environmental Services, LLC (Sealaska) employees and its subcontractors involved in the annual Long-Term Monitoring/Operations (LTM/O) at Former Naval Complex, Adak Island, Alaska (Figure 1-1). The work activities for this LTM/O will generate several waste streams, which are identified and discussed in Section 2. The annual LTM/O activities take place at groundwater monitoring wells, which are located throughout Operable Unit A (OU-A) that are known to contain petroleum related compounds as well as some Comprehensive Environmental Response Compensation and Liability Act (CERCLA) related site contaminants in their subsurface soils and groundwater. These wells are located throughout 27 of the 28 sites (there are no wells at Solid Waste Management Unit [SWMU]11, Palisades Landfill). LTM/O activities to be performed in each location for the 2009 field season are included in the Comprehensive Monitoring Plan (CMP), Revision 3, Operable Unit A (URS 2007). An Accident Prevention Plan (APP), which includes the Site Safety and Health Plan (SSHP), has been prepared separately for the LTM/O activities. The Work Plan and Quality Assurance Project Plan are included as part of the CMP. These documents contain additional information about project background, project related tasks and activities, and health and safety requirements for this project. The 28 sites (shown on Figure 1-2) that will have LTM/O activities during the 2009 annual sampling event include: Antenna Field (underground storage tank [UST] ANT-1 thru -4) Area 303 Former Power Plant Building - Building T-1451 General Communications Inc. (GCI) Compound UST GC-1 Housing Area (Arctic Acres) North Pacific (NORPAC) Hill Seep Area Naval Mobile Construction Battalion (NMCB) Building Area T-1416 Expanded Area Resident Officer in Charge of Construction (ROICC) Contractors Area (UST ROICC-7) Runway 5-23 Avgas Valve Pit 1-1

7 Source Area (SA) 78 Old Transportation Building USTs 10583, and ASTs SA 79, Main Road Pipeline South End SA 80, Steam Plant 4 (USTs & 27090) SA 82, P-80/P-81 Buildings SA-88, P-70 Energy Generator, UST South of Runway Area SWMU 14, Old Pesticide Disposal Area SWMU 15, Future Jobs/ Defense Reutilization Marketing Office (DRMO) SWMU 17, Power Plant 3 Area SWMU 55, PW Transportation Department Waste Storage Area SWMU 58 & SA 73, Heating Plant 6 SWMU 60, Tank Farm A SWMU 61, Tank Farm B SWMU 62 New Housing Fuel Leak Tanker Shed UST SWMUs 18/19, White Alice Landfill SWMU 11, Palisades Landfill SWMU 13, Metals Landfill SWMU 25, Roberts Landfill Wastes generated during the sampling events will be handled using Naval Facilities Engineering Command Northwest (NAVFAC NW) standard operating procedure (SOP) I-A-7 (as revised by Sealaska for Adak LTM/O) (Appendix A) and this plan. 1-2

8 Figure 1-1. Location Map 1-3

9 Final Waste Management Plan Figure 1-2. July 31, Long-Term Monitoring Sites 1-4

10 2. MANAGEMENT OF WASTE STREAMS Five waste streams have been identified for these LTM/O activities: field test kit wastes, monitoring well purge water and decontamination (decon) water, liquid-phase hydrocarbon (LPH) from free product recovery activities in wells, LPH-contaminated absorbents, rags, sampling debris, personal protective equipment (PPE), and common trash generated during field work. The following sections describe how the waste streams will be generated, characterized, managed, and disposed. Sealaska will work with NAVFAC Northwest regarding off site disposal of wastes. It is anticipated that wastes requiring off site disposal will be barged off site upon a barge of opportunity. It is possible that a barge will be mobilized to Adak during the contract year 2009/2010 for other U.S. Navy (Navy) contractor work on island. Meanwhile, Sealaska will continue to manage and dispose of wastes per this plan. Sealaska will minimize waste generation through proper planning and work practices (including storage), spill prevention measures, hazardous material inventory control, and prevention of cross-contamination of wastes. 2.1 FIELD TEST KIT WASTE The field test kits will be used to perform various onsite analytical testing in the field. Field test kit testing is scheduled be conducted at approximately 100 wells. Waste generated from the use of field test kits will be segregated into two separate waste streams after use during sampling - liquid and solid waste streams. Liquid waste will be contained in a sealed container (small poly drum or jerry can) and will be labeled as to its contents (Field Test Kit Waste Liquids). The amount of liquid generated by each test is small (about 15 ml per well); therefore, it is anticipated that approximately 1.5 liters of liquid will be generated. Review of the field test kit manufacturer s material safety data sheet (MSDS) has been conducted, and this review indicates that the liquid test kit waste will not be considered hazardous waste. Although some test kit components are both caustic and acidic, the resulting mixture with added deionized or purge water used with the test kits, will not likely be considered corrosive. Test strips or a water quality meter equipped with a ph probe will be on site and can be used to ensure that the ph is not corrosive. Additionally, the amount of methanol present in the test kits before use is not such that the resultant mixture would be considered F-listed waste and would be less than 1.5% in the final liquid waste. The field test kit liquids will be managed as non-hazardous waste, based on review of the manufacturer s information. 2-1

11 Because the test kit liquids are not hazardous waste, no stringent storage or inspection requirements are necessary. The liquid container will be kept closed, and when not in use, can be temporarily stored in one of the garages of a crew member during the active field season. Upon completion of field event, the field test kit liquids will be tested using a ph strip or water quality meter to ensure that ph is between 4 and 10. The liquids will then be combined with petroleum sites well purge water for disposal. Alternate storage of liquid containers will be with the Contract N D-5101, Task Order (TO) 50 materials and wastes being stored in one of the former ammunition bunkers at the former Modified Advanced Underwater Weapons (MAUW) compound. MAUW is located north of Runway 5-23 on the south side of Tundra Road at the southwest corner of the former contractor camp. The solid waste from the field test kits (i.e., glass ampoules, tubes, PPE, etc.) will be bagged and accumulated in a 30-gallon, open-top drum with used PPE. The drum will be labeled to indicate non-hazardous investigation-derived waste (IDW) including PPE ( Non-Haz IDW including PPE ) and include the date, contract, and task order numbers. At the end of the project the debris will be consolidated and disposed of in the Smart Ash burner as part of the TO 50 monthly free product recovery and operations and maintenance activities. 2.2 PURGE WATER AND DECON WATER Each well that is sampled will be purged until it is stabilized as per the procedures outlined in the Work Plan Decontamination Water Most equipment used during the 2009 field event is anticipated to be disposable and will not require decontamination. To prevent the spread of contamination and cross contamination of wells, non-disposable down well monitoring equipment will be cleaned prior to leaving each well. Cleaning will be comprised of an Alconox and tap water wash followed by a distilled water rinse to remove contaminants from the probes and meters (or as modified by the Site Safety and Health Officer [SSHO]). Decon water from the rinsing of sampling equipment and instrumentation will be captured in the same container with the purge water Purge Water from Petroleum Sites As stated in section 7.0 Investigation-Derived Waste Handling of Appendix A and B of the CMP, Revision 3, water from wells that have historically yielded water with no detectable constituents will be disposed of in the following manner. 2-2

12 If the purge water has no detectable sheen or petroleum odor, purge water will be discharged onto the ground near the monitoring well location. The purge water will be discharged so that the water infiltrates the immediate area and no runoff or leachate is created (fully absorbed within the soil). If a sheen or odor is present, purge water will be collected into a drum. To determine if the water is hazardous, the drum contents will be sampled and sent for off-site laboratory analysis. The laboratory will perform the toxicity characteristic leaching procedure (TCLP) prior to analysis of volatile organic compounds (VOCs) and lead. Additionally, analysis of petroleum hydrocarbons will be conducted. Following are the analytes that will be included in the laboratory tests: TCLP VOCs by Method 1311/8260B - benzene, carbon tetrachloride, chlorobenzene, chloroform, 1,2-dichloroethane, 1,1-dichloroethene, methyl ethyl ketone, tetrachloroethene, trichloroethene, and vinyl chloride; TCLP metals by Method 1311/6010 lead only; Gasoline range organics (GRO) by Method AK101; Diesel range organics (DRO) by Method AK102; Residual range organics (RRO) by Method AK103; and Benzene, toluene, ethyl benzene, and total xylenes (BTEX) by Method SW B. While awaiting results, the closed drum will be stored as investigation-derived waste awaiting designation in an indoor waste storage area at the MAUW compound within secondary containment. The drum will be marked with the words investigation-derived waste awaiting designation purge water from Petroleum Sites x, y, z (where x, y, z, etc. are replaced by the actual site names). An accumulation start date will also be added to the drum. This purge water will be clearly identified with the contract number and task order for tracking purposes. If the results of the TCLP sample show the waste is nonhazardous, the markings on the container will be removed or obliterated and the content of the drum will be run through an inline granular activated carbon (GAC) filter unit. After filtering, the water will again be checked for sheen or odor. If necessary, the water will be run through the filter system again. Once the water has no sheen or petroleum odor, the water can be discharged onto the ground at one or several of the petroleum site monitoring well locations. 2-3

13 A waste collection drum will be secured in the back of the work vehicle and will be transported from well to well for accumulation purposes. The drum will be marked as to the content IDW purge water from petroleum sites. Alternatively, the crew may use smaller Jerri cans to hold purge water from the day s activities and then at the end of shift, containerize the purge water into the drum kept in the storage area. The drum or Jerri cans will be kept closed unless actively adding purge water Purge Water from CERCLA Sites Purge water from each well from the four CERCLA sites (SWMU 14, 15, 17, and 55) and three landfill sites (Metals, Roberts, and White Alice) will be collected into a separate drum. The drum will be a closed top, steel U.S. Department of Transportation (DOT) specification drum that is in good condition (no severe dents or rust with secure lid that can be sealed). Prior sampling of the purge water from these CERCLA and landfill sites has shown the purge water was non-hazardous waste and it is anticipated that the water generated in 2009 will also be non-hazardous. The drum contents will be sampled and sent for off-site laboratory analysis. To determine if the water is hazardous, the laboratory will perform the TCLP prior to analysis of VOCs and metals. The following Resource Conservation Recovery Act (RCRA) analytes will be included: TCLP VOCs by Method 1311/8260B - benzene, carbon tetrachloride, chlorobenzene, chloroform, 1,2-dichloroethane, 1,1-dichloroethene, methyl ethyl ketone, tetrachloroethene, trichloroethene, and vinyl chloride. TCLP metals by Method 1311/6000 and 7000 Series arsenic, barium, cadmium, chromium, lead, mercury, selenium, and silver. As it is likely the sample results will be below the TCLP regulatory criteria and the waste determined to be non-hazardous, the samples will also be analyzed for site-specific analytes of concern to determine if the water can be disposed on site. The analyses will include a consortium of analytes of concern from all CERCLA and landfill sites with wells. The following analyses will be performed: VOCs by 8260B trichloroethene, tetrachloroethene, 1,1-dichloroethene, cis-1,2-dichloroethene, trans-1,2-dichloroethene, vinyl chloride, benzene, toluene, ethylbenzene, and xylenes; Gasoline range organics by AK101; Diesel range organics by AK102; 2-4

14 Benzene, toluene, ethyl benzene, and total xylenes (BTEX) by Method SW B; Total arsenic, barium, and lead by 6020; Dissolved (field-filtered) arsenic, barium, and lead by 6020; Bis(2-ethylhexyl)phthalate by 8270C or 8270D using a low level modification; and Polynuclear aromatic hydrocarbons (PAHs) by 8270C or 8270D using selected ion monitoring (SIM). While awaiting results, the closed drum will be stored as investigation-derived waste pending designation in an indoor waste storage area at the MAUW compound within secondary containment. The drum will be marked with the words investigation-derived waste awaiting designation purge water from SWMU 14, 15, 17, 55, Metals Landfill, Roberts Landfill, and White Alice Landfill (as appropriate). An accumulation start date will also be added to the drum. This purge water will be clearly identified as TO 02 for tracking purposes. If the results of the TCLP sample show the waste is nonhazardous and the other analytical results are below all applicable site-specific cleanup levels, the markings on the container will be removed or obliterated and the content of the drum will be run through the inline GAC filter if petroleum sheen or odor is observed and will then be discharged onto the ground at one of the CERCLA sites near a well. If the contents are filtered, and must be stored prior to discharging, the label for the container will add the word Filtered to the name of the waste. If the results of the sample show the waste is hazardous, the Navy Technical Representative (NTR) and Task Order Manager (TOM) will be notified immediately and this WMP will be updated with the appropriate RCRA waste storage, inspection, and disposal criteria. If hazardous waste, the waste will be shipped off-site for disposal at a permitted treatment, storage, and disposal facility (TSDF). 2.3 LIQUID-PHASE HYDROCARBON (LPH) Small quantities of floating LPH that is removed from groundwater wells will be containerized in closed top DOT specification drums. The drums will be labeled as recovered fuel - LPH and as FLAMMABLE or COMBUSTIBLE. The well numbers where the product originated, as well as the quantity recovered, will be recorded in the field logbook along with the container number in which the LPH is accumulated (if more than one). Based on the well information from past sampling and characterization, 2-5

15 the LPH is anticipated to be non-hazardous and suitable for recycling and fuels blending. This LPH will be stored in the TO 50 Free Product Recovery bunker at the former MAUW compound and the containers will be clearly identified as TO 02 product. The recovered LPH will be incinerated of during subsequent TO 50 waste disposal activities in the Smart Ash burner onsite. 2.4 LPH-CONTAMINATED ABSORBENTS, RAGS, SAMPLING DEBRIS, AND PPE LPH-contaminated absorbents, rags, sampling debris, and PPE will be containerized and labeled non-hazardous. If the absorbents or rags are saturated with product or water, the liquids will be wrung out of the solids into the drum containing LPH or into the purge water drum, whichever is appropriate. At the end of the project the debris will be consolidated and transferred to TO 50 for disposal in the Smart Ash burner. 2.5 COMMON TRASH Common trash (lunch waste, office paper, uncontaminated cardboard, etc.) that is generated during work activities will be kept separate from all other field waste and will be placed in appropriate garbage cans or hauled to the city s dump site. 2-6

16 3. PROJECT ORGANIZATION In accordance with the roles and responsibilities of the professional staff positions as described in the Sealaska Corporate Health, Safety, and Environmental Plan, the following individuals will provide the designated support functions on this project: Program Manager: Peter McCormick Task Order Manager (TOM): Annette Franzen Quality Control Program Manager: Mary Schneider Project Quality Control Manager (PQCM): Cara Alferness Field Operations Lead (FOL): Andy Lewis Site Safety and Health Safety Officer (SSHO): Brian Giles Certified Industrial Hygienist (CIH): Steve Frost 3-1

17 4. SPILL PREVENTION AND REPORTING All project personnel will be familiarized with the response and reporting requirements contained herein. 4.1 SPILLS AND RELEASES A spill is any unauthorized release, including leaking, pumping, emitting, emptying, discharging, injecting, escaping, leaching, disposing, or dumping of oil or a hazardous substance. For this project, the only anticipated material that could spill would consist of gasoline or diesel used onsite for vehicles or generators, or spilled LPH from the wells. The names, telephone numbers, and reportable quantities requiring notification to state and federal agencies are as follows. Emergency and non-emergency spills are defined in the following subsections. Emergency Spill Event Emergency spills are defined as: A spill that presents an immediate threat to human health, property, or the environment; A spill of a substance that is unknown to the person discovering the spill; A spill that has the immediate potential to enter or has entered a drain or waterway; A spill that requires the cleanup assistance of an outside source or a governmental agency; and/or A spill that is more than 55 gallons. If the spill is an EMERGENCY SPILL EVENT, the on-site personnel must immediately take appropriate action to control the emergency. If the properties of the hazardous material spilled are not known, or if there is a threat to human health or the environment, the area will be evacuated immediately. Personnel will be restricted from the immediate area and instructed to remain upwind. Initial spill containment and cleanup will only be attempted if it can be done without endangering the safety and health of any personnel. 4-1

18 Immediately after the initial emergency is controlled, the FOL/SSHO or designee will notify the on-site NTR and make a telephone call to: Peter McCormick, Sealaska Program Manager; and Annette Franzen, Sealaska TOM Upon notification of the emergency spill event, the TOM or Program Manager will immediately contact the Navy Remedial Project Manager (RPM) or his alternate. Sealaska will assist the Navy in reporting the spill to the appropriate regulatory agencies: Alaska Department of Environmental Conservation (ADEC) or the National Response Center (NRC) through the RPM, as required. Contact phone numbers for ADEC and NRC are located at the bottom of page 4-3. The Program Manager and TOM will assist the FOL or SSHO as appropriate to implement Sealaska s Spill/Release Reporting Procedures and a written incident report will be submitted within 24 hours. ADEC requires notification of spills as follows: Any release of oil to water must be reported as soon as the person has knowledge of the discharge. Oil to Land Any release of oil in excess of 55 gallons must be reported as soon as the person has knowledge of the discharge. Any release of oil in excess of 10 gallons but less than 55 gallons must be reported within 48 hours after the person has knowledge of the discharge. Any person in charge of a facility or operation shall maintain, and provide to ADEC on a monthly basis, a written record of any discharge of oil from 1 to 10 gallons. The NRC must be notified of any spill of oil in excess of 42 gallons to land or any discharges of oil must be reported if they cause a film or sheen upon or discoloration of the surface of the water or adjoining shorelines or cause a sludge or emulsion to be deposited beneath the surface of the water or upon adjoining shorelines. Non-Emergency Spill Event Non-emergency spills are defined as a discharge of a known material or hazardous substance that can be cleaned up by Sealaska personnel without posing an immediate threat to human health or the environment. 4-2

19 For a non-emergency spill: Stop the source of the spill if safe to do so; Contain the spill by keeping it away from drains or waterways and blocking off drains located near the spill if there is a chance the spill will reach them; Clean up the spilled material wearing the proper PPE; Handle the spill debris/material such as the PPE in accordance with the WMP (this section); Immediately notify the TOM and NTR, then TOM or NTR will notify the RPM; and An incident report may be required, and notification of regulatory agencies may be required (be prepared to communicate the source of the spill, amount spilled, what was affected by the spill, etc. to the TOM and NTR). Table 4-1 lists the contact information for the Navy and Sealaska contacts. Table 4-1. Contact List and Telephone Numbers for Spills Adak Communication Center Emergency 911 NTR, Brian Cullen Radio communication; RPM, Layna Goodman Sealaska Program Manager, Peter McCormick or Sealaska Program Health and Safety Manager, Steve Frost Sealaska TOM, Annette Franzen Radio communications; Adak, tbd; mobile: Sealaska SHSO, Brian Giles Radio communications; Adak, tbd; mobile: Sealaska FOL, Andy Lewis Radio communications; Adak, tbd; mobile, Note: Mobile phone numbers will have voice messages directing callers to Adak Island telephone numbers. The Navy will either notify ADEC of the discharge or direct Sealaska to make the initial notification if agency notification is required. The telephone numbers for the regulatory agencies are listed below in the event that the spill is deemed a reportable spill: Alaska Department of Environmental Conservation (907) or (800) National Response Center (800)

20 4.2 SPILL RESPONSE AND EMERGENCY EQUIPMENT The project site will maintain the following spill response/emergency equipment on site: Working telephone with an outside line; Portable Class ABC fire extinguishers of the amount and size required by the local fire code staged conspicuously at each project site or storage area where flammable materials are stored or used; Project-specific spill reporting requirements and ADEC spill notification poster posted by the telephone and in site vehicles; Spill kits, including absorbent pads, absorbent booms, kitty litter, and PPE of sufficient quantity and type for the operation at hand; Spare drums that can be used to replace damaged drums; Emergency eye wash stations; Shovels and brooms that are accessible in the event of a spill; and Trained site personnel familiar with this plan and basic emergency spill response procedures. Personnel working at the site will be familiar with the emergency equipment locations and procedures for handling and reporting a release. 4.3 SPILL PREVENTION Spill prevention will be addressed throughout project activities with the crew performing the work tasks through training and familiarization with this section and with the equipment and materials being handled on site. Care will be exercised to evaluate each task for the potential of causing a spill before beginning the task. In areas where spills are possible, appropriate precautions will be taken to minimize potential spills. These precautions are outlined below. A means of overflow prevention (dipstick or flashlight) allowing operator to check fullness of drum during filling operations and to stop when appropriately full; A means to capture excess fluids if an overflow does occur while being filled (duck pond or drum spill base underneath the drum being filled); Secondary containment structures must be placed under each container storing or accumulating LPH product. Secondary containment must hold 10% of all the containers content in that area or 100% of the largest container in the area. 4-4

21 If outdoor container storage is required (not preferred), the secondary containment structure must hold 110% of the largest container volume and the area must be maintained with that capacity (means rainwater accumulations must be evaluated and removed promptly). If storing outdoors, cover and secure the containers and the secondary containment to help minimize the potential for rainwater accumulation within the secondary containment structure. Even a residue of LPH on a container can cause a sheen and then the water in the containment must be containerized for disposal; Routine inspection of the recovery sites that includes secondary containment structure, condition of containers, fullness of containers, etc.; and If there is no sheen within the secondary containment, the rainwater may be disposed of on the ground at least 100 feet from the nearest surface water body. The Site Superintendent (or designee) will evaluate the rainwater before release and record the inspection and event in the site logbook. If a sheen is noted, the accumulated rainwater will be contained in 30-gallon drums and transported off-site to an approved TSDF. If available, a poly overpack with twist on lid may be used to store the drum. This overpack will eliminate the potential for rainwater accumulations as long as the lid is kept on at all times. 4-5

22 5. TRAINING AND RECORDKEEPING REQUIREMENTS 5.1 SITE-SPECIFIC ORIENTATION TRAINING All site personnel will have had 40-hour Hazardous Waste Operations and Emergency Response (HAZWOPER) course or, if already HAZWOPER certified, personnel will have a current 8-hour HAZWOPER refresher. In addition, during site orientation, personnel will be trained on the waste management procedure NAVFAC NW SOP I-A-7 (as updated for this WMP); and will be trained to implement this WMP. Employees involved with the shipment of hazardous materials, including wastes, will have training on 49 Code of Federal Regulations (DOT Hazardous Material Regulations); and, if involved with shipping hazardous materials by air carrier (i.e., shipment of hazardous material samples such as fuel (product) to the laboratory), will have training on International Air Transport Association (IATA) regulations. The FOL and SSHO will provide and document site-specific orientation training during the project site kickoff meeting and whenever new workers arrive on site. No site workers will be allowed to begin work on site until the site-specific training is completed and documented by the FOL and SSHO. Training for this WMP will be done concurrently with the orientation training requirements in the SSHP. 5-1

23 6. REFERENCES U.S. Navy Final Comprehensive Monitoring Plan, Revision 3, Operable Unit A, Former Adak Naval Complex, Adak, Alaska. Prepared by URS Group, Inc., for Naval Facilities Engineering Command, Northwest, under Contract No. N D-5100, Task Order 021. Silverdale, Washington. May

24 7. WASTE MANAGEMENT PLAN CERTIFICATION By their signature, the following undersigned site workers or visitors certify that this plan has been read, or otherwise communicated to them. They further certify that they completely understand this plan and will follow its procedures. NAME DATE 7-1

25 APPENDIX A NAVFAC NW SOP I-A-7 (SEPTEMBER 2006 VERSION; REVISED MAY 2009 BY SEALASKA FOR ADAK LTM/O)

26 NAVFAC NW Standard Operating Procedure Number: I-A-7 September 2006 Version Revised May 2009 Specifically Task Order 02 Page 1 of 15 IDW MANAGEMENT 1.0 PURPOSE This standard operating procedure (SOP) describes the activities and responsibilities of the U.S. Naval Facilities Engineering Command Northwest (NAVFAC NW) and their subcontractors with regard to management of investigation-derived waste (IDW). The purpose of this procedure provides guidance for the minimization, handling, labeling, temporary storage, and inventory of IDW generated during site investigations and remediation projects conducted under the direction of NAVFAC NW. Each base may have specific required procedures. These procedures are made available to the contractor through the NAVFAC Naval Technical Representative (NTR) or other government point of contact. This SOP is also applicable to personal protective equipment (PPE), sampling equipment, decontamination fluids, non-idw trash, non-indigenous IDW, and hazardous waste and other regulated wastes generated during implementation of site investigations and removal or remedial actions. The information presented will be used to prepare and implement Work Plans (WP), Field Sampling Plans (FSP), and Waste Management Plans (WMPs) for IDW-related field activities. 2.0 PROCEDURES The procedures for IDW management in the field are described below in Sections 2.1 to 2.5. The implementation of these procedures requires Remedial Project Managers (RPMs) and contractors to perform the following tasks: Minimize generation of IDW, Segregate IDW, Properly handle IDW containers, Properly label IDW containers, Apply good management practices in storing IDW drums and containers, Prepare IDW drum inventories,

27 SOP I-A-7: IDW MANAGEMENT Page 2 of 15 September 2006 version; Revised May 2008 specifically for this Task Order Update and report changes to IDW drum inventories, Perform inspections of IDW containers and storage areas, as required, Prepare IDW containers for proper off-site transportation and disposition, as required. 2.1 IDW MINIMIZATION Remedial Project Managers and contractors shall minimize the generation of onsite IDW to reduce the need for special storage or disposal requirements that may result in substantial additional costs and provide little or no reduction in site risks (EPA 1992). The volume of IDW shall be reduced, by applying minimization practices throughout the course of site investigation activities. These minimization strategies include: 1) material substitution; 2) using proper low-volume drilling techniques; 3) using disposable sampling and PPE; 4) using bucket and drum liners; and 5) segregating non-contaminated IDW and trash from contaminated IDW. Waste minimization strategies and types of IDW expected to be generated shall be documented in the appropriate project plans Material Substitution Material substitution consists of selecting materials that degrade readily or have reduced potential for chemical impacts to the site and the environment. An example of this practice is the use of biodegradable detergents (e.g., Alconox or non-phosphate detergents) for decontamination of non-consumable PPE and sampling equipment. In addition, field equipment decontamination can be conducted using isopropyl alcohol rather than hexane or other solvents (for most analytes of concern), to reduce the potential onsite chemical impacts of the decontamination solvent. Decontamination solvents shall be selected carefully so that solvents, and their known decomposition products, do not result in generation of RCRA hazardous waste Drilling Methods Drilling methods that minimize potential IDW generation should be given priority. Sonic, Hollow stem auger and air rotary methods should be selected, where feasible, over mud rotary methods. Mud rotary drilling produces waste drilling mud, while hollow stem and air rotary

28 SOP I-A-7: IDW MANAGEMENT Page 3 of 15 September 2006 version; Revised May 2008 specifically for this Task Order drilling methods produce relatively low volumes of soil waste. Sonic drilling produces the least amount of waste. Small diameter borings and cores shall be used when soil is the only matrix to be sampled at the boring location; the installation of monitoring wells requires the use of larger diameter borings. Soil, sludge, or sediment removed from borings, containment areas, and shallow test trenches shall not be returned to the source, unless allowed by regulation and included in the approved WP, FSP, or WMP Decontamination Fluids The use of disposable sampling equipment, such as plastic bailers, trowels, and drum thieves, when feasible (which do not require decontamination) minimizes the quantity of decontamination fluids generated. When it is appropriate to perform decontamination of non disposable sampling equipment, the generation of decontamination fluids should not be minimized because the integrity of the associated analytical data may be affected with lesser rinsate use PPE and Disposable Sampling Equipment Visibly soiled PPE and disposable sampling equipment shall be segregated from non-visibly soiled PPE and sampling equipment. Where investigation involves potentially hazardous waste or other regulated wastes, visibly soiled PPE and disposable sampling equipment may require decontamination. The RPM or designee and contractor shall use best professional judgment to determine if decontamination is appropriate. This determination should be included in the approved WP, FSP, or WMP. If decontamination is performed, PPE and disposable sampling equipment generated in the decontamination process may be double-bagged and disposed of as non-hazardous waste Liners Bucket liners can be used in the decontamination process to reduce the volume of solid IDW-generated and reduce costs on larger projects. The plastic bucket liners can be crushed into a smaller volume than the buckets, and only a small number of plastic decontamination buckets

29 SOP I-A-7: IDW MANAGEMENT Page 4 of 15 September 2006 version; Revised May 2008 specifically for this Task Order are required for the entire project. Larger, heavy-duty, 55-gallon drum liners can be used for heavily contaminated IDW to provide secondary containment, and reduce the costs of disposal and drum recycling. Drum liners may extend the containment life of the drums in severe climates and will reduce the costs of cleaning out the drums prior to recycling Segregation of non-idw All waste materials generated in the support zone are considered non-idw trash. To minimize the total volume of IDW, all trash shall be separated from IDW, sealed in garbage bags, and properly disposed of offsite as municipal waste Monitoring Well Construction Excess cement, sand, and bentonite grout prepared for monitoring well construction shall be kept to a minimum. Well construction shall be observed by the contractor to ensure that a sufficient, but not excessive, volume of grout is prepared. Some excess grout may be produced. Unused grout that has not come in contact with potentially contaminated soil or ground water shall be considered non-hazardous trash and shall be disposed of offsite by the drilling subcontractor. Surplus materials from monitoring well installation, such as scrap PVC sections, used bentonite buckets, and cement/sand bags that do not come in contact with potentially contaminated soil, shall be considered non-idw trash and shall be disposed of offsite by the drilling subcontractor Field Analytical Test Kits IDW generated from the use of field analytical test kits consists of those parts of the kit that have been used and/or come into contact with potentially contaminated site media, or excess extracting solvents and other reagents. Potentially contaminated solid test kit IDW shall be contained in plastic bags and stored with PPE or disposable sampling equipment IDW from the same source area as soil material used for the analyses. The small volumes of waste solvents, reagents, and water samples used in field test kits should be segregated, and disposed of accordingly (based upon the characteristics of the materials, MSDS sheets, and as described in the WMP). Most other test kit materials should be considered non-idw trash, and be disposed of as municipal waste.

30 SOP I-A-7: IDW MANAGEMENT Page 5 of 15 September 2006 version; Revised May 2008 specifically for this Task Order 2.2 SEGREGATION OF IDW BY MATRIX AND LOCATION To facilitate subsequent IDW screening, sampling, classification and/or disposal, IDW shall generally be segregated by matrix and source location at the time it is generated. Each drum of solid IDW shall be completely filled, when possible. For liquid IDW, drums should be left with headspace of approximately 5% by volume to allow for expansion of the liquid and potential volatile contaminants. IDW from each distinct matrix shall be stored in a single drum (e.g., soil, water or PPE shall not be mixed in one drum). In general, IDW from separate sources should not be combined in a single drum. It is possible that monitoring well development and purge water will contain suspended solids, which will settle to the bottom of the storage drum as sediment. Significant observations on the turbidity or sediment load of the development or purge water shall be included in the logbook and reported in attachments to the quarterly drum inventory report (see SOP III-D, Logbooks and Section 2.5). To avoid having mixed matrices in a single drum (i.e., sediment and water), it may be necessary to decant the liquids into a separate drum, after the sediments have settled out. This segregation may be accomplished during subsequent IDW sampling activities or during consolidation in a holding tank prior to disposal. Potentially contaminated well construction material shall be placed in separate containers. Soil, sediment, sludge, or liquid IDW shall be segregated from potentially contaminated waste well construction materials. Potentially contaminated well construction materials from different monitoring wells shall not be commingled. Potentially hazardous PPE and disposable sampling equipment shall be segregated from other IDW. PPE from generally clean field activities, such as water sampling, shall be segregated from visibly soiled PPE, double-bagged and disposed of offsite as municipal waste. Disposable sampling equipment from activities such as soil, sediment, and sludge sampling includes plastic sheeting used as liner material in containment areas around drilling rigs and waste storage areas; disposable sampling equipment; and soiled decontamination equipment. Where investigation involves potentially hazardous waste, visibly soiled PPE and disposable sampling equipment may require decontamination. The RPM and contractor shall use best professional judgment to determine if decontamination is appropriate. If decontamination is performed, PPE and

31 SOP I-A-7: IDW MANAGEMENT Page 6 of 15 September 2006 version; Revised May 2008 specifically for this Task Order disposable sampling equipment generated in the decontamination process may be double-bagged and disposed of as non-hazardous waste. PPE and disposable sampling equipment generated on separate days may be commingled. Decontamination fluids shall be stored in drums separate from other IDW. If practical, decontamination fluids generated from different sources should not be stored in the same drum. If decontamination fluids generated over several days or from different sources are stored in a single container, information regarding dates of generation and sources shall be recorded in the field notebook, on the drum label (Section 2.3.2), and in the drum inventory (Section 2.5). Liquid and sediment portions of the equipment decontamination fluid in the containment unit used by the drilling or excavation field crew should be separated. The contents of this unit normally consist of turbid decontamination fluid above a layer of predominantly coarse-grained sediment. When the contents of the containment unit are to be stored in IDW containers, the RPM or contractor shall direct the placement of as much liquid into drums as possible, leaving a 5% head space, and transfer the remaining solids into separate drums. Observations of the turbidity and sediment load of the liquid IDW should be noted in the field notebook, on the drum label (Section 2.3.2), and in attachments to the drum inventory (see Section 2.5). It is likely that decontamination fluids will contain minor amounts of suspended solids that will settle out of suspension to become sediment at the bottom of IDW storage drums. As noted above, it may be necessary to segregate the drummed water from sediment during subsequent IDW sampling or disposal activities. 2.3 DRUM HANDLING AND LABELING Drum handling consists of those actions necessary to prepare an IDW drum for labeling. Drum labeling consists of those actions required to legibly and permanently identify the contents of an IDW drum. Specific handling, storage, and labeling requirements may differ with the Naval installation or oversight entity. Specific requirements should be determined at the planning stage and documented in the WMP. General requirements are provided in the following sections.

32 SOP I-A-7: IDW MANAGEMENT Page 7 of 15 September 2006 version; Revised May 2008 specifically for this Task Order Drum Handling The drums used for containing IDW shall be approved by the United States Department of Transportation (DOT, 49 CFR 172). The drums shall be made of steel or plastic, have a 55-gallon capacity, be completely painted or opaque, and have removable lids (i.e., 1A1 or 1A2). New steel drums are preferred over recycled drums. For short-term storage of liquid IDW prior to discharge or shipment, double-walled bulk steel or plastic storage tanks may be used. Consideration must be given to scheduling and cost-effectiveness of bulk storage, treatment, and discharge system versus longer-term drum storage. For long-term IDW storage, the DOT-approved drums with removable lids are recommended. The integrity of the foam or rubber sealing ring located on the underside of some drum lids shall be verified prior to sealing drums containing IDW liquids. If the ring is only partially attached to the drum lid, or if a portion of the ring is missing, a drum lid with sealing ring that is in good condition must be used. At some facilities, drums containing liquid IDW will be required to be stored in protective overpacks. To prepare IDW drums for labeling, the outer wall surfaces and drum lids shall be wiped clean of all material that may prevent legible and permanent labeling. If potentially contaminated material adheres to the outer surface of a drum, the outer drum surface will be decontaminated by wiping that material from the drum, and the paper towel or rag used to remove the material shall be segregated with visibly soiled PPE and disposable sampling equipment. When generating IDW in drums, consideration should be given to ensure a safe and available means of handling and moving the drums is available. Consideration as to getting drums into and out of vehicles and into and out of storage areas may include assessment of proper material handling equipment (i.e. forklift, pallet jack or drum dolly, etc.) and a means to safely get the drum in and out of the transport vehicle when full. As an option to handling a full 55-gallon drum in the field, smaller intermediate containers may be used for daily accumulations and then the liquids transferred into the IDW drum (in storage area) at the end of the shift. Intermediate containers must also have proper markings as to their contents and must be compatible with the material placed inside.

33 SOP I-A-7: IDW MANAGEMENT Page 8 of 15 September 2006 version; Revised May 2008 specifically for this Task Order Drum Labeling Proper labeling of IDW drums is essential to the success and cost-effectiveness of subsequent waste screening and disposal activities. Labels shall be permanent and descriptive to facilitate correlation of field analytical data with the contents of individual IDW drums Preprinted Labels A preprinted drum label as required by the appropriate Naval installation and/or regulatory agency shall be completed. The label will be affixed to the outside of the drum (or overpack if required) with the label easily readable for inspections and inventory. Label requirements may vary based on the site. The requested information shall be printed legibly on the drum labels in black, indelible ink. Instructions for entering the required drum-specific information for each label field are provided by the NTR/RPM. Painted Labels An alternative method for labeling drums, if acceptable for the project is to paint label information directly on the outer surface of the drum. At a minimum, the information placed on the drum shall include the contract/delivery order number, a drum number, the source identification type and number, the type of IDW, the generation date(s), and the government point of contact and telephone number. The drum surface shall be dry and free of material that could prevent legible labeling. Label information shall be confined to the upper two-thirds of the total drum height. The printing on the drum shall be large enough to be easily legible. Yellow, white, or red paint markers (oil-based enamel paint) that are non-photodegradable are recommended to provide maximum durability and contrast with the drum surface Regulatory Marking and Labeling Federal and State regulations may require specific labeling for IDW generated (i.e., RCRA, TSCA, NESHAPs). Pre-printed labels shall be used as appropriate and completed in accordance with the specific regulatory requirement. These requirements will be identified in the approved

34 SOP I-A-7: IDW MANAGEMENT Page 9 of 15 September 2006 version; Revised May 2008 specifically for this Task Order project plans. Once determined to be hazardous, weekly inspections must be conducted to ensure that labels and markings are in good conditions and to ensure the integrity of containers. In addition, prior to off-site transportation USDOT requirements for marking and labeling of regulated DOT materials must be complied with. These requirements will be identified in the approved project plans or otherwise coordinated with the RPM or designee and contractor after the IDW has been characterized and off-site disposition is being planned. Note that personnel (i.e., contractors or subcontractors) who perform USDOT functions or RCRA hazardous waste handling must be properly trained in accordance with 49 CFR 172, Subpart G and 40 CFR Any EPA hazardous waste manifest will be signed by the appropriately trained NTR on island as the government representative. 2.4 DRUM STORAGE Drum storage procedures shall be implemented to minimize potential human contact with the stored IDW and prevent extreme weathering of the stored drums. Waste accumulation areas will be pre-designated by NAVFAC NW prior to the start of site work. IDW drums should be placed on pallets. Good management practices should be used in storing drums which include: containers shall be in good condition and closed during storage; wastes must be compatible with containers; where liquids are stored, storage areas should have secondary containment; and spill or leaks should be removed as soon as possible. These good management practices are mandatory requirements where RCRA hazardous wastes are stored. Waste accumulation areas shall be maintained as prescribed by local regulatory entities and the appropriate Naval installation. In general, drums of IDW shall be stored within the Area of Concern (AOC) so that the site can utilize RCRA regulatory flexibility (i.e., administrative requirements, such as 90-day storage, may not be triggered; and Land Disposal Restrictions (LDRs) will not be triggered if IDW is placed back in AOC). If IDW is determined to be RCRA hazardous waste, then RCRA storage, transportation and disposal requirements must be met. Drums shall be stored at identified waste accumulation areas. All IDW drums generated during field activities at a single AOC shall be placed together, in a secure, fenced onsite area to prevent access to the drums by unauthorized personnel. When a secure area is not available, drums shall