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Site Report: JBER-Ft. Rich AFFF Area #05 OUE Bldg 35752 SS044 (formerly with OUD)


Site Name: JBER-Ft. Rich AFFF Area #05 OUE Bldg 35752 SS044 (formerly with OUD)
Address: Off Davis Hwy. near Bldg. 35750 FTRS-044, Formerly Fort Richardson before 10/01/2010, Fort Richardson (JBER), AK 99505
File Number: 2102.38.004.07
Hazard ID: 2773
Status: Cleanup Complete - Institutional Controls
Staff: Louis Howard, 9072697552 louis.howard@alaska.gov
Latitude: 61.247242
Longitude: -149.722177
Horizontal Datum:WGS84

We make every effort to ensure the data presented here is accurate based on the best available information currently on file with DEC. It is therefore subject to change as new information becomes available. We recommend contacting the assigned project staff prior to making decisions based on this information.

Problems/Comments

The Building 35-750 transformer mounting pad area and drainage area are contained within OUE and are located north of Building 35-752. Building 35-752 is the former generator building for the adjacent high frequency transmitter site at Building 35-750. Building 35-752 is the former generator building for the operation of the adjacent joint transmitter/antenna building. 35-752 is currently enclosed with a security fence and vacant. Building 35-750 is currently in use by communications personnel. PCB-containing transformer oil was apparently spilled sometime in the past at the east side of Building 35-750, during routine transformer maintenance activities. Transformer oil containing PCB was reportedly burned in a shallow pit in the area now paved as the parking lot south of Building 35-750. The approximate location of the former burn pit area. This area was the suspected source of dioxins/furans contamination. Additionally, PCB-contaminated soil may have been spread along the paved access road and parking lot during grading activities prior to paving in 1997. Contaminated soils have been excavated and disposed of at a permitted facility out of State and site will not require any further remedial action. ACTIONS from Fort Rich OUD Bldg. 35752 RECKEY 199021X014101 needs to be transferred to this site. DESRTS Site FTRS-044. UST Facility ID 788. Formerly known as Building 35752-DEH PCB and "Emergency" Hazardous Waste Accumulation Point. Several USTs were at this site: UST 1109 and a former dry well, both north of 35-752. USTs south of 35-752: 51, 52, 53, 54, 56, 87 and 88. Seven 5,000 gallon waste oil USTS were removed in 1990 by the 6th ID/DPW. EPA ID: AK6214522157 Fort Richardson-Proposed NPL Listing Date 6/23/1993 FEDERAL REGISTER NOTICE of Final NPL Listing Date 05/31/1994 2017 Site inspection for AFFF PFOS/PFOA detected PFOS/PFOA in groundwater above EPA health advisory levels but below ADEC Table C (July 1, 2017) cleanup levels. Extent of contamination is unknown.

Action Information

Action Date Action Description DEC Staff
7/29/1983 Update or Other Action A review of aerial photographs in 1974 and 1983 showed a stained area around the western-most UST (UST 51). It appeared that this tank had been moved or excavated in the 1983 aerial photograph. Louis Howard
7/1/1987 Update or Other Action During active operations from 1953 to 1987, four generators were in operation within Building 35-752 (Antenna Building). The generators were situated in a 4 inch-deep concrete pit located in the middle of the floor. When the generators were removed in 1987, the pit was filled with concrete to bring this area to grade. In 1987, the Fort Richardson Directorate of Engineering and Housing (DEH) Environmental Resources Branch began operating the building as an emergency hazardous waste storage area. Wastes were stored inside the building for an average of 30 to 45 days until they could be transported to the Post’s hazardous waste storage area. Building 35-752 was also used for storage of unknown waste and spill cleanup debris. Louis Howard
7/3/1989 Update or Other Action In 1989, the building was used as a temporary storage location for 125 bags of PCB-contaminated soil. Each bag reportedly weighed approximately 2,000 pounds. Louis Howard
4/25/1990 Update or Other Action 1. April 25, 1990, the USACE Environmental Branch sampled seven underground storage tanks (USTs) at the antenna field. All tanks had previously been pumped and only the sludge remained, Three of the tanks did not have enough sludge to draw a sample (less than one inch). We have attached the analysis for the remaining (Samples 90041, 90042, 90043, 900441. 2. The analysis indicated no PCBs were detected in any of the samples. Additionally, samples 9941 and 90042 were water with only trace amounts of fuel. 3. The remaining compounds are not toxic unless they are ingested. It is unlikely the contents of these tanks will cause any adverse effects if proper work practices are used. (“Sampling At Antenna Field Memorandum for Record APVR-DE-PSE 200-1a Lori T. Lay Environmental Engineer). Louis Howard
7/2/1990 Update or Other Action At the time of the RCRA Facility Assessment visual site inspection (VSI) in July 1990, the building contained drums of polychlonnated biphenyl (PCB)-containing wastes, dry cleaning solvent, paint waste, and denatured alcohol (SAIC 1990). The drums were stored on pallets. No drip pans or berms were observed around the waste drums (SAIC 1990). No evidence of releases from the unit was observed during the VSI. 125 bags of PCB-contaminated soil were removed by 1990, but the dust from the bags may remain on the floor. Louis Howard
7/31/1990 Update or Other Action Seven 5,000-gallon USTs were excavated from the south side of Building 35-752 in 1990. The tanks were operational from 1958 to 1989 and presumably contained diesel fuel for the generators. Some of the USTs may have also contained waste oil. During closure activities in 1990, petroleum hydrocarbon contamination was found in the excavation, which was reportedly 19 feet deep and measured 98 feet by 43 feet at the surface. Based on these measurements, more than 2,000 cubic yards of soil was excavated. Groundwater was encountered in the excavation at approximately 16 feet. Following UST removal, 21 soil samples and 2 groundwater samples were collected from the limits of the excavations by DPW personnel and were analyzed by NTL. Sampled soil revealed total petroleum hydrocarbons (TPH) at levels of up to 14,000 milligrams per kilogram (mg/kg), and benzene, toluene, ethylbenzene, and xylenes (total BTEX) of up to 100 mg/kg. PCBs were not detected above the detection limit of 0.1 mg/kg in the four soil samples that were analyzed for PCBs. Excluding tank volumes, the excavation yielded an estimated 840 cubic yards of soil potentially contaminated with hydrocarbons. The potentially contaminated soil was taken to the Fort Richardson Landfill for temporary storage, and the excavation was backfilled with soil (USACE, 1990). Based on the apparent discrepancy between the excavated volume and the volume of potentially contaminated soil removed, some of the excavated soil may have been used as backfill. Louis Howard
8/31/1990 Update or Other Action In 1990, the USACE conducted a UST remediation sampling program at the location of the former USTs south of Building 35-752 to assess the presence and extent of fuel contamination in the soil and groundwater (U.S. Army Corps of Engineers (USACE). 1990. “Sampling Report, Underground Storage Tank Remediation, Fort Richardson, AK.” Memorandum for CENPA-EB-MB-A.). Nineteen soil samples from six borings were collected and analyzed for volatile organic compounds (VOCs) and petroleum hydrocarbons. Samples were not analyzed for PCBs. Soil samples from AP-2986 contained 730 mg/kg of diesel fuel at 10 feet below ground surface. AP-2986 is located on the south side of the excavation. No other soil borings had contaminant concentrations above the ADEC matrix cleanup levels for this site. Six groundwater samples were collected and analyzed for VOCs and petroleum hydrocarbons from six monitoring wells in 1990. A groundwater sample from Monitoring Well AP-2982 located outside excavation boundaries on the northwest corner of the excavation contained 620 ug/L of benzene and 1,300 ug/L of toluene. Groundwater samples collected and analyzed from AP-2987 contained 420 micrograms per liter (ug/L) of benzene and 1,300 ug/L toluene. AP-2987 is located outside the southwest corner of the excavation. No other groundwater samples contained analyte concentrations above MCLs. SOIL BH-16 AP-2986 104 Soil 15' to 16.5 bgs: Benzene detection limit 500 ug/kg - April 2012 18 AAC 75 Table B1 Migration to GW is 29 ug/kg. BH-16 AP-2986 103 Soil 10' to 11.5' bgs Diesel Range Organics 730 mg/kg - MGW is 250 mg/kg GW BH-12 AP2982 266 Water Benzene 620 ug/L (April 2012 Table C 18 AAC 75 5 ug/L) Toluene 1,300 ug/L (1,000 ug/L) BH-17 AP-2987 265 Water Benzene 420 ug/L (5 ug/L) Toluene 1,300 ug/L (1,000 ug/L) Louis Howard
5/15/1991 Update or Other Action CENPA-EN-G-M (200-1c) May 15, 1991, MEMORANDUM FOR CENPA-EN-MB-A SUBJECT: Sampling Report, Underground Storage Tank Remediation, Fort Richardson, AK recieved. The objective of the project was to obtain data for closure of the UST sites in accordance with the requirements of Alaska Department of Environmental Conservation (DEC). To close the sites, the ADEC has required soil borings to check for POL contamination and to determine if further excavation is. required for clean up where underground storage tanks (UST) were removed. Although there are no regulatory cleanup levels for metals in soils, the presence of high lead levels could indicate the presence of leaded motor fuel. In addition, there are restrictions on soils that are to be placed in landfills. TCLP MCLs are included in Table I for comparison with landfill restrictions. Because of test methodology and reporting parameters, TCLP metal results cannot exceed limits unless total metals exceed 10 times TCLP limits. Enclosure 1 demonstrates the mathematical logic. Six holes. BH-12 (AP-2982) to BH-17 (AP-2987). were drilled and monitor Wells were installed. Diesel fuel and BTEX contamination was found. at the 10 foot. level of borehole AP-2986. Levels of soil contamination greater than 30 mg/Kg diesel fuel. and BTEX 9.4 mg/Kg are marginal relative to cleanup levels cited in reference lb. Groundwater at the site indicates that aromatics and fuel components are present. Kerosene was also present but at less than quantifiable levels. Weathering could cause misidentification of fuels. NOTE TO FILE 18 AAC 75 (April 2012) Table C Cleanup levels BH-12 (AP-2982) Sample ID 266 wa Benzene 620 ug/L (5 ug/L) o,p-dichlorobenzene 100 ug/L (1,4-dichlorobenzene 75 ug/L) Bunker C < 1,400 ug/L (RRO 1,100 ug/L) Table B1 Migration to Groundwater BH-16 AP-2986 Sample ID 103 soil 10' to 11.5 bgs 200 ppm HNU benzene < 500 ug/kg (25 ug/kg) o,p-dichlorobenzene 5,000 ug/kg (1,4-dichlorobenzene 640 ug/kg) Diesel #2 730 mg/kg* lab estimate (250 mg/kg) Table C BH-17 AP-2987 Sample ID 265 water Benzene 420 ug/L (5 ug/L) o,p-dichlorobenzene 120 ug/L (1,4-dichlorobenzene 75 ug/L) Bunker Fuel #6D <2,800 ug/L (RRO 1,100 ug/L) John Halverson
6/26/1991 Site Visit June 12, 1991 RCRA HW Management Compliance Evaluation Inspection Report documents Tim Law, Daniel Hartung, Vic Vickaryous, Geoffrey Kany, of ADEC's RCRA program inspected the Post for compliance with the provisions of the compliance agreement (FFCA) on April 29, April 30, 1991. Although only DEH-ERB and DEH-O&M personnel have access to this building located off the Davis Highway, this unit is considered unsecured. The seventeen containers of JP-4 fuel soaked 3M absorbent pads labeled "fuel soaked absorbant" which were being stored inside Bldg. 35752 during the May 1990 inspection, which then had not had an adequate hazardous waste determination made yet, were still being stored on April 30, 1991. The pallet of two olive 5 gallon containers of waste alcohol observed during the May 1990 inspection were present as well. Several of the small containers were dented, in violation of 40 CFR 264.171, and 18 AAC 62.210. Nor were these containers marked with accumulation start dates or labeled as "hazardous waste", in violation of 40 CFR 262.34(a). Since it was admitted by Ms. Jane Smith during the May 1990 inspection that wastes here had been stored for greater than 90 days, it has now been over one year that hazardous waste has been stored in this building, in violation of 40 CFR 262.34 (b) and 40 CFR 268.50(a). Two pallets have been added since last year: including three 85 gallon overpacks, one 55 gallon container of discarded PD-680 Type II solvent, and one 10 gallon container of discarded ignitable hexane. There was also one 55 gallon container labeled "fuel filters" and "flammable" by itself next to the wall. The contents of this drum have not had an adequate hazardous waste determination made on them yet for the toxicity characteristic, in violation of 40 CFR 262.11 and Paragraph 22.I. of the FFCA. Nor is this container labeled "hazardous waste", nor is the accumulation start date clearly marked on the container, in violation of 40 CFR 262.34(a). Mr. Kany encouraged Ms. Scott to transfer containers of hazardous waste from Bldg. 35752 to Bldg. 45-125 or 45-133, in order to store hazardous waste in the interim status unit only. Tim Law
7/1/1991 Update or Other Action In 1991, samples of the dust and dirt on the floor were collected and composited. Aroclor 1254, a PCB, was the only compound detected above method reporting limits (MRLs). The Aroclor 1254 concentration in the composited sample was 411 parts per million (ppm). The presence of Aroclor 1254 inside the building was not expected, because the soil in the bags had contained only Aroclor 1260. The reason for the PCBs in the floor dirt being different from the PCBs in the bagged soil is not known; however, it could be that the contamination inside the building is related to the generators or other support equipment previously used in the building or to the drums of PCB-containing wastes stored in the building. Louis Howard
1/27/1992 Update or Other Action ENSR GW results for FRA & Greely MW Network Sampling. Benzene AP-2987 October 1992 170 ug/L (5 ug/L is Table C cleanup level) ADF&G E October 1992 Lead 24 ug/L. Louis Howard
2/28/1992 Update or Other Action During routine characterization analyses of the stockpiles from the 1990 UST excavation, Aroclor 1260 was detected at concentrations ranging from 5.5 to 322 milligrams/kilogram (mg/Kg) (E&E 1992 Contaminated Soil Stockpiles, Fort Richardson, Fort Wainwright, and Fort Greely, Alaska, February). Louis Howard
8/23/1993 Report or Workplan Review - Other EPA comments on closure plans for bldgs. 35-752, 45-590, & 704. FRA submitted a second draft Closure/Post-Closure Plan for on December 30, 1992. This second draft closure plan was reviewed by EPA to determine its technical adequacy, compliance with the requirements of 40 CFR 265, Subpart G, & overall conformance with EPA directive 9470.00-5 - RCRA Guidance Manual for Subpart G Closure & Post-Closure Care Standards. This closure plan addresses the intent of FRA to perform closure activities at this hazardous waste regulated unit under the CERCLA program if: 1. GW contamination attributable to the wastes stored or disposed of in the closure area is found. 2. Soil contamination exceeding the cleanup levels is found at a depth greater than 5 ft below the ground surface. While this closure plan must meet the criteria of RCRA closure standards as delineated in 40 CFR Part 265 Subpart G, EPA may consider deferring some or all of the closure activities, including clean-up where appropriate, to the CERCLA program at facilities which are on the National Priority List (NPL). FRA is not on the NPL, but has been officially proposed by EPA for inclusion on the NPL Once a facility is listed on the NPL, EPA will determine whether to defer any closure activities to the CERCLA program. 2. FRA failed to address chlorinated solvents or heavy metal constituents of the various petroleum products that were stored on the southern end of the eastern side of the building as potential constituents of concern (COCs). 3. Cleanup levels are not defined for some of the solvents that were stored at this site, & which may have been released into subsurface soils & possibly GW. This however, would have to be based on the findings of the historical use of this area & the results of area specific site characterization which should be expanded in this text. 4. Although the text stated that the matrices that have potentially been affected by hazardous wastes stored outside this building include the soils & subsurface soils in the closure area, no discussion is provided in the succeeding paragraphs on proposed sampling guidelines. This represents a major deficiency of the current text, & calls into question, the claim that FRA intends to address the clean closure of the southern end of the eastern area of this building as part of the closure. Section 2.12, Page 2-3, Top Paragraph: The text referenced soil borings advanced to 40 feet below ground surface (bgs) during an investigation near this building (35-752) (COE, September 1991), as a basis for extrapolating the subsurface stratigraphy beneath this closure area. To establish a correlation & to demonstrate a possible lateral continuity of subsurface stratigraphic units, a close proximity between the location of the borings & this closure area needs to be established. A map showing the spatial relations between the locations of the borings & the closure area would be ideal, including discussions establishing lateral continuity of the subsurface stratigraphic units. Section 2.4, Page 2-4, Third Paragraph: It is stated in the text that in Fall 1989, approximately 125 bags of soil contaminated with PCBs were stored in this building for a short time. It is curious that these contaminated soils are of &own origin, & that they were placed in bags, & not drums. The text further inferred that these bags may have been generated during a PCB remediation project at the Roosevelt Road Transmitter site. These bags were reportedly sent to the Defense Reutilization & Marketing Office (DRMO) at Elmendorf Air Force Base in October 1988, when the date of storage of the PCB contaminated soils at Building 35-752 is Fall 1989. The dates are conflictory & warrants additional investigation of the site history/chronology of site activities, to assure an accurate documentation of potential site contamination from these PCB contaminated remedial soils. Section 2.4, Page 2-4, Fourth Paragraph: The text referenced Appendix A as containing results of the chemical analysis performed on dust & dirt samples collected from this building, in an attempt to evaluate the potential impact to the building of the storage of the PCB contaminated soils. A review of Appendix A revealed that this information is not provided. Information provided in Appendix A are relevant to the sampling of the seven USTs, & as stated in Section 1.2, are not directly relevant to the closure activities for this building. The correct information on the analysis of the dust & dirt samples should be provided in Appendix A. The data on the USTs which are irrelevant to the closure activities of this building should be deleted from the text. Louis Howard
9/21/1993 Update or Other Action A.G. letter (Breck Tostevin) to Tamela J. Tobia OS Judge Advocate for the Army. Letter states that a separate petroleum site compliance agreement should be separate from the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) federal facility agreement. The petroleum site restoration agreement would function as a "two-party agreement" under the FFA. It would track the basic provisions of the UST Agreement but be tailored to the State's contaminated site regulations and would interface with the FFA. All petroleum sites addressed under the Two Party agreement would be reviewed in the final operable unit of the FFA and actions taken would be memorialized in a Record of Decision (ROD) under the FFA. Louis Howard
11/23/1993 Update or Other Action Memorandum for Record. Synopsis of Findings -- Draft Interim Site Assessment/Remedial Investigation, Site 4, Bldg 35752, FRA. Summary of significant field results from : a. Soil Borings. (1) PCBs (Aroclor 1260) were detected in two soil borings from within the original UST excavation boundaries at levels ranging from .053 mg/kg to 84 mg/kg. PCBs were not detected outside the boundaries. Action levels for PCBs in soil have not been established for this site. NOTE TO FILE: 18 AAC 75 Table B1 (April 2012) soil cleanup level for Total PCBs is 1 mg/kg (unrestricted use/unlimited exposure). (2) Diesel and gasoline organics (DRO/GRO) exceeded ADEC’s matrix cleanup levels, generally from two borings within the original tank excavation boundaries. Only one soil sample from a boring outside the limits of the excavation showed concentrations above ADEC’s matrix cleanup levels. (3) Lead concentrations within excavation limits ranged from 1.3 mg/kg to 85 mg/kg; outside limits ranged from 4 to 10 mg/kg. Action levels for lead in soil have not been established for this site. Sediment Samplinq (Action levels not established). (1) PCBs (Aroclor 1260) were detected in sediment at two of three sample locations (1.3 mg/kg and .055 mg/kg). (2) DRO contaminants were detected in all three sampling locations ranging from 120 mg/kg to 5.8 mg/kg. (3) Lead was detected in all three locations, ranging from 21 mg/kg to 5.5 mg/kg. Ground water Samplinq. Benzene concentration exceeded the drinking water MCL in one monitoring well. In all other wells, levels were below MCLs or non detectable. Significant decreases in contaminant concentrations, or lack of detected contaminants, suggests ground water contamination is dissipating. Surface-Water Sampling. No contaminants were detected in surface-water samples. Louis Howard
11/30/1993 Report or Workplan Review - Other The Alaska Department of Environmental Conservation-Defense Facilities Oversight group (ADEC) has received on November 15, 1993 a copy of the DRAFT Interim Site Assessment/Remedial Investigation Site 4, building 35752 High Frequency Transmitter Site, HLA Project No. 24212. Here are ADEC’s comments regarding this document. 3.1.1 Deviations from the Release Investigation Plan pages 13 & 14 The text states that the two inch standpipe near monitoring well AP-3232 was investigated through geophysics by Harding Lawson Associates. A conclusion was reached that an underground storage tank was not associated with this standpipe. Although the standpipe was not considered for furher investigation by HLA, ADEC requests that the Army further investigate &/or remove it from the site to prevent it from becoming a conduit of contamination to the subsurface soils. 5.2.2 Soil Boring Sampling Results page 36 2nd paragraph The text states that Diesel Range Organics (DRO) & Gasoline Range Organics (GRO) concentrations were in excess of ADEC Level A cleanup levels mainly in borings AP-3227 & AP-3228. ADEC is concerned that the presence of petroleum contaminants in the subsurface soils: in particular, at the fifteen foot depth interval along with Polychlorinated Biphenyls (PCBs) may pose a significant risk to the environment through increased mobilization. ADEC requests that any corrective action plans or interim removal actions for this site incorporate an appropriate method of dealing with PCB contaminated soils (i.e. TSD facility). The document also states that a qualitative risk assessment for risk based concentrations (RBCs) & potential receptors at the site be conducted to determine actions levels for PCBs. ADEC requests that the risk assessment cover: the potential multiple pathways & contaminants present at the site, potential migration to GW since it appears that the some of the contaminants are at the soil/GW interface, & an ecological assessment. 5.2.3 GW Sample Results page 38 third paragraph The text states that the significant decrease of contaminant concentrations in wells AP-2982 & AP-2987 & lack of detected contaminants in other nearby downgradient wells suggests that the contaminants detected during the 1990 USACE investigation are dissipating. This assumption cannot be substantiated with the current data set given the qualifications listed in 4.2.1 on page 25. The text states that no duplicates or MS recoveries for Volatile Organic Compounds (VOCs) were submitted for several of the aqueous samples so the data precision & accuracy could not be assessed. Subsequently, the data is suspect & should be viewed with caution. ADEC requests that additional sampling be conducted to verify the absence or presence of VOCs in all of the monitoring wells at the site. 5.2.4 Surface-Water & Sediment Sampling Results Page 39 first paragraph The text states that cleanup levels are not established for sediment, however there are sediment quality criteria (SQC) available that the U.S. EPA recommends be considered in establishing remediation goals for contaminated sediments. The SQC were designed to be protective of aquatic life & animals that consume aquatic life. The PCB SQC is not a fixed value; rather, it is dependent on the total organic carbon (TOC) concentration in the sediment. In order for the appropriate SQC level to be determined, the TOC will have to be calculated from another round of sediment sampling. ADEC requests that a sampling plan be submitted outlining specifically what sediment sampling will be done & exactly how the sample will be collected. Appendix F Chemical Quality Assurance Report Use of the detection limits for PCBs water samples of 0.5 to 1.0 ug/L (ppb) is not low enough to determine if the National Ambient Water Quality Criteria of 0.014 ug/L was exceeded. ADEC requests that additional water sampling of all monitoring wells at the site for PCBs (in addition to the VOCs mentioned in section 5.2.3) be performed with methods that are able to detect this level of concern. Louis Howard
12/13/1993 Update or Other Action Memorandum for Commander 6th ID (Light) ATTN: D. Fosbrook from Claude V. Vining Chief, Engineering Division U.S. Army Engineer District (CENPA-EN-EE-AI) (200-1c). Disposal of Investigation Derived Waste (IDW), UST Investigation, Site 4, Building 35752, Fort Richardson, Alaska. This memorandum should provide you with the information you requested concerning the drums and stockpiles from the UST Investigation for Building 35752 at Fort Richardson. Please note that the decontamination water with trace parts of PCBs must be treated before disposal and this treatment is available in-state. A list of the drums and their contents, as well as information on the stockpiles, is included in the memorandum. 2. The information regarding the contents of the drums needs to be transferred to Building 45-125, Hazardous Waste Container Storage Area, where the drums are presently located. HLA performed a site investigation at Bldg. 35752 which resulted in 2 drums of soil 6 stockpiles of soil, 15 drums of purge and development water and 5 drums of decon water. One of the two drums of soil cuttings is contaminated with diesel. The second drum is contaminated with diesel and PCbs. 14 out of 15 drums of purge/development water area uncontaminated. 1 drum is contaminated with benzene. All 5 drums of decon water contain petroleum, and 4 of 5 drums are contaminated with trace levels of PCBs. Stockpiles B1 and B4 contain diesel contaminated soil. Stockpile B2 contains diesel and PCB contaminated soil. Drum O1S-1 Soil cuttings AP-3227: DRO 150 mg/kg GRO 390 mg/kg Drum 02S-1 Soil cuttings AP-3228 DRO 2,800 mg/kg PCBs 84 mg/kg Drum AP2982W1 purge/development water: benzene 0.025 mg/L Drum Decon-1 DRO 0.871 mg/L Drum Decon-2 DRO 0.44 mg/L PCBs 2.7 ug/L Drum Decon-3 DRO 0.565 mg/L PCBs 3.7 ug/L Drum Decon-4 DRO 0.911 mg/L PCBs 1.9 ug/L Drum Decon-5 DROM 0.818 mg/L PCBs 3.4 ug/L Louis Howard
1/31/1994 Update or Other Action January 1994 Sampling Report for groundwater monitoring received. AP-2987 Round 1 Benzene 170 ug/L Round 2 94 ug/L Louis Howard
2/15/1994 Update or Other Action Quality Assurance Project Plan for the Closure of Building 35-752 (ENSR Consulting & Engineering) Doc. # 6583-058-400/QA.5 The purpose of this document is to present procedures and analytical guidelines to be used during the course of closure activities at Building 35-752. This building was originally used as the generator building for the adjacent antenna farm and transmitter building. At that time it contained four generators and ancillary equipment. The generators and equipment were removed in 1987. In the fall of 1989, approximately 125 bags of soil contaminated with polychlorinated biphenyls (PCBs) were stored in this building for a short time. In April 1988 and June 1989, personnel from the United States Environmental Protection Agency (EPA) Region X and the Alaska Department of Environmental Conservation (ADEC) Conducted a facility compliance evaluation inspection (CEI) of Fort Richardson- There was a concern that PCBs from the soil in the bags may have contaminated the building. The inspectors determined that this building was ill-suited and not permitted to store hazardous wastes. Subsequently, EPA issued a Notice of Noncompliance (NON), Docket No. 1090-05-29-8001, to Fort Richardson for the deficiencies found in the base’s handling of hazardous and other hydrocarbon-contaminated wastes. As a result of the NON, Fort Richardson entered into a Federal Facility Compliance Agreement (FFCA) with EPA Region X and ADEC. Section V of the FFCA, Required Compliance Actions, states that ‘Fort Richardson shall submit, for EPA approval, the closure/post closure plans for Building 35-752. the plans must meet the requirements of 40 CFR 285, Subpart G (Closure and Post-closure). Fort Richardson intends to demolish Building 35-752 once closure has been attained. The constituents of concern for this closure are PCB - Arochlor 1254, volatile organic compounds, RCRA metals and petroleum hydrocarbons. Prior to demolition, decontam,ination activities will . consist of removing all the floor dirt and concrete in which con&tuents of concern exceed the cleanup levels. The concrete floor inside Building 35-752 may have been affected by PCBs. Because there is a chance that the PCB contamination may have occurred as a result of a spill, the concrete will be investigated using a grid method to locate the sampling locations. This method is recommended in various EPA guidance documents because it increases the probability of detecting high concentrations of PCB in the sampled matrix. This level of sampling is necessary as the building will be demolished once all closure activities have been completed. The floor sampling locations .will be determined using the hexagonal grid method described in Field Manual for Grid Samplina of PCB Spill Sites to Verifv Cleanup (EPA, May 1986). The method of designing the grid as follows: - The site is diagrammed and the sampling circle is drawn. - The number of sample points is determined according to the radius of the sampling circle. - The sampling points are calculated and marked on the diagram. - The layout of the sampling locations is transferred to the site. Based on the size of the potentially contaminated area, the sampling points will be determined according to a hexagonal grid of 37 sample points. Constructing the sample diagram for Building 35-752 shows that 27 sample points fall within the sampling grid inside the building. One sample will be taken from each predetermined sampling point. To obtain the most representative values for the PCB concentrations in the concrete floor, core samples will be taken. This sampling method will provide a more representative value than a chip sample and will satisfy the requirement to sample the entire thickness of a potentially contaminated medium. Concrete core will be removed from the pavement with a 2-inch diameter or greater coring tool (i.e., a hole saw). The core will be cut the full thickness of the pavement. The sampling personnel will place the wre sample into a zip-lock bag and label the outside of the bag with appropriate location and sampling information. The core sample will then be handled the same as all other samples collected for the purpose of closure with respect to storage, handling, transport and chain of custody procedures.. Since the laboratory will need to crack the.core sample for the analysis aliquot, no special consideration need be given to preservatives or other analyte specific requirements. Louis Howard
2/15/1994 Update or Other Action Closure plan for Building 35-752 Document # 6583-058-400.5 received. The constituents of concern (WCs) for Building 35-752 are PCB compounds detected during sampling activities (PCBs in the floor dirt sample & in the surrounding soil) & those compounds used during routine vehicle maintenance activities. A risk-based approach was taken to calculate the preliminary cleanup levels for the constituents of concern (EPA, August 1991). Final cleanup levels will be either the preliminary cleanup levels or other EPA approved risk-based levels. Standard default exposure factors were used for calculating the preliminary cleanup concentrations. If necessary, Fort Richardson will submit to EPA, additional risk analysis demonstrating that the final cleanup levels are protective of human health & the environment. For the purpose of these closure activities, the concrete matrix will be treated as a soil matrix & the cleanup levels will be identical. Metals The preliminary cleanup level for these COCs are based on a hazard quotient for systemic compounds & a risk factor of 10” for carcinogenic compounds at a residential site, except for the following compounds. The soil lead concentration is based on EPA guidance (EPA, August 1991) that states 500 mg/kg of lead in soil will not adversely affect the blood levels of the potentially exposed population The exposure medium pathway is assumed to be ingestion. The soil cadmium concentration is based on the protection of plants. PCBs The cleanup level for the PCBs will be based on a health risk assessment, using standard risk assessment assumptions for direct contact (i.e., dermal contact, ingestion, & inhalation) in a residential area. The risk remaining at a residential site after any remedial activities should fall within the range of lo6 to lo4 individual excess cancer risk (EPA, August 1991). The standard risk assessment assumptions result in cleanup levels ranging from approximately 0.1 ppm (excess cancer risk 10-6 to approximately 10 ppm (excess cancer risk l0-4). OSWER Directive No. 9355.4-01 (EPA, August 1990) states that a PCB soil concentration of 1 ppm, which equates to an excess cancer risk of approximately l0-5, is an appropriate starting point for calculating a PCB target cleanup level for residential soils assuming no soil cover or management controls. This value represents a protective, quantifiable concentration for soil. Because access to this area is restricted, management controls are already in place. Therefore, the 1 ppm (or mg/kg) concentration will be the preliminary cleanup level. Volatile Organic Compounds The cleanup level for these COCs is based on a hazard quotient of 1 for systemic compounds, or a risk factor of 10-6 for carcinogenic compounds at a residential site. The exposure pathway scenario is by ingestion. The values cited are listed as human health risk-based “preliminary remediation goals’ for soil in EPA (1991). Ethylene Glycol The preliminary cleanup levels for ethylene glycol are based on a hazard quotient of 1 at a residential site. The reference dose used for ethylene glycol, 2 mg/kg/day, obtained from EPA’s Integrated Risk Informations System (IRIS) results in a preliminary cleanup level of 160,000 mg/kg. (NOTE May 2012 IRIS value is 120,000 mg/kg). Risk-based target cleanup levels to be used at this site for TPH in soils are extracted from a report of health risks from various types of petroleum hydrocarbon fuels, based on the polynuclear aromatic hydrocarbon (PAH) components of the fuel (ENSR, August 1992; Appendix 2). Sampling Procedure for Concrete Destructive samples need to be taken from the building floor for two reasons: 1. Concrete is a non-impervious solid surface. Because it is porous and likely to absorb spilled PCBs, wipe samples would NOT be sufficient to assess contamination of the concrete. 2. There may be a second concrete floor in the building; this can be confirmed by core sampling and simultaneously taking an analytical sample. A concrete core will be removed from the floor with a 2-inch-diameter or greater coring tool (i.e., a hole saw or concrete cover). The core will penetrate the full thickness of the floor. After the core is removed, the hole will be sealed with concrete or cement. The sampling personnel will place the core sample into a zip-lock bag and label the outside of the bag with appropriate location and sampling information and a small PCB mark. The core sample will then be handled the same as all other samples collected for the purpose of closure with respect to storage, handling, transport, and chain-of-custody procedures. Louis Howard
2/22/1994 Report or Workplan Review - Other The Alaska Department of Environmental Conservation-Defense Facilities Oversight group (ADEC) has received, on January 28, 1994, a copy of the draft Remedial Investigation & Corrective Action Plan (RI/CAP) Site 4, building 35752 High Frequency Transmitter Site, HLA Project No 24212 dated January 18, 1994. Here are ADEC's comments regarding this document. 3.1.1 Deviations from the Release Investigation Plan page 13 The text states that the two inch standpipe near monitoring well AP-3232 was investigated through geophysics by Harding Lawson Associates. A conclusion was reached that an underground storage tank was not associated with this standpipe. Although the standpipe was not considered for further investigation by HLA, ADEC requests that the Army further investigate &/or remove it. Any further investigation or proposed removal will have to follow CERCLA protocols & requirements since the garrison is proposed to be listed on the National Priorities List & this site is included as a part of Operable Unit (OU) B. 5.2.2 Soil Boring Sampling Results page 39 ADEC is concerned that the presence of petroleum contaminants & PCBs in the subsurface soils at the fifteen foot depth interval poses a risk to the environment through increased mobilization. ADEC requests that any corrective action plans or interim removal actions for this site incorporate an appropriate method of dealing with PCB contaminated soils (Le. TSD facility) that will satisfy CERCLA requirements. The document also states that a qualitative risk assessment for risk based concentrations (RBCs) & potential receptors at the site be conducted to determine actions levels for PCBs. ADEC requests that the risk assessment follow CERCLA protocols & methodology. The methodology in developing a baseline risk assessment is described in the Risk Assessment Guidance For Superfund, Volume I: Human Health Evaluation Manual, Part A, (EPA 1989d) (RAGS HHEM & Volume II, Environmental Evaluation Manual (EPA 1989c). 5.2.3 GW Sample Results page 41 The text states that the significant decrease of contaminant concentrations in wells AP-2982 & AP-2987 & lack of detected contaminants in other nearby downgradient wells suggests that the contaminants detected during the 1990 US ACE investigation are dissipating. This assumption cannot be substantiated with the current data set given the qualifications listed in 4.2.1 on page 25. The text states that no duplicates or MS recoveries for Volatile Organic Compounds (VOCs) were submitted for several of the aqueous samples so the data precision & accuracy could not be assessed. Subsequently, the data is suspect & should be viewed with caution. ADEC requests that any additional sampling be conducted with CERCLA protocols in mind since this site is proposed to be included in OU B. 5.2.4 Surface-Water & Sediment Sampling Results Page 42 The text states that cleanup levels are not established for sediment, however there are sediment quality criteria (SQC) available that the U.S. EPA recommends be considered in establishing remediation goals for contaminated sediments. The SQC were designed to be protective of aquatic life & animals that consume aquatic life. The PCB SQC is not a fixed value; rather, it is dependent on the total organic carbon (fOC) concentration in the sediment. In order for the appropriate SQC level to be determined, the TOC will have to be calculated from another round of sediment sampling. ADEC requests that a sampling plan be submitted, using applicable CERCLA protocols, outlining specifically what sediment sampling will be dune and exactly how the sample will be collected. 5.3 Recommendations Page 43 ADEC concurs with the assumption that a risk assessment is needed to evaluate the level of PCBs detected (see comments under 5.2.2). However, the risk assessment must follow CERCLA protocols & include: a conceptual site model, preliminary remediation goals, exposure scenarios & pathways. The use of the sediment quality criteria (SQC) is recommended in establishing remedial goals of the contamination present (see comment 5.2.4). GW contaminated with benzene at 2S ug/L is in excess of the S ug/L MCL & cannot be overlooked in any comprehensive risk assessment or remedial design being considered (also See comments under 5.2.3). Continued monitoring of the GW with no remedial action of the GW cannot be justified without first conducting a risk assessment that follows all CERCLA protocols described previously. Louis Howard
2/24/1994 Report or Workplan Review - Other EPA (M. Wilkening) reviewed & commented on the Draft Site Analysis/Remedial Investigation, Site 4, Building 35725, High Frequency Transmitter Site. The main focus of EPA's comments are the lack of justification as to why the investigation did not include the entire site, e.g. Building 35750, lack of detail & vagueness of the document, & some of the cost estimates. 1. Page 12, Section 3.1. The type of geophysical method employed requires clarifying, GPR or E-M, one or both? 2. Page 14, Section 3.2.1. Due to the high levels detected in the existing borings, it is recommended that borings be placed to the west of AP-2986 & east of the excavation area, & two more in the excavation area 3. Page 15, Section 3.2.2, Monitoring Wells, Paragraph 2 The type of submersible pump employed to sample the wells should be indicated. Appendix E states a submersible was used to sample VOCs, which limits pump type for suitable sampling. 4. Page 35, Section 4.3, Biofeasibility Analysis. EPA disagrees that the magnitude of the microbial populations capable of degrading petroleum hydrocarbons is at the low end of the scale. The low end of the scale is 100 cfu/g. This population represents only 25-40% of this low end, i.e. 27 to 40 cfu/g & this population should not be presented in such an optimistic manner. 5. Page 40, Section 5.2.3, Groundwater (GW) Flow, Paragraph 2 No mention was made of local or regional GW gradient. This information is required for interpreting GW data & for developing a corrective action plan. 6. Page 47, Section 6.1, No Action Alternative The text states that GW monitoring would evaluate unexpected migration of additional contaminants. These contaminants should be listed so the reader may evaluate whether the GW monitoring program is capable of detecting the presence of the additional contaminants. The introduction states that only benzene exceeded MCLs. Also see comment below on laboratory analysis & shipping (page 49). 7. Page 48, Section 6.1, No Action Alternative Capping is considered an engineering control, not an Institutional control (IC). An IC is a control caused by a change in policy or regulation. ICs include actions such as access restrictions, limitations on recreational use, &.issuance of public health advisories. Capping is considered a containment option (a control due to engineering). Given this definition, the ICs (site restrictions) will not reduce contaminant mobility & it is erroneous to say that the "limited action alternative requires the construction... of an IC. 8. Page 49, Section 6.1, No Action Alternative It is difficult to tell if $50,000 for the risk assessment & $6,000 for the final corrective action plan is reasonable when the scope of work is not provided. Please provide the scope of work with detailed information in the text. The cost for a risk assessment will be determined by factors such as the assumed exposure routes, media, contaminants, & needs for modeling. The introduction (page 46) may be an appropriate place to add this information. The cost for the final corrective action plan is different for the no action alternative than the limited action & disposal alternatives. Was this intentional? If so, state why in the text. 10 hrs per well, for sampling & purging monitoring wells seems excessive. What does lab analysis & shipping cover? If samples, individual analysis costs $187.50, there are 8 which is reasonable for a benzene analysis. However the text says monitoring for benzene & other contaminants will occur, obtaining analysis for other contaminants will be difficult at this cost. It is assumed there are 100 gal of purge water. This quantity results in 2.5 gal per well if there are 8 samples. This quantity seems low. Typically 3 well volumes are used to purge the well. Page 48, Section 6.2, Limited Action Please describe the exact area that will be capped, the square footage, & the thickness of the cap. It is difficult to tell if 95 cubic yards is reasonable. Page 51, Section 6.3, In-Situ Bioremediation Please describe the implementability of this alternative in terms of site specific geology & other physical parameters. For instance, it is desirable to have a highly permeable, homogeneous aquifer when bioventing. Does the site meet these restrictions? Are there silt lenses that may be difficult to remediate &, therefore, require special targeting? Based on site specific geology, what would the expected radius of influence be? Three wells may or may not be reasonable. Page 53, Section 6.3, In-Situ Bioremediation We would suggest including a pilot plant study in the cost estimate & in the discussion. A pilot plant study will give critical information on the feasibility of in-situ bioremediation, as well as information on whether off-gas treatment is required. Page 53, Section 6.3, In-Situ Bioremediation The well installation cost of $65 per foot might be low. Louis Howard
2/28/1994 Update or Other Action The south end of the east side of the building was the site of an approximately 20 foot by 30 foot unlined drum storage area in the 1960s and 1970s. The drums reportedly came from vehicle maintenance shops and contained various fuel products and solvents. The drums were reportedly not stacked, and the area was never completely covered with drums. Drum storage in this area apparently ceased by 1974 because no drums were visible in the 1974 aerial photograph of the site. Soil near the drum storage area appeared stained in a 1983 aerial photograph (ENSR Closure Plan for Building 35-752, Fort Richardson, Alaska, February). Louis Howard
4/13/1994 Update or Other Action A release investigation was conducted by HLA at Site 4, Bldg 35752 to 1) assess the presence & concentrations of petroleum hydrocarbons & related chemicals in the soil & GW, 2) evaluate the need for remediation, & 3) provide site-specific data for development of a corrective action plan for contaminated soil & GW, as appropriate. Site 4 consists of Building 35750, which houses equipment & controls for operation of nearby high-frequency radio transmitters, & Building 35752, a former generator building. Building 35752 is abandoned & is reportedly scheduled for demolition. Seven 5,000-gallon waste oil USTs were formerly located on the south side of Building 35752. The USTs were identified as Tanks 51, 52, 53, 54, 86, 87, & 88 (USACE, 1990a). Concern over potential releases prompted the removal of the tanks in 1990. NOTE TO FILE: Waste oil USTS require analyses for: GRO, DRO, RRO, BTEX, PAHs, solvents, metals, PCBs & EDB/1,2-DCA. EPA 8260C is required for the analysis of 1,2-Dichloroethane (1,2-DCA). EPA 8011 or EPA 504.1 should be used when evaluating ethylene dibromide (EDB). EDB soil samples should be field preserved in hexane. EPA 8260 will quantify EDB in GW; however, the detection limits do not meet the Table C cleanup level of 0.00005 mg/L (ADEC Draft Field Sampling Guidance May 2010). Fieldwork was conducted at the site from August 22 through September 2, 1993, & consisted of drilling & sampling six soil borings, installing two new monitoring wells, & sampling surface-water & sediment from two water ponds west of the site. DRO and GRO wer detected in borings were above ADEC cleanup levels for the site [AP-3228 Sample ID 92RTS005SL 15' bgs GRO: 330 mg/kg (300 mg/kg MGW), DRO 2,800 m/kg (250 mg/kg MGW) AP-3227 Sample ID 93RTS003SL 15' bgs GRO 390 mg/kg (300 mg/kg)]. PCB levels were detected in soil borings (Max at AP-3228 Sample ID 93RTS008SL 18.5' bgs on 8/24/1993). If results of quantitative risk assessment confirm that PCB concentrations pose unacceptable risk to human health, solvent extraction or excavation & offsite landfilling is recommended. If results of the proposed quantitative risk assessment confirm that concentrations pose some risk to human health, possibly limited action (site capping), bioremediation, or a combination of the two alternatives is recommended. If results of the proposed quantitative risk assessment confirm that concentrations do not pose unacceptable risk to human health, a no-action alternative is recommended. Benzene was detected above the MCL in GW at Monitoring Well AP-2982 [Sample ID 93RTS015WA on 9/2/1993 25 ug/L (5 ug/L)]. No remedial measures are recommended at this time, except to continue monitoring GW for continuing decreases in contaminant concentrations. Petroleum hydrocarbon, PCB, & lead levels were detected in sediment from the ponds in the vicinity of Building 35752. Cleanup levels for sediment have not been estimated for this site. A risk assessment is recommended to evaluate the significance of detected levels. The presence of PCBs at the site may be regulated by the TSCA. According to Title 40, Code of Federal Regulations, Part 761.120 (40 CFR 761.120), the TSCA applies to spills that occur after May 4, 1987. The date of the PCB contamination at Site 4 is not known. Cleanup levels for PCBs under the TSCA vary according to type of facility & land use. Cleanup in a restricted access area requires a soil cleanup level of 25 ppm PCBs by weight. Cleanup in a nonrestricted access area requires a soil cleanup level of 10 ppm PCBs by weight, & that the top 10 inches of soil be excavated & replaced with soil containing PCBs at less than 1 ppm. NOTE TO FILE: 18 AAC 75 (April 2012) Table B1 requires cleanup for unrestricted areas to be 1 mg/kg total PCBs in soil. 1-10 mg/kg may be allowed if covered by a cap as defined in regulations. Corrective action levels proposed under Section 264.521(a) of RCRA, & the EPA Region 10 Supplemental Risk Assessment Guidance for Superfund, RBCs are used for preliminary screening detected contaminant levels to evaluate whether a more detailed s investigation & risk assessment are warranted. The RCRA corrective act level for PCBs in soil is 0.09 mg/kg, & the EPA Region 10 RBCs vary from 0.08 mg/kg for the 10-6 carcinogenic risk to 8 mg/kg for the 10-4 carcinogenic risk. See site file for additional information. Louis Howard
7/19/1994 Update or Other Action Chemical data report received. Disposable bailers were used to collect volatile organic compounds, gasoline range organics samples. The results for these contaminants should be biased low due to sampling method and loss of volatiles with bailers. The benzene concentration detected in AP-2982 (4.5 ppb) is much reduced from benzene levels reported in that well in 1993 (2.5 ppb) and i99O (620 ppb; ref. 5c). All other volatile Organic compounds are present at concentrations below MCLs, and may be due to laboratory contamination or analytical artifacts. 1,1-dichloroethane has no MCI,, but does have a RBC of 810 ug/L for "tap water" (ref. 5k) of the volatiles The laboratory stated that its analysis sample from AP-2985 "did not meet...QA criteria"; the volatiles data with skepticism (*and flagged biased LOW). Louis Howard
8/19/1994 Report or Workplan Review - Other EPA (M. Wilkening) reviewed and provided comments on the Work Plan for the Preliminary Site Evaluations, Operable Unit D, Fort Richardson. 1. Through out the Dissolution and Transport Through Groundwater Sections there are references to the Fort being underlain by the Bootlegger Cove Formation. The scope of work for the Post Laundry, Building 726, indicated that there is evidence that indicates this Formation does not form a continuous unit underlying the Fort. This difference in interpretation needs to be resolved. 2. Note that risk based-screening requires the use of a future residential scenario in determining potential human health risk. It is this screening that allows a determination of no further action. Thus, while currently the residential scenario is not appropriate at these sites it may be necessary to evaluate such a scenario for screening purposes. Accordingly, the laboratory analysis should provide values for concentrations within the ranges of quantification necessary for such an evaluation. 3. Table 2.8-3. The proposed Table listing the sample summary for the fire training pit should include dioxins in the list of analysis since the burning of some these potential contaminants could result in the formation of dioxins. 4. The collection of back ground samples.should be coordinated for all operable units in order to provide background concentrations of analytes representative of the entire Fort. The distribution of the sites in this Operable Unit over a large portion of the Fort provides a potential opportunity to develop a Fort-wide study of the groundwater flow This opportunity should be taken advantage of. 5. Appendix A, Section 1.6. Note that the latest data quality objectives are found in the EPA document, Data Oualitv Obiectives Process of Superfund, September 1993. This document has replaced the five levels of analysis with a two tiered system. The EPA provided the Fort with a copy of this document and a copy should be forwarded to your contractor if this has not been done. Louis Howard
8/22/1994 Report or Workplan Review - Other Staff reviewed and provided comments on the Draft July 1994 Operable Unit D Preliminary Source -Evaluation 2 Work Plans Document# 9000-036-220. 2.3.3.1 Objectives page 2.3-S Objectives need to include assessing the potential groundwater contamination from any releases that may have occurred on site from the past activities in the drum accumulation area. 2.3.3.2 Field Investigation/Rationale page 2.3-S The text states two soil borings will either be mstalled in areas that have been identified after analysis of the hand auger boring samples or in areas visually identifiable at the surface within the drum storage area. ADEC requests one of the soil borings be advanced and converted into a groundwater monitoring well to assess present groundwater quality and potential contamination from releases at the site. 2.4.3.2 Field Investigation/Rationale page 2.4-S See comments under 2.3.3.2 above regarding additional monitoring we11 installation. 2.6.3.2 Field Investigation/Rationale page 2.6-10 The text states if groundwater monitoring wells (from previous investigations) with known elevations and locations are identified, then depth to groundwater measurements will be taken to evaluate the flow direction of groundwater. These previously installed wells must be comparable to any new wells installed, i.e. completed at the same depth and have comparable well screening intervals. If there are not enough wells in the immediate area to determine the flow and gradient, then ADEC requests additional wells be installed to obtain this information. ADEC also requests that any groundwater information generated from the previous UST investigations applicable to this OU be incorporated in the PSE 2 report. If the groundwater data is insufficient in detail to evaluate the former USTs as a potential source of grodndwater contamination, then additional investigation must be performed to fully assess the source of contamination. Table 2.8-2 Substantiated Groundwater Constituents page 2.8-5 The table refers to maximum detected concentrations as being above secondary or primary MCLs, but the table does not give a maximum concentration detected. Please make this consistent with information given in Table 2-l-3 where detected concentrations were listed as maximum detected amounts (i.e. “up to X ppb”) Table 2.8-3 Proposed Sample Summary for Fire Training Pit page 2.8-11 ADEC requests the proposed sampling summary include analysis for dioxins and furans (method SWSZSO) for a minimum of twenty-five of the soil/sediment samples. Table 2.9-l Substantiated Groundwater Constituents page 2.9-4 See comments above in Table 2.X-2 regarding maximum detected concentrations. 2.10-l Site Background page 2.10-l The text states the primary objective of the baswide background sampling investigation is to determine the naturally occurring or “background” concentrations of the analytes being tested for at the OU D sites. ADEC is not aware of any naturally occurring- “background” concenuations of PCBs, VOCs, pesticides, herbicides, GRO, DRO, TRPH, SVOCs other than non-detect. Usually analysis for background concentrations is limited to inorganics naturally occurring such as metals. Be aware that Elmendorf Air Force Base has done a basewide background sampling investigation for metals and data gathered during this effort must be compatible for comparison purposes. 2.10.4.2 Field Investigation page 2.10-3 The text states hand auger borings will be advanced in four sampling locations and samples collected at six inches and at two feet below grade. Please provide the rationale for choosing the amount and depths of hand auger borings. Additional background data may be needed to define background values for use in risk evaluations. It is unclear from the text how many hand auger borings will be advanced at each sampling location. Please provide additional information on exactly how many borings will be advanced at each location. The text further states a soil boring will be drilled and sampled to a depth of twenty feet bgs. It is unclear what sampling frequency (i.e. every five feet or change in lithology) will be implemented for each location. Please provide this information in the revised workplan. Louis Howard
11/3/1994 Meeting or Teleconference Held Summary FFA Meeting November 3, 1994. Building 35-752 Former Drum Storage Area: 8 shallow borings have been completed with samples from 6 inches and 2 feet below ground surface (bgs). Based on preliminary results 2-20 foot soil borings have been located. Preliminary results had high levels of TPH and DRO from soil boring #5. Soil boring #8 had hits of some SVOCs at 6 inches bgs not identified in the other samples, The 2-20 soil borings are scheduled to be advanced today. Coolinq Ponds: Not sampled yet. [8 sediment samples. 1 angled soil boring from beneath pond sediment. 3 borings completed as monitoring wells. Sample 3 new and 2 existing monitoring wells.] Concrete Floor: Not sampled yet. [27 wipe samples.] Backfill Soils in Former USTs Location: 4-20 foot soil borings advanced. Scheduled to be completed today.[2 monitoring wells yet to be sampled.] Building 35-752 is located southeast of the Transmitter building 35-750. Building 35-752 sheltered four generators used for the the adjacent transmitter station between 1953 and 1987. Since the removal of the generators in 1987, the building has been used as a general storehouse. The four generators were fueled by presumably diesel which was stored in seven 5,000 gallon USTs located just ouside the southern end of building 35-752. In 1989, approximately 125 bags of soil weighing 2,000 lbs. each were stored in the building. The soils were reported contaminated with PC&. The source of the soils was the Roosevelt Rd. transmitter site. The soils have been disposed of at the old Fort Richardson Landfill. In 1991 floor dust from building 35-752 was sampled for the presence of PCBs, pesticides and herbicides. Arochlor 1254 was detected at 411 mg/kg (ENSR, 1994). Arochlor 1254 was not detected in samples collected from Roosevelt Rd. Contaminated soils were removed with the seven USTs in 1990. During post closure activities petroleum hydrocarbons were detected in soils and groundwater, however PCBs were not tested for (COE, 1991). Approximately one year after disposal the soils were sampled and tested for PCBs (E&E, 1992). The sampling revealed the presence of Arochlor-1260 at concentrations between 5,500 to 322,000 ug/kg. A 1993 investigation of the former tank area revealed the presence of Arochlor-1260 of up to 84,000 in soils outside the former excavation and 1,150 ug/kg of Arochlor-1260 in pond sediment samples (HLA, 1994). Sludge samples collected from four of the tanks did not reveal the presence of PCBs. The east side of building 35-752 was used as an emergency hazardous waste storage area. Drums containing PCB waste, dry cleaning solvents, paint waste and denatured alcohol were stored on pallets. Aerial photos from 1974 to 1985 showed surface staining near the western two USTs and potentially stressed vegetation near the ponds. Drums were not noted in any of the photos. Contaminants of concern include: Hydrocarbons, PCBs, ethylene glycol, chlorinated solvents, and metals. The contents of the seven USTs is uncertain. Presumably some or all of the tanks contained fuel for the generators. E&E, (1992) listed the contents of the tanks as waste oil. It is possible that the use of the tanks changed with time or their contents have been mis-identified at some time. Louis Howard
5/1/1995 Report or Workplan Review - Other Staff reviewed and commented on the Operable Unit D Draft Preliminary Source Evaluation 2 doc# 9000-036-420 dated April 1995. General Comments The tables summarizing the soil, groundwater and sediment samples would be more helpful if they included comparisions of the 10-4 to l0-6 RBC or HI of 1 or more and highlighted the levels that exceeded this amount. This would aid in determining where to proceed with future investigative efforts. Where groundwater was not investigated at a specific site, a description of how this decision was reached should be included in the text. 5.1.5 Findings and Conclusions page 5.1-32 ADEC concurs with the recommendations that bldg. 35-752 be investigated further under CERCLA. Please elaborate on what would be addressed under the additional investigation being recommended. Without any specifics, ADEC cannot determine the extent or scope of work being considered would address areas of concern. (This comment applies to all other sites currently being considered for additional investigation.) 5.2.5 Findings and Conclusions page 5.2-6 ADEC concurs with the recommendations that the stormwater outfall site be considered for no further action (NFA) under CERCLA. However, the a comparision must be made between the risk based screening concentrations and the detection limits. Additionally, the Army will be required to take action to obtain compliance with the federal and state wastewater regulations concerning stormwater discharges to surface water bodies (i.e. Ship Creek). NOTE TO FILE: The U.S. Army has water rights on Ship Creek. The Army’s first right is for 6.4 MGD; this right supersedes AWWU’s earliest water right. A second U.S. Army right for 1.1 MGD has a priority date later than a portion of AWWU’s rights. The U.S. Army water right does not vary over the year. 5.3.5 Findings and Conclusions page 53-13 ADEC concurs with the recommendations that bldg. 700/718 requires further investigation under CERCLA. Further elaboration is needed justifying lack of migration pathways and extent of contamination at the site. Reference ADEC NON-UST soil cleanup levels mentioned in text. 5.4.5 Findings and Conclusions page 5.4-13 ADEC concurs with the recommendations that bldg. 704 requires further investigation under CERCLA (see comment under 5.1 S). Please reference ADEC NON-UST DRO cleanup levels in text. 5.5.5 Findings and Conclusions page 5.5-16 ADEC concurs that further investigation for bldg. 796 under CERCLA is required (see comment under 5.1S). 5.6.5 Findings and Conclusions page 5.6-13 ADEC concurs that further investigation for bldg. 955 under CERCLA is required (see comment under 5.1.5). 5.7.5 Findings and Conchsions page 5.6-11 ADEC concurs that further investigation for the Dust Palliative site under CERCLA is required (see comment under 5.1.5). 5.8.5 Findings and Conclusions page 5.8-20 ADEC concurs that further investigation for the Fire Training Area under CERCLA is required (seec ommentu nder 5.1.5). Add to the table 5.8.2 that burning of pressurized-treated wood and burning of chlorinated organics as another possible source of dioxins and furans. 5.9.5 Findings and Conclusions page 5.9-18 ADEC concurs that further investigation for the Grease Pits under CERCLA is required (see comment under 5.1.5). Louis Howard
8/31/1995 Update or Other Action ENSR Preliminary Source Evaluation 2, OUD Fort Richardson, August received. Summary of PCBs Detected Building 35-752 Concrete Floor Wipe Samples Arochlor 1254 (ug/100 cm2) Ranges from 6 (Sample ID 94575256ML) to 750 (Sample ID 94575249MI) on 12/9/1994 Arochlor 1260 (ug/100 cm2) Ranges from ND to 39 (Sample ID 94575293MI) on 12/9/1994. Note to file: WIPE sampling is inappropriate for spills of PCBs to concrete more than 72 hours old. 40 CFR 761 classifies 4 types of remediation waste which includes: porous surfaces including, but not limited to, non-coated (e.g., unpainted) or coated structural surfaces such as floors, walls, and ceilings made of concrete, brick, wood, plaster, plasterboard, etc., that have been subsequently contaminated by spills from PCB liquids. Porous surfaces also include paints or coatings that have been applied to a non-porous surface such as metal. See full definition for Porous surface at 40 CFR §761.3. IMPORTANT NOTE: For PCB waste management involving porous structural surfaces, such as floors, walls, or ceilings made of concrete, brick, wood, plaster, plasterboard, etc., "clean" is defined by a bulk PCB concentration, e.g., weight/weight or volume/volume, such as a core sample, and not a surface PCB concentration, such as a wipe sample. Appendix A "DRAFT STANDARD OPERATING PROCEDURE FOR SAMPLING CONCRETE IN THE FIELD" contains a core sampling procedure developed by EPA Region 1 that may be appropriate for use in conjunction with Subpart N to determine the extent of the contamination in concrete. Other reliable and effective methods for collecting a core sample also may be used. PCB remediation waste verification sampling must be based on in-situ characterization data (i.e., "as found" per 40 CFR §761.61) rather than post-excavation or demolition composite samples collected from waste piles and roll-off containers. (EPA November 2005 Revitalazation Guidance). b. Sampling Porous Surfaces Wipe sampling is INAPPROPRIATE for surfaces which are porous and would absorb PCBs. These include wood and asphalt [and likely CONCRETE]. Where possible, a discrete object (e.g., a paving brick) may be removed. Otherwise, chisels, drills, saws, etc., may be used to remove a sufficient sample for analysis. Samples less than 1 cm deep on the surface most likely to be contaminated with PCBs should be collected (EPA August 1985 PCB Verification Sampling). Louis Howard
11/30/1995 Update or Other Action Chemical Data Report Groundwater Study Fall 1994 & Spring 1995 received. Since Spring 1994, the concentrations of DRO. GRO. and benzene at well AP-2982 have increased dramatically. suggesting that the weI1 is stil1 being affected by contamination from some unknown source. Trichloroethene was detected in all three samples of the triplicate from this well in Spring 1995; 1,2-dichIoroethane was reported only in the quality assurance duplicate in Spring 1995. PCBs were detected in two of three triplicate samples in Spring 1995 (0.794 and 0.804 ppb of Aroclor 1260), the first time PCBs have been detected in samples from this well. The pesticides alpha-BHC and delta-BHC were reported in the quality assurance duplicate from Spring 1995 at concentrations of 0.06 and 0.1 ppb, respectively. These levels are above the RBC of 0.037 ppb for technical grade BHC. AP-3231 has a history of detections of chlorinated hydrocarbons. Trichloroethene (I .4 ppb) and dichloroethane (2.5 ppb) were reported in Spring 1994; trichloroethene (11 ppb) appears again in Spring 1995. Louis Howard
1/29/1996 Report or Workplan Review - Other Staff reviewed and commented on the Draft CSMs, DQOs, ARARs OU D December 1995, Fort Richardson, Alaska. 3.1.2 Past Practices page 3.13 fourth and fifth paragraphs The text states the cooling ponds currently receive discharge water from building 35-750. Please provide information on whether or not the discharge is currently covered by a wastewater discharge permit from DEC. The text states that it was hooked up to the post sewer system by 1972 and thus that would negate the need for a cooling pond for discharge if it is still being used for this purpose. A clarification is needed whether or not the bld. is on the sewer system with the rest of the Post. 3.1.3.2 Remediation Sampling page 3.1-5 1st paragraph Note that rotating biological factors should reference: Risk Based Concentrations (RBCs). 3.1.7 Summary of Data Gaps and Proposed Actions page 3.1-14 and 3.1-15 Cooling Ponds The text states there will be an evaluation of ecological toxicity of the sediments present. DEC requests the Army, in consultation with EPA and DEC project managers, consider not using the cooling pond for discharge purposes and filling in the manmade cooling pond in with material (gravel, clean fill, asphalt) to eliminate a pathway to potential ecological receptors. -This action would save time and money that would not be spent on evaluating ecological risk from the sediments in the pond (hut not the drainpipe from the pond), or effects from contaminants in the surface water in the pond. Groundwater The text references the most likely remedial action for the groundwater at the site as natural attenuation. Please elaborate on how PCBs will naturally attenuate in the groundwater at this site (i.e. at MW AP-2986). As a pat-t of any proposed intrinsic remediation scenarios that the Army wishes to consider, there must be a description of what type of: institutional controls, deed restrictions and land use controls placed on groundwater use. Buidling 45590 3.2.7 Summary of Data Gaps and Propose Actions page 3.2-9 The text states there are no risk values for DRO and thus the extent of DRO does not need to be further evaluated. DEC does not concur. Secticn 3.2.3 on page 3.2-5 states that the “DRO was consistently detected in the groundwater from two of the wells and exceeded ADEC Water Quality Criteria in one well.” If the groundwater contamination is not to be pursued by the FFA, then it should be addressed by either the USTMP or the SFRERA. Regardless of which agreement it is covered by, analysis of total PAHs in the groundwater will have to be conducted to determine if the PAHs have leached from the soils into the groundwater and what levels &e being detected. Building 726 See comment above regarding DRO detected in the groundwater. The chemical specific analysis does not appear to address PCBs in sediments or PCBs in soil. The ARARs should mention TSCA standards and EPA’s PCB cleanup guidance and new proposed PCB cleanup regulations. Table 3-1 should have a footnote acknowledging that ADEC has adopted EPA RCRA standards by reference in 18 AAC 62. Section 4.0, proposed location-specific ARARs, does not note the parallel state statutes involving wetlands, historic preservation or endangered species. The section should incorporate the Alaska Coastal Management Program standards in 6 AAC 80. Given the preliminary nature of the investigation and lack of remedial alternative, DEC’s review of the ARARs section is preliminary at this point. The ARARs analysis in the management plan is very general and will need to be greatly expanded in the future. Identification of ARARs is an iterative process and additional analysis will be needed when remedial alternatives are proposed and analyzed. Louis Howard
3/22/1996 Report or Workplan Review - Other Staff reviewed and commented on the Draft Management Plan OU D February 1996, Fort Richardson, Alaska. 4.3 Potential Remedial Technologies Applicable to Soil and Water page 4-13 The text references a remedial alternative for the groundwater at OU D as natural attenuation (intrinsic remediation.) As a part of any proposed intrinsic remediation scenarios that the Army wishes to consider, there must be a description of what type of institutional controls the Army is considering, deed restrictions for the OU and land use controls placed on groundwater use until the groundwater meets drinking water standards. 7.0 References Please note the DEC has new Underground Storage Tank (UST) regulations (18 AAC 78 November 3, 1995) and an accompanying UST Procedures Manual (September 22, 1995) that supersedes the 1993 reference listed on page 7-l. Appendix C ARARS DEC has included many of the same comments that were made on the December draft in a previous letter to the Army: 1) The chemical specific analysis does not appear to address PCBs in sediments or PCBs in soil. The ARARs should mention TSCA standards and EPA PCB cleanup guidance and new proposed PCB cleanup regulations. 2) Table 3-l should have a footnote acknowledging that DEC has adopted EPA RCRA standards by reference in 18 AAC 62. 3) Section 4.0, proposed location-specific ARARs, does not note the parallel state statutes involving wetlands, historic preservation or endangered species (although the notification list does not some of these state agencies involvement). The section should incorporate the Alaska Coastal Management Program standards in 6 AAC 80. DEC has also noted an incorrect citation form in table 3-l on pages 3-11 and 3-13. 46 AS 14 should be cited as AS 46.14. greatly expanded in the future. Identification of ARARs is an iterative process and additional analysis will be needed when remedial alternatives are proposed and analyzed. Louis Howard
3/28/1996 Report or Workplan Review - Other EPA's (M. Wilkening) comments on the OUD Draft Mgt. Plan Page 3.1-2, Section 3.1.2 Past Practices. Another explanation for the difference in PCBs is that identification of PCBs is somewhat subjective, particularly for older, weathered Aroclors. Since the chromatographic patterns for Aroclor 1260 and 1254 are very similar, it is quite easy for an inexperienced analyst to misidentify these two Aroclors. Generally, even with misidentification, total concentrations are accurate to within IO-15 percent of the true value. Page 3.1-11, Section 3.1.3.6, Human Health Risks Carcinogenic. Indicate if the area surrounding Building 35-752 has been developed or is pristine, If development or filling has occurred, contamination may be present, and arsenic results may not be reflective of background concentrations. Section 3.2.7, Summary of Data Gaps and Proposed Actions. All initial comments have been corrected; however, another issue that has surfaced is the use of risk values for cancer at 10 (-7). New EPA Region X guidance now accepts,10 (-6) as the current risk level. This should be changed as reflected in EPA's new guidance. Appendix A Field Sampling Plan Page 5-1, Section 5.0, Analytical Procedures. The use of GPC and florisil column cleanups is strongly recommended for PCB and organochlorine pesticide analysis to remove hydrocarbon interferences. In addition, sulfuric acid cleanup is recommended for PCB analysis. Page 5-2, Section 5.0, Analytical Procedures. The cleanup methods cited are not appropriate for volatile organics, acid extractable SVOCs, or pesticide/PCB analyses. Exhibit l-11, Purging the Well. What guidance from ADEC was provided in developing the methods for purging? Provide the field criteria to be used by field personnel to determine whether to purge a well with a bailer or pump? EPA recommends that all purging and groundwater sampling be performed using a bladder or submersible pump following lowflow techniques. Provide an SOP for low-flow sampling techniques. Exhibit 3-10, Section 2.0, Monitoring Well Construction. Will prepack wells or field installed filter packs be used? Provide the slot size to be used for the monitoring wells. Provide the criteria used to determine the appropriate screen slot size and filtered pack material. Appendix B QAPP Page 3-2, Table 3-1. The use of GPC and florisil column cleanups is strongly recommended for PCB and organochlorine pesticide analysis to remove hydrocarbon interferences. In addition, sulfuric acid cleanup is recommended for PCB analysis. Section 5 and Table 2-2 of the Field Sampling Plan. There are indications of plant leaflets, invertebrates, and amphipod toxicity being sampled. If so, include the analyses, holding times, bottle type, preservatives (if any), and data validation procedures. Also, include a discussion of any special extraction, cleanup, or analytical procedures required for analysis of these matrices. Page 6-2, Section 6, Analytical Procedures. The use of GPC and florisil column cleanups is strongly recommended for PCB and orqanochlorine pesticide analysis to remove hydrocarbon interferences. In addition, sulfuric acid cleanup is recommended for PCB analysis. Louis Howard
6/6/1996 Update or Other Action UST 1109 was removed during the summer of 1996 by Oil Spill Consultants Inc. (OSC). UST 1109 contained waste oil and was located near the former dry well on the north side of Building 35-752. The contents of UST 1109 were sampled in May 1996 and analyzed for metals, PCBs, and total halogens. Lead, cadmium, and chromium concentrations were 1,760 mg/kg, 1.97 mg/kg, and 3.37 mg/Kg, respectively. No PCBs were detected in the sample, and total halogen concentrations were 724 mg/Kg Oil Spill Consultants, Inc. 1996. “Results for Tank contents Samples.” Letter to Mr. Tom Tyler, Brown & Root Service Corporation. June 6. Louis Howard
6/24/1996 Report or Workplan Review - Other Staff reviewed and commented on the Draft Final PSE 2 Evaluation OU D June 1996 Foe Richardson, Alaska. Table 4-l Analytes Lacking Current RBCs from EPA Region III (1996) page 4-4 EPA has come out with an updated list of RBCs effective June 20, 1996 which include listings for analytes previously listed as lacking a risk-based concentiation (RBC). For semi-volatile organic compounds: if acenaphthylene is equivalent to acenaphthene, then correct this discrepancy. Lf Di-n-butyl Phthalate listed in the table is the equivalent of Di-butyl Phthalate then it must be corrected. The new RBCs does include levels for iron and a soil screening level tiansfer level from soil to groundwater for thallium. Please correct the text and table to reflect this. Finally, while there are no specific RBCs for the specific PCBs listed in table 4 - 1 there is a general category for PCBs listed and it may be appropriate to compare levels detected to the RBC. 5.9-4 Figure Frame page 5.9-25 No figure was found showing the conceptual site model for the grease pits, please include one. Louis Howard
9/24/1996 Update or Other Action Proposed amendment to OUD FSP from ENSR to Army (K. Gardner). This letter serves as a follow-up to our discussion earlier this week concerning modification to the field sampling plan for OUD at Fort Richardson. We had discussed the sampling strategy for the cooling pond at Building 35752 & the relevance of performing biological sampling as a method of identifying the risk associated with the presence of PCB contamination in soils & sediments. The following text should serve as an explanation of our position on this matter. Review of the OUD management plan by ENSR senior risk assessment staff identified an opportunity to reduce the uncertainty in the OUD ecological risk assessment through modification of the proposed scope & current field sampling plan. The Final Management Plan for OUD called for no biological sampling, but did include the evaluation of toxicity In one sediment sample to be collected from the cooling pond at Building 35752. The purpose of the proposed sediment toxicity test was to reduce the uncertainty associated with the use of hazard quotients in a screening-level risk assessment by identifying the presence or absence of acute sediment toxicity to a sensitive laboratory test organism (Hyalella azteca). A hazard quotient (HQ) is the ratio of a given site media concentration. to a conservative benchmark value. Benchmarks are conservatively set at concentrations below which ecological effects are unlikely. The HQ approach contains inherent uncertainty because it employs ultraconservative assumptions, it does not evaluate the effects of multiple contaminants, & it does not take into account site-specific contaminant bioavailability. This inherent uncertainty can result in HQ risk characterizations that have little bearing on actual site risk. The primary ecological concerns in the cooling pond sediments are due to PCBs & the potential effects of multiple sediment contaminants. PCBs are not acutely toxic & express their impacts to ecological systems through bioaccumulation in the food chain. In this case results of sediment toxicity tests will not reduce the uncertainty in the risk characterization of PCBs. Sediment benchmark values protective of possible food chain bioaccumulation of PCBs are very conservative, resulting in trace amounts of sediment PCBs having an HQ greater than 1. Site risk from sediment PC6 exposure can be better evaluated through tissue analysis of biota exposed to the sediment PCBs. The presence of bioaccumulated PCB in tissues at the bottom of the food chain is required if effects are to occur further up the food chain. The potential receptors of food chain exposure to PCBs in the pond are moose, which have been observed feeding on the pond macrophytes, & ducks, which feed on benthic macroinvertebrates. Based on this information, we propose to modify the current field sampling plan to include tissue analysis of pond macrophytes & benthic macroinvertebrates, & drop the single sediment toxicity test & replace it with a quantitative & qualitative evaluation of the benthic macroinvertebrate community composition of the pond. Five replicate benthic macroinvertebrate quantitative samples will be collected with an Ekman dredge. Organisms will be separated from the sediment, identified, & enumerated. In addition, one qualitative sample of the pond macrobenthos will be collected from the cooling pond by a certified senior ecologist to identify the presence/absence of sensitive taxa. The presence of sensitive benthic macroinvertebrate taxa can provide direct evidence of the lack of sediment toxicity & can be more definitive than the results of a single toxicity test. Three replicate macrophyte tissue samples & one sample of benthic invertebrates will be collected & analyzed for PCBs. Only one sample of benthic invertebrates is possible given the size of habitat, abundance of organisms, & the mass of a sample required for analysis. All samples will be collected according to existing ENSR Standard Operating Procedures. PCB analyses will be done according to EPA SW-846 method 8080. Louis Howard
10/16/1996 Update or Other Action Preliminary Source Evaluation 2 OUD received. Polychlorinated biphenyl (PCB) wipe samples were collected from the concrete floor at Building 35-752. At the time of sampling, equipment was stored inside the building and areas of the floor were covered in ice. Samples were collected in a modified grid pattern based on available floor space. A total of 32 samples were collected and analyzed for PCBs. Each sampling location was measured from the template's southwest comer to the southwest comer of the building and marked with a paint pen for ease of relocation. Samples could not be obtained from the northwest comer of the building due to ice on the floor. Compounds of Potential Concern include monoaromatics (benzene, toluene, ethylbenzene, xylenes, 1,3,5-trimethylbenzene, 1,2,4-trimethylbenzene, and 4-isopropyltoluene), polycyclic aromatic hydrocarbons (PAHs) [naphthalene, 2-methylnaphpthalene, phenanthrene, benz(a)anthracene, benzo(b)f1uoranthene, benzo(k)f1uorarithene, benzo(a)pyrene, indeno(1,2,3-cd)pyrene, and benzo(g,h,i)perylene], chlorinated aliphatics (trichlorethene, 1,1, 1-trichloroethane, and 1,1- dichloroethane), PCBs, polychlorinated diphenyl alkanes (4,4'-ODT), phthalates (bis[2- ethylhexyl]phthalate), and metals (arsenic, barium, cadmium, chromium, mercury, nickel, and vanadium). Although provisional dose response factors have been developed for JP-4, JP-5, gasoline, and diesel fuel (EPA 1992b), these values are not appropriate for this evaluation. These values are based on fresh petroleum products and do not accurately represent the composition, and therefore the toxicity, of weathered petroleum products. They have not been subjected to rigorous peer review and are not routinely used, even by EPA, in risk assessment. As a result, bulk hydrocarbon measurements (GRO, ORO, and TPH) were not included in the semiquantitative risk assessment. Standardized criteria for aquatic species reflect various exposure routes and test methods, and are not available for all target compounds. As a result, compilation of ecological RBGs can involve significant effort. Due to the large number of analytes measured at Building 35-752, ecological RBCs were not compiled as part of this project. Risks to human health associated with noncarcinogenic compounds are above the estimated threshold for adverse effects. The excess lifetime carcinogenic risk for soil ingestion and drinking water ingestion exceeds the lower benchmark of 1 x 10-6 listed in the NCP. The greatest carcinogenic risk is associated with arsenic. The remainder of the carcinogenic risk is associated with PCBs, benzene, trichloroethene, and bis{2-ethylhexyl)phthalate. Louis Howard
2/17/1997 Site Added to Database Site added by Shannon and Wilson, Inc. S&W-Miner
5/28/1997 Report or Workplan Review - Other EPA (M. Wilkening) review comments on the OUD Draft FSP Addendum 1. GENERAL COMMENT 1. For the analyses to be performed, provide the bottle type to be used, the preservatives required (if any), and the holding times required for each analysis by matrix (l-e., soil, sediment, groundwater). SPECIFIC COMMENTS 2. Section 2.1, Page 2-3. Explain why equipment rinsate blanks will not be collected from the Bryant Airfield Complex. 3. Section 2.1, Page 2-1. When collecting soil sampies at the Bryant Airfield Complex, it is not in keeping with health and safety procedures to use olfactory observations to determine whether samples are additionally contaminated with svocs , PCB/pesticides, and/or petroleum hydrocarbons. Please comment on this Louis Howard
5/29/1997 Report or Workplan Review - Other Field Sampling Plan Addendum 1, Fort Richardson, Alaska received. The Department of Environmental Conservation (DEC) has received the document on April 12, 1997. Below are our comments. 1.2.3 Fish Hatchery page 1-3 The text states that only a review of existing data will be done for this site. There was a report of diesel range organics being detected in a monitoring well near the site. It is DEC’s understanding that the site will be investigated this field season under one of the two POL agreements the Army has with the State (USTMP or SFRERA). If that is not the case, then the site will need to be included for investigation under the OU D sampling plan. Louis Howard
8/18/1997 Update or Other Action Two USTs remain in the area: USTs 55A and 85A at Building 35-750. UST 55A is a 5,000- gallon heating oil tank, and UST 85A is a l,OOO-gallon waste oil tank. Both are located along the southeast side of Building 35-750. Louis Howard
10/7/1997 Report or Workplan Review - Other The Department of Environmental Conservation (DEC) has received the OU D Draft Remedial Investigation, Fort Richardson, Alaska dated August 26, 1997 on August 29, 1997. DEC has reviewed the document and has the following comments. 4.1.4 Page 4-20 The text references contaminants of potential concern (COPCs) in table 4.1-2, but offers no reasoning on why they should be retained as COPCs. DEC requests a footnote be added either in the text or table 4.1-2 referring the reader to Appendix G “Analytical Data”. DEC also requests that language be explaining the raticnaie why a ccntaminant is not considered a COPC if the RBC falls within the range of non-detects or when the range of non-detects exceed the RFK for that contaminant. This comment mainly applies to the semivolatile organic compounds and in some cases volatile organic compounds. 4.1.4.5 Groundwater page 4-44 4th para. The text refers the reader to the DAR (data assessment report) for a more detailed explanation of this section. Please spell out DAR and add text which will aid the reader to Appendix F of the RI where the Data Assessment Report is located. The tables presented in this appendix list COPC determinations for bldg. 35752. DEC requests adding the remaining sites to this section list the determination of chemicals of potential concern. Louis Howard
10/30/1997 Report or Workplan Review - Other Staff reviewed and commented on the Draft Operable Unit D Risk Assessment Fort Richardson dated September 23, 1997. DEC has the following comments regarding the document. General Comments Bldg. 35-752 has had some recent activity with regards to a new paved parking lot and removal of 1,500 cubic yards of soil off-site. DEC requests the Army indicate on a map the extent of the pavement added and what the horizontal and vertical extent of the excavation performed at the site. 27.5 Building 796 page 2-50 last sentence The text states that EDB (1,2 dibromoethane) detected at bldg. 796 is unlikely to have originated from unleaded gasoline since alkylated monoaromatics (toluene, ethytinzene, and xylenes) were not detected at elevated levels in identical samples. DEC agrees with the statement, however, it should be noted that a 1994 HLA release investigation report showed that residual contamination was left in place at 8-12 feet below ground surface because of concerns of compromising foundation integrity and the two existing USTs. Plate 27 in Section 9.0 ‘Illustrations” clearly depicts an unleaded gasoline dispenser as well as a diesel fuel dispenser associated with bldg. 796. Previous sampling efforts by contractors did not access the contaminated soils beneath the building, thus leaving question as to how much contamination is present. This may not have any bearing on the overall ‘risk” to receptors since it is at depth, but needs to be noted that the site has not been completely characterized. Attachment E The graphical presentation of risk and hazards presented here was a bit confusing and difficult to discern which COC was contributing to the excess lifetime cancer risk DEC requests that the risks for each COC and total site/analyte risk for each scenario be presented in a table format or bar graph rather than 3D images. Louis Howard
10/31/1997 Update or Other Action To remove PCB-contaminated soil, an Air Force contractor excavated the parking lot area to an estimated depth of0.9 m (3 ft) in October 1997. The area where PCB oils were suspected to have been drained in 1984 was not excavated. Approximately 1223 m3 (1600 yd3 ) of soil was collected and stockpiled on Elmendorf Air Force Base (EAFB). Louis Howard
9/4/1998 Update or Other Action Concurrence letter sent out to Army on extending date of Record of Decision for OUD to May 1999. Louis Howard
9/30/1998 Update or Other Action Approximately 1223 m3 (1600 yd3 ) of soil was collected and stockpiled on Elmendorf Air Force Base (EAFB). In September 1998, the soil was moved from EAFB by B.C. Excavating, Inc., and trucked to a new stockpile location southwest of Building 35-750. Louis Howard
10/8/1998 Site Characterization Report Approved Letter sent approving draft final version of Remedial Investigation/Feasibility Study for Operable Unit D. Louis Howard
3/23/1999 Proposed Plan Preferred alternative for contaminated groundwater at buildings 35-752, 796 and 45-590 is monitored natural attenuation combined with natural attenuation. Soil and sediment PCB contamination preferred alternative is phytoremediation and if not effective after two seasons-thermal desorption will be implemented. Additionally, windows and doors of Building 35-752 will be sealed with plywood and 8 foot security fence to prohibit access to PCB contaminated dust inside the building. Cooling pond and trench will be filled in and the source of water rerouted to sanitary sewer. Louis Howard
4/21/1999 Update or Other Action Directive number 9200.4-17P Use of Monitored Natural Attenuation at Superfund, RCRA Corrective Action, and Underground Storage Tank Sites, April 21, 1999 (Final). Each OSWER program has developed regulations and policies to address the particular types of contaminants and facilities within its purview13. Although there are differences among these programs, they share several key principles that should generally be considered during selection of remedial measures, including: • Source control measures should use treatment to address “principal threat” wastes (or products) wherever practicable, and engineering controls such as containment for waste (or products) that pose a relatively low long-term threat, or where treatment is impracticable. • Contaminated groundwaters should be returned to “their beneficial uses wherever practicable, within a timeframe that is reasonable given the particular circumstances of the site.” When restoration of groundwater is not practicable, EPA “expects to prevent further migration of the plume, prevent exposure to the contaminated groundwater, and evaluate further risk reduction.” • Contaminated soil should be remediated to achieve an acceptable level of risk to human and environmental receptors, and to prevent any transfer of contaminants to other media (e.g., surface or groundwater, air, sediments) that would result in an unacceptable risk or exceed required cleanup levels. • Remedial actions in general should include opportunity(ies) for public involvement that serve to both educate interested parties and to solicit feedback concerning the decision making process. Consideration or selection of MNA as a remedy or remedy component does not in any Way change or displace these (or other) remedy selection principles. Nor does use of MNA diminish EPA’s or the regulated party’s responsibility to achieve protectiveness or to satisfy long-term site remediation objectives. EPA expects that MNA will be an appropriate remediation method only where its use will be protective of human health and the environment and it will be capable of achieving site-specific remediation objectives within a timeframe that is reasonable compared to other alternatives. The effectiveness of MNA in both near-term and long-term timeframes should be demonstrated to EPA (or other overseeing regulatory authority) through: 1) sound technical analyses which provide confidence in natural attenuation’s ability to achieve remediation objectives; 2) performance monitoring; and 3) contingency (or backup)remedies where appropriate. In summary, use of MNA does not imply that EPA or the responsible parties are “walking away” from the cleanup or financial responsibility at a site. It also should be emphasized that the selection of MNA as a remedy does not imply that active remediation measures are infeasible, or are “technically impracticable” from an engineering perspective. Technical impracticability (TI) determinations are used to justify a departure from cleanup levels that would otherwise be required at a Superfund site or RCRA facility based on the inability to achieve such cleanup levels using available remedial technologies. Such a TI determination does not imply that there will be no active remediation at the site, nor that MNA will be used at the site. Rather, such a TI determination simply indicates that the cleanup levels and objectives which would otherwise be required cannot practicably be attained using available remediation technologies. In such cases, an alternative cleanup strategy that is fully protective of human health and the environment must be identified. Such an alternative strategy may still include engineered remediation components, such as recovery of free phase NAPLs and containment of residual contaminants, in addition to approaches intended to restore some portion of the contaminated groundwater to beneficial uses. Several remedial approaches could be appropriate to address the dissolved plume, one of which could be MNA under suitable conditions. However, the evaluation of natural attenuation processes and the decision to rely upon MNA for the dissolved plume should be distinct from the recognition that restoration of a portion of the plume is technically impracticable (i.e., MNA should not be viewed as a direct or presumptive outcome of a technical impracticability determination.) Louis Howard
9/15/1999 Update or Other Action USAF action memorandum sent regarding the closure of the polychlorinated biphenyl (PCB) contaminated location. The soil pile contaminated with PCBs which was generated from a parking lot excavation and paving activity at a leased building (Building 35750) on Fort Richardson and in front of Building 35752 which was inadvertently relocated to Elmendorf AFB was overexcavated in 1998. The location of the pile on EAFB was sampled for PCBs and lab results were above the USAF's cleanup goal for unrestricted use of 5 mg/kg (ppm). This location was overexcavated in 1999 and soil resampled for PCBs. This time lab results were below the AF cleanup goal of 5 ppm. Both times that the soil was overexcavated, the resulting soil was moved to its origination point (OUD Building 35-752 Fort Rich), where the Army is currently in the process of selecting a remedial action. The EAFB location of the soil pile has met its cleanup goal. The AF considers this location a clean closure and will treat future land use of this location as unrestricted. ADEC concurred with closure. Louis Howard
10/11/1999 Site Ranked Using the AHRM Site ranked based on new information Louis Howard
11/16/1999 Update or Other Action Cooling pond proposed for filling in to eliminate pathway for ecological receptors to low level PCBs in sediments. Louis Howard
11/16/1999 Long Term Monitoring Established Results from sampling at 35-752 showed a decrease from the high of 240 ug/L to 29 ug/L for benzene. At 45-590 the levels were lower than the 100 ug/L to 68.2 ug/L for tetrachloroethene. Louis Howard
12/22/1999 Report or Workplan Review - Other Staff provided comments on the August 23, 1999 Technical Memorandum which was received by ADEC on 9/9/99. It identifies data gaps for groundwater which exists after completion of the Remedial Investigation/Feasibility Study (RI/FS) and yet to be signed ROD for OUD source areas, Buildings: 35-752, 45-590, and 796. Main comments centered on the lack of monitoring for natural attenuation parameters: D.O., Nitrate, Iron II, Sulfate, Methane, ethane, and ethene. alkalinity, Ox-redox potential, pH, Conductivity, Chloride. Louis Howard
2/9/2000 Update or Other Action Staff sent a letter to the Army which commented on draft-final version of the Record of Decision (ROD). ADEC does not concur with the "No Action" remedy for the PCB soils stockpiled at Building 35-752. ADEC requested that the soils be addressed under CERCLA and that the 3 project managers and their supervisors meet to discuss the matter as soon as possible per the federal facility agreement "dispute resolution" section. Louis Howard
3/8/2000 Meeting or Teleconference Held J. Roberts attended conference call between ADEC, EPA and Army staff. New information caused Buildings 45-590 and 35-752 to be withdrawn from ROD and become Operable Unit "E". Transformers were opened and oil disposed of in a pit dug in 1983 then lit on fire at corner of 35-752. Transformers were operated and used until 1980 at 35-750. Air photos from 1966 shows open pit with trenches and solid waste disposal along with historical information that tanks and armored vehicles were washed down with carbon tetrachloride. This carbon tetrachloride is more than likely the source for the contaminant in groundwater associated with 45-590. The OU D ROD will consist of 796, the NFA sites and two party sites. New site-wide risk assessment to be done with OU E which will consist of the Armored Vehicle Maintenance Facility that is the source of the groundwater contamination detected at Building 45-590 and Building 35-752. Draft ROD for OU D will be delivered at end of March 2000 for agency review. Louis Howard
9/29/2000 Update or Other Action USACE ERDC CRREL draft report Geophysical Investigations dated September 2000 received. A geophysical study around Buildings 35-750 & 35-752 was conducted in May 2000 to determine the possible locations where PCB oils were drained from transformers now removed from the site, & to attempt to locate soil contaminated with petroleum. In 1982, the PCB oil in four 750-kVA transformers was drained out of them before they were removed. There are two different reports on how the oil was disposed of. One states that the oil was allowed to flow south along the east edge of Building 35-750 & across the parking lot along a low area on the ground surface where it pooled in a natural depression at the approximate center of the current parking lot (Jim King, pers comm, former Fort Richardson Fire Dept. personnel). A temporary soil berm was constructed to prevent flow of the oils south from the parking lot into the cooling pond (Jim King, pers. Comm.). Another version states that the oil flowed within a trench from the transmitters to an excavated pit located in the approximate center of the parking lot. Four 55-gallon drums of diesel fuel were poured on the pooled PCB oils, & this mixture was ignited by the Fort Richardson Fire Department (Jim King, personal communication). The diesel & PCB oils were almost burned to completion before they were extinguished with foam. There is no evidence from the GPR data of a depression that could be associated with the 1982 bum pit or a trench that would have extended from the transformers at 35-750 to the center of the parking lot area. Assume that these features were removed during parking lot excavation in 1997. Before it was paved, the parking lot was maintained by adding gravel & grading. These processes may have caused mixing & an increased volume of PCB-contaminated sediments. Therefore, the excavation of the parking lot area in 1997 may not have been sufficient to remove all PCB-contaminated sediments, especially in the southwest & northeast comers where the excavation was shallow. The resistivity soundings & profiles do not indicate the presence of a highly resistive anomaly that could be attributed to petroleum contamination. However, the absence of high resistivity values does not indicate that the site is clean. Due to physical constraints of the resistivity technique, low concentration or deep petroleum contamination might not be detected. In addition, resistivity analyses were not possible where the asphalt is present, limiting the extent of data collection in the parking lot area. CONCLUSIONS This investigation did not find evidence for a subsurface depression that may be associated with the burn pit in the parking lot area. Several trench-like features were located, but they were associated with buried utilities & not the transformer drainage trench. It is suspected that the PCB oils flowed in a shallow trench from the transformer area to the burn pit. It is likely that the northern part of the trench was buried beneath the garage bay addition & the rest of the trench was removed during parking lot excavation in 1997. Resistivity data from the south & east sides of the lot do not indicate petroleum contamination; however, PCB-oil contaminated soils may still exist beneath the asphalt parking lot & in areas not included in this investigation. Additional soil sampling for PCB's & hydrocarbons within the parking lot area & periphery is recommended. See site file for additional information. Louis Howard
10/19/2000 Meeting or Teleconference Held Staff met with U.S. Army and EPA project managers to discuss preliminary source evaluation investigation at Buildings 35750 and 35752. Soil sampling for PCBs and dioxins will be conducted around the road and nearby area of 35750 and the parking lot of 35752. Louis Howard
11/15/2000 Update or Other Action In 2000, ENSR conducted an investigation of surface and near-surface soil on the east side of Building 35-750, in a small area of the peripheral road to be crossed by a new buried cable. Low levels of PCB were found in several samples, although none was above the regulatory cleanup levels. The site was assigned to OUE based on information that PCB oil had been incinerated at the site, and that additional COPCs may have been present. Louis Howard
2/22/2001 Update or Other Action EPA sent comment letter on RCRA closure under 1991 Fort Richardson FFCA. EPA cannot confirm from the documentation that USARAK has met the requirements of the FFCA by obtaining a detailed chemical physical analysis of a representative sample of waste or using knowledge of the waste to determine if the wastes stored or released from this unit were hazardous. EPA is particularly concerned about the former drum storage area east of the building. USARAK has not provided documentation that wastes stored in this area were hazardous. Media or debris contaminated with polychlorinated biphenyls (PCBs) as found within and outside the building does not appear to be a hazardous waste as defined under 40 CFR 262.11. This unit has been referred to OU E for further investigation and remediation if necessary. Upon completion of the OU E investigation and remediation, USARAK must present documentation to EPA that COCs remaining at the unit do not exceed concentrations above the cleanup levels established at 18 AAC 75.341 Tables A1, B1, B2 before EPA could consider this unit to be clean closed. Louis Howard
12/12/2001 Institutional Control Record Established 1. All organizations conducting activities on United States Army Alaska (USARAK) controlled land are responsible for complying with established institutional controls (ICs). ICs are administrative, procedural, and regulatory measures to control human access to and usage of property. They are applicable to all known or suspected contaminated sites where contamination has been left in place. 2. These controls have been established to implement the selected remedial actions agreed upon by the U.S. Army (Army), the U.S. Environmental Protection Agency (USEPA), and the Alaska Department of Environmental Conservation (ADEC) in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) as amended by the Superfund Amendment Reauthorization Act (SARA). These controls also apply to remedial actions agreed upon under Two-Party Compliance Agreements. These agreements are concluded between USARAK and ADEC and apply to petroleum/oil/lubricants- (POL) contaminated sites. 3. ICs such as limitations on access, water use, excavations, and property transfers will supplement engineering controls as appropriate for short-term and long-term management to prevent or limit human and environmental exposure to hazardous substances, pollutants, or contaminants. Specific ICs include, among other things: limitations on the depth and location of excavations, prohibition of or restrictions on well drilling and use of ground water, requirements for worker use of personal protective equipment, site monitoring, and prohibition of certain land uses, types of vehicles, etc. 4. Organizational units, tenants, and support/contractor organizations must obtain an Excavation Clearance Request (ECR) for all soil disturbing activities impacting soils six inches or more below the ground surface. The review process for approval of an ECR begins with the identification of the current status (known or suspected hazardous waste site or “clean” site) of a work location. ECR’s for work in known or suspected hazardous waste sites: a. will include specific limitations and controls on such work; b. will include specific IC procedures, and notification, monitoring, reporting, and stop work requirements; c. may include procedures for management, characterization, and disposal of any soil or groundwater encountered or removed; d. will identify “project managers” for both the unit/contractor requesting the work and DPW Environment Resources. 5. The DPW project manager will conduct on-site inspections of each work site (at which ICs apply) to determine continued compliance with the terms and conditions of the approved ECR. DPW has the authority to revoke ECR approval if the specified terms and conditions are not being met. ECR forms are available at the Customer Service Desks at: a. Building 730 at Fort Richardson; b. Building 3015 at Fort Wainwright; c. Building 605 at Fort Greely. 6. USARAK has negotiated (with USEPA and/or ADEC) decision documents and/or Records of Decision (RODs) that mandate the implementation of ICs USARAK Directorate of Public Works, Environmental Resources Department (PWE), maintains copies of all decision documents and RODs requiring ICs in its real property files. PWE provides regularly updated post maps showing all areas affected by ICs. These maps can easily be accessed by using an approved intranet mapping interface application. Copies of these maps will be available to each directorate, activity, and tenant organization. To ensure the effectiveness of ICs, all organizational units and tenant activities will be informed on an annual basis of ICs on contaminated soils and groundwater in effect near their facilities. 7. ICs are enforceable by the U.S. Environmental Protection Agency (USEPA) and the Alaska Department of Environmental Conservation (ADEC). Failure to comply with an IC mandated in a decision document or ROD will violate the USARAK Federal Facility Agreement and may result in stipulated fines and penalties. This does not include the costs of corrective actions required due to violation of an established IC. Louis Howard
2/20/2003 CERCLA ROD Periodic Review Jennifer Roberts (ADEC) signed the first five year review document for the Post. ADEC’s concurrence with the findings of this five year review is based on the information presented in the accompanying Five-Year review Report, First Five-Year Review Report for Fort Richardson, Alaska. In order to construct a more permanent asphalt surface, approximately 1,500 cubic yards of soil were excavated from the gravel parking lot at the site in 1997. Soil removed during excavation activities was found to contain PCBs at higher concentrations than samples collected at other locations evaluated during the RI. A definitive source of the PCBs was never determined. The Proposed Plan for OUD indicated that the soil removed during the excavation would be treated using phytoremediation. The soil was stockpiled at the site and later packaged and shipped to a TSCA permitted TSDF for disposal. While the OUD ROD was being developed, new information was discovered about the source of PCB contamination in this area. Interviews with Fort Richardson personnel indicated that oil from four 750-kilovolt transformers located behind Building 35-750 was drained via a trench into a pit located adjacent to Building 35-752 and burned with diesel fuel. The interviews also indicated that another transformer was drained onto the ground in the area directly east of Building 35-752. A pre-RI investigation was conducted in 2000 at the Building 35-752 OUE source area to evaluate the site-specific subsurface geology and identify areas for future sampling. A groundwater sampling program was implemented and the first sampling event was conducted during September 2001; low levels of site contaminants were detected. During 2002, the OUE Management Plan was used to conduct the RI. A removal action was also conducted for the PCB contaminated soil that was excavated and stockpiled by the Air Force. This soil transported by rail for disposal at a TSCA permitted landfill in Idaho. Further action requirements for this source area will be documented in the OUE ROD. Considering the new information obtained after issuing the Proposed Plan, it was determined that this site had not been adequately characterized for PCBs and potentially dioxins. As a result, this site is being investigated as part of OUE. Access to Building 35-752 has been completely restricted. In addition, institutional controls will prohibit access to the groundwater as a source of drinking water and, the land use at this source area and neighboring source areas will remain industrial for the foreseeable future. Further action requirements for this site will be documented in the OUE ROD. The next Fort Richardson Five-Review will be conducted in 2008, five years from the date of this review. The next Five-Year Review will be the first full-term review for the OUC ROD. Jennifer Roberts
9/30/2003 Risk Assessment Report Approved Staff reviewed and approved the human health risk assessment approach document for operable unit E. Louis Howard
10/8/2003 Report or Workplan Review - Other Staff reviewed and commented on the General work plan for PCB treatability study at building 35-750. The text states the ADEC (the Department) and EPA have set cleanup criteria for PCBs (polychlorinated biphenyls) in soil at 1 ppm to protect human and ecological receptors through the ingestion of soil. The Department wishes to elaborate further on this cleanup level. The PCB cleanup level of one (1) mg/kg found in 18 AAC 75.341 Soil Cleanup Levels is specifically for unrestricted land use. Additionally, the text states the ADEC and EPA guidelines indicate that PCB concentrations of 1 to 10 ppm in soil can remain in the ground if capped with a suitable material to eliminate the complete pathway. The Department wishes to elaborate further on this matter. With the prior approval of the Department, PCBs in soil may be cleaned up by the Army to (A) between one (1) and ten (10) mg/kg if the Army (i) caps each area containing PCBs in soil at levels between 1 and 10 mg/kg; “caps” means covering an area of PCB contaminated soil with an appropriate material to prevent exposure of humans and the environment to PCBs; to be approved, a cap must be designed and constructed of a material acceptable to the department and of sufficient strength and durability to withstand the use of the surface that is exposed to the environment; within 72 hours after discovery of a breach to the integrity of a cap, the Army or the landowner shall initiate repairs to that breach; and (ii) provides the Department within 60 days after completing the cleanup, documentation that the Army has recorded a deed notation in the appropriate land records, or on another instrument that is normally examined during a title search, documenting that PCBs remain in the soil, that the contaminated soil has been capped, and that subsequent interest holders may have legal obligations with respect to the cap and the contaminated soil; or (B) an alternative PCB soil cleanup level (i.e. PCBs remain at levels greater than 10 mg/kg ) developed through an approved site-specific risk assessment, conducted according to the Risk Assessment Procedures Manual, adopted by reference at 18 AAC 75.340. The applicable EPA rule governing disposal and cleanup of PCB contaminated facilities under 40 C.F.R. Part 761.61 (PCB remediation waste ) may apply to PCB cleanup at this site. The PCB cleanup levels listed in Table B1 are based on cleanup levels referred to in 40 C.F.R. 761.61 for high occupancy areas with no cap. The Department will approve the document as final, pending incorporation of any other comments on the document from the EPA. The Department’s review and concurrence on the document is to ensure the proposed work is in accordance with State of Alaska environmental conservation laws and regulations. While the Department may comment on other state and federal laws and regulations, our concurrence on the treatability study does not relieve the United States Army or its consultants, contractors, or Army civilian personnel from complying with other applicable laws and regulations Louis Howard
5/18/2004 Update or Other Action Staff reviewed and approved the OU E Feasibility Study. There were no COCs for groundwater identified at the Building 35-752 Area. There were no COCs for soil under CERCLA identified at the Building 35-752 Area. Louis Howard
9/27/2004 Meeting or Teleconference Held The public meeting also will provide an opportunity for interested parties to submit written or verbal comments on this Proposed Plan, the RI/FS, or risk assessment documents. A 30-day comment period is scheduled from September 27 to October 26, 2004. Public meeting for Proposed Plan: Bldg. 35752 and Armored Vehicle Maintenance Area (AVMA). Site investigations and risk evaluations conducted for the Building 35-752 Area indicate that the contaminants found at the site do not pose a threat to human health or the environment and do not require cleanup action. Therefore, no further action is recommended for the Building 35-752 site. However, site investigations and risk evaluations performed for the AVMA indicate that contaminants detected in groundwater at the site do pose a threat to human health if groundwater is ingested. Therefore an action is recommended for the AVMA site to prohibit use of groundwater and to monitor contaminant trends in groundwater to ensure protectiveness. The preferred cleanup technology for groundwater at the AVMA site is land use controls, natural attenuation, and monitoring. PCBs were detected in near-surface soils at the site. Contamination in localized areas adjacent to the transformer mounting pad exceeded EPA screening values for industrial sites (concentrations ranged to about 100 mg/kg). In general, where PCBs were detected, they decreased with depth and contamination was limited to near-surface soils. Although not mandated, the Army has decided to proceed with removal of soil contaminated with PCBs exceeding levels established by regulation (State Regulations and Toxic Substances Control Act). The soil removal will be conducted under the Toxic Substances Control Act [TSCA]) self-implementation rule and will be completed prior to the OUE ROD. The preferred alternative for treatment of groundwater contaminated with PCE and dibenzo(a,h)anthracene at the AVMA is Alternative 2 - Land Use Controls, Natural Attenuation, and Monitoring. Alternative 2 is expected to achieve overall protection of human health and the environment, would be easily implementable, and would meet ARARs. Additionally, this alternative is a cost-effective and permanent solution to groundwater contamination at the AVMA. This alternative also provides measures to prevent exposure to currently contaminated groundwater and to maintain industrial land use at the site. Because, contaminant concentrations are low and isolated, active treatment is anticipated to be difficult and less effective. This alternative is subject to public comment and participation. No alternative will be selected until the public comment period ends and all comments are addressed. As with any remedial action under CERCLA, as long as contamination remains on site, the effectiveness of the selected remedy is subject to periodic reviews, not to exceed 5 years. If groundwater monitoring shows a consistent increase in contaminant levels or if the remedy is no longer protective, additional measures will be evaluated. Louis Howard
12/7/2004 Update or Other Action 2004 polychlorinated biphenyls treatability study at Building 35-750 conducted. Project consisted of reviewing existing background information, comparing four different PCB field test kits and selecting the most appropriate one for the project, excavating and disposing of PCB impacted soil and evaluating the data generated. Supersacks containing PCB-impacted soil shipped off-site for disposal on December 7, 2004 at an approved facility in the lower 48. Louis Howard
5/19/2005 Update or Other Action The field test kits comparision efforts indicated that the Hach kit was the preferred method of the four evaluated test kits to field screen the PCB impacted soil and guide the excavation activities for this project. Analytical results of the composite samples collected from the transformer mounting pad area excavation indicate that the Hach test kit screening results were generally successful in guiding the excavation of PCB impacted soil in the transformer mounting pad area. The field screening action level selected for soil excavation appears to have been slightly conservative and may have resulted in removing additional soil during excavation efforts. If the field screening action level was met, however, for each grid sampled, it is possible that PCB impacted soil above the cleanup criteria of 1 mg/kg would no longer remain. As a result of the PCB treatability study, a total of approximately 60 CY (180,000 pounds) of PCB impacted soil were generated from the transformer mounting pad and drainage areas. Based on analytical soil sample results, 2,076 pounds of soil was considered TSCA waste and the remaining 177,924 pounds of soil were disposed of as PCB impacted soil. The non-detectable results of the eight gauze wipe samples indicated that the concrete transformer mounting area pad surface is not impacted with PCBs. Louis Howard
10/11/2005 Record of Decision ADEC signed off on the Record of Decision for Operable Unit E. ADEC signature page states: "Signature sheet for the foregoing Operable Unit E at Fort Richardson, Record of Decision, between the United States Department of the Army and the United States Environmental Protection Agency, Region 10, with concurrence by the Alaska Department of Environmental Conservation. The decision may be reviewed and modified in the future if new information becomes available that indicates the presence of previously undiscovered contamination or exposures that may cause unacceptable risk to human health or the environment." OUE was established because two potential hazardous-substance source areas, the Building 35-752 Area and the Armored Vehicle Maintenance Area (AVMA), required further investigation to determine the nature and extent of contamination at the sites. Based on the remedial investigation and risk assessments, soil and groundwater at the Building 35-752 Area and the soil in the AVMA are recommended for No Further Action (NFA) under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). Recommendations- Based on the following data, soil at the Building 35-752 Area is recommended for NFA under CERCLA: Risk assessment results indicate that contamination in soils poses no unacceptable risk to human health or the environment; PCB contamination in soils is less than the relevant TSCA cleanup standards and surface soils containing PCBs in excess of 25 ppm have been excavated and removed from the site Based on the following data, groundwater at the Building 35-752 Area is recommended for NFA under CERCLA: • Risk assessment results indicate that contamination in groundwater poses no unacceptable risk to human health or the environment • Shallow groundwater is not used as a drinking water source and is non-potable due to high turbidity and high metals levels • Contaminant concentrations in groundwater are decreasing and the concentration of TCE (8.6 µg/L) is only slightly greater than the MCL (5 µg/L). Current data suggest that the contaminant is degrading • To ensure the protectiveness of the NFA decision, the Army will monitor groundwater and site conditions during the five-year reviews. Next five year review is approximately February 2008. All areas outside the building fit the definition of low-occupancy under the Toxic Substances Control Act (TSCA) regulation (e.g., unoccupied areas outside a building, electrical equipment vaults, or non-office space in a warehouse where occupancy is transitory). Thus, the relevant TSCA cleanup level is 25 ppm. All of the surface soils around the transformer mounting pad that contained PCBs in excess of 1 mg/kg were excavated and disposed at a TSCA landfill. Post 2004 PCB removal - mounting area: 14.1 mg/kg PCBs Post 2004 PCB removal - discharge area: 2.59 mg/kg PCBs Peripheral Road - 3.7 mg/kg PCBs (beneath asphalt road surface) The entire area is capped with geotextile fabric and a minimum of 0.5 foot of clean soil. Jennifer Roberts
12/12/2005 Conditional Closure Approved Effective with the signing of the ROD the site was "closed" but required monitoring of groundwater every five years as part of the evaluation required by the ROD. TCE is above Table C levels. Louis Howard
2/23/2007 Exposure Tracking Model Ranking Louis Howard
8/31/2007 GIS Position Updated 61.2445 N latitude -149.7117 longitude Louis Howard
1/16/2008 Update or Other Action CS DB Reckey 199021X014101 Fort Rich OUD bldg. 35752 USTs actions need to be imported into this site. Louis Howard
1/18/2008 Report or Workplan Review - Other Staff reviewed and commented on Draft Five-Year Review. The Alaska Department of Environmental Conservation (ADEC) has received the above document for review and comment via electronic mail from Mr. Bob Hazlett on January 14, 2008. Below are our comments on the document which are provided to your office as requested in an expedited manner (deadline given was January 28, 2008). Be aware that the 1994 Federal Facility Agreement (FFA) Section G. Review and Comment on Draft Documents 20.13 states: “Unless the Parties mutually agree to another time period, all draft documents shall be subject to a thirty (30) day period for review and comment.” This expedited review of the document is provided as a courtesy by ADEC to the Army and should not be construed by the Army or its contractors as standard operating procedure for future agency reviews. 1.2 Statutory Review : ADEC requests a footnote or additional text explaining what “unlimited use and unrestricted exposure” means. EPA OSWER no. 9355.7-03B-P states: “Unlimited use and unrestricted exposure” (UU/UE) means that the selected remedy will place no restrictions on the potential use of land or other natural resources. In general, if the selected remedy relies on restrictions of land and/or groundwater use by humans and/or ecological populations to be protective, then the use has been limited and a five-year review should be conducted. For example, if a site is cleaned up to an industrial-use level, and/or other types of uses are restricted (e.g., residential use), then, generally, UU/UE is not met.” 1.3.1 Federal Facility Agreement: ADEC requests additional text in this section regarding the FFA requiring a review of remedial action no less than every five years to assure that human health and the environment are being protected by the remedial action being implemented. Table 9-1 Response to Recommendations from 2003 Five-Year Review: Table 9-1 states the installation of fence with warning signs in June 2003 affects the protectiveness. ADEC agrees that the presence of a fence and signs around Areas A-1 and A-2 would prevent exposure to potential UXO buried in these areas, but has difficulty on it affecting protectiveness of human health or the environment negatively. Table 9-1’s main purpose is to call attention to issues of potential remedy problems (affecting current or future protectiveness) to human health or the environment. ADEC does not believe that installing a fence with warning signs, negatively affects protectiveness. If the intent is to show remedial actions which positively affect protectiveness, then the remaining three recommendations/follow-up actions would require a “Yes” as well. 10.0 Protectiveness Statements: ADEC requests adding a section 10.4 for OUE – Building 35-752 to this section. The sampling results from groundwater monitoring and review of site conditions needs to be included in this five-year review as was indicated would be done in the OUE Record of Decision (ROD). The 2003 Five-Year review states in section 7.5.1 on page 7-6: “…institutional controls will prohibit access to the groundwater as a source of drinking water and, the land use at this source area and neighboring source areas will remain industrial for the foreseeable future. Further action requirements for this site will be documented in the OUE ROD.” The OUE ROD stated the groundwater was recommended for no-further action under CERCLA. However under Section 2.2.1 Recommendations on page 20 it also states: “Contaminant concentrations in groundwater are decreasing and the concentration of TCE (8.6 ìg/L) is only slightly greater than the MCL (5 ìg/L). Current data suggest that the contaminant is degrading. To ensure the protectiveness of the NFA decision, the Army will monitor groundwater and site conditions during the five-year reviews”. This five year review will need to address groundwater and site conditions at Building 35-752. If the Army does not have sampling results for groundwater at Building 35-752, then it needs to state so in this review. Something can still be said about existing site conditions at Building 37-752 with regards to existing and future land use, land use controls being protective. ADEC has no comments at this time on the figures or spreadsheet accessible from the Corps FTP site. Louis Howard
2/27/2008 CERCLA ROD Periodic Review ADEC Jennifer Roberts signed the second five year review for Fort Richardson. The concurrence with the findings of the review is based on the information presented in the accompanying Five-Year review Report, Second Five-Year Review Report for Fort Richardson. This statutory review is required by the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) since all of the RODs for this site were signed after the effective date of the Superfund Amendments and Reauthorization Act of 1986 (SARA) and some of the remedial actions result in hazardous substances, pollutants, or contaminants remaining at the site above levels that allow for unlimited use and unrestricted exposure. The Fort Richardson NPL site is comprised of five OUs: OUA, OUB, OUC, OUD, and OUE. Records of Decision (RODs) have been written and signed for all five of these OUs, although it should be noted that the OUE ROD was signed in 2005, following the first Five-Year Review. The Five-Year Review found that the remedies for all Fort Richardson OUs are expected to be protective of human health and the environment upon completion, and in the interim, exposure pathways that could result in unacceptable risk are being controlled. It should be noted that because the sites in OUA and OUD sites have all been previously recommended for NFA or deferred to other regulatory authorities, no protectiveness determination was necessary for these OUs. Two sites (the AVMA and Bldg 35-752) were moved from OUD to OUE, and two OUD sites (Bldg 796 and Bldg 955) were designated as NFA in the OUE ROD. All remaining OUD sites have either been designated for NFA or have been referred to the Two-Party Agreement. Based on the following, soil at the Building 35-752 Area was recommended for NFA under CERCLA in the OUE ROD: • Risk assessment results indicated that contamination in soils poses no unacceptable risk to human health or the environment • PCB contamination in soils was less than the relevant TSCA cleanup standards and surface soils containing PCBs in excess of 25 ppm were excavated and removed from the site Based on the following data, groundwater at the Building 35-752 Area was recommended for NFA under CERCLA in the OUE ROD: • Risk assessment results indicated that contamination in groundwater poses no unacceptable risk to human health or the environment • Shallow groundwater is not used as a drinking water source and is non-potable due to high turbidity and high metals levels • Contaminant concentrations in groundwater were decreasing and the concentration of TCE (8.6 µg/L) was only slightly greater than the MCL (5 µg/L); data suggested that the contaminant was degrading • To ensure the protectiveness of the NFA decision, the Army will monitor groundwater and site conditions during the five-year reviews In general, the project managers should review continued operation and planned optimization changes to determine whether they are performing as intended (continuing to make progress toward achieving the RAOs). The project managers will further determine whether the plan is operating efficiently and cost-effectively. Based on the results of the annual evaluation, the project managers will set the operating parameters of the plan for the next year. The Army will make operational adjustments that they consider reasonable and in accordance with agreements made during the last annual evaluation. If the project managers can not reach concurrence on the operating parameters, then operating parameters previously agreed to will be followed until the issue is resolved in accordance with the dispute resolution procedures incorporated in the Federal Facility Agreement. The remedy at OUE is expected to be protective of human health and the environment upon attainment of groundwater cleanup goals through natural attenuation. In the interim, exposure pathways that could result in unacceptable risks are being controlled and ICs are preventing exposure to, or ingestion of, contaminated groundwater. Jennifer Roberts
5/19/2011 Update or Other Action Wing Instruction 32-7003 dated May 19, 2011 Land Use Control Management. OPR: 673 CES/CEANR Certified by: 673 CEG/CC (Col Russell R. Hula). This instruction implements AFPD 32-70, Environmental Quality, & is used in conjunction with AFIs 32-7020, The ERP, 32-7066, Environmental Baseline Surveys in Real Estate Transactions, & 673ABWI 32-1007, Safeguarding Utilities From Damage. It prescribes the processes & responsibilities for the management of & compliance with land use controls on Joint Base Elmendorf-Richardson (JBER) & applies to all military & civilian organizations that occupy facilities, or conduct business, on the installation. This publication does not apply to the USAF Reserve or Air NG units & members. The current land use control areas can be found on the Environmental Restoration map located on the GeoBase webpage. General: 1.1. Land use controls (LUC), such as limitations on access, water use, excavations, & property transfers, will supplement engineering controls as appropriate for short-term & long-term mgt to prevent or limit human & environmental exposure to hazardous substances, pollutants, or contaminants. Examples include limitations on the depth & location of excavations, prohibition of or restrictions on well drilling & use of GW, mgt. of excavated soils, & prohibition of certain land uses. LUCs, often used interchangeably with (ICs), are administrative, procedural, engineering, & regulatory measures to control human access to & use of property. 1.2. LUCs were established at JBER to prevent exposure to contaminated soil & water, based on agreements between the military services & the EPA & the ADEC. LUCs are used to reduce the potential for exposure to hazardous substances or to enhance the protectiveness of a soil &/or water cleanup remedy. They include restrictions on the use of portions of the shallow aquifer south of the Elmendorf Moraine, limitations on the types of buildings allowed in certain areas – primarily occupancy limitations, & land use designations for certain areas as recreational use only. The LUCs have been implemented at several sites & operable units (OU) as part of the ERP. LUCs were established for DP98 & OUs 1, 2, 4, 5, & 6 on former Elmendorf AFB property in their respective records of decision (ROD), as a component of the selected cleanup remedy. LUCs were also established for restoration & compliance sites formerly part of Fort Richardson in their respective RODs or Decision Documents. LUCs must be in place as long as a property is not available for UU or UE & may include temporary or permanent restrictions or requirements. When all cleanup goals have been achieved for a given site, temporary controls, such as GW use restrictions, may be removed. 2. Responsibilities: 2.1. JBER personnel, tenants, or contractors whose projects or activities require excavation in areas where site-specific LUCs are in effect will comply with all LUCs, 673ABWI 32-1007, & applicable AF instructions. Base contractors & tenant organizations will have LUC compliance requirements incorporated into their contracts & interagency agreements, as will be necessary. Failure to comply with LUCs will be grounds for penalty, in accordance with provisions specified in applicable contract documents. At project completion, the JBER organization or contractor will sign a certification of LUC compliance & return the compliance statement to 673 CES/CEANR. 2.2. The 673d Civil Engineer Squadron (673 CES): 2.2.1. Asset Management Flight (673 CES/CEA): 2.2.1.1. Natural Resources Management (673 CES/CEAN): 2.2.1.1.1. Environmental Restoration (673 CES/CEANR): 2.2.1.1.1.1. Will provide GW & site-specific LUC requirements throughout the installation & identify any known soil contaminated sites & monitoring wells for the area of the proposed project. 2.2.1.1.1.2. Will conduct annual site visits to ensure compliance with LUCs during project implementation. 2.2.1.1.1.3. Will conduct 5-year reviews, at 5-year intervals, or as required by any subsequent RODs. 2.2.1.1.1.4. Will prepare annual LUC compliance reports & submit reports to ADEC & USEPA by 1 February each year. 2.2.1.1.1.5. Will disseminate LUC information to personnel involved in LUC mgt, including real property & 673 CES/CEPT for inclusion into GeoBase. 2.2.1.1.1.6. Will operate an active educational program that includes disseminating updated fact sheets & LUC information, providing notices through the installation intranet & the Arctic Warrior newspaper, & by briefing LUC mgt at project kick-off meetings; Environmental, Safety & Occupational Health Council meetings, & CEB meetings. 2.2.1.1.1.7. Will coordinate any changes in the base general plan (BGP), or real estate transactions, with USEPA & ADEC. 2.2.1.1.1.8. Will maintain copies of signed certificates of compliance, indicating requestor’s adherence to LUCs during project execution. See site file for additional information. Louis Howard
6/6/2012 Update or Other Action Draft Project Management Plan received for PCB Site 35-752 (IRP) Performance Objective Optimized Exit Strategy for Site Closure Performance Indicators • Complete an approved OES Plan by April 2013 • Treatability Study Work Plan, Field Work, and Report • Complete an approved OU-E ROD ESD by March 2013 • Complete an approved RA Work Plan by July 2013 • Complete RA-C by December 2014 • Complete an approved RA-C Complete Report by May 2015 • OES Implementation Completion Plan • Annual Performance Monitoring and Reporting • OES Confirmation Report Potential Risks SVE system is not achieving performance metrics Risk Mitigation The system will be modified as necessary (e.g., additional extraction wells installed or system vacuum adjusted). Date of Achieving Performance Objective 2nd Quarter FY2013 Brief Description of Planned objectives Prepare and implement an approved OES Plan. Complete Treatability Study Work Plan and implement SVE system and revise Treatability Study as needed. Perform biannual monitoring to evaluate SVE system operations. Prepare an approved OES Report following SVE shutdown and drill two soil borings to evaluate and achieve SC. Louis Howard
6/22/2012 Report or Workplan Review - Other Staff provided comments on the draft project management plan. PCB Site 35-752 Page 2-19 Please note this site is a CERCLA site covered by the FFA under Operable Unit (OU) E. Please include text in site name to reflect that it is also a part of OUE. As such, any work plans, scoping documents, investigations, reports developed for this site will need to follow EPA CERCLA guidance and coordination of reviews with EPA and ADEC as required by the Fort Richardson FFA. Page 2-31 The text states: “The WPs will be submitted in the initial phases of the project for Air Force and regulatory review and concurrence according to the schedule outlined in the IMS. If regulatory agencies elect not to review/approve documents, approval will be sought through the Secretary of the Air Force/Installations and Environment (SAF/IE) to proceed with execution of the plan activities. The WESTON Team understands that a procedure has been established for this situation, and that the Air Force controls this process.” Failure to obtain work plan approval before implementing site work described above is considered a violation of Alaska regulations and may result in field work not being approved or additional work being required and may subject responsible parties and/or contractors to a Notice of Violation (NOV). In addition, proceeding with unapproved work plans and finalizing documents which are not approved by EPA or ADEC will likely cause the regulatory agencies to invoke dispute resolution as allowed for under the respective Federal Facility Agreements (XXI Dispute Resolution). Table 6-3 JBER-Elmendorf General comments Risk mitigation: In general, vadose zone soils shall not exceed maximum allowable levels for petroleum contamination for soil from 0 – 15’ bgs (i.e. direct contact for BTEX, PAHs and ingestion for DRO, GRO, RRO) regardless of HRC calculated levels. Treatment or excavations deeper than 15’ bgs may be warranted on a site-specific basis to prevent the soil from acting as a continuing source of groundwater contamination. In addition, sites with existing groundwater contamination above Table C cleanup levels will require that migration to groundwater cleanup levels be used for soil and ICs will be required. Once groundwater is below Table C for for a period of time (per the latest approved “Basewide Monitoring Program Well Sampling Frequency Decision Guide”), the maximum allowable levels may become the cleanup levels as determined by ADEC on a case by case basis. Louis Howard
11/1/2012 Update or Other Action Draft Groundwater Monitoring report received. The U.S. Army Corps of Engineers, Alaska District, Engineering Division, Geotechnical Engineering Services Branch, Chemistry and Industrial Hygiene Section (CEPOA-EN-G-CIH) was tasked by the Environmental Branch (CEPOA-PM-ESP) to collect groundwater samples at Building 35-752 on Joint Base Elmendorf Richardson (JBER), Alaska. The objective of this sampling event was to provide data indicating that the No Further Action (NFA) remedy selected in the Operable UnitE Record of Decision (OUE ROD) is continuing to be protective of human health and the environment. The regulatory agencies (Alaska Department of Environmental Conservation [ADEC] and the Environmental Protection Agency [EPA]) and the Army agreed that continued monitoring of this site is necessary to ensure that the NF A decision continues to be protective. All results are below the cleanup levels as defined in 18 AAC 75 Table C; detections of TCE in AP-3231 were noted but were below the cleanup level and below the levels reported in 2008 (0.00472 and a duplicate of 0.00500 mg/L; the 2012 result is 0.00312 mg/L). These results demonstrate that the concentrations of all target analytes are below ADEC cleanup levels. In addition, the concentration of TCE seems to be decreasing from the 2008 levels. Louis Howard
12/18/2012 Report or Workplan Review - Other The draft report deviates from the “Comprehensive Five Year Review Guidance”, EPA OSWER No. 9355.7-03 B-P (June 2001) in that for two issues & two OUs the report concludes the answer to the question about whether the issue may affect future protectiveness the answer given is “TBD”. The only options available consistent with the guidance are “yes” or “no”, & when the answer is uncertain, the appropriate response is “Yes” the issue may affect protectiveness, in this case future protectiveness. From that, the appropriate conclusion for each of those OUs in terms of protectiveness is one of the following: 1. “protectiveness deferred”, with recommendations & followup actions to be taken to resolve the uncertainty (which the Guidance calls for the lead agency to do within 1 year); 2. “currently protects, & in order to remain protective for the long term the following factions need to be taken:...” ; or 3. “Not protective” & say what will be done about the issue. If protectiveness if deferred, the Guidance calls for issues to be resolved in 1 year if at all possible. Tables 2-3 & 2-4 do not appear to present a complete chronology of events for OUC & OUE respectively. For example, Tables 2-3 & 2-4 do not include the site visits/inspections conducted for the FYR Report in June 2012. In addition, neither table includes the construction complete date (September 2006 according to the Summary Form on page ES-3). Groundwater monitoring is initiated in 2004, however annual monitoring appears chronologically in 2008. Please explain the gap in sampling. Please revise Tables 2-3 & 2-4 to provide a complete chronology of the significant events for OUC & OUE respectively. For OUE Building 35-752, please describe the quantity of PCB contaminated soils removed from the site, when this occurred, & if/how the soil was treated & disposed. OUE Building 35-752 no further action determination for groundwater requires monitoring in conjunction with the FYR. The reference provides an August 2012 date for this document. The document was reviewed by regulators in December 2012. Please correct reference date for final document. REFERENCES U.S. EPA. 2012. Integrated Risk Information System (IRIS). www.epa.gov/iris U.S. EPA. 2011. Draft Assessing Protectiveness at Sites for Vapor Intrusion: Supplemental Guidance to the “Comprehensive Five-Year Review Guidance.” OSWER Directive 9200.2-84 U.S. EPA. 2004. Performance Monitoring of MNA Remedies for VOCs in Groundwater. EPA 600-R-04-027 U.S. EPA. 2002. OSWER Draft Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathway from Groundwater & Soils. EPA 530-D-02-004 U. S. EPA 2001. Comprehensive Five Year Review Guidance”, OSWER No. 9355.7-03 B-P (June 2001) , EPA 540-R-01-007 7.1.2 Independent QA Oversight on Performance Based Contracts The site cleanup rules require that “collection, interpretation, & reporting of data, & the required sampling & analysis is conducted or supervised by a qualified, impartial third party”. Depending upon the specific terms in a performance based contract, a contractor may no longer be considered an impartial third party with respect to collecting, interpreting & reporting data. This should be taken into consideration when preparing scopes of work. ADEC strongly recommends the Air Force provide an on-site Quality Assurance Representative or a third party QA oversight contractor to monitor fieldwork for consistency with approved plans & contract requirements. Louis Howard
3/22/2013 Update or Other Action Draft UFP-QAPP received. SITE-SPECIFIC PROPOSED WORK The seven existing groundwater monitoring wells will be sampled in 2013 to confirm that contaminants of concern (TCE) remain below the MCL. The target analytes for SS044 are listed below: ? VOCs ? Metals (aluminum, arsenic, cadmium, chromium, iron, lead, manganese, and nickel) ? DRO and GRO ? PCBs The target minimum detection limits for groundwater are one-tenth of the groundwater ingestion cleanup levels listed in 18 AAC 75 Table C. Target detection limits and example detection and reporting limits are included in Tables 15-3 to 15-7 of the JBER Basewide UFP-QAPP. Seven monitoring wells (AP-2982, AP-2983, AP-2987, AP-3231, AP-3232, AP-3458, and AP-3503) will be sampled. Samples will be collected using low-flow sampling techniques, as described in SOP-13. Groundwater samples will be analyzed for VOCs, metals, DRO, GRO, and PCBs as described in Worksheet #11 and shown in Table 18-1. Observations of odor, turbidity, and color will be recorded on the groundwater sample collection log. Specific laboratory methods, bottle requirements, field preservation requirements, and sample volumes for these analyses are provided in Worksheet #19 of this work plan. Quality assurance/quality control (QA/QC) samples will be collected as specified in Worksheet #20. Sample handling will follow the procedures listed in SOP-02. Louis Howard
12/10/2013 Update or Other Action Staff received the draft gw monitoring report for Bldg. 35752. Groundwater samples were collected from seven monitoring wells (AP-2982, AP-2983, AP-2987, AP-3231, AP-3232, AP-3458, and AP-3503) using low-flow sampling techniques, as described in Standard Operating Procedure (SOP)-13 from the Work Plan. Samples were analyzed for volatile organic compounds (VOCs), metals, diesel-range organics (DRO), gasoline-range organics (GRO), and PCBs. Observations of odor and color were recorded on the groundwater sample collection log. Samples were collected between July 30 and August 1, 2013. Duplicate samples were collected at monitoring well AP-2983 TCE concentrations remain below cleanup levels in the groundwater, and continue to decrease. Based on the results of the last two rounds of groundwater sampling (in 2012 and 2013), as well as the results of OUE RI risk assessment, no further remedial action or monitoring for groundwater is needed, and the existing groundwater ICs at the SS044 site are no longer necessary. A Baseline Risk Assessment was completed as part of the OUE RI. The cumulative risk from contaminants in groundwater at the site fell within acceptable risk ranges for unrestricted use, and the risk assessment concluded that contamination in groundwater poses no unacceptable risk to human health or the environment. However, since TCE exceeded the MCL at well AP-3231, the OUE ROD determined that periodic monitoring during 5-year reviews would be required. Although TCE concentrations detected in well AP-3231 exceeded the MCL during historical sampling events, TCE concentrations have been steadily decreasing since monitoring began and were measured at concentrations at or below the MCL in sampling conducted in 2008, 2012, and 2013 (see Figure 1). Concentrations of TCE have now remained below the MCL for two consecutive annual monitoring events, and the consistent declining concentration trend shows that it is unlikely for concentrations to increase in the future Louis Howard
1/28/2014 Report or Workplan Review - Other Staff provided comments on the draft groundwater monitoring results. The Alaska Department of Environmental Conservation (ADEC) has received the above document on December 10, 2013 for review and comment for the SS044 Building 35-752 (Formerly with OU D now with OUE CS DB Hazard ID 2773, aka Former Generator Building for the adjacent high frequency transmitter Building 35-750). Pending EPA comments on the matter, ADEC concurs with the recommendations in the document that groundwater monitoring is no longer required to meet the conditions of the 2005 Operable Unit E Record of Decision under CERCLA. ADEC’s decision is subject to a future department determination that conditions at SS044 are not protective of human health, safety, or welfare, or of the environment. ADEC will then require the Air Force to conduct additional actions that meet the requirements of the site cleanup rules (18 AAC 75) and any other applicable regulations (e.g. 18 AAC 78). A “no further action” decision under CERCLA does not prohibit future regulatory activity undertaken pursuant to State authority Louis Howard
4/9/2014 Report or Workplan Review - Other Staff provided comments on the Draft Monitoring Well Decommissioning – SS044 (Bldg. 35-752) dated March 2014. The TCE levels at SS044 have been at the MCL of 5 µg/L in 2008, below the MCL in 2012 and 2013. While no statistics can be determined with six data points (1995, 2002, 2003, 2008, 2012, 2013), the fact the last three monitoring events have met the MCL allows for discontinuation of monitoring at SS044. This approach is consistent with the other decision documents: “Groundwater monitoring data will be reviewed regularly to assess the progress made by the selected remedy toward the cleanup levels and will continue in the downgradient portion of the plume until state and federal MCLs are achieved over three consecutive quarters.” (OUB 1997 ROD). “Monitoring will be discontinued when at least three subsequent sampling events indicate that contaminant concentrations have consistently dropped below MCLs.” (OUE 2005 ROD). Pending incorporation of any EPA comments, the document may be finalized. Louis Howard
4/28/2015 CERCLA PA Final Preliminary Assessment received. Under authority of CERCLA and the Superfund Amendments and Reauthorization Act of 1986, CH2M HILL conducted a PA visit at Joint Base Elmendorf-Richardson (JBER) during the week of December 15, 2014, with a follow-up visit on January 12 and 13, 2015, to secure additional information. Based on background research and visits to JBER, a total of four FTAs, seven fire stations, seven hangars, five crash locations, four areas where AFFF spray testing has occurred, and three additional “miscellaneous” locations have been identified as being active during the timeframe when AFFF has been used by the USAF for fire suppression. JBER Fire Department personnel identified an area of SS044 (Building 35-752) where a temporary burn pit was used in 1982 to dispose of polychlorinated biphenyl (PCB) oil that had been drained from four transformers. The contents of the pit (PCB oil and 200 gallons of diesel fuel) were allowed to burn to completion prior to being extinguished with AFFF (U.S. Army Cold Regions Research and Engineering Laboratory, 2000). Subsequently, the contaminated soil was stockpiled in an unlined location southwest of the building, and the soil was also used to repair the road that circles Building 35-752. Because investigations have indicated that contaminants (for example, trichloroethylene) have been found in groundwater at the site, PFCs may also have reached the shallow groundwater aquifer. A release of AFFF to soil from the pit, stockpile, or road fill areas is likely. Recommendation: initiate a site inspection as an investigation to collect and analyze waste and environmental samples to support an evaluation. Louis Howard
7/23/2015 Update or Other Action Draft Field Activities Report received for review & comment. SITE SUMMARY AND RECOMMENDATIONS No deficiencies were observed during the LUC inspection in 2014. LUC inspections will continue to be conducted annually in accordance with the OUE ROD. Five-Year Review Consistent with the National Contingency Plan (NCP), five-year reviews are required because the remedial action resulted in hazardous substances, pollutants, or contaminants remaining onsite above levels that allow for UU/UE. PCBs remain in soil at concentrations that do not allow for UU/UE. To date, three CERCLA five-year reviews have been performed for JBER-Richardson (which includes SS044), in 2003, 2008, and 2013. No recommendations specific to SS044 were made in the Third CERCLA Five-Year Review Report for JBER-Richardson, Alaska. NOTE To File: Future Five-Year Reviews for OUs B, C, and E are necessary because COC concentrations remain above levels that allow for unlimited use of the site and unrestricted exposure to the air, soil, and water. The next JBER-R Five-Year Review will be in April 2018. Recommendations Site SS044 is identified as a Green priority. NFA and continuation of internal administrative control inspections are recommended for this site. Louis Howard
8/10/2015 Report or Workplan Review - Other Staff provided comments on the Annual CERCLA Report. Staff recommended that 1,4-dioxane be sampled for in groundwater since it is associated with TCE contamination. Louis Howard
4/11/2016 Report or Workplan Review - Other Staff provided comments on the draft PFC Site Inspections work plan for JBER-E and JBER-R. Main comments were regarding obtaining prior approval from ADEC and EPA project managers before making changes to the approved QAPP and that the EPA RSSLs are less stringent than the human health soil cleanup levels and migration to ground cleanup levels ADEC will be promulgating this winter (2016). It was noted that WS# 10 is especially vague: "Based on the above, the best available screening criteria for PFOA and PFOS releases are the EPA PHAs for groundwater and RSSLs for soil. Because ADEC has proposed lower concentration limits that are in the public comment process, the ADEC levels should also be considered." It states that ADEC levels should also be considered, however in WS # 11, it states the concentrations of PFOA and PFOS in soil and groundwater will be compared to project screening levels based on the most conservative risk based EPA or ADEC values. For determining presence or absence of PFOS and PFOA using solely risk based screening levels is not acceptable to ADEC. If the migration to groundwater cleanup level is adopted by ADEC and it exceeds for PFOS or PFOA, a release is confirmed and it is deemed to be contaminated by ADEC. 18 AAC 75.990 Definitions. (23} "contaminated soil" means soil containing a concentration of a hazardous substance that exceeds the applicable cleanup level determined under the site cleanup rules. If AFCEC chooses to proceed with risk based values (as it is apparent upon review of Table 10-2 Steps 2, 4, & 5), then ADEC reserves the right to require further investigation/cleanup under 18 AAC 75 for all areas of concern/source areas where AFC EC determined no addition action was necessary at an area of concern/ source area, but the PFC levels detected exceed migration to groundwater cleanup levels for PFCs. See site file for additional information. Louis Howard
1/13/2017 Update or Other Action ADEC received a GW monitoring report for several JBER sites which summarizes the 2015 annual long-term management (LTM) activities, including remedial action-operation (RA-O) & ROD requirements conducted at JBER CERCLA sites. Site SS044 is identified as a Green priority. NFA, continuation of internal administrative control inspections, and groundwater sampling at monitoring well AP-3231 prior to the 2018 Five-Year Review are recommended for this site. See site file for additional information. Louis Howard
6/1/2017 Update or Other Action Site inspection (SI) at aqueous film forming foam (AFFF) areas on JBER-E and JBER-R waa received for review and comment. The purpose of the SI was to determine the presence or absence of perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS) in the environment. These compounds are a class of synthetic fluorinated chemicals used in industrial and consumer products, including defense-related applications. This class of compounds is also referred to as per- and polyfluorinated alkyl substances (PFAS). Soil results PFOA/PFOS detected at concentrations below EPA RBSLs and ADEC soil cleanup levels. Groundwater results had PFOS and PFOA detected above EPA Health Advisories but below ADEC Table C groundwater cleanup levels. See site file for additional information. Louis Howard
6/13/2017 Report or Workplan Review - Other Staff commented on the draft Site Investigation Report on AFFF areas at JBER-E and JBER-R. Soil Sampling The text states: “PID readings were obtained through direct readings of soil along the length of the soil core with the maximum reading recorded in the field notes and soil boring logs (Appendix A-2). PID readings of up to 20 parts per million were detected in boring UC35A-1 (maximum reading over 15-foot sampled interval in cores).” The 20 ppm PID reading and other positive results will need to be investigated under CERCLA or as required by 18 AAC 75.335 Site Characterization. This action would either be included in the PFAS field work to follow or as an additional action by a yet to be selected contractor. See site file for additional information. Louis Howard
6/19/2017 Update or Other Action EPA email requests clarification on whether AFCEC has a coordinated review on the data (especially lab packages) before it goes to the regulatory partners [EPA & ADEC] for review. For example, does Cornell Long (AFCEC) or someone else with PFAS expertise review and comment on the data from the AF sites. Louis Howard
7/17/2017 Report or Workplan Review - Other EPA received the Draft Site Inspection Report for Aqueous Film Forming Foam Areas, Joint Base Elmendorf-Richardson, Alaska, May 2017 for review the week of June 2, however Appendix B2 (App B2) laboratory data was not included. EPA received App B2 for review the week of June 20. EPA preliminary comments were sent to the Air Force on July 17, 2017. EPA Office of Research and Development staff, as well as EPA Region 5 Laboratory chemists, reviewed App B2. EPA has asked the Air Force for clarification regarding what level of report and data review was done by the government prior to submittal of the report to EPA and have not received a clear response. EPA’s initial review has identified a number of data quality issues and that the government data review should be completed and submitted to EPA before we are asked to finalize our comments. The comments submitted reflect only those requiring clarification on the narrative or figures and are not inclusive of review of the laboratory data, and therefore cannot substantiate any conclusions drawn on the presence/absence of PFAS at the 26 AOCs. EPA review of the laboratory data packages has raised a number of concerns with deviations from workplan approved standard operating procedures, laboratory methods, and data validation. EPA requests the Air Force clarify the level of governmental data review conducted on the JBER Site Inspection laboratory packages, and provide a copy of the Air Force data review to EPA. Additional EPA comments on the laboratory data are pending receipt of the Air Force data review. See site file for additional information. Louis Howard
8/15/2017 Update or Other Action AFCEC will have the U.S. Army Corps of Engineers conduct a level IV data review for the JBER PFAS data. Guestimates are it will be at least 4-6 weeks. The review may also include Eielson and Clear AFB since they were on the same contract/ same labs. Level IV data validation These data undergo full review and evaluation of a complete Data Validation Package (DVP) according to DQO/QAPP specific criteria, and National Functional Guidelines. This level of review includes all summaries, and raw data associated with the data package, and ensures the highest level of defensibility. Louis Howard
8/28/2017 Exposure Tracking Model Ranking Initial ranking with ETM completed for source area id: 73749 name: Leaking Tanks & Surface release Louis Howard
11/7/2017 Update or Other Action Letter report received for CY2016 [January 1, 2016 - December 31, 2016] Annual Land Use Control (LUC) and Institutional Control (IC) Monitoring at Joint Base Elmendorf-Richardson (JBER). This letter serves as the annual monitoring report on the status of LUCs/ICs in place on JBER-Elmendorf (JBER-E) and JBER-Richardson (JBER-R). The Air Force ensures compliance with LUCs by conducting periodic monitoring and site inspections. Formal LUC/IC inspections occur annually on JBER during late spring through early fall and are typically conducted by contract. A total of 55 sites were formally inspected. Random site inspections are also conducted throughout the year by JBER Restoration staff. Discrepancies: The interior PVC cap of monitoring well AP-3231 was missing during the time of the 2016 inspection/sampling effort. Louis Howard
11/21/2017 Update or Other Action Per AFCEC email: A memo from the USACE summarizing issues found in their review should be in hand on the 4th of December. Louis Howard

Contaminant Information

Name Level Description Media Comments
Trichloroethene > Table C Groundwater

Control Type

Type Details
Land Use Plan / Maps / Base Master Plan The Army has established Standard Operating Procedures & a Geographic Information System based tracking system to ensure the land use restrictions are enforced. The IC system has been incorporated into the post wide Master Plan, & compliance with ICs is reported in the Annual Monitoring Reports for each OU. The IC policy applies to all USARAK units & activities, Military & Civilian Support Activities, Tenants Organizations and Agencies and Government & Civilian Contractors.

Requirements

Description Details
Groundwater Monitoring Groundwater monitoring is ongoing at the site. Five year review due in 2008.

Missing Location Data

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