Standard Operating Procedures: Building Feature Evaluation and Sampling Revision 1 Santa Susana Field Laboratory Ventura County, California

Transcription

1 Standard Operating Procedures: Building Feature Evaluation and Sampling Revision 1 Santa Susana Field Laboratory Ventura County, California Prepared for: The Boeing Company, The National Aeronautics and Space Administration, and The United States Department of Energy Prepared by: MWH Americas, Inc. and CH2M HILL JUNE 2009

2 Contents Section Page Acronyms and Abbreviations... ii 1. Introduction and Background SOP Overview SOP Objectives SOP Organization Evaluation and Inspection of Existing Buildings Records Review Building Inspection Building Categorization Buildings with No Chemical Use Buildings With Chemical Use and Likely Impacted Environmental Media Buildings With Chemical Use and Potentially Impacted Environmental Media Sampling and Analysis Sampling and Analysis Criteria Buildings Not Planned for Demolition Buildings Planned for Demolition Field Activities Field Inspection and Headspace Screening Soil Sampling and Analysis Delineation Investigation and Removal Action Sampling Feature Removal Documentation Analytical Methods Reporting Table 1 Summary of Standard Operating Procedures for Building Evaluation Figures 1 Building Feature Evaluation Process Flow Chart: Buildings Not Planned For Demolition 2 Building Feature Evaluation Process Flow Chart: Buildings Planned For Demolition Appendix A Building Feature Inspection Information STANDARD OPERATING PROCEDURES: BUILDING FEATURE EVALUATION AND SAMPLING i

3 Acronyms and Abbreviations Bgs Boeing CMI CMS DFI DOE DTSC EIR FS GPS HSP NASA NFA NPDES PAH PCB PID QAPP RBSL RCRA RFI RI SIM SOP SSFL SVOC TPH VOC below ground surface The Boeing Company Corrective Measure Implementation Corrective Measures Study deferred further investigation United States Department of Energy Department of Toxic Substances Control Environmental Impact Report Feasibility Study global positioning system Health and Safety Plan National Aeronautics and Space Administration no further action National Pollutant Discharge Elimination System polycyclic aromatic hydrocarbon polychlorinated biphenyl photoionization detector Quality Assurance Project Plan risk-based screening level Resource Conservation and Recovery Act Resource Conservation and Recovery Act Remedial Investigation selective ion monitoring Standard Operating Procedure Santa Susana Field Laboratory semivolatile organic compound total petroleum hydrocarbon volatile organic compound STANDARD OPERATING PROCEDURES: BUILDING FEATURE EVALUATION AND SAMPLING REV 1 ii

4 1. Introduction and Background This document, entitled Standard Operating Procedures: Building Feature Evaluation and Sampling (Building Evaluation SOP), presents the procedures for evaluating environmental conditions associated with existing buildings, concrete pads left from previously removed buildings, and adjacent building support infrastructure at the Santa Susana Field Laboratory (SSFL) in Ventura County, California. This document has been prepared for The Boeing Company (Boeing), the National Aeronautics and Space Administration (NASA), and the United States Department of Energy (DOE) to support the SSFL building decommissioning and demolition program. This SOP has been prepared to meet current RFI requirements defined by the Department of Toxic Substances Control (DTSC) as contained in the 2007 Consent Order for Corrective Action. However, the 2007 Consent Order is in the process of being revised, and the regulatory framework for SSFL cleanup will be transitioned from the RCRA Corrective Action to the California Superfund Remedial Investigation / Feasibility Study (RI/FS) Process. Therefore, this SOP has been prepared to meet current requirements as to support both the RFI, and future RI requirements. References to the RCRA process/documentation will also be applied to the respective CERCLA process/documentation. Also, determinations of additional characterization and risk requirements for the SSFL associated with Senate Bill 990 are ongoing. Once these determinations are made, RFI/RI Group documents, using the information obtained from this SOP, will be reviewed and revised, as appropriate. Concurrently with the building demolition work, environmental conditions associated with the buildings, concrete pads, and adjacent supporting infrastructure at SSFL are being evaluated as part of the Resource Conservation and Recovery Act (RCRA) Facility Investigation (RFI) Corrective Action program, and the information collected as part of this SOP will be incorporated into the RCRA reports. The RCRA Corrective Action program is now in the investigation stage, with future remedial actions planned. Depending on the timing of the environmental assessment activities described herein, the information gathered will be incorporated into the RFI, Corrective Measures Study (CMS), or Corrective Measures Implementation (CMI) reports as appropriate and provided to the Department of Toxic Substances Control (DTSC). As described in this document, some sampling will be performed before building demolition, some will be deferred until after building foundation removal, and some will be performed at buildings that are not planned for demolition (for the purposes of the SOP, the term building includes concrete pads and adjacent or nearby supporting infrastructure). This SOP allows for the collection and analysis of samples that will be used for the timely completion of the RFI so that the overall RFI process will not be compromised. Through the implementation of this SOP, environmental conditions at all existing buildings, concrete pads, and adjacent or nearby supporting infrastructure will be evaluated prior to final RFI decision making. The timing of sampling will depend on the likelihood of impact, and the results will be incorporated into the RCRA reports. STANDARD OPERATING PROCEDURES: BUILDING FEATURE EVALUATION AND SAMPLING-REV 1 1-1

5 1. INTRODUCTION AND BACKGROUND 1.1 SOP Overview This SOP presents the approach for building feature inspection and sampling activities that will be performed as part of the RFI process as it relates to the decommissioning and demolition program for buildings, concrete pads, and nearby supporting infrastructure currently onsite. This document describes the standard methodology for identifying building features and process areas where chemicals were potentially used, documenting the conditions of those features, and, if warranted, collecting samples to assess environmental impacts. Many of the existing buildings, concrete pads, and adjacent supporting infrastructure at the SSFL are planned for decommissioning and demolition. During decommissioning and demolition, buildings, foundations, sub-slab features (e.g., sumps, drains), and utilities will be removed. The removal of these facilities presents a unique opportunity to inspect, screen, and/or sample the soil directly beneath the facilities. Furthermore, many of the existing facilities significantly hinder sample collection and/or assessment of potential impacts related to interior features, such as floor drains, sumps, and pipelines. Therefore, rather than attempt to core through thick or reinforced building slabs or sample in otherwise inaccessible areas, a thorough inspection of the building interior will be performed to document features potentially associated with chemical uses. Furthermore, prior to the demolition of buildings with known or potential chemical uses, samples will be collected prior to demolition outside the buildings where the sewer or drain lines exit the buildings. However, some RFI sampling within existing buildings prior to demolition is warranted to address areas of known or suspected significant releases to the environment. Therefore, samples will be collected inside buildings prior to demolition if significant chemical releases are known to have existed inside the building and either (1) visible damage to a sub-slab feature (e.g., a sump or drain) indicates that a release to the environment has occurred, or (2) there are known soil vapor and/or groundwater impacts centered at or near the building, with no other source identified. In other cases where an environmental impact is less likely, RFI samples will not be collected from existing buildings prior to demolition. Rather, samples will be collected surrounding the building before demolition and additional inspection and/or sampling beneath existing building features will be performed during/after building demolition. Some buildings may remain onsite depending on the final land use plans for the SSFL property. Because of this uncertainty, this SOP also describes the criteria and methodologies for evaluating environmental site conditions in areas where buildings may remain onsite. This SOP includes building evaluation under the following scenarios: Environmental assessment prior to building demolition Environmental assessment during/after building demolition Environmental assessment for buildings not planned for demolition STANDARD OPERATING PROCEDURES: BUILDING FEATURE EVALUATION AND SAMPLING-REV 1 1-2

6 1. INTRODUCTION AND BACKGROUND The approach for evaluating each building will depend on the likelihood of impact as well as whether a building is planned for demolition. Figure 1 shows the building evaluation process as described in this SOP for those buildings not scheduled for demolition, and Figure 2 shows the building evaluation process for buildings that are scheduled for demolition. 1.2 SOP Objectives The procedures presented in this Building Evaluation SOP have been developed to accomplish the following objectives: Complete a preliminary evaluation to identify existing buildings where chemical releases may have resulted in impacts to environmental media. Determine whether environmental impacts are present beneath and/or in the vicinity of those buildings. If present, characterize the nature and extent of identified environmental impacts sufficient to support the ongoing RFI activities, including risk assessment and CMS decision making. If present, mitigate significant impacts on an expedited basis, as appropriate. Avoid impacts to the 2017 project closure schedule. Since the building reviews and sampling will be conducted in a thorough manner as proposed in this SOP, the RFI process will not impact the 2017 project completion schedule. The main items included in this SOP that will allow for the meeting of this schedule are as follows: Historical document reviews along with physical inspection and documentation of all building features, and inclusion of results in the RFI reports; Timely characterization of the most likely impacted areas prior to RFI reporting, including sampling within building footprints prior to demolition, if appropriate; Characterization of areas surrounding building footprints of potentially impacted areas, allowing for appropriate identification of chemicals of concern and determination of order of magnitude impact estimates for CMS and EIR planning; Oversight and inspection by a professional as defined in the Consent Order during demolition activities, allowing for the identification of previously unknown impacts and the incorporation of data for the impacted areas into the RCRA process; and Incorporation of new information obtained for areas that are less likely to be impacted into the RCRA process as the new data are collected. Data collected during later phases will be reviewed with DTSC, and as warranted, cleanup plans will be modified and implemented. These procedures were developed in consideration of the necessary steps of the RCRA Corrective Action process, which will continue to be performed under DTSC oversight. STANDARD OPERATING PROCEDURES: BUILDING FEATURE EVALUATION AND SAMPLING-REV 1 1-3

7 1. INTRODUCTION AND BACKGROUND 1.3 SOP Organization This Building Evaluation SOP is organized as follows: Section 1 presents an overview and the objectives of the SOP. Section 2 describes the preliminary building evaluation process, which consists of reviewing records and inspecting the buildings to identify areas that warrant further investigation. Section 3 presents the approach for categorizing buildings so that sampling and analysis can be planned Section 4 presents the approach for sampling building features to evaluate environmental conditions for the RFI Section 5 discusses the incorporation of information about building features into the RFI reports. The SOP contains one appendix: Appendix A Building Feature Inspection Information STANDARD OPERATING PROCEDURES: BUILDING FEATURE EVALUATION AND SAMPLING-REV 1 1-4

8 2. Evaluation and Inspection of Existing Buildings This section describes activities that will be performed to identify historical chemical uses and potential environmental impacts at and near the existing buildings, concrete pads, and nearby supporting infrastructure at the SSFL prior to demolition. The evaluation, which includes a review of historical documents and an onsite visual inspection, will be performed to identify (1) historical processes both outside and within the buildings, (2) building features that may have associated chemical uses, and (3) significant chemical releases to the environment (i.e., soil, surface water, or groundwater). Although the data gap assessment process for the SSFL RFI has always addressed chemical uses both inside the buildings and in the surrounding areas, the DTSC has requested a more detailed evaluation of sub-slab internal building features (e.g., sumps, pipelines, sinks, drains) within existing buildings onsite. Presented below are descriptions of the standard procedures associated with this expanded scope. 2.1 Records Review The first step in the building feature evaluation process is to perform a comprehensive review of available historical site documents generated during facility operations or in subsequent environmental investigations to identify known or potential chemical use areas. Buildings can have records dating back to the 1940s. During the review of this information, which has been compiled onto the document database, significant building interior features (e.g., clarifiers, equipment vaults) that may have associated chemical uses will be identified. In addition to identifying these larger features, the records will also be reviewed to identify smaller features such as sumps, drains, and pipelines if used to support chemical process operations. During the records review, the location, use, and chronological history of each feature will be determined in preparation for the building inspection (Section 2.2). In addition, historical site assessment data will be reviewed to determine whether there are known impacts in areas surrounding the buildings. The building evaluation process will include reviewing the following information: Historical documents, including RCRA and non-rcra work plans, reports, memoranda, and letters Tank inventories, including underground and aboveground storage tanks Building inventories design drawings, and demolition reports Transformer records and associated polychlorinated biphenyl (PCB) sampling results Spill records STANDARD OPERATING PROCEDURES: BUILDING FEATURE EVALUATION AND SAMPLING-REV 1 2-1

9 2. EVALUATION AND INSPECTION OF EXISTING BUILDINGS Soil, groundwater, soil vapor, and surface water analytical data, including stormwater (i.e., National Pollutant Discharge Elimination System [NPDES]) data and quarterly groundwater monitoring results Field sampling logs and maps Site photographs Waste characterization and disposal records Site inspection findings Historical interview records In addition to reviewing available historical documents, current site personnel may be interviewed regarding their knowledge of current and historical site operations. The results of these interviews will be fully documented, considered during the selection of sampling locations and analyses, and uploaded to a document database. 2.2 Building Inspection Once the SSFL records have been searched for relevant information, and after the available historical data have been compiled and the known or potential chemical use areas have been identified for the existing buildings and adjacent supporting infrastructure, inspections will be performed to (1) confirm and document the locations of known features, (2) identify undocumented features, and (3) evaluate the current condition of each visible or accessible feature. As requested by DTSC, photographs will be taken of every building, tank pad, and former building concrete foundation and additional photographs will be taken of exterior and interior perspectives of the building and the building features. For features located in buildings planned for demolition, a building feature documentation log will be completed for each feature, photographs of the feature will be taken at close range and at a distance giving perspective of the location of the feature in reference to its location within the building, and the location will be documented using a hand-held global positioning system (GPS) unit or by measuring from a reference point having known or measurable GPS coordinates, such as a building corner. The locations of concrete pad features, including cuts and stains, will also be identified and mapped. If a building or pad has no identifiable features, photographs will be taken to document the absence of features. Features that cannot be visibly inspected prior to building demolition (e.g., sub-grade pipelines) will be addressed as described in Section 4. Items that will be recorded during the building feature inspection include the following. Additional details regarding information to be collected are presented in Appendix A. Building feature location: RFI Reporting Group, RFI site name, and building number Feature Identification Number: Feature numbers will consist of the four-digit building number followed by a dash and a three-digit number (e.g., feature numbers for Building 4133 will begin with the designation ) STANDARD OPERATING PROCEDURES: BUILDING FEATURE EVALUATION AND SAMPLING-REV 1 2-2

10 2. EVALUATION AND INSPECTION OF EXISTING BUILDINGS Feature type (e.g., clarifier, equipment bay, pipeline [process, fuel, water, sewer, storm water], pump station, storage vault [chemical or radiological material], sink [process, sanitary], sump, tank, trench, floor drain, manhole, shaft, patch [i.e., unspecified removed feature] Construction material (e.g., metal, concrete, plastic, asphalt) Size (e.g., volume [gallons or length/width/depth], pipe diameter, pipe length) Operational use/process (e.g., conveyance; storage; containment of sanitary waste, industrial waste, water, or storm water) Open or closed system (i.e., any discharge?) Status (i.e., active, closed/inactive, removed) Associated chemicals, if any, including indications of chemical use based on signage Condition (intact, compromised)presence or absence of debris, odor, and staining Concentration of volatile compounds in ambient air within sub-slab features (e.g., sumps, drains), as measured using a photoionization detector (PID) GPS coordinates (vertical and horizontal), or measured distance from a GPS reference point SSFL facilities maintenance support personnel will be contacted to assist in understanding pipeline connections, discharge directions, and/or exit locations from the buildings if this information is not available in the historical record. If a feature contains water, attempts will be made to dewater the feature to allow inspection and documentation. If dewatering is not feasible, the depth to water in the feature will be measured periodically to see if leakage occurs. An inspection will be attempted for all subsurface features that are covered or closed including vaults, sumps, and manholes and notes will be recorded as to whether the feature was successfully inspected. Any prior samples collected adjacent to the feature as part of the RFI program will also be documented in the RFI reports. The building feature documentation log will also include the inspector s name, inspection date and time, responsible party (Boeing, NASA, or DOE), photograph identification number, and photograph orientation. Appendix A presents an example list of the information that will be collected during building inspections. A tabular list of feature identification numbers and GPS coordinates will be compiled for the information recorded during feature inspections for buildings to be demolished. Data gathered during the building feature inspections (Table A-1) will be included in the RFI reports and/or in RFI sampling and analysis plans as described in Section 5. Depending on historical site uses and observations made during the building inspections, samples may be collected inside and/or outside of the buildings prior to demolition as part of the ongoing RFI program (see Sections 3 and 4). If so, sampling information (sample number, depth, analyses requested, etc.) will also be recorded and included on the associated STANDARD OPERATING PROCEDURES: BUILDING FEATURE EVALUATION AND SAMPLING-REV 1 2-3

11 2. EVALUATION AND INSPECTION OF EXISTING BUILDINGS building feature documentation log for inclusion in the RFI report (Section 5). Recommendations for post-demolition sampling are also specified. Sampling rationale is detailed in Sections 3 and 4. STANDARD OPERATING PROCEDURES: BUILDING FEATURE EVALUATION AND SAMPLING-REV 1 2-4

12 3. Building Categorization The need to collect RFI samples at a building or adjacent supporting infrastructure will depend on whether there are associated chemical uses and/or impacts at or near the building. Sampling within or near a building will be performed only if it has been determined that chemicals have or might have been released, resulting in potential impacts to environmental media beneath a building foundation. This determination will be made based on the following: Indications of known or suspected historical chemical use in the building The detection of chemicals in environmental media above background concentrations or risk-based screening levels (RBSLs) in the area, if no known source of impact has been identified Other information gathered during the document review and/or building inspection Based on this information, each building will be placed into one of three categories: Buildings with no chemical use Buildings with chemical use and likely impacts to environmental media Building with chemical use and potential impacts to environmental media These building categories are described below. 3.1 Buildings with No Chemical Use If historical records indicate that no chemicals were used at a building throughout its entire history, and if there are no sumps, drains, process sinks, or other suspect features observed in the building or shown on historical building drawings, no sampling of environmental media will be performed, and a request for no further action (NFA) or deferred further investigation (DFI) will be documented in the RFI report along with rationale for the request and documentation regarding the absence of historical chemical use in the building (Section 5). NFA will be requested when the building is not planned for demolition, and DFI will be requested when the building is planned for demolition. In the latter case, the building will be inspected during demolition for evidence of potential impact, as described in Section 4, and if evidence of potential impact is identified, the building may be placed back into the RFI program for further evaluation. 3.2 Buildings With Chemical Use and Likely Impacted Environmental Media Features that are highly degraded or compromised and likely to have resulted in significant impacts to environmental media will be considered likely impacted. The potential for impact will be determined based on site documents (e.g., spill records), analytical data (e.g., STANDARD OPERATING PROCEDURES: BUILDING FEATURE EVALUATION AND SAMPLING-REV 1 3-1

13 3. BUILDING CATEGORIZATION a soil vapor or groundwater plume centered near the building, with no other release source identified), and building inspection results (e.g., highly degraded or cracked sumps where liquids would accumulate in the event of a release). Likely impacted areas consist of areas with degraded/compromised sub-slab features where liquids are likely to have accumulated (e.g., drains, sumps, laboratory sinks, manholes/shafts, vaults, trenches, etc. used to support chemical process operations) and one or both of the following: Known or suspected chemical uses Known or documented spills of liquids Buildings features that are likely to have associated environmental impacts will be sampled as described in Section Buildings With Chemical Use and Potentially Impacted Environmental Media Features that are not highly degraded or compromised and have a potential for releases but have no known environmental impacts will be considered potentially impacted. These will include the following: Buildings with intact sub-slab features and one or more of the following: o Known, suspected, or uncertain historical chemical uses o Known or documented spills of liquids o Nearby areas with environmentally impacted media and no other identified source o Portions of the feature are located below grade or within concrete, and their condition cannot be adequately assessed or observed Areas in which there are only minor visual or olfactory indications of possible impacts. For potentially impacted areas, building features should not display highly degraded or compromised construction material, processes and chemical uses should be considered minimal to moderate, and historical sampling data should not show a strongly increasing concentration gradient toward the building (with no other known source), otherwise the area will be considered likely impacted. Building features that have potential environmental impacts will be sampled as described in Section 4. STANDARD OPERATING PROCEDURES: BUILDING FEATURE EVALUATION AND SAMPLING-REV 1 3-2

14 4. Sampling and Analysis The purposes of the sampling and analysis program are to (1) evaluate the condition of environmental media in areas of likely or potential impact, and (2) characterize environmental impacts, if present. Following categorization of the buildings as described in Section 3, sampling locations and timing will be determined as outlined in Table 1, and analyses will be selected as described in Section Sampling and Analysis Criteria As discussed above, the need for sampling at each building will depend on historical chemical use, while sample locations and timing will depend on the demolition plans for the building. Once the likelihood of impact has been determined as described in Section 3, the sampling approach will be developed as outlined on Figures 1 and 2. For buildings that are not planned for demolition, sampling will be performed as indicated on Figure 1, and for buildings that are planned for demolition, sampling will be performed as indicated on Figure 2. Additional information regarding sample locations, timing, and analytical methods are discussed below Buildings Not Planned for Demolition Figure 1 shows the process for evaluating buildings that are not planned for demolition. As shown, buildings with no historical chemical uses will not be sampled. However, sampling will be performed at buildings with potential or likely environmental impacts. Sample locations are described in Table 1. Building features with likely environmental impacts will be targeted for sampling inside the building. Building features with potential environmental impacts will be targeted for sampling at the building exit points of the features (e.g., may include pipeline exit points, doors, loading docks). At a minimum, at least one sample will be collected from outside each side of the building. For buildings with potential environmental impacts, one sample will be collected inside the building beneath the building slab at the location most likely to have environmental impact. If a building has no specific chemical use areas or features, the inside sample will be collected at or near the center of the building. Likewise, if no chemical use is indicated for the building (i.e., if an area is considered to be potentially impacted as a result of known environmental impacts but no identified source), the inside sample will be collected at or near the center of the building Buildings Planned for Demolition Figure 2 shows the process for evaluating buildings that are planned for demolition. As shown, buildings with no historical chemical uses will not be sampled. However, sampling will be performed at building features with both potential and likely environmental impacts. Likely impacted locations will be sampled inside the building before demolition, and potentially impacted locations will be sampled (1) prior to demolition at feature exit points around the building, and (2) after demolition if warranted based on professional judgment. STANDARD OPERATING PROCEDURES: BUILDING FEATURE EVALUATION AND SAMPLING-REV 1 4-1

15 4. SAMPLING AND ANALYSIS The need for sampling will be evaluated based on building feature type, known or suspected chemical use, documented spills, etc. Samples will be collected from the soil directly below the suspect feature at the location most likely to have been impacted. Each building feature identified during the records review and site inspection (Section 2) will be inspected during demolition, and the need for sampling will be evaluated based on professional judgment, as discussed in Section 4.2. In addition to inspecting and sampling as warranted at known features identified during the document review and site inspection, sampling will be performed at unplanned locations if potential impact is identified during demolition. For example, if soil appears to be potentially impacted beneath a concrete pad feature such as a cut, a soil sample will be collected. Detailed inspection, evaluation, and sampling procedures are described below. 4.2 Field Activities Field activities will include inspection during building demolition, field screening for potential environmental impacts, soil sampling at planned locations, and sampling at unplanned locations if warranted based on field conditions. All field activities (headspace screening, soil sample collection, sample analysis, etc.) will be performed according to the standard RFI procedures described in the DTSC-approved RFI work plan, Health and Safety Plans (HSPs), Field SOPs, and Quality Assurance Project Plans (QAPPs), as well as any additional monitoring/field procedures required by the SSFL contractor implementing this work Field Inspection and Headspace Screening Based on discussions with the SSFL management and its contractors, demolition is expected to progress to a point where the building cladding walls and frames have been removed, leaving only the floor slabs and the surrounding asphalt or concrete pavement. A RCRA team representative will be notified that slab removal is imminent, and will be present onsite during all building foundation removal actions. Prior to demolition of the foundation, the building feature documentation logs will be reviewed for inspection points, GPS coordinates, and sampling requirements, if any. SSFL management will also notify DTSC at least a week in advance of the building foundation removal to give DTSC the option to be present. The floor slabs and pavement will then be broken and removed by the demolition contractor. Based on this approach to demolition, near-surface soil will be exposed almost exclusively during the removal of floor slabs, spread footings, and concrete or asphalt surface paving. However, indications of potential environmental impacts that are revealed as paving and broken concrete are removed could be obliterated quickly thereafter by subsequent demolition activities. Accordingly, the RCRA team representative will work as close to the concrete/pavement removal equipment as is safely possible. During the removal of floor slabs, surface paving, footings, and subsurface utilities, nearsurface soil will be inspected, and environmental conditions will be systematically evaluated. All features identified during the preliminary evaluation (i.e., building and concrete pad features, drains, etc., as described in Section 2) will be inspected, and general subsurface conditions will be logged and evaluated following slab removal. Once the soil has been STANDARD OPERATING PROCEDURES: BUILDING FEATURE EVALUATION AND SAMPLING-REV 1 4-2

16 4. SAMPLING AND ANALYSIS exposed, near-surface soil samples will be collected for headspace screening for volatile organic compounds (VOCs) using a calibrated PID. Samples for headspace screening may also be collected at randomly selected locations within each building footprint if appropriate based on historical chemical uses in the area. The spacing and locations of samples collected for headspace readings will be determined in the field based on professional judgment. Soil samples for headspace screening will be collected from at least 6 inches below ground surface (bgs) so that they are representative of in situ soil conditions. The PID readings, date, time, and location of soil samples collected for headspace screening will be logged according to standard RFI procedures. Soil beneath features exposed during concrete slab removal will be inspected for indications of potential environmental impacts, with particular attention at the building feature documentation points. Indications of potential environmental impacts include: Stained or discolored soils, Wet or saturated soils, Odors in ambient air, and/or Other previously unknown sub-slab features, such as wet subsurface utilities, sumps, or other features that might be indicative of past chemical use. If an indication of a potential environmental impact is noted, the SSFL remediation team will immediately alert the SSFL Demolition Project Coordinator, who will then notify the demolition contractor foreman and prime contractor. Once alerted, the contractor will be required to proceed with caution to minimize soil disturbance, thereby minimizing the mixing of potentially impacted soil with clean soil Soil Sampling and Analysis Samples will be collected at potentially impacted locations as described in Section In addition, areas with visual and/or olfactory indications of possible impact and areas with elevated headspace PID readings will be sampled to assess environmental site conditions at potentially impacted locations that are identified during demolition. Soil sampling will be performed as soon as it is possible to safely do so following the discovery of impact; that is, once the surface paving is removed and potential impact is identified, demolition activities will pause in the area until soil sampling is completed. Samples will be analyzed for the chemicals suspected to have been used in the building and additional chemicals if warranted based on field observations. Samples will be collected following RFI processes and/or any subsequently approved procedures Delineation Investigation and Removal Action Sampling If impact is confirmed based on laboratory results for samples collected around a building, the lateral and vertical extent of impact will be assessed to meet standard RFI requirements (i.e., delineation of the volume of impacted environmental media to within an order of magnitude, and identification of any additional potential chemicals of concern). This will provide sufficient information for RFI decision making. If RFI decision making is uncertain (e.g., multiple lines of evidence suggesting a possible release inside a building at a potential STANDARD OPERATING PROCEDURES: BUILDING FEATURE EVALUATION AND SAMPLING-REV 1 4-3

17 4. SAMPLING AND ANALYSIS source), then limited sampling at features with potential environmental impacts within the building footprint may be performed if feasible prior to demolition to complete RFI characterization. During the course of a delineation investigation, it may become apparent that impacted soil is present. In such instances, the impact may be proposed to be removed in its entirety, if localized (i.e., relatively small, incidental areas equal to or less than 25 cubic yards of material). If impacted soil is removed under this circumstance, one or more confirmation soil samples will be collected from the floor and/or walls of the excavation for verification purposes. The impacted soil removed from the excavation would be stockpiled or containerized and handled in accordance with applicable regulations. Any removal action will be documented in the appropriate report (Section 5) Feature Removal Documentation When buildings undergo demolition, the removal of features identified during the building feature inspection will be documented on a feature removal log. Items that will be recorded during the building demolition and feature removal include the following: Building feature location: RFI Reporting Group, RFI site name, and building number Feature Identification Number: Feature numbers will consist of the four-digit building number followed by a dash and a three-digit number (e.g., feature numbers for Building 4133 will begin with the designation ) Feature type (e.g., clarifier, equipment bay, pipeline [process, fuel, water, sewer, storm water], pump station, storage vault [chemical or radiological material], sink [process, sanitary], sump, tank, trench, floor drain, manhole, shaft, patch [i.e., unspecified removed feature] Condition of the soil beneath the feature (impacted, not impacted) o Impacted soil will be identified by the same criteria outlined in Section PID headspace reading Sample collection and analysis to be performed (based on recommendation from the preliminary building feature inspection or observations during feature removal) Comments including a written description of field observations and sketches of orientation and termination of subsurface features that are exposed during demolition activities Photographs will be taken during removal of each feature to document subsurface soil conditions beneath the feature. Specifically, photographs will be taken of any observed impacted soil during building demolition activities regardless of whether the soil is located beneath or adjacent to a feature. A map will be prepared after field activities are complete showing locations of all observed impacted soil. STANDARD OPERATING PROCEDURES: BUILDING FEATURE EVALUATION AND SAMPLING-REV 1 4-4

18 4. SAMPLING AND ANALYSIS 4.3 Analytical Methods Sample analyses will be selected consistent with the existing RFI approach, whereby samples are tested for chemicals that are suspected to be present based on historical site uses and current conditions. For areas with unspecified but suspected chemical use, samples will be analyzed for a standard list of screening analyses including VOCs, total petroleum hydrocarbons [TPH], semivolatile organic compounds - selective ion monitoring [SVOC SIM], PCBs, metals, and ph. Soil vapor samples will be collected for VOCs analysis if soil depth and building access allows. Soil matrix samples may also be collected for VOCs analysis depending on project requirements. For areas where the type of chemical use is documented, analyses will be selected based on known or suspected historical chemical uses, field observations, and the location of the impact. For example, dark staining and fuel hydrocarbon odors in a sample collected in or near fuel facilities area would trigger analysis for TPH. Depending on the resulting TPH concentration, analysis for SVOC SIM, polycyclic aromatic hydrocarbon (PAHs), PCBs, or VOCs may also be performed. Soil, soil vapor, and headspace sample collection and analysis will be performed according to the standard RFI procedures described in the DTSC-approved RFI work plans, HSPs, Field SOPs, and QAPPs, as well as any additional monitoring/field procedures required by the SSFL contractor implementing this work. STANDARD OPERATING PROCEDURES: BUILDING FEATURE EVALUATION AND SAMPLING-REV 1 4-5

19 5. Reporting Information collected during the building evaluation and sampling activities will be incorporated into the appropriate RCRA report, depending on when the buildings are evaluated and sampling is performed. Building feature information will be documented within the appropriate RCRA report or work plan either as building feature documentation logs and building feature removal logs for buildings that are planned for demolition, or within the context of the RFI report if the building is not planned for demolition. The building feature evaluation information will be included in RFI reports and/or RFI sampling and analysis plans. For buildings to be demolished, the building feature evaluation information will include building feature documentation logs, feature removal documentation logs, photographs associated with the feature inspection and removal logs, a tabulated list of feature identification numbers and GPS coordinates, and a site-wide figure showing all feature locations and RFI site chemical use areas. Reporting will be as follows: For RFI sites where buildings are demolished, building features are evaluated, sampling is performed, and data are received prior to preparation of the draft or final RFI report, the information collected will be incorporated into the RFI sampling and analysis plan and RFI report. If an RFI report has been finalized and the CMS has not been started, new information will be submitted in an addendum to the Final RFI Group Report. If contaminated soil was detected and not removed during building demolition, or if confirmation sampling indicates the presence of residual impacts, the additional information will be incorporated into the CMS recommendation for the RFI site, and the CMS work plan will be amended as appropriate. For RFI sites where (1) existing building areas are potentially impacted and (2) sampling data are limited to areas outside of the buildings, the RFI sampling and analysis plan and RFI report will acknowledge that additional inspection and/or sampling will be performed during/after building demolition. The RFI report will also state that any additional information collected during/after building demolition will be incorporated into the RFI process and submitted to DTSC for review once it becomes available. This condition will apply whether or not the building area is included in the CMS. If building evaluation or sampling results indicate that significant impacts are present, the RFI report may include CMS recommendations for the impacted areas beneath existing buildings. With respect to CMS recommendations, the report will also discuss any uncertainties resulting from the postponement of sampling within building footprints until after building demolition. STANDARD OPERATING PROCEDURES: BUILDING FEATURE EVALUATION AND SAMPLING-REV 1 5-1

20 5. REPORTING If building evaluation and sampling results indicate that there are no environmental impacts that contribute to unacceptable risk, and if the building is planned for demolition, then DFI will be recommended for the building for the RFI. Further inspection and/or sampling will be performed following demolition, and the results will be provided to DTSC as a RCRA report addendum or in a subsequent RFI report. If this situation occurs for a building with no demolition plans, then the report will request NFA for the RFI and document historical building conditions and current sampling results in the RFI report. For buildings with no historical chemical use, no documented or observed releases, no suspect building features, and no historical operational use prior to existing building construction, the RFI report will include a request for NFA. The report will document the historical record and rationale for the NFA request, along with sufficient information to clearly demonstrate that the request is justified. If building demolition is not planned and the sampling data and risk assessment results indicate no unacceptable risk, the report will include a request for NFA. The report will document the historical building use and rationale for the NFA request, along with sufficient information to clearly demonstrate that the request is justified. If a building is not scheduled for demolition and the sampling data and/or risk assessment results indicate that a significant impact is present, the RFI report may include CMS recommendations for the impacted area beneath the building. Information for existing buildings will be presented in the RFI report. This will include historical uses, inspection findings, sample results (if any), etc. STANDARD OPERATING PROCEDURES: BUILDING FEATURE EVALUATION AND SAMPLING-REV 1 5-2

21 TABLES

22 Table 1 Summary of Standard Operating Procedures for Building and Feature Evaluation Page 1 of 1 Building Status Standard Operating Procedures for Buildings and/or Features Building With No Chemical Use Building/Feature with Likely Impact to Environmental Media Building/Feature with Potential Impact to Environmental Media No potential chemical use documented in facility records or during building inspection (see Section 3.1 for details) Feature degraded and chemical use known or suspected at feature or nearby location (see Section 3.2 for details) Feature intact and chemical use known or suspected at feature or nearby location (see Section 3.3 for details) Demolition Not Planned Determine historical building and feature uses based on site records (Section 2.1) Inspect and document building and feature uses and conditions (Section 2.2) Verify that building vicinity has no known environmental impacts from unidentified source (Section 2.1) Collect no samples (Section 3.1) Document historical building and feature uses based on site records (Section 2.1) Inspect and document feature use and condition (Section 2.2) Collect samples beneath degraded features where there is a high likelihood of a release to the environment. (Section 4.1.1) Collect at least one sample outside each side of the building, with sampling locations placed near building openings and/or pipeline exit points, if any (Section 4.1.1) If impact is confirmed based on laboratory results for the samples collected around the building, assess the lateral and vertical extent of impact to meet standard RFI requirements (i.e., delineation of the volume of impacted environmental media to within an order of magnitude, and identification of any additional potential chemicals of concern) (Section 4.2.3) Document historical building and feature uses based on site records (Section 2.1) Inspect and document feature use and condition (Section 2.2) Collect one sample outside each side of the building, with sampling locations placed near building openings and/or pipeline exit points, if any (Section 4.1.1) Collect one sample inside building beneath the building slab at most likely location where chemicals were or might have been used (Section 4.1.1) If no chemical use is indicated, collect inside sample at or near center of building (Section 4.1.1) If impact is confirmed based on laboratory results for one or more samples collected around the building, assess the lateral and vertical extent of impact to meet standard RFI requirements (i.e., delineation of the volume of impacted environmental media to within an order of magnitude, and identification of any additional potential chemicals of concern) (Section 4.2.3) Demolition Planned Determine historical building and feature uses based on site records (Section 2.1) Inspect and document building and feature uses and conditions prior to demolition (Section 2.2) Verify that building vicinity has no known environmental impacts from unidentified source (Section 2.1) Observe and document subsurface soil conditions at building during demolition (Section 4.2.1) If staining is observed, odors are noted, headspace screening results indicate that soil may be impacted, and/or there are other indications of potential chemical use or impact, collect samples (Section 4.2.2) If no evidence of impact is noted, collect no samples. (Section 3.1) Document historical building and feature uses based on site records(section 2.1) Inspect and document feature use and condition prior to demolition (Section 2.2) Prior to demolition, collect samples within building at degraded features inside the building (Section 4.1.2) During demolition, observe and document subsurface soil conditions at feature to further assess subsurface conditions (Section 4.2.1) During demolition, using professional judgment, evaluate whether additional sampling is warranted given type of feature and chemical use, previous sampling results, soil staining/odor, etc. (Sections and 4.2.2) Document historical building and feature uses based on site records (Section 2.1) Inspect and document feature use and condition prior to demolition (Section 2.2) Prior to demolition, collect samples around building at exit points of potential release features (e.g., may include outside doors, in loading dock areas, where pipelines exit the building, etc.) (Section 4.1.2). During demolition, observe and document subsurface soil conditions at feature. (Section 4.2.1) During demolition, using professional judgment, evaluate whether sampling is warranted given type of feature and chemical use, previous sampling results, soil staining/odor, etc. (Sections and 4.2.2) STANDARD OPERATING PROCEDURES: BUILDING EVALUATION AND SAMPLING

23 FIGURES

24

25

26 Appendix A Building Feature Inspection Information

27 Appendix A Building Feature Inspection Information Information gathered during the building feature inspections will be recorded in the field primarily using hand-held personal computers or laptop computers. However, as a backup in the event that computer problems are encountered or weather conditions are such that hand-held or laptop computers cannot be used, the necessary information will be noted in a field log book or on a separate field form. Table A-1 presents the list of information that will be collected during the building inspections. This information will be included in the RFI reports as described in Section 5. For buildings planned for demolition, the information collected during the building inspections will be reported on a Building Feature Documentation Log. Certain items on the Building Feature Documentation Log require standardization and definition for clarity. The following is a list of the items, the standard terms used in each item, and the definition of the term as it applies to the building feature inspection. Status Active - Feature is currently being used for operations at SSFL. Closed/Inactive - Feature is not currently being used for operations at SSFL, but is still present. Removed Feature was removed from the location, but prior to removal was used for operations at SSFL. General Condition Intact - Feature is in a condition that is the same or nearly the same as the original condition, and no observable pathway exists for associated chemicals of concern to exit or discharge from the feature in a manner not originally intended due to the construction of the feature. A feature can be intact despite normal wear and tear due to operational and environmental conditions experienced during the lifetime of the feature. Compromised - Feature is in a condition such that the structural integrity of the feature has been affected, and exit or discharge of chemicals of concern are either observed or are believed to have occurred in the past based on professional judgment (visual observation of stains, residual oils, etc). Examples of compromises to features are cuts, cracks, breaks, loose joints and connections, and/or corrosion to the point of exposure to internal feature areas. NA Not applicable. STANDARD OPERATING PROCEDURES: BUILDING FEATURE EVALUATION AND SAMPLING-REV 1