| Action Date |
Action |
Description |
DEC Staff |
| 5/7/1981 |
Site Added to Database |
Date the "umbrella" site,Tatalina "umbrella" site, Tatalina LRRS Base Facilities, Reckey 198125X91270, was originally added to the database. |
Former Staff |
| 7/22/1988 |
Update or Other Action |
Final Technical Support Document for Record of Decision (dated February 29, 1988) received. Sites 1 (SS001), 2, 3, and 9 are spill/leak sites, sites 5, 7, 8, and 10 are previously used dumpsites or waste accumulation areas, site 6 is an area of Lower Camp road oiling, and sites 4 and 11 are the active landfill and waste accumulation area, respectively.
Waste Accumulation Area No. 2 and Landfill No. 1 Lower Camp (Site 10): These contiguous areas were in use from the 1950s to 1977. Reportedly, minor spills and leaks from drummed wastes occurred during site operations. The area was cleaned of all stored drums in 1973, and filled to a depth of 4 meters. The landfill section of site 10 was in use from the 50s to the mid-1960s and covers an area of about 1 hectare. The landfill has been covered and graded and no contamination remains at the site and no debris was observed by the survey team. Therefore, no further action is considered warranted for site 10.
Note attached to this document from ADEC project manager, Ray Burger, remarks that:USAF (David Paulsen Colonel March 7, 1988), USEPA (Jacques Gusmano February 21, 1988) and ADEC signed the ROD in 1988 (Bill Lamoreux July 22, 1988) , but the ROD was based on almost no sampling of some sites, therefore was deemed inadequate and a RI/FS was necessary. |
Bill Lamoreaux |
| 4/19/1993 |
CERCLA SI |
EPA letter to Patrick M. Coullahan (LTC), Commander U.S. Air Force, 11th CEOS. This letter is to inform you that EPA Region 10 has completed the review of the Site Inspection (SI) report for the US Air Force Tatalina Long Range Radar Site, Alaska. The SI has been evaluated in accordance with 40 CFR Part 300 Appendix A, which is EPA's Hazard Ranking System (HRS) used to evaluate federal facilities for inclusion on the National Prioritles List (NPL).
From our evaluation, EPA has determined that the site does not score high enough to be proposed for inclusion on the NPL. Therefore, a recommendation of no further remedial action planned (NFRAP) on the EPA'S part will be included in our Federal Agency Hazardous Waste Compliance Docket tracking system. If new or additional information becomes available that suggests the facility may score high enough to be proposed for the NPL, EPA must reevaluate your facility accordingly.
EPA's NFRAP designation will NOT relieve your facility from complying with appropriate Alaska state regulations (i.e. A.S. 46.03, 18 AAC 75, 18 AAC 78, 18 AAC 60, 18 AAC 70, 18 AAC 80, 18 AAC 62). The Superfund Amendments and Reauthorization Act (SARA) of 1986, Section 120(a) (4)* requires federal facilities to comply with state cleanup requirements and standards when not listed on the NPL. All sources of contamination should be remediated to Alaska State clean-up standards.
An alternative water supply should be provided IMMEDIATELY to on site personnel, and the water gallery well should be resampled. Analytical results should be provided to both the EPA and the state of Alaska.
This facility will not be removed from the Federal Agency Hazardous Waste Compliance Docket, but as noted earlier, will be listed for no further action by EPA. If you have any questions regarding EPA's evaluatlon of the site, please contact me, at (206)553-1808.
*NOTE To File: CHAPTER 103--COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION, AND LIABILITY
SUBCHAPTER I--HAZARDOUS SUBSTANCES RELEASES, LIABILITY, COMPENSATION
Sec. 9620. Federal facilities
(a) Application of chapter to Federal Government
(1) In general
Each department, agency, and instrumentality of the United States (including the executive, legislative, and judicial branches of government) shall be subject to, and comply with, this chapter in the same manner and to the same extent, both procedurally and substantively, as any nongovernmental entity, including liability under section 9607 of this title. Nothing in this section shall be construed to affect the liability of any person or entity under sections 9606 and 9607 of this title.
(2) Application of requirements to Federal facilities
All guidelines, rules, regulations, and criteria which are applicable to preliminary assessments carried out under this chapter for facilities at which hazardous substances are located, applicable to evaluations of such facilities under the National Contingency Plan, applicable to inclusion on the National Priorities List, or applicable to remedial actions at such facilities shall also be applicable to facilities which are owned or operated by a department, agency, or instrumentality of the United States in the same manner and to the extent as such guidelines, rules, regulations, and criteria are applicable to other facilities. No department, agency, or instrumentality of the United States may adopt or utilize any such guidelines, rules, regulations, or criteria which are inconsistent with the guidelines, rules, regulations, and criteria established by the Administrator under this chapter.
(3) Exceptions
This subsection shall not apply to the extent otherwise provided in this section with respect to applicable time periods. This subsection shall also not apply to any requirements relating to bonding, insurance, or financial responsibility. Nothing in this chapter shall be construed to require a State to comply with section 9604(c)(3) of this title in the case of a facility which is owned or operated by any department, agency, or instrumentality of the United States.
(4) State laws
State laws concerning removal and remedial action, including State laws regarding enforcement, shall apply to removal and remedial action at facilities owned or operated by a department, agency, or instrumentality of the United States or facilities that are the subject of a deferral under subsection (h)(3)(C) of this section when such facilities are not included on the National Priorities List. The preceding sentence shall not apply to the extent a State law would apply any standard or requirement to such facilities which is more stringent than the standards and requirements applicable to facilities which are not owned or operated by any such department, agency, or instrumentality. |
Jennifer Roberts |
| 7/15/1993 |
Preliminary Assessment Approved |
Final Site Investigation Report (dated July 1993). |
Ray Burger |
| 3/28/1995 |
Update or Other Action |
Management Action Plan (draft dated Febraruy 1995, received March 28, 1995, no final received). |
Ray Burger |
| 2/14/1996 |
Update or Other Action |
Quality Program Plan Addendum for Interim Remedial Actions Final by ASRC Contracting Company Inc. The Air Force is conducting interim remedial actions at Tatalina LRRS as part of the Installation Restoration Program. These actions are based on the results of record searches,& investigations. The remedial actions are to be conducted at Sites LF010 & SS011.
This plan has been prepared for the United States Air Force (USAF) by ASRC Contracting Company, Inc. (ACCI) for the purpose of aiding in the implementation & documentation of remedial actions being conducted under the Air Force Installation Restoration Program (IRP). The limited objectives of this plan & the ongoing nature of the IRP, along with the evolving knowledge of site conditions & chemical effects on the environment & health, must be considered when evaluating this plan, since subsequent facts may become known which may make this plan premature or inaccurate.
The objective of this IRA is to remove buried drums of waste & perform site restoration as part of the IRP. This will be done by performing the following tasks:
• Conduct a geophysical survey in an attempt to locate buried drums.
• Excavate, remove, & dispose of drums, residual liquids, sludges, & other waste material. This includes labeling, manifesting, & transporting of hazardous waste.
• Characterize, excavate, & stockpile contaminated soil based on field screening & laboratory analysis.
• Characterize final site conditions following the conclusion of drum removal activities.
• Backfill & revegetate excavated areas when appropriate.
• Maintenance on soil stockpiles will be performed until December 1998 by the contractor. Maintenance will be continued by the Air Force, if necessary.
• Prepare a remedial action report providing a summary of work completed, an interpretation of analytical results, & recommendations for future site activities or closure.
Between 80 & 100 drums, either empty or filled with waste liquids such as used oil, were removed from the installation & shipped offsite for disposal in the early 70s. The contents found in these drams were used to plan for what may be encountered in drums excavated this summer [1997]. The drums had been located at a LF010 in an area referred to as Upper Waste Accumulation Area No. 2. The Upper Waste Accumulation Area No. 2 (LF010) is a separate location from the Upper Landfill No. 1 & Lower Waste Accumulation Area No. 2 (LF010) & is not an area considered for current activities under this plan.
The primary emphasis of this IRA is to remove drums with product. However, contaminated soil encountered during drum removal activities will be removed & stockpiled. Soil contamination will be identified using field test kits & laboratory analysis. For the purposes of this IRA, contaminated soil wall be defined as follows:
• PCBs > 1mg/kg in surface soil (0-1 foot bgs)
• PCBs > I0 mg/kg in subsurface soil (>1 foot bgs)
• DRO/RRO > 1,000 mg/kg m surface soil (0-1 foot bgs)
• DRO/RRO > 3,000 mg/kg in subsurface soil (> 1 foot bgs)
DRO/RRO is defined as the sum of diesel range organics (DRO) & residual range organics (RRO), as determined by State of Alaska Methods 102 & 103. This corresponds to an n-atkane range from the beginning Of Cl0 to the end of C36.
Gasoline range organics (GRO) are not expected to be present at the sites in significant concentrations because most POL products used at the installation were diesel & oil. Furthermore, gasoline, in contrast to used oil, was generally burned in vehicles & not discarded as waste. This assumption is supported by drum removal projects at other LRRS such as Cape Lisbume & Tin City, where over 95 percent of the recovered product consisted of used oil.
To verify that GRO in contaminated soil is negligible, the excavated soil & soil stockpiles will be analyzed for GRO, although on a less frequent basis than DRO/RRO. Assuming GRO is negligible, the DRO/RRO results can be considered a measurement of total petroleum hydrocarbons (TPH). Glycol may be present at the sites, however concentrations are not expected to significantly change the TPH value. The lab will flag sample results when glycol is present in significant concentrations. This will alert the contractor to any lab results that could be interpreted as high due to the presence of glycol.
After the geophysical survey is complete & excavatton boundaries are marked, surface sampling will be conducted at any area appearing significantly stained with contaminants. This screening will be conducted to detect any surface soil which requires removal & stockpiling before subsurface work can commence. The samples will be analyzed using immunoassay test kits for PCBs & lab testing on a quick turnaround basis.
For additional information see site file. |
Louis Howard |
| 2/12/1997 |
Update or Other Action |
Site added by Shannon and Wilson, Inc. this date. Site split off from the Tatalina "umbrella" site, Tatalina LRRS Base Facilities, Reckey 198125X912701. All relevant information from the "umbrella" site moved into subordinate sites 10/31/01 by Pikul and Petrik. |
S&W-Miner |
| 2/12/1997 |
Update or Other Action |
(Old R:Base Action Code = SI - Site Investigation). SI action added 02/12/1997 by Shannon and Wilson, Inc., based on Air Force Relative Risk Evaluation Worksheet dated 8/26/95. No other information available. |
S&W-Miner |
| 3/6/1997 |
Document, Report, or Work plan Review - other |
Tatalina LRRS, Draft Quality Program Plan, Addendum for Interim Remedial Actions, November 1996 received for review and comment on February 14, 1996.
The designation of "LF010" is used to identify the Lower Waste Accumulation Area 2 and Upper Landfill No. 1. Please clarify and address appropriately throughout the report. For the purposes of this DEC review, LF010 is assumed to refer to the Lower Waste Accumulation Area 2.
2.2 Survey and Removal of Soil and Drums at Sites LF010 and SS011 The first sentence states that LF010 reportedly contained buried drums. However, on page 13 of this addendum, during the 1996 site visit, drums were visible in several areas protruding from the hill slope. Please clarify.
DRO/RRO contaminated soil should be defined as 3,000 mg/kg in subsurface soil and 1,000 mg/kg in surface soil. Using these lower levels during the soil removal process, could likely result as the final action at sites LF010 and SS011, and potentially save on remobilization costs. However, if groundwater is impacted, remedial actions may be warranted.
Soil stockpiles should be bedded with sand, well rounded 3/8" minus material, or have a sufficient geofabric under the liner, and should be properly compacted to help prevent puncturing. The liners should be sloped to a leachate collection sump; this leachate will require monitoring. Please use the DEC Guidance for Storage, Remediation and Disposal of Non-UST Petroleum Contaminated Soils, dated July 29, 1991, as a reference.
It is stated that the equipment decontamination cleaning agents will not include solvents or potentially hazardous materials. The use of Orange Sol and Alconox detergents may not be sufficient for the potential contaminants and could result in cross contamination between samples.
It is stated that the treatment or disposal of the proposed soil in the cells is anticipated by 1999. PCB contaminated soil should not be stockpiled on-site for two years. If such material is generated, it will need to be treated or disposed of using approved meethods in a shorter time frame. Please elaborate on the treatment/disposal and the proposed liner maintenance.
The frequency of confirmation sampling should be based on the amount of soil removed and the surface area of the excavation. Please refer to the DEC Interim Guidance for Non-UST Contaminated Soil Cleanup Levels, dated July 17, 199l, which specifies a minimum of one sample for each 250 square feet of surface area in an excavation. |
Gretchen Pikul |
| 3/7/1997 |
Update or Other Action |
NOTE TO FILE: Tatalina LRRS is in the Under 40 Inch Zone (38 cm or 15 inches rainfall annually) therefore, the applicable current (as of 2/2012) cleanup levels with no differentiation for surface or subsurface soil [not Arctic zone which is defined by 18 AAC 75(4): “Arctic zone” means areas north of latitude 68 North; and area south of that latitude will be considered an “Arctic zone” on a site-specific basis, based on a demonstration that the site is underlain by continuous permafrost;]
DRO: ingestion is 10,250 mg/kg, inhalation 12,500, migration to GW 250 mg/kg,
GRO: ingestion/inhalation 1,400 mg/kg & 300 mg/kg migration to GW.
RRO: ingestion 10,000 mg/kg, inhalation 22,000 mg/kg & migration to GW 11,000 mg/kg.
PCBs: For unrestricted land use, PCBs in soil shall be cleaned up to one [1] (throughout the soil column not just in the 0-1’ interval) mg/kg or less, unless ADEC determines a different cleanup level is necessary as provided in 18 AAC 75.340(i); with the prior approval of ADEC, PCBs in soil may be cleaned up to
(A) between 1 & 10 mg/kg if the responsible person
(i) caps each area containing PCBs in soil at levels between 1 & 10 mg/kg; “caps” means covering an area of PCB contaminated soil with an appropriate material to prevent exposure of humans & the environment to PCBs; to be approved, a cap must be designed & constructed of a material acceptable to ADEC & of sufficient strength & 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 responsible person or the landowner shall initiate repairs to that breach; &
(ii) provides ADEC within 60 days after completing the cleanup, documentation that the responsible person 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, & that subsequent interest holders may have legal obligations with respect to the cap & the contaminated soil; or (B) an alternative PCB soil cleanup level developed through an approved site-specific risk assessment, conducted according to the Risk Assessment Procedures Manual, adopted by reference at 18 AAC 75.340.
LF010 soil confirmation sampling should have used the EPA. Field Manual for Grid Sampling of PCB Spill Sites to Verify Cleanup. EPA-560/5-86-017. May 1986 & not the discretion of the site superintendent & sampling team leader. Field screening with any device or method (ENSYS or PID), visual observations will not substitute for the required analytical sampling required for definitive data.
PCB soil sampling should have been based confirmation samples & not just Ensys field screening. ENSYS kits cannot reliably detect 1 mg/kg or less of PCBs. Definitive data is only from PCB soil samples collected with the EPA hexagonal grid sampling methodology. Specifically an excavated area will be subdivided into 15-foot squares. Centered within each of these squares will be four 5-foot square grids. Composite samples will be collected from the 9 points of intersection created by these 5-foot grids.
One dedicated steel sampling spoon will be used to scoop soil from each of the nine locations. The volume of this spoon will be sufficient to recover approximately 25-grams of material from each location. These 9 scoops will then be deposited in an 8-ounce sample container. The contents will be mixed with the dedicated sample spoon & prepared for shipment to the analytical lab.
There is PCBs at LF010 below 1 ft. which are greater than 1 ppm per the ENSYS field screening for PCBs.
Sample number, site, location, reading & result from ENSYS for PCBs in ppm.
5 LF010 (190,90) 0.48 < 10 ppm
6 LF010 (190, 1(0) 0.30 < 10 ppm
7 LF010 (190, 108) 0.54 < 10 ppm
8 LF010 (175, 1(0) 0.46 < 10 ppm
9 LF010 (42, 65) 0.50 < 10 ppm
10 LF010 (50, 110) 0.45 < 10 ppm
11 LF010 (50, 155) 0.43 < 10 ppm
12 LF010 (95, 135) 0.27 < 10 ppm
21 LF010 (158, 82.5) 0.42 < 10 ppm
22 LF010 (158, 87.5) 0.39 < 10 ppm
23 LF010 (158, 92.5) 0.42 < 10 ppm
24 LF010 (158,97.5) 0.31 < 10 ppm
29 LF010 (110, 93) 1.29 < 10 ppm
30 LF010 (115, 87) 1.17 < 10 ppm
31 LF010 (115, 105) 1.27 < 10 ppm
32 LF010 (13, 113) 1.14 < 10 ppm
37 LF010 (-16, 120) 0.59 < 10 ppm
38 LF010 (-16, 115) 0.25 < 10 ppm
39 LF010 (-16, 113) 0.67 < 10 ppm
Duplicate of 39: 40 LF010 (-16,113) 0.42 < 10 ppm
41 LF010 (35, 220) 0.64 < 10 ppm
42 LF010 (50, 220) 0.61 < 10 ppm
43 LF010 (70,220) 0.55 < 10 ppm
44 LF010 (50, 185) 0.37 < 10 ppm
45 LF010 (60, 180) 0.74 < 10 ppm
46 LF010 (125, 220) 0.70 < 10 ppm
47 LF010 (100, 160) 0.67 < 10 ppm
48 LF010 (125, 145) 0.68 < 10 ppm
49 LF010 (0, 20) 0.48 < 10 ppm
50 LF010 (-2,40) 0.47 < 10 ppm
51 LF010 (2, 60) 0.52 < 10 ppm
52 LF010 (50, 85) 0.46 < 10 ppm |
Louis Howard |
| 3/7/1997 |
Update or Other Action |
Addendum for Interim Remedial Action (drum removal workplan) dated November 1996; comment resolution meeting on March 7, 1997; excavation and removal of buried drums and associated soil contamination from site LF10 and SS11. |
Gretchen Pikul |
| 3/7/1997 |
Site Characterization Workplan Approved |
Remedial Investigation Workplan and associated plans (draft dated August 1996; final dated June 1997 and received on January 13, 1997; ADEC comment letter dated February 4, 1997; comment resolution meeting on March 7, 1997; no final received following ADEC comment letter and comment resolution meeting. |
Gretchen Pikul |
| 1/12/1998 |
Update or Other Action |
Final Management Action Plan (dated and received in January 1998). |
Gretchen Pikul |
| 2/10/1998 |
Update or Other Action |
Draft Remedial Investigation received. WAA No. 2 (Upper and Lower)and Upper Landfill No.1 (LF-010)
RI sampling focused on the Upper Landfill No. 1 and Lower WAA No. 2 areas. Sampling at
the Lower WAA No. 2 was conducted in conjunction with a drum removal action at that
area. RI results indicate that the two former storage and disposal areas have not released
contaminants that pose a risk to receptors. No COCs were identified in the human health risk assessment, and no COECs were identified in the ecological risk assessment for this site. In addition, detected levels of contarrunants were all below ADEC non-UST cleanup guidance and proposed soil and groundwater cleanup standards. No further action is recommended for this site. |
Gretchen Pikul |
| 3/31/1998 |
Document, Report, or Work plan Review - other |
The Department of Environmental Conservation (DEC), DoD Oversight group, received the
Draft Remedial Investigation Report. (dated February 1998) on February 10, 1997. The Draft
Remedial Investigation Report includes a Baseline Risk Assessment, a Human Health Risk
Assessment, and Ecological Risk Assessment. We appreciate the extended review deadline of
March 31, 1998. We have completed our review of Draft Remedial Investlgation Report and
provided comments below. Please note, the Draft Risk Assessment sections are currently under
review. A separate comment letter will be forwarded shortly.General Comments: The document is well written, comprehensive, and easy to follow. Tables such as ES-2 are very helpful in an overall view of the site. The site by site resuit and recommendations are a goo quick reference.
The Department files include the draft Sampling and Analysis Plan (SAP; (dated August 1996), the draft Quality Program Plan (QPP) - Addendum for Interim Remedial Actions (dated November 1996), and the final Remedial Investigation / Feasibility Study (RI/FS) Workplan (dated June 1997). During a site meeting on January 13, 1998, DEC received a final copy of the workplan. Requests were made by the DEC on January 13 and February 13, 1998 to obtain final copies of the SAP and the QPP documents; no final copies have been forwarded. Therefore, any DEC comments regarding the SAP are based on the draft SAP, and may not be indicative of final decisions incorporated into the final SAP. With that clarified, any deviations from the SAP need to be clearly stated with the rationale for the changes recorded in Section 8.0 (RI Recommendations) and other appropriate sections.
2.2 Review of past Studies and Remedial Actions: The report titled "Sterling Landing Fuel Tanks Site Environmental Baseline Survey" (dated March 1997) has not been received by the Department. The report should be forwarded as soon as possible.
8.12 SS-002, Spill No. 8, Truck Fill Stand (Sterling Landing) comments-Site Description: Include the reference for a detailed description of the fill stand and piping removal. Figure 8,12-1: Include the background sample on this figure. Table 8.13-3 and Table,8.13-4: These sample numbers presented in both of these tables are the same, was Table 8.13-4 intended as a summary results table? |
Gretchen Pikul |
| 6/2/1998 |
Site Visit |
ADEC participated in a facility-wide site visit. |
Gretchen Pikul |
| 6/4/1998 |
Update or Other Action |
Interim Remedial Action Report draft received.
Approximately 8,000 cy of material was excavated at site LF010. The excavation went as deep as 12' in some areas. The excavation was guided by the geophysical survey, PID readings, visual evidence of contamination, & the EnSys immunoassay PCB field screening kits. 9 major metallic anomalies were identified during the geophysical survey & excavated. In addition, the excavation was extended downslope (NE) of the geophysical survey grid due to the presence of drums protruding at the surface.
During the IRA, soils were considered contaminated if field screening and lab analysis indicated concentrations above target cleanup levels. These target cleanup levels WERE DETERMINED BY THE Air Force solely for the purposes of this IRA.
Target cleanup levels for the IRA were:
• 1 milligrams per kilogram (mg/kg) polychlorinated biphenyls (PCBs) from 0 to 1 feet below ground surface (bgs).
• 10 mg/kg PCBs for depths greater than 1 foot bgs.
• 1,000 mg/kg total petroleum hydrocarbon (TPH) (based on a diesel range organic [DRO]/residual range organic [RRO] analysis) from 0 to 1 feet bgs.
• 3,000 mg/kg TPH (based on DROIRRO analysis) for depths greater than 1 foot bgs.
Excavation activities were conducted from June 17 to July 11, 1997. Site restoration, including regrading & revegetation, was completed on July 16, 1997.
Lab analysis for PCBs & GRO were periodically conducted to verify the accuracy of the [field screening] test kits & confirm GRO negligible. The sampling events for both test kit sampling & lab analysis were at the discretion of the site superintendent & sampling team leader. In most circumstances, it was based on site conditions, such as visible soil contamination, the presence of leaking drums, or PID readings.
A total of 52 [field screening] samples were collected at sites LF010 & SS011 & screened for PCBs using the EnSys immunoassay kits. 49 of these [field screening] samples were collected from LF010 [& 3 from SS011]. Sample collection locations for the All EnSys [field screening]results were below the 1 & 10 mg/kg cleanup objectives for PCBs. To confirm these [field] screening results, 8 lab samples were collected & submitted for PCB analysis to verify the accuracy of the PCB field screening. No PCBs were found at detectable concentrations in any of the eight samples. Therefore, no soil was removed due to PCB contamination.
A total of 20 soil samples were collected & analyzed for DRO/RRO. Only 1 sample exceeded the cleanup objective. Sample 97TATLF010022SS was collected from 4 to 4.5' bgs & had a combined DRO/RRO value of 29,900 mg/kg. The sample was collected from stained soil near a drum which appeared to have leaked. After the sample was collected & confirmed to be above cleanup objectives, the stained soil (approximately 2 cy) was excavated & placed in drums.
A sample was collected to ensure that the contamination had been removed to below the cleanup objectives. Sample results indicated a DRO/RRO value of 1,380 mg/kg, which is less than the 3,000 mg/kg cleanup objective for soils greater than 1' bgs. The PCB analytical results for this sample were non detect.
Two samples were also collected & submitted for GRO analysis & were non detect. Drum removal activities caused an additional drum to leak. The contaminated soil (approximately 0.5 cubic yards) was placed in drums & sampled for waste characterization (Drums LF-010-47 a & b). The soil exhibited high DRO & RRO & was sent off site for disposal.
A total of 6 confirmation samples were collected & submitted for analysis prior to backfilling to confirm field screening results & ensure cleanup objectives have been met for PCBs & TPH. In addition, these samples were analyzed for GRO, VOCs, SVOCs, pesticides, & metals to provide a thorough characterization of the final site conditions. No contaminants of concern were detected in these analyses.
Soil contamination at LF010 was limited to localized areas surrounding leaking drums. The stained soil was excavated & confirmation sampling indicated that contamination had been removed to levels at or below cleanup objectives. Drums with product or potentially hazardous waste were removed from the site. The landfill area is fairly large & dispersed & there is a small possibility that an isolated drum of product/waste remains buried at the site.
However, the significant geophysical anomalies were investigated & it is very unlikely that clusters of drums with product remain buried at the site. As a result of these removal actions, no further excavation activities are recommended for this site. Monitoring of the area may be warranted because of the slight possibility that a small quantity of waste still remains at the site. |
Louis Howard |
| 7/6/1998 |
Update or Other Action |
Interim Remedial Action report (draft dated March 1998,received on June 4, 1998, no final received). The Department of Environmental Conservation (DEC), DoD Oversight group, received the Draft Interim Remedial Action Report (dated March 1998) on June 4, 1998. Specific Comments-Objectives: The target cleanup levels are listed in this section. As stated in the Department comment letter (dated March 6, 1997) on the IRA workplan, the target cleanup levels listed in this section are acceptable, however, if groundwater is impacted, remedial actions may be warranted. Include how the potential impact to groundwater been addressed in this study. Also include the depth to groundwater in these areas.
Pg. ES-2 Site LF010 Remedial Activities: It is stated that the excavation went as deep as 12 feet in some areas. Include whether native, undisturbed soil was encountered, and incorporate within appropriate sections throughout the report. Also, the IRA workplan states that the drums were estimated to be buried up to 18 feet bgs. Explain how this area has been fully characterized.
It is stated that no further excavation activities are recommended for this site. However, this section should also include that a monitoring program of 3 to 5 years (to develop a trend) should be implemented. A 5-year review should also be conducted to reevaluate the monitoring program. This comment also applies to Site SS011 Remedial Activities presented on page ES-3.
Pg. 4-2 4.1.2 Field Screening and Analytical Results: Include the reasoning for 49 samples at LF010 and 3 samples at SS011.
Pg. 4-3 4.1.2 Field Screening and Analytical Results: Sample 97TATLF01002SS is presented on Figure 4-1 within Area A, not Area E. Also, it is stated that this sample was collected to ensure that the contamination had been removed to below the cleanup objectives. However, the sample was collected at the same depth as the initial sample. Explain how this sample is a confirmation sample.
Pg. 4-3 4.1.2 Field Screening and Analytical Results: It is stated that the PCB analytical results for sample 97TATLF01002SS (possibly typographical error, and should be 27SS) were non-detect. Figure 4-1 shows this sample was not tested for PCB. In addition, it is stated that 2 samples were submitted for GRO analysis. Figure 4-1 shows only one sample was analyzed for GRO. Please correct the figure, text, and/or table.
Pg. 4-3 4.1.2 Field Screening and Analytical Results: It is stated that contaminated soil was placed in drums (LF-010-47 a and b) and sampled for waste characterization. However, Figure 4-2 shows only 047, with no a or b. Please correct the figure, text, and/or table. Also, include the actual concentrations for the “high DRO and RRO contamination” that was sent off site for disposal.
Figure 4-1 should be corrected to show sample 97TATLF010027SS as a confirmation sample. Also, the confirmation samples are fairly localized in 2 areas, with 4 samples in the eastern end of Area A, and one sample in Area E. Include how these confirmation sample locations were chosen. It is stated that sample 97TATLF010027SS was analyzed for PCB. However, Figure 4-1 shows no PCB analysis for this sample.
It is stated that no contaminants of concern were detected in these analyses. This statement should be revised to include the samples that did have detections, and whether the concentrations are above or below the draft regulations (18 AAC 75, dated May 4, 1998). Table 4-2 presents Aroclor-1260 at 61 ppb for sample 97TATLF010014SS, and lead at 3,400 ppm for sample 97TATLF010027SS.
Table 4-1: The “location” column is difficult to correlate to the locations on the figures. Also, there is one location that is labeled “stockpile”; page 3-9 states that the soil was not stockpiled. Please explain this label. In addition, explain what numbers are presented in the “reading” column. The table title indicates that field screening results are shown on the table. If this data represents analytical data, then the table title, notes, and references should reflect this. |
Gretchen Pikul |
| 10/13/1998 |
Site Characterization Report Approved |
Remedial Investigation Report (draft dated February 1998, final dated and received in October 1998) includes a risk assessment; ADEC comment letter dated March 31, 1998; comment resolution meeting on May 15, 1998. Soil and groundwater samples from BH11/MW were used to assess environmental conditions downgra&ent from the Upper Landfill No. 1. Analytical results for the three soil samples collected from BH11/MW indicated no VOCs, pesticides or PCBs were detected above the method reporting limits, with the exception of methylene chloride, which was detected; however, the result was qualified because of the associated method blank detection. DRO was detected in two samples at 12 and 13 mg/kg; however, a review of the
laboratory chromatogram data did not indicate a pattern match for diesel, indicating biogenic material in the soil matrix may have contributed to the results. GRO and ICRO were not detected above the method reporting limits in any of the samples.
Analytical results for the groundwater sample collected from BH11/MW indicated trace levels of VOCs, SVOCs and pesticides, and in most cases the levels were below the method reporting limit. Results were qualified by the laboratory because of a matrix interference, which increases the uncertainty of the results. Levels that were reported for these contaminants were below risk-based levels developed in the baseline risk assessment.
Soil from two test pits and two surface samples were used to assess environmental conditions downgradient from the drum removal activity at Lower WAA No. 2. Each test pit had two soil samples: the top sample between 2.5 and 3 feet, and the bottom sample at 4.5 feet.
Analytical results for the test pit soil samples indicated the presence of a few VOC, SVOC, and pesticide contarmnants at very low levels below human health and ecological riskbased
risk levels developed in the baseline risk assessment. No pesticides or PCBs were detected above the method reporting limits. GRO was also not detected above the method reporting limits. DRO ranged from 6 to 18 mg/kg; however, review of the laboratory analytical chromatogram data did not indicate a pattern match for diesel in the samples, indicating biogenic matenal in the soil matrix may have contnbuted to theresult. RRO was below the reporting limit m TP2 and was detected at 90 and 121 mg/kg in TP1.
Analytical results for the surface soil samples indicated the presence of low levels of VOCs, SVOCs, and pesticide contaminants and, in most cases, the levels were below the method reporting limit. GRO ranged from below the method reporting limit to 3.95 mg/kg, DRO ranged from 44 to 45.5 mg/kg, and RRO ranged from 256 to 281.5 mg/kg in both samples. Review of the DRO laboratory analytical chromatogram data did not indicate a pattern match for diesel in either of the samples, indicating biogenic material in the soil matrix contributed to the results. Levels of the contaminants that were detected were all below human health and ecological risk-based levels developed in the baseline risk assessments.
The analytical data indicates that residues from organic compounds were detected in soil and groundwater near the Upper Landfill No. 1 and Upper and Lower WAA No. 2; however, the detected levels of these compounds were very low and pose little or no threat to human or ecological receptors. No COCs or COECs were identihed in the baseline risk assessment for the Upper Landfill No. 1 and Upper and Lower WAA No. 2 (LF-010). Levels of contaminants are also below current ADEC non-UST cleanup guidance and below proposed cleanup standards in draft 18 AAC 75 regulations. On the basis of RI analytical results, site observations and the baseline risk assessment, no further action is recommended for this source area. |
Gretchen Pikul |
| 10/13/1998 |
Risk Assessment Report Approved |
Risk Assessment, a part of the Remedial Investigation Report (draft dated February 1998, final dated October 1998); ADEC comment letter dated April 6,1998; comment resolution meetings on May 11, 1998; ADEC Memorandum on Response to Comments dated August 3, 1998. |
Gretchen Pikul |
| 12/4/1998 |
Meeting or Teleconference Held |
Record of Decision template reviewed and discussed. |
Gretchen Pikul |
| 12/24/1998 |
Update or Other Action |
The Department of Environmental Conservation (DEC), DoD Oversight group, received the Draft Proposed Plan for No Further Action (dated December 1998) on December 8, 1998. The Draft Proposed Plan for No Further Action covers IRP Sites DP-005, OT-012, SS-001, SS-007, SS-009, LF-010, and OT-006, Tatalina LRRS, Alaska
ADEC has completed our review and provided comments below. A State of Alaska Memorandum dated December 9, 1998 has also been submitted in response to this draft Proposed Plan; similar comments were noted but not reiterated in this comment letter.
Within this Proposed Plan and the upcoming Record of Decision (ROD), a deed notice/land record (and dissemination of this information to current and future site workers), documentation of adequate cover, and an annual cover maintenances chedule (for 2-3 years following the final ROD) will be necessary at several sites. Theses ites include SS-009,LF-010, DP-005, and SS-007. In addition, site SS-001 will require a deed notice, as well as a
mechanism to distribute this information to current and future site workers. The design and setup of the Recommended actions section stands out nicely and is easily read. While reviewing this Proposed Plan, several RI figures present "-" within the
petroleum hydrocarbon analyses (GRO, DRO, and RRO). On the figures, the "-" indicates that the sample was not analyzed or reported for this parameter.
However the laboratory data indicates that many of these sample data is "R" flagged; this information is not clearly discussed within the RI text. For example, SS-00 the MAR site, presents extremely limited data on the petroleum hydrocarbon compounds which was the potential contaminant of concern within this area. This flagged data and the rationale for no conclusive petroleum hydrocarbon data needs to be discussed during the comment resolution meetings on the Proposed Plan and the upcoming ROD.
The site descriptions do not adequately capture the actual site description and site activities to sufficiently inform the intended readers (community members). For example, LF-004 is an active landfill, and WAA No. 3 had drum storage. Truck Fill Stand (SS-009): The distinction between sites SS-008 and SS-009 needs to be more clearly defined within this plan. The reference to the petroleum hydrocarbon contamination (23,900 mg/kg in BH8) exceeding ADEC cleanup levels within SS-008 (Waste Accumulation Area No.4, Old Sanitary Sewer System, Former Sewage Lagoon, and Former Paint Shop) needs to be removed from this proposed plan. As agreed upon in a meeting on December 2nd, further subsurface investigation will be conducted within this exceedence area. The NFA decision needs to incorporate site SS-009 only. |
Gretchen Pikul |
| 2/18/1999 |
CERCLA Proposed Plan |
Proposed Plan for No Further Action: IRP Sites DP05, OT12, SS01, SS07, SS09, LF10, and OT06 (draft dated December 1998, final dated February 1999); ADEC internal briefings on December 10 and 21; ADEC comment letter dated December 24, 1998; comment resolution meeting dated January 11, 1999; public meeting on February 18, 1999.
WAA No. 2 (Upper and Lower) and Upper Landfill No. 1 (LF-010). The human health and ecological risks at this site were below ADEC risk-management standards, indicating the site does not pose a risk. All detected contaminants were below the ADEC-recommended cleanup levels. Site LF-010 is a candidate for NFRAP after approximately 50 drums are removed from the site. These drums were inspected by the ADEC and found to be mostly empty or to contain very little residue. The drums will be collected, rinsed, de-headed and either recycled or buried as solid waste.
Recommended Action: No Further Remedial Action Planned (Following Drum Removal). |
Gretchen Pikul |
| 4/16/1999 |
Update or Other Action |
The Alaska Department of Environmental Conservation (ADEC), DoD Oversight group, received the Draft Decision Documents for 7 No Further Response Action Planned (NFRAP) IRP Sites: DP-
005, OT-012, SS-001, SS-007, SS-009, LF-010, and OT-006 (dated February 1999) on March 9, 1999. We have completed our review and provided comments below.
2.1 Site History: It is stated that in 1973, between 80 and 100 drums were removed from the site; some drums were empty, and others were reported to have been filled with waste oil and other liquids. Include which the site had the 1973 drum removal,
Upper or Lower WAA No.2. Also, there axe a few periods "." missing within this DD.
(pg. 5) 3.2 RI Results: The second paragraph describing the Upper WAA No. 2 site states that no RI sampling was conducted. However, downgradient seep and sediment samples as well as monitoring well groundwater samples were collected to evaluate mpacts to downgradient receptors. This information must be included within the DD.
4.0 Selected Remedy:
• It is stated that the ADEC representative inspected the drums during the site visit and determined they were empty or contained very little residue. This statement is not completely accurate. During the June 1998 site inspection, most of the drums appeared empty, some drums contained what appeared to be rainwater and
native soil, and all the observed drums were suspected not to contain any hazardous or petroleum materials.
• The drum disposal activities are required to follow appropriate regulations and guidelines, such as 18 AAC 60 and RCRA.
• An anticipated date for this drum removal action needs to be included within this DD.
• The proposed disposal location for the drums needs to be included within this DD. |
Gretchen Pikul |
| 10/14/1999 |
Site Ranked Using the AHRM |
Initial ranking. |
Gretchen Pikul |
| 8/10/2000 |
Meeting or Teleconference Held |
Public meeting in Takotna, and site visit to Sterling Landing. |
Gretchen Pikul |
| 1/17/2001 |
CERCLA ROD Approved |
7 Decision Documents signed by ADEC on November 21, 2000, and by Air Force on January 17, 2001. Sites include OT012, SS001, SS007, LF010, OT006, SS009, and DP005. LF010 Decision Document has a no further action status. Based upon investigations conducted at IRP Site LF-10 to date, there is presently no unacceptable risk or threat to public health or the environment at this time. Therefore, the selected remedy for IRP Site LF-OI0 is no further action under CERCLA.
However, before site closure at LF-010, the Air Force will remove a collection of approximately fifty 55-gallon drums currently at this site. The drums are not considered part of the original LF-010 source area. USAF and ADEC representatives observed the drums during a site visit to the Tatalina LRRS in June 1998. The ADEC representative inspected the drums during the site visit and determined that most of the drums appeared empty.
Some drums contained what appeared to be rainwater and native soil, and all the observed drums were suspected not to contain any hazardous or petroleum materials. In FY 2001, the USAF will collect the drums, rinse them if necessary, properly dispose of rinsate, de-head the drums, and either recycle the drums or bury them as non-hazardous solid waste. The drum disposal activities will follow requirements in appropriate regulations, including 18 AAC 60 and the federal Resource Conservation and Recovery Act. Disposal locations for the drums and rinsate will be determined with input from the local community and ADEC.
Institutional control in the form of notice in land records will be developed by the Air Force, with ADEC concurrence, for waste left in place and within a base master plan.
Visual inspections of cover material will be conducted and documented over a 5 year period (the first, third, and fifth years) to check that healthy vegetation exists and no erosion of the cover is occurring. After the last inspection, a 5-year review will be conducted to review the results of the inspections. If the cover material has remained in good condition, no further inspections will be required.
The selected remedy is protective of human health and the environment, complies with
federal and state requirements that are legally applicable or relevant and appropriate, and is
cost-effective. The statutory preference for treatment is not satisfied because treatment was
not found to be necessary. Contaminant levels at the site have been determined to present no
unacceptable threat to human health or the environment; thus, no treatment is necessary.
This decision may be reviewed and modified in the future if new information becomes
available which indicates the presence of previously undiscovered contamination or exposure
routes that may cause a risk to human health or the environment. |
Jennifer Roberts |
| 6/20/2001 |
Update or Other Action |
Site visits/inspections new 611th project manager were performed in June 2001 in accordance with the signed Record of Decision. Inspection letter reports are anticipated Winter 2001. Institutional Controls are being developed with ADEC input and approval. ADEC received CD copy of Tatalina LRRS Administrative Record (dated April 2001) Disk 1. |
Gretchen Pikul |
| 6/20/2001 |
Meeting or Teleconference Held |
A public meeting was held in June to discuss upcoming work, and the signed Record of Decisions for 7 sites. |
Gretchen Pikul |
| 10/10/2001 |
Update or Other Action |
Air Force field visit and work (including land surveys for institutional controls required by Decision Documents) delayed until mid-September due to in-house crew work conflicts (August 9, 2001); delayed to October due to September 11th terrorist attacks (September 17, 2001); was cancelled for this field season due to bad weather and impassable road conditions (October 10, 2001); field work is scheduled for FY02. ADEC received final Clean Sweep Environmental Survey Report (dated September 2001). |
Gretchen Pikul |
| 10/19/2001 |
Meeting or Teleconference Held |
ADEC particpated in a community meeting in Takotna with Air Force. |
Gretchen Pikul |
| 1/10/2002 |
Update or Other Action |
The Alaska Department of Environmental Conservation (ADEC), DoD Oversight group, received the draft Solid Waste Disposal Facilities Request for Approval of Tatalina Solid Waste Facility Modifications (dated December 2001) on January 3, 2002. We have completed our review, and provided comments below.
General comment: 1. As discussed in our meeting on January 3, 2002, specific requirements detailed in the Technical Document to Support Installation Restoration Decision (final signed by ADEC in November 2000 and the Air Force in January 2001) for Installation Restoration Program (IRP) Site LF-010 will need to be conducted prior to the proposed solid waste facility modifications, if in fact these areas coincide. As for the IRP Site LF-004, providing adequate cover for landfill closure during the construction of the active camp waste landfill appears to be an ideal solution for both sites, saving government funds and efforts. Specific details regarding the landfill closure, proposed No Further Remedial Action Required (NFRAP) status, long-term monitoring, inspection and maintenance, and institutional controls will be detailed in the future Decision Document for IRP Site LF-004 scheduled for review and signature prior to 2002 field season activities.
Specific comment: 2. Transmittal Letter: Number 6 on the second page states that Tatalina LRRS is a remote facility and is not connected by road to any other community or landfill. Please clarify that based on the ADEC Solid Waste Program definition of ‘remote’, (NOTE: no definition exists in 18 AAC 60 for "remote" the writer may be referring to a Class III MSWLF-a landfill NOT connected by road to a Class I MSWLF or, if connected by road, is located more than 50 miles from a Class I MSWLF, and that accepts, for disposal,
(A) ash from incinerated municipal waste in quantities less than one ton daily on an annual average, which ash must be free of food scraps that might attract animals; or
(B) less than five tons daily of municipal solid waste, based on an annual average, and is not located in a place
(i) where public access is restricted, including restrictions on the
right to move to the place and reside there; or
(ii) that is provided by an employer and that is populated totally by
persons who are required to reside there as a condition of employment and who do not consider the place to be their permanent residence.)
the facility conforms with that definition, however, the facility is connected by road to other communities.
Please note ADEC review and concurrence on these documents is to ensure that the work is done in accordance with State of Alaska environmental conservation laws and regulations. While ADEC may comment on other state and federal laws and regulations, our concurrence on these documents does not relieve responsible persons from the need to comply with other applicable laws and regulations. |
Gretchen Pikul |
| 1/29/2002 |
Meeting or Teleconference Held |
ADEC CS DoD Oversight and Air Force Environmental Restoration and Compliance meeting on 2002 field work. |
Gretchen Pikul |
| 3/4/2002 |
Update or Other Action |
Final Environmental Assessment for Property Disposal (dated August 1997, received on March 4, 2002). |
Gretchen Pikul |
| 4/24/2002 |
Update or Other Action |
ADEC comment letter Draft Work Plan Remedial Actions and Investigation which was received on April 19, 2002. 8.1 Site LF-010 and WAA2: It is stated that the drums are not considered part of the original LF-010 or LF-004 source area. This statement has been revised from the LF-010 Decision Document to incorrectly include site LF-004. The boundaries of LF-004 encompass the debris disposed in this area. Please revise the sentence.
It is stated that the selected remedy for LF-010 is no further action under CERCLA and drum removal is necessary before site closure. For clarifications purposes, please also note (as recorded on page 2 of the LF-010 Decision Document
Declaration Page) the site will be in a No Further Remedial Action Planned (NFRAP) status since the site is a disposal area; landfills / disposal areas cannot be considered or termed ’closed’ sites because waste is being left in place.
There should be a section on the ’Excavated Material Management / Drum Recovery, Staging, and Processing Area’ as presented in the 2001 Draft Work Plan prepared by Mr. Wootten; please note that these draft work plans were not utilized
because no field work was conducted in 2001.
It is stated that a composite sample will be made in the field, and this will be analyzed by Hazcat procedures for subsequent transport to town. Please define ’town."
Please note that if any contaminants are detected by field screening tests or are observed during field efforts, that laboratory analyses will be necessary prior to capping this area. Also if larger quantities of soil need to be addressed during the field work ADEC should be notified of the proposed removal and disposal activities.
Per the final LF-010 Decision Document, the area requires adequate cover so that visual inspections of cover material can be conducted and documented over a 5 year period to check that healthy vegetation exists and no erosion of the cover is
occurring. |
Gretchen Pikul |
| 6/7/2002 |
Meeting or Teleconference Held |
Site visit, inspections, and meetings at facility with Air Force. Public meeting with Takotna community on June 3, 2002. |
Gretchen Pikul |
| 6/11/2002 |
Meeting or Teleconference Held |
ADEC and Air Force meeting on 2002 field work and work plan; draft work plan dated April 2002 and received on April 19, 2002; comment resolution meeting on April 30, 2002; 2nd draft work plan received May 9 and 10, 2002; 3rd draft received May 28, 2002; 4th draft received on and comment resolution meeting on June 4, 2002; ADEC approval letter dated June 11, 2002. |
Gretchen Pikul |
| 12/9/2002 |
Update or Other Action |
Draft Annual Report received. As part of the United States Air Force (USAF) Installation Restoration Program (IRP), the 611th CES/CEVO engaged in several projects at Tatalina LRRS during FY 2002. Activities completed involved drum removal from areas surrounding both an active and inactive landfills (USAF, 1999), confirmation sampling of water and sediments in order to determine potential contamination migration, and the installation of thirteen monitoring wells at various locations.
SUMMARY OF WORK ACCOMPLISHED IN 2002
Work accomplished at Tatalina in 2002 took place at seven sites. By category, these projects consisted of:
-Remediation of an area strewn with drums, and cleaning and sampling them as necessary at LF 10, Waste Accumulation Area # 2.
-Drilling and installing Monitor Wells (SS-08, Waste Accumulation Area # 4; SS-03, Former POL Tank Farm; and Sterling Landing, SS-002).
-Collecting soil and/or water samples for analysis (SS-02, Sterling Landing; SS-08, Waste Accumulation Area # 4; Lower Camp drum staging area, SS-03, Former POL Tank Farm; SS-011, Hardfill # 1).
-Investigating sites reported in a community meeting where transformers were reportedly buried. Trenches were excavated in an attempt to locate the transformers.
-Investigating and collecting soil and/or water samples at areas of concern which include: the MEK debris field north of upper camp, the lower camp tram building foundation area, and areas under the deactivated tram cables.
Site LF 010 (Figure 4) lies approximately 1500’ east of the present main lower camp. Presumably, this site was active during the lifespan of the camp, and received various incidental materials in the form of waste wood, garbage, scrap metal, construction debris, drums, and shop wastes.
The Air Force removed twenty-four 55-gallon drums (photos 1 and 2, appendix A), and five 5 gallon fuel cans found scattered between LF-010 and the adjacent LF-004 landfill site (figure
4). The removal of the drums was in accordance with the Record of Decision for LF-010 in 1999. Based on field screening results and physical characterization i.e. soils, oils, waters, etc., like waste materials were consolidated for further laboratory analysis. The emptied drums were then de-headed, cleaned of any remaining residues and purged of vapors to remove any potential hazard. The cleaned drums were then crushed, crated for transport to DRMO for scrap. Only one drum had any contents that were repackaged. The drum contained approximately 30 gallons of oil. The oil was sampled and underwent oil burning analysis (sample 52063025042). After receiving the results of the oil burning analysis, the oil was given to the site to be burned in the waste oil heating unit.
The soil lying beneath these drums was sampled and tested by the PetroFLAG method. Based on the field screening results and visual observations (ie. soil staining), laboratory samples were collected at a depth of 6” to ensure there is no petroleum contamination. The results from the field screening conducted under the drums are detailed in table 1.1. Locations of the samples is illustrated in Figure 3. Results of the PetroFLAG analysis do not correlate well with the laboratory analysis and are considered biased high due to the high organic material content of the samples. One sample had DRO concentrations (463 mg/Kg) above ADEC clean up levels (method 2, table B2).
LF-010
Twenty-four, 55 gallon drums and five fuel cans were excavated, crushed, and disposed of from LF-010. Soil underneath the drums and cans were tested with the PetroFlag analysis, and no significant contamination was discovered.
No further work is recommended. |
Louis Howard |
| 2/5/2003 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (ADEC), DoD Oversight group, received the Draft Annual Report - Remedial Action and Monitoring Program (dated November 2002) on December 9, 2002. We appreciate the extended review period, have completed our review, and provided comments below.
8.1 Site LF-010 and WAA 2: For clarification purposes, the LF-010 Decision Document requiring the drum removal action should be noted within this section. It is stated that PetroFLAG method and laboratory sampling was conducted to ensure there was no petroleum contamination. Based on the approved work plan, “chloride specific electrode sensitive to 10-ppm chloride ion shall be used to determine if PCBs or chlorinated pesticides are present.”
Table 1.2 appears to refer only to the areas of suspected buried transformers, not the drums areas. Include the chloride data performed for this task, and how the field screening relates to the absence/presence of PCBs and chlorinated pesticides. It is stated that “the soil lying beneath these drums was sampled and tested by the PetroFLAG method and Laboratory sampling at a depth of 6” to ensure there is no petroleum contamination.”
Please clarify if this sampling was performed on all or specific drum locations. In addition, include the rationale for collecting samples for laboratory analysis vs. simply field screening.
A statement on how the sample field screening compares to the sample laboratory results would be helpful. As stated in the approved Field Sampling Plan (FSP) include (or refer to specific field notes) the field observations, drum labels, sample and sampling point description, etc.
LF-010: Field screening and no significant contamination is noted, however, to more completely summarize the activities the laboratory confirmation samples and soil sample with the contaminant level exceeding the soil cleanup levels should be added to this summary.
The data validation discussion is not include m this draft report; please provide this information and incorporate any qualifying notes withm the text. There is data on a soil trip blank which needs to be discussed within the appropriate table and text. LF010 has data qualifiers that need to be included within the table and text discussion (if applicable). |
Gretchen Pikul |
| 5/31/2003 |
Meeting or Teleconference Held |
ADEC participated in a public meeting at Takotna and site visits for 2003 field work and general inspections. |
Gretchen Pikul |
| 6/13/2003 |
Update or Other Action |
Air Force letter to Mr. Chuck Gottschalk responding to his public meeting question on LF-010. |
Gretchen Pikul |
| 11/4/2003 |
Update or Other Action |
2002 Annual Report, Remedial Action and Monitoring Program; draft dated November 2002 and received December 9, 2002; ADEC comment letter dated February 5, 2003; Air Force response to comments received on February 19 and ADEC response sent on February 21; comment resolution meeting on March 17, 2003; draft final received on April 3, 2003; ADEC commented via e-mail on April 16, 2003; final dated April 2003 and received May 2, 2003; ADEC conditional approval letter dated September 25, 2003; final report received October 27, 2003 and CD on November 4, 2003. |
Gretchen Pikul |
| 8/29/2005 |
Meeting or Teleconference Held |
ADEC and Air Force project managers conducted a site visit to Tatalina LRRS from August 23 to August 26, 2005. The purpose of this visit was to provide an opportunity to view and to discuss the status of ongoing contaminated sites work being performed by the Air Force. |
Jeff Norberg |
| 9/15/2005 |
Institutional Control Record Established |
Institutional controls for LF-10 established in Base General Plan restricting excavation and surface grading at the site. See notation on 17 Jan 2001 regarding residual contaminaton left in place. |
Jeff Norberg |
| 12/28/2005 |
Update or Other Action |
Five Year Review for IRP Sites: DP-005, LF-010, OT-012, SS-001, SS-007 and SS-009 Tatalina Long Range Radar Station received for review and comment.
The purpose of the five-year review is to determine whether the remedy selected for the installation restoration program (IRP) Site LF-010, located at the Tatalina Long-Range Radar Station (LRRS) continues to be protective of human health and the environment. The methods, findings, and conclusions of the reviews conducted for IRP Site LF-010 are documented. In addition, this report identifies any issues found during the reviews and provides recommendations for addressing the issues.
This is the first five-year review conducted at Site LF-010. The triggering action for the
review is the signing of the Record of Decision (ROD) document for Site LF-010 on January 2, 2001. A five-year review is required because potentially hazardous debris or substances may remain buried at the site above levels that allow for unlimited use and unrestricted exposure.
Inspections at LF-010 were conducted on August 8, 2004 by Montgomery Watson and again on August 24, 2005, by Mant Flynn/CH2M HILL Stacey Re/CH2M HILL, Todd Fickel/611th CES, and Jeff Norberg/ DEC. The purpose of the inspections was to assess the protectiveness and integrity of the landfill soil material covers.
Land use controls (also known as institutional controls) were evaluated by verifying their existence within the Tatalina Base General Plan and their location presented on the Tatalina Base Map. The institutional controls that are in place include restrictions on excavating and surface grading at the site. No activities were observed during the SIs that would have violated the land use controls. The soil material covers on all three landfills were intact, undisturbed, and have naturally revegetated. Photographs of these sites are provided at the end of this section.
There is no other information that calls into question the protectiveness of the remedy.
According to the data reviewed and the Sls conducted at Site LF-010, the remedy is
functioning as intended by the ROD. There have been no changes in the physical conditions
of the site that would affect the protectiveness of the remedy. The exposure assumptions
and toxicity factors for the contaminants of concern used to develop the Human Health Risk
Assessment have not changed. There is no other information that calls into question the
protectiveness of the remedy.
No direct issues were identified that could impact the effectiveness of the selected remedy.
The 55-gallon drums identified in 1998 at Site LF-01t0 by the ADEC and the USAF were
successfully removed in 2002 as required for closure by the ROD.
Pursuant to the Base Risk Assessment, no contaminants of concern were found at Site LF-010 and with the landfill soil material cover in place and protected by land use controls there is no need for additional remedial action. This remedy is protective of human health and the environment. Recent inspections verify the effectiveness of the selected remedy.
With the successful completion of this five-year review, no further five-year reviews are
required for Site LF-010. If future land use changes or physical impacts to the landfill soilI
material covers have occurred, future five-year reviews may be required. |
Jeff Norberg |
| 1/30/2006 |
CERCLA ROD Periodic Review |
Five-Year Review – Installation Restoration Sites DP-005, LF-010, OT-012, SS-001, SS-007, and SS-009; Final dated November 2005 received December 28, 2005; ADEC issued approval letter on January 30, 2006.
The Alaska Department of Environmental Conservation (ADEC), Federal Facilities Oversight group, received the Five-Year Review of Installation Restoration Program Sites DP-005; LF-010; OT-012; SS-001; SS-007; and SS-009 Tatalina LRRS, Alaska (dated November 2005) on December 28, 2005. ADEC have completed our review and concur with the contents of this document, with the following exception.
The Protectiveness Statement within Section 5.8 indicates that “no contaminants of concern exist at SS-001” and “there is no need for further remedial action.” As stipulated in the ROD for Site SS-001, “petroleum contaminated soil adjacent to the MAR facility has not been fully delineated due to the risk of compromising the structural integrity of the MAR facility. When the current MAR facility is decommissioned and removed in the future, the extent of subsurface contamination remaining beneath the building will be assessed to determine if remedial action is necessary.” Although summarized in Section 5.3, this information should also be emphasized in Section 5.8.
Please note that the ADEC review and concurrence on this document is to ensure that the work is done in accordance with State of Alaska environmental conservation laws and regulations. While the ADEC may comment on other state and federal laws and regulations, our concurrence on this document does not relieve responsible persons from the need to comply with other applicable laws and regulations.
Thank you for providing a copy of the Five-Year Review of Installation Restoration Program Sites DP-005; LF-010; OT-012; SS-001; SS-007; and SS-009 Tatalina LRRS, Alaska. |
Jeff Norberg |
| 1/30/2006 |
Long Term Monitoring Complete |
In accordance with the ROD for this site and based on the results of the Five-Year Review, no further cap inspections are required unless physical impact to the soil cap is identified in the future that may pose a risk to human or ecological receptors. |
Jeff Norberg |
| 2/1/2006 |
Update or Other Action |
File number issued 2655.38.007. |
Aggie Blandford |
| 6/14/2013 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 73825 name: auto-generated pm edit Tatalina LRRS LF10 |
Louis Howard |
| 3/18/2015 |
Institutional Control Update |
One of several sites with Land Use Controls in effect (LUC Mgt Plan 2015 Pacific Air Forces Regional Support Center Installations, JBER, AK) March 13, 2015.
In addition to ICs established as part of LUCs of the ERP for landfill sites with LUCs in effect, both ERP landfill and non-ERP landfill sites in Alaska under the management of PRSC must also comply with regulations set forth by the ADEC solid waste regulations in 18 AAC 60. Furthermore, landfill sites under the management of PRSC but not categorized as an ERP site must also comply with ADEC 18 AAC 60. Table 1-3 describes PRSC non-ERP landfill sites.
Landfills are defined in 18 AAC 60 as “an area of land, or an excavation in which solid wastes are placed for permanent disposal, and that is not an application site, injection well, reserve pit, or waste pile.” This definition applies to most PRSC ERP and non-ERP sites in Alaska designated as landfills, dumps, or caches. Small PRSC ERP and non-ERP landfill sites at remote installations, such as the long-range radar stations, are regulated as Class III landfills as defined by ADEC.
General requirements to manage landfills in place are established by ADEC and included in Table 2-2. However, alternative criteria can and often are adopted through negotiation with ADEC (see 18 AAC 60.900, Waivers). Post-closure notification requirements for Class III landfills, including notifications to ADEC and to potential future landowners, are summarized in Table 2-3. Tables 2-2 and 2-3 both generally assume the subject landfill is closed, has been reasonably well characterized, and a monitoring program for media of concern has been established and approved by ADEC.
One of several sites with Land Use Controls in effect (LUC Mgt Plan 2015 Pacific Air Forces Regional Support Center Installations, JBER, AK) March 13, 2015.
In addition to ICs established as part of LUCs of the ERP for landfill sites with LUCs in effect, both ERP landfill and non-ERP landfill sites in Alaska under the management of PRSC must also comply with regulations set forth by the ADEC solid waste regulations in 18 AAC 60. Furthermore, landfill sites under the management of PRSC but not categorized as an ERP site must also comply with ADEC 18 AAC 60. Table 1-3 describes PRSC non-ERP landfill sites.
Landfills are defined in 18 AAC 60 as “an area of land, or an excavation in which solid wastes are placed for permanent disposal, and that is not an application site, injection well, reserve pit, or waste pile.” This definition applies to most PRSC ERP and non-ERP sites in Alaska designated as landfills, dumps, or caches. Small PRSC ERP and non-ERP landfill sites at remote installations, such as the long-range radar stations, are regulated as Class III landfills as defined by ADEC.
General requirements to manage landfills in place are established by ADEC and included in Table 2-2. However, alternative criteria can and often are adopted through negotiation with ADEC (see 18 AAC 60.900, Waivers). Post-closure notification requirements for Class III landfills, including notifications to ADEC and to potential future landowners, are summarized in Table 2-3. Tables 2-2 and 2-3 both generally assume the subject landfill is closed, has been reasonably well characterized, and a monitoring program for media of concern has been established and approved by ADEC.
Tatalina LRRS Hardfill No. 2, Morrison-Knudsen Debris Area, Northeast Landfill DP005
Tatalina LRRS Landfill No. 2 LF004
Tatalina LRRS WAA No. 2 and Upper Landfill No. 1 LF010
Tatalina LRRS Former WACS Facility OT012
Tatalina LRRS Minimally Attended Radar Site SS001
Tatalina LRRS Barge Landing and Fuel Storage Area SS002
Tatalina LRRS Spill/Leak No. 1, 2 ,3, 4, Lower Camp Former T/F SS003
Tatalina LRRS WAA No. 3 SS007
Tatalina LRRS WAA No. 4 SS008
Tatalina LRRS Former Truck Fill Station SS009
Tatalina LRRS WAA No. 1 SS011
LUC_RESTRICTION *Institutional control in the form of notice in land records will be developed by the Air Force, with ADEC concurrence, for waste left in place and within a base master plan.
*Visual inspections of cover material will be conducted and documented over a 5 year period (the first, third, and fifth years) to check that healthy vegetation exists and no erosion of the cover is occurring. After the last inspection, a 5-year review will be conducted to review the results of the inspections. If the cover material has remained in good condition, no further inspections will be required. The institutional controls that are in place include restrictions on excavating and surface grading at the site. |
Louis Howard |
| 2/3/2021 |
Update or Other Action |
Bulk action entry - all Tatalina LRRS sites x-referenced with the general file, 2655.38.001, on this date. |
Cascade Galasso-Irish |
