Contaminated Media Management Plan 173d Fighter Wing Oregon Air National Guard Kingsley Field Klamath Falls, Oregon July 2014 Prepared For: Oregon Department of Environmental Quality FINAL TABLE OF CONTENTS LIST OF FIGURES ii LIST OF ACRONYMS iii SECTION 1.0 INTRODUCTION 1-1 1.1 CMMP DESCRIPTION 1-2 SECTION 2.0 CONTAMINATED MEDIA MANAGEMENT 2-1 2.1 Identification of Potentially Contaminated Media 2-1 2.2 Determination & Identification of Contaminated Media 2-2 2.3 Excavating and Storage of Contaminated Media 2-3 2-4 Sampling & Testing Requirements 2-3 2-5 Disposal of Contaminated Media 2-5 SECTION 3.0 WORKER SAFETY & TRAINING 3-1 3.1 Health and Safety Plan 3-2 3.2 Worker Training 3-3 APPENDIX 1 - BACKGROUND HISTORY & CIP 4-1 i FINAL LIST OF FIGURES FIGURE 1 Site Map FIGURE 2 Site TU015 FIGURE 3 Site PL016 ii FINAL LIST OF ACRONYMS Acronym Definition ORANG Oregon Air National Guard CMMP Contaminated Media Management Plan ERM ERM-West, Inc. 173FW 173d Fighter Wing HASP Health and Safety Plan NAP Naphthalene ODEQ Oregon Department of Environmental Quality OSHA Occupational Safety and Health Administration PSH Phase-separated hydrocarbons RBC Risk-based concentration TMB Tri-methylbenzene HAZWOPER Hazardous Waste Operations and Emergency Response IRP Installation Restoration Program NPL National Priority Listing RCRA Resource Conservation and Recovery Act EMO Environmental Management Office (173FW) SOW Statement Of Work iii FINAL SECTION 1.0 INTRODUCTION 1.1 CMMP Description This Contaminated Media Management Plan (CMMP) provides guidance for managing contaminated soil and groundwater encountered during earthwork-related construction activities at Kingsley Field, located in Klamath Falls, Oregon (Figure 1). The purpose of this CMMP is to minimize risks to worker health and the environment by outlining procedures for the identification, handling, and disposal of petroleum contaminated soil and groundwater that may be encountered during future earthwork-related construction activities. This document is NOT intended to address requirements for an initial/immediate response to a contamination event, (such as an aircraft fuel spill). This document identifies specific geographic areas of concern that have been established as a clean-up site and are in either active or former “clean-up” site status. Provided in the following sections is the background information of the contaminated areas that have been identified as impacted by the release of hazardous materials by the U.S. Environmental Protection Agency (EPA) and the Oregon Department of Environmental Quality (ODEQ). This CMMP is a locally derived document and is not a standard or regulation. This document is advisory in nature and informational in content; it is intended to assist Kingsley Field personnel and Contractors to execute a safe and healthful workplace for compliance with Federal, State and Local regulations. The 173FW EMO will periodicaly review this document and update as necessary. 1-1 FINAL 1.2 Installation Description The Kingsley Field is located in the City of Klamath Falls, of Klamath County, in southern Oregon; and is situated on the western side of the Crater Lake Regional Airport. A site location map is presented as Figure 1. Kingsley Field was originally formed as a United States Naval Air Station during World War II. Subsequently, the station was deactivated and the property was transferred back to the City of Klamath Falls. In 1954, the United States Air Force obtained portions of the airport and the ANG became the main tenant during the early 1980s. Kingsley Field was officially recognized as an ANG installation in 1984 Based on investigations and corrective measures implemented at various clean-up sites across Kingsley Field, contaminated soil and/or groundwater may be encountered during future earthwork-related construction activities in the area. The following is a list and background of Active, and Former Clean-Up sites where future contamination may be encountered. 1-2 FINAL SECTION 2.0 CONTAMINATED MEDIA MANAGEMENT This section provides guidance for the identification, characterization, handling and disposal of contaminated soil and groundwater that may be encountered during earthwork-related construction activities at the site. All contractors are required to test and manage contaminated media in accordance with ODEQ requirements. Testing and special handling requirements are necessary for proper storage, transportation and disposal. 2.1 Identification of Potentially Contaminated Media Each party involved in any earthwork-related construction activities at the site shall be solely responsible for identification of contaminated soil and groundwater. Each contractor shall monitor soil, groundwater, vapors, and any waste material for evidence of contamination. If site personnel observe media exhibiting characteristics of contaminant impacts, the media in question shall be identified as “potentially impacted” and will be managed as if contaminated until further determination can be made. The following field observations can be used to screen potentially impacted media: Staining of soil; Chemical or petroleum odors; Measurements made with a photoionization detector; Sheen on water; Sheen on moist or saturated soil; and Groundwater, if removed in the proximity to impacted soils. Note that the absence of these characteristics does not necessarily imply that the media does not contain contaminants. Some forms of soil and 2-1 FINAL groundwater contamination are only detectable with the use of environmental testing equipment or analytical testing. If unexpected hazardous or contaminated materials are encountered, the contractors shall: Stop all work in that area; Notify the 173d Environmental Manager immediately; Ensure no contaminated material is hauled from the site; Remove the work force from the immediate area of the contamination; Involve an environmental consultant and/or the ODEQ; and Secure the area from access by the public until such time as all parties involved have verified that site work can be completed in accordance with the HASP and this CMMP. 2.2 Determination & Identification of Contaminated Media 173FW EMO will assist in the contractor’s determination of the identified “potentially impacted” as contaminated media. The EMO will provide background information contained in APPENDIX 1 and other pertinent Base Records to aid in the identification of the type of potential contamination and selection of analytical testing that may be required. In most cases, if the soil/water displays the characteristics of contaminated media, and has been excavated in the vicinity of an Active or Former Clean-up site, The 173FW EMO will consider the media as contaminated, and will require the contractor to treat the media as such, until additional analysis conducted by the contractor could prove otherwise. The contractor is ultimately responsible to make the determination that the media is(is not) contaminated, and to identify the contaminates for the purpose of health, safety, and disposal of the media. When potentially impacted media is encountered, 173FW/CE will document the outcome of the determination and place in office files to be included in future updates of this plan. 2-2 FINAL 2.3 Excavating and Storage of Contaminated Media Contaminated soil and/or groundwater must be stored and disposed of in accordance with all ODEQ requirements. The following steps will be taken to store or stockpile contaminated media at Kingsley Field: Contaminated soil will only be stockpiled on a temporary basis, while making arrangements for disposal or treatment. Contaminated soil will be containerized in a roll-off bin or stockpiled in an approved storage area that is lined and covered by durable plastic sheeting, and bermed to control run-on/runoff. Contaminated groundwater will be placed in 55-gallon steel drums. The drums will be placed in a designated secured storage area on site or at an approved alternate storage area. Site workers will comply with Best Management Practices for erosion and sediment control to prevent further exposure or cross contamination of contaminated media. 2.4 Sampling & Testing Requirements Soil / Water sampling & testing requirments will be influenced by the determination made in section 2.2. Sampling may be required to validate Media Disposal methods and Health & Saftey procedures during handling. Testing methods for Media Disposal is different than those used to establish Health and Safety. If user knowledge is not sufficient to establish a complete Waste Disposal determination, a composite soil and/or groundwater sample will be collected to determine waste class for disposal. Any waste facility that is in consideration for receiving soil/water from the site (e.g., landfill) should be contacted as to their requirements for acceptance of contaminaed media, as they may have a unique set of LDRS for their specific facility, LDRS may drive additional sampling & testing requirments. SAMPLING; All samples should be stored in a cooler below 4°C until submitted to analytical laboratory certified by the Oregon and/or National Environmental Laboratory Accreditation Program. Quality control 2-3 FINAL and quality assurance protocols should be followed. Chain-of- custody documentation needs to be maintained. Analytical method reporting limits need to be less than regulatory screening criteria.. All personel accomplishing a field sample shall utilize all PPE and saftey precautions necessary to protect themeselves from exposure to