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Alaska Gasifier Project Water Well Sampling Plan, December 1985
2291/524/1 ALASKA GASIFIER PROJECT Water Well Sampling Plan Submitted to: Environmental Protection Agency - Region X RCRA Compliance Section 1200 Sixth Avenue Seattle, Washington 98101 By: Department of Commerce and Economic Development Alaska Power Authority 701 East Tudor Road Anchorage, Alaska 99503 December 1985 December , 1985 Mr. William H. Chamberlain Environmental Protection Specialist RCRA Compliance Section EPA Region 10 1200 Sixth Avenue Seattle, Washington 98101 Dear Mr. Chamberlain: On October 28, 1985, Alaska Power Authority received a letter from Bonneville Power Administration requesting that we assume responsibility for water well testing on the Alaska Gasifier Project. A copy of Mr. Seely's letter is attached as Appendix I in the enclosed document. Mr. Seely's request was made as a result of your October 21 letter to Patrick Fox, suggesting that a sampling plan be developed prior to water well sampling. After reviewing available well log data and ground water information surrounding the spill site, we have selected test wells which -- we believe -- will provide the most representative test results. The basis for this selection is described in Appendix II of the enclosed document. 2291/524/4 We believe that Bonneville Power Administration has done a commendable job in removing soils suspected of contamination from the gasifier site. It is our concern that these water test results lay to rest remaining questions about the environmental impacts of this project. The water samples that will be taken upon EPA approval of this plan, were not funded in Alaska Power Authority's current year budget. For this reason, our financial participation in environmental testing will be limited to payment for labwork involving these 5 samples. We look forward to your letter approving our sampling plan and await your direction to proceed. Sincerely, Robert D. Heath Executive Director Enclosures as stated. PW/RDH/tg cc: Jack Gusmano, EPA, Anchorage Larry Dearborn, DNR, DGGS, Eagle River 2291/524/5 Bill Lamoreaux, DEC, Anchorage Jim Hayden, DEC, Anchorage Douglas Seely, BPA, Portland Patrick Fox, BPA, Portland Eugene Yonkin, Chemical and Geological Laboratories of Alaska Dave Trudgen, Environmental Field Officer, APA 2291/524/6 2291/524/1 ALASKA GASIFIER PROJECT Water Well Sampling Plan Submitted to: Environmental Protection Agency - Region X RCRA Compliance Section 1200 Sixth Avenue Seattle, Washington 98101 By: Department of Commerce and Economic Development Alaska Power Authority 701 East Tudor Road Anchorage, Alaska 99503 December 1985 2291/524/2 TABLE OF CONTENTS Cover Letter Background - Alaska Gasifier Project Sampling Plan Appendix I U.S. EPA Letter from William H. Chamberlain to Patrick J. Fox -- October 21, 1985 BPA Letter from Douglas B. Seely to Edwin L. Morris -- October 24, 1985 Appendix II Alaska Department of Natural Resources, Division of Geological and Geophysical Surveys -- Memo from Larry Dearborn to Pat Woodell -- December 9, 1985 Appendix IIT Well Log Data for Proposed Test Wells Appendix IV Subdivision Map of Affected Site Appendix V Alaska Department of Environmental Conservation -- Environmental Quality Monitoring and Laboratory Oper- ations Appendix VI Chemical and Geological Laboratories of Alaska, Inc. -- Quality Control Procedures Appendix VII Soil Test Results Appendix VIII Agency Review of Sampling Plan 2291/524/3 BACKGROUND Alaska Gasifier Project On October 24, we received a letter from Bonneville Power Administration (BPA) requesting Alaska Power Authority (APA) and Department of Environ- mental Conservation (DEC) assistance in water well testing. The request concerned a former state-federal wood gasifier project, which was managed by the now defunct Division of Energy and Power Development in the Alaska Department of Commerce and Economic Development. The Mitkof Wood Gasifier Project (1981-1985) was jointly funded by the U.S. Department of Energy and the State of Alaska. Over $1.1 million was spent on research and development work to fabricate a working model of a low-BTU gasifier. The project was conducted in a rented warehouse on Klatt Road near the 01d Seward Highway in Anchorage. Over the years, contractor, Marenco, Inc., apparently stored some 300-500 gallons of creosote water waste at the Anchorage work site, and buried additional creosote waste in the soil adjacent to the gasifier warehouse. State project managers were not aware of these activities at the time. Upon project conclusion, the Department of Commerce and Economic Devel- opment (DCED) transferred all interest in the gasifier project to BPA. 2291/524/7 Subsequently, this agency took full responsibility for project activ- ities. BPA dismantled the gasifier last winter and discovered the accumulated solid and liquid waste at the Klatt Road warehouse. Subsequently, BPA developed a cleanup plan, containerized soils suspected of contamination and shipped over 100 barrels of creosote affected water and soils out of state. After soils were removed, core samples were drilled directly over the outside spill site and analyzed for evidence of contamination. Cleanup work, drilling and testing were supervised by Crowley Environ- mental Services in Anchorage. Forty-two soil samples were taken to identify possible contamination. Soil test results (See Appendix VIII) were under EPA limits. 2291/524/8 ALASKA GASIFIER PROJECT Water Supply Wells Sampling Plan I. Selection of Water Wells Alaska Power Authority contacted Bill Lamoreaux, Environmental Supervisor at the Alaska Department of Environmental Conservation (DEC) in late October to seek assistance in identifying appropriate test wells for the Plan. Mr. Lamoreaux recommended we contact the Department of Natural Resources (DNR) to get an opinion on the direction of ground water movement in the subject area. In November 1985, we contacted DNR's Division of Geological and Geophysical Surveys (DGGS) for an opinion on this and a recommenda- tion on the selection of appropriate test wells. Alaska Power Authority also contacted the Division of Land and Water Management in the Department of Natural Resources to provide DGGS with indi- vidual listings on wells from water rights files. On December 3, Larry Dearborn, DGGS Hydrologist; Colleen Burgh, Department of Environmental Conservation, and Pat Woodell from Alaska Power Authority met to discuss Mr. Dearborn's evaluation of ground water flow and recommendations on possible test wells. 2291/524/9 Using information presented by Mr. Dearborn, Pat Woodell contacted four agencies to obtain more specific information on individual wells: 2) 4) 2291/524/10 Municipality of Anchorage, Anchorage Water and Waste Water Utility, Treatment Division - Robert LeVar. It was determined that Municipality of Anchorage wells and water lines did not serve residences or commercial facilities in the subject area. We could, therefore, use private wells in our sample without concern of city water from adjacent wells being mixed with private well water. Municipality of Anchorage, Property Appraisal Office Wells in the area recommended for testing were identified to determine whether wells they are actively being used. Department of Environmental Conservation - Jim Hayden, Jim Allen. Well log records in areas recommended for testing were copied and well depths studied. U.S. Geological Survey, Water Resources Division - Pat Strelakos. Well log records in areas recommended for testing were copied and well depths studied. Meanwhile, Mr. Dearborn completed his evaluation of the subject area. His recommendations are presented in Appendix II of this Sampling Plan (memo dated December 9, 1985). Based on these recommendations, and discussion with all agencies concerning well depths, the following wells were selected: <TO BE DESCRIBED UPON VERIFICATION OF CURRENT USE AND PERMISSION TO TEST> 1) Up gradient Well 2) Down gradient well -- Angelus #2 3) Angelus #3 4) Well in Area A 5) Well in Area B It was agreed by all concerned that a shallow well up gradient from the subject site should be used to provide a background sample for the test. The two, shallow Angelus Memorial Park Wells were considered key because of their close location down gradient from the spill site. 2291/624/11 Well logs for the five wells selected for testing are presented in Appendix III of this Sampling Plan. A sub-division map in Appen- dix IV marks locations of the proposed test wells. II. Field Sampling Water sample collection will be performed by Jim Hayden, Environ- mental Field Officer, Supervisor of Alaska Department of Environ- mental Conservation, Western District Office. Pat Woodell from Alaska Power Authority will provide complete logistical support for field activities, and witness custody forms. Chemically clean containers in cooler pack kits will be obtained form Chemical and Geological Laboratories of Alaska, Inc. on the morning the water samples will be collected. The laboratory will prepare two cooler pack kits containing five containers each for each well to be tested. One set of samples for each well will serve as a backup for the actual samples tested. Backup samples will be stored under refrig- eration at the laboratory named above for a period of 30 days from the date test results are issued. Water samples will be taken from residential and commercial wells identified in Section I of this Plan. Procedures described in Appendix V, “Alaska Department of Environmental Conservation -- 2291/524/12 Environment Quality Monitoring and Laboratory Operations," will govern activities in this portion of the Plan. A Chain-of-Custody form will be completed for each group of five samples taken at each site. One set of water samples taken at a down gradient well will be split to provide a quality check on laboratory test results. Completed laboratory samples will be delivered to Chemical and Geological Laboratories of Alaska Inc., on the same day that they are collected. Mr. Eugene T. Yonkin, Laboratory Director, will receive a copy of the EPA approved Sampling Plan and will be responsible for overseeing the performance of tests. III. Laboratory Testing In accordance with EPA's letter to Bonneville Power Administration (Appendix I), the laboratory will perform tests on the following parameters: PARAMETER | DETECTION LIMIT RANGE (ppb) | pH cr Conductivity (umhos/cm) | s---- TOC | < 20 2291/524/13 TOX | < 10 Volatile Organic Scan | < 10 (GC/MS )* | Fe | <1 cd | <1 Pb | <1 Ba | <1 *includes benzene, chlorobenzene, ethylbenzene, dichloromethane, toluene, acetone, 2-butanone, 2-hexanone, styrene, and total xylenes. Handling and testing of water samples will be conducted in accor- dance with Chemical and Geological Laboratory's Quality Control Procedures presented in Appendix VI of this Sampling Plan. Volatile Organic Scan (GC/MS) will be performed by Lauk's Labora- tories in Seattle, Washington. All other tests will be conducted by Chemical and Geological Laboratory in Anchorage, Alaska. IV. Test Results Completed test results will be sent from Chemical and Geological Laboratories of Alaska, Inc. to Alaska Power Authority. Alaska Power Authority will distribute copies of results and chain of custody logs to the following agencies: 2291/524/14 1) EPA Region 10, Seattle, William H. Chamberlain 2) EPA, Anchorage, Jack Gusmano 3) DNR, DGGS, Larry Dearborn 4) DEC, Bill Lamoreaux 5) DEC, Jim Hayden 6) BPA, Douglas Seely 7) BPA, Pat Fox 8) APA, Dave Trudgen Test results will be maintained in Alaska Power Authority's Gasi- fier Project File, which will be archived in Juneau, Alaska. 2291/524/15 APPENDIX I U.S. EPA Letter from William H. Chamberlain to Patrick J. Fox -- October 21, 1985 BPA Letter from Douglas B. Seely to Edwin L. Morris -- October 24, 1985 2291/524 U.S. ENVIRONMENTAL PROTECTION AGENCY REGION 10 Ss 1200 SIXTH AVENUE SEATTLE. WASHINGTON 98101 OCT <1 1985 REPLY TO x? SNF. M/S 533 Sw ge 9,9 aU\” Patrick J. Fox — ©. Generation Engineering eo Routing EPG Box 3621 Portland, Oregon 97208 Dear Mr. Fox, As a follow-up to our telephone conversation of October 18, 1985, this correspondence fulfills your request for additional information regarding sampling and analysis of water supply wells in the vicinity of the Alaska Wood Gasifier Development Site. Suggested parameters and detection limits for sampling and analysis of local domestic and commercial water supply wells are listed in Table 1. 7 Table 1 Suggested Parameters and Detection Limits for Water Supply Well Sampling (ppb) Parameter Detection Limit Range (ppb) pH as Conductivity (umhos/cm) - -- TOC <20 TOX <10 Volatile Organic Scan (GC/MS)* <10 Fe <1 Cd <1 Ph - <1 Ba <1 *Volatile Scan should include those compounds listed as waste analysis parameters in our letter of October 17, 1985. Sample results will depend greatly on the particular matrix sampled, the physical methods used to sample wells, and other ambient physical factors. It is recommended that a sampling plan detailing sampling procedures, QA/QC measures, and sample custody be developed prior to sampling the wells. NOTE TO READERS: Volatile organic scan referred to in EPA's Octoker 17 letter includes benzene, chlorobenzene, ethylbenzene, dichloromethane, toluene, acetone, 2-butanone, 2-hexanone, styrene, and total xylenes. 2 If there are any further questions regarding this letter or other correspondence, please contact me at FTS 399-1886. Sincerely, Ma ae ES ais aee William H. Chamberlain Environmental Protection Specialist RCRA Compliance Section EPA Region 10 Department of Energy RECEIVED BY Bonneville Power Administration ALASKA POWFS AUTHORITY P.O. Box 3621 Portland, Oregon 97208 85 OCT 28 P3 :29 October 24, 1985 In reply reter to: EPG Mr. Ed Morris Associate Executive Director of Planning Alaska Power Authority 334 West 5th Avenue Anchorage, AK 99501 Dear Mr. Morris: As you are aware, the close-out of the Alaska Gasifier Project has been frought with many difficulties, the latest of which has been the clean-up and removal of the potentially hazardous gasifier waste from the site. As such, we have attempted to keep Ms. Pat Woodell of your staff apprised of relevent events as they have occurred. The last round of laboratory tests conducted on the soil coring samples taken after Crowley Environmental Services cleaned the area, where project waste had been land filled, indicated no evidence of the suspect waste elements or com- pounds. Therefore, it is our position that the site is free of any residual gasifier-related waste. As of this date, our accumulated expenditures for environmental site clean-up total approximately $135,000. The Environmental Protection Agency (EPA) would like laboratory analysis of domestic water supply wells in close proximity to the former gasifier site. We are hereby requesting that your office, in cooperation with the State of Alaska, Department of Environmental Conservation, assume responsibility for the collection, handling, and testing of water samples, at no expense to the U.S. Department of Energy. We request that local groundwater supply wells be sampled and analyzed consistent with EPA testing requirements and the enclosed EPA request. As program managers for the U.S. Department of Energy, we are anxious that these tests be conducted at the earliest possible date so that this project may be brought to conclusion. Your attention to these tests would be greatly appreciated. For additional background/details, please do not hesitate to contact me at (503) 230-4523 or Mr. Patrick Fox (503) 230-3449. si rely, Douglas B. Seely, Chair Pacific Northwest and Al Utilization Task Force Enclosure co: Pat Woodell.,;- APA, Anchorage Colleen Burgh - ADEC Jim Dwight - CES Charles Rice - EPA, Seattle Bill Chamberlain - EPA, Seattle Jack Gusmano - EPA, Anchorage BPA, Environmental Manager's Office - SJ APPENDIX II Department of Natural Resources Division of Geological and Geophysical Surveys Memo from Larry Dearborn to Pat Woodell -- December 9, 1985 2291/524 MEMORANDUM State of Alaska DEPARTMENT OF NATURAL RESOURCES nile DIVISION OF GEOLOGICAL & GEOPHYSICAL SURVEYS TO: PAT WOODELL DATE: 12+ iY Alaska Power Authority ALASKA CEIVED BY oRITY FILE NO: TELEPHONE NO: “Sf {GE5$3 Pi 16 From: LARRY DEARBORES<—> susvect: Ground-water information Hydrologist pertaining to the Mitkof Wood Gasifer Project As you requested at the December 3, 1985, meeting on the above subject, I am herein providing ground-water data for an area encompassing the creosote spill, along with my estimation of ground-water flow and other information pertinent to assessing possible contamination. Prior to your contact, I had not studied the hydrogeology of this area in any detail. The following information represents that which is available in the DGGS/USGS databank, and was not complemented or verified by field work. Attachment A shows the locations of water wells listed in the databank that are less than 105 ft deep (a convenient cut-off depth). About half as many deeper wells are known to exist, but considerably more wells, shallow or deep, might exist for which records are not available in our files. Most of the wells shown tap an aquifer lying 70 to 90 ft below land surface. A few drilling logs note that a small inflow of water occurred as drilling proceded through the 30 and 40 ft depths. Drilling logs of most, but not all, of these wells indicate 5 or more ft of low permeability materials were penetrated. However, the upper 30 to 40 ft was predominantly logged as sand and gravel. One of the Angelus Memorial Park wells (designated as #2 in Sec. 19) is reported as perforated at 30 ft below land surface even through the well was drilled to over 200 ft. This well is approximately 700 ft southwest of the spill locality. The exact direction of ground-water movement in the subject area is unknown. However, using a 1974 U.S. Geological Survey Open-File Report titled “Water-table contour map, Anchorage, Alaska", a general westward flow direction is indicated (see. Attachment B). The water-table contours are based on the altitude of reported water levels in wells that just penetrate shallow ground water. As a co-author of this map I believe that it is the 30 to 40 ft depth zone in the Klatt Road area that was used in construction of this map. If water levels of the 70 to 90 ft aquifer had been used, very little difference in flow direction probably would result. Several known inaccuracies involved in compiling the USGS map plus the unknown effect of pumping since 1971 (date of compilation) are causes for caution when delineating the current direction of ground-water flow. The water levels are mostly those reported by drillers, who commonly give estimates instead of measurements, and furthermore represent various years and seasons. Altitudes of the well heads were not surveyed to a common datum; instead a 20-ft contour topographic map was used. The locations of some wells were (and still are) not known with desirable accuracy. With the above uncertainties, the direction of flow might be anything between northwest and southwest, but it is Page 2 Memo to Woodell 12-9-85 unlikely to be outside this sector. If levels in four or five wells were measured on the same day and the measurement reference points of each surveyed to a common datum, the actual direction of flow could be determined. With the present status of knowledge, a sampling strategy should include wells in an arc extending from northwest of the spill to southwest of the spill. Implementation of this plan will increase the odds of intercepting a downgradient plume of contaminated ground water, if any is present. Considering the array of known wells shown on the illustration, it seems logical that water from the following sites be sampled: upgradient location 1. Nieffer well USGS# SB12-3-19-31 open-end casing at 70 ft downgradient locations 2. Angelus #2 well USGS# SB12-3-19-2 perforated casing at 30 ft Angelus #3 well USGS# SB12-3-19-3 perforated casing at 75 ft PP WwW a well in “area A", if aquifer tapped is less than 100 ft deep 5. awell in “area B", if aquifer tapped is less than 100 ft deep Driller's logs of the first three wells listed above should be available at the U.S. Geological Survey Water Resources office at 1209 Orca Street, Anchorage. Good luck to you in obtaining samples, and please let us know the results. LLD/jlw Attachments cc; Colleen Burgh, DEC «ses "ne Zo 82 water well wets deott S higheat- e vation, ©) 3% Yeported spi focal, ATTACH MENT WATER-TABLE CONTOUR MAP ANCHORAGE AREA, ALASKA By Larry L. Dearborn and Geoffrey W. Freethey OPEN-FILE REPORT 1974 Prepared by the U.S. Department of the Interior, Geological Survey, in cooperation with the City of Anchorage and the Greater Anchorage Area; Borough. This map shows contours of the water table in the Anchorage area. The water table is the surface of an unconfined ground-water body, and in the map area generally lies within 30 feet of the land surface. The water- table contours shown are based on the altitude of the water level in wells that just penetrate the water body. Water-level measurements used to pre- pare this map were made from 1955 to 1973. Seasonal fluctuation of the water table, which normally ranges between 1 and 4 feet, was not con- sidered significant with respect to the contour interval used; therefore, no corrections were made. Modified from unpublished water-table contour maps by W.W. Barnwell, and J. Reeder. q EXPLANATION Sarl) a Water-table contour, dashed where uncertain. --80 Contour interval 20 feet (6 meters) Datum is mean sea level SCALE 1:24, 000 0 1 5 0 1 KILOMETER Contour interval 20 feet Dotted tines tepresent 10 foot contours Datum is mean sea level Depth curves and soundings in feet datum is mean lower tow water Shoreline shown represents the approximate line of mean high water The mean range of tide is approximately 27 feet Base map from U.S. Geological Survey, Anchorage and vicinity, Alaska, 1: 24,000, \ ' \ ' \ po heeator this report Bora Ty ALASKA 6S 69! 0S or! APPENDIX III Well Log Data for Proposed Test Wells 2291/524 AKRG 0958> _ FORM NO 9-1904— A site noz SR 12-319 DAA DISS FF U.S. DEPT. OF THE INTERIOR GEOLOGICAL SURVEY Recorded by 2 n WATER RESOURCES DIVISION Dote =e 9=— GROUND WATER SITE INVENTORY SITE SCHEDULE C “ Check One —— Enginn —— Metric Units GENERAL SITE DATA (0) su tot nolo OOS SNES. ETOT —— a Odd, delete, modity, verified Data ae ve Lez] ee cotenter. Grin, inthote, connecter, tate, ee Hl 8 ‘checked, ee location not, minimal accurate date t| CT nee TOE) tee TOE] a (= Toa.c) 2 sy CLGIOGSSE) mel DRS) bl Ot sh a dey min wee doen we OCKmo depression, stream, dunes, Hat, hilltop, sink, wwamp, offshore, pediment, hillside, terrace, undulating, valley, upland == 141AINC HORA i ! : Method of ER [w]e ie «© we te ty vw To) trons, [0-11 2050.00 DE) ; | channel tat ow | | | Dete of First || SAMGQOOO7TASAL FG ee we J 5 month dev site ‘anode, drain, geo. selamic, heat, observ. mina. oll or, recharge, repress, test, unused, with. waste, destroyed ther met revere ation, oe drawal, : ee an ae [ze-] a 8 c o € r @) ' N ° R s T vussY¥ 2 iG sir Cond. bottling, commercial, dewater, power, fire, domestic, irrigation, medicinal, industriel, public, recreation, stock, institution, unused, desal, other supply sem Gel) nee bee Geo Piel oF) sesh worer Lover L329"! 4 mt hOverm inl} Oote Messured |? * 99/0,0/\9,54|* source 33-[pJ+ month Fi _ = Method of Measurement (24°) 4 ¢ . . = a) sy ve iY errtine, caltrated, extimated. premure, calitrated, geophyscel, manometer, 1: ted, steel, electric, calierated, other ealoe (9 premuregege = fogs tape tape electre tape - — . 3 aw snesum L220 FG 4 6 P RSs tT Ov x z {s} ey. Howing, nearby, ceerby, obstruction, pumping. recently, nearby, Sanrby. foreqn srfece water other towing — recentty, Pumped pumping fecently wbstence effects Nowe pumped Source of a al Measuring) o66. | Py] Measuring (E02 “7 ig] Geeneervtegis One 12° rome ines 35 : Point 266: ou l*! fer oee mar — i ieee ne mont dey veer OWNER IDENTIFICATION (1) eve) om ms} Ownership 244, delete, modity nome: unt LIS INERT] OTHER SITE IDENTIFICATION NUMBERS (1) [n= +09]*] G-1é) oT] ident 190 #103 wl eel s|ra add, delete, modily New Gard Some R&T rae 2° DAS BA 1) an - UN CONSOL NE” SW FOR MATIC“) SITE VISIT DATA (1) 163= * Initiat ate of R-1861*] tela o mie] Cera 7 /_.,, | 04 ON LVECLCS LUCL 244. delete, modity month day veer FIELO WATER QUALITY MEASUREMENTS (1) ; StU if aot] GH) owl) yf 0772071910) bt Pets 244, delete, modily month day ver om eT... FORMIYT OR wmolml as THE FOR/AT On THE Felounnse /4& PAGES New Card Same Rh 195 FOOT NOTES @ Source of Data Codes SO 12-3-17- DAAD /-3/. 9-063 UNITED STATES aarnnaiied DEPARTMENT OF THE INTERIOR GEOLOGICAL SURVEY No. TOE Le WATER RESOURCES DIVISION CI TOO cestnresenerrstn ciara ccesiserslolge = WELL LOG State ___ —_—— County Subarea epee eel Owner ile EE f= Location _. Va f L: Z liege o eee! x es Sette viol Be Drilled by lei lee eee Addams fo Pill Date Casing diam. Lendé-ourf. alt. Source of data ____. a 7 (Enter type of well, perforations, yield, and drawdown at end of log) CORRELATION MATERIAL =" ttoth . UIT BILL Lt ee et VINES ELL 2e)| Ze... “pe oe a ae Ang APPENDIX IV Sub-Division Map of Affected Site 2291/524 ais I 9 way | | n | | « | : | TRA ¥ | G | Y | ° | —— | S Ie me ae R 10 1 s v i oO 3 e Z ae * 3 A , e. " j/> 5 e walQS 2 5 SS marr 4 . le 124 se | 0 | ; ze) | 19¢ > o T.. | {18 | 7 | 16 eg, : 3 8 rm Eanes | j i ies )— se | wo | cbentea’cr' | fo] hel Fe Fs ANGELUS.-- MEMORIAL 26 1 1 PARK CEMETERY ly anoneoty Bt [ass | 30 z 19 o rs | $214 try [*}9-"]5| ocegnview In 5 Aid [she al 1, SCHOOL SITE | te £ aC e | E BT) teed bc! aT Lil [eet Pie SesoR pane i s | ye 1c 76 —{ re} a) rm : 10 |>L.0} © \uge| re — a | Teta ; wt] 9 hoa) The oP L es /, a hist ral Qe o1 sT || 2iei Heggope rae | Mee Int) YN 4 > 24 <@> 26 S< 2291/524 APPENDIX V State of Alaska Department of Environmental Conservation Environmental Quality Operations Environmental Quality Monitoring and Laboratory Operations April 1982 oo CHAIN-OF-CUSTODY The following procedures have been used successfully, and are Presented as suggested procedures insofar as they fulfill the legal requirements of the appropriate State legal authority. Procedures Quality assurance should be stressed during all compliance monitoring and when reviewing self-monitoring programs, no matter what the reason for the spot check or inspection. Successful implementation of a compliance monitoring program depends heavily on the capability to produce valid data, and on clearly demonstrating such validity. No other environmental monitoring area requires more rigorous adherence to validated methodology and quality control measures. It is imperative that laboratories and field operations involved in collecting primary evidence prepare written procedures. These procedures should be used whenever evidence samples are collected, transferred, stored, analyzed, or destroyed. A primary objective of these procedures is to create an accurate written record which can be used to trace possession of the sample from the time it is collected through its introduction into evidence. Preparing Samples The evidence-gathering portion of a survey is characterized by an absolute minimum number of samples required to give a fair representation of the effluent or water body sampled. The quantity and location of samples are determined before the survey. Prepare chain-of-custody record tags before actual field survey work. Ensure tags contain all possible information to minimize clerical work by field personnel. Also write the source of each sample on the container before starting any field survey work. Field logsheets used to document field procedures and chain- of-custody, and to identify samples, should be pre-filled to the extent practicable to reduce repetitive clerical field entries. The sampler or project leader should maintain custody during sampling, using the logbook. Any information from previous studies should be copied (or removed) and filed before the logbook is returned to the field. Follow explicit chain-of-custody procedures to maintain the documentation necessary to trace sample possession from the time the sample is taken until the evidence is introduced into court. A sample is in your custody if: \V-6 a ( + ¢ Itis in your physical possession; or a2 9 Chie.” St * It is in your view, after being in your physical possession; or ge * It was in your physical possession and you locked it in a ; transfer-proof container or storage area. All survey participants should receive a copy of the study plan and should be familiar with its contents before the survey begins. A pre-survey briefing should be held to inform all participants of the survey objectives, sample locations and chain-of-custody pro- cedures. After all chain-of-custody samples are collected, a de- ‘ briefing should be held in the field to verify that chain-of-custody procedures have been followed, and to determine if additional evidence samples are required. Collecting Samples 1. Ensure that the smallest possible number of people handle the sample. 2. Obtain stream and effluent samples using standard field sampling techniques. When using sampling equipment, assume it is in the custody of the source being sampled. 3. Attach chain-of-custody record tag to the sample container when the complete sample is collected. Ensure the container has the following information: sample number, time taken, date taken, source of sample (include type of sample and name of firm), preservative, analyses required, name of person taking sample, and witnesses. The front side of the card (which has been prefilled) is signed, timed, and dated by the person doing the sampling. Tags must be legible and filled out in ballpoint (water-proof ink). Secure individual sample containers or group of sample containers using a tamper-proof seal. 4. Take blank samples. Include one sample container without preservative, and containers with preservatives. The laboratory will analyze these contents to verify if any containers are contaminated. 5. Maintain an up-to-date Field Data Record Logbook. Record field measurements and other pertinent information necessary to refresh the sampler’s memory if, later on, he ae. takos tho stand to tostify regarding his actions during the nentong evidence-gathering activity. Maintain a separate set of field sbo notebooks for each survey; store them in a safe place where they can be protected and accounted for at all times. IV-7 Standard formats have been established to minimize field entries; these include the date, time, survey, type of sample taken, volume of each sample, type of analysis, sample number, preservatives, sample location and_ field measurements (temperature, conductivity, DO, pH, flow), * and any other pertinent information or observations. The field sampler signs the entries. The survey coordinator is usually responsible for preparing and conserving the field logbook during the survey. Once the survey is complete, field logs will be retained by the survey coordinator or his designated representative, as a part of the permanent record. . The field sampler is responsible for the care and custody of the collected samples until they are properly dispatched to the receiving laboratory, or turned over to an assigned custodian. The field sampler should verify that each container is in his physical possession or in his sight at all times, or is locked so that no one can tamper with it. . Colored slides or photographs are often taken to show the outfall sample location and any visible water pollution. Written documentation on the back of the photo should include the photographer's signature, and the time, date, and site location. These photographs can be used as evidence, and are handled by chain-of-custody procedures to prevent alteration. Transfer of Custody and Shipment 1. When transferring the possession of samples, the transferee a signs, dates, and times the reverse side of the chain-of- custody record tag or record. Custody transfers, if made toa sample custodian in the field, are made for individual samples. The chain-of-custody tag or card must be dated and signed by the second person who takes custody. If a third person takes custody, he must follow the same procedure. An additional chain-of-custody tag or card is completed by persons who thereafter, take custody. It is apparent, from this chain, that the number of custodians should be minimal. Additional tags or cards should be numbered consecutively. . If a custodian has not been assigned, the field custodian or field sampler is usually responsible for properly packaging and dispatching samples to the proper laboratory for IV-8 wn ee ee eee we ger ttn a analysis. In that case, the ‘Dispatch of Sample” portion of the chain-of-custody record tag or card should be properly filled out, dated, and signed. 3. Ensure that samples are properly packed in shipping containers (for example, ice chests) to avoid breakage. Ensure that shipping containers are padlocked for shipment to the receiving laboratory. 4. Include a “Sample Transmittal Sheet” with all packages. The original, and one copy generally accompany the shipment. Mail copies directly to the laboratory, to data management personnel, and to any other responsible agent. The survey coordinator usually retains one copy. 5. If the package is sent by mail, ensure that it is registered with return receipt requested. If package is hand-delivered, record delivery in the logbook. Send receipts from post offices and bills of lading to the laboratory custodians for retention as part of the permanent chain-of-custody docu- mentation. 6. When samples are delivered to the laboratory, and appropriate personnel are not there to receive them, samples should be locked in a secure, tamper-proof area. The same person must unlock the samples and deliver custody to the appropriate custodian. Laboratory Custody Procedures The following procedures are recommended by the EPA's National Enforcement Investigation Center, and are suggested to the State insofar as they comply with the State's statutory and regulatory requirements. 1. The laboratory director will designate one full-time employee (usually the laboratory supervisor) as a sample custodian, and one other person as an alternate. In addition, the laboratory must provide a sample storage area that is secure. This is a clean, dry, isolated room which can be securely locked. 2. All samples will be handled by a minimum possible number of persons. 3. Only the custodian will receive incoming samples. If he is abaent, the allarnate will indicate roceipt by signing tho Saiple llansmillal sheets and, (as appropriate), the sample tags which accompany the samples. The alternate will retain the transmittal sheets as permanent records. IV-9 Sample Custodian; Environmental Technician { ' } Analyses completed Summary results Alaska Dept. of Environmental Conservation Douglas Laboratory Facility Tia cals eat 4 ares aL Volume of sample remaining Bidens las Lila e oe [ ] No { ] Yes Disposition of unused portion Signature Inspector's Seal Intact Analyses completed Volume of sample remaining Summary results } { ' 1 j _L Alaska Dept. of Environmental Conservation Sample Custodian; Environmenta) Technician Douglas Laboratory Facility Pouch OL, Mail Station 1801 Technical Services Section Douglas, Alaska 99824 State of Alaska Department of Environmental Conservation Chain-of-Custody Log Use one log for each sample. Enclose with shipping container. The last person whose signature appears on this log certifies he/she has received the sample described below from the person whose signature im- mediately proceeds his/hers, and is according the sample proper custody by maintaining it in his/her physical possession or constant view or by storing in a secure tamper proof storage area. Transfers must be hand- to-hand, by registered mail, or other tamper proof means. Sample No. Assigned Laboratory No. Sample description Container description Location taken Latitude Longitude Person taking sample Signature Title Agency Date collected Time collected Witness Signature Witness i Signature 1. Transferred to via For purposes of Date Time Received by Signature Disposition 2. Transferred to . via _—$ $ — For purposes of. Date : Time Received by Signature Disposition ee APPENDIX VI Chemical and Geological Laboratories of Alaska, Inc. -- Quality Control Procedures 2291/524 CHEMICAL & GEOLOGICAL LABORATORIES OF ALASKA, INC. ¢ P.O. BOX 4-1276 TELEPHONE (907) 562-2343 ANCHORAGE t#ORSTRIAL CENTER Anchorage, Alaska 99509 "ALAS 5633 B'StREeRITY 9 © mega November 25, 1985 Pat Woodell Alaska Power Authority 334 W. 5th Ave., 2nd Floor Anchorage, Alaska 99501 Dear Pat, Enclosed is a copy of Chemical and Geological Laboratory's Quality Control. If you have any questions, please contact me. 7; Were Hew Pre Eugene ‘P. Yonkin ETYYkmb CHEMICAL & GEOLOGICAL LABORATORIES OF ALASKA, INC. J P.O. BOX 4-1276 TELEPHONE (907) 562-2343 ANCHORAGE INDUSTRIAL CENTER Anchorage, Alaska 99509 5633 B Street CHEMICAL & GROLOGICAL LABORATORY 'S QUALITY CONTROL Uf P.O. BOX 4-1276 TELEPHONE (907) 562-2343 ANCHORAGE INDUSTRIAL CENTER ToNes Anchorage, Alaska 99509 5633 B Street Chemical & Geological Laboratories of Alaska, Inc. ‘is certified~ ~~ by the Alaska Dept. of Environmental Conservation for the analysis of Drinking Water in the area of: Inorganic Chemicals Organic Chemicals Physical Contaminants Microbiological Analysis This Certification is done in accordance to EPA Regulations, which includes an on-site evaluation. of..the laboratory. by ADEC annually to insure equipment, personnel and laboratory techniques are in accordance with the EPA guidlines. Also unknown check samples are submitted to the laboratory by EPA for analysis and results of these are evaluated by EPA and must fall in the acceptable ranges of analytical performance. Chem Labs has been inspected, evaluated and is a member of the American Council of Independent Laboratories. Chem Labs is a member of A. S. T. M. (Voting), Spectrometric 0i1 Analysis Laboratory Association and the Society of Applied Spec- troscopy. EN CHEMICAL & GEOLOGICAL LABORATORIES OF ALASKA, INC. BSB P.O. BOX 4-1276 TELEPHONE (907) 562-2343 ANCHORAGE INDUSTRIAL CENTER Anchorage, Alaska 99509 5633 B Street RECEIPT AND LOGGING OF SAMPLE The Sample_is inspected at time of receipt for condition of sample and sample seal if any. Information on sample and seal is recon- ciled against information on chain of custody record (if chain of custody is applicable) and any descrepancies noted. A work order is written and lab number from work order is placed on container. All information on sample tag is retained on work order. The analysis required is logged on work order and sample. Work sheets filled out where appropriate. The samples are inspected for leaks, damage, etc. and these are noted-on -work- orders: ° Samples in plastic which the walls of the container show pressure build-up are noted on work order and containers are labelled with a "Caution" so that the sample will be handled as potentially dan- gerous. The. samples with a chain of custody are stored in a secured sample storage unit until analysis is performed. The routine samples are given to the appropriate departments and the supervisors assign the samples for analysis. Routine samples not being analyzed are stored according to sampling and handling requirements. P.O. BOX:4-1276 Anchorage, Alaska 99509 TABLE SUMMARY OF SPECIAL SAMPLING OR HANDLING REQUIREMENTS _ X IMUM SAMPLE . STORAGE SIZE : RECOMMENDED/ JETERMINATION CONTAINER mL PRESERVATION REGULATORY acidity P, G(B) 100 Refrigerate 24 h/14 d Alkalinity P,G 200 Refrigerate 24 h/14 d D P,G 1000 Refrigerate 6 h/48 h -2ron P 100 None Required 28 d/28 d sromide P,G wee None Required 28 d/28 d irbon, organic, total G 100 Analyze immediately; or refrigerate 7 d/28 d and add H2S04 to pH <2 varbon dioxide P,G 100 Analyze immediately --/-- a) ) P, G 100 Analyze as soon as possible, or add 7 d/28 d HaS0q4 to pH <2 ‘niorine, residual P,G 500 Analyze immediately 0.5 h/2 h “‘hlorine dioxide - -- P, G- 500 --- Analyze-immediately ~~ 0.5 h/2 h \lorophy11. - P, G 500 30 d-in dark; freaie = 30 d/---- lor P,G 500 Refrigerate 48 h/48 h ‘onductivity P,G 500 Refrigerate 28 d/28 d ‘anide: Total PL, G 500 Add NaOH to pH >12, refrigerate 24 h/14 d in dark Amenable to chlori- nation P, G 500 Add 100 mg Na2S203/L --/-- luoride P 300 None required 28 d/28 d “ease and oil i 1000 Add H2S04 to pH <2, refrigerate 28 d/28 d mout calibrated dardness P, G 100 Add HNO3 to pH <2 6 months/ 6 months/ .-dine P, G 500 Analyze immediately 0.5 h/---- fetals, general P(A) ,G(A) --- For dissolved metals filter 6 months/ immediately, add HNO3 to pH <2 6 months Chromium VI P(A) ,G(A) 300 © Refrigerate 24 h/48 h Copper Mercury P(A) ,G(A) 500 Add HNO3 to pH <2, 4°C 28 d/28 d trogen: Ammonia P, G 500 Analyze as soon as possible or add H2S04 to pH <2, refrigerate 7 d/28 d Nitrate P, G 100 Add fS04 to pH <2, refrigerate 48 h/48 h Nitrate + nitrite P, G 200 Analyze as soon as possible or none/28 d refrigerate; or freeze at -20°C Nitrite P, G 100 Analyze as soon as possible or refrigerate; or freeze at -20°C none/48 h Organic, Kjeldahl P, G 500 Refrigerate; add H2S04 to pH <2 7 d/28 d vr G 500 Analyze as soon as possible, 6 h/---- Janic compounds: refrigerate Pesticides G(S), TFE- --- Refrigerate; add 100 mg Na2So03/L 7 d/7d lined cap if residual chlorine present TELEPHONE {907} 562-2343-——--. ANCHORAGE 4NDUSTRIAL-GENTER 5633 B Street TABLE SUMMARY OF SPECIAL SAMPLING OR HANDLING REQUIREMENTS SAMPLE : STORAGE SIZE RECOMMENDED ve ERMINATION CONTAINER mL _—_ PRESERVATION REGULATORY »ganic compounds: Phenols P,G 500 — Refrigerate, add H2S04 to pH <2 ----/28 d Purgeables by purge G, TFE- 50 Refrigerate, add 100 mg NagS203/L 7 d/14 d and trap. lined cap if residual chlorine present xygen, ‘dissolved: - G, BOD bottle 300 - Electrode Analyze immediately 0.5 h/l h Winkler Titration may be delayed after 8 h/8 h acidification ~one G 1000 Analyze immediately 0.5 h/--- = P, G . ------ Analyze immediately - .- 2 h/2.h nosphate G(A) 100 For dissolved phosphate filter 48 h/48 h immediately;. refrigerate;-freeze . . at -10°C _linity G, wax seal 240 Analyze immediately or use wax 6 months/-- seal lica P --- Refrigerate, do not freeze 28 d/28 d idge digester gas G, gas bottle --- --- --- dlids P,G --- Refrigerate 7 d/7-14 ¢ lfate P, G --- Refrigerate 28 d/28 d Ifide P,G 100 Refrigerate; add 4 drops 2N zinc 28 d/28 d acetate/100 mL - aste G 500 Analyze as soon as possible; re- frigerate —-- 24 h/---- ‘caperature P, G --- Analyze immediately --/-- ‘urbidity P, G --- Analyze same day, store in dark 24 h/48 h up to 24h testing required is not on this list please contact lab for proper containers and instructions ‘Collections. P.O. BOX 4-1276 TELEPHONE (907) 562-2343 ANCHORAGE INDUSTRIAL CENTER .F BBE. | Ped Anchorage, Alaska 99509 5633 B Street QUALITY CONTROL FOR GAS CHROMATOGRAPHY DEPARTMENT All gas aoe eneer eee checked prior to running analysis by the use of standards. All data systems, auto-integrators and recorders are checked for. zero- ing and full scale operation, any corrections necessary are implemented before any analyses are started. Carrier and detector gas flows are measured periodically using a bubble meter to be sure measured rates fall within manufacturer's specifications. Standards are prepared fresh weekly from stock solutions and stored in refrigerator at 5°C. Stock solutions are prepared by the G. C. chemist, menicus marked to insure_against evaporation loss of solvent and stored in refrigerator at 5°C. Stocks are made from concentration stored in freezer at -15°C. The standards range in concentrations within the linear range of the instrument and cover the expected range of the unknowns. Liquid samples and solids ran by purge and trap and headspace analysis techniques are accompanied by water and air blanks method to demon- strate that the system is free of contamination. Any significant con- tamination above the method detection limit requires cleaning and purg- ing of the system before analysis can continue. Field duplicates and sample blanks are requested with each batch. Samples and standards are injected using the solvent flush technique. Syringes are cleaned between each injection by rinsing with appropriate solvent. Periodic-checks—for -sample-carry-over are -made—by injecting blanks_into system. Any carry-over will result in the halting of analysis until syringe is properly cleaned, all prior samples are rerun to check ac- curacy. Known EPA or commercial check samples are run with analysis and duplicate samples are run every ten samples. P.O. BOX 4-1276 Anchorage, Alaska 99509 _ATOMIC AND ICP SPECTROSCOPY Instruments are checked for proper calibration of energy levels and zeroing prior to analysis. Standards are prepared fresh daily from commercially prepared stocks. These standards cover the ranges within the linearity of the instrument and the expected ranges-of the unknowns. Commercial or EPA known check samples are run with each set of unknowns. Spiked samples and duplicate samples are run every ten samples and results must fall within the proper ranges. If they exceed these ranges analyses are halted, corrections made and knowns rechecked. All analysis are rerun after corrections and checked for accuracy. P.O. BOX 41276 -- TELEPHONE (907) 562-2343 - - Anchorage, Alaska 99509 WATER DEPARTMENT Tests in this area are performed according to EPA Methods or Standard Methods -for Water & Wastewater. All spectrophotometers are checked for zeroing and full scale operation prior to analysis. Standards--are prepared - from. commercial. stocks..or prepared by water .. laboratory chemists when necessary. All calibration. curves are checked by the use of standards run with each set of analysis. Known commercial or EPA check samples are run with each set of analysis and spikes and duplicates are run every ten samples. Results must fall within the proper ranges of knowns and spikes. If they exceed these ranges all analyses are halted until necessary cor- rections are made and all analysis are rerun for accuracy. P.O. BOX 4-1276 TELEPHONE (907) 562-2343 Anchorage, Alaska 99509 ANALYTICAL EQUIPMENT All analytical instruments and equipment are on service contracts, and are checked, cleaned and calibrated by service representative annually. When new equipment is purchased two or more operators are sent to factory training schools for proper operation of instrument. In house training programs are continually on-going to keep analysts a- breast of techniques and up-dates.- Incubators—and-refrigeraters—are -checked-daily-for proper-temperature-and ——. ogs are kept. temperature deviates from tolerance-ranges immediate adjustments are made. Balances are checked weekly by use of standard weights and log kept. Balances are on service contract. Distilled Water is produced using an all glass still. After distillation the water 1S ton exchanged through two ultra pure filters and conductivity is periodically checked on water. All Chemicals used are Reagent grade, GC grade or Ultra Pure. _ CHEMICAL & GEOLOGICAL LABORATORIES OF ALASKA, INC. pe ES Cf P.O. BOX 4-1276 TELEPHONE (907) 562-2343 ANCHORAGE INDUSTRIAL CENTER ARN Anchorage, Alaska 99509 5633 B Street Ne ies DATA--“HANDEING: ~~ All data is checked by department supervisor and submitted to the technical director for final approval before sending to client. 4 3) Anchorage, Alaska 99509 P.O. BOX 4-1276 EQUIPMENT Perkin Elmer Infrared Spectrophameter Bausch & Lomb Spectrophotaometer Perkin Elmer Atomic Absarbsion with Professional Computer Jarrel Ash Plasma Atom Comp with Computer 3-Varian Gas Chromatographs with Vista Computer Hach Turbidimeter Penski Martin Flash Point Tester O-I Total Organic Carbon Analyzer Mettler Balance Mettler Balance Mettler Balance GCA Incubator Freas GCA Coliform Incubator Bath Fisher ISO Therm Incubator VW&R Constant Temperature Incubator Christian Beckers Specific Gravity Tester Brinkman Auto Titrator Systems I.E.C. Centrifuge Wheaton Autostill Barnsted ION Exchange Unit Lab Line Oven Imperial Linberg Muffle Furnace . Fall Millipore Six (6) Place Stainless Filtration System 710 B Spectramic 88 5000 7500 975 3700 401 2100 A Koehler 525 PT 320 AE 100 E 3 815 303 1230 E-535, 536 cs II * We also have on order with Perkin-Elmer the Zeeman 5000 Graphite Furnace System that is to be shipped August 15, 1985. APPENDIX VII Soil Test Results 2291/524/23 at a = RESULTS OF LABORATORY SOILS ANALYSIS - PPM Alaska Gasifier Site Clean-Up Marenco Facility - Near Klatt and Gambell Roads Anchorage, Alaska Max EPA Hy Soil Samples 0 to 1 foot in depth 1) Limit AU) Bist (Cel) (Dar eit ear Sele eed |S) Plas | Fra2 (1) (1) Lead (2) 5.0 0.08 <0.05 <0.05 <€ 05 <0.05 ¢<0.05 ¢0.05 ¢0.05 0.24 ¢0.05 0.17 3) pheno (3) LT THC LEAL PEC eC Is Is Cresol: i Ortho (3) <ek <1 <a <1 ZU 41 cl <1 <1 1s ts \ Meta (3) <1 <1 Gk cL <1 el Sor <1 <1 Is ts iS Para (3) “1 CET cel £1 <1 <1 <1 “1 <1 1s Is a Benzene (3) <0.05 <0.05 <0.05 <0.05 <9.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 ° Toluene (3) <0.05 <0.05 ¢0.05 <0.05 <0.05 <0.05 <0.05 ¢0.05 <0.05 <0.05 <0.05 iD MEK (4) {3} ol ic <0.05 <0.05 <0.05 <1 <a. <1 <1 a aE Benzo-A 7 Pyrene (3) <) <1 eu <1 cr ot <1 <1 Cath Is <1: v Pyridine (3) <u <1 <1 <1 <1 <1 <1 <1 <1 <1 <1 a NOTES: {1) Samples G-1 and I-1l are background reference samples. 4 (2) As per EPA toxicity extraction methodlogy. pa {3) If a small quantity generator generates acutely hazardous waste in a calendar month in 7 quantities greater that set forth below, all quantities of that acutely hazardous waste are : subject to regulation and the notification requirement of RCRA. A total of 100kg (220Lbs) of any no residue oc contaminated soil, water of other debris resulting from the clean-up of a spill, into ' or om any land or water,...of any off specification products having the generic names listed in 261.33 (e). A small quantity generator may accumulate hazardous waste on-site. If he accumulates at any time more than a total of 1000kg (2,2001bs) of his harzacdous waste, or has acutely hazardous waste in quantities greater than set forth in the paragraph above, all of those accumulated wastes for which the accumulated limit was reached are subject to regulation (40 CFR 261.5(f)). (4) MEK = methyl ethyl ketone IS = Insufficient Sample WP-50S2A BPA - August 30, 1985 APPENDIX VIII Agency Review of Sampling Plan 2291/524/24 Agency Review of Sampling Plan Copies of the draft Sampling Plan were distributed to the people listed below. Their comments were incorporated into the final Plan. Mr. Jack Gusmano Environmental Protection Specialist Anchorage Field Office Environmental Protection Agency Mr. Larry Dearborn Hydrologist Division of Geological and Geophysical Services Department of Natural Resources Mr. Bill Lamoreaux Environmental Supervisor Southcentral Regional Officer Department of Environmental Conservation Mr. Jim Hayden Environmental Field Officer Alaska Western District Office Department of Environmental Conservation 2291/524/24 Mr. Dave Trudgen Environmental Field Officer Alaska Power Authority Mr. Edwin Morris Associate Executive Director Planning and Operations Alaska Power Authority Mr. Eugene T. Yonkin Laboratory Director Chemical and Geological Laboratories of Alaska, Inc. 2291/524/25 AGENCY REVIEW Alaska Gasifier Project Water Well Sampling Plan Department of Commerce and Economic Development Alaska Power Authority 701 East Tudor Road Anchorage, Alaska 99503 {[ ] I have reviewed this Plan and agree it is responsive to Environmental Protection Agency's request letter (Appendix I). { ] I have reviewed this Plan and would like to make the following comments (additions, deletions, recommended changes). Signature Date Name (Typed or Printed itle 2330/524/1