Client: US Coast Guard
Location: Kodiak, AK
Scope of Work:
- Environmental Compliance
- Operations and Maintenance
- Long-term Monitoring
USCG Base Kodiak is under a RCRA Permit for post closure and corrective action to address various contaminants including petroleum, oils, and lubricants (POLs), metals, chlorinated solvents, PFAS, and pesticides from historic base operations. Brice was contracted to maintain regulatory compliance under the RCRA permit which involves environmental planning; post-closure LTM; inspection; sampling; surveying; reporting on various hazardous and solid waste management units (HWMUs/SWMUs); Land Use Control inspections and reporting; cleanup/control and extensive plan and report preparation. Regular activities at the three HWMUs on Base Kodiak include post-closure inspections of the landfill caps/monitoring well corrective action/compliance/effectiveness and detection groundwater monitoring, indoor air sampling and O&M of three vapor intrusion mitigation systems in commercial buildings, well surveys/inventories, O&M of two AS/SVE systems, and associated reporting.
Brice prepared two memoranda supporting the technical justification for remedial system optimization at two of the HWMUs with AS/SVE systems. Both memos provided analysis to demonstrate that:
- Mass removal from the systems is asymptotic
- Additional optimizations or pulsing of the systems will have no benefit
- VOC concentrations in downgradient monitoring wells have statistically significant decreasing concentrations
Ultimately, shutting down the systems at both sites will save the USCG more than $1M in O&M and energy costs. EPA concurred with the recommendations in the memoranda and both systems have been shutdown/mothballed. SWMU post-closure care, monitoring, and reporting activities at one site and LTM at two sites include groundwater and surface water monitoring; LUC inspections; post-closure care monitoring of earthen cover and leachate diversion systems; surface water and groundwater contaminant trend analysis; mass removal calculations, and effectiveness of the remediation system; and associated reporting.
In 2020, Brice led the re-issuance of Base Kodiak’s RCRA Permit, which is administered by the EPA in lieu of the State of Alaska having an authorized RCRA program. The Permit includes nine parts and 11 attachments that apply to many aspects of hazardous waste throughout USCG Base Kodiak. Brice performed extensive updates to all parts and attachments, provided the revised Permit to EPA who reviewed and had minimal comments, and closely supported EPA to submit the Permit Renewal for public comment in February 2021.
As part of this contract, Brice has also supported the USCG in response to an accidental AFFF release, collecting soil, groundwater, and foam samples to determine the nature and extent of release. Additionally, Brice is providing USCG technical support to characterize the nature and extent of PFAS contamination in soil/groundwater at a former fire training pit on-Base.
- Optimized the monitoring networks at multiple sites – reducing the number of wells sampled and frequency of monitoring events.
- Optimized AS/SVE remedies at two sites, providing technical evaluation and justification for shutting down two AS/SVE systems that were no longer effective. Ultimately, shutting down the systems at both sites will save the USCG more than $1M in O&M and energy costs.
- Implemented electronic data capture of field parameters during low-flow groundwater sampling. The electronic data capture increases efficiency in the field, reduces the level of effort for reporting, and minimizes transcription errors when entering field data into the project database.
- Performed extensive repairs to a vapor barrier in the crawlspace of a large commercial building to improve the efficiency/effectiveness of the building’s vapor intrusion mitigation system.