Prepared For:

TCE RI/FS Coordinator

Final TRICHLOROETHENE FEASIBILITY STUDY REPORT

Former WACS Site / Joe Parent Vocational Education Center Aniak,

Prepared By:

4101 Arctic Blvd., Suite 206 Anchorage, Alaska 99503

Geosyntec Project Number: PNG0712

March 2019

Final TRICHLOROETHENE FEASIBILITY STUDY REPORT

Former WACS Site / Joe Parent Vocational Education Center Aniak, Alaska

Prepared By:

Geosyntec Consultants, Inc. 4101 Arctic Blvd., Suite 206 Anchorage, Alaska 99503

Ben Martich Bruce Marvin Principal Senior Principal

Geosyntec Project Number: PNG0712 March 2019

TABLE OF CONTENTS

EXECUTIVE SUMMARY ...... VI 1. INTRODUCTION ...... 1 1.1 Purpose and Objectives ...... 1 1.2 Regulatory Framework ...... 1 1.3 Organization of Report ...... 2 2. BACKGROUND INFORMATION ...... 3 2.1 Site Location and Surroundings ...... 3 2.2 Site Use ...... 3 2.3 Investigation History ...... 4 2.4 Constituents of Potential Concern ...... 5 2.5 Previous and Ongoing Remedial Activities ...... 5 2.5.1 Previous Remedial Studies and Activities ...... 5 2.5.2 Ongoing and Planned Remedial Activities ...... 8 2.6 Conceptual Site Model Overview ...... 8 2.6.1 Geology and Hydrogeology ...... 8 2.6.2 TCE Sources ...... 9 2.6.3 Nature and Extent of TCE and Breakdown Products ...... 10 2.6.4 Fate and Transport of TCE ...... 13 2.6.5 Potential Exposure Pathways ...... 14 3. REGULATORY REQUIREMENTS AND REMEDIAL ACTION OBJECTIVES...... 16 3.1 Applicable Requirements ...... 16 3.2 Remedial Action Objectives ...... 16 3.3 Target Areas for Remedial Response Actions ...... 17 4. TECHNOLOGY IDENTIFICATION AND SCREENING ...... 18 4.1 Remedial Technologies ...... 18 4.2 Screening Criteria ...... 18 4.2.1 Effectiveness ...... 18 4.2.2 Implementability ...... 19 4.2.3 Cost ...... 19 4.3 Screening Results ...... 19 5. REMEDIAL RESPONSE ACTION ALTERNATIVES DEVELOPMENT AND EVALUATION...... 21

Final FS Report i March 2019

5.1 Remedial Alternatives Development ...... 21 5.2 Alternatives Descriptions ...... 21 5.2.1 Alternative 1 – No Action ...... 22 5.2.2 Alternative 2 – Institutional Controls and Engineering Controls ...... 22 5.2.3 Alternative 3 – Targeted Soil Vapor Extraction with ICs and ECs ...... 23 5.2.4 Alternative 4 – Long-Term Groundwater Monitoring with ICs and ECs ...... 25 5.2.5 Alternative 5 – Targeted SVE and LTGM with Limited ICs and ECs ...... 25 5.2.6 Alternative 6 – Excavation and LTGM with Limited ICs and ECs ...... 26 5.3 Alternatives Evaluation ...... 27 5.3.1 Evaluation Criteria ...... 27 5.3.2 Comparative Discussion of Alternatives ...... 28 6. RECOMMENDED REMEDIAL ALTERNATIVE ...... 31 7. CONCLUSIONS...... 32 8. REFERENCES ...... 33

LIST OF TABLES – IN TEXT

Table 4-1: List of Potential Remedial Technologies ...... 18

LIST OF TABLES – APPENDED

Table 1 Default Remedial Action Cleanup and Target Levels Table 2 TCE Mass Estimates by Geologic Unit Table 3 Technology Screening Table 4 Remedial Alternatives Evaluation

Final FS Report ii March 2019

LIST OF FIGURES – APPENDED

Figure 1 Site Location Figure 2 Site Vicinity Figure 3 1959 Aerial Photograph Figure 4 Extent of Removal Actions Figure 5 Plan View of Cross Sections Figure 5A Cross Section A-A’ Figure 5B Cross Section B-B’ Figure 5C Cross Section C-C’ Figure 5D Cross Section D-D’ Figure 5E Cross Section E-E’ Figure 6 Extent of TCE in Gravel Fill Layer Figure 7 Extent of TCE in Fine Silt Layer Figure 8 Extent of TCE in Groundwater Figure 9 Extent of TCE in Soil Figure 10 Unsaturated Zone – Institutional and Engineering Controls Figure 11 Saturated Zone – Institutional and Engineering Controls Figure 12 Unsaturated Zone – Targeted SVE with Institutional and Engineering Controls Figure 13 Saturated Zone – LTGM with Institutional and Engineering Controls Figure 14 Unsaturated Zone – Excavation with Institutional and Engineering Controls

LIST OF CHARTS – APPENDED

Chart 1 Alternatives Cost Comparison

LIST OF APPENDICES

Appendix A Spring 2018 Groundwater Monitoring Appendix B Remedial Response Action Alternatives Cost Estimates Appendix C Response to Comments

Final FS Report iii March 2019

LIST OF ACRONYMS AND ABBREVIATIONS

µg/kg ...... micrograms per kilogram µg/L ...... micrograms per liter µg/m3 ...... micrograms per cubic meter AAC ...... Alaska Administrative Code ADEC ...... Alaska Department of Environmental Conservation ADOT&PF ...... Alaska Department of Transportation & Public Facilities bgs ...... below ground surface CD ...... Consent Decree cDCE ...... cis-1,2-dichloroethene CERCLA ...... Comprehensive Environmental Response, Compensation, and Liability Act COPC ...... constituent of potential concern CSM ...... conceptual site model E&E...... Ecology and Environment, Inc. ECs ...... engineering controls FS ...... feasibility study Geosyntec ...... Geosyntec Consultants, Inc. ICs ...... institutional controls JPVEC ...... Joe Parent Vocational Education Center KSD...... Kuspuk School District LTGM ...... long-term groundwater monitoring mg/kg ...... milligrams per kilogram NAVD88 ...... North American Vertical Datum of 1988 NCP ...... National Contingency Plan O&M ...... operations and maintenance OASIS ...... OASIS Environmental, Inc. PCBs ...... polychlorinated biphenyls PCE ...... tetrachloroethene RAOs...... remedial action objectives RI Report ...... Trichloroethene Remedial Investigation Report RI...... remedial investigation RI/FS Work Plan ...... Trichloroethene Remedial Investigation and Feasibility Study Work Plan ROI ...... radius of influence

Final FS Report iv March 2019

SMP...... Site Management Plan SSD ...... sub-slab depressurization SVE ...... soil vapor extraction TCE ...... trichloroethene tDCE ...... trans-1,2-dichloroethene TSD ...... treatment, storage, and disposal USEPA ...... United States Environmental Protection Agency VC ...... vinyl chloride WACS ...... White Alice Communications System

Final FS Report v March 2019

EXECUTIVE SUMMARY

This feasibility study (FS) report, prepared by Geosyntec Consultants, Inc. (Geosyntec), presents an evaluation of potential remedial alternatives to address impacts from trichloroethene (TCE) and its breakdown products at the former Aniak White Alice Communications System (WACS) facility and Joe Parent Vocational Education Center (JPVEC) (hereafter “site”) in Aniak, Alaska. The objective of the FS is to provide an assessment of potential remedial alternatives and identify the preferred remedy. The objective is met by presenting regulatory requirements and remedial action objectives (RAOs), identifying and screening potential remedial technologies, developing and evaluating remedial alternatives, and identifying the preferred remedy.

The primary RAO for the site is to reduce concentrations of TCE in soil vapor, soil, and groundwater to levels that are protective of human health and the environment. The target areas for TCE remediation are the unsaturated zone (unsaturated soil and soil vapor) and the saturated zone (saturated soil and groundwater).

Remedial technologies are screened based on their effectiveness, implementability, and cost, and this screening identified the following technologies by target zone to be carried forward for evaluation:

• Unsaturated Zone

o Institutional Controls (ICs) – Land Use Restrictions o Engineering Controls (ECs) – Vapor Intrusion Mitigation System o Soil Vapor Extraction (SVE) o Excavation o Long-Term Soil Vapor Monitoring • Saturated Zone

o ICs – Groundwater Use Restrictions o ECs – Wellhead Treatment o In Situ – Enhanced Reductive Dechlorination o Long-term Groundwater Monitoring (LTGM) Alternatives were developed by combining technologies for the unsaturated and saturated zones into comprehensive remedial strategies. Six remedial alternatives were evaluated:

• Alternative 1 – No Action (for comparison purposes) • Alternative 2 – ICs and ECs • Alternative 3 – Targeted SVE with ICs and ECs

Final FS Report vi March 2019

• Alternative 4 – LTGM with ICs and ECs • Alternative 5 – Targeted SVE and LTGM with Limited ICs and ECs • Alternative 6 – Excavation and LTGM with Limited ICs and ECs The remedial alternatives were compared against each other using the following criteria:

• Overall Protectiveness of Human Health and the Environment • Compliance with Laws and Regulations • Long-Term Effectiveness and Permanence • Reduction of Toxicity, Mobility, and Volume • Short Term Effectiveness • Implementability • Cost The recommended remedial alternative for implementation at the site is Alternative 5 – Targeted SVE and LTGM with Limited ICs and ECs. This alternative is protective of human health and the environment, complies with applicable laws and regulations, scores favorably in both long- and short-term effectiveness while reducing TCE mass at the site, and has a reasonable cost.

Final FS Report vii March 2019

(Page Intentionally Left Blank)

Final FS Report viii March 2019

1. INTRODUCTION

This feasibility study (FS), prepared by Geosyntec Consultants, Inc. (Geosyntec), presents an evaluation of potential remedial alternatives to address impacts from trichloroethene (TCE) and its breakdown products at the former Aniak White Alice Communications System (WACS) facility and Joe Parent Vocational Education Center (JPVEC) (hereafter “site”) in Aniak, Alaska (Figure 1). This FS is being submitted based on the results and conclusions of the Trichloroethene Remedial Investigation Report (RI Report) dated May 2018 (Geosyntec, 2018); in accordance with the Trichloroethene Remedial Investigation and Feasibility Study Work Plan (RI/FS Work Plan) dated August 2016 (Geosyntec, 2016); and based on the requirements of the site Consent Decree (CD).

1.1 Purpose and Objectives

The purpose of this FS is to present the information and evaluations relevant to assessing remedial technologies and alternatives to address TCE and its breakdown products at the site. The overall objective of this FS is to provide an assessment of remedial alternatives and identify the preferred remedy. To meet the objective, this FS includes relevant site background information, regulatory requirements and remedial action objectives (RAOs), identifies and screens remedial technologies, develops and evaluates remedial alternatives and identifies the preferred remedy.

1.2 Regulatory Framework

This FS is required by the CD: State of Alaska, Plaintiff, v. United States of America, Alaska Department of Transportation and Public Facilities, Alaska Department of Education and Early Development, Kuspuk School District, Alascom Inc., AT&T Corp., Exelis ASI, Inc., and Lockheed Martin Corporation, Defendants, effective date 4 March 2016. The CD established Alascom, Inc., Exelis Arctic Services, Inc., and Lockheed Martin Corporation as the TCE RI/FS Coordinator. The TCE RI/FS Coordinator is responsible for hiring a qualified party as the TCE RI/FS Contractor to undertake and complete a TCE RI/FS in the vicinity of the JPVEC. The TCE RI/FS Coordinator hired Geosyntec as the TCE RI/FS Contractor. The RI was conducted in 2016 and 2017, and the results were provided in the RI Report (Geosyntec, 2018). Both the RI and FS have been conducted in accordance with the RI/FS Work Plan (Geosyntec, 2016), which was required by the CD and approved by the Alaska Department of Environmental Conservation (ADEC).

The site is defined in the CD as the “vicinity of the Joe Parent Vocational Education Center.” The primary features at the site are shown in Figure 2 and include:

• JPVEC, which was the main building of the former WACS facility; • Former septic system, inclusive of the septic line, septic tank, and seepage pit/leach field;

Final FS Report 1 March 2019

• Maintenance building located to the northwest of the main building; • Former truck fill stand, which was built and removed by Kuspuk School District (KSD) in the 2000s; and • Four antenna foundations.

This FS was prepared substantially in accordance with the United States Environmental Protection Agency (USEPA) regulations (40 CFR § 300.430) and in accordance with Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA (USEPA, 1988) and the National Contingency Plan (NCP).

The CD also defines a PCB Cleanup for the site to be undertaken and completed by a PCB Coordinator. Polychlorinated biphenyls (PCBs) are not part of the TCE RI/FS. Previous investigations and remedial actions involving PCBs are mentioned in Section 2 to inform the TCE RI/FS.

1.3 Organization of Report

This document includes the following sections:

Section 2 presents background information relevant to the FS, including site location and use, investigation history, remedial activities history, and a summary of the conceptual site model (CSM).

Section 3 presents the applicable regulatory requirements, establishes RAOs, and outlines target areas for remedial response actions.

Section 4 summarizes the various technologies that were considered and screens them based on effectiveness, implementability, and cost.

Section 5 presents, evaluates, and compares remedial alternatives.

Section 6 identifies the preferred remedy based on the findings from previous sections.

Section 7 summarizes the findings of this report.

Section 8 contains references used to produce this FS.

Final FS Report 2 March 2019

2. BACKGROUND INFORMATION

Detailed site background information was presented in the RI Report, which is incorporated by reference. A summary of background information relevant to the FS is provided herein.

2.1 Site Location and Surroundings

The site is located in the village of Aniak, Alaska, on the south side of the . Alaska Department of Transportation & Public Facilities (ADOT&PF) airport property is adjacent to the site and located approximately 250 feet to the north-northeast of the JPVEC. The immediate area surrounding the site is wooded to the north, west, and east. The Aniak High School is located approximately 150 feet to the southwest (Figure 2). The nearest residence is approximately 550 feet south of the JPVEC.

2.2 Site Use

The Aniak WACS facility was constructed between 1955 and 1958 on federally-owned land as part of the network of communications facilities built by the United States Government to support the Air Force’s Cold War air defense mission. The facility officially was activated on 14 January 1958. The Aniak WACS was constructed on gravel fill imported to the site. Figure 3 shows 1959 historical imagery in which the lateral extent of the gravel pad is visible, and Figure 2 shows the location of the original gravel fill base relative to the other site improvements. Original improvements included a 6,080-square-foot equipment and power building connected to a 4,750- square-foot dormitory, a maintenance building, associated utilities, and three fuel tanks with a combined capacity of approximately 7,000 barrels. The facility had two sets of 60-foot parabolic antennas (Reynolds, 1988). Historical imagery indicates a maintenance building was constructed between 1963 and 1967 to the northwest of the WACS facility.

In 1979, the United States deactivated the Aniak WACS facility and granted the Alaska Department of Education and Early Development occupancy rights beginning 1 May 1979 for the purpose of converting the facility into a school. KSD contracted for the conversion of the facility to an educational building in 1979 and 1980. In September 1981, the United States transferred the property to the ADOT&PF, which leases the property to KSD.

KSD has operated the JPVEC at the site since 1980. An approximate 5,000-square-foot addition was added on the south end of the main building for classrooms and administration offices. The addition has crawl space construction, whereas the original main building was built slab-on-grade. The former WACS maintenance building on the northwest side of the school building is also used by KSD. The antenna arrays have been removed but their concrete foundations remain. A fuel tank farm, located west of the JPVEC, and a truck fill stand, located south of the fuel tank farm, were constructed by KSD around 2005. The truck fill stand was removed by 2008. The only current consistent use of the JPVEC is office space for KSD maintenance staff. Daily classes are not held

Final FS Report 3 March 2019

at the JPVEC, and the dormitory does not have full-time occupants. Occasional special events or training programs, such as welding and construction short courses, are taught at the JPVEC and during these times the dormitory may be occupied.

The JPVEC has a drinking water well (Figure 2). The JPVEC well is 60 feet deep and approximately 100 feet northeast of the JPVEC.

Future use of the site may change. KSD’s lease of the JPVEC reportedly ends in 2021. If ADOT&PF does not renew KSD’s lease, it is possible that the facility will remain vacant or be demolished due to its proximity to the Aniak Airport. The relocation of the Aniak runway 260 feet closer to the JPVEC could also trigger a change in site use, as it may limit land use type and height of any new structures.

2.3 Investigation History

Initial investigation efforts at the site focused on impacts from polychlorinated biphenyls (PCBs). During a site inspection conducted by Ecology and Environment, Inc. (E&E) in 1997 on behalf of the USEPA, TCE was identified in a sludge sample collected from a vault in the leach pit associated with the septic system (E&E, 1997). The May 2018 RI Report includes a detailed chronology of TCE investigations, which is summarized in the following paragraphs (Geosyntec, 2018).

Site characterization activities were conducted by Shannon & Wilson, under contract to ADEC, in 2006, 2008, and 2009 (Shannon & Wilson, 2008; 2010). The 2006 characterization investigated the former septic system and maintenance building area through collection of soil and groundwater samples for laboratory analyses. Soil and groundwater in this area was further investigated during the 2008 characterization. In 2009, soil, groundwater, and soil vapor were sampled across the site to further delineate TCE impacts.

OASIS Environmental, Inc. (OASIS), under contract to ADEC, conducted vapor intrusion assessments of the JPVEC in May 2009, December 2009, and April 2010, and the maintenance building in May 2009 and December 2009. Sub-slab vapor, indoor air, and outdoor air samples were collected to assess the vapor intrusion pathway. In August 2010, a sub-slab depressurization (SSD) system was installed at the JPVEC to mitigate potential exposure of building occupants to TCE through vapor intrusion. In May and October of 2011, OASIS on behalf of ADEC conducted groundwater monitoring events, collecting groundwater for laboratory analyses from several monitoring wells and soil vapor points (OASIS, 2012).

Geosyntec conducted a series of RI field events from May 2016 to March 2018. These included an initial site visit; four groundwater gauging and/or sampling events; and two RI events, including, but not limited to, well maintenance or installation, groundwater gauging, along with soil and groundwater sampling (Geosyntec, 2018).

Final FS Report 4 March 2019

Since 2006, 18 permanent monitoring wells have been installed at the site (MW01 through MW18). Each well has been sampled one to eight times. Monitoring wells MW01, MW02, MW03, and MW05 have been decommissioned, resulting in 14 current monitoring wells at the site. The most recent semi-annual sampling event occurred in March 2018, with results reported in Appendix A.

2.4 Constituents of Potential Concern

The previous investigations, CD, and RI Report (Geosyntec, 2018) established TCE as a primary constituent of potential concern (COPC) at the site. Tetrachloroethene (PCE) is also a COPC because it may have been present as an impurity or added component of TCE released at the site. In addition, the TCE degradation compounds, cis-1,2-dichloroethene (cDCE), trans-1,2- dichloroethene (tDCE), and vinyl chloride (VC) are also identified as COPCs because they are byproducts of TCE natural attenuation or engineered biodegradation. As noted in Section 1.2, the cleanup of PCBs is addressed separately from the TCE RI/FS.

The potential sources of TCE and the other COPCs are discussed in the CSM in Section 2.6.

2.5 Previous and Ongoing Remedial Activities

2.5.1 Previous Remedial Studies and Activities

To date, most remedial activities at the site have focused on cleanup of PCB-impacted soils and materials. The following subsections summarize the remedial activities chronologically with more detail provided for the activities related to TCE.

2.5.1.1 2001 PCB Removal

Shannon & Wilson, under contract to ADEC, removed mostly near-surface soils from the east side of the school building near the wood shop (Figure 4). A total of 631 supersacks, corresponding to about 872 tons of PCB-impacted material, were transported to a treatment, storage, and disposal (TSD) facility.

2.5.1.2 2008 Septic System Removal

During the 2008 characterization effort (Section 2.3), Shannon & Wilson also removed the septic system (Figure 4). The septic system consisted of concrete pipe sections exiting the west side of the metals shop and emptying into a septic tank approximately 50 feet from the metals shop. Concrete pipe sections exited the septic tank and extended further west to the seepage pit/leach field, located approximately 100 feet from the septic tank.

Shannon & Wilson reported that the concrete piping sections were belled and did not appear to be designed to be liquid tight or to convey liquids without some leakage. The top of the septic tank

Final FS Report 5 March 2019

was located approximately 8 feet below ground surface (bgs). The septic tank was characterized using wipe samples, and then removed, demolished, and containerized for disposal. The depth of the septic tank excavation was 18 feet bgs at its deepest point. During excavation of the concrete around the seepage pit, a wooden crib structure was identified at approximately 14 feet bgs. As a result, this excavation was extended to a maximum depth of 26 feet bgs. All excavated materials were containerized and characterized for off-site disposal. The seepage pit was backfilled with concrete debris from demolition of the former truck fill stand and stockpiled overburden.

The 2008 remedial activities also included extensive PCB-impacted soil removal on the southwestern side of the JPVEC and from a small area on the south side of the Wood Shop associated with the JPVEC (Figure 4).

2.5.1.3 2009 Bench-scale and Pilot Tests

Shannon & Wilson, under contract to ADEC, conducted bench-scale and pilot testing for TCE remedial alternative screening. In situ chemical oxidation, soil vapor extraction (SVE), and air sparging were evaluated.

Soils collected from 30 feet bgs in two borings and from a PCB-related soil boring near the septic system were tested for potassium permanganate and sodium permanganate soil oxidant demand to support evaluation of in situ chemical oxidation. The oxidant demand ranged from 0.3 to 1.5 percent, which are lower than the oxidant demand results measured during the 2016 sampling. It should be noted the 2009 samples were collected from outside the area with the highest concentrations.

Two vapor extraction wells (VES1 and VES2) were installed to evaluate SVE as a remedial technology. An SVE pilot test was conducted on each of the vapor extraction wells. A third SVE pilot test was performed on soil vapor monitoring point SGP17. VES1, located near nested monitoring wells MW07 and MW08 (Figure 5 inset), was screened across the fine silt and gravelly sand layers; VES2, located on the east side of the building near the wood shop, was screened within the gravel fill layer; and SGP17 was screened within the fine silt layer. All three tests resulted in reasonably constant extraction efficiencies based on evaluation of specific capacities (system flow divided by blower vacuum). TCE concentrations in the extracted soil vapor effluent ranged from 1,000 to 2,000 micrograms per cubic meter (µg/m3) for the duration of pilot tests at VES1 and SGP17. Volatile compounds, including TCE, were not detected during the pilot test at VES2. The radius of influence (ROI) was found to be between 40 and 67 feet.

Shannon & Wilson also completed an air sparging study. The results of a pilot test indicated that air injected in the water-bearing zone of the gravelly sand layer had a 20-foot radius of influence. However, the report questioned the effectiveness of air sparging because the fine silt layer above the gravelly sand layer would act as a trap for volatilized compounds.

Final FS Report 6 March 2019

2.5.1.4 2012 Groundwater Focused Feasibility Study

OASIS, under contract to ADEC, prepared a focused FS for groundwater. In addition to the No Action alternative, four remedial alternatives were evaluated:

1. Monitored Natural Attenuation (MNA), 2. In Situ Chemical Oxidation (ISCO), 3. Enhanced Reductive Dechlorination (ERD), and 4. Air Sparging. Alternative 3 (ERD) had the highest total score (combined effectiveness and cost), but MNA was recommended if the remedial timeframe was flexible.

2.5.1.5 2017 PCB Soil Removal

Olgoonik Specialty Contractors and SLR, on behalf of the PCB Coordinator, conducted excavation of PCB-impacted soil from an area east of the Wood Shop and an area southwest of the JPVEC, which included the area of the former truck fill stand (Figure 4). While the focus of this removal was PCB-impacted soil, co-located TCE-impacted soil was also removed during this activity. Due to the recent completion of this work, the full benefit of this VOC mass removal to soil vapor and groundwater concentrations has not yet been realized. The area excavated east of the wood shop was 15,800 square feet in size and varied from 1 to 8 feet in depth with most of the excavation being 1 to 2 feet deep. The area excavated southwest of the JPVEC was 6,774 square feet and varied from 1 to 6 feet in depth with most of the excavation being 2 to 3 feet deep. In the excavation southwest of the JPVEC, a 9-foot-diameter, 25-foot-long septic tank (the septic system installed by KSD post-conversion) was exposed and removed. The bottom of the tank was at an elevation of 73 feet measured by the North American Vertical Datum of 1988 (NAVD88), or approximately 17 feet bgs. During backfilling, 2 feet of native fine silt that had been removed during the tank excavation was used to re-establish the fine silt layer. A non-woven geotextile felt liner was placed on the floor of the excavation on the southwestern side of the JPVEC and a 20-mil polyethylene liner was placed on the excavation floor at the former truck fill stand (Olgoonik/SLR, 2018; ADEC 2018).

At the completion of excavation activities, 65 samples were collected from the base of the excavations and 44 samples were collected from the excavation sidewalls for analysis of TCE and COPCs. The analytical results for these soil samples are incorporated into the CSM summary in Section 2.6.

Final FS Report 7 March 2019

2.5.2 Ongoing and Planned Remedial Activities

2.5.2.1 SSD System

The results of the vapor intrusion assessment conducted by OASIS in 2009 indicated that vapor intrusion mitigation was recommended at the JPVEC building but not at other buildings located on-site. OASIS, under contract to ADEC, installed an SSD system in the JPVEC in August 2010. The system includes 11 extraction wells (two are beneath a membrane liner in the crawl space) and a 2.5 horsepower blower with a design system flow of 70 cubic feet per minute. The system has operated continuously since installation except for a period from March 2013 to August 2014 when the building was unoccupied. The SSD system remains in operation and maintenance and monitoring of the SSD system has been ongoing and has included sampling of sub-slab monitoring points, indoor air, and system effluent. ADEC-approved optimization of the SSD system included reducing the system flow rate from 70 cubic feet per minute to 60 cubic feet per minute (ERM 2017).

The residential soil vapor decision level for TCE has not been exceeded in any sub-slab soil vapor sample since August 2011 (18 consecutive monitoring events). SSD exhaust stack samples have been at or below the residential soil vapor decision level for TCE (range of 14 to 22 µg/m3) since May 2012 (seven samples). For indoor air, 15 monitoring events have occurred since removal of a can of TCE-containing vulcanizing cement in 2013. TCE has only been detected three times inside the JPVEC since the removal of the background source (three out of 103 samples), and all three detections were at a concentration approximately one-tenth of the residential indoor air decision level.

2.5.2.2 Institutional Controls for PCBs

Since the PCB cleanup is considered complete to the extent practical until the building is removed, institutional controls (ICs) will be used to mitigate potential exposure to the PCB-impacted soil remaining on-site (Olgoonik/SLR, 2018; ADEC 2018).

2.6 Conceptual Site Model Overview

Based on the results of the previous investigations and remedial activities at the site, a CSM was developed in the RI Report for TCE and its breakdown products. The CSM is summarized in the following sections.

2.6.1 Geology and Hydrogeology

There are three distinct geologic layers identified at the site: gravel fill overlying a fine silt layer, overlying a gravelly sand layer. The gravel fill was presumably brought to the site for construction of the WACS facility in the 1950s and extends across the former WACS facility. In undisturbed

Final FS Report 8 March 2019

areas beyond the gravel fill, there also is a thin top layer of looser, native soils and organic material underlain by the fine silt. The fine silt layer and underlying gravelly sand layer appear to be present across the site. As shown in the cross-section in Figures 5A-5E, the gravel fill has a thickness of 3 to 28 feet, with the top of the fine silt layer generally located between 73.5 and 92.5 feet NAVD88. The top of the gravelly sand layer is generally located between 67.5 and 78 feet NAVD88.

Groundwater elevation at the site correlates with the river stage of the nearby and with local precipitation patterns. Generally, groundwater elevation shows a consistent downward trend from December to April, when the groundwater table generally reaches the annual low. The largest annual fluctuation in groundwater elevation occurs during spring at the time of seasonal thaw when groundwater elevation rapidly increases 3 to 6 feet over a two- to four-week period and then decreases. The annual maximum groundwater level is often observed in May. Summertime elevations (in June and July) are generally stable with fluctuations less than 2 feet. Precipitation and groundwater elevations are observed to have greater variability from year to year in August through November.

At low groundwater elevations, the water is almost solely within the gravelly sand layer and the fine silt is unsaturated. High groundwater elevation, which only occurs over a few days in spring thaw, causes an upward gradient from the gravelly sand toward the fine silt layer. During this time, the gravelly sand layer becomes semi-confined with the potentiometric surface extending upward into the fine silt layer, resulting in saturated conditions in the deeper portion of the fine silt layer. However, upward flow of groundwater is limited by the fine-grained nature and low permeability of the fine silt layer such that for all but a few days each year, approximately 80% of the fine silt layer is unsaturated. Underneath the JPVEC building, where the gravel fill layer is deepest and the fine silt layer is thinner, groundwater may have the potential to enter into the base of the gravel fill layer during the few days of high groundwater.

The potentiometric surface is relatively flat with variability related to seasonal precipitation. For a majority of the year, the horizontal hydraulic gradient is less than 0.0043 with a predominant groundwater flow direction to the northeast. However, the groundwater flow direction may vary throughout the year with periods of flow to the southwest, nearly 180 degrees from the predominant flow direction, and to the north. These events usually occur in the summer and last approximately 10 weeks. Between 2014 and 2017, the groundwater flow direction was to the north more often than to the southwest, but in 2016 and 2017 the duration of these two less frequent groundwater flow directions was about the same. The gradient is less than 0.0023 for both of the non-dominant groundwater flow directions.

2.6.2 TCE Sources

TCE may have been utilized for various cleaning operations at the site. The chemical’s presence, release, and distribution are or may be associated with the following site features or activities:

Final FS Report 9 March 2019

• Former WACS septic system, which was removed in 2008; • Former floor drain system, which was connected to the former WACS septic system and reportedly decommissioned when KSD converted the building; • Drums that were stored at the site before, during, or after WACS operations; • Degradation and vandalism of drums that were abandoned on site after WACS operations; • Maintenance building; • Conversion activities by KSD that included cleanup of the WACS facility and movement of drums; and • Activities that disturbed and redistributed site soil, including:

o Construction of the KSD septic system, which was removed in 2017; o Construction and decommissioning of the former truck fill stand in the 2000s by KSD; and

o Construction of a new fuel tank farm by KSD.

2.6.3 Nature and Extent of TCE and Breakdown Products

The following sections summarize the presence of TCE and its breakdown products at the site for the unsaturated zone (vadose soil and soil vapor), the saturated zone (saturated soil and groundwater), and indoor air. For the purposes of this summary and consistent with the RI Report, the results are screened against default ADEC cleanup and target levels (Table 1). Due to the limited detections and exceedances of TCE breakdown products, this section is focused primarily on the nature and extent of TCE, unless otherwise noted.

2.6.3.1 Unsaturated Zone

The unsaturated zone at the site consists primarily of the gravel fill layer and the fine silt layer. As summarized in Section 2.5.1 above, the gravel fill layer is almost always unsaturated, with the exception of the area beneath the JPVEC when high groundwater events occur, and the groundwater table is above 73.5 feet NAVD88. The fine silt layer is primarily unsaturated, except for the bottom portion of the layer, which may occasionally become saturated due to groundwater fluctuations. Because the underlying gravelly sand is generally saturated, except when the top few feet of the layer occasionally are above the groundwater table, the gravelly sand is discussed as part of the saturated zone.

Soil has been the primary media sampled within the unsaturated zone. However, some soil vapor and sub-slab vapor samples also have been collected.

Final FS Report 10 March 2019

2.6.3.1.1 Soil

In the gravel fill layer, which is present across the original WACS facility, nearly 80 samples at 62 locations have been analyzed for TCE and its breakdown products. TCE concentrations in these samples range from 0.00608 to 1.1 milligrams per kilogram (mg/kg), with several locations exceeding the ADEC cleanup level of 0.011 mg/kg (Figure 6). Concentrations are generally lower in the near-surface soils and higher near the interface with the fine silt layer (Figures 5A-5E). The highest concentrations of TCE in soil (0.9 to 1.1 mg/kg) were detected southwest of the JPVEC metals shop and near the former truck fill stand. Immediately east and south of these higher concentrations, TCE concentrations in the gravel fill layer decrease to 0.2 to 0.4 mg/kg. Further east under the JPVEC building and on the eastern side of the building, TCE concentrations in the gravel fill layer range from 0.04 to 0.1 mg/kg. A second area of relatively elevated TCE concentrations in the gravel fill is located near the maintenance building, with TCE concentrations of 0.08 mg/kg north of the building and 0.212 mg/kg south of the building in a former drum storage area.

The fine silt layer underlies the gravel fill and is present near the surface on the western and southern portions of the site where no gravel fill was used. Nearly 120 samples at 86 locations have been analyzed for TCE and its breakdown products in the fine silt layer. TCE concentrations range from 0.0046 to 0.850 mg/kg (Figure 7). Concentrations show no apparent trend with depth. TCE detections in the fine silt layer extend from the eastern side of the JPVEC building to the west off the gravel pad and beyond where the seepage pit/leach field and KSD septic tank were located. The highest TCE concentrations in the fine silt layer are centered southwest of the JPVEC metals shop near the former truck fill stand, the same area that had the highest TCE concentrations in the gravel fill layer. Concentrations in the fine silt layer generally are lower than concentrations in the gravel fill layer.

Based on the sample results, Table 2 provides an estimate for the mass of TCE in the gravel fill and fine silt layers. As shown in the table, the majority of the TCE mass is estimated to be in the gravel fill (approximately 79 percent). Sixty-seven percent of the TCE mass at the site is localized to the gravel fill area southwest of the JPVEC building in the area of the former truck fill stand. The fine silt layer is estimated to contain only 21 percent of the total TCE mass in the unsaturated zone.

2.6.3.1.2 Soil Vapor

In 2009, semi-quantitative passive soil vapor samplers were used to collect soil vapor samples across the site at 40 soil vapor point locations and two vapor extraction pilot text wells. TCE concentrations exceeded the commercial soil vapor target level at seven of the sampled locations and exceeded the residential soil vapor target level at an additional five locations. The highest

Final FS Report 11 March 2019

concentrations were measured to the southwest of the JPVEC metals shop near the former truck fill stand. This is the same area with the highest TCE concentrations detected in soil.

Since September 2010, potential exposure to soil vapor via indoor air has been controlled at the JPVEC by the SSD system. Since that time, one hundred thirty-four sub-slab soil vapor samples have been collected. TCE concentrations have ranged from non-detect (<1 µg/m3) to 180 µg/m3. However, since 2012, there have been 102 sub-slab samples with only 32 detections of TCE and a maximum TCE concentration of 14 µg/m3, which is less than the residential soil vapor target level of 20 µg/m3. Twelve SSD exhaust stack samples have been collected with TCE concentrations ranging from 14 to 210 µg/m3. However, since 2013, TCE concentrations in six SSD exhaust stack samples have ranged from 14 to 22 µg/m3.

The concentrations of TCE in sub-slab soil vapor and SSD effluent are consistent with the concentrations and spatial distribution of TCE in soil and groundwater, with higher concentrations found near the southwest corner of the JPVEC metals shop.

2.6.3.2 Saturated Zone

The saturated zone at the site consists primarily of the gravelly sand layer, although the bottom portion of the overlying fine silt layer may also be saturated at times as a result of groundwater fluctuations. Groundwater has been the primary media sampled within the saturated zone. However, saturated soil samples also have been collected and used to assess the amount of mass sorbed to soil within this zone.

2.6.3.2.1 Soil

A majority of the TCE mass in the soil is contained within the unsaturated zone; however, some TCE is sorbed to soil in the saturated zone. An estimate of TCE mass and soil volumes is available in Table 2. In general, approximately 90 percent of the TCE mass within the saturated zone is sorbed to the soil.

2.6.3.2.2 Groundwater

TCE has been detected with concentrations ranging from 0.2 to 187 micrograms per liter (µg/L) in site groundwater. TCE detections in groundwater follow a similar spatial pattern as the TCE detections in soil from the fine silt layer (Figure 8). Similar to unsaturated zone impacts, the highest concentrations of TCE in groundwater are detected southwest of the JPVEC metals shop and near the former truck fill stand. TCE is detected in groundwater to the north toward the maintenance building in the range of 10 to 20 µg/L. To the west of the area with the highest TCE concentrations, TCE concentrations range from 3 to 10 µg/L. These concentrations are above the groundwater cleanup level of 2.8 µg/L. TCE is not detected to the south of or on the eastern side of the JPVEC building. There is a longitudinal area oriented perpendicular to the fuel tank farm where TCE is

Final FS Report 12 March 2019

not present in groundwater. Further west, TCE was detected in the most-recently installed groundwater monitoring wells, MW-15 and MW-18. TCE concentrations in these wells have ranged from 4 to 8 µg/L, since installation in 2017.

Vertically, TCE is bounded in groundwater at 60 feet NAVD88 in the impacted area immediately west of the JPVEC building. To the far west, TCE is not delineated vertically but would appear to be no deeper than 60 feet NAVD88. The average groundwater level was generally measured around 70 to 71 feet NAVD88; therefore, VOC impacts in the saturated zone are approximately 10 feet thick.

Groundwater samples also have been analyzed for the breakdown products of TCE. cDCE was the most commonly detected daughter compound in groundwater, with concentrations ranging from 0.26 to 68 µg/L, with one sample exceeding the cleanup level of 36 µg/L. tDCE has been detected only occasionally with concentrations ranging from 0.22 to 0.69 µg/L, which are all below the cleanup level of 360 µg/L. VC has not been detected in groundwater at the site.

2.6.3.3 Indoor Air

Indoor air at the JPVEC has been protected from potential soil vapor intrusion by the SSD system since 2010. Indoor air at the JPVEC, including the crawl space, has been sampled 23 times at up to six locations inside the JPVEC and the crawl space (153 total samples) since installation of the SSD system. In the 15 monitoring events since removal of TCE-containing vulcanizing cement from KSD shop supplies in 2013, TCE has only been detected three times inside the JPVEC (three out of 96 samples) at concentrations of 0.20, 0.22, and 0.39 µg/m3, which are all below the ADEC residential target level of 2.0 µg/m3 for TCE.

2.6.4 Fate and Transport of TCE

Based on the nature and extent of TCE presented in Section 2.6.3, the migration of TCE in the subsurface at the site is controlled by five primary processes, which are discussed in more detail in the RI Report (Geosyntec, 2018):

• Sorption to soils; • Leaching from the gravel fill layer to the fine silt layer; • Movement into and out of the silt layer by diffusion and infiltration, including:

o Into soil moisture in the gravel fill; and o Into the underlying gravelly sand layer; • Advection and dispersion in the saturated gravelly sand layer; • Volatilization into soil vapor and then potential migration to aboveground air (outside and inside buildings); and

Final FS Report 13 March 2019

• Natural attenuation by dilution, diffusion, and biological reductive dechlorination and abiotic degradation.

A majority of the TCE in soil is sorbed within the gravel fill layer with only approximately 20 percent of the TCE in soil sorbed within the fine silt layer. Due to the fine-grained nature of the silt layer, minimal migration of TCE out of or through the silt layer is expected. For this reason, the fine silt layer is believed to limit migration of TCE from the gravel fill layer to the groundwater.

Advection in the saturated zone has been observed to be limited due to the relatively flat groundwater gradient. This is evidenced by the lack of TCE migration in groundwater . In general, groundwater impacts remain localized to the original TCE source area, despite several decades since the potential release.

The TCE in the gravel fill layer is expected to be the primary source for volatilized TCE. The fine silt layer likely provides a barrier for TCE volatilizing from the groundwater, limiting the contribution from groundwater to the vadose zone.

Additionally, natural attenuation is anticipated to play a role in the stability of the VOC impacts. Groundwater monitoring results to date indicate that the TCE concentrations are likely stable to decreasing in the saturated zone, with no discernable migration of VOC concentrations. Even though some groundwater monitoring has been performed, additional monitoring would allow for longer term trend analyses to be conducted.

2.6.5 Potential Exposure Pathways

The following sections summarize the potential receptors and exposure pathways identified in the RI Report (Geosyntec, 2018).

2.6.5.1 Receptors

There are no full-time residents at the site. There is a dormitory located at the northeastern end of the JPVEC building. Visitors may stay in the dormitory for extended periods of time, but usually for periods lasting a few days to less than one month. Current human receptors could include the following:

• Visitors, such as students (possibly long-term) and parents; and • Commercial workers, such as school teachers and maintenance personnel.

Future human receptors could include the following:

• Residents; • Visitors, such as students (possibly long-term) and parents;

Final FS Report 14 March 2019

• Commercial workers, such as school teachers and maintenance personnel; and • Construction workers, including remedial contractors.

If the school building is removed, the future human receptors could include the following:

• Visitors, such as airport personnel; and • Construction workers, including remedial contractors.

There are no critical habitats or anadromous streams that could be affected, and there are no habitats affected that support valued species important to the region.

2.6.5.2 Exposure Pathways

The following are potential exposure pathways for human receptors that may come in contact with TCE at the site:

• Groundwater ingestion through the potentially downgradient JPVEC drinking water well (potentially complete pathway for future human receptors); • Direct contact with impacted soil, although the risk is not considered significant since soil concentrations are below human health cleanup criteria; and • Soil vapor inhalation (complete pathway for current and future human receptors; current pathway at JPVEC mitigated by an SSD system).

Surface water ingestion and ingestion of wild foods are not complete pathways for current or future human receptors. The RI Report showed that ecological risk characterization and assessment were not necessary because of a lack of habitat at the site (Geosyntec, 2018).

Final FS Report 15 March 2019

3. REGULATORY REQUIREMENTS AND REMEDIAL ACTION OBJECTIVES

This section presents applicable regulatory requirements, cleanup goals, RAOs, and areas that have been targeted for remediation.

3.1 Applicable Requirements

This FS was conducted substantially in accordance with the USEPA regulations for the preparation of an RI/FS in compliance with the National Contingency Plan, pursuant to the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA). It was also conducted in compliance with state law. The primary state law regulatory requirements for consideration in the development of an FS are listed below. These requirements are the primary regulations and guidance documents that influence remedy selection for the site.

• Alaska’s cleanup law (AS 46.03.822 and AS 46.03.760), including applicable regulations such as the applicable soil cleanup levels (18 AAC 75.340) and the groundwater cleanup levels (18 AAC 75.345); • Residential air targets (Vapor Intrusion Guidance for Contaminated Sites); • Air quality regulations (18 AAC 50.502); • Anti-degradation policy for water (18 AAC 70.015); • Waste water discharge regulations (18 AAC 83.005); • Hazardous waste regulations (18 AAC 62.020); and • Solid waste regulations (18 AAC 60.005).

3.2 Remedial Action Objectives

The primary RAO for the site is to reduce concentrations of TCE in soil vapor, soil, and groundwater to levels that are protective of human health and the environment. The media-specific objectives of this primary RAO include the following:

• For soil, the objective is to mitigate human exposure to TCE in soil that exceeds the ADEC soil cleanup levels for the protection of groundwater quality and for the protection of human health via the direct contact and vapor intrusion pathway to indoor air. • For groundwater, the objective is to reduce concentrations of TCE in groundwater to levels consistent with the ADEC groundwater cleanup levels (18 AAC 75.345) for the protection of human health. • For soil vapor, the objective is to mitigate exposures to TCE in vapor for protection of human health. TCE in soil vapor will be mitigated to protect human health via the vapor

Final FS Report 16 March 2019

intrusion pathway in indoor air so that soil vapor concentrations do not exceed ADEC’s air targets.

3.3 Target Areas for Remedial Response Actions

Based on the primary RAO, media-specific objectives and RI results, the following are the “Target Areas” for TCE remediation at the site. These target areas are divided into unsaturated and saturated areas. The unsaturated area addresses unsaturated soil and soil vapor, and the saturated area addresses saturated soil and groundwater.

• The unsaturated target area includes soil with TCE concentrations detected above the ADEC default cleanup level of 0.011 mg/kg (Figure 9). This is the migration to groundwater cleanup level and is the lowest applicable cleanup level for soil. Soil vapor impacts are consistent with the spatial distribution of TCE in soil. The unsaturated target area spans a footprint of approximately 400 feet by 350 feet and extends from the gravel fill layer into the gravelly sand layer from approximately 71 to 99 feet NAVD88, or from approximately 25 feet bgs to the ground surface. Based on the distribution of TCE mass in the unsaturated zone, remedial alternatives may be developed to target a small area(s) with high concentrations using one technology while addressing lower concentration areas with another technology. • The saturated target areas where TCE concentrations exceed the drinking water standard of 2.8 µg/L are west of the JPVEC building (Figure 8). The area adjacent to the JPVEC building spans a footprint approximately 100 by 170 feet and extends from the fine silt/sandy gravel interface into the gravelly sand layer from approximately 60 to 71 feet NAVD88, or approximately 20 to 35 feet bgs. The second area, farther west of the JPVEC, is expected to span approximately 160 feet by 170 feet and extend from approximately 60 to 75 feet NAVD88, or approximately 25 to 40 feet bgs, based on preliminary sampling results from MW15 and MW18.

Final FS Report 17 March 2019

4. TECHNOLOGY IDENTIFICATION AND SCREENING

The RI/FS Workplan (Geosyntec, 2016) identified a preliminary list of technologies for achieving the primary RAO and media-specific objectives. This list has been modified based on the results of the RI and is presented and screened in this section. The screening and retention of suitable technologies/process options for alternative development was based on effectiveness, implementability, and cost in accordance with Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA (USEPA, 1988) and the NCP.

4.1 Remedial Technologies

The following remedial technologies/process options were screened for the unsaturated and saturated zones. A description of each technology is presented in Table 3.

Table 4-1: List of Potential Remedial Technologies

Impacted Zone/Media Unsaturated Zone Saturated Zone Technology Category (Soil and Soil Vapor) (Saturated Soil and Groundwater) ICs Land Use Restrictions Groundwater Use Restriction Engineering Controls Capping Wellhead Treatment (ECs) Vapor Intrusion Mitigation System In Situ Treatment Chemical Oxidation Enhanced Reductive Dechlorination SVE (Biotic or Abiotic) Phytoremediation Chemical Oxidation Activated Carbon Phytoremediation Removal Excavation Air Sparging Extraction and Treatment (i.e., “pump and treat”) Natural Attenuation Long-Term Soil Vapor Monitoring Long-Term Groundwater Monitoring (LTGM) 4.2 Screening Criteria

This section summarizes the three USEPA criteria for screening remedial technologies/process options: effectiveness, implementability, and cost.

4.2.1 Effectiveness

Effectiveness is the ability of each remedial technology to address TCE and its breakdown products and protect human health and the environment relative to other options, based on the following:

Final FS Report 18 March 2019

• The ability of a remedial technology to address the specified areas and volumes impacted by TCE and to achieve the desired regulatory criteria for TCE, as well as regulatory criteria for associated breakdown products that may be produced as a result of the technology; • The potential impacts to human health and the environment during construction and implementation of the remedial technology; and • The reliability of the remedial technology with respect to TCE abatement and site conditions.

4.2.2 Implementability

Implementability is the administrative and technical feasibility of a remedial technology, based on the following:

• The institutional or administrative aspects of implementation, including the ability to obtain necessary permits and general public acceptance; • The availability of support services and equipment, and the degree to which the technology process option has been demonstrated at other sites; and • Property owner acceptance of the remedial technology.

4.2.3 Cost

Relative cost is used to compare the capital and operations and maintenance (O&M) costs of the remedial technology/process option. Cost plays an important role in the screening of remedial technologies/process options and development of remedial alternatives. Costs that are grossly excessive compared to the overall effectiveness may be considered as one of several factors used to eliminate technologies/process options. For example, if two technologies are both equally effective and implementable, the remedial technology with the lower cost will be retained for development of remedial alternatives. Relative costs are evaluated based on professional judgment, and each option will be evaluated as to whether costs are expected to be low, medium, or high.

4.3 Screening Results

Table 3 presents the screening of remedial technologies. Retained technologies include:

• Unsaturated Zone:

o ICs – Land Use Restrictions; o ECs – Vapor Intrusion Mitigation System; o In situ – SVE;

Final FS Report 19 March 2019

o Removal – Excavation; o Long-Term Soil Vapor Monitoring; • Saturated Zone:

o ICs – Groundwater Use Restrictions; o ECs – Wellhead Treatment (potential contingency); o In Situ – Enhanced Reductive Dechlorination (potential contingency); and o Natural Attenuation – LTGM. Retained remedial technologies were used to develop remedial alternatives, which are evaluated in Section 5.

The technologies not retained for the unsaturated zone were capping, phytoremediation, and in situ chemical oxidation. The technologies not retained for the saturated zone were phytoremediation, in situ chemical oxidation, in situ activated carbon, and groundwater extraction and treatment. These remedial technologies, along with wellhead treatment and enhanced reductive dechlorination listed above, are available as potential contingency technologies, if future site conditions indicate a need to modify the site remedial approach.

Final FS Report 20 March 2019

5. REMEDIAL RESPONSE ACTION ALTERNATIVES DEVELOPMENT AND EVALUATION

This section presents and describes the development and evaluation of remedial alternatives that address primary site RAOs and media-specific objectives.

5.1 Remedial Alternatives Development

Alternatives were developed using the saturated and unsaturated zone technologies retained from the technology screening in Section 4. Because TCE and its breakdown products remain in both the saturated and unsaturated zones, a complementary approach was used to combine saturated and unsaturated zone technologies into site-wide remedial alternatives. While enhanced reductive dechlorination was retained as a potential remedial technology for the saturated zone in Section 4, it has not been incorporated into the remedial alternatives because it has not been tested at this site and effectiveness may be limited or similar to natural degradation rates due to the site geochemistry, climate, and relatively low initial TCE concentrations in groundwater. Enhanced reductive dechlorination has been retained as a contingent technology if future site conditions indicate a need to modify the site remedial approach

A total of six remedial alternatives were developed:

• Alternative 1 – No Action (for comparison purposes); • Alternative 2 – ICs and ECs; • Alternative 3 – Targeted SVE with ICs and ECs; • Alternative 4 – LTGM with ICs and ECs; • Alternative 5 – Targeted SVE and LTGM with Limited ICs and ECs; and • Alternative 6 – Excavation and LTGM with Limited ICs and ECs.

The alternatives are described in Section 5.2 and evaluated in Section 5.3 below.

5.2 Alternatives Descriptions

Each of the six remedial alternatives are described in this section. Conceptual layouts of the alternatives are provided in Figures 10 through 14. Cost estimates for implementation of the alternatives are detailed in Appendix B and summarized in the remedial alternatives evaluation table, provided as Table 4. The cost estimates developed for the alternatives do not include contingency measures, nor do they include decommissioning costs for things such as monitoring wells and remedial systems (such as the SSD system).

Final FS Report 21 March 2019

5.2.1 Alternative 1 – No Action

Under the No Action alternative, operation of the existing SSD system and monitoring of sub-slab vapor at the current JPVEC building would be discontinued. No further or additional sampling, monitoring, investigation, remediation, or mitigation activities would be performed. The cost of this remedial alternative is estimated to be $0.

5.2.2 Alternative 2 – Institutional Controls and Engineering Controls

The second alternative includes protection of human health and the environment under current and future land uses through the implementation of ICs and ECs. A land use covenant would be incorporated into the property deed and run with the land in perpetuity or until site conditions change. The areas of the property where ICs and ECs would be implemented are shown in Figures 10 and 11. The land use covenant is expected to require the following:

• ICs that restrict groundwater use to protect human health by addressing the groundwater ingestion pathway. The ICs would take the form of a deed restriction that would prohibit additional supply wells in a portion of the site (as shown in Figure 11). The potential for impacts to the current JPVEC supply well would be evaluated through continued monitoring of the sentry well (MW11), and treatment of the JPVEC supply well would be available as an EC option if concentrations of TCE are observed above drinking water standards in the sentry well. • ICs that restrict future land uses to protect human health by addressing the vapor intrusion pathway. The deed restriction discussed above would require vapor intrusion mitigation for any future buildings to be constructed in the area of the property impacted by TCE. Consistent with this land use restriction, the current SSD system at the JPVEC building would continue to operate unless and until the building is removed or concentrations attenuate to levels protective of human health.1 The SSD was assumed to operate for 30 years for cost estimating purposes. • A Site Management Plan (SMP) that provides guidelines for the implementation of ECs (such as vapor barriers) along with soil and groundwater management protocols. The SMP would define the actions to be taken in the event that TCE-impacted soil or groundwater are encountered during future construction or site development activities. The SMP would also include guidelines for the assessment and implementation of wellhead treatment for any new supply wells or potential contingency wellhead treatment for the existing JPVEC supply well.

1 While other existing buildings are within the footprint shown in Figures 10 and 11, the nature and use of these buildings do not currently require vapor intrusion mitigation.

Final FS Report 22 March 2019

Operation of the current SSD system in the current JPVEC building and annual sentry well (MW11) monitoring would continue unless and until the building is removed or concentrations attenuate to levels protective of human health. For the purpose of evaluating the remedial alternative, 30 years of SSD operation and annual sentry well monitoring are conservatively assumed, along with the preparation of the land use covenant and SMP. Costs associated with the implementation of the SMP are not included, as these costs are dependent upon the scope of future redevelopment; currently, there are no known plans for site development or installation of any new supply wells. As such, the estimated cost for this alternative is $3,130,000 with a +50%/-30% range of $2,191,000 to $4,695,000.

5.2.3 Alternative 3 – Targeted Soil Vapor Extraction with ICs and ECs

This alternative utilizes SVE to target the majority of the TCE mass in the gravel fill layer with the objective of reducing any long-term threat to groundwater and reducing the level of reliance on ICs and ECs for long-term protection of human health. The ICs and ECs would be similar to those presented in Alternative 2 above but may apply to a smaller area over time for those restrictions related to protection of human health the via vapor intrusion pathway and direct contact with soil. This alternative is expected to reduce soil vapor concentrations in the vicinity of the JPVEC building to levels protective of human health so that the current SSD system will operate for less time than is require for Alternative 2. Outside of the JPVEC building footprint, soil vapor concentrations in the target area are expected to decline to below commercial levels, such that vapor mitigation and soil management protocols may not be necessary over time or may apply to a smaller portion of the property. Figures 11 and 12 show the components of Alternative 3.

SVE wells would be installed to the southwest of and directly adjacent to the JPVEC building and are expected to be screened in the gravel fill (Figure 12). The target area has historically had some of the higher TCE concentrations in sub-slab vapor and the highest TCE concentrations in unsaturated soil. The target area focuses on portions of the gravel fill with TCE concentrations greater than 110 micrograms per kilogram (µg/kg), which, as discussed in Section 2.5.3, contain approximately 67% of the remaining TCE mass in the unsaturated zone. The ROI for an SVE well in the gravel fill is conservatively estimated to be 30 feet, based on previous SVE testing at the site. 2 A portion of the SVE target area (the former truck fill stand) also includes a 20-mil polyethylene liner at a depth of 3 to 5 feet bgs that was placed by the PCB Contractor in 2017 for the purpose of supporting future SVE actions by improving ROI. Using a 30 feet ROI, it is expected that five extraction wells would be sufficient to cover the targeted area, requiring approximately 1,500 feet of piping to reach the current SSD system enclosure (Figure 12). An assumed ten soil vapor monitoring points would be installed at various depths to assess system performance (i.e., confirm ROI and monitor soil vapor concentrations). For evaluation purposes,

2 A pilot study (Shannon & Wilson, 2010) found an ROI of 40-feet for one test well screened in the gravel fill layer. An ROI of 30-ft was used to account for geologic variation and provide sufficient overlap between the SVE wells.

Final FS Report 23 March 2019

the use of the existing SSD system is assumed. The system was designed and installed with a 10- horsepower blower and SVE manifold capable of connecting up to 20 SVE extraction lines.3 It is assumed the SVE system would operate for eight years, followed by three years of post-shutdown monitoring.

Operation of the SVE system is currently assumed to occur during the half of the year with non- frozen soil conditions (May to October) in an effort to improve efficiency of TCE extraction. It is assumed the SSD system would continue to operate year-round but would be monitored in conjunction with the SSD system three times a year. When the SVE system is on, the monitoring will assess SVE system performance. When the SVE system is off during the winter months, monitoring will be used to assess rebound of TCE concentrations in soil vapor. The SVE system is assumed to operate until:

• TCE concentrations in soil vapor have been reduced to levels protective of a commercial/industrial land use throughout the SVE area and to residential land use in proximity of the JPVEC building; • TCE mass in the gravel fill target area has been reduced by approximately 90 percent, based on extracted vapor concentrations upon SVE system startup; or • TCE concentrations in soil vapor have reached asymptotic conditions, both during operations and during rebound testing. Post-shutdown samples are assumed to be collected annually during the summer, when soil vapor concentrations will likely be higher.

If concentrations in soil vapor and sub-slab vapor beneath the JPVEC building are below the ADEC vapor intrusion residential target levels at SVE system shutdown, the current SSD system would also be shut down. For the purposes of this evaluation, operation of the SSD for two years after SVE shutdown is assumed, for a total of 10 years of operation.

Because TCE may be present in soil and/or groundwater, this alternative assumes ICs (i.e., land and groundwater use restrictions) will be used during and after SVE to protect human health under future land use scenarios. These land use restrictions would be the same as Alternative 2 above; however, it is expected the vapor intrusion mitigation system will be operated for a shorter period and less TCE-impacted soil will be encountered and managed under the SMP in comparison to Alternative 2.

3 The SSD/SVE system enclosure on-site has a 2.5-horsepower blower that applies the vacuum to the SSD and a currently unused 10-horsepower blower intended for SVE with an SVE manifold capable of connecting to 20 extraction wells. The capital costs for initiation of SVE remedial activities are associated with the installation of extraction wells and piping to the existing system enclosure.

Final FS Report 24 March 2019

The estimated cost for this alternative is $2,530,000 with a +50%/-30% range of $1,771,000 to $3,795,000. Similar to Alternative 2, 30 years of annual sentry well monitoring are assumed, along with the preparation of the land use covenant and SMP. Costs associated with the implementation of the SMP are not included, as these costs are dependent upon the scope of future redevelopment; currently, there are no known plans for site redevelopment.

5.2.4 Alternative 4 – Long-Term Groundwater Monitoring with ICs and ECs

The fourth alternative includes LTGM combined with ICs and ECs. The objective of LTGM is to monitor continued stability and natural attenuation of groundwater concentrations and to provide additional confirmation of protectiveness for the JPVEC supply well. This alternative also includes added protection of human health under current and future land uses through the implementation of ICs and ECs, consistent with those presented in Alternative 2 above. As such, the details on the ICs and ECs are not presented again in this section. Figures 10 and 13 show the components of Alternative 4.

Selected monitoring wells from the existing groundwater monitoring well network will be used for remedy performance monitoring. The need for additional wells will be assessed in the RAP, as part of the design of the preferred alternative. For cost comparison in this FS, 14 long-term groundwater monitoring wells are assumed. Monitoring is assumed to be conducted until TCE concentrations decline to levels below the groundwater cleanup level of 2.8 µg/L. For the purposes of cost estimating, 30 years of monitoring is assumed with semi-annual sampling (spring and fall) during the initial five years, and annual sampling for the subsequent seven years. Annual sampling will continue during the season for which the highest TCE concentrations are typically observed. After 12 years, it is assumed that the monitoring frequency can be reduced to biennial (every other year). At this time, it also is expected that some wells could be removed from the monitoring network based on established trends or reductions to less than the cleanup level. For the purposes of the cost estimate, biennial sampling is assumed to be performed on a reduced monitoring network consisting of 12 wells.

The estimated cost for this alternative is $3,470,000 with a +50%/-30% range of $2,429,000 to $5,205,000. As detailed in Appendix B, operation of the SSD system for an assumed 30 years makes up the majority of the estimate cost of this alternative.

5.2.5 Alternative 5 – Targeted SVE and LTGM with Limited ICs and ECs

Alternative 5 combines the installation and operation of an SVE system, as outlined in Alternative 3 above, with LTGM, as outlined in Alternative 4. ICs and ECs from Alternative 2 would also be included but could be limited in scope depending on site conditions and residual concentrations remaining after implementation of SVE and LTGM. Consistent with Alternative 3, the existing SSD system is assumed to operate for a total of 10 years (as opposed to 30 years under Alternatives 2 and 4). Figures 12 and 13 show the components of Alternative 5.

Final FS Report 25 March 2019

The estimated cost for this alternative is $2,870,000 with a +50%/-30% range of $2,009,000 to $4,305,000.

5.2.6 Alternative 6 – Excavation and LTGM with Limited ICs and ECs

This alternative includes excavation of TCE-impacted soil combined with LTGM and limited ICs and ECs. The Alternative 6 excavation boundary is outlined in Figure 14 and corresponds to the area where TCE has been detected above the most stringent soil cleanup level of 11 µg/kg. LTGM is assumed to be the same as Alternative 4. Limited ICs and ECs from Alternative 2 would also be included but the scope of which would depend on site conditions before, during, and after excavation.

The presence of site infrastructure (JPVEC building, maintenance building, fuel tank farm and dispensing system, antenna foundations) prevents access to a majority of the TCE-impacted area, therefore limiting the scope of the excavation. Therefore, the excavation would need to be performed in two stages (one now and one in the future when site infrastructure has been removed) or delayed until some indeterminate future time when site infrastructure is removed. For simplicity, the following description and costs assumes that impacted soil will be excavated in the future after site infrastructure is removed. If the excavation were to be completed in two stages, logistical costs (e.g., mobilization of heavy equipment and barging of excavated soil to/from Aniak) would be incurred twice (for each excavation event) and extensive shoring or sufficient side sloping would be needed during the first phase of excavation to ensure the integrity of existing foundations. In addition, if the excavation were completed in two stages, the first excavation may not be able to reach the targeted depth due side sloping requirements. As such, it would also mean that areas would need to be re-excavated when site infrastructure has been removed to reach the targeted depth of TCE impacts.

To protect human health in the interim, the current JPVEC SSD system would be operated as an EC until the building is demolished or concentrations attenuate to levels protective of human health.

Due to the lack of appropriate equipment and materials in Aniak, excavation equipment and backfill material would be barged to the site. During design, geotechnical drill will be required to determine the appropriate slide slope grade. Approximately 36,000 cubic yards of TCE-impacted soil is assumed to be excavated within the unsaturated zone at the site.4 The unsaturated zone is assumed to be the soil above the average groundwater level of approximately 71 ft NAVD88. Excavation depth will depend on the groundwater table elevation at the time of implementation. Clean overburden, including the backfill material from previous PCB excavation activities, will be stockpiled on-site and reused to backfill portions of the excavation. The excavated TCE-

4 Includes a 30% contingency on known volume with TCE over the cleanup goal, as additional excavation would likely be needed based on confirmation/verification sampling.

Final FS Report 26 March 2019

impacted soil would be containerized and barged from Aniak for disposal in an appropriate landfill. Disposal as non-hazardous waste is assumed.

Even if portions of the impacted soil were excavated prior to infrastructure removal, TCE mass would remain under the current JPVEC building, and therefore the SSD system would continue to operate as an interim EC until the building is removed or mitigation is no longer necessary. It is assumed that monitoring activities would continue three times per year throughout SSD system operation. Thirty years of SSD operations is assumed, as there are no current plans for abandonment and closure of the JPVEC building or for site redevelopment.

For the purposes of this evaluation, it is assumed all soil below the JPVEC is impacted by TCE. It is assumed the excavation extent would be refined, as needed, during excavation design. Excavation and backfill activities are assumed to take approximately four months. Building and infrastructure demolition activities are not included in this remedial alternative cost estimate.

Since impacted soil may be encountered during site activities prior to excavation, these potential risks would be mitigated through the preparation and implementation of an interim SMP. The interim SMP would be applicable until the impacted soil is excavated from the site. The interim SMP would include guidelines for the implementation of ECs (such as vapor mitigation systems) and soil management protocols should TCE-impacted soil be encountered during future construction or site development activities.

The estimated cost for this alternative is $13,170,000 with a +50%/-30% range of $9,219,000 to $19,755,000. However, the costs associated with this alternative have more uncertainty than the other alternatives due to the more complex nature of the work involved. Similar to the other alternatives, this alternative includes the preparation of an interim SMP but does not include implementation of the SMP, as these costs are dependent upon the scope of future site activities.

5.3 Alternatives Evaluation

Each alternative was evaluated using the criteria described in Section 5.3.1 below. Table 4 provides a summary of each alternative, an evaluation of each alternative using the criteria and a comparative ranking of the alternatives. Section 5.3.2 below provides a discussion on the comparative evaluations of the alternatives.

5.3.1 Evaluation Criteria

Each remedial alternative was evaluated using the following criteria:

• Overall Protectiveness of Human Health and the Environment: This criterion addresses whether or not a remedial alternative provides adequate protection of human

Final FS Report 27 March 2019

health and the environment and describes how risks posed through each pathway are eliminated, reduced, or controlled through treatment, ECs, or ICs. • Compliance with Laws and Regulations: This criterion addresses whether or not and identifies how each alternative complies with applicable federal/state/local requirements and guidelines. • Long-Term Effectiveness and Permanence: This criterion refers to the ability of a remedial alternative to achieve and maintain protection of human health and the environment over time. • Reduction of Toxicity, Mobility, and Volume: This criterion evaluates the remedial alternative with respect to how well it can permanently and significantly reduce toxicity, mobility, or volume of the hazardous substances. • Short Term Effectiveness: This criterion addresses the period of time needed to achieve protection and any adverse impacts on human health and the environment that may be posed during the construction and implementation period until the RAO and media-specific objectives are achieved. • Implementability: This criterion evaluates the feasibility of implementing a technology. The evaluation includes both institutional aspects of implementability, such as the ability to obtain access and permits for actions, as well as technical aspects such as site geology and infrastructure constraints, and the availability of treatment, storage, and disposal services to support the technology. • Cost: This criterion evaluates the relative capital and O&M costs of the alternatives.

The remedial alternatives were compared against each other to select the preferred and recommended remedy for the site. The comparative evaluation included scoring of each alternative under each of the criteria above (1 through 5 scoring with a score of 1 for most favorable). Protection of human health and the environment and compliance with laws and regulations are not scored, but rather were evaluated to be acceptable or not acceptable. For the remaining criteria (long-term effectiveness and permanence; reduction of toxicity, mobility, and volume through treatment; short-term effectiveness; implementability; and cost), the major tradeoffs among alternatives are discussed and considered when selecting the preferred alternative.

5.3.2 Comparative Discussion of Alternatives

Table 4 presents the evaluation of each alternative. As shown in this table, the No Action Alternative (Alternative 1) was determined not to satisfy the first two evaluation criteria: protection of human health and the environment and compliance with laws and regulations. As such, this alternative was not retained for the comparative analysis discussed herein. The other five alternatives were determined to satisfy the first two criteria and are retained for further evaluation.

Final FS Report 28 March 2019

The following bullets provide a comparison of the alternatives using each of the remaining evaluation criteria:

• Long-Term Effectiveness: Alternative 5 actively removes TCE mass from the subsurface while monitoring groundwater stability, and therefore received the top score for long-term effectiveness and permanence. Alternative 2 is the least effective in the long-term. • Reduction of Toxicity, Mobility, and Volume: Alternatives 3, 5, and 6 include SVE or excavation of TCE, thereby reducing the volume and mass of TCE on-site through active removal. These alternatives received the top score. While natural attenuation is expected at this site, the other alternatives monitor concentrations but do not actively reduce toxicity, mobility, or volume and did not score as well. • Short-Term Effectiveness: Alternatives 2 and 4 could be quickly implemented, would be effective at meeting their objectives and scored favorably for short-term effectiveness. Alternative 6 scored unfavorably for short-term effectiveness, because the excavation could only be partially completed in the short-term and would cause significant disruption to the site. Alternatives 3 and 5 had more moderate scores because they require installation of an SVE system, which would take longer to implement than Alternatives 2 and 4 but would be expected to be effective in the short-term. • Implementability: Alternatives 2 and 4 received the top score because they are the easiest options to implement and they do not require substantial construction, installation, or excavation at the site. Alternatives 3 and 5 would require more construction for the SVE portion of the remedies but would also be feasible to implement. Alternative 6 scored less favorably because it is the most difficult to implement, as it would require significant mobilization of equipment and materials and, if partly implemented while current site infrastructure remains in place and in use, is the most disruptive to site operations. • Cost: Alternative 3 is estimated to be the least expensive alternative, followed relatively closely by Alternatives 2, 4, and 5 (Chart 1). The costs of these three alternatives are essentially equivalent because their estimated cost ranges overlap. Alternative 6 is estimated to be 3 to 4 times more expensive when compared to the other alternatives.

Table 4 presents unweighted summary scores of the evaluation criteria for long-term effectiveness; reduction of toxicity, mobility, and volume; short-term effectiveness; and implementability. The alternatives are then ranked based on this score and considering the cost criterion. The three lowest scoring (and most favorable) alternatives were: Alternative 5 – Targeted SVE and LGTM with ICS and ECs with the lowest score, Alternative 4 – LTGM with ICs and ECs with the second- lowest score, and Alternative 3 – Targeted SVE with ICs and ECs with the third-lowest score. The three highest ranked alternatives are discussed in numerical order below:

Final FS Report 29 March 2019

• Alternative 3, targeted SVE with ICs and ECs, requires installation and operation of an SVE system, which is logistically challenging given the remote location of the site. Alternatives with LTGM (such as Alternatives 4 or 5) are more effective in the long term and more permanent. The SVE system would reduce the volume of TCE present in the gravel fill, providing protection of human health via the vapor intrusion pathway as well as reducing long-term risk to groundwater. This alternative was assigned an overall ranking of 3, based on its total score and relative cost when compared to the other alternatives. • Alternative 4, LTGM with ICs and ECs, could be implemented quickly. This alternative would not reduce the toxicity, mobility, or volume of TCE through treatment, but would rely on natural attenuation of TCE. However, TCE concentrations are expected to attenuate over time and the commitment to LTGM would make this alternative effective in the long- term at protecting human health when considering the groundwater ingestion pathway. This alternative was assigned an overall ranking of 2. The cost is anticipated to be approximately 20% more than Alternative 5 due to the anticipated long-term need for 30 years of SSD operations. • Alternative 5, targeted SVE and LTGM with limited ICs and ECs, would be effective in both the short-term and the long-term. The active removal of TCE from the soil vapor would reduce the volume and mass of TCE on-site, protecting groundwater and addressing the vapor intrusion pathway. Similar to Alternative 4, implementation of this alternative would be feasible but transportation of equipment and materials to a remote site would be challenging. This alternative was assigned an overall ranking of 1. This alternative is anticipated to be more cost-effective than Alternative 4, as SVE (8 years) is expected to reduce long-term reliance on the current SSD system (10 years).

The two remaining alternatives, Alternative 2 – ICs and ECs and Alternative 6 – Excavation and LTGM with Limited ICs and ECs scored the least favorable (i.e., had the highest scores).

• Alternative 2, consisting of ICs and ECs, could be implemented quickly and is very feasible. However, ICs and ECs alone do not reduce toxicity, mobility, or volume of TCE and may not be effective in the long-term. This alternative was ranked as number 4. • Alternative 6, excavation and LTGM with limited ICs and ECs, would be effective in the long-term due to the permanent removal of TCE-impacted soil. However, excavation would be difficult to implement in the short-term with the site infrastructure in place and there would be a potential risk to mobilization of TCE from the silt layer to underlying groundwater during implementation. Assuming excavation does not take place until site infrastructure is removed, this alternative would not reduce the duration of ECs (such as the SSD system). This alternative would be difficult to implement due to the large mobilization effort and was assigned a rank of 5.

Final FS Report 30 March 2019

6. RECOMMENDED REMEDIAL ALTERNATIVE

Alternative 5, targeted SVE and LTGM with limited ICs and ECs, is the recommended remedial alternative. This alternative is protective of human health and the environment and complies with laws and regulations. This alternative also received the most favorable (lowest) score and its cost is reasonable relative to the other alternatives.

The permanent removal of TCE through operation of the SVE system would be effective in the long-term and would reduce TCE mass in the target area. This would also likely promote TCE attenuation in surrounding areas. The SVE system would also reduce risk to underlying groundwater, provide protection of human health by addressing the vapor intrusion pathway, and reduce the duration of required SSD operation. The use of ICs and ECs make this alternative effective in the short-term, although implementation of the SVE system would result in temporary site impacts during system installation.

Groundwater exposure would be mitigated through the use of LTGM, ICs and ECs. The stability and attenuation of TCE concentrations would be confirmed by groundwater monitoring. Sentry well monitoring would be used to continue to confirm protection of the JPVEC supply well.

Final FS Report 31 March 2019

7. CONCLUSIONS

Several technologies were screened to address TCE impacts in both the unsaturated and saturated zones at the site. Based on the screening, the retained unsaturated and saturated zone technologies were combined to create six alternatives for further evaluation:

• Alternative 1 – No Action; • Alternative 2 –ICs and ECs; • Alternative 3 – Targeted SVE with ICs and ECs; • Alternative 4 – LTGM with ICs and ECs; • Alternative 5 – Targeted SVE and LTGM with Limited ICs and ECs; and • Alternative 6 – Excavation and LTGM with Limited ICs and ECs.

As a result of the detailed evaluation of these alternatives, Alternative 5 was selected as the recommended remedial action to address TCE and its breakdown products at the site. This alternative is protective of human health and the environment, complies with applicable laws and regulations, and also scores favorably in both long- and short-term effectiveness while reducing TCE mass at the site.

Final FS Report 32 March 2019

8. REFERENCES

Alaska Department of Environmental Conservation (ADEC), 2018. 2017 PCB-Contaminated Soil Removal Report – ADEC Approval. Received by Matt Tanaka, from Bill O’Connell. 17 September.

Ecology and Environment (E&E), 1997. Final Site Inspection Report, White Alice Communications Site SI, Aniak Alaska. Prepared for the United States Environmental Protection Agency. September.

Geosyntec Consultants, Inc. (Geosyntec), 2016. Trichloroethene Remedial Investigation and Feasibility Study Work Plan, Former WACS Site / Joe Parent Vocational Education Center, Aniak, Alaska. August.

Geosyntec, 2018. Draft Trichloroethene Remedial Investigation Report. Former WACS Site / Joe Parent Vocational Education Center. Aniak, Alaska. May.

OASIS Environmental, Inc., (OASIS), 2012. Focused Feasibility Study – Groundwater, Aniak Middle School, Aniak, Alaska. June.

Olgoonik Specialty Contractors, LLC and SLR International Corporation (Olgoonik/SLR), 2018. 2017 PCB-Contaminated Soil Removal, Former WACS Aniak Middle School. Aniak, Alaska. 18 May.

Reynolds, G.L., 1988. Historical overview and inventory--White Alice Communications System: United States Army Corps of Engineers, Alaska District, 98 p.

Shannon & Wilson, 2008. TCE Characterization, Former White Alice Communication System, Aniak Middle School Site, Aniak, Alaska. November.

Shannon & Wilson, 2010. Final Site Characterization Report, Former White Alice Communication System, Aniak Middle School Site, Aniak, Alaska. June.

United States Environmental Protection Agency (USEPA), 1988. Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA. October.

Final FS Report 33 March 2019

TABLES

Final FS Report March 2019 Geosyntec Consultants

Table 1 Default Remedial Action Cleanup and Target Levels TCE Feasibility Study Former WACS Site/Joe Parent Vocational Education Center Aniak, Alaska

Units TCE cDCE tDCE VC PCE ADEC Method Two Soil Cleanup Levels Human Health mg/kg 4.9 200 960 0.65 68 Migration to Groundwater mg/kg 0.011 0.12 1.3 0.0008 0.19 ADEC Groundwater Cleanup Levels Groundwater Cleanup Level µg/L 2.8 36 360 0.19 41 ADEC Vapor Intrusion Target Levels Residential Target Levels Groundwater µg/L 5.0 NA NA 1.5 58 Soil Gas µg/m3 20 NA NA 17 410 Indoor Air µg/m3 2.0 NA 790 1.7 41 Commercial Target Levels Groundwater µg/L 21 NA NA 25 240 Soil Gas µg/m3 84 NA NA 280 1,800 Indoor Air µg/m3 2.2 NA 790 28 41

Notes: μg/L = micrograms per liter µg/m3 = micrograms per cubic meter ADEC = Alaska Department of Environmental Conservation cDCE = cis-1,2-dichloroethene mg/kg = milligrams per kilogram NA = not applicable PCE = tetrachloroethene TCE = trichloroethene tDCE = trans-1,2-dichloroethene VC = vinyl chloride

Page 1 of 1 March 2019 Geosyntec Consultants

Table 2 TCE Mass Estimates by Geologic Unit TCE Feasibility Study Former WACS Site/Joe Parent Vocational Education Center Aniak, Alaska

Unsaturated Zone Soil > 11 µg/kg Soil > 50 µg/kg Soil > 110 µg/kg Percent of Total Percent of Total Percent of Total Percent of Total Average Contaminant Percent of Total Average Contaminant Percent of Total Average Contaminant Lithological Layer Soil Volume Soil Soil Volume Soil Soil Volume Soil Impacted Soil Concentration Mass Impacted Soil Concentration Mass Impacted Soil Concentration Mass (cy) Contaminant (cy) Contaminant (cy) Contaminant Volume (µg/kg) (lbs) Volume (µg/kg) (lbs) Volume (µg/kg) (lbs) Mass Mass Mass Gravel Fill 16,600 64% 150 8.6 79% 5,000 19% 460 7.7 71% 3,100 12% 690 7.3 67% Fine Silt 9,300 36% 100 2.3 21% 3,100 12% 250 1.9 17% 1,900 7% 370 1.7 16% Total Unsaturated Soil 25,900 100% 125 10.9 100% 8,100 31% 355 9.6 88% 5,000 19% 530 9.0 83% Saturated Zone Soil > 11 µg/kg Soil > 50 µg/kg Soil > 110 µg/kg Groundwater > 2.8 µg/L Groundwater > 10 µg/L Groundwater > 28 µg/L Average Soil and Percent of Total Average Percent of Total Soil and Percent of Total Percent of Total Soil and Percent of Total Average Percent of Total Lithological Layer Contaminant Concentration Contaminant Contaminant Groundwater Impacted Concentration (µg/kg Groundwater Groundwater Impacted Groundwater Groundwater Impacted Concentration (µg/kg Groundwater Mass (µg/kg saturated Mass Mass Volume Groundwater saturated soils; µg/L Contaminant Volume Groundwater Contaminant Volume Groundwater saturated soils; µg/L Contaminant (lbs) soils; µg/L (lbs) (lbs) (cy) Volume groundwater) Mass (cy) Volume Mass (cy) Volume groundwater) Mass groundwater) Sorbed to Fine Silt * 250 2% 71 0.04 8% 70 1% 180 0.03 6% 40 0% 270 0.03 5% Sorbed to Gravelly Sand * 2,600 22% 56 0.43 82% 650 5% 160 0.30 57% 300 3% 250 0.22 41% Total Saturated Soil 2,850 24% 64 0.47 90% 720 6% 170 0.33 63% 340 3% 260 0.24 46% Groundwater in Fine Silt 600 5% 14 0.004 1% 140 1% 42 0.003 1% 65 1% 71 0.002 0% Groundwater in Gravelly Sand 11,400 95% 8.4 0.05 9% 1,300 11% 38 0.03 5% 610 5% 61 0.02 4% Total Groundwater 12,000 100% 11 0.05 10% 1,440 12% 40 0.03 5% 675 6% 66 0.02 4% Total Saturated Soil and 12,000 100% - 0.53 100% 1,440 12% - 0.36 68% 675 6% - 0.26 50% Groundwater **

Notes: The most conservative ADEC cleanup level for soil is 11 µg/kg and for groundwater is 2.8 µg/L. The other concentrations shown in this table are arbitrary concentrations for consideration. Three dimensional modeling software was used to estimate volumes, concentrations, and contaminant mass values using site data from the Remedial Investigation Report. An exponential Kriging model was used as it most closely approximated known conditions at the site. The boundaries of the volumes were determined based on the designated concentrations. Percentages based on total volume/mass within the unsaturated or saturated zone that exceeds designated concentrations. A water table elevation of 71.8 feet NAVD88 was used to approximate the saturated and vadose zones. * Mass of sorbed constituents in soil is based on exceedance of designated concentrations in saturated soil samples. ** Estimated using volume of soil within groundwater impacts over designated groundwater concentrations, as the saturated soil exceedances are generally inside the extent of the groundwater impacts.

Page 1 of 1 March 2019 Geosyntec Consultants

Table 3 Remedial Technology Description and Screening TCE Feasibility Study Former WACS Site/Joe Parent Vocational Education Center Aniak, Alaska

Retained Technology for Remedial Technology Description Effectiveness Implementability Relative Cost Alternative Development? Unsaturated Zone (Unsaturated Soil and Soil Vapor) Not effective for protecting human health and the environment Implementable, but not acceptable to the general public or Yes, for comparison to other No Action No institutional or engineering controls, actions, or treatment. No cost. when risks are present. government agencies. alternatives Implement land use restrictions to inform current and future site owners of TCE and breakdown product impacts at the site and for the protection of human health and environment. ICs Effectiveness for protection of human health and environment could include land use restrictions, such as the prohibition of would depend on enforcement of and compliance with land Practical to implement with property owner Institutional Controls (ICs) - Land Use Restrictions current and future building occupation without use covenants and specific application. Given site conditions approval/acceptance. Specific legal requirements and Low capital. Yes implementation of engineering controls and implementation of and anticipated land use, ICs could be effective to mitigate authority would need to be met. soil management protocols, should soil with residual levels of potential risk to human health and the environment. TCE be encountered during future construction or site development activities. Effective for preventing direct contact exposure (i.e. dermal contact or ingestion); however, this risk is not considered significant since soil concentrations are below human health Technically implementable for areas around existing buildings Installation of cap over TCE-impacted soil to prevent or cleanup criteria for direct contact. Can limit infiltration and No, but current onsite buildings and structures; however, significant regrading may be needed. reduce migration to groundwater and exposure. Cap may leachate formation, but less effective than source removal act as a cap and should be Engineering Controls (ECs) - Capping Existing buildings could act as a cap to the soil that underlies Moderate capital. Low O&M. include asphalt or concrete paving, synthetic membranes, or options for protection of groundwater. Also, less effective for considered in selected remedial them; however, the majority of TCE mass is located outside low permeability soil in landscaped areas. protection of human health via the vapor intrusion pathway. design the existing building footprints. Long-term effectiveness would be dependent on continued maintenance of the cap and would reduce options for future site redevelopment Continued operation of sub-slab depressurization (SSD) Effective for preventing migration of TCE into indoor air. Not system inside JPVEC building, and implementation of SSD effective for decreasing concentrations of TCE in the Technically implementable. SSD system already operating at Moderate capital. Moderate ECs - Vapor Intrusion Mitigation System for any future buildings. Prevents vapor intrusion to indoor Yes subsurface or protection of groundwater. Also not effective at site. O&M. air. Additional vapor intrusion mitigation systems may also be mitigating potential dermal contact or ingestion pathways. implemented in the future. Difficult to implement, given remote site location that would require transportation of drill rig, injection trailer, and No, not viable due to Injection of chemical oxidant into TCE-impacted soil through Effective for treating TCE in and immediately surrounding the oxidants. Multiple injection events may be needed. In In Situ - Chemical Oxidation High capital. Moderate O&M. implementability concerns and direct-push injections. injection areas. addition, injections into vadose zone would be a challenge cost. given depth and ability to effectively distribute oxidant throughout targeted area. No, infeasible due to current and Survival of phytoremediation trees may be limited due to site Not practical to implement, given that the existing JPVEC Trees (e.g., poplars) planted in the areas with TCE impacted assumed future land use (i.e., location. Effectiveness of plant uptake of TCE also limited by building would block access for planting trees. Would need to Moderate capital. Moderate In Situ - Phytoremediation soil. TCE uptaken from the soil into the plant, then phyto- building configurations), as well cold climate conditions. During cold weather, plants slow plant trees directly into the impacted area at locations used by O&M. volatilized and degraded in the atmosphere. as uncertainty of effectiveness in metabolic processes or go dormant altogether. the JPVEC building for access. colder climate Vacuum is applied through extraction wells to create an Effective for removing TCE mass in coarser-grained soils. advective pressure gradient in TCE impacted areas. This However, presence of fine-grained soils may reduce Technically implementable, but challenging given the remote gradient also induces gas-phase volatiles to diffuse through Moderate capital. Moderate In Situ - Soil Vapor Extraction (SVE) effectiveness. SVE would mitigate potential vapor intrusion location of the site. Existing building infrastructure may limit Yes soil to extraction wells outside of the radius of influence of the O&M. risks and reduce risks to underlying groundwater through access to potential TCE mass beneath the building. vacuum. The process could include a system for treating off- mass removal in the unsaturated zone. gas. Effective for permanent TCE removal in excavation areas and Technically implementable. Demolition of structures and Excavation and disposal of impacted material. Import of clean Excavation mitigating potential risks to human health and the infrastructure would be required where they overlie areas of High capital. Negligible O&M. Yes fill. environment. impacted soil. Possible depth limitations.

Page 1 of 3 March 2019 Geosyntec Consultants

Table 3 Remedial Technology Description and Screening TCE Feasibility Study Former WACS Site/Joe Parent Vocational Education Center Aniak, Alaska

Retained Technology for Remedial Technology Description Effectiveness Implementability Relative Cost Alternative Development?

Not effective for protecting human health and the environment Monitoring to confirm continued degradation of TCE through Yes, but only as an element in from potential vapor intrusion risks while concentrations are Implementable, but possibly not acceptable to the general Long-Term Soil Vapor Monitoring naturally occurring processes such as dispersion and Low capital. Moderate O&M. evaluating the performance of above criteria for protection of human-health. Not effective for public or government agencies. volatilization. other technologies reducing potential impacts to groundwater. Saturated Zone (Groundwater and Saturated Soil) Not effective for protecting human health and the environment Implementable, but not acceptable to the general public or Yes, for comparison to other No Action No institutional or engineering controls, actions, or treatment. No cost. when risks are present. government agencies. alternatives Implement land and groundwater use restrictions to inform current and future site owners of TCE and breakdown Effectiveness for protection of human health and environment products at the site and for the protection of human health and would depend on enforcement of and compliance with land environment. ICs could include TCE monitoring in a sentry use covenants and specific application. Prevents ingestion of Practical to implement with property owner ICs - Groundwater Use Restrictions well located upgradient of existing JPVEC water supply well, TCE-impacted groundwater. Given site conditions and approval/acceptance. Specific legal requirements and Low capital. Yes requiring engineering controls if TCE is detected in the sentry anticipated land and groundwater use, ICs could be effective authority would need to be met. well, and restricting the operation of current and future supply to mitigate potential risk to human health and the wells without the inclusion of engineering controls (e.g. environment. wellhead treatment). Implementation of wellhead treatment as an engineering Effective for preventing ingestion of TCE-impacted control at the JPVEC supply well, should groundwater with Technically implementable. Transportation, installation, and groundwater. Long-term effectiveness would depend on ECs - Wellhead Treatment residual levels of TCE be detected in an upgradient sentry operation of wellhead treatment system may be challenging Moderate capital. Low O&M. Yes, as a contigency only continual well monitoring and operation of the wellhead well. Engineering controls implemented for any future supply given the site location. treatment systems. wells. Effectiveness of technology may be limited by cold climate and ability of microbes to survive. If conditions are suitable Drilling of temporary borings and injection of electron donor Possibly implementable. Would need to conduct pilot study to for bioremediation, this could be effective for permanent TCE In Situ - Enhanced Reductive Dechlorination and microbial culture into the TCE source area to enhance determine if microbial cultures could survive in the climate. Moderate to high capital. degradation. For biotic reduction, this technology is more Yes, as a contigency only (Biotic or Abiotic) reductive degradation of TCE in the groundwater and Additionally, transportation of drilling and injection Moderate O&M. effective in higher concentration source areas (typically >50 saturated soil. equipment and amendments would be logistically challenging. µg/L of TCE initially), and biotic reduction may be slower or less effective at lower concentrations. Technically implementable. However, transportation of drill Chemical oxidation could be an effective technology for rig, injection trailer, and amendments would be logistically treating TCE in and immediately surrounding the injection difficult due to the remote location of the site. Naturally high No, not viable due to Injection of chemical oxidant into groundwater and saturated Moderate to high capital. In Situ - Chemical Oxidation areas. However, naturally occurring high soil oxidant demand SOD creates an additional implementation challenge, as this implementability concerns and soil through direct-push injections. Moderate O&M. (SOD) would likely reduce the effectiveness of the chemical would require large doses of chemical oxidant. Delivery of cost. oxidant on the TCE. oxidant to remote location could possibly pose safety concerns. Effectiveness uncertain. Technology is unproven for low Technically implementable. However, transportation of drill Injection of activated carbon through direct-push injections. concentrations of TCE and cold weather climates. No, unproven technology for rig, injection trailer, and amendments would be logistically Moderate to high capital. Low In Situ - Activated Carbon Indefinite retention of TCE by adsorption onto carbon Immobilized TCE mass bound to carbon would remain in the relatively low concentrations and difficult due to the remote location of the site. Injection into O&M. molecules. subsurface and could pose potential risks during future site colder climates the fine silt layer may pose an additional challenge. excavation or construction activities.

Page 2 of 3 March 2019 Geosyntec Consultants

Table 3 Remedial Technology Description and Screening TCE Feasibility Study Former WACS Site/Joe Parent Vocational Education Center Aniak, Alaska

Retained Technology for Remedial Technology Description Effectiveness Implementability Relative Cost Alternative Development? Survival of phytoremediation trees may be limited due to site Not practical to implement, given that the existing JPVEC No, infeasible due to current and Trees (e.g., poplars) planted in the areas with TCE impacted location. Effectiveness of plant uptake of TCE also limited by building would block access for planting trees. Would need to assumed future land use (i.e., groundwater and saturated soil. TCE uptaken from the cold climate conditions. During cold weather, plants slow In Situ - Phytoremediation plant trees directly into the impacted area at locations used by Moderate capital. Low O&M. building configurations), as well saturated zone into the plant, then phyto-volatilized and metabolic processes or go dormant altogether. Effectiveness the JPVEC building for access. Additionally, tree roots may as uncertainty of effectiveness in degraded in the atmosphere. also depends on ability to plant trees directly into the saturated not be able to reach saturated zone. colder climate zone. Injection of air into the saturated zone using air sparge wells Ineffective for site conditions, as the TCE impacted to induce volatilization of TCE. Volatized TCE mass is groundwater is located in a semi-confined aquifer. The fine Not practical to implement given the site conditions. captured using a vapor capture system (e.g. SVE), liquids are No, likely ineffective for site silt layer may act as an aquitard, which would trap the vapor Additionally the installation, transportation, and operation of Moderate to high capital. Ex Situ - Air Sparging collected in knock-out tank, and air stream is treated prior to conditions and impractical to stream from the gravelly sand and prevent it from capture by equipment logistically difficult given the remote location of Moderate O&M. venting to atmosphere. Liquid waste is taken off-site for implement SVE. Additionally, air sparge would not be effective for the the site. disposal. Vapor capture from air sparging could be combined fine silt layer. with unsaturated zone SVE.

Extraction of groundwater using existing and/or new wells Not practical to implement due to groundwater and equipment and treating TCE on-site with a new onsite treatment system. Effectiveness limited by relatively low concentrations of TCE. Ex Situ - Groundwater Extraction and Treatment freezing concerns. Installation, transportation, and operation No, low long-term effectiveness Objective is both removal of TCE from groundwater and Not an effective technology for significantly reducing mass or High capital. High O&M. (i.e. "pump and treat") of equipment logistically difficult given the remote location of for mass removal prevention of groundwater migration to existing JPVEC water volume of TCE in the saturated zone. the site. supply well. Technically implementable. Uses existing monitoring wells to Monitoring existing and new wells to track continued Concentrations of TCE are relatively low. Natural TCE evaluate natural attenuation. Installation of new monitoring degradation of TCE through naturally occurring processes degradation would be effective in the long-term for reducing Moderate capital. Moderate Long-Term Groundwater Monitoring (LTGM) wells would be logistically challenging given the remote Yes such as dilution, dispersion, volatilization, and potential risks, but would need continued monitoring and O&M. location of the site, but feasible. biodegradation. protective measures in place in the interim.

Notes: µg/L - micrograms per liter ECs - engineering controls ICs - institutional controls JPVEC - Joe Parent Vocational Education Center LTGM - long-term groundwater monitoring O&M - operation and maintenance SSD - sub-slab depressurization SVE - soil vapor extraction TCE - trichloroethylene WACS - White Alice Communications System

Page 3 of 3 March 2019 Geosyntec Consultants

Table 4 Remedial Alternatives Evaluation TCE Feasibility Study Former WACS Site/Joe Parent Vocational Education Center Aniak, Alaska

Alternative Evaluation Categories Total Score Total Score Overall Remedial Protection of Human Health & the a Long-Term Effectiveness and Implementability b,c Alt Compliance with Laws and Regulations Reduction of Toxicity, Mobility and Volume Short-Term Effectiveness Cost (Unweighted, (Unweighted, Alternative Ranking Name Description a Permanence (1=High Feasibility; No. Environment (Yes=Compliant; No=Not Compliant) (1=Effective; 5=Ineffective) (1=Effective; 5=Ineffective) (1=Low; 5=High) Excluding Cost) Including Cost) (1=Top Alternative) (Yes=Protective; No=Not Protective) (1=Effective/Permanent; 5=Ineffective/Impermanent) 5=Low Feasibility) Under the No Action alternative, no further or additional (No) Not protective. This alternative (No) While current TCE concentrations in sub- (5) This alternative does not provide and (5) This alternative would not reduce the (5) This alternative is not (1) No action required to (1) $0 ($0 to $0) sampling, monitoring, investigation, remediation, or mitigation would not mitigate potential TCE slab vapor are below residential levels at the maintain reliable protection of human health toxicity, mobility, or volume of TCE. effective for addressing or implement this alternative. activities would be performed. As such, the SSD system at the exposure pathways via vapor JPVEC, discontinuation of the SSD system and the environment over time. mitigating potential exposure current JPVEC building would be shut down and groundwater intrusion to indoor air. It also does would likely lead to an increase in sub-slab to TCE in the short-term. monitoring would cease. not restrict installation of new and indoor air TCE concentrations. As such, 1 No Action supply wells or mitigate the indoor air concentrations may exceed 16 17 6 potential ingestion pathway for the regulatory levels. Additionally, the no action existing JPVEC supply well. alternative does not address concentrations of TCE in soil and groundwater above ADEC cleanup levels.

Protection of human health and the environment under the (Yes) ICs and ECs would be (Yes) This alternative would meet laws and (4) TCE impacts are expected to be stable (4) This alternative does not treat TCE, and (1) This alternative is (2) Implementation of this (2) $3,130,000 current and future land uses through the use of ICs and ECs protective for current and future site regulations for protection of human health via and ICs/ECs will protect human health by therefore would not reduce toxicity, mobility, effective in the short-term as alternative is feasible with ($2,191,000 to would include: (1) prohibition of additional supply wells uses. Continued operation of the vapor intrusion, direct contact, and mitigating potential vapor intrusion, direct or volume through treatment. The mobility of the SSD at the JPVEC approval from and coordination $4,695,000) without wellhead treatment in a portion of the property and SSD system would mitigate groundwater ingestion. contact, and ingestion pathways long-term. TCE into overlying building(s) would be building prevents inhalation with the current land owner. SSD requirement for sentry well monitoring (MW11) for the current potential vapor intrusion into the However, the lack of long-term monitoring reduced by vapor mitigation systems. While exposure and no impacts are operations would continue; a JPVEC supply well, with contingency wellhead treatment as an existing JPVEC building. Sentry for groundwater would inhibit the ability to the volume or potential mobility downward to currently present at the land use covenant would be EC, if concentrations of TCE are observed above drinking water well monitoring and contingency confirm reliable protection over time. the underlying groundwater would not JPVEC supply well. incorporated into the site deed standards in the future in the sentry well; (2) continued wellhead treatment would mitigate change, ECs would protect human health via for ICs and ECs; and an SMP operation of the current SSD system in the JPVEC building the potential ingestion pathway for the ingestion pathway. However, without would be prepared and (unless and until the building is removed or concentrations the existing JPVEC supply well. groundwater monitoring the mobility or implemented. If needed, Institutional attenuate to levels protective of human health) and prohibition volume of the TCE impacts could not be wellhead treatment at the JPVEC Controls (ICs) and of building construction in the portion of the property overlying assessed. supply well could be 2 11 13 4 Engineering Control the TCE impacts without the assessment for and implementation implemented using a mobile unit (ECs) of vapor intrusion mitigation as an EC; and (3) restriction of (likely granular activated future construction activities, through the preparation and carbon). implementation of a Site Management Plan (SMP), which would include guidelines for the implementation of ECs (such as vapor mitigation systems) and requirements for the assessment and implementation of wellhead treatment for any new supply wells or contingency wellhead treatment for the existing JPVEC supply well.

Installation and operation of an SVE system to target the (Yes) ICs and ECs would be (Yes) This alternative would meet laws and (3) Permanent removal of TCE mass in the (2) By focusing on the majority of TCE mass (2) This alternative is (3) Implementation of the limited (2) $2,530,000 majority of mass in the gravel fill layer with the objective of protective for current and future site regulations for protection of human health via target SVE area would be effective in the in the unsaturated zone, this alternative would effective in the short-term as SVE system would be feasible ($1,771,000 to reducing threat to groundwater and reducing the level of uses. In addition to mitigating risk to vapor intrusion, direct contact, and long-term and likely promote TCE be effective at reducing the mass and volume the SSD at the JPVEC but challenging given the remote $3,795,000) reliance on ICs and ECs for long-term protection of human human health via ICs and ECs, this groundwater ingestion. attenuation in areas surrounding the target of TCE, as well as reducing potential mobility building prevents inhalation location of the site. A land use health. The SVE system is assumed to operate half the year for alternative also would remove the area. SVE also reduces risk to underlying downward to groundwater. This alternative exposure and no impacts are covenant would be incorporated 8 years, followed by 3 years of post-shutdown monitoring. Ten majority of remaining TCE mass in groundwater and provides protection of would also be effective at reducing the currently present at the into the site deed for ICs and (10) years of continued SSD operations at the current JPVEC the unsaturated zone and thereby human health via the vapor intrusion mobility of TCE into overlying building(s). JPVEC supply well. contingent ECs and require land building is assumed. Based on residual concentrations after reduce reliance on ICs and ECs and pathway. TCE impacts are expected to be However, without groundwater monitoring the However, implementation of owner acceptance and Targeted Soil Vapor SVE, additional protection of human health and the environment reduce risk to underlying stable and ICs/ECs will protect human extent of the resulting reduction in mobility, the SVE remedy will have coordination. An SMP would be 3 Extraction (SVE) 10 12 3 is assumed for future land uses through the implementation of groundwater. Sentry well monitoring health by mitigating potential vapor mass and volume of the TCE impacts could temporary impact on the site prepared and implemented. If with ICs and ECs the same ICs and ECs, for both unsaturated and saturated zone, and contingency wellhead treatment intrusion and ingestion pathways long-term. not be assessed. by disturbing impacted soil needed, supply wellhead outlined in Alternative 2 (except that the SSD system would not would mitigate the potential However, the lack of long-term monitoring during SVE well and treatment could be implemented operate after the assumed 10-year period). ICs and ECs could be ingestion pathway for existing for groundwater would inhibit the ability to conveyance line installation. using a mobile unit (likely reduced over time based on residual concentrations remaining JPVEC supply well. confirm reliable protection over time. Impacts due to SVE granular activated carbon). after SVE implementation. installation are expected to be minimal.

Page 1 of 2 March 2019 Geosyntec Consultants

Table 4 Remedial Alternatives Evaluation TCE Feasibility Study Former WACS Site/Joe Parent Vocational Education Center Aniak, Alaska

Alternative Evaluation Categories Total Score Total Score Overall Remedial Protection of Human Health & the a Long-Term Effectiveness and Implementability b,c Alt Compliance with Laws and Regulations Reduction of Toxicity, Mobility and Volume Short-Term Effectiveness Cost (Unweighted, (Unweighted, Alternative Ranking Name Description a Permanence (1=High Feasibility; No. Environment (Yes=Compliant; No=Not Compliant) (1=Effective; 5=Ineffective) (1=Effective; 5=Ineffective) (1=Low; 5=High) Excluding Cost) Including Cost) (1=Top Alternative) (Yes=Protective; No=Not Protective) (1=Effective/Permanent; 5=Ineffective/Impermanent) 5=Low Feasibility) Along with implementation of the same ICs and ECs detailed (Yes) ICs and ECs would be (Yes) This alternative would meet laws and (2) This remedy would be effective long- (4) This alternative does not treat TCE, and (1) This alternative is (2) Same as Alternative 2 above, (3) $3,470,000 for Alternative 2 above, long-term groundwater monitoring protective of human health under regulations for protection of human health via term, as TCE impacts are expected to be therefore would not reduce toxicity, mobility, effective in the short-term as plus routine groundwater ($2,429,000 to (LTGM) would be conducted for continued protection of the current and future site uses via the vapor intrusion, direct contact, and stable, ICs/ECs will protect human health or volume through treatment. The mobility of the SSD at the JPVEC sampling, which is relatively $5,205,000) JPVEC supply well and for tracking stability and natural vapor intrusion and direct contact groundwater ingestion. by mitigating potential vapor intrusion and TCE into overlying building(s) would be building prevents inhalation easy to implement. attenuation of TCE in groundwater. Monitoring would be pathways. Monitoring the stability ingestion pathways, and LTGM will allow reduced. However, the volume or potential exposure and no impacts are Long-Term conducted until TCE concentrations decline to levels below the of the TCE impacts in groundwater for monitoring of TCE stability and mobility downward to the underlying currently present at the Groundwater drinking water standard of 2.8 µg/L (assumed 30 years). Five (5) provides a method to confirm attenuation over time. groundwater would not change. TCE JPVEC supply well. 4 9 12 2 Monitoring (LTGM) years of semi-annual monitoring are assumed, followed by 7 protection in the future. concentrations are expected to attenuate over with ICs and ECs years of annual monitoring. This will be followed by 18 years of time, and monitoring would confirm stability biennial (every other year) monitoring on a reduced monitoring and the reduction of TCE impacts in network. The monitoring network would consist of the existing groundwater. site wells (14 wells). The need for additional wells would be assessed in the Remedial Action Plan.

Installation and operation of an SVE system as outlined in (Yes) In addition to mitigating risk (Yes) This alternative would meet laws and (1) Permanent removal of the TCE mass in (2) This alternative would be effective at (2) This alternative is (3) Implementation of the limited (2) $2,870,000 Alternative 3. LTGM as outlined in Alternative 4. ICs and ECs to human health via ICs and ECs, regulations for protection of human health via the target SVE area would be effective in reducing the majority of TCE mass in the effective in the short-term as SVE system would be feasible ($2,009,000 to from Alternative 2 could also be included, but could be reduced this alternative would remove the vapor intrusion, direct contact, and the long-term and likely promote TCE unsaturated zone, as well as reducing potential the SSD at the JPVEC but challenging given the remote $4,305,000) over time based on residual concentrations remaining after SVE majority of remaining TCE mass in groundwater ingestion. attenuation in areas surrounding the target mobility downward to groundwater. This building prevents inhalation location of the site. Approval and LTGM implementation. the unsaturated zone, and thereby area. SVE also reduces risk to underlying alternative would also be effective at reducing exposure and no impacts are from and coordination with the reduce reliance on ICs and ECs and groundwater and provides protection of the mobility of TCE into overlying currently present at the current land owner would be Targeted SVE and reduce risk to underlying human health via the vapor intrusion building(s). TCE concentrations are expected JPVEC supply well. needed to implement ICs and 5 LTGM with Limited groundwater. Routine groundwater pathway. ICs/ECs will protect human health to attenuate over time, and monitoring would However, implementation of ECs. 8 10 1 ICs and ECs monitoring would be performed to by mitigating potential vapor intrusion and confirm the resulting reduction in mobility, the SVE remedy will have assess ongoing stability and ingestion pathways, and LTGM will allow mass and volume of the TCE. temporary impact on the site attenuation over time. for monitoring of TCE stability and by disturbing impacted soil attenuation over time. during SVE well and conveyance line installation.

Excavation to remove the TCE mass in the unsaturated zone (Yes) Excavation would eventually (Yes) This alternative would meet laws and (2) Permanent removal of the TCE mass (3) This alternative would be effective at (4) This alternative is (5) Excavation to the appropriate (5) $13,170,000 above the default remedial goals, including from the gravel fill remove the TCE that exceeds the regulations for protection of human health via would be effective in the long-term to removing TCE-impacted soil within the effective in the short-term as depths around existing site ($9,219,000 to and native silt layers within the unsaturated zone. The default cleanup goals in the vapor intrusion, direct contact, and human health and the environment, but unsaturated zone and reducing the mass and the SSD at the JPVEC infrastructure would be more $19,755,000) alternative could be completed all at once, during site unsaturated zones. Reduction of groundwater ingestion. some or all of the mass would remain unless volume of TCE. However, a portion or all of building prevents inhalation challenging to implement than redevelopment, or in two stages: initial removal of impacted soil TCE mass would remove the risk to and until areas are accessible after current the TCE-impacted soil would not be exposure and no impacts are installation of the SVE system. in accessible areas and a second excavation after eventual human health via direct contact and site infrastructure is removed. ICs/ECs will accessible unless and until the site is currently present at the Excavation requires one or two removal of site infrastructure. In the interim, the current JPVEC vapor intrusion pathways. Continued protect human health by mitigating potential redeveloped, requiring ongoing SSD for the JPVEC supply well. large mobilization and SSD system would continue to operation as an EC, until the operation of the SSD system would vapor intrusion and ingestion pathways, and protection of human health in the interim. However, implementation of demobilization efforts, as well as building is removed, or concentrations decline to levels mitigate the vapor intrusion pathway LTGM will allow for monitoring of TCE While mass removal in the vadose zone would the excavation remedy would offsite disposal of a significant protective of human health. LTGM as outlined in Alternative 4. for the JPVEC building. Routine stability and attenuation over time. reduce long-term risk to groundwater, have a notable short-term amount of soil waste. Routine Excavation and ICs and ECs from Alternative 2 would also be included, the groundwater monitoring would excavation could compromise the confining impact on the site by groundwater sampling would be 6 LTGM with Limited 14 19 5 level of which would depend on site conditions before, during, assess ongoing stability and silt layer above the saturated zone, creating a disturbing impacted soil and relatively easy to implement. ICs and ECs and after excavation. attenuation over time. potential new pathway for migration of site operations. Approval from and coordination residual TCE to groundwater. Barring such with the current land owner migration through a new pathway, TCE would be needed to implement concentrations in groundwater are expected to ICs and ECs. attenuate over time, and monitoring would confirm the resulting reduction in mobility, mass and volume of the TCE.

Notes: a. Protection of human health & the environment and compliance with laws & regulations need to be "Yes" for an alternative to be eligible for selection. b. Cost breakdowns for Alternatives 2 - 6 are provided in Attachment 1. All costs are -30%/+50%. Costs do not include decommissioning of existing infrastructure (wells and SSD system) as these would be universal costs for all alternatives. c. Cost for contingency measures, such as wellhead treatment, and building demolition are not included in the alternatives cost estimates. ADEC - Alaska Department of Environmental Conservation EC - engineering control IC - institutional control JPVEC - Joe Parent Vocational Education Center LTGM - long-term groundwater monitoring SSD - sub-slab depressurization SVE - soil vapor extraction TCE - trichloroethene µg/L - micrograms per liter

Page 2 of 2 March 2019

FIGURES

Final FS Report March 2019 ³ 8 2 2 0 9 1 0 2

M T S d x ^_ m . n o i t a c o L e t i S _ 1 0 g i F \ 8 1 7 0 9 0 s n o i s i v e R \ t r o p e R S F _ 8 1 0 2 _ 6 0 \ s t c e j o r P \ S I G \ n o i t a z i l a u s i V _ t n e m e g a n a M a t a D _ 6 0 \ S F

I R

E C T

S C A W

K A I ^_ N A _

2 0.5 0.25 0 0.5 Mile 1 7 0 G N P \ d e e h k c o

L Site Location _ s i l e x Former WACS Site and JPVEC E _ m o Aniak, Alaska c s a l A \ Legend s t n e i l C \ Site Location : ^_ P

Figure a t a D \

1 Notes 0 - e g a r - Basemap provided courtesy of National Geographic o 1 h c n Anchorage, Alaska March 2019 A Society. ³

Equipment Building

Maintenance JPVEC Drinking Building Water Well Fuel Tank %! Farm Antenna Former Leach / Foundation Seepage Pit

Joe Parent Vocational Educational Former Truck Center (JPVEC) Fill Stand Antenna Foundation

8 High School 2 2 0 9 1 0 2 Antenna M T S Foundation d x m . y t i n i c

i Antenna V e t i Foundation S _ 2 0 g i F \ 8 1 7 0 9 0 s n o i s High School i v %! e

R Drinking Water Well \ t r o p e R S F _ 8 1 0 2 _ 6 0 \ s t c e j o r P \ S I G \ n o i t a z i l a u s i V _ t n e m e g a n a M a t a D _ 6 0 \ S F

I R

E C T 200 100 0 200 Feet S C A W

K A I N

A Legend _ 2 1 7 0

G %! Drinking Water Wells N P \ d e Site Vicinity e h Location of original gravel fill based on 1959 imagery k c o L

_ Former WACS Site and JPVEC s i l e x Aniak, Alaska E _ m o c s a l A

\ s t n e i l C \ : P

Figure a t

a Notes D \ 1

0 Overlaid image is Survey Control Diagram for the Aniak Airport - e g a r Improvement, dated 01/07/2014. o 2 h c Anchorage, Alaska n Aerial imagery from June 20, 2007 received from Quantum Spatial. March 2019 A ³

Fuel Tanks

Dormitory 8

2 Antenna Foundation 2 0 9 1 0 2

M Seepage/Leach Pit T S d x m . l a i r e A 9 5 9 1 _ 3 0 g i F \

8 Equipment and 1 7 0

9 Power Building 0 s n Septic Tank o i s i v e R \ t r o p e R S F _ 8 1 0 2 _ 6 0 \ s t c e j o r P \ S I G \ n o i t a z i l a u s i V _ t n e m e g a n a M a t a D _ 6 0 \ S F

I R

E C T 200 100 0 200 Feet S C A W

K A I N A _ 2 1 7 0 Notes G N P \

d Aerial imagery received from Quantum Spatial. e e h 1959 Aerial Photograph k c o L

_ Former WACS Site and JPVEC s i l e x Aniak, Alaska E _ m o c s a l A

\ s t n e i l C \ : P

Figure a t a D \ 1 0 - e g a r o 3 h c Anchorage, Alaska n March 2019 A Equipment ³ Building

Metals Shop Former JPVEC Truck Fill Building Stand Wood Shop 8 2 2 0 9 1 0 2

M T S d x m . s n o i t c A l a v o m e R _ 4 0 g i F \ 8 1 7 0 9 0 s n o i s i v e R

\ High t r o p

e School R S F _ 8 1 0 2 _ 6 0 \ s t c e j o r P \ S I G \ n o i t a z i l a u s i V _ t n e m e g a n a M a t a D _ 6 0 \ S F

I R

E C T

S C A W

K A I

N 75 37.5 0 75 Feet

A Legend _ 2 1 7 0 G

N Approximate 2001 PCB Excavation P \ d e e h k c o

L Approximate 2008 Septic System and Extent of Removal Actions _ s i l e x Seepage/Leach Pit Excavation Former WACS Site and JPVEC E _ m Aniak, Alaska o c s a l A

\ Approximate 2008 PCB Excavation s t n e i l C \ : P

Figure

a Approximate 2017 PCB Excavation t a D \ 1 0 - e g a r Notes o 4 h c Anchorage, Alaska n Aerial imagery from June 20, 2007 received from Quantum Spatial. March 2019 A D' # SGP28 16-SB40 C'

SGP35 8

2 # 2 0 9 1

0 D 2

M T S d x m . s n o i t c e S s s o r C _ 5 0 g i F \ 8 1 7

0 16-SB47 9 0 s n o i

R P S

F W1-W-V _

8 FSCS102 1

0 FSCS105 2

_ " 6

0 W1-V

\ SGP1 s t " c e A j MW08 ! " # o r PA! 06-TS8 P \ P "

S 09-B21

I FSCS107

G " 08-B11 \ X < n ! o

i " t MW07 P a

z High School P i l 09-SB14 W2-N-V a " u Drinking Water Well 09-B20 s i

V W2-V " _ t %! " n 08-B18 e P W2-E-V m

e 16-SB52 g Legend W4A-V a n A! a M a t a Excavation Confirmation Cross Section A-A'

I R 16-SB28 08-B12 E A! Monitoring Well C Cross Section C-C' 17-SB67 T

S

C MW13

I "

N Soil Boring A Cross Section E-E'

_ P

2 MW13 1

7 100 50 0 100 Feet 0 Soil Boring / Temporary Well G < Dominant N ! P \ P d Point Groundwater e e h k c Flow Direction o # Soil Gas Point L _ s Plan View of Cross Sections i l e x Former WACS Site and JPVEC

E ! Surface Soil _ m

o Aniak, Alaska c s a %! Drinking Water Well l A

\ s t

n Notes e i l C \

: Data presented are from multiple years of investigation and excavation P

Figure a t

a and include results from the 2016-2017 RI and other investigations (2006, D \ 1

0 2008, 2009, and 2011) as applicable to the media presented. Data from - e g a r locations that were later excavated are excluded. o 5 h c Anchorage, Alaska March 2019 n Aerial imagery from June 20, 2007 received from Quantum Spatial. A CLIENT TCE RI/FS Coordinator 4101 Arctic Boulevard, #206 SUBSURFACE DIAGRAM PROJECT NUMBER PNG0712 Anchorage, AK 99503 Cross Section A-A' Telephone: 907-929-3326 PROJECT NAME TCE Remedial Investigation, Former Aniak WACS Site Figure 5A PROJECT LOCATION Aniak, Alaska NOTES All elevations are approximate. 0 50 100 150 200 250 300 350 400 450 500 550

110 110

JPVEC Building 105 105

09-SB14 SGP12 16-SB52 SGP11 MW07/09-B20 FSCS107 17-SB56 0.024 MW08/09-B21 W1-W-V W2-E-V 100 FSCS102 100 FSCS105 W2-V

0.014

95 ND 0.050 95 0.063 0.02 16-SB43 SGP23 FSCS21 16-SB47 FSCS18 90 FSCS24 90 FSCS13 36 0.0 0.065 < 0.019

ND 85 85

0.029 < 0.019 0.076 0.082 80 80 <0.015 < 0.039

0.067 23 0.035 0.0 0.023

Elevation (ft) 75 < 0.004 75

< 0.005 0.042 0.094 < 0.0045 0.044 70 70

0.004 < 0.0002

65 65

0.011

60 60

55 55

50 50 < 0.0005 Not for printing; use in zoomable PDF reader only for legibility. 45 45 0 50 100 150 200 250 300 350 400 450 500 550 Distance Along Baseline (ft) USCS USCS USCS Excavated Notes: Groundwater elevations taken from datalogger data Poorly-graded USCS Silt Well-graded Poorly-graded Material Highest Water Level Recorded 2014-2017 (May 2015) TCE sample results are shown as follows: between January 2014 and October 2017. Gravel Gravel Sand Screened Interval Groundwater (light blue-grey) mg/L Low, Mid, and High designations are from historical Average Water Level Recorded 2014-2017 Soil (light brown) mg/kg Color-Tec results as follows: 3 USCS Approximate Boundary of Excavations Soil gas (green) mg/m Low <10 ppb USCS Silty Well-graded USCS Silty Sand Not detected values are reported as less than the reporting Mid <30 ppb Gravel Lowest Water Level Recorded 2014-2017 (June 2017) Sand limit or as ND where reporting limit is not available. High >30 ppb LITHOLOGY_SAMPLERESULTS_11X17 - ANIAK_GINT_PROJTEMPLATE.GDT - 2/1/18 10:20 - P:\CLIENTS\ALASCOM_EXELIS_LOCKHEED\PNG0712_ANIAK WACS TCE RI FS\06_DATAMANAGEMENT_VISUALIZATION\GINT\ANIAK_GINT_RI_XSECT.GPJ TCE WACS - 2/1/18 10:20 - - ANIAK_GINT_PROJTEMPLATE.GDT P:\CLIENTS\ALASCOM_EXELIS_LOCKHEED\PNG0712_ANIAK LITHOLOGY_SAMPLERESULTS_11X17 CLIENT TCE RI/FS Coordinator SUBSURFACE DIAGRAM 4101 Arctic Boulevard, #206 PROJECT NUMBER PNG0712 Anchorage, AK 99503 Cross Section B-B' Telephone: 907-929-3326 PROJECT NAME TCE Remedial Investigation, Former Aniak WACS Site Figure 5B PROJECT LOCATION Aniak, Alaska NOTES All elevations are approximate. 0 50 100 150 200 250 300 350 400 450 500

110 110

JPVEC Building JPVEC Building

105 JPVEC 105 Drinking Water 16-SB52 17-SB55 17-SB63 MW11/09-B24 Well 09-SB9 0.024 SGP2 W20-V 08-B12 100 MW13 100 SGP18 < 0.064 Low

W33-V W27-V Low 95 09-SB12 0.050 95 W36-V 0.050 Low W40B-V

17-SB58 Low 0.017 < 0.016 90 SGP19 90 Mid 0.065 ND 0.11 < 0.02 Low 85 85 0.011 ND Mid < 0.04 0.029

6.96

High 80 < 0.034 80

0.023 < 0.032 Mid Elevation (ft) 75 75 0.602

< 0.0002 < 0.04 < 0.0045 0.187 70 70

0.055

65 65 High

< 0.0005

60 60

Mid

55 55

50 50 Not for printing; use in zoomable PDF reader only for legibility. 45 45 0 50 100 150 200 250 300 350 400 450 500

USCS USCS USCS Distance Along Baseline (ft) USCS Silty Notes: Groundwater elevations taken from datalogger data Well-graded Poorly-graded USCS Silt Poorly-graded Highest Water Level Recorded 2014-2017 (May 2015) Gravel Screened Interval TCE sample results are shown as follows: between January 2014 and October 2017. Gravel Sand Gravel Groundwater (light blue-grey) mg/L Low, Mid, and High designations are from historical Average Water Level Recorded 2014-2017 Soil (light brown) mg/kg Color-Tec results as follows: 3 USCS Approximate Excavation Boundaries Soil gas (green) mg/m Low <10 ppb Excavated Well-graded USCS Silty Sand Not detected values are reported as less than the reporting Mid <30 ppb Material Lowest Water Level Recorded 2014-2017 (June 2017) Sand limit or as ND where reporting limit is not available. High >30 ppb LITHOLOGY_SAMPLERESULTS_11X17 - ANIAK_GINT_PROJTEMPLATE.GDT - 2/1/18 10:22 - P:\CLIENTS\ALASCOM_EXELIS_LOCKHEED\PNG0712_ANIAK WACS TCE RI FS\06_DATAMANAGEMENT_VISUALIZATION\GINT\ANIAK_GINT_RI_XSECT.GPJ TCE WACS - 2/1/18 10:22 - P:\CLIENTS\ALASCOM_EXELIS_LOCKHEED\PNG0712_ANIAK - ANIAK_GINT_PROJTEMPLATE.GDT LITHOLOGY_SAMPLERESULTS_11X17 CLIENT TCE RI/FS Coordinator SUBSURFACE DIAGRAM 4101 Arctic Boulevard, #206 PROJECT NUMBER PNG0712 Anchorage, AK 99503 Cross Section C-C' Telephone: 907-929-3326 PROJECT NAME TCE Remedial Investigation, Former Aniak WACS Site Figure 5C PROJECT LOCATION Aniak, Alaska NOTES All elevations are approximate. 0 50 100 150 200 250 300 350 400

110 110

105 105

High School Drinking Water Well SGP5 350 ft MW14 MW04/08-B17 16-SB34 100 08-B18 08-B8 16-SB29 100 09-SB8 MW13 16-SB28 16-SB40 17-SB53 W4A-V W2-N-V Low W56,57-V W28-E-V < 0.0024 SGP40 W54,57-N-V W38A-V 0.080 Low 0.035 0.022 95 95 ND 0.64 0.140 Low < 0.0021 0.006 < 0.0024 ND 0.590 Low 90 90 0.470 0.013 Low

< 0.06 Low 0.868 85 1.10 85 < 0.0039 0.900 Low < 0.045 0.680 0.730 Low 80 0.044 80 0.730 Low < 0.056 0.089 0.690

0.040 0.210 Elevation (ft) 75 0.850 75 0.160 < 0.0045 0.510 < 0.0036

< 0.0039 0.180 0.003

< 0.0002 70 0.012 < 0.0034 < 0.0002 70 0.0062

0.055 0.065 0.060

65 < 0.002 65 < 0.0002

0.0009 60 60

< 0.0002 55 55

50 50

45 Not for printing; use in zoomable PDF reader only for legibility. 45 0 50 100 150 200 250 300 350 400

USCS USCS USCS Distance Along Baseline (ft) USCS Silty Notes: Groundwater elevations taken from datalogger data USCS Silt Well-graded Poorly-graded Poorly-graded Highest Water Level Recorded 2014-2017 (May 2015) Gravel Screened Interval TCE sample results are shown as follows: between January 2014 and October 2017. Gravel Gravel Sand Groundwater (light blue-grey) mg/L Low, Mid, and High designations are from historical Average Water Level Recorded 2014-2017 Soil (light brown) mg/kg Color-Tec results as follows: Average Water Level Recorded 2014-2017 3 USCS Soil gas (green) mg/m Low <10 ppb Excavated Approximate Excavation Boundaries Well-graded USCS Silty Sand Not detected values are reported as less than the reporting Mid <30 ppb Material No soil retrieved Lowest Water Level Recorded 2014-2017 (June 2017) Sand limit or as ND where reporting limit is not available. High >30 ppb LITHOLOGY_SAMPLERESULTS_11X17 - ANIAK_GINT_PROJTEMPLATE.GDT - 2/1/18 10:26 - P:\CLIENTS\ALASCOM_EXELIS_LOCKHEED\PNG0712_ANIAK WACS TCE RI FS\06_DATAMANAGEMENT_VISUALIZATION\GINT\ANIAK_GINT_RI_XSECT.GPJ TCE WACS - 2/1/18 10:26 - P:\CLIENTS\ALASCOM_EXELIS_LOCKHEED\PNG0712_ANIAK - ANIAK_GINT_PROJTEMPLATE.GDT LITHOLOGY_SAMPLERESULTS_11X17 CLIENT TCE RI/FS Coordinator 4101 Arctic Boulevard, #206 SUBSURFACE DIAGRAM PROJECT NUMBER PNG0712 Anchorage, AK 99503 Cross Section D-D' Telephone: 907-929-3326 PROJECT NAME TCE Remedial Investigation, Former Aniak WACS Site Figure 5D PROJECT LOCATION Aniak, Alaska NOTES All elevations are approximate. 0 50 100 150 200 250 300 350 400 450 500

110 110

105 105

16-SB51 SGP15 17-SB66 SGP35 SGP17 17-SB67 100 16-SB42 W2-E-V SGP1 100

0.034 W2-N-V < 0.065

0.022 95 95

0.063

96 0.0 SGP28 MW03/06-B5 SGP27 90 16-SB48 SGP25 90

ND

ND ND 0.290 85 ND 85 2.0 ND

0.390 0.905 < 2 0.170 < 0.006 80 0.000 80 Elevation (ft) 75 54 75 0.0 0.460

0.00036 < 0.033 70 70 0.021

< 0.0002

65 65 0.0002

60 60

55 55

50 50

45 Not for printing; use in zoomable PDF reader only for legibility. 45 0 50 100 150 200 250 300 350 400 450 500 Distance Along Baseline (ft) USCS USCS Silty Excavated Notes: Groundwater elevations taken from datalogger data USCS Silt USCS Silty Sand Well-graded Gravel Material Highest Water Level Recorded 2014-2017 (May 2015) TCE sample results are shown as follows: between January 2014 and October 2017. Sand Screened Interval Groundwater (light blue-grey) mg/L Low, Mid, and High designations are from historical Average Water Level Recorded 2014-2017 Soil (light brown) mg/kg Color-Tec results as follows: 3 USCS USCS Approximate Excavation Boundaries Soil gas (green) mg/m Low <10 ppb Not detected values are reported as less than the reporting Mid <30 ppb Well-graded Poorly-graded Lowest Water Level Recorded 2014-2017 (June 2017) Gravel Sand limit or as ND where reporting limit is not available. High >30 ppb LITHOLOGY_SAMPLERESULTS_11X17 - ANIAK_GINT_PROJTEMPLATE.GDT - 2/5/18 11:18 - P:\CLIENTS\ALASCOM_EXELIS_LOCKHEED\PNG0712_ANIAK WACS TCE RI FS\06_DATAMANAGEMENT_VISUALIZATION\GINT\ANIAK_GINT_RI_XSECT.GPJ TCE WACS - 2/5/18 11:18 - - ANIAK_GINT_PROJTEMPLATE.GDT P:\CLIENTS\ALASCOM_EXELIS_LOCKHEED\PNG0712_ANIAK LITHOLOGY_SAMPLERESULTS_11X17 CLIENT TCE RI/FS Coordinator SUBSURFACE DIAGRAM 4101 Arctic Boulevard, #206 PROJECT NUMBER PNG0712 Anchorage, AK 99503 Cross Section E-E' Telephone: 907-929-3326 PROJECT NAME TCE Remedial Investigation, Former Aniak WACS Site Figure 5E PROJECT LOCATION Aniak, Alaska NOTES All elevations are approximate. 0 50 100 150 200 250 300 350 400 450 500

110 110

JPVEC Building 105 105

FSCS107 17-SB59 08-B11 W1-V 16-SB37 MW17 100 06-TS8 100 MW08/09-B21MW07/09-B20 0.110 Low 0.013

Low 95 95

0.055 Low MW15/17-SB57 < 0.046 08-B14 Low 90 MW18 90 0.041 Low Low

< 0.055 Low Low < 0.092 85 85

Low Low 0.023

Low Low 80 < 0.047 80

0.043 Low Low 0.067

Low Low Elevation (ft) 75 75

< 0.04 0.005 0.094

Low 0.171 0.004 0.032

70 < 0.0002 70

0.004 < 0.0005 0.006 65 65 Low

0.011

60 60

Low

55 55

50 Not for printing; 50 < 0.0005 use in zoomable PDF reader only for legibility. 45 45 0 50 100 150 200 250 300 350 400 450 500 Distance Along Baseline (ft) USCS USCS USCS Notes: Groundwater elevations taken from datalogger data No soil retrieved USCS Silt Poorly-graded Well-graded Well-graded Highest Water Level Recorded 2014-2017 (May 2015) Screened Interval TCE sample results are shown as follows: between January 2014 and October 2017. Sand Sand Gravel Groundwater (light blue-grey) mg/L Low, Mid, and High designations are from historical Soil (light brown) mg/kg Color-Tec results as follows: Average Water Level Recorded 2014-2017 3 USCS Soil gas (green) mg/m Low <10 ppb USCS Silty Excavated USCS Peat USCS Silty Sand Poorly-graded Not detected values are reported as less than the reporting Mid <30 ppb Gravel Material Lowest Water Level Recorded 2014-2017 (June 2017) Gravel limit or as ND where reporting limit is not available. High >30 ppb LITHOLOGY_SAMPLERESULTS_11X17 - ANIAK_GINT_PROJTEMPLATE.GDT - 2/1/18 10:43 - P:\CLIENTS\ALASCOM_EXELIS_LOCKHEED\PNG0712_ANIAK WACS TCE RI FS\06_DATAMANAGEMENT_VISUALIZATION\GINT\ANIAK_GINT_RI_XSECT.GPJ TCE WACS - 2/1/18 10:43 - P:\CLIENTS\ALASCOM_EXELIS_LOCKHEED\PNG0712_ANIAK - ANIAK_GINT_PROJTEMPLATE.GDT LITHOLOGY_SAMPLERESULTS_11X17 ³ (! 0.050 (! (! (! (!

0.030

0.150 *# 0.020 (! (!(! ((((!!!! 0.011 (! (((!!! (! 0.020 (! *### *#***###*# 0.011 ** 0.030*# *# *# *#*#*# *#*#(!*#*# *#***### *#*#*# ((((((!!!!!! (! *# 0.150 0.020 *# (((!!!(! (! *# *#(((((!!!!! *# *# *# *# 0.500 (! *#*#***###*# 0.050 *#(!*# (! 0.030

*#*#0.011 0.011 ((!!

0.030 (((!!! 0.020 (!

Legend RI Soil Samples Other Soil Samples (! Not Detected *# Not Detected (! Detected *# Detected (! Exceeds 0.011 mg/kg *# Exceeds 0.011 mg/kg 75 37.5 0 75 Feet Approximate Edge of Gravel Fill Layer TCE Concentration Contours TCE Concentration Contours in the Gravel Fill Layer Former WACS Site and JPVEC (in mg/kg) Aniak, Alaska Notes Soil RI decision level of 0.011 mg/kg is based on ADEC Method 2. Data presented are from multiple years of investigation and excavation Figure and include results from the 2016-2017 RI and other investigations (2006, 2008, 2009, and 2011) as applicable to the media presented. Data from locations that were later excavated are excluded. 6 Aerial imagery (June 2007) received from Quantum Spatial. Anchorage, Alaska March 2019 Anchorage-01\Data P:\Clients\Alascom_Exelis_Lockheed\PNG0712_ANIAK WACSTCE RI FS\06_DataManagement_Visualization\GIS\Projects\06_2018_FSReport\Revisions090718\Fig06_Soil_TCE_Litho_Gravel_Contours.mxd STM20190228 ³

(! (! (! *#(! 0 .02 *# (! 0 (! 0 05 0 0 0. .0 03 2 (! . 0 0 (! (! 0.050 *# (!*# (! (! *# *#(! (! 0.200 0.030 (! (! *# *# *# *#*# *# 0 *#*#(!*# *# .2 # (! 0 0 8 *(! . 0 2 *#0*# 5 (! 2 . *#*# (! 0 *#02 *# # 0 9 0 *#*#* 0 1 *# *# 0 (! 2 *# *# *# (! M # *# (! T * #*##

S **

*# d *# x *# m . s *# r *# u *## o * t

n (!*# (! o

C *# _ t l *# i *# *#

S (! _ *# (! o h *# t *# i L _ E C T

_ *# l i (! o (! S _ 7 0 g i F \

8 (! 1 7 0 9

0 (! s n o i (! s i v e R \ t r o p e R S F _ 8 1 0 2 _ 6 0 \ s t c e j o r P \ S I G \ n o i t a z i l a u s i V _ t n e m e g a n a M a t a D _ 6 0 \ S F

I R

E C T

S Legend C A W

K RI Soil Samples Other Soil Samples A I N A _ 2

1 Not Detected Not Detected 7 (! *# 75 37.5 0 75 Feet 0 G N P \ Detected *# Detected d (! e e h k c Exceeds 0.029 mg/kg Exceeds 0.029 mg/kg o (! *# L

_ TCE Concentration Contours in the Fine Silt Layer s i l e

x TCE Concentration Contours

E Former WACS Site and JPVEC _ m

o (in mg/kg) c Aniak, Alaska s a l

A Notes \ s t n e Soil RI decision level of 0.029 mg/kg is based on ADEC Method 3 calculation. i l C \ : Data presented are from multiple years of investigation and excavation P

Figure a t a and include results from the 2016-2017 RI and other investigations (2006, 2008, D \ 1 0

- 2009, and 2011) as applicable to the media presented. Data from locations that e g a r were later excavated are excluded. o 7 h c Anchorage, Alaska March 2019 n Aerial imagery (June 2007) received from Quantum Spatial. A ! Eq uipm e nt A Build ing 1 A! . 5 2 A! .8 A!A! 1.5 A! %! A! 2.8 ! 5 A MW11 ³ 5 5 A A! 10 ! MW04 5 ! . 8 A 1 . A! ! MW18 2 5 ! A A! ! A A! MW15 A! AA! ! ! MW08 AA! A ! A! MW07 A ! ! A!A! A *# A A! A! MW17 ! !A! A! A A! AA! MW14 A! JPVEC ! MW13 ! ! ! A MW09 AA! A A Build ing *# A! A! 100 A! 28 A! ! A! ! A 10 A MW06 A MW16 ! MW10 A! A! A!

High Sc hool 1 2 3 0 9 1 0 2

M T S d x m . s r u o t n o c _ E C T _ r e t a w d n

u MW12 o r G

_ A! 8 0 g i F \ 8 1 7 0 9 0 s n o i s i v e R \ t r o p e R S F _ 8 1 0 2 _ 6 0 \ s t c e j % o ! r P \ S I Legend G \ n o i t a z i % l ! Drinking Wate r We ll Monitoring Well a u s i

V (decommissioned) _ t Dom inant Ground wate r Flow n e m e Dire c tion g A! N ot De te c te d a n a M a TCE Conc e ntration Contours t A! Exc e e d s 2.8 µg/L a D _

6 (in µg/L) 0 \ 2008 Temporary Well Point S F

I

R Monitoring Well

E ! C N ot De te c te d

T A

S A!

C N ot De te c te d A ! De te c te d W

A K

A A! De te c te d I

N ! Exc e e d s 2.8 µg/L A A _ 2

1 A! Exc e e d s 2.8 µg/L

7 100 50 0 100 Fe e t 0 Historical Soil Gas Point G N P

\ Temporary Well Point d e e *# N ot De te c te d h k c ! o N ot De te c te d

L A _ # De te c te d TCE Concentration Contours in Groundwater s * i l e x ! De te c te d Form e r WACS Site and JPVEC E A _ m o Aniak, Alaska c s ! Exc e e d s 2.8 µg/L a l A A

\ s t

n Notes e i l C \

: RI d e c ision lim it is 2.8 μg/L (ADEC Table C Ground wate r Cle anup Le ve l). P

Figure a t

a Data pre se nte d are from m ultiple ye ars of inve stigation and e xc avation D \ 1

0 and inc lud e re sults from 2008, 2011, 2016, or 2017 as applic able to the - e g a r m e d ia pre se nte d . o 8 h c Anc horage , Alaska Marc h 2019 n Ae rial im age ry (June 2007) re c e ive d from Quantum Spatial. A ³ Equipment

Building

5

0

. 0

0.05 1 0.1

1 1 .1 01 0 0. JPVEC Building 8 2 2 0 9 1 0 2

M T S d x m . s r

u 1

o 1 t . n 0 o C _ E

C .05 T 0 _ l i o S _ 9 0 g i F \ 1

8 1 1 .0 7 0 0 9 0 s n o i s i v e R \ t r o p e R S F

_ High 8 1 0

2 School _ 6 0 \ s t c e j o r P \ S I G \ n o i t a z i l a u s i V _ t n e m e g a n a M a t a D _ 6 0 \ S F

I R

E C T

S C A W

K A I N A _ 2 1

7 75 37.5 0 75 Feet

0 Legend G N P \ d e TCE Soil Contours (mg/kg) e h k c o L

_ Approximate Edge of Gravel s Extent of TCE in Soil i l e x Former WACS Site and JPVEC

E Fill Layer _ m

o Aniak, Alaska c s a

l Notes A

\ s t

n Soil RI decision level of 0.011 mg/kg is based on ADEC Method 2. e i l C \

: Contours are created from multiple years of investigation and include P

Figure a t

a results from 2006, 2008, 2009, 2011, 2016, or 2017 as applicable to the D \ 1

0 media presented. Data from locations that were later excavated are - e g a r excluded. o 9 h c Anchorage, Alaska March 2019 n Aerial imagery (June 2007) received from Quantum Spatial. A ³

Equipment Building 8 2 2

0 JPVEC 9 1 0 2 Building* M T S d x m . C E - C I _ e n o Z _ t a s n U _ 0 1 g i F \ 8 1 7 0 9 0 s n o i s i v e R \ t r o p e R S F _ 8 1 0 2 _ 6 0 \ s t c e j o r P \ S I G \ n o i t a z i l

a High u s i V _ t School n e m e g a n a M a t a D _ 6 0 \ S F

I R

E C T

S C A W

K 75 37.5 0 75 Feet

A Legend I N A _ 2

1 TCE Concentration in Soil 7 0 G

N (>0.011 mg/kg) P \ d e e h Proposed Land Use Unsaturated Zone - k c o L

_ Restriction Area Institutional and Engineering Controls s i l e x Former WACS Site and JPVEC E _ m o Aniak, Alaska c s a l

A Notes \ s t n e Aerial imagery (June 2007) received from Quantum Spatial. i l C \ : Contours are created from multiple years of investigation and include P

Figure a t a results from 2006, 2008, 2009, 2011, 2016, or 2017 as applicable to the D \ 1 0

- media presented. Data from locations that were later excavated are e g a r excluded. o 10 h c Anchorage, Alaska March 2019 n * JPVEC Building currently has a sub-slab depressurization system operating. A ³

Equipment Building

JPVEC Well %!

8 A . ! 2 MW11

5 (Sentry Well) 5 5

8 2. 5 JPVEC Building 8 2 2 0 9 1 0 2

M T S d x m . C E - C I _ e n o Z _ t a

S High _ 1 1 g i School F \ 8 1 7 0 9 0 s n o i s i v e R \ t r o p e R S F _ 8 1 0 2 _ 6 0 \ s t c e j o r P \ S I G \ n o i t a z i l a u s i V _ t n e m e g a n a M a t a D _ 6 0 \ S F

I R Legend E C T

S

C A

A ! Monitoring Well W

K 75 37.5 0 75 Feet A I

N Groundwater TCE Contours (µg/L) A _ 2 1

7 %

0 ! Drinking Water Well G N P \ d

e Dominant Groundwater Flow Direction e Saturated Zone - h k c o

L Groundwater Use Restriction Area

_ Institutional and Engineering Controls s i l e x Former WACS Site and JPVEC E

_ Building Construction Restrictions for Vapor Intrusion Risk m o Aniak, Alaska c s Mitigation a l A

\ s t

n Notes e i l C \

: Contours are created from multiple years of investigation and include P

Figure a t

a results from 2008, 2011, 2016, or 2017 as applicable to the media D \ 1

0 presented. Data from locations that were later excavated are - e g a r excluded. o 11 h c Anchorage, Alaska March 2019 n Aerial imagery (June 2007) received from Quantum Spatial. A ³

Equipment Building

JPVEC 8 2

2 ! 0 A 9 Building* 1 0 2

M T S

d ! x A m ! .

E A V S _ e n o Z _ t a s ! n A U _ 2 1 g i ! F \ A 8 1 7 0 9 0 s n o i s i v e R \ t r o p e R S F _ 8 1 0 2 _ 6 0 \ s t c e j o r P \ S I G \ n o i t a z i l a u s i

V High _ t n e

m School e g a n a M a t a D _ 6 0 \ S F

I Legend R

E C

T ! A SVE Well S C A W TCE Concentration in Soil (>0.011 mg/kg) K 75 37.5 0 75 Feet A I N A

_ SVE Radius of Influence 2 1 7 0 G

N TCE Concentration in Gravel Fill (>0.110 mg/kg) P \ d e e h SVE Line Unsaturated Zone - Targeted SVE with k c o L

_ Institutional and Engineering Controls s i l Proposed Land Use Restriction Area e x

E Former WACS Site and JPVEC _ m SSD/SVE System Enclosure o c Aniak, Alaska s a l

A Notes \ s t n e Aerial imagery (June 2007) received from Quantum Spatial. i l C \ : Contours are created from multiple years of investigation and include P

Figure a t a results from 2006, 2008, 2009, 2011, 2016, or 2017 as applicable to the D \ 1 0

- media presented. Data from locations that were later excavated are e g a r excluded. o 12 h c Anchorage, Alaska March 2019 n * JPVEC Building currently has a sub-slab depressurization system operating. A ³

Equipment Building

JPVEC Well %!

8 A . ! 2 MW04 MW11 A! (Sentry Well) MW18 5 5 A! A! 5 MW08 MW15 A!A! MW07 A! 8 2. MW14 A! 5 MW17 A! JPVEC A! MW13 Building MW09

A! A! MW06 A! 8

2 MW10 2 0

9 MW16 1 0 2

M T S d x m . M G T L _ e n o Z _ t a

S High _ 3 1 g i School F \ 8 1 7 0 9 0 s n o i s i v e R \ t r o p e R S F _ 8 1 0 2 _ 6 0 \ s t c e j A! MW12 o r P \ S I G \ n o i t a z i l a u s i V _ t n e m e g a n a M a t a D _ 6 0 \

S Legend F

I R

E C

T Groundwater TCE Contours (µg/L)

S C A

W A ! Monitoring Well

K 100 50 0 100 Feet A I N

A %! _ Drinking Water Well 2 1 7 0

G Dominant Groundwater Flow Direction N P \ d e e Saturated Zone - LTGM with h Groundwater Use Restriction k c o L

_ Institutional and Engineering Controls s i Building Construction Restrictions for Vapor Intrusion Risk l e x Former WACS Site and JPVEC E

_ Mitigation m o Aniak, Alaska c s a

l Notes A

\ s t

n LTGM= Long-term Groundwater Monitoring e i l C \

: Contours are created from multiple years of investigation and include P

Figure a t

a results from 2008, 2011, 2016, or 2017 as applicable to the media D \ 1

0 presented. Data from locations that were later excavated are - e g a r excluded. o 13 h c Anchorage, Alaska March 2019 n Aerial imagery (June 2007) received from Quantum Spatial. A ³

Equipment Building 8 2 2 0 9 1 0

2 JPVEC

M T S Building* d x m . n o i t a v a c x E _ e n o Z _ t a s n U _ 4 1 g i F \ 8 1 7 0 9 0 s n o i s i v e R \ t r o p e R S F _ 8 1 0 2 _ 6 0 \ s t c e j o r P \ S I G \ n o i t a z i l

a High u s i V _ t School n e m e g a n a M a t a D _ 6 0 \ S F

I R

E C T

S C A W

K 75 37.5 0 75 Feet A I

N Legend A _ 2 1 7

0 TCE Concentration in Soil (>0.011 mg/kg) G N P \ d e Proposed Excavation Boundary e

h Unsaturated Zone - Excavation with k c o

L Proposed Land Use Restriction Area _ Institutional and Engineering Controls s i l e x Former WACS Site and JPVEC E Notes _ m o Aniak, Alaska

c Aerial imagery (June 2007) received from Quantum Spatial. s a l

A Proposed Land Use Restriction Area will be in place until TCE-contaminated \ s t n e soil does not remain on site. i l C \ : Contours are created from multiple years of investigation and include P

Figure a t a results from 2006, 2008, 2009, 2011, 2016, or 2017 as applicable to the D \ 1 0

- media presented. Data from locations that were later excavated are e g a r excluded. o 14 h c Anchorage, Alaska March 2019 n * JPVEC Building currently has a sub-slab depressurization system operating. A

CHARTS

Final FS Report March 2019 Geosyntec Consultants

Chart 1 Alternatives Cost Comparison TCE Feasibility Study Former WACS Site/Joe Parent Vocational Education Center Aniak, Alaska

Alternative 1 $0

$3,130,000

Alternative 2 $2,191,000 $4,695,000

$2,530,000

Alternative 3 $1,771,000 $3,795,000

$3,470,000

Alternative 4 $2,429,000 $5,205,000

$2,870,000

Alternative 5 $2,009,000 $4,305,000

$13,170,000

Alternative 6 $9,219,000 $19,755,000

Page 1 of 1 March 2019

APPENDIX A Spring 2018 Groundwater Monitoring

Final FS Report March 2019 4101 Arctic Blvd, Suite 206 Anchorage, Alaska 99503 PH (907) 929-3326 www.geosyntec.com

Memorandum

Date: 10 December 2018 To: TCE RI/FS Coordinator From: Geosyntec Consultants, Anchorage Office Subject: March 2018 Groundwater Results Aniak WACS Site

Geosyntec visited the former Aniak White Alice Communications System (WACS) site on 29-30 March 2018 for groundwater monitoring. The purpose was to collect additional data to meet the project objectives of understanding the seasonal variation of the groundwater hydrology and groundwater concentrations of trichloroethene (TCE). The following tasks were completed.

• Water level measurements were collected at all wells and the datalogger data was downloaded. These data are stored for potential future use. • MW08 and MW10 were redeveloped prior to sampling due to apparent sediment accumulation. The redevelopment logs are present in Attachment 1. • Locks were added to the three above ground well completions (MW09, MW15, and MW18). • Groundwater was sampled at a period of low groundwater elevation.

Geosyntec performed the field activities in accordance with Alaska Department of Environmental Conservation (ADEC) guidance and Section 5 of the Trichloroethene Remedial Investigation and Feasibility Study Work Plan (Work Plan).

1 GROUNDWATER SAMPLING

Thirteen of the fourteen wells (MW06 through MW18) were sampled using an electric submersible pump. Low-flow methodologies were used and water quality parameters were collected through an in-line flow-through cell using dedicated polyethylene tubing for each well. Field notes, calibration logs, and water sampling logs are provided in Attachment 1.

All wells were accessible, in good condition, and no damage was observed. MW04 had less than five inches of water in the well and could not be sampled. Groundwater levels for the other thirteen

Aniak_March2018_GW_TechMemo_120718

March 2018 Groundwater Results, Aniak WACS 10 December 2018 Page 2

wells were within the screened intervals of each well, and the samples were collected from the bottom one to two feet of the water column.

Field parameters, including dissolved oxygen (DO), specific conductance, temperature, pH, and oxidation-reduction potential (ORP) were monitored during purging and sampling activities with a YSI water quality multi-meter. Turbidity was measured during purging and sampling activities using a Hach 2100P Turbidimeter. DO was also monitored using a YSI optical meter deployed down the well. The parameters reached stable conditions prior to samples being collected in accordance with Section 5.3.2.3 of the Work Plan. The pH probe did not calibrate to standards on 29 March, and the ORP probe did not calibrate to standard on 29 and 30 March. Table 1 presents final readings for water quality parameters.

Groundwater analytical samples were collected into pre-preserved vials for shipment to SGS Laboratory in Anchorage, Alaska, for analysis of tetrachloroethene (PCE), trichloroethene (TCE), cis-1,2-dichloroethene (cDCE), trans-1,2-dichloroethene (tDCE), and vinyl chloride (VC). Two duplicate samples were collected at MW07 and MW18, which were submitted blind to the laboratory. Immediately after collection, sample vials were placed into a cooler with ice and chilled until delivery to the analytical laboratory.

Table 2 presents the analytical results as well as historical results for each monitoring well. Attachment 2 contains the laboratory report. Geosyntec conducted a data quality review using standard ADEC guidelines. No data quality issues were noted. The data quality review report and ADEC checklist are contained in Attachment 2.

TCE was detected in MW07, MW13, MW14, MW15, and MW18, which is consistent with historical sampling results. cDCE was detected in MW09, MW13, and MW15, which is consistent with the historical sampling results. Other detections include PCE (in MW10) and tDCE (in MW13). The detection of PCE in MW10 is the first time PCE has been detected in groundwater at the site, although the concentration (1.86 micrograms per liter [µg/L]) is well below the default groundwater cleanup level of 41 µg/L (18 Alaska Administrative Code 75.345 – revised on 7 November 2017). In addition, MW10 has never had a detection of TCE or its daughter compounds in eight sampling events, so the presence of PCE appears unrelated to the former Aniak WACS site.

The concentrations of TCE in MW07 (27.7 µg/L), MW13 (124 µg/L), MW14 (112 µg/L), MW15 (4.88 µg/L) and MW18 (7.69 µg/L) exceed the default groundwater cleanup level of 2.8 µg/L.

2 COMPARISON TO HISTORICAL DATA

TCE has not been detected in MW06, MW08, MW10, MW11, MW12, MW16, and MW17.

Aniak_March2018_GW_TechMemo_120718

March 2018 Groundwater Results, Aniak WACS 10 December 2018 Page 3

At MW09, TCE concentrations decreased from 0.76 µg/L (in October 2017) to below the detection limit (0.5 µg/L). With the exception of the October 2017 detection, TCE has not been detected at MW09 in the other seven sampling events since the well was installed in 2009.

The TCE concentrations in MW07, MW13, and MW14 increased by an approximate factor of two from concentrations measured in the October 2017 sampling event. MW07 increased from 11 µg/L to 27.7 µg/L, although 27.7 µg/L is within the range of concentrations previously measured in MW07 and less than the maximum of 47.5 µg/L. MW13 and MW14 have been sampled twice, and there is insufficient information to determine if the change is due to seasonal variation or an increasing trend. TCE concentrations in MW15 and MW18 are comparable between the October 2017 and March 2018 sampling events.

Figure 1 presents a plan view of TCE results for the past three years for fifteen monitoring wells, including MW05 which was decommissioned in 2017 and replaced with MW14.

*****

Attachments:

Table 1 – Water Quality Parameters Table 2 – Groundwater Analytical Results Figure 1 – TCE Concentrations in Groundwater Attachment 1 – Field Notes, Groundwater Sampling Logs Attachment 2 – Laboratory Analytical Report Attachment 3 – Data Validation Report

Aniak_March2018_GW_TechMemo_120718

March 2018 Groundwater Results, Aniak WACS 10 December 2018 Page 4

TABLES

Aniak_March2018_GW_TechMemo_120718

Table 1 Water Quality Parameters Former Aniak WACS Site March 2018 Groundwater Monitoring

Specific Date Turbidity Dissolved ORP2 Temperature Well pH1 Conductivity Sampled (NTU) Oxygen (mg/L) (mV) (°F) (mS/cm) MW06 3/29/18 8.63 0.57 3.03 0.294 892.9 39.6 MW07 3/30/18 381 0.77 5.62 0.309 343.6 43.0 MW08 3/30/18 15.7 4.12 5.88 0.233 395.3 39.9 MW09 3/29/18 26.4 1.37 2.74 0.355 934.9 39.1 MW10 3/30/18 >1,000 13.12 5.67 0.344 354.9 43.5 MW11 3/30/18 23.7 6.61 5.86 0.263 433.3 38.4 MW12 3/29/18 22.3 2.68 2.67 0.524 919.5 37.4 MW13 3/30/18 119 1.57 5.48 0.351 480.1 40.2 MW14 3/30/18 82.6 3.63 5.60 0.270 489.0 40.5 MW15 3/29/18 21.3 1.25 1.93 0.673 975.4 39.3 MW16 3/29/18 20.0 0.16 2.31 0.462 957.9 38.8 MW17 3/30/18 42.1 13.71 5.75 0.234 459.1 40.1 MW18 3/29/18 3.76 1.99 4.40 0.411 961.9 39.1

Notes: 1 pH probe did not calibrate to standards on 3/29/18. 2 ORP probe did not calibrate to standard on 3/29/18 and 3/30/18. °F - degrees Fahrenheit mg/L - miligrams per liter mS/cm - milliSiemens per centimeter mV - milliVolts NTU - Nephelometric Turbidity Units ORP - oxidation reduction potential

Page 1 of 1 Table 2 Groundwater Analytical Results Former Aniak WACS Site March 2018 Groundwater Monitoring

Trichloroethene cis-1,2- trans-1,2- Vinyl Tetrachloroethene Location Date (TCE) Dichloroethene Dichloroethene Chloride (PCE) µg/L µg/L µg/L µg/L µg/L

ADEC Method 2 Groundwater Cleanup 2.8 36 360 0.19 41 Level, 18 AAC 75 (November 7, 2017)

6/4/2008 19.3 ND (1) ND (1) ND (1) ND (1) 6/4/2008 19.6 ND (1) ND (1) ND (1) ND (1) 9/10/2016 12.7 ND (0.5) ND (0.5) ND (0.5) ND (0.5) MW04 10/9/2016 12 ND (0.2) ND (0.2) ND (0.2) ND (0.2) 4/27/2017 9.48 ND (0.5) ND (0.5) ND (0.075) ND (0.5) 10/11/2017 12 0.1 J ND (0.5) ND (0.5) ND (0.5) 6/4/2008 157 ND (1) ND (1) ND (1) ND (1) 5/11/2011 77 ND (0.4) ND (0.4) ND (0.4) ND (0.4) 5/11/2011 77 ND (0.4) ND (0.4) ND (0.4) ND (0.4) MW05 9/10/2016 1 3.24 ND (0.5) ND (0.5) ND (0.5) ND (0.5) 10/8/2016 5.7 ND (0.2) ND (0.2) ND (0.2) ND (0.2) 4/27/2017 4.89 ND (0.5) ND (0.5) ND (0.075) ND (0.5) Decommissioned in October 2017. Replaced by MW14. 6/4/2008 ND (1) ND (1) ND (1) ND (1) ND (1) 8/27/2009 ND (1) ND (1) ND (1) ND (1) ND (1) 5/10/2011 ND (0.2) ND (0.2) ND (0.2) ND (0.2) ND (0.2) 10/19/2011 ND (0.2) ND (0.2) ND (0.2) ND (0.2) ND (0.2) MW06 9/9/2016 ND (0.5) ND (0.5) ND (0.5) ND (0.5) ND (0.5) 10/7/2016 ND (0.2) ND (0.2) ND (0.2) ND (0.2) ND (0.2) 4/27/2017 ND (0.5) ND (0.5) ND (0.5) ND (0.075) ND (0.5) 10/12/2017 ND (0.5) ND (0.5) ND (0.5) ND (0.5) ND (0.5) 3/29/2018 ND (0.5) ND (0.5) ND (0.5) ND (0.075) ND (0.5) 8/26/2009 44.6 2.42 ND (1) ND (1) ND (1) 8/30/2009 47.5 2.73 ND (1) ND (1) ND (1) 8/30/2009 46.6 2.81 ND (1) ND (1) ND (1) 5/10/2011 ND (0.2) ND (0.2) ND (0.2) ND (0.2) ND (0.2) 10/19/2011 42 3.1 0.3 ND (0.2) ND (0.2) 9/10/2016 17.1 ND (0.5) ND (0.5) ND (0.5) ND (0.5) 9/10/2016 17.4 ND (0.5) ND (0.5) ND (0.5) ND (0.5) MW07 10/8/2016 12 ND (0.2) ND (0.2) ND (0.2) ND (0.2) 10/8/2016 12 ND (0.2) ND (0.2) ND (0.2) ND (0.2) 4/27/2017 0.77 J ND (0.5) ND (0.5) ND (0.075) ND (0.5) 4/27/2017 0.79 J ND (0.5) ND (0.5) ND (0.075) ND (0.5) 10/11/2017 11 ND (0.5) ND (0.5) ND (0.5) ND (0.5) 3/30/2018 27 ND (0.5) ND (0.5) ND (0.075) ND (0.5) 3/30/2018 27.7 ND (0.5) ND (0.5) ND (0.075) ND (0.5) 8/26/2009 ND (1) ND (1) ND (1) ND (1) ND (1) 8/30/2009 ND (1) ND (1) ND (1) ND (1) ND (1) 5/10/2011 ND (0.2) ND (0.2) ND (0.2) ND (0.2) ND (0.2) MW08 10/18/2011 ND (0.2) ND (0.2) ND (0.2) ND (0.2) ND (0.2) 9/10/2016 ND (0.5) ND (0.5) ND (0.5) ND (0.5) ND (0.5) 10/8/2016 ND (0.2) ND (0.2) ND (0.2) ND (0.2) ND (0.2)

Page 1 of 3 Table 2 Groundwater Analytical Results Former Aniak WACS Site March 2018 Groundwater Monitoring

Trichloroethene cis-1,2- trans-1,2- Vinyl Tetrachloroethene Location Date (TCE) Dichloroethene Dichloroethene Chloride (PCE) µg/L µg/L µg/L µg/L µg/L

ADEC Method 2 Groundwater Cleanup 2.8 36 360 0.19 41 Level, 18 AAC 75 (November 7, 2017)

4/27/2017 ND (0.5) ND (0.5) ND (0.5) ND (0.075) ND (0.5) MW08 (cont) 10/11/2017 ND (0.5) ND (0.5) ND (0.5) ND (0.5) ND (0.5) 3/30/2018 ND (0.5) ND (0.5) ND (0.5) ND (0.075) ND (0.5) 9/1/2009 ND (1) ND (1) ND (1) ND (1) ND (1) 5/10/2011 ND (0.2) ND (0.2) ND (0.2) ND (0.2) ND (0.2) 10/18/2011 ND (0.2) 0.26 ND (0.2) ND (0.2) ND (0.2) 9/10/2016 ND (0.5) 0.54 J ND (0.5) ND (0.5) ND (0.5) MW09 10/8/2016 ND (0.2) 0.34 ND (0.2) ND (0.2) ND (0.2) 4/26/2017 ND (0.5) 0.46 J ND (0.5) ND (0.075) ND (0.5) 10/12/2017 0.76 2 ND (0.5) ND (0.5) ND (0.5) 3/29/2018 ND (0.5) 0.35 J ND (0.5) ND (0.075) ND (0.5) 9/1/2009 ND (1) ND (1) ND (1) ND (1) ND (1) 5/10/2011 ND (0.2) ND (0.2) ND (0.2) ND (0.2) ND (0.2) 10/19/2011 ND (0.2) ND (0.2) ND (0.2) ND (0.2) ND (0.2) 9/9/2016 ND (0.5) ND (0.5) ND (0.5) ND (0.5) ND (0.5) MW10 10/7/2016 ND (0.2) ND (0.2) ND (0.2) ND (0.2) ND (0.2) 4/26/2017 ND (0.5) ND (0.5) ND (0.5) ND (0.075) ND (0.5) 10/9/2017 ND (0.5) ND (0.5) ND (0.5) ND (0.5) ND (0.5) 3/30/2018 ND (0.5) ND (0.5) ND (0.5) ND (0.075) 1.86 9/1/2009 ND (1) ND (1) ND (1) ND (1) ND (1) 5/11/2011 ND (0.2) ND (0.2) ND (0.2) ND (0.2) ND (0.2) 10/19/2011 ND (0.2) ND (0.2) ND (0.2) ND (0.2) ND (0.2) 9/9/2016 ND (0.5) ND (0.5) ND (0.5) ND (0.5) ND (0.5) MW11 10/7/2016 ND (0.2) ND (0.2) ND (0.2) ND (0.2) ND (0.2) 4/27/2017 ND (0.5) ND (0.5) ND (0.5) ND (0.075) ND (0.5) 10/9/2017 ND (0.5) ND (0.5) ND (0.5) ND (0.5) ND (0.5) 3/30/2018 ND (0.5) ND (0.5) ND (0.5) ND (0.075) ND (0.5) 9/1/2009 ND (1) ND (1) ND (1) ND (1) ND (1) 5/10/2011 ND (0.2) ND (0.2) ND (0.2) ND (0.2) ND (0.2) 5/12/2011 ND (0.2) ND (0.2) 0.22 ND (0.2) ND (0.2) 10/19/2011 ND (0.2) ND (0.2) ND (0.2) ND (0.2) ND (0.2) MW12 9/9/2016 ND (0.5) ND (0.5) ND (0.5) ND (0.5) ND (0.5) 10/8/2016 ND (0.2) ND (0.2) ND (0.2) ND (0.2) ND (0.2) 4/26/2017 ND (0.5) ND (0.5) ND (0.5) ND (0.075) ND (0.5) 10/9/2017 ND (0.5) ND (0.5) ND (0.5) ND (0.5) ND (0.5) 3/29/2018 ND (0.5) ND (0.5) ND (0.5) ND (0.075) ND (0.5) 10/11/2017 55 9.8 0.08 J ND (0.5) ND (0.5) MW13 3/30/2018 124 34.5 0.46 J ND (0.075) ND (0.5) 10/11/2017 65 0.1 J ND (0.5) ND (0.5) ND (0.5) MW14 3/30/2018 112 ND (0.5) ND (0.5) ND (0.075) ND (0.5) 10/12/2017 4.4 3.1 0.14 J ND (0.5) ND (0.5) MW15 3/29/2018 4.88 2.43 ND (0.5) ND (0.075) ND (0.5)

Page 2 of 3 Table 2 Groundwater Analytical Results Former Aniak WACS Site March 2018 Groundwater Monitoring

Trichloroethene cis-1,2- trans-1,2- Vinyl Tetrachloroethene Location Date (TCE) Dichloroethene Dichloroethene Chloride (PCE) µg/L µg/L µg/L µg/L µg/L

ADEC Method 2 Groundwater Cleanup 2.8 36 360 0.19 41 Level, 18 AAC 75 (November 7, 2017)

10/13/2017 ND (0.5) ND (0.5) ND (0.5) ND (0.5) ND (0.5) MW16 3/29/2018 ND (0.5) ND (0.5) ND (0.5) ND (0.075) ND (0.5) 10/13/2017 ND (0.5) ND (0.5) ND (0.5) ND (0.5) ND (0.5) MW17 3/30/2018 ND (0.5) ND (0.5) ND (0.5) ND (0.075) ND (0.5) 10/14/2017 6.4 0.62 ND (0.5) ND (0.5) ND (0.5) MW18 3/29/2018 7.69 ND (0.5) ND (0.5) ND (0.075) ND (0.5) 3/29/2018 7.64 ND (0.5) ND (0.5) ND (0.075) ND (0.5) Key: Result exceeds decision level Reporting limit or detection limit exceeds decision level Detections * Refer to Table 1-1 of the Aniak TCE RI Report µg/L - microgram(s) per liter ADEC - Alaska Department of Environmental Conservation ft bgs - feet below ground surface Method 2 Groundwater Cleanup Level - Defined in Table C of Chapter 18, Alaska Administrative Code, Title 75, dated November 7, 2017 ND - not detected (reporting limit shown in parentheses)

Page 3 of 3 March 2018 Groundwater Results, Aniak WACS 10 December 2018 Page 5

FIGURES

Aniak_March2018_GW_TechMemo_120718

0: 6HSW1'  0: 2FW1'  6HSW $SU1'  2FW 2FW1'  0: $SU 0DU1'  6HSW1'  2FW 0: 2FW1'  0DU'U\ 2FW $SU1'  0DU 2FW1'  0DU1'  0: 0: 2FW1'  0DU1'  0: 6HSW 2FW 2FW 0: $SU- 0DU 2FW 2FW 0DU 0DU

0: 0: 0: 6HSW1'  6HSW 2FW 2FW1'  0: 2FW 0DU $SU1'  6HSW1'  $SU 2FW1'  2FW1'  $SU1'  0DU1'  2FW 0DU1'  0: 0: 6HSW1'  2FW1'  2FW1'  0DU1'  $SU1'  2FW1'  0DU1' 

0: 6HSW1'  2FW1'  $SU1'  2FW1'  0DU1' 

Legend     )HHW 0RQLWRULQJ:HOO 0RQLWRULQJ:HOO GHFRPPLVVLRQHG TCE in Monitoring Wells, 2016-2018 'ULQNLQJ:DWHU:HOO )RUPHU:$&66LWHDQG-39(& $QLDN$ODVND *UH\±QRWGHWHFWHG %OXH±GHWHFWHGEHORZ5,GHFLVLRQOHYHO XJ/ 3XUSOH±GHWHFWHGDERYH5,GHFLVLRQOHYHO XJ/ )LJXUH

Notes 1 $HULDOLPDJHU\IURP-XQHUHFHLYHGIURP4XDQWXP6SDWLDO $QFKRUDJH$ODVND -XQH $QFKRUDJH?'DWD3?&OLHQWV?$ODVFRPB([HOLVB/RFNKHHG?31*B$1,$.:$&67&(5,)6?B'DWD0DQDJHPHQWB9LVXDOL]DWLRQ?*,6?3URMHFWV?BB)65HSRUW?$SS;B)LJB:HOOVB5,B7&(P[G March 2018 Groundwater Results, Aniak WACS 10 December 2018 Page 6

ATTACHMENT 1

FIELD NOTES, GROUNDWATER SAMPLING LOGS

Aniak_March2018_GW_TechMemo_120718

Groundwater Purging and Sampling Log

Project Number: PNG0712 Project Name: Aniak RI Date: 03/30/2018

Site Location: Aniak, AK Well ID: MW-4 Screen Interval (ft BGS): 21 Depth to Water (ft BTOC): 30.43 Well Diameter (inch): 2 Total Well Depth (ft BTOC): 30.8 Well Construction Material: SCH 40 PVC Weather: cold, clear, sunny Casing Volume (gal): 0.064 Samplers: OMS, KGT 3 Casings Volume (gal): 0.193 Low-flow Sampling Equipment: Dedicated Tubing Purging Method: Water Quality Meter: YSI Pro Plus, YSI Pro ODO, Purging Equipment: Proactive Hurricane Electric Submersible Pump Hach 2100P Pump Placement (ft BTOC): 30.7 Water Dissolved Specific Total Turbidity pH ORP Temperature Rate Time Level Oxygen Conductivity Volume (ft BTOC) (NTU) (mg/L) (units) (mS/cm) (mV) (°F) (mL/min) (gal) 15:51 water column too short, unable to pump water

Notes: Issues with ORP calibration.

Total Volume Purged (gal): DTW After Purge (ft BTOC):

Original: Signature:

Duplicate:

Equipment Blank:

Field Blank: Groundwater Purging and Sampling Log

Project Number: PNG0712 Project Name: Aniak RI Date: 03/29/2018

Site Location: Aniak, AK Well ID: MW-6 Screen Interval (ft BGS): 19 Depth to Water (ft BTOC): 28.05 Well Diameter (inch): 2 Total Well Depth (ft BTOC): 30.1 Well Construction Material: SCH 40 PVC Weather: cold, overcast, light wind Casing Volume (gal): 0.357 Samplers: OMS 3 Casings Volume (gal): 1.07 Sampling Equipment: Dedicated Tubing Purging Method: Low-flow Water Quality Meter: YSI Pro Plus, YSI Pro ODO, Purging Equipment: Proactive Hurricane Electric Submersible Pump Hach 2100P Pump Placement (ft BTOC): 29 Water Dissolved Specific Total Turbidity pH ORP Temperature Rate Time Level Oxygen Conductivity Volume (ft BTOC) (NTU) (mg/L) (units) (mS/cm) (mV) (°F) (mL/min) (gal) 15:19 28.15 570 0.88 5.5 0.307 750.3 38.5 400 0.2 15:22 28.15 388 0.6 5.16 0.3 783 38.8 170 0.3 15:25 28.15 219 0.49 4.61 0.296 819.5 39.0 128 0.4 15:28 28.14 125 0.48 4.06 0.295 850.4 39.2 135 0.45 15:31 28.12 80.4 0.56 3.71 0.295 868.2 39.3 140 0.5 15:34 28.13 53.0 0.56 3.48 0.294 879.5 39.5 165 0.6 15:38 28.14 24.5 0.59 3.22 0.294 889 39.5 120 0.65 15:42 28.14 13.6 0.61 3.11 0.294 892.4 39.5 150 0.7 15:46 28.13 8.63 0.57 3.03 0.294 892.9 39.6 140 0.9

Notes: Issues with pH and ORP calibration.

Total Volume Purged (gal): 1.2 DTW After Purge (ft BTOC): 28.13

Original: 18-AWS-MW6-GW - 15:49 - cVOC Signature:

Duplicate:

Equipment Blank:

Field Blank: Groundwater Purging and Sampling Log

Project Number: PNG0712 Project Name: Aniak RI Date: 03/30/2018

Site Location: Aniak, AK Well ID: MW-7 Screen Interval (ft BGS): 22.6 Depth to Water (ft BTOC): 29.73 Well Diameter (inch): 4 Total Well Depth (ft BTOC): 38.1 Well Construction Material: SCH 40 PVC Weather: cold, clear, sunny Casing Volume (gal): 5.533 Samplers: OMS, KGT 3 Casings Volume (gal): 16.598 Low-flow Sampling Equipment: Dedicated Tubing Purging Method: Water Quality Meter: YSI Pro Plus, YSI Pro ODO, Purging Equipment: Proactive Hurricane Electric Submersible Pump Hach 2100P Pump Placement (ft BTOC:) 37 Water Dissolved Specific Total Turbidity pH ORP Temperature Rate Time Level Oxygen Conductivity Volume (ft BTOC) (NTU) (mg/L) (units) (mS/cm) (mV) (°F) (mL/min) (gal) 09:35 29.74 89.3 0.98 4.16 0.314 439 40.9 215 0.05 09:39 29.74 142 0.88 5.21 0.311 386.2 41.9 280 0.1 09:43 29.74 246 0.80 5.42 0.309 378.9 42.4 370 0.15 09:47 29.74 311 0.77 5.46 0.308 371.2 43.0 360 0.2 09:51 29.74 318 0.76 4.9 0.309 362.9 43.2 220 1.2 09:55 29.74 389 0.79 5.62 0.308 355.3 43.0 160 1.5 09:58 29.74 361 0.77 5.65 0.308 349.7 43.1 210 1.7 10:01 29.74 381 0.77 5.62 0.309 343.6 43.0 100 1.8

Notes: Issues with ORP calibration. Discarded pump tubing after use; well no longer has dedicated electric pump tubing.

Total Volume Purged (gal): 2 DTW After Purge (ft BTOC): 29.74

Original: 18-AWS-MW7-GW - 10:05 - cVOC Signature:

Duplicate: 18-AWS-MW1-GW - 10:35 - cVOC

Equipment Blank:

Field Blank: Groundwater Purging and Sampling Log

Project Number: PNG0712 Project Name: Aniak RI Date: 03/30/2018

Site Location: Aniak, AK Well ID: MW-8 Screen Interval (ft BGS): 47 Depth to Water (ft BTOC): 29.75 Well Diameter (inch): 2 Total Well Depth (ft BTOC): 51.7 Well Construction Material: SCH 40 PVC Weather: cold, clear, sunny Casing Volume (gal): 3.819 Samplers: OMS, KGT 3 Casings Volume (gal): 11.458 Low-flow Sampling Equipment: Dedicated Tubing Purging Method: Water Quality Meter: YSI Pro Plus, YSI Pro ODO, Purging Equipment: Proactive Hurricane Electric Submersible Pump Hach 2100P Pump Placement (ft BTOC): 51 Water Dissolved Specific Total Turbidity pH ORP Temperature Rate Time Level Oxygen Conductivity Volume (ft BTOC) (NTU) (mg/L) (units) (mS/cm) (mV) (°F) (mL/min) (gal) 10:42 29.75 62.4 4.96 5.83 0.233 438.8 39.2 180 0.3 10:45 29.75 53.7 4.70 5.88 0.232 426.6 39.4 100 0.35 10:48 29.75 44.2 4.49 5.92 0.232 413.3 39.5 180 0.7 10:51 29.75 56.0 4.33 5.94 0.232 401.4 39.7 240 0.8 10:54 29.75 19.7 4.21 5.94 0.232 396.9 39.8 280 1 10:58 29.75 15.7 4.12 5.88 0.233 395.3 39.9 160 1.2

Notes: Issues with ORP calibration.

Total Volume Purged (gal): 1.5 DTW After Purge (ft BTOC): 29.75

Original: 18-AWS-MW8-GW - 11:00 - cVOC Signature:

Duplicate:

Equipment Blank:

Field Blank: Groundwater Purging and Sampling Log

Project Number: PNG0712 Project Name: Aniak RI Date: 03/29/2018

Site Location: Aniak, AK Well ID: MW-9 Screen Interval (ft BGS): 13.4 Depth to Water (ft BTOC): 22.96 Well Diameter (inch): 2 Total Well Depth (ft BTOC): 31.1 Well Construction Material: SCH 40 PVC Weather: cold, overcast, light wind Casing Volume (gal): 1.416 Samplers: OMS & KGT 3 Casings Volume (gal): 4.249 Sampling Equipment: Dedicated Tubing Purging Method: Low-flow Water Quality Meter: YSI Pro Plus, YSI Pro ODO, Purging Equipment: Proactive Hurricane Electric Submersible Pump Hach 2100P Pump Placement (ft BTOC): 30 Water Dissolved Specific Total Turbidity pH ORP Temperature Rate Time Level Oxygen Conductivity Volume (ft BTOC) (NTU) (mg/L) (units) (mS/cm) (mV) (°F) (mL/min) (gal) 18:53 22.98 100 1.73 4.30 0.354 844.0 38.7 160 0.5 18:56 22.97 96.8 1.50 3.49 0.354 891.9 38.7 100 0.8 19:00 22.96 68.4 1.27 3.24 0.354 906.0 38.8 140 1 19:04 22.96 54.4 1.20 3.06 0.352 925.0 39.0 275 1.3 19:09 22.97 33.7 1.29 2.83 0.355 929.3 39.1 460 1.5 19:12 22.97 26.4 1.37 2.74 0.355 934.9 39.1 160 1.7

Notes: Issues with pH and ORP calibration.

Total Volume Purged (gal): 2 DTW After Purge (ft BTOC): 22.97

Original: 18-AWS-MW09-GW - 19:20 - cVOC Signature:

Duplicate:

Equipment Blank:

Field Blank: Groundwater Purging and Sampling Log

Project Number: PNG0712 Project Name: Aniak RI Date: 03/30/2018

Site Location: Aniak, AK Well ID: MW-10 Screen Interval (ft BGS): 25 Depth to Water (ft BTOC): 30.85 Well Diameter (inch): 2 Total Well Depth (ft BTOC): 37.1 Well Construction Material: SCH 40 PVC Weather: cold, clear, sunny Casing Volume (gal): 1.088 Samplers: OMS, KGT 3 Casings Volume (gal): 3.262 Low-flow Sampling Equipment: Dedicated Tubing Purging Method: Water Quality Meter: YSI Pro Plus, YSI Pro ODO, Purging Equipment: Proactive Hurricane Electric Submersible Pump Hach 2100P Pump Placement (ft BTOC): 36.5 Water Dissolved Specific Total Turbidity pH ORP Temperature Rate Time Level Oxygen Conductivity Volume (ft BTOC) (NTU) (mg/L) (units) (mS/cm) (mV) (°F) (mL/min) (gal) 14:54 - >1000 13.26 5.58 0.354 491.6 42.6 400 0.1 14:57 - >1000 13.24 5.55 0.353 429.0 42.7 300 0.6 15:02 - - 13.18 5.56 0.348 366.0 7.3 140 1 15:07 - >1000 13.15 5.72 0.346 364.8 43.3 300 1.5 15:11 - - 13.12 5.67 0.344 354.9 43.5 120 2

Notes: Issues with ORP calibration. Turbidity readings noted with "-" indicate a problem with the turbidimeter. The water column was too short to obtain a water level reading above the pump (as noted in the field notebook) and therefore the DO meter was likely suspended in air above the water column.

Total Volume Purged (gal): 2.5 DTW After Purge (ft BTOC): -

Original: 18-AWS-MW10-GW - 15:20 - cVOC Signature:

Duplicate:

Equipment Blank:

Field Blank: Groundwater Purging and Sampling Log

Project Number: PNG0712 Project Name: Aniak RI Date: 03/30/2018

Site Location: Aniak, AK Well ID: MW-11 Screen Interval (ft BGS): 25 Depth to Water (ft BTOC): 31.79 Well Diameter (inch): 2 Total Well Depth (ft BTOC): 37.4 Well Construction Material: SCH 40 PVC Weather: cold, clear, sunny Casing Volume (gal): 0.976 Samplers: OMS, KGT 3 Casings Volume (gal): 2.928 Sampling Equipment: Dedicated Tubing Purging Method: Low-flow Water Quality Meter: YSI Pro Plus, YSI Pro ODO, Purging Equipment: Proactive Hurricane Electric Submersible Pump Hach 2100P Pump Placement (ft BTOC): 36.5 Water Dissolved Specific Total Turbidity pH ORP Temperature Rate Time Level Oxygen Conductivity Volume (ft BTOC) (NTU) (mg/L) (units) (mS/cm) (mV) (°F) (mL/min) (gal) 14:00 31.88 49.9 7.17 5.70 0.263 477.2 42.0 1500 0.3 14:03 31.82 32.7 6.46 5.68 0.263 471.7 40.9 170 0.8 14:08 31.81 37.1 6.36 6.34 0.263 450.5 40.0 180 1 14:11 31.81 29.3 6.58 5.91 0.263 442.2 39.9 140 1.3 14:14 - 23.3 6.09 5.89 0.263 440.9 38.7 240 1.6 14:17 - 23.8 6.41 5.91 0.262 431.6 38.5 280 1.9 14:20 31.89 23.7 6.61 5.86 0.263 433.3 38.4 130 2.1

Notes: Issues with ORP calibration.

Total Volume Purged (gal): 2.5 DTW After Purge (ft BTOC): 31.89

Original: 18-AWS-MW11-GW - 14:30 - cVOC Signature:

Duplicate:

Equipment Blank:

Field Blank: Groundwater Purging and Sampling Log

Project Number: PNG0712 Project Name: Aniak RI Date: 03/29/2018

Site Location: Aniak, AK Well ID: MW-12 Screen Interval (ft BGS): 20 Depth to Water (ft BTOC): 27.31 Well Diameter (inch): 2 Total Well Depth (ft BTOC): 34.4 Well Construction Material: SCH 40 PVC Weather: cold, overcast, light wind Casing Volume (gal): 1.234 Samplers: OMS 3 Casings Volume (gal): 3.701 Sampling Equipment: Dedicated Tubing Purging Method: Low-flow Water Quality Meter: YSI Pro Plus, YSI Pro ODO, Purging Equipment: Proactive Hurricane Electric Submersible Pump Hach 2100P Pump Placement (ft BTOC): 34 Water Dissolved Specific Total Turbidity pH ORP Temperature Rate Time Level Oxygen Conductivity Volume (ft BTOC) (NTU) (mg/L) (units) (mS/cm) (mV) (°F) (mL/min) (gal) 10:16 27.32 234 2.26 3.17 0.645 879.7 36.9 172 0.2 10:19 27.32 101 1.71 2.95 0.599 899.4 36.9 420 0.3 10:22 27.32 57.3 1.70 2.87 0.571 905.7 37.0 260 0.35 10:26 27.32 34.2 1.60 2.79 0.551 915.4 37.1 180 0.4 10:29 27.32 31.3 1.62 2.73 0.542 917.6 37.2 160 0.5 10:32 27.32 26.9 2.09 2.72 0.532 917.5 37.3 140 0.6 10:36 27.32 22.3 2.68 2.67 0.524 919.5 37.4 160 0.7

Notes: Issues with pH and ORP calibration.

Total Volume Purged (gal): 1 DTW After Purge (ft BTOC): 27.32

Original: 18-AWS-MW12-GW - 10:38 - cVOC Signature:

Duplicate:

Equipment Blank:

Field Blank: Groundwater Purging and Sampling Log

Project Number: PNG0712 Project Name: Aniak RI Date: 03/30/2018

Site Location: Aniak, AK Well ID: MW-13 Screen Interval (ft BGS): 28 Depth to Water (ft BTOC): 29.22 Well Diameter (inch): 2 Total Well Depth (ft BTOC): 33.55 Well Construction Material: SCH 40 PVC Weather: cold, clear, sunny Casing Volume (gal): 0.753 ' Samplers: OMS, KGT 3 Casings Volume (gal): 2.26 Low-flow Sampling Equipment: Dedicated tubing Purging Method: Water Quality Meter: YSI Pro Plus, YSI Pro ODO, Purging Equipment: Proactive Hurricane Electric Submersible Pump Hach 2100P Pump Placement (ft BTOC): 33 Water Dissolved Specific Total Turbidity pH ORP Temperature Rate Time Level Oxygen Conductivity Volume (ft BTOC) (NTU) (mg/L) (units) (mS/cm) (mV) (°F) (mL/min) (gal) 16:19 29.24 >1000 2.03 5.61 0.363 483.4 40.0 1200 0.3 16:23 29.24 >1000 1.64 5.31 0.354 501.5 40.1 800 0.7 16:27 29.24 527 1.24 5.57 0.352 481.1 40.2 600 1 16:31 29.24 252 1.24 5.56 0.350 480.9 40.1 120 1.2 16:35 29.25 164 1.25 5.53 0.349 482.2 40.2 250 1.5 16:38 29.23 119 1.57 5.48 0.351 480.1 40.2 280 1.7

Notes: Issues with ORP calibration.

Total Volume Purged (gal): 2 DTW After Purge (ft BTOC): 29.23

Original: 18-AWS-MW13-GW - 16:40 - cVOC Signature:

Duplicate:

Equipment Blank:

Field Blank: Groundwater Purging and Sampling Log

Project Number: PNG0712 Project Name: Aniak RI Date: 03/30/2018

Site Location: Aniak, AK Well ID: MW-14 Screen Interval (ft BGS): 27.5 Depth to Water (ft BTOC): 29.64 Well Diameter (inch): 2 Total Well Depth (ft BTOC): 33.5 Well Construction Material: SCH 40 PVC Weather: cold, clear, sunny Casing Volume (gal): 0.672 Samplers: OMS, KGT 3 Casings Volume (gal): 2.015 Low-flow Sampling Equipment: Dedicated tubing Purging Method: Water Quality Meter: YSI Pro Plus, YSI Pro ODO, Purging Equipment: Proactive Hurricane Electric Submersible Pump Hach 2100P Pump Placement (ft BTOC): 33 Water Dissolved Specific Total Turbidity pH ORP Temperature Rate Time Level Oxygen Conductivity Volume (ft BTOC) (NTU) (mg/L) (units) (mS/cm) (mV) (°F) (mL/min) (gal) 17:11 - >1000 4.89 5.94 0.294 488.7 40.2 360 0.25 17:15 - 590 4.80 5.70 0.276 486.0 40.2 480 0.45 17:19 - 179 3.92 5.69 0.271 486.4 40.4 120 1 17:23 - 82.6 3.63 5.60 0.270 489.0 40.5 400 1.7

Notes: Issues with ORP calibration.

Total Volume Purged (gal): 2 DTW After Purge (ft BTOC): -

Original: 18-AWS-MW14-GW - 17:30 - cVOC Signature:

Duplicate:

Equipment Blank:

Field Blank: Groundwater Purging and Sampling Log

Project Number: PNG0712 Project Name: Aniak RI Date: 03/29/2018

Site Location: Aniak, AK Well ID: MW-15 Screen Interval (ft BGS): 18.5 Depth to Water (ft BTOC): 24.21 Well Diameter (inch): 2 Total Well Depth (ft BTOC): 27.85 Well Construction Material: SCH 40 PVC Weather: cold, overcast, light wind Casing Volume (gal): 0.633 Samplers: OMS & KGT 3 Casings Volume (gal): 1.9 Sampling Equipment: Dedicated Tubing Purging Method: Low-flow Water Quality Meter: YSI Pro Plus, YSI Pro ODO, Purging Equipment: Proactive Hurricane Electric Submersible Pump Hach 2100P Pump Placement (ft BTOC): 27 Water Dissolved Specific Total Turbidity pH ORP Temperature Rate Time Level Oxygen Conductivity Volume (ft BTOC) (NTU) (mg/L) (units) (mS/cm) (mV) (°F) (mL/min) (gal) 17:50 24.18 - 1.75 4.23 0.678 849.4 38.9 320 0.2 17:55 24.21 477 0.89 3.67 0.680 886.9 39.1 400 0.3 18:00 24.23 251 1.10 2.91 0.690 931.9 39.2 240 0.4 18:05 24.23 142 1.24 2.33 0.690 962.6 39.2 260 0.4 18:09 24.22 50.5 1.34 2.10 0.687 970.0 39.1 230 0.6 18:12 24.23 25.6 1.26 2.00 0.681 975.5 39.2 230 0.9 18:15 24.23 21.3 1.25 1.93 0.673 975.4 39.3 240 1.1

Notes: Issues with pH and ORP calibration.

Total Volume Purged (gal): 1.5 DTW After Purge (ft BTOC): 24.23

Original: 18-AWS-MW15-GW - 18:20 - cVOC Signature:

Duplicate:

Equipment Blank:

Field Blank: Groundwater Purging and Sampling Log

Project Number: PNG0712 Project Name: Aniak RI Date: 03/29/2018

Site Location: Aniak, AK Well ID: MW-16 Screen Interval (ft BGS): 27.5 Depth to Water (ft BTOC): 27.3 Well Diameter (inch): 2 Total Well Depth (ft BTOC): 33.27 Well Construction Material: SCH 40 PVC Weather: cold, overcast, light wind Casing Volume (gal): 1.039 Samplers: OMS & KGT 3 Casings Volume (gal): 3.116 Sampling Equipment: Dedicated Tubing Purging Method: Low-flow Water Quality Meter: YSI Pro Plus, YSI Pro ODO, Purgingach 2100P Equipment: Proactive Hurricane Electric Submersible Pump Hach 2100P Pump Placement (ft BTOC): 32.5 Water Dissolved Specific Total Turbidity pH ORP Temperature Rate Time Level Oxygen Conductivity Volume (ft BTOC) (NTU) (mg/L) (units) (mS/cm) (mV) (°F) (mL/min) (gal) 20:38 27.34 580 0.68 6.08 0.469 740.1 38.3 1050 0.5 20:43 27.36 303 0.32 4.53 0.472 837.3 38.5 320 0.7 20:47 27.37 97.4 0.21 3.01 0.471 916.3 38.6 560 1.2 20:51 27.35 32.3 0.17 2.72 0.468 935.8 38.6 560 1.7 20:55 27.32 29.2 0.15 2.56 0.466 947.8 38.7 240 2 20:58 27.34 18.5 0.15 2.43 0.464 948.7 38.7 320 2.2 21:01 27.36 20.0 0.16 2.31 0.462 957.9 38.8 600 2.5

Notes: Issues with pH and ORP calibration.

Total Volume Purged (gal): 3 DTW After Purge (ft BTOC): 27.36

Original: 18-AWS-MW16-GW - 21:04 - cVOC Signature:

Duplicate:

Equipment Blank:

Field Blank: Groundwater Purging and Sampling Log

Project Number: PNG0712 Project Name: Aniak RI Date: 03/30/2018

Site Location: Aniak, AK Well ID: MW-17 Screen Interval (ft BGS): 29 Depth to Water (ft BTOC): 30.52 Well Diameter (inch): 2 Total Well Depth (ft BTOC): 32.9 Well Construction Material: SCH 40 PVC Weather: cold, clear, sunny Casing Volume (gal): 0.414 Samplers: OMS, KGT 3 Casings Volume (gal): 1.242 Low-flow Sampling Equipment: Dedicated tubing Purging Method: Water Quality Meter: YSI Pro Plus, YSI Pro ODO, Purging Equipment: Proactive Hurricane Electric Submersible Pump Hach 2100P Pump Placement (ft BTOC): 32.5 Water Dissolved Specific Total Turbidity pH ORP Temperature Rate Time Level Oxygen Conductivity Volume (ft BTOC) (NTU) (mg/L) (units) (mS/cm) (mV) (°F) (mL/min) (gal) 12:49 - 459 14.19 5.65 0.231 458.5 37.6 400 0.15 12:52 - 199 13.91 5.70 0.217 453.7 39.0 200 0.3 12:54 - 89.1 13.81 5.68 0.219 455.9 39.5 120 0.4 12:57 - 64.0 13.75 5.73 0.22 454.7 38.9 280 0.7 13:00 - 42.1 13.71 5.75 0.234 459.1 40.1 120 1

Notes: Issues with ORP calibration. Well casing had an ice plug at approximately 12-18 inches BTOC. Poured ~1,200 mL of hot water down hole to melt the plug and used a disposable poly bailer to dislodge it.

Total Volume Purged (gal): 1.5 DTW After Purge (ft BTOC): -

Original: 18-AWS-MW17-GW - 13:05 - cVOC Signature:

Duplicate:

Equipment Blank:

Field Blank: Groundwater Purging and Sampling Log

Project Number: PNG0712 Project Name: Aniak RI Date: 03/29/2018

Site Location: Aniak, AK Well ID: MW-18 Screen Interval (ft BGS): 18.5 Depth to Water (ft BTOC): 23.17 Well Diameter (inch): 2 Total Well Depth (ft BTOC): 26.95 Well Construction Material: SCH 40 PVC Weather: cold, overcast, light wind Casing Volume (gal): 0.658 Samplers: OMS&KGT 3 Casings Volume (gal): 1.973 Sampling Equipment: Dedicated Tubing Purging Method: Low-flow Water Quality Meter: YSI Pro Plus, YSI Pro ODO, Purging Equipment: Proactive Hurricane Electric Submersible Pump Hach 2100P Pump Placement (ft BTOC): 26 Water Dissolved Specific Total Turbidity pH ORP Temperature Rate Time Level Oxygen Conductivity Volume (ft BTOC) (NTU) (mg/L) (units) (mS/cm) (mV) (°F) (mL/min) (gal) 16:32 23.20 820 5.34 6.34 0.436 741.9 38.6 260 0.2 16:36 23.20 369 5.92 5.97 0.428 760.8 38.7 260 0.25 16:40 23.19 159 5.84 5.45 0.427 794.9 38.8 150 0.4 16:44 23.20 107 5.72 5.08 0.424 821.8 38.9 180 0.7 16:48 23.19 51.4 5.38 4.75 0.421 831.9 39.0 220 1 16:52 23.19 26.3 3.78 4.51 0.421 842.6 39.1 170 1.2 16:56 23.19 15.1 3.29 3.76 0.419 887.3 39.1 165 1.3 17:00 23.19 11.0 3.01 3.59 0.416 894.7 39.1 170 1.5 17:03 23.19 7.9 2.24 3.44 0.413 899.9 39.1 185 1.6 17:06 23.19 5.37 2.07 3.30 0.411 913.0 39.1 160 1.7 17:10 23.19 3.76 1.99 4.40 0.411 961.9 39.1 145 2

Notes: Issues with pH and ORP calibration.

Total Volume Purged (gal): 2.5 DTW After Purge (ft BTOC): 23.19

Original: 18-AWS-MW18-GW - 17:15 - cVOC Signature:

Duplicate: 18-AWS-MW02-GW - 17:45 - cVOC

Equipment Blank:

Field Blank: March 2018 Groundwater Results, Aniak WACS 10 December 2018 Page 7

ATTACHMENT 2

LABORATORY ANALYTICAL REPORT

Aniak_March2018_GW_TechMemo_120718

Laboratory Report of Analysis

To: Geosyntec Consultants 4101 Arctic Boulevard #206 Anchorage, AK (907)433-0770

Report Number: 1181296

Client Project: PNG0712 Aniak 2018 GW

Dear Ben Martich,

Enclosed are the results of the analytical services performed under the referenced project for the received samples and associated QC as applicable. The samples are certified to meet the requirements of the National Environmental Laboratory Accreditation Conference Standards. Copies of this report and supporting data will be retained in our files for a period of ten years in the event they are required for future reference. All results are intended to be used in their entirety and SGS is not responsible for use of less than the complete report. Any samples submitted to our laboratory will be retained for a maximum of fourteen (14) days from the date of this report unless other archiving requirements were included in the quote.

If there are any questions about the report or services performed during this project, please call Justin at (907) 562-2343. We will be happy to answer any questions or concerns which you may have.

Thank you for using SGS North America Inc. for your analytical services. We look forward to working with you again on any additional analytical needs.

Sincerely, SGS North America Inc.

______Justin Nelson Date Project Manager [email protected]

Print Date: 04/06/2018 2:20:47PM

SGS North America Inc. 200 West Potter Drive, Anchorage, AK 99518 t 907.562.2343 f 907.561.5301 www.us.sgs.com Member of SGS Group

1 of 31 Case Narrative

SGS Client: Geosyntec Consultants SGS Project: 1181296 Project Name/Site: PNG0712 Aniak 2018 GW Project Contact: Ben Martich

Refer to sample receipt form for information on sample condition. LB for HBN 1777847 [TCLP/9311] (1439112) LB 8260C - LB recovery for 2-butanone does not meet QC criteria. This analyte was not detected in associated samples.

*QC comments may be associated with the field samples found in this report. When applicable, comments will be applied to associated field samples.

Print Date: 04/06/2018 2:20:48PM 200 West Potter Drive, Anchorage, AK 99518 SGS North America Inc. t 907.562.2343 f 907.561.5301 www.us.sgs.com Member of SGS Group

2 of 31 Laboratory Qualifiers

Enclosed are the analytical results associated with the above work order. All results are intended to be used in their entirety and SGS is not responsible for use of less than the complete report. This document is issued by the Company under its General Conditions of Service accessible at . Attention is drawn to the limitation of liability, indenmification and jurisdiction issues defined therein.

Any holder of this document is advised that information contained hereon reflects the Company's findings at the time of its intervention only and within the limits of Client's instructions, if any. The Company's sole responsibility is to its Client and this document does not exonerate parties to a transaction from exercising all their rights and obligations under the transaction documents. Any unauthorized alteration, forgery or falsification of the context or appearance of this document is unlawful and offenders may be prosecuted to the fullest extent of the law.

SGS maintains a formal Quality Assurance/Quality Control (QA/QC) program. A copy of our Quality Assurance Plan (QAP), which outlines this program, is available at your request. The laboratory certification numbers are AK00971 (DW Chemistry & Microbiology) & 17-021 (CS) for ADEC and 2944.01 for DOD ELAP/ISO17025 (RCRA methods: 1020B, 1311, 3010A, 3050B, 3520C, 3550C, 5030B, 5035A, 6020A, 7470A, 7471B, 8015C, 8021B, 8082A, 8260C, 8270D, 8270D-SIM, 9040C, 9045D, 9056A, 9060A, AK101 and AK102/103). Except as specifically noted, all statements and data in this report are in conformance to the provisions set forth by the SGS QAP and, when applicable, other regulatory authorities.

The following descriptors or qualifiers may be found in your report:

* The analyte has exceeded allowable regulatory or control limits. ! Surrogate out of control limits. B Indicates the analyte is found in a blank associated with the sample. CCV/CVA/CVB Continuing Calibration Verification CCCV/CVC/CVCA/CVCB Closing Continuing Calibration Verification CL Control Limit DF Analytical Dilution Factor DL Detection Limit (i.e., maximum method detection limit) E The analyte result is above the calibrated range. GT Greater Than IB Instrument Blank ICV Initial Calibration Verification J The quantitation is an estimation. LCS(D) Laboratory Control Spike (Duplicate) LLQC/LLIQC Low Level Quantitation Check LOD Limit of Detection (i.e., 1/2 of the LOQ) LOQ Limit of Quantitation (i.e., reporting or practical quantitation limit) LT Less Than MB Method Blank MS(D) Matrix Spike (Duplicate) ND Indicates the analyte is not detected. RPD Relative Percent Difference U Indicates the analyte was analyzed for but not detected.

Note: Sample summaries which include a result for "Total Solids" have already been adjusted for moisture content. All DRO/RRO analyses are integrated per SOP.

Print Date: 04/06/2018 2:20:50PM

SGS North America Inc. 200 West Potter Drive, Anchorage, AK 99518 t 907.562.2343 f 907.561.5301 www.us.sgs.com Member of SGS Group

3 of 31 Sample Summary

Client Sample ID Lab Sample ID Collected Received Matrix 18-AWS-MW12-GW 1181296001 03/29/2018 04/02/2018 Water (Surface, Eff., Ground) 18-AWS-MW6-GW 1181296002 03/29/2018 04/02/2018 Water (Surface, Eff., Ground) 18-AWS-MW18-GW 1181296003 03/29/2018 04/02/2018 Water (Surface, Eff., Ground) 18-AWS-MW02-GW 1181296004 03/29/2018 04/02/2018 Water (Surface, Eff., Ground) 18-AWS-MW15-GW 1181296005 03/29/2018 04/02/2018 Water (Surface, Eff., Ground) 18-AWS-MW09-GW 1181296006 03/29/2018 04/02/2018 Water (Surface, Eff., Ground) 18-AWS-MW16-GW 1181296007 03/29/2018 04/02/2018 Water (Surface, Eff., Ground) 18-AWS-MW7-GW 1181296008 03/30/2018 04/02/2018 Water (Surface, Eff., Ground) 18-AWS-MW1-GW 1181296009 03/30/2018 04/02/2018 Water (Surface, Eff., Ground) 18-AWS-MW8-GW 1181296010 03/30/2018 04/02/2018 Water (Surface, Eff., Ground) 18-AWS-MW17-GW 1181296011 03/30/2018 04/02/2018 Water (Surface, Eff., Ground) 18-AWS-MW11-GW 1181296012 03/30/2018 04/02/2018 Water (Surface, Eff., Ground) 18-AWS-MW10-GW 1181296013 03/30/2018 04/02/2018 Water (Surface, Eff., Ground) 18-AWS-MW13-GW 1181296014 03/30/2018 04/02/2018 Water (Surface, Eff., Ground) 18-AWS-MW14-GW 1181296015 03/30/2018 04/02/2018 Water (Surface, Eff., Ground) 18-AWS-TB01-GW 1181296016 03/21/2018 04/02/2018 Water (Surface, Eff., Ground)

Method Method Description SW8260C Volatile Organic Compounds (W) FULL

Print Date: 04/06/2018 2:20:52PM

200 West Potter Drive, Anchorage, AK 99518 SGS North America Inc. t 907.562.2343 f 907.561.5301 www.us.sgs.com Member of SGS Group

4 of 31 Detectable Results Summary

Client Sample ID: 18-AWS-MW18-GW Lab Sample ID: 1181296003 Parameter Result Units Volatile GC/MS Trichloroethene 7.69 ug/L Client Sample ID: 18-AWS-MW02-GW Lab Sample ID: 1181296004 Parameter Result Units Volatile GC/MS Trichloroethene 7.64 ug/L Client Sample ID: 18-AWS-MW15-GW Lab Sample ID: 1181296005 Parameter Result Units Volatile GC/MS cis-1,2-Dichloroethene 2.43 ug/L Trichloroethene 4.88 ug/L Client Sample ID: 18-AWS-MW09-GW Lab Sample ID: 1181296006 Parameter Result Units Volatile GC/MS cis-1,2-Dichloroethene 0.350J ug/L Client Sample ID: 18-AWS-MW7-GW Lab Sample ID: 1181296008 Parameter Result Units Volatile GC/MS Trichloroethene 27.0 ug/L Client Sample ID: 18-AWS-MW1-GW Lab Sample ID: 1181296009 Parameter Result Units Volatile GC/MS Trichloroethene 27.7 ug/L Client Sample ID: 18-AWS-MW10-GW Lab Sample ID: 1181296013 Parameter Result Units Volatile GC/MS Tetrachloroethene 1.86 ug/L Client Sample ID: 18-AWS-MW13-GW Lab Sample ID: 1181296014 Parameter Result Units Volatile GC/MS cis-1,2-Dichloroethene 34.5 ug/L trans-1,2-Dichloroethene 0.460J ug/L Trichloroethene 124 ug/L Client Sample ID: 18-AWS-MW14-GW Lab Sample ID: 1181296015 Parameter Result Units Volatile GC/MS Trichloroethene 112 ug/L

Print Date: 04/06/2018 2:20:53PM 200 West Potter Drive, Anchorage, AK 99518 SGS North America Inc. t 907.562.2343 f 907.561.5301 www.us.sgs.com Member of SGS Group

5 of 31 Results of 18-AWS-MW12-GW

Client Sample ID: 18-AWS-MW12-GW Collection Date: 03/29/18 10:38 Client Project ID: PNG0712 Aniak 2018 GW Received Date: 04/02/18 11:40 Lab Sample ID: 1181296001 Matrix: Water (Surface, Eff., Ground) Lab Project ID: 1181296 Solids (%): Location: Results by Volatile GC/MS

Allowable Parameter Result Qual LOQ/CL DL Units DF Limits Date Analyzed cis-1,2-Dichloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 15:01 Tetrachloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 15:01 trans-1,2-Dichloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 15:01 Trichloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 15:01 Vinyl chloride 0.0750 U 0.150 0.0500 ug/L 1 04/03/18 15:01

Surrogates 1,2-Dichloroethane-D4 (surr) 99.7 81-118 % 1 04/03/18 15:01 4-Bromofluorobenzene (surr) 102 85-114 % 1 04/03/18 15:01 Toluene-d8 (surr) 99.7 89-112 % 1 04/03/18 15:01

Batch Information Analytical Batch: VMS17689 Prep Batch: VXX32081 Analytical Method: SW8260C Prep Method: SW5030B Analyst: FDR Prep Date/Time: 04/03/18 00:00 Analytical Date/Time: 04/03/18 15:01 Prep Initial Wt./Vol.: 5 mL Container ID: 1181296001-A Prep Extract Vol: 5 mL

Print Date: 04/06/2018 2:20:54PM J flagging is activated 200 West Potter Drive Anchorage, AK 95518 SGS North America Inc. t 907.562.2343 f 907.561.5301 www.us.sgs.com Member of SGS Group

6 of 31 Results of 18-AWS-MW6-GW

Client Sample ID: 18-AWS-MW6-GW Collection Date: 03/29/18 15:49 Client Project ID: PNG0712 Aniak 2018 GW Received Date: 04/02/18 11:40 Lab Sample ID: 1181296002 Matrix: Water (Surface, Eff., Ground) Lab Project ID: 1181296 Solids (%): Location: Results by Volatile GC/MS

Allowable Parameter Result Qual LOQ/CL DL Units DF Limits Date Analyzed cis-1,2-Dichloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 15:18 Tetrachloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 15:18 trans-1,2-Dichloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 15:18 Trichloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 15:18 Vinyl chloride 0.0750 U 0.150 0.0500 ug/L 1 04/03/18 15:18

Surrogates 1,2-Dichloroethane-D4 (surr) 99.6 81-118 % 1 04/03/18 15:18 4-Bromofluorobenzene (surr) 101 85-114 % 1 04/03/18 15:18 Toluene-d8 (surr) 100 89-112 % 1 04/03/18 15:18

Batch Information Analytical Batch: VMS17689 Prep Batch: VXX32081 Analytical Method: SW8260C Prep Method: SW5030B Analyst: FDR Prep Date/Time: 04/03/18 00:00 Analytical Date/Time: 04/03/18 15:18 Prep Initial Wt./Vol.: 5 mL Container ID: 1181296002-A Prep Extract Vol: 5 mL

Print Date: 04/06/2018 2:20:54PM J flagging is activated 200 West Potter Drive Anchorage, AK 95518 SGS North America Inc. t 907.562.2343 f 907.561.5301 www.us.sgs.com Member of SGS Group

7 of 31 Results of 18-AWS-MW18-GW

Client Sample ID: 18-AWS-MW18-GW Collection Date: 03/29/18 17:15 Client Project ID: PNG0712 Aniak 2018 GW Received Date: 04/02/18 11:40 Lab Sample ID: 1181296003 Matrix: Water (Surface, Eff., Ground) Lab Project ID: 1181296 Solids (%): Location: Results by Volatile GC/MS

Allowable Parameter Result Qual LOQ/CL DL Units DF Limits Date Analyzed cis-1,2-Dichloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 15:36 Tetrachloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 15:36 trans-1,2-Dichloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 15:36 Trichloroethene 7.69 1.00 0.310 ug/L 1 04/03/18 15:36 Vinyl chloride 0.0750 U 0.150 0.0500 ug/L 1 04/03/18 15:36

Surrogates 1,2-Dichloroethane-D4 (surr) 99.3 81-118 % 1 04/03/18 15:36 4-Bromofluorobenzene (surr) 101 85-114 % 1 04/03/18 15:36 Toluene-d8 (surr) 101 89-112 % 1 04/03/18 15:36

Batch Information Analytical Batch: VMS17689 Prep Batch: VXX32081 Analytical Method: SW8260C Prep Method: SW5030B Analyst: FDR Prep Date/Time: 04/03/18 00:00 Analytical Date/Time: 04/03/18 15:36 Prep Initial Wt./Vol.: 5 mL Container ID: 1181296003-A Prep Extract Vol: 5 mL

Print Date: 04/06/2018 2:20:54PM J flagging is activated 200 West Potter Drive Anchorage, AK 95518 SGS North America Inc. t 907.562.2343 f 907.561.5301 www.us.sgs.com Member of SGS Group

8 of 31 Results of 18-AWS-MW02-GW

Client Sample ID: 18-AWS-MW02-GW Collection Date: 03/29/18 17:45 Client Project ID: PNG0712 Aniak 2018 GW Received Date: 04/02/18 11:40 Lab Sample ID: 1181296004 Matrix: Water (Surface, Eff., Ground) Lab Project ID: 1181296 Solids (%): Location: Results by Volatile GC/MS

Allowable Parameter Result Qual LOQ/CL DL Units DF Limits Date Analyzed cis-1,2-Dichloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 15:53 Tetrachloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 15:53 trans-1,2-Dichloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 15:53 Trichloroethene 7.64 1.00 0.310 ug/L 1 04/03/18 15:53 Vinyl chloride 0.0750 U 0.150 0.0500 ug/L 1 04/03/18 15:53

Surrogates 1,2-Dichloroethane-D4 (surr) 99.7 81-118 % 1 04/03/18 15:53 4-Bromofluorobenzene (surr) 100 85-114 % 1 04/03/18 15:53 Toluene-d8 (surr) 100 89-112 % 1 04/03/18 15:53

Batch Information Analytical Batch: VMS17689 Prep Batch: VXX32081 Analytical Method: SW8260C Prep Method: SW5030B Analyst: FDR Prep Date/Time: 04/03/18 00:00 Analytical Date/Time: 04/03/18 15:53 Prep Initial Wt./Vol.: 5 mL Container ID: 1181296004-A Prep Extract Vol: 5 mL

Print Date: 04/06/2018 2:20:54PM J flagging is activated 200 West Potter Drive Anchorage, AK 95518 SGS North America Inc. t 907.562.2343 f 907.561.5301 www.us.sgs.com Member of SGS Group

9 of 31 Results of 18-AWS-MW15-GW

Client Sample ID: 18-AWS-MW15-GW Collection Date: 03/29/18 18:20 Client Project ID: PNG0712 Aniak 2018 GW Received Date: 04/02/18 11:40 Lab Sample ID: 1181296005 Matrix: Water (Surface, Eff., Ground) Lab Project ID: 1181296 Solids (%): Location: Results by Volatile GC/MS

Allowable Parameter Result Qual LOQ/CL DL Units DF Limits Date Analyzed cis-1,2-Dichloroethene 2.43 1.00 0.310 ug/L 1 04/03/18 16:11 Tetrachloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 16:11 trans-1,2-Dichloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 16:11 Trichloroethene 4.88 1.00 0.310 ug/L 1 04/03/18 16:11 Vinyl chloride 0.0750 U 0.150 0.0500 ug/L 1 04/03/18 16:11

Surrogates 1,2-Dichloroethane-D4 (surr) 99.3 81-118 % 1 04/03/18 16:11 4-Bromofluorobenzene (surr) 100 85-114 % 1 04/03/18 16:11 Toluene-d8 (surr) 100 89-112 % 1 04/03/18 16:11

Batch Information Analytical Batch: VMS17689 Prep Batch: VXX32081 Analytical Method: SW8260C Prep Method: SW5030B Analyst: FDR Prep Date/Time: 04/03/18 00:00 Analytical Date/Time: 04/03/18 16:11 Prep Initial Wt./Vol.: 5 mL Container ID: 1181296005-A Prep Extract Vol: 5 mL

Print Date: 04/06/2018 2:20:54PM J flagging is activated 200 West Potter Drive Anchorage, AK 95518 SGS North America Inc. t 907.562.2343 f 907.561.5301 www.us.sgs.com Member of SGS Group

10 of 31 Results of 18-AWS-MW09-GW

Client Sample ID: 18-AWS-MW09-GW Collection Date: 03/29/18 19:20 Client Project ID: PNG0712 Aniak 2018 GW Received Date: 04/02/18 11:40 Lab Sample ID: 1181296006 Matrix: Water (Surface, Eff., Ground) Lab Project ID: 1181296 Solids (%): Location: Results by Volatile GC/MS

Allowable Parameter Result Qual LOQ/CL DL Units DF Limits Date Analyzed cis-1,2-Dichloroethene 0.350 J 1.00 0.310 ug/L 1 04/03/18 16:28 Tetrachloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 16:28 trans-1,2-Dichloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 16:28 Trichloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 16:28 Vinyl chloride 0.0750 U 0.150 0.0500 ug/L 1 04/03/18 16:28

Surrogates 1,2-Dichloroethane-D4 (surr) 99.1 81-118 % 1 04/03/18 16:28 4-Bromofluorobenzene (surr) 103 85-114 % 1 04/03/18 16:28 Toluene-d8 (surr) 101 89-112 % 1 04/03/18 16:28

Batch Information Analytical Batch: VMS17689 Prep Batch: VXX32081 Analytical Method: SW8260C Prep Method: SW5030B Analyst: FDR Prep Date/Time: 04/03/18 00:00 Analytical Date/Time: 04/03/18 16:28 Prep Initial Wt./Vol.: 5 mL Container ID: 1181296006-A Prep Extract Vol: 5 mL

Print Date: 04/06/2018 2:20:54PM J flagging is activated 200 West Potter Drive Anchorage, AK 95518 SGS North America Inc. t 907.562.2343 f 907.561.5301 www.us.sgs.com Member of SGS Group

11 of 31 Results of 18-AWS-MW16-GW

Client Sample ID: 18-AWS-MW16-GW Collection Date: 03/29/18 21:04 Client Project ID: PNG0712 Aniak 2018 GW Received Date: 04/02/18 11:40 Lab Sample ID: 1181296007 Matrix: Water (Surface, Eff., Ground) Lab Project ID: 1181296 Solids (%): Location: Results by Volatile GC/MS

Allowable Parameter Result Qual LOQ/CL DL Units DF Limits Date Analyzed cis-1,2-Dichloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 16:46 Tetrachloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 16:46 trans-1,2-Dichloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 16:46 Trichloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 16:46 Vinyl chloride 0.0750 U 0.150 0.0500 ug/L 1 04/03/18 16:46

Surrogates 1,2-Dichloroethane-D4 (surr) 101 81-118 % 1 04/03/18 16:46 4-Bromofluorobenzene (surr) 100 85-114 % 1 04/03/18 16:46 Toluene-d8 (surr) 100 89-112 % 1 04/03/18 16:46

Batch Information Analytical Batch: VMS17689 Prep Batch: VXX32081 Analytical Method: SW8260C Prep Method: SW5030B Analyst: FDR Prep Date/Time: 04/03/18 00:00 Analytical Date/Time: 04/03/18 16:46 Prep Initial Wt./Vol.: 5 mL Container ID: 1181296007-A Prep Extract Vol: 5 mL

Print Date: 04/06/2018 2:20:54PM J flagging is activated 200 West Potter Drive Anchorage, AK 95518 SGS North America Inc. t 907.562.2343 f 907.561.5301 www.us.sgs.com Member of SGS Group

12 of 31 Results of 18-AWS-MW7-GW

Client Sample ID: 18-AWS-MW7-GW Collection Date: 03/30/18 10:05 Client Project ID: PNG0712 Aniak 2018 GW Received Date: 04/02/18 11:40 Lab Sample ID: 1181296008 Matrix: Water (Surface, Eff., Ground) Lab Project ID: 1181296 Solids (%): Location: Results by Volatile GC/MS

Allowable Parameter Result Qual LOQ/CL DL Units DF Limits Date Analyzed cis-1,2-Dichloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 17:03 Tetrachloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 17:03 trans-1,2-Dichloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 17:03 Trichloroethene 27.0 1.00 0.310 ug/L 1 04/03/18 17:03 Vinyl chloride 0.0750 U 0.150 0.0500 ug/L 1 04/03/18 17:03

Surrogates 1,2-Dichloroethane-D4 (surr) 101 81-118 % 1 04/03/18 17:03 4-Bromofluorobenzene (surr) 100 85-114 % 1 04/03/18 17:03 Toluene-d8 (surr) 101 89-112 % 1 04/03/18 17:03

Batch Information Analytical Batch: VMS17689 Prep Batch: VXX32081 Analytical Method: SW8260C Prep Method: SW5030B Analyst: FDR Prep Date/Time: 04/03/18 00:00 Analytical Date/Time: 04/03/18 17:03 Prep Initial Wt./Vol.: 5 mL Container ID: 1181296008-A Prep Extract Vol: 5 mL

Print Date: 04/06/2018 2:20:54PM J flagging is activated 200 West Potter Drive Anchorage, AK 95518 SGS North America Inc. t 907.562.2343 f 907.561.5301 www.us.sgs.com Member of SGS Group

13 of 31 Results of 18-AWS-MW1-GW

Client Sample ID: 18-AWS-MW1-GW Collection Date: 03/30/18 10:35 Client Project ID: PNG0712 Aniak 2018 GW Received Date: 04/02/18 11:40 Lab Sample ID: 1181296009 Matrix: Water (Surface, Eff., Ground) Lab Project ID: 1181296 Solids (%): Location: Results by Volatile GC/MS

Allowable Parameter Result Qual LOQ/CL DL Units DF Limits Date Analyzed cis-1,2-Dichloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 17:21 Tetrachloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 17:21 trans-1,2-Dichloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 17:21 Trichloroethene 27.7 1.00 0.310 ug/L 1 04/03/18 17:21 Vinyl chloride 0.0750 U 0.150 0.0500 ug/L 1 04/03/18 17:21

Surrogates 1,2-Dichloroethane-D4 (surr) 99.5 81-118 % 1 04/03/18 17:21 4-Bromofluorobenzene (surr) 102 85-114 % 1 04/03/18 17:21 Toluene-d8 (surr) 100 89-112 % 1 04/03/18 17:21

Batch Information Analytical Batch: VMS17689 Prep Batch: VXX32081 Analytical Method: SW8260C Prep Method: SW5030B Analyst: FDR Prep Date/Time: 04/03/18 00:00 Analytical Date/Time: 04/03/18 17:21 Prep Initial Wt./Vol.: 5 mL Container ID: 1181296009-A Prep Extract Vol: 5 mL

Print Date: 04/06/2018 2:20:54PM J flagging is activated 200 West Potter Drive Anchorage, AK 95518 SGS North America Inc. t 907.562.2343 f 907.561.5301 www.us.sgs.com Member of SGS Group

14 of 31 Results of 18-AWS-MW8-GW

Client Sample ID: 18-AWS-MW8-GW Collection Date: 03/30/18 11:00 Client Project ID: PNG0712 Aniak 2018 GW Received Date: 04/02/18 11:40 Lab Sample ID: 1181296010 Matrix: Water (Surface, Eff., Ground) Lab Project ID: 1181296 Solids (%): Location: Results by Volatile GC/MS

Allowable Parameter Result Qual LOQ/CL DL Units DF Limits Date Analyzed cis-1,2-Dichloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 17:38 Tetrachloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 17:38 trans-1,2-Dichloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 17:38 Trichloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 17:38 Vinyl chloride 0.0750 U 0.150 0.0500 ug/L 1 04/03/18 17:38

Surrogates 1,2-Dichloroethane-D4 (surr) 99.9 81-118 % 1 04/03/18 17:38 4-Bromofluorobenzene (surr) 104 85-114 % 1 04/03/18 17:38 Toluene-d8 (surr) 101 89-112 % 1 04/03/18 17:38

Batch Information Analytical Batch: VMS17689 Prep Batch: VXX32081 Analytical Method: SW8260C Prep Method: SW5030B Analyst: FDR Prep Date/Time: 04/03/18 00:00 Analytical Date/Time: 04/03/18 17:38 Prep Initial Wt./Vol.: 5 mL Container ID: 1181296010-A Prep Extract Vol: 5 mL

Print Date: 04/06/2018 2:20:54PM J flagging is activated 200 West Potter Drive Anchorage, AK 95518 SGS North America Inc. t 907.562.2343 f 907.561.5301 www.us.sgs.com Member of SGS Group

15 of 31 Results of 18-AWS-MW17-GW

Client Sample ID: 18-AWS-MW17-GW Collection Date: 03/30/18 13:05 Client Project ID: PNG0712 Aniak 2018 GW Received Date: 04/02/18 11:40 Lab Sample ID: 1181296011 Matrix: Water (Surface, Eff., Ground) Lab Project ID: 1181296 Solids (%): Location: Results by Volatile GC/MS

Allowable Parameter Result Qual LOQ/CL DL Units DF Limits Date Analyzed cis-1,2-Dichloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 17:56 Tetrachloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 17:56 trans-1,2-Dichloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 17:56 Trichloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 17:56 Vinyl chloride 0.0750 U 0.150 0.0500 ug/L 1 04/03/18 17:56

Surrogates 1,2-Dichloroethane-D4 (surr) 99.9 81-118 % 1 04/03/18 17:56 4-Bromofluorobenzene (surr) 101 85-114 % 1 04/03/18 17:56 Toluene-d8 (surr) 101 89-112 % 1 04/03/18 17:56

Batch Information Analytical Batch: VMS17689 Prep Batch: VXX32081 Analytical Method: SW8260C Prep Method: SW5030B Analyst: FDR Prep Date/Time: 04/03/18 00:00 Analytical Date/Time: 04/03/18 17:56 Prep Initial Wt./Vol.: 5 mL Container ID: 1181296011-A Prep Extract Vol: 5 mL

Print Date: 04/06/2018 2:20:54PM J flagging is activated 200 West Potter Drive Anchorage, AK 95518 SGS North America Inc. t 907.562.2343 f 907.561.5301 www.us.sgs.com Member of SGS Group

16 of 31 Results of 18-AWS-MW11-GW

Client Sample ID: 18-AWS-MW11-GW Collection Date: 03/30/18 14:20 Client Project ID: PNG0712 Aniak 2018 GW Received Date: 04/02/18 11:40 Lab Sample ID: 1181296012 Matrix: Water (Surface, Eff., Ground) Lab Project ID: 1181296 Solids (%): Location: Results by Volatile GC/MS

Allowable Parameter Result Qual LOQ/CL DL Units DF Limits Date Analyzed cis-1,2-Dichloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 18:13 Tetrachloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 18:13 trans-1,2-Dichloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 18:13 Trichloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 18:13 Vinyl chloride 0.0750 U 0.150 0.0500 ug/L 1 04/03/18 18:13

Surrogates 1,2-Dichloroethane-D4 (surr) 99.2 81-118 % 1 04/03/18 18:13 4-Bromofluorobenzene (surr) 103 85-114 % 1 04/03/18 18:13 Toluene-d8 (surr) 101 89-112 % 1 04/03/18 18:13

Batch Information Analytical Batch: VMS17689 Prep Batch: VXX32081 Analytical Method: SW8260C Prep Method: SW5030B Analyst: FDR Prep Date/Time: 04/03/18 00:00 Analytical Date/Time: 04/03/18 18:13 Prep Initial Wt./Vol.: 5 mL Container ID: 1181296012-A Prep Extract Vol: 5 mL

Print Date: 04/06/2018 2:20:54PM J flagging is activated 200 West Potter Drive Anchorage, AK 95518 SGS North America Inc. t 907.562.2343 f 907.561.5301 www.us.sgs.com Member of SGS Group

17 of 31 Results of 18-AWS-MW10-GW

Client Sample ID: 18-AWS-MW10-GW Collection Date: 03/30/18 15:20 Client Project ID: PNG0712 Aniak 2018 GW Received Date: 04/02/18 11:40 Lab Sample ID: 1181296013 Matrix: Water (Surface, Eff., Ground) Lab Project ID: 1181296 Solids (%): Location: Results by Volatile GC/MS

Allowable Parameter Result Qual LOQ/CL DL Units DF Limits Date Analyzed cis-1,2-Dichloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 18:31 Tetrachloroethene 1.86 1.00 0.310 ug/L 1 04/03/18 18:31 trans-1,2-Dichloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 18:31 Trichloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 18:31 Vinyl chloride 0.0750 U 0.150 0.0500 ug/L 1 04/03/18 18:31

Surrogates 1,2-Dichloroethane-D4 (surr) 99.5 81-118 % 1 04/03/18 18:31 4-Bromofluorobenzene (surr) 103 85-114 % 1 04/03/18 18:31 Toluene-d8 (surr) 101 89-112 % 1 04/03/18 18:31

Batch Information Analytical Batch: VMS17689 Prep Batch: VXX32081 Analytical Method: SW8260C Prep Method: SW5030B Analyst: FDR Prep Date/Time: 04/03/18 00:00 Analytical Date/Time: 04/03/18 18:31 Prep Initial Wt./Vol.: 5 mL Container ID: 1181296013-A Prep Extract Vol: 5 mL

Print Date: 04/06/2018 2:20:54PM J flagging is activated 200 West Potter Drive Anchorage, AK 95518 SGS North America Inc. t 907.562.2343 f 907.561.5301 www.us.sgs.com Member of SGS Group

18 of 31 Results of 18-AWS-MW13-GW

Client Sample ID: 18-AWS-MW13-GW Collection Date: 03/30/18 16:40 Client Project ID: PNG0712 Aniak 2018 GW Received Date: 04/02/18 11:40 Lab Sample ID: 1181296014 Matrix: Water (Surface, Eff., Ground) Lab Project ID: 1181296 Solids (%): Location: Results by Volatile GC/MS

Allowable Parameter Result Qual LOQ/CL DL Units DF Limits Date Analyzed cis-1,2-Dichloroethene 34.5 1.00 0.310 ug/L 1 04/03/18 18:48 Tetrachloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 18:48 trans-1,2-Dichloroethene 0.460 J 1.00 0.310 ug/L 1 04/03/18 18:48 Trichloroethene 124 1.00 0.310 ug/L 1 04/03/18 18:48 Vinyl chloride 0.0750 U 0.150 0.0500 ug/L 1 04/03/18 18:48

Surrogates 1,2-Dichloroethane-D4 (surr) 102 81-118 % 1 04/03/18 18:48 4-Bromofluorobenzene (surr) 102 85-114 % 1 04/03/18 18:48 Toluene-d8 (surr) 102 89-112 % 1 04/03/18 18:48

Batch Information Analytical Batch: VMS17689 Prep Batch: VXX32081 Analytical Method: SW8260C Prep Method: SW5030B Analyst: FDR Prep Date/Time: 04/03/18 00:00 Analytical Date/Time: 04/03/18 18:48 Prep Initial Wt./Vol.: 5 mL Container ID: 1181296014-A Prep Extract Vol: 5 mL

Print Date: 04/06/2018 2:20:54PM J flagging is activated 200 West Potter Drive Anchorage, AK 95518 SGS North America Inc. t 907.562.2343 f 907.561.5301 www.us.sgs.com Member of SGS Group

19 of 31 Results of 18-AWS-MW14-GW

Client Sample ID: 18-AWS-MW14-GW Collection Date: 03/30/18 17:30 Client Project ID: PNG0712 Aniak 2018 GW Received Date: 04/02/18 11:40 Lab Sample ID: 1181296015 Matrix: Water (Surface, Eff., Ground) Lab Project ID: 1181296 Solids (%): Location: Results by Volatile GC/MS

Allowable Parameter Result Qual LOQ/CL DL Units DF Limits Date Analyzed cis-1,2-Dichloroethene 0.500 U 1.00 0.310 ug/L 1 04/04/18 17:33 Tetrachloroethene 0.500 U 1.00 0.310 ug/L 1 04/04/18 17:33 trans-1,2-Dichloroethene 0.500 U 1.00 0.310 ug/L 1 04/04/18 17:33 Trichloroethene 112 1.00 0.310 ug/L 1 04/04/18 17:33 Vinyl chloride 0.0750 U 0.150 0.0500 ug/L 1 04/04/18 17:33

Surrogates 1,2-Dichloroethane-D4 (surr) 98.6 81-118 % 1 04/04/18 17:33 4-Bromofluorobenzene (surr) 97.7 85-114 % 1 04/04/18 17:33 Toluene-d8 (surr) 102 89-112 % 1 04/04/18 17:33

Batch Information Analytical Batch: VMS17691 Prep Batch: VXX32083 Analytical Method: SW8260C Prep Method: SW5030B Analyst: FDR Prep Date/Time: 04/04/18 00:00 Analytical Date/Time: 04/04/18 17:33 Prep Initial Wt./Vol.: 5 mL Container ID: 1181296015-A Prep Extract Vol: 5 mL

Print Date: 04/06/2018 2:20:54PM J flagging is activated 200 West Potter Drive Anchorage, AK 95518 SGS North America Inc. t 907.562.2343 f 907.561.5301 www.us.sgs.com Member of SGS Group

20 of 31 Results of 18-AWS-TB01-GW

Client Sample ID: 18-AWS-TB01-GW Collection Date: 03/21/18 12:00 Client Project ID: PNG0712 Aniak 2018 GW Received Date: 04/02/18 11:40 Lab Sample ID: 1181296016 Matrix: Water (Surface, Eff., Ground) Lab Project ID: 1181296 Solids (%): Location: Results by Volatile GC/MS

Allowable Parameter Result Qual LOQ/CL DL Units DF Limits Date Analyzed cis-1,2-Dichloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 12:58 Tetrachloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 12:58 trans-1,2-Dichloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 12:58 Trichloroethene 0.500 U 1.00 0.310 ug/L 1 04/03/18 12:58 Vinyl chloride 0.0750 U 0.150 0.0500 ug/L 1 04/03/18 12:58

Surrogates 1,2-Dichloroethane-D4 (surr) 98.1 81-118 % 1 04/03/18 12:58 4-Bromofluorobenzene (surr) 99.5 85-114 % 1 04/03/18 12:58 Toluene-d8 (surr) 99.5 89-112 % 1 04/03/18 12:58

Batch Information Analytical Batch: VMS17689 Prep Batch: VXX32081 Analytical Method: SW8260C Prep Method: SW5030B Analyst: FDR Prep Date/Time: 04/03/18 00:00 Analytical Date/Time: 04/03/18 12:58 Prep Initial Wt./Vol.: 5 mL Container ID: 1181296016-A Prep Extract Vol: 5 mL

Print Date: 04/06/2018 2:20:54PM J flagging is activated 200 West Potter Drive Anchorage, AK 95518 SGS North America Inc. t 907.562.2343 f 907.561.5301 www.us.sgs.com Member of SGS Group

21 of 31 Method Blank

Blank ID: MB for HBN 1778058 [VXX/32081] Matrix: Water (Surface, Eff., Ground) Blank Lab ID: 1440025

QC for Samples: 1181296001, 1181296002, 1181296003, 1181296004, 1181296005, 1181296006, 1181296007, 1181296008, 1181296009, 1181296010, 1181296011, 1181296012, 1181296013, 1181296014, 1181296016

Results by SW8260C

Parameter Results LOQ/CL DL Units cis-1,2-Dichloroethene 0.500U 1.00 0.310 ug/L Tetrachloroethene 0.500U 1.00 0.310 ug/L trans-1,2-Dichloroethene 0.500U 1.00 0.310 ug/L Trichloroethene 0.500U 1.00 0.310 ug/L Vinyl chloride 0.0750U 0.150 0.0500 ug/L Surrogates 1,2-Dichloroethane-D4 (surr) 98.1 81-118 % 4-Bromofluorobenzene (surr) 100 85-114 % Toluene-d8 (surr) 99.2 89-112 %

Batch Information

Analytical Batch: VMS17689 Prep Batch: VXX32081 Analytical Method: SW8260C Prep Method: SW5030B Instrument: VPA 780/5975 GC/MS Prep Date/Time: 4/3/2018 12:00:00AM Analyst: FDR Prep Initial Wt./Vol.: 5 mL Analytical Date/Time: 4/3/2018 11:01:00AM Prep Extract Vol: 5 mL

Print Date: 04/06/2018 2:20:56PM

200 West Potter Drive Anchorage, AK 95518 SGS North America Inc. t 907.562.2343 f 907.561.5301 www.us.sgs.com Member of SGS Group

22 of 31 Blank Spike Summary Blank Spike ID: LCS for HBN 1181296 [VXX32081] Spike Duplicate ID: LCSD for HBN 1181296 Blank Spike Lab ID: 1440026 [VXX32081] Date Analyzed: 04/03/2018 11:18 Spike Duplicate Lab ID: 1440027 Matrix: Water (Surface, Eff., Ground)

QC for Samples: 1181296001, 1181296002, 1181296003, 1181296004, 1181296005, 1181296006, 1181296007, 1181296008, 1181296009, 1181296010, 1181296011, 1181296012, 1181296013, 1181296014, 1181296016 Results by SW8260C

Blank Spike (ug/L) Spike Duplicate (ug/L) Parameter Spike Result Rec (%) Spike Result Rec (%) CL RPD (%) RPD CL cis-1,2-Dichloroethene 30 30.1 100 30 29.5 98 ( 78-123 ) 1.90 (< 20 ) Tetrachloroethene 30 30.3 101 30 29.6 99 ( 74-129 ) 2.30 (< 20 ) trans-1,2-Dichloroethene 30 30.1 100 30 29.4 98 ( 75-124 ) 2.30 (< 20 ) Trichloroethene 30 30.5 102 30 29.8 99 ( 79-123 ) 2.40 (< 20 ) Vinyl chloride 30 30.6 102 30 29.4 98 ( 58-137 ) 3.90 (< 20 )

Surrogates 1,2-Dichloroethane-D4 (surr) 30 93.8 94 30 94.1 94 ( 81-118 ) 0.35 4-Bromofluorobenzene (surr) 30 99 99 30 99.5 100 ( 85-114 ) 0.44 Toluene-d8 (surr) 30 97.8 98 30 97.7 98 ( 89-112 ) 0.07

Batch Information

Analytical Batch: VMS17689 Prep Batch: VXX32081 Analytical Method: SW8260C Prep Method: SW5030B Instrument: VPA 780/5975 GC/MS Prep Date/Time: 04/03/2018 00:00 Analyst: FDR Spike Init Wt./Vol.: 30 ug/L Extract Vol: 5 mL Dupe Init Wt./Vol.: 30 ug/L Extract Vol: 5 mL

Print Date: 04/06/2018 2:20:59PM

200 West Potter Drive Anchorage, AK 95518 SGS North America Inc. t 907.562.2343 f 907.561.5301 www.us.sgs.com Member of SGS Group

23 of 31 Method Blank

Blank ID: MB for HBN 1778104 [VXX/32083] Matrix: Water (Surface, Eff., Ground) Blank Lab ID: 1440201

QC for Samples: 1181296015

Results by SW8260C

Parameter Results LOQ/CL DL Units cis-1,2-Dichloroethene 0.500U 1.00 0.310 ug/L Tetrachloroethene 0.500U 1.00 0.310 ug/L trans-1,2-Dichloroethene 0.500U 1.00 0.310 ug/L Trichloroethene 0.500U 1.00 0.310 ug/L Vinyl chloride 0.0750U 0.150 0.0500 ug/L Surrogates 1,2-Dichloroethane-D4 (surr) 100 81-118 % 4-Bromofluorobenzene (surr) 102 85-114 % Toluene-d8 (surr) 104 89-112 %

Batch Information

Analytical Batch: VMS17691 Prep Batch: VXX32083 Analytical Method: SW8260C Prep Method: SW5030B Instrument: VSA Agilent GC/MS 7890B/5977A Prep Date/Time: 4/4/2018 12:00:00AM Analyst: FDR Prep Initial Wt./Vol.: 5 mL Analytical Date/Time: 4/4/2018 12:34:00PM Prep Extract Vol: 5 mL

Print Date: 04/06/2018 2:21:01PM

200 West Potter Drive Anchorage, AK 95518 SGS North America Inc. t 907.562.2343 f 907.561.5301 www.us.sgs.com Member of SGS Group

24 of 31 Leaching Blank

Blank ID: LB for HBN 1778054 [TCLP/9317] Matrix: Water (Surface, Eff., Ground) Blank Lab ID: 1440011

QC for Samples: 1181296015

Results by SW8260C

Parameter Results LOQ/CL DL Units Tetrachloroethene 25.0U 50.0 15.5 ug/L Trichloroethene 25.0U 50.0 15.5 ug/L Vinyl chloride 3.75U 7.50 2.50 ug/L Surrogates 1,2-Dichloroethane-D4 (surr) 108 81-118 % 4-Bromofluorobenzene (surr) 101 85-114 % Toluene-d8 (surr) 102 89-112 %

Batch Information

Analytical Batch: VMS17691 Prep Batch: VXX32083 Analytical Method: SW8260C Prep Method: SW5030B Instrument: VSA Agilent GC/MS 7890B/5977A Prep Date/Time: 4/4/2018 12:00:00AM Analyst: FDR Prep Initial Wt./Vol.: 5 mL Analytical Date/Time: 4/4/2018 6:38:00PM Prep Extract Vol: 5 mL

Print Date: 04/06/2018 2:21:01PM

200 West Potter Drive Anchorage, AK 95518 SGS North America Inc. t 907.562.2343 f 907.561.5301 www.us.sgs.com Member of SGS Group

25 of 31 Blank Spike Summary Blank Spike ID: LCS for HBN 1181296 [VXX32083] Spike Duplicate ID: LCSD for HBN 1181296 Blank Spike Lab ID: 1440202 [VXX32083] Date Analyzed: 04/04/2018 13:10 Spike Duplicate Lab ID: 1440203 Matrix: Water (Surface, Eff., Ground)

QC for Samples: 1181296015

Results by SW8260C

Blank Spike (ug/L) Spike Duplicate (ug/L) Parameter Spike Result Rec (%) Spike Result Rec (%) CL RPD (%) RPD CL cis-1,2-Dichloroethene 30 27.6 92 30 27.4 91 ( 78-123 ) 0.84 (< 20 ) Tetrachloroethene 30 33.2 111 30 33.5 112 ( 74-129 ) 0.66 (< 20 ) trans-1,2-Dichloroethene 30 28.2 94 30 28.3 94 ( 75-124 ) 0.25 (< 20 ) Trichloroethene 30 29.3 98 30 29.6 99 ( 79-123 ) 0.95 (< 20 ) Vinyl chloride 30 31.1 104 30 30.1 100 ( 58-137 ) 3.20 (< 20 )

Surrogates 1,2-Dichloroethane-D4 (surr) 30 98.2 98 30 99.5 100 ( 81-118 ) 1.40 4-Bromofluorobenzene (surr) 30 97.4 97 30 97.5 98 ( 85-114 ) 0.10 Toluene-d8 (surr) 30 105 105 30 105 105 ( 89-112 ) 0.29

Batch Information

Analytical Batch: VMS17691 Prep Batch: VXX32083 Analytical Method: SW8260C Prep Method: SW5030B Instrument: VSA Agilent GC/MS 7890B/5977A Prep Date/Time: 04/04/2018 00:00 Analyst: FDR Spike Init Wt./Vol.: 30 ug/L Extract Vol: 5 mL Dupe Init Wt./Vol.: 30 ug/L Extract Vol: 5 mL

Print Date: 04/06/2018 2:21:03PM

200 West Potter Drive Anchorage, AK 95518 SGS North America Inc. t 907.562.2343 f 907.561.5301 www.us.sgs.com Member of SGS Group

26 of 31 27 of 31 28 of 31 e-Sample Receipt Form SGS Workorder #: 1181296 1181296 Review Criteria Condition (Yes, No, N/A) Exceptions Noted below Chain of Custody / Temperature Requirements n/a Exemption permitted if sampler hand carries/delivers. Were Custody Seals intact? Note # & location yes 1F, 1L COC accompanied samples? yes n/a **Exemption permitted if chilled & collected <8 hours ago, or for samples where chilling is not required yes Cooler ID: 1 @ 0.2 °C Therm. ID: D41 n/a Cooler ID: @ °C Therm. ID: Temperature blank compliant* (i.e., 0-6 °C after CF)? n/a Cooler ID: @ °C Therm. ID: n/a Cooler ID: @ °C Therm. ID: n/a Cooler ID: @ °C Therm. ID: *If >6°C, were samples collected <8 hours ago? n/a

If <0°C, were sample containers ice free? n/a

If samples received without a temperature blank, the "cooler temperature" will be documented in lieu of the temperature blank & "COOLER TEMP" will be noted to the right. In cases where neither a temp blank nor cooler temp can be obtained, note "ambient" or "chilled".

Note: Identify containers received at non-compliant temperature . Use form FS-0029 if more space is needed.

Holding Time / Documentation / Sample Condition Requirements Note: Refer to form F-083 "Sample Guide" for specific holding times. Were samples received within holding time? yes

Do samples match COC** (i.e.,sample IDs,dates/times collected)? yes **Note: If times differ <1hr, record details & login per COC. Were analyses requested unambiguous? (i.e., method is specified for yes analyses with >1 option for analysis)

n/a ***Exemption permitted for metals (e.g,200.8/6020A). Were proper containers (type/mass/volume/preservative***)used? yes Volatile / LL-Hg Requirements Were Trip Blanks (i.e., VOAs, LL-Hg) in cooler with samples? yes Were all water VOA vials free of headspace (i.e., bubbles ≤ 6mm)? yes Were all soil VOAs field extracted with MeOH+BFB? n/a Note to Client: Any "No", answer above indicates non-compliance with standard procedures and may impact data quality.

Additional notes (if applicable):

F102b_SRFpm_2017013129 of 31 SGS logo new.gif

Sample Containers and Preservatives

Container Id Preservative Container Container Id Preservative Container Condition Condition

1181296001-A HCL to pH < 2 OK 1181296015-A HCL to pH < 2 OK 1181296001-B HCL to pH < 2 OK 1181296015-B HCL to pH < 2 OK 1181296001-C HCL to pH < 2 OK 1181296015-C HCL to pH < 2 OK 1181296002-A HCL to pH < 2 OK 1181296016-A HCL to pH < 2 OK 1181296002-B HCL to pH < 2 OK 1181296016-B HCL to pH < 2 OK 1181296002-C HCL to pH < 2 OK 1181296016-C HCL to pH < 2 OK 1181296003-A HCL to pH < 2 OK 1181296003-B HCL to pH < 2 OK 1181296003-C HCL to pH < 2 OK 1181296004-A HCL to pH < 2 OK 1181296004-B HCL to pH < 2 OK 1181296004-C HCL to pH < 2 OK 1181296005-A HCL to pH < 2 OK 1181296005-B HCL to pH < 2 OK 1181296005-C HCL to pH < 2 OK 1181296006-A HCL to pH < 2 OK 1181296006-B HCL to pH < 2 OK 1181296006-C HCL to pH < 2 OK 1181296007-A HCL to pH < 2 OK 1181296007-B HCL to pH < 2 OK 1181296007-C HCL to pH < 2 OK 1181296008-A HCL to pH < 2 OK 1181296008-B HCL to pH < 2 OK 1181296008-C HCL to pH < 2 OK 1181296009-A HCL to pH < 2 OK 1181296009-B HCL to pH < 2 OK 1181296009-C HCL to pH < 2 OK 1181296010-A HCL to pH < 2 OK 1181296010-B HCL to pH < 2 OK 1181296010-C HCL to pH < 2 OK 1181296011-A HCL to pH < 2 OK 1181296011-B HCL to pH < 2 OK 1181296011-C HCL to pH < 2 OK 1181296012-A HCL to pH < 2 OK 1181296012-B HCL to pH < 2 OK 1181296012-C HCL to pH < 2 OK 1181296013-A HCL to pH < 2 OK 1181296013-B HCL to pH < 2 OK 1181296013-C HCL to pH < 2 OK 1181296014-A HCL to pH < 2 OK 1181296014-B HCL to pH < 2 OK 1181296014-C HCL to pH < 2 OK

4/2/2018 30 of 31 Container Id Preservative Container Container Id Preservative Container Condition Condition

Container Condition Glossary Containers for bacteriological, low level mercury and VOA vials are not opened prior to analysis and will be assigned condition code OK unless evidence indicates than an inappropriate container was submitted.

OK - The container was received at an acceptable pH for the analysis requested. BU - The container was received with headspace greater than 6mm. DM - The container was received damaged. FR - The container was received frozen and not usable for Bacteria or BOD analyses. IC - The container provided for microbiology analysis was not a laboratory-supplied, pre-sterilized container and therefore was not suitable for analysis. PA - The container was received outside of the acceptable pH for the analysis requested. Preservative was added upon receipt and the container is now at the correct pH. See the Sample Receipt Form for details on the amount and lot # of the preservative added. PH - The container was received outside of the acceptable pH for the analysis requested. Preservative was added upon receipt, but was insufficient to bring the container to the correct pH for the analysis requested. See the Sample Receipt Form for details on the amount and lot # of the preservative added.

4/2/2018 31 of 31 March 2018 Groundwater Results, Aniak WACS 10 December 2018 Page 8

ATTACHMENT 3

DATA VALIDATION REPORT

Aniak_March2018_GW_TechMemo_120718

180A Market Place Boulevard Knoxville, TN 37922 PH 865.330.0037 www.geosyntec.com

Memorandum

Date: 27 April 2018 To: Ben Martich From: Chris Pracheil CC: J. Caprio

Subject: Stage 2A Data Validation – Level II Data Deliverable – #1181296

SITE: Former WACS Site / Joe Parent Vocational Education Center, Aniak, Alaska

INTRODUCTION

This report summarizes the findings of the Stage 2A data validation of thirteen groundwater samples, two field duplicates and one trip blank, collected from March 29-30, 2017, as part of the Former WACS Site / Joe Parent Vocational Education Center, Aniak, Alaska sampling event. All analyses were performed by SGS North America Inc., Anchorage, Alaska (SGS Anchorage). The samples were analyzed for the following test:

• Volatile Organic Compounds (VOCs) by EPA Methods 5030B/8260C

EXECUTIVE SUMMARY

The samples were handled, prepared, and measured in the same manner under similar prescribed conditions.

Overall, based on this Stage 2A data validation covering the quality control (QC) parameters listed below, the data are usable for meeting project objectives.

The data were reviewed based on the following: Trichloroethene Remedial Investigation and Feasibility Study Work Plan (herein referred to as the RIFS), Former WACS Site / Joe Parent Vocational Education Center, Aniak, Alaska, August 2016, the USEPA Contract Laboratory Program National Functional Guidelines for Organic Superfund Methods Data Review, January 2017 (USEPA-540-R-2017-002) and the pertinent methods referenced by the data packages and professional and technical judgment.

The following samples were analyzed and validated at a Stage 2A level in the data set:

Former WACS/Joe Parent Vocational Education Center 1181296 DVR Final Review: JK Caprio 5/9/18 Former WACS Site / Joe Parent Vocational Education Center 27 April 2018 Page 2

Laboratory Client ID Laboratory Client ID ID ID 1181296001 18-AWS-MW12-GW 1181296009 18-AWS-MW1-GW 1181296002 18-AWS-MW6-GW 1181296010 18-AWS-MW8-GW 1181296003 18-AWS-MW18-GW 1181296011 18-AWS-MW17-GW 1181296004 18-AWS-MW02-GW 1181296012 18-AWS-MW11-GW 1181296005 18-AWS-MW15-GW 1181296013 18-AWS-MW10-GW 1181296006 18-AWS-MW09-GW 1181296014 18-AWS-MW13-GW 1181296007 18-AWS-MW16-GW 1181296015 18-AWS-MW14-GW 1181296008 18-AWS-MW7-GW 1181296016 18-AWS-TB01-GW

The samples were received at the laboratories within the temperature criteria of 4+2oC and in good condition. Incorrect error correction was observed on the chain of custody, instead of a single strike through initialed and dated, this did not result in any data qualifications.

1.0 VOLATILE ORGANIC COMPOUNDS

The samples were analyzed for VOCs per EPA Methods 5030B/8260C.

The areas of data review are listed below. A leading check mark () indicates an area of review in which the data were acceptable. A preceding crossed circle (⊗) signifies areas where issues were raised during the course of the validation review and should be considered to determine the impact on data quality and usability.

 Overall Assessment  Holding Times  Method Blank  Matrix Spike  Laboratory Control Sample  Trip Blank  Surrogates  Field Duplicate  Sensitivity  Electronic Data Deliverable Review

1.1 Overall Assessment

The VOC data reported in this package are considered usable for meeting project objectives. The analytical completeness, defined as the ratio of the number of valid analytical results (valid analytical results include values qualified as estimated) to the total number of analytical results requested on samples submitted for analysis, for the data set is 100%.

Former WACS/Joe Parent Vocational Education Center 1181296 DVR Final Review: JK Caprio 5/9/18

Former WACS Site / Joe Parent Vocational Education Center 27 April 2018 Page 3

1.2 Holding Times

The holding time for VOC analysis of preserved water samples is 14 days from collection to analysis. The holding times were met for the sample analyses.

1.3 Method Blank

Method blanks were analyzed at the proper frequency for the number and types of samples analyzed (one per batch of 20 samples). Two method blanks were reported (batches VXX32081 and VXX32083). VOCs were not detected in the method blanks above the limits of detection (LODs).

1.4 Matrix Spike (MS)

MSs were not reported for the VOC analysis.

1.5 Laboratory Control Sample (LCS)/ Laboratory Control Sample Duplicate (LCSD)

LCS/LCSDs were analyzed at the proper frequency for the number and types of samples analyzed (one per batch of 20 samples). Two LCS/LCS duplicate (LCSD) pairs were reported. The recovery and RPD results were within the laboratory specified acceptance criteria.

1.6 Trip Blank

One trip blank, 18-AWS-TB01-GW was submitted with the sample set. VOCs were not detected in the trip blank above the LODs.

1.7 Surrogates

Acceptable surrogate recoveries were reported for the samples.

1.8 Field Duplicate

Two field duplicate samples, 18-AWS-MW1-GW and 18-AWS-MW02-GW were collected with the sample set. Acceptable precision (RPD <30% for water samples) was demonstrated between the field duplicates and the original samples, 18-AWS-MW7-GW and 18-AWS-MW18-GW, respectively.

1.9 Sensitivity

The samples were reported to the LODs. No elevated non-detect results were reported.

Former WACS/Joe Parent Vocational Education Center 1181296 DVR Final Review: JK Caprio 5/9/18

Former WACS Site / Joe Parent Vocational Education Center 27 April 2018 Page 4

1.10 Electronic Data Deliverable (EDD) Review

The results and sample identifications (IDs) in the EDD were reviewed against the information provided by the associated level II report at a minimum of 20% as part of the data validation process. The detection limits are listed as LODs and limits of quantitation (LOQs) in the EDDs and are listed as method detection limits (MDLs) and method reporting limits (MRLs) in the laboratory reports, this discrepancy did not impact the data. No other discrepancies were identified between the level II report and the EDD.

* * * * *

Former WACS/Joe Parent Vocational Education Center 1181296 DVR Final Review: JK Caprio 5/9/18

Former WACS Site / Joe Parent Vocational Education Center 27 April 2018 Page 5

ATTACHMENT 1 DATA VALIDATION QUALIFIER DEFINITIONS AND INTERPRETATION KEY Assigned by Geosyntec’s Data Validation Team

DATA QUALIFIER DEFINITIONS U The analyte was analyzed for, but was not detected above the reported sample quantitation limit.

J The analyte was positively identified; the associated numerical value is the approximate concentration of the analyte in the sample.

J+ The analyte was positively identified; however, the associated numerical value is likely to be higher than the concentration of the analyte in the sample due to positive bias of associated QC or calibration data or attributable to matrix interference.

J- The analyte was positively identified; however, the associated numerical value is likely to be lower than the concentration of the analyte in the sample due to negative bias of associated QC or calibration data or attributable to matrix interference.

UJ The analyte was not detected above the reported sample quantitation limit. However, the reported quantitation limit is approximate and may or may not represent the actual limit of quantitation necessary to accurately and precisely measure the analyte in the sample.

R The sample results are rejected due to serious deficiencies in the ability to analyze the sample and meet quality control criteria. The presence or absence of the analyte cannot be verified.

Former WACS/Joe Parent Vocational Education Center 1181296 DVR Final Review: JK Caprio 5/9/18

Former WACS Site / Joe Parent Vocational Education Center 27 April 2018 Page 6

ATTACHMENT 2 DATA VALIDATION REASON CODES Assigned by Geosyntec’s Data Validation Team

Valid Value Description 1 Preservation requirement not met 2 Analysis holding time exceeded 3 Blank contamination (i.e., method, trip, equipment, etc.) 4 Matrix spike/matrix spike duplicate recovery or RPD outside limits 5 LCS or RPD recovery outside limits (LCS/LCSD) 6 Surrogate recovery outside limits 7 Field Duplicate RPD exceeded 8 Serial dilution percent difference exceeded 9 Calibration criteria not met 10 Linear range exceeded 11 Internal standard criteria not met 12 Lab duplicates RPD exceeded 13 Other

Former WACS/Joe Parent Vocational Education Center 1181296 DVR Final Review: JK Caprio 5/9/18

Laboratory Data Review Checklist

Completed By:

Chris Pracheil

Title:

Senior Staff Scientist

Date:

04/27/2018

CS Report Name:

Aniak / PNG0712

Report Date:

04/06/2018

Consultant Firm:

Geosyntec Consultants

Laboratory Name:

SGS North America Inc. Anchorage, Alaska

Laboratory Report Number:

1181296

ADEC File Number:

Hazard Identification Number:

July 2017 Page 1

1181296

1. Laboratory

a. Did an ADEC CS approved laboratory receive and perform all of the submitted sample analyses?

b. If the samples were transferred to another “network” laboratory or sub-contracted to an alternate laboratory, was the laboratory performing the analyses ADEC CS approved?

NA, the samples were not transferred to another laboratory

2. Chain of Custody (CoC)

a. CoC information completed, signed, and dated (including released/received by)?

b. Correct Analyses requested?

3. Laboratory Sample Receipt Documentation

a. Sample/cooler temperature documented and within range at receipt (0° to 6° C)?

b. Sample preservation acceptable – acidified waters, Methanol preserved VOC soil (GRO, BTEX, Volatile Chlorinated Solvents, etc.)?

c. Sample condition documented – broken, leaking (Methanol), zero headspace (VOC vials)?

July 2017 Page 2

1181296

d. If there were any discrepancies, were they documented? For example, incorrect sample containers/preservation, sample temperature outside of acceptable range, insufficient or missing samples, etc.?

The laboratory provided a completed sample receipt form to document discrepancies, though there were no discrepancies with the sample set.

e. Data quality or usability affected? Comments:

No

4. Case Narrative

a. Present and understandable?

b. Discrepancies, errors, or QC failures identified by the lab?

c. Were all corrective actions documented?

No corrective actions were required.

d. What is the effect on data quality/usability according to the case narrative? Comments:

None

5. Samples Results

a. Correct analyses performed/reported as requested on COC?

b. All applicable holding times met?

July 2017 Page 3

1181296

c. All soils reported on a dry weight basis?

NA

d. Are the reported LOQs less than the Cleanup Level or the minimum required detection level for the project?

e. Data quality or usability affected?

6. QC Samples

a. Method Blank i. One method blank reported per matrix, analysis and 20 samples?

ii. All method blank results less than limit of quantitation (LOQ)?

iii. If above LOQ, what samples are affected? Comments:

iv. Do the affected sample(s) have data flags? If so, are the data flags clearly defined?

NA

v. Data quality or usability affected? Comments:

No

July 2017 Page 4

1181296

b. Laboratory Control Sample/Duplicate (LCS/LCSD) i. Organics – One LCS/LCSD reported per matrix, analysis and 20 samples? (LCS/LCSD required per AK methods, LCS required per SW846)

ii. Metals/Inorganics – one LCS and one sample duplicate reported per matrix, analysis and 20 samples?

NA

iii. Accuracy – All percent recoveries (%R) reported and within method or laboratory limits? And project specified DQOs, if applicable. (AK Petroleum methods: AK101 60%-120%, AK102 75%-125%, AK103 60%-120%; all other analyses see the laboratory QC pages)

iv. Precision – All relative percent differences (RPD) reported and less than method or laboratory limits? And project specified DQOs, if applicable. RPD reported from LCS/LCSD, MS/MSD, and or sample/sample duplicate. (AK Petroleum methods 20%; all other analyses see the laboratory QC pages)

v. If %R or RPD is outside of acceptable limits, what samples are affected? Comments:

NA

vi. Do the affected sample(s) have data flags? If so, are the data flags clearly defined?

NA

vii. Data quality or usability affected? (Use comment box to explain.) Comments:

No

July 2017 Page 5

1181296

c. Surrogates – Organics Only i. Are surrogate recoveries reported for organic analyses – field, QC and laboratory samples?

ii. Accuracy – All percent recoveries (%R) reported and within method or laboratory limits? And project specified DQOs, if applicable. (AK Petroleum methods 50-150 %R; all other analyses see the laboratory report pages)

iii. Do the sample results with failed surrogate recoveries have data flags? If so, are the data flags clearly defined?

NA

iv. Data quality or usability affected? Comments:

No

d. Trip blank – Volatile analyses only (GRO, BTEX, Volatile Chlorinated Solvents, etc.): Water and Soil i. One trip blank reported per matrix, analysis and for each cooler containing volatile samples? (If not, enter explanation below.)

ii. Is the cooler used to transport the trip blank and VOA samples clearly indicated on the COC? (If not, a comment explaining why must be entered below)

iii. All results less than LOQ?

July 2017 Page 6

1181296

iv. If above LOQ, what samples are affected? Comments:

NA

v. Data quality or usability affected? Comments:

No

e. Field Duplicate i. One field duplicate submitted per matrix, analysis and 10 project samples?

ii. Submitted blind to lab?

iii. Precision – All relative percent differences (RPD) less than specified DQOs? (Recommended: 30% water, 50% soil) RPD (%) = Absolute value of: (R1-R2) x 100 ((R1+R2)/2)

Where R1 = Sample Concentration R2 = Field Duplicate Concentration

iv. Data quality or usability affected? (Use the comment box to explain why or why not.) Comments:

No

f. Decontamination or Equipment Blank (If not applicable, a comment stating why must be entered below).

July 2017 Page 7

1181296

i. All results less than LOQ?

NA

ii. If above LOQ, what samples are affected? Comments:

NA

iii. Data quality or usability affected? Comments:

No

7. Other Data Flags/Qualifiers (ACOE, AFCEE, Lab Specific, etc.)

a. Defined and appropriate?

July 2017 Page 8

APPENDIX B Remedial Response Action Alternatives Cost Estimates

Final FS Report March 2019 APPENDIX B Geosyntec Consultants COST SUMMARY TABLE Former WACS Site and JPVEC, Aniak, Alaska

Unsaturated Zone Saturated Zone Total Cost Alternative Name Technology Cost Technology Cost Estimated Cost -30% 50% 1 No Action NA $0 NA $0 $0 $0 $0 2 ICs and ECs ICs/ECs $2,700,000 ICs/ECs $430,000 $3,130,000 $2,191,000 $4,695,000 3 SVE with ICs and ECs SVE $2,100,000 ICs/ECs $430,000 $2,530,000 $1,771,000 $3,795,000 4 LTGM with ICs and ECs ICs/ECs $2,700,000 LTGM $770,000 $3,470,000 $2,429,000 $5,205,000 5 SVE and LTGM with ICs and ECs SVE $2,100,000 LTGM $770,000 $2,870,000 $2,009,000 $4,305,000 6 Excavation and LTGM with ICs and ECs Excavation $12,400,000 LTGM $770,000 $13,170,000 $9,219,000 $19,755,000

Notes: EC = Engineering Control IC = Institutional Control LTGM = Long-Term Groundwater Monitoring NA = Not Applicable SVE = Soil Vapor Extraction

Cost details provided in the following tables: Table B-1 Unsaturated Zone - Institutional and Engineering Controls Table B-2 Unsaturated Zone - Targeted SVE with ICs and ECs Table B-3 Unsaturated Zone - Excavation with ICs and ECs Table B-4 Saturated Zone - Institutional and Engineering Controls Table B-5 Saturated Zone - Long-Term Groundwater Monitoring with ICs and ECs

Page 1 of 1 Geosyntec Consultants TABLE B-1 COST ESTIMATE FOR UNSATURATED ZONE INSTITUTIONAL AND ENGINEERING CONTROLS Former WACS Site and JPVEC, Aniak, Alaska

ICs and ECs

Design/Cost Basis Estimated Years of SSD Operation 30 Number of Monitoring Events per Year 3 Number of Air Samples Collected per Monitoring Event 10 Costs Item Unit Unit Cost Unit Qty Total Cost

CAPITAL COSTS Institutional Controls Land Use Covenant Negotations lump sum $10,000 1 $ 10,000 Site Management Plan (SMP) lump sum $5,000 1 $ 5,000 Project Management % costs 15% 15,000 $ 2,250

CAPITAL COSTS TOTAL $ 17,250 OPERATION, MAINTENANCE, & MONITORING (OM&M) COSTS SSD Operations, Monitoring, & Maintenance Costs (Years 1 - 30) Annual SSD System Operation Costs Operating and Maintenance Cost month $2,000 12 $ 24,000 Project Management % costs 15% 24,000 $ 3,600

Annual SSD Performance Monitoring Costs Air Sampling - Collection event $5,000 3 $ 15,000 Air Analytical - VOCs sample $90 30 $ 2,700 Sample Shipping & Handling event $500 3 $ 1,500 Geosyntec Site Travel Costs (Airfare + Time) lump sum $3,800 3 $ 11,400 Site Costs (Lodging, Truck Rental, Per diem) day $700 12 $ 8,400 Data Processing/Data Validation event $2,000 4 $ 8,000 Field Equipment Rental week $300 3 $ 900 Miscellaneous Field Supplies event $100 3 $ 300 Project Management % costs 15% 48,200 $ 7,230

SSD Performance Monitoring Evaluation & Reporting Performance Evaluation Reports (Every 5 years) report $8,000 6 $ 48,000 Project Management % costs 15% 48,000 $ 7,200

SSD OM&M Annual Subtotal $ 84,870 SSD OM&M (Years 1 - 30) Subtotal $ 2,546,100

Page 1 of 2 Geosyntec Consultants TABLE B-1 COST ESTIMATE FOR UNSATURATED ZONE INSTITUTIONAL AND ENGINEERING CONTROLS Former WACS Site and JPVEC, Aniak, Alaska

SDD Shutdown and Closure Costs (Year 30) SSD Shutdown Monitoring, Evaluation, & Reporting Air Sampling - Collection event $5,000 1 $ 5,000 Air Analytical - VOCs sample $90 10 $ 900 Sample Shipping & Handling event $500 1 $ 500 Geosyntec Site Travel Costs (Airfare + Time) lump sum $3,800 1 $ 3,800 Site Costs (Lodging, Truck Rental, Per diem) day $700 4 $ 2,800 Field Equipment Rental week $300 1 $ 300 Miscellaneous Field Supplies event $100 1 $ 100 Rebound Data Evaluation & Closure Reporting lump sum $33,000 1 $ 33,000 Project Management % costs 15% 46,400 $ 6,960

SSD Shutdown/Closure (Year 30) Subtotal $ 53,360

OM&M COSTS TOTAL $ 2,599,460 TOTAL COSTS $ 2,700,000 TOTAL COSTS (-30%) $ 1,890,000 TOTAL COSTS (+50%) $ 4,050,000

Notes / Assumptions: Costs are estimated using 2018 dollars. Cost estimates were based on Geosyntec's experience at similar sites and working in rural Alaska, as well as subcontractor and vendor quotes. Costs assume operations and monitoring for the time frames listed above. System demolition and well decommissioning costs are not included as these costs are likely similar for all remedial alternatives. Costs savings associated with combining the land use covenent and the SMP with the unsaturated zone and/or the polychlorinated biphenyl (PCB) cleanup are not included. Electricity costs are included in operation costs. SMP - Site Management Plan SSD - Sub-slab depressurization VOCs - Volatile organic compounds

Page 2 of 2 Geosyntec Consultants TABLE B-2 COST ESTIMATE FOR UNSATURATED ZONE TARGETED SVE WITH INSTITUTIONAL AND ENGINEERING CONTROLS Former WACS Site and JPVEC, Aniak, Alaska

Targeted SVE with ICs and ECs Design/Cost Basis SVE System Cost Assumptions: Focused Area for Treatment (square feet) 15,000 Total Depth of Focused Area for Treatment (feet) 20 SVE Well ROI (feet) 30 Number of SVE Wells Installed 5 Number of Baseline Soil Samples 10 Number of Proposed Vapor Monitoring Points for Installation 10 Estimated Years of SVE Operation 8 Number of SVE Monitoring Events per Year 3 Number of Samples Collected per SVE Monitoring Event 8 Years of Post-Shutdown Monitoring 3 SSD System Cost Assumptions: Estimated Years of SSD Operation 10 Number of SSD Monitoring Events per Year 3 Number of Air Samples Collected per SSD Monitoring Event 10 Years of Post-Shutdown Monitoring 3 Costs Item Unit Unit Cost Unit Qty Total Cost

CAPITAL COSTS Detailed SVE Design Detailed Design lump sum $55,000 1 $ 55,000 Regulatory Negotiations lump sum $10,000 1 $ 10,000 Project Management % cost 15% 65,000 $ 9,750

Preparation Field Preparation lump sum $10,000 1 $ 10,000 Utility Clearance lump sum $5,000 1 $ 5,000 Project Management % costs 15% 15,000 $ 2,250

Baseline & Design Sampling Soil Sampling - Collection boring $600 10 $ 6,000 Soil Analytical - VOCs sample $90 10 $ 900 Air Sampling - Collection event $5,000 1 $ 5,000 Air Analytical - VOCs sample $90 10 $ 900 Sample Shipping & Handling event $500 1 $ 500 Geosyntec Site Travel Costs (Airfare + Time) lump sum $3,800 1 $ 3,800 Site Costs (Lodging, Truck Rental, Per diem) day $700 7 $ 4,900 Data Processing/Data Validation event $2,000 1 $ 2,000 Field Equipment Rental week $300 1 $ 300 Miscellaneous Field Supplies event $500 1 $ 500 Project Management % costs 15% 24,800 $ 3,720

Page 1 of 4 Geosyntec Consultants TABLE B-2 COST ESTIMATE FOR UNSATURATED ZONE TARGETED SVE WITH INSTITUTIONAL AND ENGINEERING CONTROLS Former WACS Site and JPVEC, Aniak, Alaska

Drilling Services Drill Rig Mob/Demob to Site lump sum $66,000 1 $ 66,000 Drill Rig + Crew day $4,200 7 $ 29,400 Vapor Monitoring Point Installation point $5,000 10 $ 50,000 SVE Well Installation well $5,000 5 $ 25,000 Permits well $250 5 $ 1,250 Miscellaneous Field Supplies event $1,000 1 $ 1,000 Waste Management and Disposal drum $1,400 15 $ 21,000 Well Construction Log Creation well $500 5 $ 2,500 Project Management % costs 15% 196,150 $ 29,423

SVE System Installation Installation Activities week $20,000 1 $ 20,000 Conveyance Piping ft $20 1500 $ 30,000 Conveyance Piping Installation day $2,800 5 $ 14,000 Electrician lump sum $25,000 1 $ 25,000 Miscellaneous Field Supplies week $500 1 $ 500 Project Management % costs 15% 89,500 $ 13,425

Institutional Controls Land Use Covenant Negotations lump sum $10,000 1 $ 10,000 Site Management Plan (SMP) lump sum $5,000 1 $ 5,000 Project Management % costs 15% 15,000 $ 2,250

CAPITAL COSTS TOTAL $ 466,268 OPERATION, MAINTENANCE, & MONITORING (OM&M) COSTS SSD Operations, Monitoring, & Maintenance Costs (Years 1 - 10) Annual SSD System Operation Costs Operating and Maintenance Cost month $2,000 12 $ 24,000 Project Management % costs 15% 24,000 $ 3,600

Annual SSD Performance Monitoring Costs Air Sampling - Collection event $5,000 3 $ 15,000 Air Analytical - VOCs sample $90 30 $ 2,700 Sample Shipping & Handling event $500 3 $ 1,500 Geosyntec Site Travel Costs (Airfare + Time) lump sum $3,800 3 $ 11,400 Site Costs (Lodging, Truck Rental, Per diem) day $700 12 $ 8,400 Data Processing/Data Validation event $2,000 3 $ 6,000 Field Equipment Rental week $300 3 $ 900 Miscellaneous Field Supplies event $100 3 $ 300 Project Management % costs 15% 46,200 $ 6,930

SSD Performance Monitoring Evaluation & Reporting Performance Evaluation Reports (Every 5 years) report $8,000 2 $ 16,000 Project Management % costs 15% 16,000 $ 2,400

SSD OM&M Annual Subtotal $ 82,570 SSD OM&M (Years 1 - 10) Subtotal $ 825,700

Page 2 of 4 Geosyntec Consultants TABLE B-2 COST ESTIMATE FOR UNSATURATED ZONE TARGETED SVE WITH INSTITUTIONAL AND ENGINEERING CONTROLS Former WACS Site and JPVEC, Aniak, Alaska

SVE Operations, Monitoring, & Maintenance Costs (Years 1 - 8) Annual SVE System Operation Costs Operating and Maintenance Cost month $2,000 6 $ 12,000 Project Management % costs 15% 12,000 $ 1,800

Annual SVE Performance Monitoring Costs Air Sampling - Collection event $5,000 3 $ 15,000 Air Analytical - VOCs sample $90 192 $ 17,280 Sample Shipping & Handling event $500 24 $ 12,000 Data Processing/Data Validation event $2,000 3 $ 6,000 Field Equipment Rental week $300 3 $ 900 Miscellaneous Field Supplies event $100 3 $ 300 Project Management % costs 15% 51,480 $ 7,722

SVE Performance Monitoring Evaluation & Reporting Performance Evaluation Reports (Every 5 years) report $8,000 1 $ 8,000 Project Management % costs 15% 8,000 $ 1,200

SVE OM&M Annual Subtotal $ 74,152 SVE OM&M (Years 1 - 8) Subtotal $ 593,216

SVE Shutdown Monitoring Costs (Years 9 - 11) Annual SVE System Shutdown Monitoring Costs Air Sampling - Collection event $1,250 1 $ 1,250 Air Analytical - VOCs sample $90 8 $ 720 Sample Shipping & Handling event $500 8 $ 4,000 Geosyntec Site Travel Costs (Airfare + Time) lump sum $3,800 1 $ 3,800 Site Costs (Lodging, Truck Rental, Per diem) day $700 3 $ 2,100 Data Processing/Data Validation event $2,000 1 $ 2,000 Field Equipment Rental week $300 1 $ 300 Miscellaneous Field Supplies event $100 1 $ 100 Project Management % costs 15% 14,270 $ 2,141

SVE Shutdown Monitoring Reporting Shutdown Evaluation Report report $8,000 1 $ 8,000 Project Management % costs 15% 90,053 $ 13,508

SVE Shutdown Monitoring Annual Subtotal $ 23,580 SVE Shutdown Monitoring (Years 9 - 11) Subtotal $ 70,739

SSD Shutdown Monitoring Costs (Years 11-13) Annual SSD System Shutdown Monitoring Costs Air Sampling - Collection event $1,250 1 $ 1,250 Air Analytical - VOCs sample $90 10 $ 900 Sample Shipping & Handling event $500 1 $ 500 Geosyntec Site Travel Costs (Airfare + Time) lump sum $3,800 1 $ 3,800 Site Costs (Lodging, Truck Rental, Per diem) day $700 3 $ 2,100 Data Processing/Data Validation event $2,000 1 $ 2,000 Field Equipment Rental week $300 1 $ 300 Miscellaneous Field Supplies event $100 1 $ 100 Project Management % costs 15% 10,950 $ 1,643

Page 3 of 4 Geosyntec Consultants TABLE B-2 COST ESTIMATE FOR UNSATURATED ZONE TARGETED SVE WITH INSTITUTIONAL AND ENGINEERING CONTROLS Former WACS Site and JPVEC, Aniak, Alaska

SSD Shutdown Monitoring & Reporting Shutdown Evaluation Report report $8,000 1 $ 8,000 Project Management % costs 15% 8,000 $ 1,200

SSD Shutdown Monitoring Annual Subtotal $ 15,659 SSD Shutdown Monitoring (Years 11 - 13) Subtotal $ 46,978

SSD Shutdown and Closure Costs (Year 14) SSD Shutdown and Closure Sampling Costs Air Sampling - Collection event $1,250 1 $ 1,250 Air Analytical - VOCs sample $90 10 $ 900 Sample Shipping & Handling event $500 1 $ 500 Geosyntec Site Travel Costs (Airfare + Time) lump sum $3,800 1 $ 3,800 Site Costs (Lodging, Truck Rental, Per diem) day $700 3 $ 2,100 Data Processing/Data Validation event $2,000 1 $ 2,000 Field Equipment Rental week $300 1 $ 300 Miscellaneous Field Supplies event $100 1 $ 100 Project Management % costs 15% 10,950 $ 1,643

Closure Report Rebound Data Evaluation & Closure Reporting lump sum $33,000 1 $ 33,000 Project Management % cost 15% 33,000 $ 4,950

SSD Shutdown and Closure (Year 14) Subtotal $ 50,543

OM&M COSTS TOTAL $ 1,587,175 TOTAL COSTS $ 2,100,000 TOTAL COSTS (-30%) $ 1,470,000 TOTAL COSTS (+50%) $ 3,150,000

Notes / Assumptions: Costs are estimated using 2018 dollars. Cost estimates were based on Geosyntec's experience at similar sites and working in rural Alaska, as well as subcontractor and vendor quotes. Costs assume operations and monitoring for the time frames listed above. System demolition and well decommissioning costs are not included as these costs are likely similar for all remedial alternatives. Costs savings associated with combining the land use covenent and the SMP with the unsaturated zone and/or the polychlorinated biphenyl (PCB) cleanup are not included. The current SSD enclosure has equipment that can support the proposed SVE wells. The excavator and drill rig can be mobilized together. Electricity costs are included in operation costs. ROI - Radius of influence SMP - Site Management Plan SSD - Sub-slab depressurization SVE - Soil vapor extraction VOCs - Volatile organic compounds

Page 4 of 4 Geosyntec Consultants TABLE B-3 COST ESTIMATE FOR UNSATURATED ZONE EXCAVATION WITH ICs AND ECs Former WACS Site and JPVEC, Aniak, Alaska

Excavation with Interim ECs Design/Cost Basis SSD Operations (Assumes same SSD OM&M as Alt 2): Estimated Years of SSD Operation 30 Number of Monitoring Events per Year 3 Number of Air Samples Collected per Monitoring Event 10 General Excavation Assumptions Gravel Fill Density (kilograms per cubic meter [kg/m3]) 2000 Horizontal Extent of Contamination (square feet) 75,000 Average Vertical Extent of Contamination 13 Contamination Quantity (cubic yards [cy]) 36,000 Contaminated Soil Weight (tons) 61,000 Estimated Duration (months) 4 Excavation Confirmation Soil Samples 450 Costs Item Unit Unit Cost Unit Qty Total Cost

CAPITAL COSTS Detailed Design Excavation Design lump sum $13,000 1 $ 13,000 Regulatory Negotiations lump sum $10,000 1 $ 10,000 Project Management % cost 15% $ 23,000 $ 3,450

Preparation Field Preparation lump sum $15,000 1 $ 15,000 Utility Clearance lump sum $5,000 1 $ 5,000 Project Management % cost 15% 20,000 $ 3,000

Geotechnical Design Sampling Drill Rig Mob/Demob to Site lump sum $66,000 1 $ 66,000 Drill Rig + Crew day $4,200 7 $ 29,400 Soil Sampling - Collection boring $600 20 $ 12,000 Soil Analytical - Geotech sample $75 20 $ 1,500 Soil Analytical - Baseline Backfill sample $250 10 $ 2,500 Sample Shipping & Handling event $500 1 $ 500 Geosyntec Site Travel Costs (Airfare + Time) lump sum $3,800 1 $ 3,800 Site Costs (Lodging, Truck Rental, Per diem) day $700 7 $ 4,900 Data Processing/Data Validation event $2,000 3 $ 6,000 Miscellaneous Field Supplies week $500 1 $ 500 Project Management % cost 15% 127,100 $ 19,065

Page 1 of 3 Geosyntec Consultants TABLE B-3 COST ESTIMATE FOR UNSATURATED ZONE EXCAVATION WITH ICs AND ECs Former WACS Site and JPVEC, Aniak, Alaska

Excavation Services Excavator Mob/Demob lump sum $120,000 1 $ 120,000 Excavation Equipment month $120,000 4 $ 480,000 Excavation Personnel month $650,000 4 $ 2,600,000 Excavation Personnel Expenses day $2,500 180 $ 450,000 Infrastructure Removal lump sum $10,000 1 $ 10,000 Soil Disposal ton $55 61000 $ 3,355,000 Backfill Material cy $30 36000 $ 1,080,000 Soil Analytical - VOCs sample $90 450 $ 40,500 Field Equipment Rental week $300 16 $ 4,800 Sample Shipping & Handling event $500 9 $ 4,500 Data Processing/Data Validation event $2,000 9 $ 18,000 Miscellaneous Supplies month $100,000 4 $ 400,000 Project Management % cost 15% $ 8,562,800 $ 1,284,420

Reporting Excavation Closure Reporting lump sum $33,000 1 $ 33,000 Project Management % cost 15% 33,000 $ 4,950

Institutional Controls Land Use Covenant Negotations lump sum $10,000 1 $ 10,000 Site Management Plan (SMP) lump sum $5,000 1 $ 5,000 Project Management % costs 15% 15,000 $ 2,250

CAPITOL COSTS TOTAL $ 10,098,035 OPERATION, MAINTENANCE, & MONITORING (OM&M COSTS) SSD Operations, Monitoring, & Maintenance Costs (Years 1 - 30) Annual SSD System Operation Costs Operating and Maintenance Cost month $2,000 12 $ 24,000 Project Management % cost 15% 24,000 $ 3,600

Annual SSD Performance Monitoring Costs Air Sampling - Collection event $5,000 3 $ 15,000 Air Analytical - VOCs sample $90 30 $ 2,700 Sample Shipping & Handling event $500 3 $ 1,500 Geosyntec Site Travel Costs (Airfare + Time) lump sum $3,800 3 $ 11,400 Data Processing/Data Validation event $2,000 3 $ 6,000 Field Equipment Rental week $300 3 $ 900 Miscellaneous Field Supplies event $100 3 $ 300 Project Management % cost 15% 37,800 $ 5,670

SSD Performance Monitoring Evaluation & Reporting Performance Evaluation Reports (Every 5 years) report $8,000 6 $ 48,000 Project Management % cost 15% 48,000 $ 7,200

SSD OM&M Annual Subtotal $ 72,910 SSD OM&M (Years 1 - 30) Subtotal $ 2,187,300

Page 2 of 3 Geosyntec Consultants TABLE B-3 COST ESTIMATE FOR UNSATURATED ZONE EXCAVATION WITH ICs AND ECs Former WACS Site and JPVEC, Aniak, Alaska

SDD Shutdown and Closure Costs (Year 30) SSD Performance Monitoring Evaluation & Reporting Air Sampling - Collection event $5,000 1 $ 5,000 Air Analytical - VOCs sample $90 10 $ 900 Sample Shipping & Handling event $500 1 $ 500 Geosyntec Site Travel Costs (Airfare + Time) lump sum $3,800 1 $ 3,800 Field Equipment Rental week $300 1 $ 300 Miscellaneous Field Supplies event $100 1 $ 100 Rebound Data Evaluation & Closure Reporting lump sum $33,000 1 $ 33,000 Project Management % costs 15% 43,600 $ 6,540

SSD Shutdown/Closure (Year 30) Subtotal $ 50,140

OM&M COSTS TOTAL $ 2,237,440 TOTAL COSTS $ 12,400,000 TOTAL COSTS (-30%) $ 8,700,000 TOTAL COSTS (+50%) $ 18,600,000

Notes / Assumptions: Costs are estimated using 2018 dollars. Cost estimates were based on Geosyntec's experience at similar sites and working in rural Alaska, as well as subcontractor and vendor quotes. Costs assume operations and monitoring for the time frames listed above. System demolition and well decommissioning costs are not included as these costs are likely similar for all remedial alternatives.

Costs savings associated with combining the land use covenent and the SMP with the unsaturated zone and/or the polychlorinated biphenyl (PCB) cleanup are not included. Electricity costs are included in operation costs. SMP - Site Management Plan SSD - Sub-slab depressurization VOCs - Volatile organic compounds

Page 3 of 3 Geosyntec Consultants TABLE B-4 COST ESTIMATE FOR SATURATED ZONE INSTITUTIONAL AND ENGINEERING CONTROLS Former WACS Site and JPVEC, Aniak, Alaska

ICs and ECs

Design/Cost Basis Number of Sentry Monitoring Wells 1 Years of Annual Monitoring on Sentry Wells 30 Number of GW Samples Collected During Annual Monitoring Event 2 Costs Item Unit Unit Cost Unit Qty Total Cost CAPITAL COSTS Institutional Controls Land Use Covenant Negotations ls $10,000 1 $ 10,000 Site Management Plan (SMP) ls $5,000 1 $ 5,000 Project Management % costs 15% 15,000 $ 2,250 5 CAPITAL COSTS TOTAL $ 17,250 5 GROUNDWATER MONITORING COSTS Annual Sampling Costs (Years 1 - 30) Groundwater Sampling - Collection well $450 1 $ 450 Groundwater Analytical - VOCs sample $90 2 $ 180 Sample Shipping & Handling event $500 1 $ 500 Geosyntec Site Travel Costs (Airfare + Time) event $3,800 1 $ 3,800 Site Costs (Lodging, Truck Rental, Per diem) day $700 2 $ 1,400 Data Processing/Data Validation event $2,000 1 $ 2,000 Miscellaneous Field Supplies event $200 1 $ 200 GW Monitoring Summary Reports event $3,000 1 $ 3,000 Project Management % cost 15% 9,210 $ 1,382

Annual Subtotal $ 13,592 Years 1 - 30 Subtotal $ 407,745

GROUNDWATER MONITORING COSTS TOTAL $ 407,745 TOTAL COSTS $ 430,000 TOTAL COSTS (-30%) $ 301,000 TOTAL COSTS (+50%) $ 645,000

Notes / Assumptions: Costs are estimated using 2018 dollars. Cost estimates were based on Geosyntec's experience at similar sites and working in rural Alaska, as well as subcontractor and vendor quotes. Costs assume operations and monitoring for the time frames listed above. System demolition and well decommissioning costs are not included as these costs are likely similar for all remedial alternatives.

Costs savings associated with combining the land use covenent and the SMP with the unsaturated zone and/or the polychlorinated biphenyl (PCB) cleanup are not included. Costs for contingency wellhead treatment are not included. VFA and GeneTrac samples collected annually only. bgs - Below ground surface VOCs - Volatile organic compounds SMP - Site Management Plan

Page 1 of 1 TABLE B-5 Geosyntec Consultants COST ESTIMATE FOR SATURATED ZONE LONG-TERM GROUNDWATER MONITORING WITH ICs AND ECs Former WACS Site and JPVEC, Aniak, Alaska

LTGM with ICs and ECs Design/Cost Basis Number of Existing Monitoring Wells 14 Years of Semi-Annual GW Monitoring 5 Years of Annual GW Monitoring 7 Years of Biennial GW Monitoring 18 Number of GW Samples Collected During Monitoring Event (Years 1-12) 17 Number of GW Samples Collected During Monitoring Event (Years 13-30) 15 Costs Item Unit Unit Cost Unit Qty Total Cost CAPITAL COSTS Institutional Controls Land Use Covenant Negotations ls $10,000 1 $ 10,000 Site Management Plan (SMP) ls $5,000 1 $ 5,000 Project Management % costs 15% 15,000 $ 2,250 CAPITAL COSTS TOTAL $ 17,250 GROUNDWATER MONITORING COSTS Groundwater Sampling (Years 1-12) Groundwater Sampling - Collection well $450 14 $ 6,300 Groundwater Analytical - VOCs sample $90 17 $ 1,530 Sample Shipping & Handling event $500 1 $ 500 Geosyntec Site Travel Costs (Airfare + Time) event $3,800 1 $ 3,800 Site Costs (Lodging, Truck Rental, Per diem) day $700 6 $ 4,200 Data Processing/Data Validation event $2,000 1 $ 2,000 Miscellaneous Field Supplies event $750 1 $ 750 GW Monitoring Summary Reports event $3,000 1 $ 3,000 Project Management % cost 15% 22,080 $ 3,312 Costs Per Sampling Event Subtotal $ 25,392 Semi-Annual Sampling (Years 1 - 5) Subtotal $ 253,920 Annual Sampling (Years 5 - 12) Subtotal $ 177,744 Groundwater Sampling (Years 13-30) Groundwater Sampling - Collection well $450 12 $ 5,400 Groundwater Analytical - VOCs sample $90 15 $ 1,350 Sample Shipping & Handling event $500 1 $ 500 Geosyntec Site Travel Costs (Airfare + Time) event $3,800 1 $ 3,800 Site Costs (Lodging, Truck Rental, Per diem) day $700 5 $ 3,500 Data Processing/Data Validation event $2,000 1 $ 2,000 Miscellaneous Field Supplies event $750 1 $ 750 GW Monitoring Summary Reports event $3,000 1 $ 3,000 Project Management % cost 15% 20,300 $ 3,045

Costs Per Sampling Event Subtotal $ 23,345

Biennial Sampling (Years 13 - 30) Subtotal $ 210,105

Page 1 of 2 TABLE B-5 Geosyntec Consultants COST ESTIMATE FOR SATURATED ZONE LONG-TERM GROUNDWATER MONITORING WITH ICs AND ECs Former WACS Site and JPVEC, Aniak, Alaska

Remedy Evaluation Reports Remedy Evaluation Reports (Every 5 years) report $15,000 6 $ 90,000 Project Management % cost 15% 90,000 $ 13,500

Remedy Evaluation Reports Subtotal $ 103,500

GROUNDWATER MONITORING COSTS TOTAL $ 745,269 TOTAL COSTS $ 770,000 TOTAL COSTS (-30%) $ 539,000 TOTAL COSTS (+50%) $ 1,155,000

Contingency cost - two additional groundwater monitoring wells (cost not included above) $ 155,000

Notes / Assumptions: Costs are estimated using 2018 dollars. Cost estimates were based on Geosyntec's experience at similar sites and working in rural Alaska, as well as subcontractor and vendor quotes. Costs assume no new monitoring wells will be installed. Costs assume operations and monitoring for the time frames listed above. System demolition and well decommissioning costs are not included as these costs are likely similar for all remedial alternatives. Costs savings associated with combining the land use covenent and the SMP with the unsaturated zone and/or the polychlorinated biphenyl (PCB) cleanup are not included. Costs for contingency wellhead treatment are not included. Contingency cost: Assessment of additional wells will be included in the Remedial Action Plan, based on remedy design. bgs - Below ground surface VOCs - Volatile organic compounds SMP - Site Management Plan

Page 2 of 2

APPENDIX C Response to Comments

Final FS Report March 2019 SITE: Former WACS Site/Joe Parent Vocational Education Center, Aniak, Alaska DOCUMENT: Draft Trichloroethene Feasibility Study Report REVIEWERS: Bill O’Connell, 2-01-19 Accepted (Y/N) No. Section Pg. Comment Response Third full paragraph indicates the silt layer likely acts as a Agreed. Given the proximity of the barrier limiting the extent to which TCE can volatilize from nearby JPVEC supply well and that groundwater. Section 3.2 Remedial Action Objectives the level for protection of however states that the RAO for groundwater is to reduce groundwater as a drinking water TCE concentrations to levels consistent with ADEC source is slightly more conservative 1 2.6.4 14 cleanup levels for the protection of human health via the than the groundwater level for vapor intrusion pathway, which would appear to be protection of human health via the inconsistent with the information in Section 2.6.4. Given vapor intrusion pathway, the RAO the current and potential future use of groundwater for will be changed to the Table C drinking water, the RAO for TCE in groundwater should be groundwater cleanup level (2.8 µg/L). the Table C groundwater cleanup level from 18 AAC 75.345. The first paragraph in section three will be replaced with the following: “This FS was conducted substantially in accordance with the USEPA regulations for the preparation of an Applicable Requirements – This section includes a general RI/FS in compliance with the National reference to the Comprehensive Environmental Response, Contingency Plan, pursuant to the Compensation, and Liability Act (CERCLA) and uses the Comprehensive Environmental term “applicable and relevant” which might be confused Response, Compensation and Liability 2 3.1 16 with CERCLA applicable, relevant, and appropriate Act (CERCLA). It was also conducted requirements (ARARs). For the purpose of clarity, please in compliance with state law. The emphasize that the investigation and cleanup of this site is primary state law regulatory proceeding under State authority only and please replace or requirements for consideration in the remove the phrase “applicable and relevant” in the text. development of an FS are listed below. These requirements are the primary regulations and guidance documents that influence remedy selection for the site. The alternative for Long-Term Recent groundwater sampling at monitoring well MW18 Groundwater Monitoring with indicated that the extent of TCE in groundwater has not 3 General ICs/ECs acknowledges that the need been delineated to the west. In order to implement the for additional wells will be assessed in selected remedy, at least one additional groundwater the Remedial Action Plan (RAP). As Page 1

SITE: Former WACS Site/Joe Parent Vocational Education Center, Aniak, Alaska DOCUMENT: Draft Trichloroethene Feasibility Study Report REVIEWERS: Bill O’Connell, 2-01-19 Accepted (Y/N) No. Section Pg. Comment Response monitoring well will be needed west of MW18 to delineate such, implementation of the ADEC- the western extent of the plume. approved Alternative 5 will address this comment. 4 General ADEC has no objection to Alternative 5 as the selected Noted remedy.

* * *

Page 2

From: Oconnell, Bill A (DEC) To: Ben Martich Cc: Halverson, John E (DEC); Jennifer Black; Beth Kramer; Currie, Jennifer A (LAW); Manolopoulos, Lynn; Steve S. Tervooren; [email protected]; McCullough, Patrick T; Duane Siler; Binder, John R (DOT); Stark, Jeff P (LAW); Weyhrauch, Luann E B (LAW); [email protected]; "Greg Carter"; Hanson, Kent (ENRD) ([email protected]); Bruce Marvin; Melissa Asher Subject: RE: Draft Trichloroethene Feasibility Study Report - Former Aniak WACS Date: Monday, March 4, 2019 11:17:04 AM

Thanks Ben, ADEC has no objection to your responses to our comments and I look forward to seeing the final report.

Bill

Bill O'Connell, CPG Environmental Program Manager ADEC Contaminated Sites Program (907) 269-3057

From: Ben Martich [mailto:[email protected]] Sent: Friday, March 1, 2019 3:02 PM To: Oconnell, Bill A (DEC) Cc: Halverson, John E (DEC) ; Jennifer Black ; Beth Kramer ; Currie, Jennifer A (LAW) ; Manolopoulos, Lynn ; Steve S. Tervooren ; [email protected]; McCullough, Patrick T ; Duane Siler ; Binder, John R (DOT) ; Stark, Jeff P (LAW) ; Weyhrauch, Luann E B (LAW) ; [email protected]; 'Greg Carter' ; Hanson, Kent (ENRD) ([email protected]) ; Bruce Marvin ; Melissa Asher Subject: Draft Trichloroethene Feasibility Study Report - Former Aniak WACS

Hello Bill, On behalf of the TCE RI/FS Coordinator, I am providing responses (first attachment) to the ADEC comments (second attachment), dated February 1, 2019, on the above-referenced report. Please let me know if ADEC has questions or wishes to discuss the responses. A final report will be prepared with ADEC acceptance of the responses.

Thank you, Ben

Ben Martich, QEP Principal Geosyntec Consultants, Inc. 4101 Arctic Blvd., Ste 206 | Anchorage, AK 99503 Off: 907-929-3326 | Dir: 907-754-9677 | Mob: 907-330-4391