Contaminated Media Management Plan

173d Fighter Wing Oregon Air National Guard Kingsley Field Klamath Falls, Oregon

July 2014

Prepared For:

Oregon Department of Environmental Quality FINAL

TABLE OF CONTENTS

LIST OF FIGURES ii

LIST OF ACRONYMS iii

SECTION 1.0 INTRODUCTION 1-1 1.1 CMMP DESCRIPTION 1-2

SECTION 2.0 CONTAMINATED MEDIA MANAGEMENT 2-1 2.1 Identification of Potentially Contaminated Media 2-1 2.2 Determination & Identification of Contaminated Media 2-2 2.3 Excavating and Storage of Contaminated Media 2-3 2-4 Sampling & Testing Requirements 2-3 2-5 Disposal of Contaminated Media 2-5

SECTION 3.0 WORKER SAFETY & TRAINING 3-1 3.1 Health and Safety Plan 3-2 3.2 Worker Training 3-3

APPENDIX 1 - BACKGROUND HISTORY & CIP 4-1

i FINAL

LIST OF FIGURES

FIGURE 1 Site Map

FIGURE 2 Site TU015

FIGURE 3 Site PL016

ii FINAL

LIST OF ACRONYMS

Acronym Definition ORANG Oregon Air National Guard CMMP Contaminated Media Management Plan ERM ERM-West, Inc. 173FW 173d Fighter Wing HASP Health and Safety Plan NAP Naphthalene ODEQ Oregon Department of Environmental Quality OSHA Occupational Safety and Health Administration PSH Phase-separated hydrocarbons RBC Risk-based concentration TMB Tri-methylbenzene HAZWOPER Hazardous Waste Operations and Emergency Response IRP Installation Restoration Program NPL National Priority Listing RCRA Resource Conservation and Recovery Act EMO Environmental Management Office (173FW) SOW Statement Of Work

iii FINAL

SECTION 1.0

INTRODUCTION

1.1 CMMP Description

This Contaminated Media Management Plan (CMMP) provides guidance for managing contaminated soil and groundwater encountered during earthwork-related construction activities at Kingsley Field, located in Klamath Falls, Oregon (Figure 1). The purpose of this CMMP is to minimize risks to worker health and the environment by outlining procedures for the identification, handling, and disposal of petroleum contaminated soil and groundwater that may be encountered during future earthwork-related construction activities.

 This document is NOT intended to address requirements for an initial/immediate response to a contamination event, (such as an aircraft fuel spill).

 This document identifies specific geographic areas of concern that have been established as a clean-up site and are in either active or former “clean-up” site status. Provided in the following sections is the background information of the contaminated areas that have been identified as impacted by the release of hazardous materials by the U.S. Environmental Protection Agency (EPA) and the Oregon Department of Environmental Quality (ODEQ).

 This CMMP is a locally derived document and is not a standard or regulation. This document is advisory in nature and informational in content; it is intended to assist Kingsley Field personnel and Contractors to execute a safe and healthful workplace for compliance with Federal, State and Local regulations.

 The 173FW EMO will periodicaly review this document and update as necessary.

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1.2 Installation Description

The Kingsley Field is located in the City of Klamath Falls, of Klamath County, in southern Oregon; and is situated on the western side of the Crater Lake Regional Airport. A site location map is presented as Figure 1.

Kingsley Field was originally formed as a United States Naval Air Station during World War II. Subsequently, the station was deactivated and the property was transferred back to the City of Klamath Falls. In 1954, the United States Air Force obtained portions of the airport and the ANG became the main tenant during the early 1980s. Kingsley Field was officially recognized as an ANG installation in 1984

Based on investigations and corrective measures implemented at various clean-up sites across Kingsley Field, contaminated soil and/or groundwater may be encountered during future earthwork-related construction activities in the area. The following is a list and background of Active, and Former Clean-Up sites where future contamination may be encountered.

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SECTION 2.0

CONTAMINATED MEDIA MANAGEMENT

This section provides guidance for the identification, characterization, handling and disposal of contaminated soil and groundwater that may be encountered during earthwork-related construction activities at the site. All contractors are required to test and manage contaminated media in accordance with ODEQ requirements. Testing and special handling requirements are necessary for proper storage, transportation and disposal.

2.1 Identification of Potentially Contaminated Media

Each party involved in any earthwork-related construction activities at the site shall be solely responsible for identification of contaminated soil and groundwater. Each contractor shall monitor soil, groundwater, vapors, and any waste material for evidence of contamination. If site personnel observe media exhibiting characteristics of contaminant impacts, the media in question shall be identified as “potentially impacted” and will be managed as if contaminated until further determination can be made. The following field observations can be used to screen potentially impacted media:

 Staining of soil;

 Chemical or petroleum odors;

 Measurements made with a photoionization detector;

 Sheen on water;

 Sheen on moist or saturated soil; and

 Groundwater, if removed in the proximity to impacted soils.

Note that the absence of these characteristics does not necessarily imply that the media does not contain contaminants. Some forms of soil and

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groundwater contamination are only detectable with the use of environmental testing equipment or analytical testing. If unexpected hazardous or contaminated materials are encountered, the contractors shall:

 Stop all work in that area;

 Notify the 173d Environmental Manager immediately;

 Ensure no contaminated material is hauled from the site;

 Remove the work force from the immediate area of the contamination;

 Involve an environmental consultant and/or the ODEQ; and

 Secure the area from access by the public until such time as all parties involved have verified that site work can be completed in accordance with the HASP and this CMMP.

2.2 Determination & Identification of Contaminated Media

173FW EMO will assist in the contractor’s determination of the identified “potentially impacted” as contaminated media. The EMO will provide background information contained in APPENDIX 1 and other pertinent Base Records to aid in the identification of the type of potential contamination and selection of analytical testing that may be required. In most cases, if the soil/water displays the characteristics of contaminated media, and has been excavated in the vicinity of an Active or Former Clean-up site, The 173FW EMO will consider the media as contaminated, and will require the contractor to treat the media as such, until additional analysis conducted by the contractor could prove otherwise.

 The contractor is ultimately responsible to make the determination that the media is(is not) contaminated, and to identify the contaminates for the purpose of health, safety, and disposal of the media.

 When potentially impacted media is encountered, 173FW/CE will document the outcome of the determination and place in office files to be included in future updates of this plan.

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2.3 Excavating and Storage of Contaminated Media

Contaminated soil and/or groundwater must be stored and disposed of in accordance with all ODEQ requirements.

The following steps will be taken to store or stockpile contaminated media at Kingsley Field:

 Contaminated soil will only be stockpiled on a temporary basis, while making arrangements for disposal or treatment. Contaminated soil will be containerized in a roll-off bin or stockpiled in an approved storage area that is lined and covered by durable plastic sheeting, and bermed to control run-on/runoff.

 Contaminated groundwater will be placed in 55-gallon steel drums. The drums will be placed in a designated secured storage area on site or at an approved alternate storage area.

Site workers will comply with Best Management Practices for erosion and sediment control to prevent further exposure or cross contamination of contaminated media.

2.4 Sampling & Testing Requirements

Soil / Water sampling & testing requirments will be influenced by the determination made in section 2.2. Sampling may be required to validate Media Disposal methods and Health & Saftey procedures during handling. Testing methods for Media Disposal is different than those used to establish Health and Safety.

If user knowledge is not sufficient to establish a complete Waste Disposal determination, a composite soil and/or groundwater sample will be collected to determine waste class for disposal. Any waste facility that is in consideration for receiving soil/water from the site (e.g., landfill) should be contacted as to their requirements for acceptance of contaminaed media, as they may have a unique set of LDRS for their specific facility, LDRS may drive additional sampling & testing requirments.

SAMPLING;

 All samples should be stored in a cooler below 4°C until submitted to analytical laboratory certified by the Oregon and/or National Environmental Laboratory Accreditation Program. Quality control

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and quality assurance protocols should be followed. Chain-of- custody documentation needs to be maintained. Analytical method reporting limits need to be less than regulatory screening criteria..

 All personel accomplishing a field sample shall utilize all PPE and saftey precautions necessary to protect themeselves from exposure to the contaminants that are suspected to be present while collecting the sample.

TESTING; Samples should be analyzed for suspected contaminants including:

 If presence of Petroleum,Oils & Lubricants (POL) are detected by field screening, samples should be analyzed for Total Petroleum Hydrocarbons by Northwest Methods NWTPH-Gx and NWTPH- Dx.

 If volatile compounds are indicated by field screening, samples should be analyzed for Volatile Organic Compounds by United States Environmental Protection Agency Methods 8021, 8260, or a comparable method.

 If POL or petroleum-related contaminants are detected, additional follow-up analyses (e.g., metals, polynuclear aromatic hydrocarbons) may be necessary.

 If presence of contaminants considered to be Hazardous Waste are indicated additional analysis must be made. Not all samples would need to be tested for Hazardous Waste or the determination of RCRA compliance; some tests may only be needed for specific containments of concern to comply with local Land Disposal Restrictions (LDRS)

 If compliance with Land Disposal Restrictions (LDRS) are expected, then the contractor must coordinate with the facility to ensure the proper testing is conducted to satisfy the disposal facility’s specific standards and requirments.

 All testing shall comply with standards outlined in EPA, Test Methods for Evaluating Solid Wastes, Physical/Chemical Methods SW 846. SW-846 On-line, methods for the sampling and analysis of wastes: SW-846 On-line.

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2.5 Disposal of Contaminated Media

All excavated soil and/or groundwater that has been determined as contaminated must be removed from the site and disposed of within 30 days. It is the contractors responsibility to make arrangements for the disposal of all contaminated media. These requirements shall be outlined as part of the site plan. A waste profile will be established through a waste disposal contractor for disposal of soil and/or groundwater at an off–site facility. Soils and/or groundwater encountered at the 173FW is expected to be classified as non-hazardous waste, and will be transported by a licensed waste hauler to an off–site facility in accordance with the 173d FW standard waste disposal procedures.

Transportation of contaminated soil and/or groundwater off site requires specific manifesting, licensing, and insurance requirements. Under no circumstances will contaminated soil and or groundwater leave the site without acceptance by the off-site disposal facility. Contractor shall only dispose of Contaminated Soils at facilities approved by the ODEQ. Contact ODEQ and or the Environmental management office for facility approval prior to disposal.

 A copy of DOT Shipping papers, Manifests, and landfill weigh tickets shall all be provided to the 173FW Environmental Management Office for record keeping.

 The EMO shall review all disposal plans prior to waste leaving the installation, to ensure compliance with State, Federal, and DOD regulations

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SECTION 3.0

WORKER SAFETY & TRAINING

This section provides guidance for the requirments to ensure worker saftey & training when exposed to contaminated media.

3.1 Health and Safety Plan (HASP)

If working in an active clean-up site, or contaminated media is encountered, (or is expected to be encountered because of working in or near a historical clean-up site) a HASP is required by the HAZWOPER standard and must be written in accordance with section 1910.120(b) through 1910.120(o). Contamination in the soil and groundwater could pose an unacceptable health risk to workers The contractor is responsible to comply with all applicable sections of the HAZWOPER standard, but, each entity involved in earthwork-related activities is responsible for the safety of their workers. Prior to beginning site activities within the areas of known contamination, each entity shall prepare a site-specific Health and Safety Plan (HASP) in accordance with the HAZWOPER standard to cover safety issues related to site environmental and physical hazards and to describe any training requirements, monitoring, and certifications.

In general the HASP should have the following program elements:  Site evaluation: Before your employees begin work at a new site, a qualified person must evaluate the site to identify hazards and to determine how to control the hazards.

 Organizational structure: Establishes the chain of command for directing site operations and defines employees responsibilities at the site.

 Comprehensive work plan: Defines the work objectives, the employees’ tasks, and the resources employees need to accomplish the tasks.  Site control: Establishes procedures to control employee exposure to hazardous substances before cleanup work begins at the site.

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3.2 Worker Training (HAZWOPER)

Personel working with or near contaminated media on Kingsley Field are required to have HAZWOPER training.. According to the Hazardous Waste Operations and Emergency Response standard: 1910.120, Subdivision 2/H, of the Oregon Administrative Rules.

 If working on a listed and “active” clean-up site; - HAZWOPER training is required

 If working in– HAZWOPER training is required

 If working in any part of the Kingsley Field, where previously undiscovered hazardous substances are encountered – HAZWOPER training is required

 UNLESS; the employer [Prime Contractor] can demonstrate that the operation does not involve employee exposure or the reasonable possibility for employee exposure to safety or health hazards – NO Hazwoper training is required. As mentioned in previous sections, Contractor may be required to provide sampling and testing results as evidence that the contamination is below the RBC levels required to consider the media as contaminated. The 173FW/CE will document how the employer demonstrated this action and place in the appropriate office records.

It is up to the contractor to ensure they meet the requirments contained in the HAZWOPER section 1910.120(e) for training. However In general;(and with many exceptions)

 Site Workers (and their supervisor) that could potentially be exposed to hazardous substances, health or safety hazards are required a minimum of 24-Hour HAZWOPER requirement. (IE general laborers, delivery drivers)

 Site workers (and supervisor) engaged in hazardous substance removal or other activities which expose or potentially expose workers to hazardous substances and health hazards shall comply with the 40- Hour HAZWOPER requirment .( IE equipment operators, dump truck drivers etc. the people who are actually touching the media)

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APPENDIX 1

BACKGROUND HISTORY

See Attached copy of the Installation Community Involvement Plan (CIP). Information contained in section 3.0 Covers in detail the history sites 1-14. Below is information not yet added to the CIP as sites 15 and 16 have received recent decisions of NFA, and project closeout is still underway.

Former Site TU015

Former Site TU015 (former Site 13) is located at the western portion of Kingsley Field (Figure 2). During periods of high groundwater in the spring of 1998 and 1999, base personnel noticed a strong petroleum odor emanating from the storm drain near Building 226. An oily sheen was also observed in a drainage ditch west of Building 223. Investigations into the historical use of petroleum products in the area revealed that former Building 238 was a likely source of petroleum impact and jet fuel was suspected to have been dumped in the floor drains of this building. Other areas of concern included an abandoned or removed oil/water separator beneath the south end of Building 223, a former heating plant with an underground storage tank now occupied by Building 226, and former gas station and vehicle maintenance area northwest of Building 238. As defined in the Corrective Action Plan (ERM-West, Inc. [ERM] 2009), the chemicals of concern in soil and groundwater at Site TU015 include 1,2,4- trimethylbenzene (TMB), 135-TMB, benzene, ethylbenzene, naphthalene (NAP), xylenes (total), gasoline-range organics, diesel-range organics, and mineral insulation oil.

During previous investigations, three petroleum-related soil impacts included an area beneath and to the west and northwest of Building 238,

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an area south of Building 238, and a small area near MW-3. Five petroleum-related groundwater impacts were identified:

 An area beneath and to the west and north of Building 238, with conditions suggesting weathered diesel, gasoline, and kerosene impacts; a hot spot of benzene, NAP, 124-TMB, and 135-TMB groundwater impacts was noted west of Building 238;

 An area south of Building 238, with conditions suggesting weathered diesel and gasoline impacts; a hot spot of benzene impacts and a hot spot of NAP impacts are located within this area;

 An area south of Building 223 characterized by weathered gasoline and kerosene impacts;

 An area west of Building 226 characterized by weathered gasoline impacts; and

 An area near the Former Gas Station characterized by diesel and gasoline impacts (ERM 2009).

In October of 2012, EHC-O® was injected into the subsurface at eight locations around MW-6 and MW-10 to remediate the groundwater to occupational ingestion risk-based concentrations (RBCs). The total mass of EHC-O® near monitoring wells MW-6 and MW-10 was 300 and 450 pounds, respectively. Following implementation of remedial measures at Site TU015, a No Further Action determination was granted for Site TU015 by the Oregon Department of Environmental Quality (ODEQ) in a letter dated 6 September 2013. In May 2014 all 16 monitoring wells were abandoned.

Former Site PL016

Site PL016 is located at the corner of Vandenberg Drive and Bong Street near the Kingsley Field flight line (Figure 3). The site is leased from the City of Klamath Falls until 2045 and no interim changes are planned. Currently, Former Site PL016 is used as a jet fuel storage and distribution facility. The facility includes an R-11 Fuel Truck loading area, a jet fuel and +100 additive distribution facility, and two bulk JP-8 jet fuel storage tanks, all using a series of nearby aboveground storage tanks and a fill stand.

Historically, Site PL016 was used as an aircraft fueling facility and petroleum storage area for Kingsley Field. Between 1994 and 1996, four

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uunderground storage tanks, fuel distribution lines, a fuel island, and approximately 6,500 cubic yards of petroleum-impacted soil were removed from the site. The majority of the soil was treated on site and re-placed. Several rounds of groundwater sampling, limited soil sampling, and additional monitoring well installation were conducted near the excavation, and to the east near the flight line. The results of the site investigations prior to 2009 indicated the presence of phase separated hydrocarbons (PSH) and elevated gasoline-range organics, diesel-range organics, along with benzene, toluene, ethylbenzene, and total xylenes in groundwater and soil at the site.

Benzene and ethylbenzene concentrations in unsaturated and smear zone soils exceeded the ODEQ occupational RBC for vapor intrusion; however, results of the sub-slab vapor sampling in areas near this impact were below the applicable RBCs therefore no active remediation will be required to address the soil impacts. Although smear zone soil results exceeded RBCs for leaching to groundwater, those standards were determined to not be applicable because the smear zone soils are typically saturated (i.e., considered part of the aquifer) and the impact to these soils appears to have originated from groundwater.

Benzene concentrations in groundwater were detected above the occupational RBCs for vapor intrusion into buildings and/or groundwater in excavation. Additionally, gasoline-range total petroleum hydrocarbons was detected in one monitoring well above RBCs for groundwater in excavation (e.g., MW10-19). The vertical extent of impact is generally considered to be the upper 10 feet of saturated sediments beneath the site.

Since December 2007, PSH has consistently been observed in monitoring well MW10-08, at thicknesses ranging from 0.01 to 0.23 feet. The January 2012 occurrence of 0.23 feet of PSH was the highest recorded thickness measured in that well.

Existing concentrations of chemicals of concern (COCs) at Site PL016 were above the applicable and appropriate occupational risk-based concentrations, which required corrective measures by the ODEQ. In an effort to reduce COCs below standards (i.e., occupational volatilization to outdoor air, occupational vapor intrusion into buildings, and construction and excavation worker-groundwater in excavation), implementation of a corrective measure (enhanced aerobic bioremediation) was completed for groundwater near monitoring wells MW10-19, MW16-01, MW16-02, and P10-2.

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The corrective measures at Site PL016 included:

 Injecting EHC-O® into the subsurface at depths between approximately 4 and 15 feet near the monitoring wells exhibiting the highest concentrations of dissolved-phase COCs (MW10-19, P10-2, MW16-01, and MW16-02); and

 Conducting quarterly groundwater performance monitoring and semiannual reporting for one year following injections.

The selected remedy for groundwater at Site PL016 included subsurface application of Cool-Ox™, a peroxygen-based source of hydroxyl radicals to aid chemical oxidation. The planned injections around MW10-8 were delayed until late spring of 2014 due to concerns with weather and concrete repair. However based on discussions with the ODEQ, it was determined that the injections were no longer necessary. In October of 2013, EHC-O® was injected into the subsurface at 35 locations around monitoring wells MW10-19, MW16-01, MW16-02, and P10-2 to remediate groundwater to occupational ingestion risk-based concentrations. Between 95 to 254 gallons of EHC-O® slurry were injected into each injection point at between 5 and 14 feet below ground surface. The total mass of EHC-O® injected near monitoring wells MW10-19, MW16-01, MW16-02, and P10-2 was 11,750 pounds.

The performance monitoring program at Site PL016 consisted of quarterly groundwater sampling and semi-annual reporting until the concentrations of COCs was below cleanup levels for four consecutive quarters.

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FIGURES

File: Created By: Date: Project: F:\Projects\ANG_NGB_Others\K-Falls\0145317 TU015 and PL016 Corrective Action\GIS\Site TU015 Draft PCO WP\Figure 1 (Site Map).mx d Mike Appel 6/16/2014 11:44:18 AM 0160280.07 Arnold Ave Arnold Ave Vandenberg Drive Vandenberg Vandenberg Drive Vandenberg

ERP Site Fairchild Ave TU015 Fairchild Ave Bong St

ERP Site Rand Way Rand Rand Way Rand PL016

SpringSpring LakeLake RoadRoad

Legend Figure 1 Site Map 173d Fighter Wing Property Boundary 173d Fighter Wing Kingsley Field 0 400 800 Klamath Falls, Oregon Feet ³ 06/14 File: Created By: Date: Project: F:\Projects\ANG_NGB_Others\K-Falls\0145317 TU015 and PL016 Corrective Action\GIS\Site TU015 Draft PCO WP\Figure 2 (Draft PCO WP ).mxd Austin Phelps 6/12/2014 11:01:59 AM 0145317

A MW-16

A MW-1

A MW-11 225

A MW-12

A MW-13 MW-10 A A MW-2 238

Arnold Ave Arnold 239 Arnold Ave Arnold

A MW-5 A MW-6

A MW-8 A MW-7 Bong St A MW-3 A MW-9

223 226

A MW-15 A MW-4

A MW-14

224

Legend Figure 2

A Monitoring Well Site TU015 173d Fighter Wing 0 50 100 Feet Kingsley Field ³ Klamath Falls, Oregon

06/14 File:211 Created By: Date: Project: F:\Projects\ANG_NGB_Others\K-Falls\0145317 TU015 and PL016 Corrective Action\GIS\Draft CMMP\Figure 3 (Site PL016 Map).mxd Mike Appel 6/18/2014 0145317.2

229 A MW10-12

@SB16-01

@SB16-02 AMW10-05 231 230 A MW10-10

@ SB16-03 225

243

Fairchild Ave 242 Fairchild Ave AP10-1 @ SB16-04 MW10-01 A 239 A MW10-21 MW16-03 @ SB16-05 SB16-06 A@ 3031 A MW10-13 A MW10-18 Bong St Existing Fuel Stand A MW10-15 A MW16-01A@ MW10-19 SB16-07 @ SB16-08 @ SB16-09

AMW10-14 @ SB16-10 302 A MW10-09

AMW10-16 MW16-02 A@ AMW10-20 SB16-11 @SB16-14 A MW10-04 A 306 MW16-04 SB16-13@ MW10-03 A@SB16-12 @SB16-18 SB16-16@ @SB16-17 MW16-05A@ SB16-20 325 SB16-15 330 MW16-06 A@ @

A Rand Way SB16-19 Rand Way 303 P10-2 @ SB16-21

AMW10-07 A@ MW16-07 @SB16-22 SB16-23 304 AMW10-08 A MW10-22 307 @SB16-24 A MW10-24 Vandenberg Drive Vandenberg 305 Drive Vandenberg AMW10-17 MW10-02 A @ SB16-25

A P10-3 A MW10-11

331

313 AMW10-23

332 Legend Figure 3 @ Data Gap Investigation Soil Boring Location (January 2012) Site Map 012024060 Site PL016 A Existing Monitoring Well Feet 173d Fighter Wing A Monitoring Well Installed 2012 Kingsley Field ³ Klamath Falls, Oregon 1992 Excavation Area - Original IRP Site 10 Boundary

06/14