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Site Report: Tatalina LRRS SS002 Spill/Leak 8 (Sterling Landing)

Site Name: Tatalina LRRS SS002 Spill/Leak 8 (Sterling Landing)
Address: Sterling Landing, aka Spill/Leak No. 8, McGrath, AK 99627
File Number: 2655.38.011, 2655.38.001
Hazard ID: 2854
Status: Active
Staff: Axl LeVan, 9074512156 axl.levan@alaska.gov
Latitude: 62.868418
Longitude: -155.665473
Horizontal Datum:NAD83

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 Sterling Landing site is a barge landing site, and fuel transfer and storage location on the Kuskokwim River. A 16-mile road connects Sterling Landing with the facility Lower Camp; the town of McGrath is 30 miles upriver from the site. From the late 1950s until 1994, the USAF owned and operated 2 bulk fuel ASTs, a truck fill stand, and associated underground piping between the tanks and fill stand on a 1.7-acre parcel under a shared use agreement with the State of Alaska. The tanks consisted of a 225,540-gallon diesel fuel tank and a 10,906-gallon mogas tank. Releases of fuel during routine fuel transfer operations in the past have been reported at the diesel and mogas tanks and fill stand. The USAF owned and operated 2 bulk fuel ASTs, a truck fill stand, and associated underground piping between the tanks and fill stand on a 1.7-acre parcel under a shared use agreement with the State of Alaska. The tanks consisted of a 225,540-gallon diesel fuel tank and a 10,906-gallon mogas tank. Releases of fuel during routine fuel transfer operations in the past have been reported at the diesel and mogas tanks and fill stand. While not listed on the NPL, investigation at Tatalina LRRS must follow CERCLA process per E.O. 12580 [e.g. CERCLA Sections 104(a), (b), and (c)(4), 113(k), 117(a), and (c), 119, and 121) with respect to releases or threatened releases where either the release is on or the sole source of the release is from any facility or vessel under the jurisdiction, custody, or control of their departments. These functions must be exercised consistent with CERCLA Section 120 Federal Facilities. 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 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.] Sterling Landing-SS-002 Spill/Leak No. 8 Update 12/3/2021: Contamination was left in place of sidewall adjacent to riverside during the 2009 excavation in order to prevent collapse of the sidewall (excavation to 11 ft bgs). DRO in sidewall post-treatment samples had a maximum of 19,000 mg/kg (above HH levels). Additionally, contamination in groundwater is not decreasing in size currently.

Action Information

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 (SS002), 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. Spill/Leak No. 8 (Site 2) - This site is one of the routine diesel fuel leaks and spills at the Sterling Landing. The site was not visited in 1987 due to access problems. These minor leaks and spills are not considered significant and no further action is warranted. 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. Jennifer Roberts
7/31/1993 Update or Other Action Woodward-Clyde was contracted by the Tennessee Valley Authority to conduct Site Investigations (SIs) under the EPA CERCLA (Superfund) for the United States Air program Force (USAF) at Tatalina Long Range Radar Site (LRRS). The EPA, USAF, and Woodward Clyde discussed sampling objectives in August 1992 and agreed on a general approach to determining sampling requirements for potential contaminant sources, groundwater pathway targets, and surface water targets for nine Alaskan long range radar stations. A general approach was appropriate since all the facilities had similar operations, chemical usages, and waste management practices. The SI performed at Tatalina LRRS enabled the EPA (Region X) to calculate a HRS Score by addressing the data gaps identified by the PA. Work at the site was performed during August 25 - 29, 1992. The field work included sample collection and handling, recording observations, mapping, and photo documentation. Potential contamination sources listed in the PA were screened to determine those relevant to HRS scoring. Some of the sources at each site were subsequently eliminated from consideration based on historical information that the source consisted of fuel spills or that the source was not a threat to potential target populations. NOTE to file: Fuel spills would be covered and regulated by the State of Alaska oversight. Jennifer Roberts
7/29/1994 Update or Other Action USAF owned and operated 2 bulk fuel ASTs, a truck fill stand, and associated underground piping between the tanks and fill stand on a 1.7-acre parcel under a shared use agreement with the State of Alaska. The tanks consisted of a 225,540-gallon diesel fuel tank and a 10,906-gallon mogas tank. Releases of fuel during routine fuel transfer operations in the past have been reported at the diesel and mogas tanks and fill stand. The tanks were removed from service in 1994 and ownership of the tanks was transferred to the Takotna Community Association. Louis Howard
3/28/1995 Update or Other Action Management Action Plan (draft dated Febraruy 1995, received March 28, 1995, no final received). Ray Burger
11/30/1995 Update or Other Action 611th Civil Engineer Squadron, Working Draft Environmental Baseline Survey for Air Force Radar Stations prepared by HQ AFCEE Environmental Analysis Division, Brooks Air Force Base, TX received. Tatalina Long Range Radar Site (LRRS) was established in November 1952 and is located in the upper Kuskokwm River area, 240 miles northwest of Anchorage. The Tatalina LRRS consists of 4,968 acres at the base of Takotna Mountain on the eastern flank of the Kuskokwim Mountains. The installation is composed of four distinct areas; the Upper Camp on Takotna Mountain, the Lower Camp,the airstrip, and the barge landing site along the Kuskokwim River. In 1957 Tatalina activated a WACS which operated continuously from 1957 until 1979. The White Alice era began to end in 1967 when the "Alaska Commumcations Disposal Act" began the process of transferring US government-owned long-haul communications to private industry. RCA Alaska Commumcations, Inc. (now Alascom) was the successful bidder and over the next 13 years the WACS were replaced with newer satellite communications system. The Tatalina WACS was deactivated and replaced by an Alascom-owned satellite earth terminal in 1979. Onglnally the site was operated and maintained by a detachment F-10, 531st AC&W Group with an authorized strength of 174 personnel. By 1977, the strength was reduced to 27 positions as obsolete systems were replaced with modern systems requiring less personnel to operate. In 1983, the remaining military personnel were inactivated and replaced by contractor personnel to maintain the Joint Surveillance System (JSS) Equipment. The final reduction of personnel occurred in 1985 when the AN/FPS-117 Minimally Attended Radar (MAR) was activated. Tatalina LRRS has been resupplied annually since construcbon started in 1950 by river barge. Cargo is off-loaded at Stedlng Landing on the Kuskokwtm River and transported 16 miles by truck to the site. An airfield is also used to facilitate the transportation of personnel, perishable or critical cargo, and mail. The Air Force began the IRP process at Tatalina Radar installation in 1985 prior to the terminology and procedural changes that took place in the IRP after the passage of the Superfund Amendments and Reauthorization Act (SARA) in 1986. As a result,the IRP was realigned to incorporate the terminology and requirements in the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). The IRP Administrative Record file contains both pre- and post-SARA terminology. The Remedial Investigation(RI) results presented are from investigation activities conducted at the Tatalina Radar Installation. Additional information was gathered from previous investigations at these sites. Twelve sites were investigated at the Tatalina Radar Installation: Spill/Leak Nos. 6 & 7 (SS001), Spill/Leak No. 8 (SS002), Spill/Leak Nos. 1-4 (SS003), Landfill No.2 (LF004), Dump Areas (DP005), Road and Runway Oiling (OT006), Waste Accumulation Area No. 3 (SS007), Waste Accumulation Area No. 4 (SS008), Spill/Leak No. 5 (SS009), Waste Accumulation Area/Landfill (LF010), Waste Accumulation No. 1 (SS0011), and White Alice Site (OT011) Jennifer Roberts
2/13/1997 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
2/13/1997 Update or Other Action (Old R:Base Action Code = SI - Site Investigation). SI action added on 02/13/1997 by Shannon and Wilson, Inc. Based on Air Force Relative Risk Evaluation Worksheet dated 8/28/95, Site Investigation is the current phase. S&W-Miner
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
6/2/1998 Site Visit ADEC participated in a facility-wide site visit. Gretchen Pikul
7/15/1998 Update or Other Action Sterling Landing Fuel Tanks Site, Environmental Baseline Survey (dated March 1997) 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. Analytical results from soil & groundwater (GW) samples collected from all borings & GW monitoring wells (MW) at Sterling Landing indicate the presence of POL contamination beneath the former Air Force facilities at Sterling Landing. Truck Fill Stand (SS-009) As indicated by OVM screening of borehole samples, the POL contaminants appear to extend from the ground surface to the water table at BH14/MW, BH15/MW, & BH18/MW. Within the bermed POL tank area (BH16/MW & BH17), elevated OVM readings were first encountered at 10 & 5' bgs, respectively, but also extended to the water table. Normal seasonal fluctuations of the water table could result in a smear zone of contaminated subsurface materials that could act as a secondary source of contaminants to groundwater (GW). GRO values were elevated within 15' of the ground surface in BH14/MW,BH15/MW, & BH16/MW (ranging from 10 to 4,000 mg/kg), & were less than 22 mg/kg in all other samples. The highest GRO level was detected in the 15 ft. samples from BH16/MW near the former diesel tank. Elevated DRO values were observed within 15' of the ground surface at BH16/MW, BH18/MW & within 20' of the ground surface in BH15/MW, ranging from 22 to 29,000 mg/kg. Lower DRO levels (less than 77 mg/kg) were observed in all other samples. The highest DRO level was detected in the 5-ft. sample collected from BH15/MW near the truck fill stand. Total BTEX in soil ranged from below detection to 151 mg/kg (5-ft. sample in BH15/MW). Benzene levels in soil samples were all reported either below detection or below the method reporting lirmt. Analytical results for lead in soil samples ranged from 3 mg/kg to 22.7 mg/kg. Analytical results from the GW samples collected from the MW BH14/MW, BH15/MW, BH16/MW, and BH18/MW confirmed that POL contaminants have also impacted GW resources at these locations. GRO values ranged from below the method detection limit to 200 ug/L (BH14/MW). DRO values were detected for BH16/MW and BH18/MW at 366 and 2,720 ug/L, respectively. Arsenic was detected above the reporting limit only in BH15/MW (22 ug/L), and BH18/MW (20 ug/L). The level of arsenic in GW at BH15/MW was above risk-based levels presented in the HHRA. Total BTEX was elevated in the GW samples from BH14/MW (85.4 ug/L) and BH15/MW (78.6 ug/L), but was less than 6 ug/L in the other two wells. Benzene was detected in GW samples from BH14/MW (4.9 ug/L) and BH15/MW (5 ug/L). It should be noted that the top of the well screen for BH16/MW was below the water level in the well on July 24, 1997; therefore, sample results may not be representative of actual conditions in the aquifer at the time of sampling. See site file for additional information. 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. The results of the baseline risk assessment at SS-002 identified arsenic as a human health COC for ground water (GW) because of sample results from BH15/MW. Diesel compounds in surface soil at BH15/MW exceeded CTVs for mammals and were identified as a COEC for surface soil at that location. Levels of petroleum hydrocarbons are present in site soil and GW at levels exceeding current ADEC non-UST cleanup guidelines and proposed 18 AAC 75 cleanup standards. RI results indicate that past fuel releases have resulted in soil and groundwater contamination at the site at levels that exceed ecological risk-based levels and ADEC proposed soil cleanup standards for petroleum hydrocarbons. Although arsenic is present in GW at the site at levels exceeding human health risk criteria, the levels are below federal drinking water MCLs for GW and below proposed ADEC cleanup standards in draft 18 AAC 75 regulations. There is no known source of arsenic at the site and the detected levels likely result from background soil conditions in the area. In addition, GW is not used as a drinking water source at Sterling Landing. Therefore, the HHRA results do not warrant remedial action for arsenic at the site. Gretchen Pikul
10/13/1998 Update or Other Action Remedial Investigation Report (draft dated February 1998, final dated and received in October 1998) includes a risk assessment. Analytical results from soil & groundwater (GW) samples collected from all borings & GW monitoring wells (MW) at Sterling Landing indicate the presence of POL contamination beneath the former Air Force facilities at Sterling Landing. POL Tank Farm (SS-003) The POL Tank Farm is located near the southeastern portion of the Lower Camp pad. This area has been used for above-ground diesel and mogas fuel storage and dispensing from the 1950s to the present. Subsequent to the 1997 field investigations, the 611 CES/CEVO cleaned and removed tanks from this area that were no longer in use. Three bulk diesel storage tanks and two bulk mogas storage tanks were removed. The tank removal project did not include investigation or removal of soil or the liner within the storage tank bermed areas. The remaining three tanks are currently used for diesel (2 tanks) and mogas (1 tank) storage and dispensing. The POL Tank Farm pad was previously drained by two 4-inch- to 6-inch-diameter pipes. The pipes released water into the top of the drainage area that begins just below the tank farm pad. This drainage system may have released petroleum hydrocarbons into the drainage in the past. Analytical results from soil samples collected from borings BH1/MW, BH12/MW, and BH20/MW, as well as from shallow surface samples THSL38A1 and THSL39A1, indicate the presence of petroleum hydrocarbon contamination in soils beneath the tank farm. GRO levels ranged from below the detection limit to 3,500 mg/kg. DRO levels ranged from below the detection limit to 38,000 mg/kg. Total BTEX in soil ranged from 0.00036 to 2,600 mg/kg. The highest GRO, DRO, and BTEX levels were detected in the two surface samples (THS138A1 and THSL39A1) collected near BHI2/MW, in the area where the stained sorbents were observed below grade in the new roadcut. BTEX levels reported were primarily xylenes. Petroleum hydrocarbon contamination is subsurface soils generally decreased with increasing distance from the POL tanks. Analytical results from the groundwater samples collected from the monitoring wells at BHI/MW, BH12/MW, and BH20/MW confirmed that POL contaminants have also impacted groundwater resources at these locations. GRO, DRO, benzene and BTEX levels detected in groundwater decreased with increasing distance from the POL Tank Famn. Maximum GRO levels in groundwater were reported in BH1/MW (nearest the POL tanks) at 7,200 ug/L and decreased to 2,200 ug/L in BH12/MW and 1,900 ug/L in BH20/MW. DRO levels in groundwater ranged from a maximum 5,355 ug/L in BH1/MW down to 1,530 ug/L in BH20/MW. Total BTEX in groundwater ranged from a maximum 1,460 ug/L in BH1/MW down to 146 ug/L in BH20/MW. Benzene was detected at 335 ug/L m BH1/MW and decreased to 51 ug/L in BH20/MW. See site file for additional information. Louis Howard
8/3/1999 Document, Report, or Work plan Review - other The Alaska Department of Environmental Conservation (ADEC), DoD Oversight group, received the Remedial Investigation / Feasibilty Study Sampling and Analysis Plan Addendum(dated July 1999) on July 30, 1999. We have acknowledge the expedited review period to meet field work and public meeting deadlines, have completed our review, and provided comments below. General comments 1. Based on this SAP, Sites LF-004, SS-008, and SS-002 wdl have follow-on investigations. It is the Department’s understanding through meetings and comment letters that the contamination encountered at Sites SS-003 (POL Tank Farm) and SS-011 (Hardfill No.1 and Waste Accumulation Area No 1) will be addressed in the future, and prior to site closure. 2. Based on meetings, comment letters, and telephone conversations three borings at Site SS-008 were to be completed as monitoring wells if a productive groundwater zone was reached within a reasonable depth from the ground surface. If monitoring well installation were not possible, then seep and sediment samples would be collected downgradlent of the BH-8 area. The soil and groundwater samples collected for laboratory analysis would be analyzed for the complete suite of analytical methods based on the contaminants of concerns within a drum storage area. This information needs to be incorporated into this workplan for ADEC concurrence. In addition, outfall areas were to be sampled. There appears to be 2 or 3 outfall locations within the Lower Camp area; these locations need to be sampled for the full suite of analyses as part of the remedial investigation. Within Site SS-002, 3 monltonng wells within the contaminated area and one background momtoring well were to be installed. The borings were to include 10 to 15 locations (please include a lower limit not simply up to 16 borings). The analytical methods may be reduced based on the RI soil and groundwater site samples; such as no RRO exceedences, therefore RRO can be eliminated from the follow-on sampling event this season. Please note that the extent of contaminated soil and groundwater needs to be determined prior to site closure, and if the extent is not defined it will be considered at data gap. The groundwater collected from Well BH-15/MW detected the most elevated contaminants; how will the downgradient and leading edge of the contamination be evaluated? Based on the level of contamination encountered in the soil borings proposed for step 2, installation of monitoring wells may be prudent. Gretchen Pikul
10/14/1999 Site Ranked Using the AHRM Initial ranking. Gretchen Pikul
11/3/1999 Update or Other Action Remedial Investigation / Feasibility Study Sampling Plan Addendum - follow-on Remedial Investigation at Sterling Landing, Lower Camp, and LF04 (draft dated July 1999, no final received); ADEC comment letter dated August 3, 1999; comment resolution meeting and public meeting dated August 4, 1999; preliminary results data meeting on November 3, 1999. Gretchen Pikul
3/7/2000 Document, Report, or Work plan Review - other Gretchen Pikul (ADEC) sent Patricia Striebich (USAF) letter re: Draft Follow-on Remedial Investigation and Feasibility Study Report, Source Area SS-002 (Sterling Landing), Tatalina LRRS, Alaska. We acknowledge the expedited review period to meet release of the draft report to the community and the subsequent public meeting deadlines, have completed our review, and provided comments below. General comments- 1. Based on the information presented within this document, the Department does not agree that the groundwater is not an expected future source of drinking water. In addition, some of the input parameters used to calculate the proposed Method 3 alternative cleanup levels (ACLs) for soil are not well documented and further discussion is necessary. Therefore, the proposed ACLs are NOT approved at this time. 2. The Method 3 ACLs is proposed and requires ADEC review and approval prior to implementation. Please provide consistent wording and discussions throughout the text, tables, and figures that at this time these site-specific ACLs are proposed. Past Investigation Results: It is stated that the arsenic levels detected in the groundwater are below the proposed ADEC standards for groundwater cleanup. The groundwater cleanup levels are no longer proposed and were promulgated on January 22, 1999. Please compare the site groundwater concentrations to the promulgated regulations, and make appropriate corrections throughout the document. Also, the second bullet should be rephrased that there is currently not a drinking water source at SS-002. Please make this correction throughout the document (also found on pages 2-11 and 7-1). Table ES-2: Under the Former Truck Fill Stand column, the statement, “therefore, these releases have stopped” should be reworded to a less definitive statement, and to reflect that the subsurface investigation indicates that no ongoing releases within the former fill stand area are evident. This statement is also used within section 9.1.1. 2.3.1.2 EBS Findings: It is stated that the pipeline footprint was excavated in two areas. To support the appropriate sampling protocol and location selections, please provide the depth of these samples and whether the collection was beneath or above the piping. 2.3.2.3 RI Findings: It is stated that there is no known source of arsenic at the site and the levels detected are likely indicative of background soil levels in the area. These levels should be checked against site-specific background concentrations within SS-002 gathered during the previous investigations. See site file for additional information. Gretchen Pikul
5/22/2000 Meeting or Teleconference Held Meeting with other agencies and stakeholders to coordinate future activities at Sterling Landing and potentially share mob/demob, equipment, etc. costs (anticipated activities include community tank farm upgrade with Denali Grant, site assessment and cleanup of current community tank farm area, and cleanup of Air Force former tank site). Gretchen Pikul
8/10/2000 Meeting or Teleconference Held Public meeting in Takotna, and site visit to Sterling Landing. Gretchen Pikul
11/30/2000 Update or Other Action Final RI/FS Site Characterization Report received. The U.S. Air Force (USAF) has completed site characterization and feasibility study activities at the Tatalina Long Range Radar Station (LRRS) in southcentral interior Alaska. The site characterization and feasibility study, described in this report, focused on Source Area SS-002, also known as Sterling Landing. Site characterization fieldwork accomplished in August and September 1999 involved drilling soil borings and monitoring wells and collecting and analyzing environmental samples from soil, sediment, groundwater, and surface water. Groundwater elevations taken at the time of sampling showed that shallow groundwater is generally fiat, but was flowing across most of the site south of the former tank farm in a southeasterly direction at an average gradient of approximately 0.014 foot per foot. In this direction, groundwater appears to flow counter to the Kuskokwim River. Because of local variability in soil types, topography, and the occurrence of permafrost, the gradient and direction of groundwater flow are expected to vary somewhat in areas outside the wells. The presence of discontinuous permafrost and bedrock at SS-002 indicate that groundwater flow mayb e restricted in somea reas. Groundwatera t the site occurs either as a shallow, perched aquifer overlying permafrost and bedrock in the former tank farm area or as a continuous unconfined aquifer in permafrost-free areas south and closer to the river. Existing data indicate that groundwater is hydraulically connected to the Kuskokwim River. Petroleum contamination results are summarized below: -With one exception, DROre sults in all borings and testholes ranged from not detected (ND), or not above the method reporting limit (<2 to <8 mg/kg), to 137 mg/kg. Soil BH31 contained 5,800 mg/kg of DRO at a depth of 11 to 12 feet. -With the exception of four samples, all RRO results were ND (<2 to <8 mg/kg). RRO concentrations were identified in BH22, BH23, BH24/MW and TH1, ranging from 100 to 500 mg/kg. -GRO results were ND (<1 to <5 mg/kg) in all samples submitted from SS-002. -Benzene was ND (<0.02 to <0.05 mg/kg) m all borings, except for 0.13 mg/kg in BH31 at a depth of 12 to 14 feet. -Ethylbenzene, toluene, and total xylenes ranged from ND to 0.11 mg/kg, ND to 0.11 mg/kg, and ND to 0.53 mg/kg, respectively. Groundwater results: In the area surrounding the former truck fill stand, groundwater contained 0.14 mg/L of dissolved DRO in BH15/MW to 3.79 mg/L in BH25/MW. Groundwater was found at depths ranging from about 9 to 21 feet in this area. Groundwater beneath the former tank farm berm contained 3.64 mg/L of dissolved DRO in BH16/MW. Groundwater was found at a depth of about 21 feet in this area. RRO was ND (<0.5 mg/L) in all groundwater samples. With one exception, GRO values were below method reporting limits. Dissolved GRO in groundwater was found in BH25/MW near the former truck fill stand, at a concentration of 0.183 mg/L. With one exception, BIEX was not detected in groundwater. BH25/MW, near the former truck fill stand, contained BTEX, consisting of 0.0032 mg/L of benzene, 0.0042 mg/L of ethylbenzene, and 0.0158 mg/L of total xylenes. -Lead was found in concen~afions ranging from 0.0106 to 0.0371 mg/L. -Detectable PAHs in groundwater included 0.0336 mg/L of naphthalene and 0.0541 mg/L of 2-methylnaphthalene in BH25/MW. Gretchen Pikul
6/20/2001 Update or Other Action ADEC received CD copy of Tatalina LRRS Administrative Record (dated April 2001) Disk 1. Gretchen Pikul
6/20/2001 Meeting or Teleconference Held Public meeting in Takotna, site visits to all sites with new 611th project manager, and site-specific inspection for upcoming land survey and anticipated 2001 fieldwork. Gretchen Pikul
7/10/2001 Update or Other Action Former Takotna community member and school teacher Bob Woolf called and relayed a Sterling Landing spill he witnessed in early winter 2000 (reported to ADEC PERP on October 9, 2000). In October Mr. Dick Newton (operates Takotna community tank farm and fuel truck) enlisted help from 2 teachers (Mr. Woolf and Mr. Steve Bently) to collected a gas-powered pump and collapsible hose (approximately 30 foot in length, 3-4-inch diameter) used for community fueling purposes from Sterling Landing. Mr. Newton drove school truck to collect pump and hose, laid out hose across roadway towards ASTs closest to Kuskokwim River and rolled up hose with estimated gallons of product exiting hose onto ground surface. Mr. Woolf remarked that Mr. Newton made an 'off-colored comment' regarding - it will look like these other folks have spilled fuel. Mr. Woolf is concerned about the environment and stated that he believes this is not a one-time event, that Mr. Newton professes he is concerned about the environment, but his actions do not reflect it. Mr. Woolf remarked that he does not want to be anonymous, and would be willing to reiterate his story to other concerned parties. Note: the described spill location does not appear to be on Air Force leased property or land used by Air Force, but on community tank farm leased land. The community has Denali Commission grant funds to build a new tank farm and cleanup the current tank farm area in FY02/03. Gretchen Pikul
10/10/2001 Update or Other Action Year 2000 Clean Sweep Environmental Survey Report (final dated September 5, 2001, received on October 10, 2001). 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
11/5/2001 Meeting or Teleconference Held ADEC participated in meeting with Air Force, MTNT, and BLM (DOT and DNR were scheduled to attend but did not) to discuss Sterling Landing contaminant issues and property lease lines - meeting minutes are in project file. Gretchen Pikul
11/7/2001 Meeting or Teleconference Held ADEC participated in meeting with Air Force, MTNT, DOT, and DNR to discuss Sterling Landing contaminant issues and property lease lines - meeting minutes are in project file. DNR owns the parcels that house Air Force former tank farm area and current community tank farm area, and DOT is land manager. Gretchen Pikul
11/8/2001 Update or Other Action ADEC sent out 2 e-mail updates to community regarding the ADEC investigation and observances of a seep into the Kuskokwim River at Sterling Landing. Gretchen Pikul
1/8/2002 Document, Report, or Work plan Review - other ADEC letter to Mr. Dick Newton, Ms. Nell Huffman, and Mr. Bart Mawarey RE: Aboveground Storage Tank Farm Site Assessments Sterling Landing and Takotna, Alaska. The Alaska Department of Environmental Conservation (ADEC), DoD Oversight group, received the draft Aboveground Storage Tank Farms Site Assessments Sterling Landing and Takotna, Alaska (dated December 2001) report prepared by Ecology and Environment, Inc. for ADEC today. The report details the September 2001 investigation conducted at Sterling Landing and Takotna. During our last meetingo n October1 9, 2001, you requested a copy of the report when it became available. ADEC does not have a toll-free telephone number, but please feel free to call me collect at 269-3077, drop an e-mall (Gretchen_Pikul@envircon.state.ak.us), or send a letter with any questions or concerns regarding this letter or other cleanup issues at Tatalina. Gretchen Pikul
1/17/2002 Document, Report, or Work plan Review - other Draft Aboveground Storage Tank Farm Site Assessments Sterling Landing and Takotna (dated December 2001) received on January 8, 2002. General comments-1. The binding and the left margin spacing of this report make reading the report difficult when bound. 2. Please include within the appropriate section, whether the individual Sterling Landing and Takotna tanks presented in this report are in service or out of service, and whether the tanks contain product or not. 3. Test pit logs or schematics would be appreciated in future reports. Specific comments-4. (pg.2-1) 2.3 Project Logistics: There is a typographical error in the 3rd sentence. 5. (pg.3-3) 3.4 ADEC Cleanup Levels: It is stated within the 2nd paragraph that ADEC does not agree that the groundwater is not an expected future source of drinking water (ADEC 3/7/2000). This statement refers to general comment #1 in ADEC’s comment letter on the Draft Follow-on Remedial Investigation and Feasibility Study Report, Source Area SS-002 (Sterling Landing) dated February 2000. This statement was made based on the information provided in the draft report basically due to lack of supporting information to make a 18 AAC 75.350 determination. Please note that due to the site proximity to the Kuskokwim River, and the presence and position of the contaminated groundwater plume, a 10x rule would likely not be approved. 6. (pg.5-8/10) Table 5-1: The TOC value for soil sample 01STL012SB (STL-04 at 5.5 feet bgs) is 1.77%, and was not used within the calculations for Method 3 (the lowest value of 0.6% was used). Please note that this sample should not be included in future TOC site calculations since the sample is not supported by contaminant of concern analytical data, the 8-foot interval notes a hydrocarbon odor, and the sample may have contamination that would artificially inflate the TOC value. Include the location of soil sample STL-09 on Figure 5-2. 7. (pg.5-11) Table 5-2: Soil cleanup levels have been incorrectly applied to sediment. The appropriate state and federal regulations and guidelines (such as 18 AAC 70 and Compilation of the U.S. Environmental Protection Agency’s Water Quality Criteria for the Priority Toxic Pollutants (ADEC 1997)), and ecological-benchmarks (such as NOAA SQuiRTs and ORNL) need to be referenced and compared to the appropriate media. Please note that there are no sediment criteria for GRO, DRO, and RRO; simply stating this and using the results for comparison and potential trend analyses is suggested. The right side of the table is unclear; please provide a clear copy within the final report. 8. (pg.5-13) Table 5-3: As stated above, soil cleanup levels have been incorrectly applied to sediment. The appropriate state and federal regulations and guidelines (such as 18 AAC 70 and Compilation of the U.S. Environmental Protection Agency’s Water Quality Criteria for the Priority Toxic Pollutants (ADEC 1997)), and ecological-benchmarks (such as NOAA SQuiRTs and ORNL) need to be referenced and compared to the appropriate media. Please make these corrections within the executive summary and throughout the report tables, text, and figures, if applicable. The units of measurement for the cleanup levels should be presented in mg/kg as they are referenced in 18 AAC 75 and to be consistent throughout the report; the sample results presented in this table should also be adjusted accordingly. Please make this change throughout the report text, tables, and figures. See site file for additional information. Gretchen Pikul
1/28/2002 Update or Other Action Aboveground Storage Tank Farm Site Assessments Sterling Landing and Takotna, Alaska - draft dated December 2001; ADEC comment letter dated January 17, 2002; comment resolution meeting on January 28, 2002. 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
3/11/2002 Document, Report, or Work plan Review - other The Alaska Department of Environmental Conservation (ADEC), DoD Oversight group, received your letter (dated February 20, 2002) requesting a waiver of 18 AAC 75.355(b) in order to use qualified Air Force personnel for the 2002 fieldwork at Tatalina LRRS. The site project objectives include USAFC ES/CEVO employees obtaining soil and groundwater samples at Installation Restoration Program sites SS-002, SS-003, SS-008, and SS-011, as specified in the project’s forthcoming work plan that will be reviewed and approved, prior to field work, by this Department; the field work is currently scheduled from July through September, 2002. Per your letter, the proposed qualified samplers are Mr. Joseph Millhouse, Mr. Carl Homlg, and Mr. James Linne of the USAF 611th CES/CEVO. These individuals are currently listed on the ADEC qualified persons website as qualified samplers, and were previously granted a waiver of the 18 AAC7 5.355(b) Impartial Third Party Requirements within ADEC letters dated August 29, 2001 and October 8, 2001. A waiver of the Impartial Third Party requirement is granted and the 2002 fieldwork sampling by Mr. Millhouse, Mr. Homig, and Mr. Linne is approved. This waiver only applies to this specific project at Tatalina LRRS and does not extend to other projects or samplers. Signed Jennifer L. Roberts Section Manager. Jennifer Roberts
3/26/2002 Meeting or Teleconference Held ADEC met with Dick Newton (Takotna Community Association Chair) and Gary Heitz (Iditarod School Superintendent) regarding Takotna, Sterling Landing, and Lime Village 2002 projects and general updates and issues. Gretchen Pikul
4/24/2002 Document, Report, or Work plan Review - other ADEC comment letter Draft Work Plan Remedial Actions and Investigation which was received on April 19, 2002. 8.3 IRP Site SS-002, Sterling Landing. Include the analytical method identifications and the monitoring well numbers within the second paragraph. The proposed analytical tests for the boring soil samples and the groundwater samples from the newly installed monitoring wells need to be included within this section. Testing for SVOCs and RRO at the existing monitoring wells is not necessary at this site since these tests have been performed during previous investigations and are not considered contaminants of concern. However, a more complete suite of analytical parameters is suggested for the 2 new monitoring wells to be installed between the community tank farm and SS-002 since the purpose of the wells is to determine if there is any migration of contaminants onto SS-002. The last sentence states that samples will be collected and analyzed by a separate third party contract, however, since this will not be accomplished please update this section. Figure 4 does not show all of the existing monitoring wells, and only one boring is presented. Please include all of the existing monitoring wells, and for consistency either all of the site borings or none of the site borings. Also the 3 ring binder holes eliminates portions of the legend. The use of aerial photos for the site figure is appreciated; please include the date of the aerial photos on all of the figures. Gretchen Pikul
5/1/2002 Document, Report, or Work plan Review - other Sterling Landing Site Characterization and Feasibility Study Report (1st draft dated Feburary 2000, 2nd draft dated March 2000; ADEC comment letter dated March 7, 2000; comment resolution meeting on March 15, 2000; ADEC received response to comments dated March 15, 2000 on March 28, 2000; ADEC e-mailed comments on May 11, 2000; final report dated November 2000 and received on May 1, 2002). Gretchen Pikul
5/9/2002 Update or Other Action David Kelley Permit Program Mgr. Dept. of Natural Resources, Div. of Mining, Land and Water Southcentral Region Land Office sent Douglas Wootten (RPM 611th Civil Engineer Squadron/CEVR) a letter RE: Monitoring Wells/USAF Sterling Landing Tank Farm. The Southcentral Land Office, Division of Mining, Land and Water has completed its review of the project described in your letter dated April 24, 2002. The proposed activity appears to be a generally allowed activity (11 AAC 96.010), and a permit from this office would not be required. With this being the case, the Southcentral Region Land Office does not object to the installation of temporary monitoring wells on state land located in the vicinity of the USAF Sterling Landing tank farm with the understanding that the monitoring wells will be back-filled once they are no longer needed. Gretchen Pikul
5/29/2002 Update or Other Action Aboveground Storage Tank Farms Site Assessments - Takotna and Sterling Landing - community tank farm (dated March 2002 and received May 29, 2002). Gretchen Pikul
6/3/2002 Update or Other Action Douglas Wootten (USAF) sent a letter to ADEC RE: Response To Comments, Tatalina LRRS, AK, Work Plan, 4th Draft Submission. In response to your 24 April 2002 letter, I am pleased to have delivered this 4th dralt work plan to you in person on this date. Please review the enclosed Tatalina LRRS documen that was prepared by our in-house personnel and provide comments back to me at your convenience. In connection with our Takotna and Tatalina LRRS site visits on this date, I suggest that we meet in person to address any further comments that you may have. The 611th CES/CEV personnel that prepared this draft work plan will be arriving at Tatalina between June 3rd and 5th for the scheduled operations, as specified in the work plan. I suggest that we meet at the site and address any pending replies that you may need to finalize and approve the work plan. For your information, 611th CES/CEV will be preparing their machinery and installing various on-site support equipment from June 3rd through approximately June 5th. They anticipate June 6th to be the earliest date that they will begin site operations. Accordingly, I believe we can finalize the work plan on June 4th and 5th while we are all at Tatalina LRRS. 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 Cleanup Plan Approved G. Pikul (ADEC) sent letter to Air Force (Douglas Wootten) Subject: Approval letter for the 2002 Draft Work Plan, Remedxal Action and Monitoring Program, Tatalina LRRS, Alaska. The Alaska Department of Environmental Conservation (ADEC), DoD Oversight group, received the 4th version. of the 2002 Draft Work.Plan, Remedial Action and Monitoring Program (dated June 2000) on June 3, 2002. We provided comments on the draft documents within a comment letter on April 24, 2002, within e-mails on May 20 and 28, 2002, and within a comment resolution meeting on June 5, 2002 at Tatalina LRRS. Based on our review of the draft documents and the Air Force response to comments, and on the comment resolution meeting on June 5, 2002, ADEC concurs with the work plan, and therefore approves this document based on the incorporation of the revisions discussed within the meeting. Please note 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 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. Thank you for your continued coordination efforts on Tatalina LRRS projects. If you have any questions regarding this letter, please contact me at 269-3077. 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
8/2/2002 Update or Other Action Remedial Investigation, Sterling Landing - community tank farm (dated and received in August 2002). Gretchen Pikul
10/22/2002 Document, Report, or Work plan Review - other G. Pikul (ADEC) sent D. Wootten (AF) letter RE: Draft Sterling Landing Focused Feasibility Study received it on October 18, 2002. ADEC acknowledges your request for an expedited review, have completed our review, and provided comments below. General comments- 1. The topographic lines on the topographic maps are not visible. 2. Based on the November 2001 agency meetings and previous discussions throughout the management of the site, the former drum storage area(s) at Sterling Landing, and any other potential source areas uncovered throughout the site investigation stages, may not have been evaluated. How and when will this potential source area be addressed? 1.2 Site Setting: It is stated that the Air Force tanks were removed from service in 1994 and ownership of the tanks was transferred to the Takotna Community Association. It was our understanding that only the MOGAS was transferred; please clarify whether both tanks were transferred and revise the document if necessary. 1.3.6 2002 USAFS S-002 Follow-on RI: Please note that ADEC has not received or reviewed this draft report, and therefore has not able to comment on the content or conclusions of this section. 3.2 1 Screening Criteria and Results: It is stated that options shaded blue were dropped from further consideration because of anticipated difficulties in implementation or marginal effectiveness and cost; there are no colors on Table 3-1. 5.2.7 Cost: The costs shown within this section and in section 5.3 are not consistent with the costs recorded in Appendix B; please address. Figure 1-4: The legend describes the green and red colored monitoring wells as soil samples; please address. 1.3.3 1999 Sterling Landing Site Characterzation: Based on the 1999 report, the highest concentration of DRO is up to 3.79 mg/L; please address. Gretchen Pikul
10/25/2002 Update or Other Action USAF Response to comments on ADEC letter Oct. 22, 2002. The scope of the Focused Feasibility Study (FFS) is to address fuel-related compounds at the Sterling Landing USAF tank farm area. The mentioned potential source area is geographically removed from the area addressed by the FFS. This potential source area will be addressed as an area of concern and will enter the IRP process as such. The IRP process for this AOC will be scheduled as funding permits. 1.2 Site Setting: USAF use of the tanks ceased in 1994. At that time, ownership of the tanks was transferred to to the Takotna Community Association (TCA). The MOGAS tank was reportedly moved by the TCA to the adjacent TCA tank farm in 1996. The diesel tank was left in place in 1996, and the TCA reportedly stored 48,000 gallons of diesel in the tank at or around that time. The TCA reportedly moved the diesel tank between June and August 1997. the fuel transfer lines were removed by the USAF in 1997. Section 1.3.6 2002 USAF SS-002 Follow-On RI: ADEC has not received or reviewed this draft report. AF response: comment NOTED. Gretchen Pikul
12/9/2002 Update or Other Action Draft Annual Report received. Tatalina AFS became operation in 1952. It is annually supplied by river barge. Materials and fuel are off-loaded at Sterling Landing. The Tatalina LRRS consists of three distinct areas: Upper Camp on Takotna Mountain, Lower Camp and the Airstrip, and Sterling Landing. Because they are so close, the Lower Camp and Airstrip areas are discussed as one overall area. The Air Force utilizes a joint use permit for a 1.7 acre barge offloading plot on the north shore of the Kuskokwim River just downstream from McGrath. This area was formerly used since the 1950’s for bulk fuel storage and transfer operations. Diesel fuel and Mogas were formerly stored in above ground storage tanks at the site. The tanks were transferred from the USAF to private ownership and have since been removed from the site. In 1997, the USAF removed the underground fuel transfer lines and fill stand at the site. Ground water at lower camp is found primarily in the more permeable sediments at depths that range from 8 to 28 feet. Depth to ground water at Sterling Landing is influenced by the level of the Kuskokwim River but generally occurs near 28 feet. Permafrost occurs at depths of approximately 35 feet and may act as an aquifer boundary. If the permafrost does act as a lower boundary for the aquifer, then the aquifer is about 7 feet thick at Sterling Landing. Sterling Landing, SS-002 Three boreholes and three monitoring wells were installed at Sterling Landing in FY 2002. The three boreholes and 2 of the monitoring wells were drilled southwest of the USAF POL tank farm area. No hydrocarbon contamination was detected in soil samples from the 5 drill strings. Contaminant concentrations in soil samples from the 5 drill strings above ADEC clean up levels were limited to arsenic and chromium. Groundwater samples from the two new monitoring wells southwest of the POL tank farm had no contaminants above ADEC clean up levels. BH/MW02-16 had DRO concentrations of 0.507 mg/L. A duplicate sample from BH/MW02-16 had no detectable DRO. BH/MW02-16 is the farthest away from the POL tank farm among any of the boreholes/wells. The third monitoring well was installed down gradient from the POL tank farm and replaces a severely damaged BH14/MW that was installed by CH2MHill in 1997. Other work accomplished in FY 2002 at Sterling Landing include the repair of BH25/MW. Hydrocarbon levels in monitoring wells down gradient from the POL tank farm have remained nearly constant or declined slightly since 1997. The boreholes and monitoring wells installed southwest of the POL tank farm in FY 2002 define a clear break in contaminant plumes between the USAF tank farm and the tanks owned by other parties. Recommendations for further work at Sterling Landing include sampling all the monitoring wells in 2003 in order to further detail contaminant attenuation, concentration, and location. Additional work accomplished in FY 2002 include repair of 2 existing monitoring wells. BH25/MW was leaning at an angle of approximately 30 degrees from vertical in a downstream direction. The damage was likely the result of area residents mooring their boats to the well monument. The well monument was straightened and a series of 4 bollards were installed to protect the well (photo 12, appendix A). BH14/MW had been shot and sheared off at ground level. The damage was likely due to vehicular traffic, specifically interaction with a snowplow (photo 13, appendix A). A new well was drilled approximately 5 feet northeast (upstream) of the existing well location. This new well was labeled BH/MW02-17. A series of 4 bollards was installed to protect the well (photo 14, appendix A). The defunct BH14/MW was decommissioned and filled with grout 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. 8.3 IRP Site SS-002, Sterling Landing: Figure 4 is incorrectly referred to in the first paragraph instead of Figure 6. It is stated that there are 7 existing monitoring wells when in actuality there are only 6 wells; BH17 is a boring and was not developed into a monitoring well. The sentence regarding the Shannon and Wilson Environmental contractor and well installation is unclear and needs further discussion. In addition, the monitoring well identification should be included, and the figure number should be corrected from 5 to 6. For clarification purposes, include the rationale for some monitoring wells to be sampled for the full analytical suite, while other wells were analyzed for a limited list of analytes. The site identifier ‘POL Tank Farm’ used in this section could be confused with the IRP site POL Tank Farm; suggest using the specific IRP site name or different description. It is stated that the DRO and GRO values in all the contaminated wells has decreased steadily since the wells were installed. This statement is incorrect and needs to be revised. Table 1.5 has conversion errors and should be revised; the contaminant concentrations have varied over the sampling events and show only minor fluctuations in concentration. These corrections should also be made within the conclusions and recommendations discussion on page 7 and 29. The word ‘backround’ is spelled incorrectly throughout the report. Comparing 2002 arsenic and chromium levels to 1997 background sample levels is acceptable, however, only similar soil types should be used for comparison. These levels should also be compared to the facility risk assessment levels to establish whether the levels indicate acceptable or unacceptable risk. It is stated that the 2002 boreholes and monitoring wells installed southwest of SS-002 former tank farm define a clear break in contaminant plumes between the USAF tank farm and the tanks owned by other parties. More explanation is necessary to clarify this conclusion; using site subsurface investigations to support this statement is needed. A brief summary narrative or table showing the boring and monitoring well identification numbers for the site is necessary since similar numbers have been used at this site. For example, BH15/MW was installed in 1997, and BH/MW02-15 was installed in 2002. See site file for additional information. Gretchen Pikul
2/25/2003 Document, Report, or Work plan Review - other ADEC sent review comments on response to comments by the Air Force. 8. Analytical data tables should include the specific cleanup level used in comparison since up to three cleanup levels are listed in Table B1 and B2, and depending on the sample information, the most applicable cleanup level varies. It is also helpful to include the MDL or PQL in parentheses adjacent to the undetected analyte symbol for future trend analysis and comparison to risk assessment data. In addition, all analytical data qualifiers, such as ‘F’ for the 1999 BH16/MW groundwater sample in Table 1.5, should be noted. Air Force Response: Analytical data qualifiers added. All cleanup levels are "under 40" zone, migration to groundwater". ADEC: Response partially accepted. As noted above, Tables B1 and B2 have 3 exposure pathway cleanup levels and the cleanup level that applies at a site is the most stringent of the applicable exposure pathway-specific cleanup levels based on ingestion, inhalation, or migration to groundwater. If a soil sample depth is between 0-15 feet bgs and for example has benzo(b)fluoranthene, RRO, or benzo(a)pyrene, the applicable cleanup level is the ingestion pathway which is a lower cleanup level than the migration to groundwater pathway. As requested, please include the cleanup level used for comparison within a column in all the report tables. Also, please consider including the MDL or PQL in parentheses adjacent to the undetected analyte symbol for all future reports. 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. Air Force Response: Chlorides were not run on samples 26-29 which were collected beneath drums. Only ran chloride on areas of suspected transformers. ADEC comment: Response not accepted. This is a deviation from the approved work plan, should be noted as such within the final report, and an explanation should be provided for the deviation. PCBs and chlorinated solvents are a concern since the drums with unknown contents may have contained waste oil or spent solvents. 8.2 Former LF-004: Based on the approved work plan, this investigation included field screening using PetroFLAG and chlorides; the PetroFLAG data needs to be reported within this section. Air Force Response: All the data was presented in the report. ADEC comment: Response not accepted. This is a deviation from the approved work plan, should be noted as such within the final report, and an explanation should be provided for the deviation. The location column for BH/MW02-28 records depths of 70.5 – 90.5’; please revise. Air Force response: revised. ADEC comment: Response accepted. The difference between ‘clarified’, ‘ corrected’, and ‘revised’ is unclear since incorrect information is noted and the response is ‘clarified’ not ‘corrected’ or ‘revised’. ADEC simply wants to assure that the incorrect information is correctly reported in the final report. Gretchen Pikul
5/22/2003 Meeting or Teleconference Held ADEC participated in a kick-off meeting for Sterling Landing (SS-002) and LF-004 Proposed Plan and ROD. Remedial Action Summary: SS002 -Big dig and burn to be conducted in summer of 2005. Soil to be excavated to approximately 14 feet bgs. Assume all contamination to be removed, however, there is a possibility of contamination remaining beyond the reach of equipment. Monitored natural attenuation (MNA) for groundwater and possibly remaining contaminated soft. Groundwater (GW) sampling to be conducted every other year (’02, ’05, ’06, ’08). 5 year review will be based on the signing of the ROD. Assume 5 year review in 2009. Need to initiate institutional controls (ICs) for the SS002 site now. Drum Storage Area: New site designated AOC 14, Sterling Depot. Programmed for 2005. Will be sampled as part of the SS002 remedial action. 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
7/31/2003 CERCLA Proposed Plan Proposed Plan for Cleanup (draft dated June 2003 and received June 17; ADEC comment letter dated July 1; internal briefing meeting July 8; comment resolution meeting July 15; Air Force Comment Response July 21; final dated July 2003 and received July 31, 2003). Addressed LF-004 and SS-002 (Sterling Landing). This Proposed Plan focuses on two locations at the Tatalina LRRS: Lower Landfill No. 2 (USAF site designation LF-004) and the former USAF tank farm at Sterling Landing (USAF site designation SS-002). The SS-002 site is located on property owned by the State of Alaska. The USAF has operated their facility under a shared-use agreement with the State of Alaska since the 1950s. The USAF owned and operated two fuel storage tanks at SS-002: a 225,540-gallon diesel tank and an 11,906-gallon gasoline (MOGAS) tank. The fuel tanks were taken out of service in 1993 and 1994. The gasoline tank was removed from the SS-002 site in 1996. The diesel tank was removed in 1997. The USAF has investigated contamination at the SS-002 site on four separate occasions: during an assessment in 1994, during an investigation and subsequent risk assessment in 1997, during a site characterization/feasibility study in 1999, and during another investigation in 2002. The assessment in 1994 concluded that past operations at the SS-002 site resulted in the release of petroleum hydrocarbons. The investigation conducted in 1997 further determined the nature and extent of contamination at the SS-002 site. Surface soil, subsurface soil, Kuskokwim River sediment, and groundwater samples were collected at the SS-002 site. Contaminants identified in soil and groundwater at the SS-002 site include benzene, diesel range organic compounds (DRO), and gasoline-range organic compounds (GRO). The investigation concluded the following: • Past fuel releases have resulted in DRO, GRO, and benzene concentrations in surface and subsurface soil that exceed ADEC Method 2 soil cleanup levels, the most stringent cleanup levels for soil. • Sediment samples collected along the banks of the Kuskokwim River adjoining the SS-002 site did not detect petroleum hydrocarbons. • Concentrations of benzene and DRO in groundwater at the SS-002 site exceed ADEC’s most stringent groundwater cleanup levels. The preferred remedial alternative selected for contaminated groundwater is monitored natural attenuation. Natural attenuation is the combined effect of several naturally occurring mechanisms that reduce the concentration of hydrocarbon contamination. These mechanisms include both destructive and nondestructive processes, with biodegradation being the most destructive process. Groundwater at the SS-002 site will be monitored every 2 years to verify that contaminants naturally decrease over time. The effectiveness of natural attenuation of groundwater will be reviewed 5 years after the treatment of the contaminated soil. The SS-002 site is currently scheduled for cleanup during the summer of 2005. Gretchen Pikul
8/14/2003 Meeting or Teleconference Held ADEC participated in public meeting at Takotna and general site visits. Gretchen Pikul
9/19/2003 Meeting or Teleconference Held ADEC participated in an all day meeting with Air Force attorney, project manager, and consultants on LF004 and SS002 1st draft RODs (received via e-mail on September 11, 2003). Gretchen Pikul
10/17/2003 Document, Report, or Work plan Review - other Sterling Landing Focused Feasibility Study (meeting to discuss general contents of FS prior to development; draft report dated and received in October 2002; ADEC comment letter dated October 22, 2002; draft final dated October 31, 2002; final dated January 2003 and received October 17, 2003). Gretchen Pikul
10/31/2003 Update or Other Action ADEC letter to USAF RE: Final Sterling Land Focused Feasibility Study. The Alaska Department of Environmental Conservation (ADEC), DoD Oversight group, received the Final Sterling Landing Focused Feasibility Study (dated January 2003) on October 17, 2003. The ADEC concurs with the contents of this final document. The Draft Sterling Landing Focused Feasibility Study (dated October 2002) was received on October 18, 2002; the ADEC comment letter is dated October 22, 2002. The Air Force Comment Response was received on October 25, 2002, and the ADEC reviewed the Comment Response and sent an e-mail approval on October 31, 2002. The Draft Final Sterling Landing Focused Feasibility Study (dated October 2002) was received on October 31, 2002. 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. 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
1/12/2004 Update or Other Action DNR South Centrol Land section letter to Takotna Community Association regarding land lease at Sterling Landing (dated January 8, 2004, received by ADEC on January 12, 2004). Gretchen Pikul
1/31/2004 Update or Other Action Follow-on RI at SS03, SS08, SS11 Report. The objectives of the 2003 RI include, by site: -SS03 - Investigate surface soil contamination at the petroleum, oil, and lubricants (POL) tank source area. In addition, collect groundwater samples from existing monitoring wells to document contamination trends. -SS08 - Collect groundwater samples to evaluate the impact from fuel contamination at the site. -SSI1 - Collect surface water and sediment samples at previously sampled locations to monitor contamination trends. In 2002, 13 boreholes were drilled within the POL Tank Farm impoundment and on the berm. DRO contamination above the ADEC Method Two cleanup level was found in several borings, primarily within the bermed area, at depths ranging from 5 to 22 feet bgs. The highest concentration of DRO detected was 12,300 milligrams per kilogram (mg/Kg) found from 5 to feet bgs in BH 2-20, located within the bermed area. Other analytes that exceeded their ADEC cleanup levels include benzene, GRO, methylene chloride, and naphthalene. Downgradient from the POL Tank Farm, five monitoring wells (BH/MW02-8, BH/MW02-9, BH/MW02-21, BH/MW02-23, and BH/MW02-24) were installed m 2002. BH/MW02-8 was dry, but samples collected from the remaining four wells had benzene concentrations that exceeded ADECT able C groundwater cleanup levels. DRO concentrations exceeded the ADEC cleanup level in two samples, and GRO exceeded the ADEC cleanup level in one sample. Groundwater samples contained benzene ranging from not detected to 0.087 mg/L, DROr anging from not detected to 2.5 mg/L, and GROra nging from not detected to 3.8 mg/L. Contamination above the cleanup level appears concentrated in BHI/MW, although other wells nearby had similar contaminant levels. BH/MW02-8w, hich was dry during previous sampling events, contained no detectable contamination. This well is shallower than the other wells at this site and is likely collecting groundwater from a perched zone of groundwater, as evidenced by its ephemeral nature and lack of contamination. Analytical detections for surface soil samples collected from within the tank impoundmentsa t SS03 in 2003 are presented in Table 4-2. Surface soil samples contained DROra nging from 11 to 2,300 mg/Kg. No VOCs, GRO, PAHs or lead were detected above cleanup levels. Comparison of groundwater data from samples collected in 2002 and 2003 show no significant trends. Benzene, DRO,a nd GROc oncentrations remained relahvely stable, except for DROin BH/MW02-21, which dropped from 4.66 mg/L in 2002 to 2.3 mg/L in 2003. Continued monitoring is recommended in 2004. Contaminated soil in the POL Tank Farm impoundment area is believed to be a continuing source of contamination to the groundwater downgradient, as evidenced by the fact that soil samples collected from above the water table downgradient of the source area were not significantly contaminated, but the groundwater was contaminated. Specifically, soil collected in 2002 from BH2-22 located between the tank impoundment and downgradient monitoring wells did not contain DRO contamination above ADEC cleanup criteria (Appendix F), but the groundwater in downgradient wells did contain DRO. Standing water in the tank impoundmentsd ictated sampling locations and may further restrict sampling in the future, depending on rainfall activity. Removal of the secondary containment berms, the foundations of the former POL Tank Farm impoundments, and associated liner material is recommendedin order to delineate contamination beneath these structures. Until these items are removed, the site cannot be fully characterized (i.e., slowing down the cleanup process and record of decision process). Louis Howard
2/5/2004 Update or Other Action SS02 and LF04 ROD - 1st draft dated September 2003; 2nd draft received on October 6, 2003 via e-mail; ADEC comments dated October 15 and 23, 2003. On February 5, 2004, ADEC participated in an all day comment resolution meeting on LF04 draft ROD using new Air Force ROD guidance. Gretchen Pikul
4/8/2004 Meeting or Teleconference Held Kathy Luttio note to file: April 8,2004, 10:25 A.M. Called Gretchen Pikul with DEC (269-3077) and asked her about TeA's tank farm at Sterling Landing regarding all of the tallies having liners underneath them. Gretchen stated that the three tanks I was asking about were all on the soil with no liners. I also mentioned that Mr. Newton claimed that there was only one spill at Sterling Landing; which was the spill we have documentation about. But Gretchen Pikul said that she had spoke to a teacher and had documentation that that was not true, Gretchen Pikul
6/24/2004 Update or Other Action Sterling Landing Barge Ramp - June 21, 2004 petroleum-contaminated soil in the Air Force former June 21, 2004: Unidentified Contractor bulldozed petroleum contaminated soil from a former Air Force fuel truck fill stand into the Kuskokwim River while constructing a barge landing on State of Alaska-owned property at Sterling Landing. ~13.5 Miles WSW of McGrath. Air Force consultant was on-site collecting groundwater samples from Air Force monitoring wells and informed barge contractor not to disturb the contaminated soil, but the barge contractor disregarded the information and created a barge ramp using the contaminated soil; photos of the barge ramp construction are in ADEC files. On June 24, 2004, Air Force consultant met with ADEC and DNR (land manager of the Air Force leased land) to brief on the events; potentially 2 monitoring wells (one ADEC and one Air Force) were destroyed in process. Gretchen Pikul
8/31/2004 Update or Other Action On June 30, ADEC entered the barge ramp construction in the Complaint Automated Tracking System (CATS) database - #2004-435, and sent an update e-mail to Takotna community. On July 2, ADEC completed a Memorandum for consideration of an investigation by ADEC Environmental Crimes Unit; the consideration was granted by ADEC management. ADEC procured an ADEC term contractor to sample the barge ramp and disturbed area; a pre-proposal meeting was held on August 16 and participants included ADEC term contractor, Environmental Crimes Unit staff, AG's office staff, and CS and Contracting staff; draft work plan received and a comment resolution meeting on August 24/25; August 31 e-mail with ADEC and Air Force monitoring well inventory and figure from Dave Longtin site visit. Gretchen Pikul
9/16/2004 Update or Other Action SS02 and LF04 ROD - 3rd draft received on March 8, 2004; ADEC sent comments on March 19. On May 6, 2004, ADEC participated in a comment resolution meeting, and on May 13, 2004, ADEC participated in a teleconference. On May 20, 2004, ROD Declaration Pages were submitted for review; ADEC comments were sent on May 24; an expedited review was requested so that the RODs could be forwarded to Air Staff and PACAF quickly. In June 2004, the Air Force project management changed from Doug Wootten to Dave Longtin. On July 15, 2004, ADEC received a call from Jim Klasen (Air Force attorney) on ROD LUCs; it was decided to add recently-developed ROD guidance template language to RODs. On July 22, 2004, Air Force submitted draft final ROD versions with Jim Klasen edits; however, the March 2004 was used instead of the latest version dated May 2004. ADEC received August 2004 version of LF04 and SS02 RODs on September 16; continuing discussion with PACAF on format and contents of LF04 ROD. Gretchen Pikul
10/6/2004 Update or Other Action Sterling Landing Barge Ramp Site Investigation; draft dated and received via e-mail on October 6, 2004. Gretchen Pikul
6/9/2005 Update or Other Action Tod Fickel (USAF) sent letter to Rick Thompson (ADNR) letter Subject: Land Use Controls at Sterling Landing. This will confirm our telephone conference with Mr. Jeff Norberg of Alaska Department of Conversation (ADEC) and you on April 18, 2005, whereby we discussed Land Use Controls (LUCs) at Sterling Landing. A map of the area is enclosed. The area outlined on the map contains petroleum contaminated soil and groundwater above ADEC most stringent cleanup levels (as specified in 18 AAC 75). The Air Force is in the process of developing a cleanup plan for the Sterling Landing site and documenting that plan in a Record of Decision (ROD) to be signed by the Air Force and ADEC. As part of the cleanup plan, the Air Force and ADEC are proposing to restrict land use in the outlined area from uncontrolled excavations and/or groundwater use until the cleanup goal outlined area from uncontrolled excavations and/or groundwater use until the cleanup goal specified in the ROD have been met. The time to reach cleanup goals may exceed twenty (20) years. The proposed LUCs will: prohibit the excavation, grading, or disturbing soil that contains petroleum contamination above cleanup levels in this ROD, prohibit the installation of drinking water wells, prohibit the use of untreated groundwater for any purpose without specific approval from the Air Force 611th CES/CC, and require a US Air Force approved Groundwater Management and Treatment Plan for any activity that has the potential to encounter groundwater. It is our understanding that the DNR will cooperate with the documentation and enforcement of these LUCs. Our understanding is that DNR will place a "reserved use" designation on the subject property in the DNR land records. It is also our understanding that DNR will use this reserve use designation to help DNR property managers to be informed of the restrictions on the property. In the event of people applying to use this land, DNR will be better able to evaluate their requests. We understand that DNR will satisfy the public notice requirements pursuant to its regulations. In our teleconference call, we also discussed how signage could be useful in informing the public of the contaminated soil and groundwater, and restrictions on the land use. The Air Force hereby requests permission to install signs that indicates the land is contaminated and land use is restricted by DNR. Please sign and return this letter indicating the DNR's concurrence. Thank you for your cooperation. Signed by Todd Fickel Remedial Project Manager. Mr. Rick Thompson, Regional Manager, Department of Natural Resources, Southcentral Region signed letter on June 16, 2005. Jeff Norberg
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
8/31/2005 Update or Other Action Follow-on RI At SS03, SS08 and SS11 Report. SS03 Soil sampling results: Four analytes were detected in soil samples collected from Tank Pit 2/3 (Test Pits 1 through 3) at concentrations above the ADEC Method Two cleanup levels. • DRO – detected in nine samples at concentrations above the ADEC Method Two cleanup level of 250 mg/Kg. DRO concentrations ranged from 840 mg/Kg to 22,000 mg/Kg in samples collected from the surface to 11.5 feet bgs. • GRO – detected in one sample at 3 feet bgs from Test Pit 2 at 440 mg/Kg, above the ADEC Method Two cleanup level of 300 mg/Kg. GRO was detected below the cleanup level in all other samples. • Benzene – detected in five samples, collected from two of the three test pits (Test Pits 2 and 3), at concentrations above the ADEC Method Two cleanup level of 0.02 mg/Kg. Benzene concentrations that exceeded the cleanup level ranged from 0.024 mg/Kg to 0.17 mg/Kg in samples collected from the surface to 11.5 feet bgs. • Naphthalene – detected at 33 mg/Kg in the surface sample and at 29 mg/Kg in the 3-foot sample from Test Pit 2 – both above the ADEC Method Two cleanup level of 21 mg/Kg. Naphthalene was analyzed by U.S. Environmental Protection Agency Solid Waste Methods 8260 and 8270 Selective Ion Monitoring (USEPA, 1986), and the concentration reported above reflect the highest concentration reported for both methods. In Tank Pit 1, DRO was detected in three of six samples collected from Test Pits 9 and 10 at concentrations above the ADEC Method Two cleanup level of 250 mg/Kg. DRO concentrations that exceeded the cleanup level ranged from 860 mg/Kg to 4,900 mg/Kg. Surface soil samples collected from Test Pits 9 and 10 did not contain DRO above the cleanup level. Subsurface samples collected from Test Pit 9 had DRO above the cleanup level at 5 and 11 feet bgs, whereas Test Pit 10 had DRO above the cleanup level at 5 feet bgs. In samples collected from test pits located outside of the tank pits (Test Pits 4 through 8), analytes were detected above the ADEC Method Two cleanup level in one sample. DRO was detected in the sample collected from the 5-foot interval in Test Pit 7 at 2,000 mg/Kg, above the Method Two cleanup level of 250 mg/Kg. This test pit was excavated topographically downgradient from and outside of Tank Pit 1. Groundwater samples from the seven monitoring wells sampled at SS03 in 2004 contained concentrations of benzene that exceed ADEC Table C cleanup level of 0.005 mg/L (Table 3-2 and Figure 3-1). Benzene was detected at concentrations ranging from 0.0093 mg/L to 0.094 mg/L. A comparison of 2004 data with selected historical data is presented in Table 3-3. DRO was detected above the ADEC Table C cleanup level of 1.5 mg/L in three of the seven wells sampled (BH1-MW, BH/MW02-21, and BH/MW02-24), ranging from 2.1 mg/L to 6.4 mg/L (Table 3-2 and Figure 3-1). GRO was also detected above the ADEC Table C cleanup level of 1.3 mg/L in three of the seven wells sampled (BH1-MW, BH20-MW, and BH/MW02-23), ranging from 1.8 to mg/L to 5.1 mg/L. Louis Howard
10/17/2005 Update or Other Action Record of Decision (ROD) received. As there is no CERCLA authority to take action, a no action response is the appropriate and selected remedy for this site under CERCLA. However, because petroleum substances are COCs under State of Alaska laws and regulations, the site is being addressed under those applicable laws and regulations, including but not limited to Title 46 of the Alaska Statutes and regulations promulgated there under. This Record of Decision (ROD) is issued in accordance with and satisfies the requirements of the Defense Environmental Restoration Program, 10 United States Code (USC) 2701 et seq.; CERCLA 42 USC 9601 et seq.; Executive Order 12580, 52 Federal Register 2923 (23 January 1987); National Contingency Plan, 40 Code of Federal Regulations 300; and, Alaska Oil and Hazardous Substance Pollution Control Act, 18 Alaska Administrative Code (AAC) 75. The State of Alaska concurs with the selected remedies. EPA has been consulted consistent with the requirements of 10 USC 2705 and has provided no comments. The selected final remedial actions for SS-002 address the petroleum constituents in soil and groundwater which exceed the Alaska Department of Conservation (ADEC) Cleanup Levels. The Remedial Action Objectives (RAOs) for SS-002 are to: · reduce the soil concentration of benzene, GRO, and DRO to levels that allow for unrestricted use of the land and improve the effectiveness and efficiency of the groundwater remedy and · reduce groundwater concentrations of DRO and GRO to levels that allow for unrestricted use of the groundwater and prevent potential impacts to the surface water. This ROD is based on documents contained in the administrative record file for Tatalina LRRS, including but not limited to the 1991 Preliminary Assessment, the 1996 Environmental Baseline Survey, the 1997 Remedial Investigation and Baseline Risk Assessment, the 1999 Site Characterization and Feasibility Study, the 2002 Remedial Action and Monitoring Report, the 2002 Focused Feasibility Study, and the 2004 Groundwater Monitoring Report. SS-002 Soil: max. concentration- DRO 75,000 mg/kg (BH15/MW, 1997) cleanup level 250 mg/kg, GRO max. concentration 4,000 mg/kg (BH16/MW, 1997) cleanup level 300 mg/kg, benzene-max. concentration 0.201 mg/kg (MW-01, 2002) cleanup level 0.02 mg/kg. Groundwater: DRO max. concentration 470 mg/L (BH25/MW) cleanup level 1.5 mg/L, GRO 2.7 (BH25/MW) cleanup level 1.3 mg/L, benzene 0.005 mg/L (BH15MW, 1997) cleanup level 0.005 mg/L. The selected remedial action for DRO and GRO contaminated groundwater at SS-002 is monitored natural attenuation (MNA) with LUCs. To ensure the protectiveness of the remedy the groundwater will be sampled for benzene, DRO, GRO and natural attenuation parameters in approximately six monitoring wells immediately prior to soil excavation activities, once a year for two years and then once every two years thereafter. The groundwater sampling will be performed consistent with a comprehensive monitoring plan developed and approved by the Air Force and ADEC. The monitoring program will be consistent with the technical requirements of the State of Alaska regulations, 18 AAC 75.360. The site will be considered closed and no further groundwater monitoring will be required after the results of two consecutive biannual groundwater-monitoring events demonstrate that the COCs are below the groundwater cleanup levels. The LUCs at SS-002 will · prohibit the excavation, grading or disturbing soil that contains COCs above the cleanup levels listed in this ROD, · prohibit the installation of drinking water wells, · prohibit the use of untreated groundwater for any purpose without specific approval from the CES/CC, and · require a Groundwater Management and Treatment Plan for any activity that has the potential to encounter groundwater. The LUCs at SS-002 will be implemented by the following: · The LUCs and LUC boundaries (Figure 4) will be documented in the Tatalina Base General Plan (BGP). · The LUCs will be incorporated into an administrative procedure for construction activities, including well installation. The LUCs at SS-002 will be enforced by the following: · Annual inspections consisting of an administrative inspection of the LUCs in the Tatalina BGP, a review dig permit approval records and a visual inspection of the SS-002 site, will be performed by the Air Force. The inspections shall be documented on a site inspection checklist. Jeff Norberg
11/7/2005 Update or Other Action Record of Decision: Sterling Landing - SS-002 Site Spill/Leak No. 8; version October 17, 2005 signed by PACAF on November 4, 2005 and submitted to ADEC on November 7, 2005 for signature of concurrence. Jeff Norberg
1/5/2006 Update or Other Action Email memo for the record by Jeff Norberg to USAF Todd Fickel RE: Tatalina LRRS RODs- ADEC position for Sites SS002 and LF004. It is not ADEC's intentions to slow down the Record of Decision (ROD) proceedings for Tatalina Sites SS-002 and LF-004. It is mutually beneficial to the Air Force and ADEC to move forward on the conditional closure of these sites; however, given that these are legal documents, it is both of our responsibilities to ensure that the selected remedies are protective (of human health, welfare, safety and the environment) and meet our program goals and requirements. Per my email dated December 8, 2005, ADEC management will NOT sign the Decision Document for SS-002 in its current state. While required revisions related to monitoring frequency were expected and reflected in my review dated May 5, 2005, I unfortunately did not anticipate other revisions which stem from a legal perspective prompted by the selected remedy of No Action Response under CERCLA. The legal changes are necessary to make language in the document consistent with State (of Alaska) cleanup requirements where the Air Force is the "Responsible Party" (NOTE: i.e. "responsible person" which means a person who is required under AS 46.04.020 or AS 46.09.020 to contain or perform a cleanup of a discharge or release of a hazardous substance;"person" means any individual, public or private corporation, political subdivision, government agency, municipality, industry, copartnership, firm, trust, estate or any other entity whatsoever.) instead of the lead agency and DEC is the lead regulatory agency. Again, prior to ADEC concurrence with the ROD for SS-002, the Air Force needs to make the changes that are marked within the attached PDF version of the ROD. Our preference is to revise the document and print a clean version for signature. We are willing to meet as soon as possible to come to resolution on these issues. Please contact me at your ealiest convenience, I understand the RA contract/funding issues for Site SS-002 are imminent. Jeff Norberg
2/1/2006 Update or Other Action File number issued 2655.38.011. Aggie Blandford
2/27/2006 Update or Other Action ADEC briefing December 9; meeting with the Air Force to discuss issues with ROD on January 26, 2006; February 27, 2006 ADEC issued letter to Air Force indicating that although the department agrees with the overall cleanup approach proposed for SS-002, ADEC does not concur with specific text written within and therefore refuses to sign the ROD. The department agrees with the overall cleanup approach in the ROD. However, due to some specific wording the document, the department is not willing to sign the ROD. Our primary concerns are written below. The Statement of Basis indicates, “a no action response is the appropriate and selected remedy for this site under CERCLA. However, because petroleum substances are COCs under State of Alaska laws and regulations, the site is being addressed under those applicable laws and regulations.” The department agrees that it is appropriate to address the contamination at Site SS-002 under ADEC 18 AAC 75; however, several clauses throughout the ROD confuse the issues of lead agency authority under CERCLA and State authority on cleanups conducted under Alaska law. A few such examples are provided below. The second paragraph within the Statement of Basis states, “the ROD is issued in accordance with and satisfies the requirements of the Defense Environmental Restoration Program, 10 United States Code (USC) 2701 et seq.; CERCLA 42 USC 9601 et seq.; Executive Order 12580, 52 Federal Register 2923 (23 January 1987); National Contingency Plan, 40 Code of Federal Regulations 300; and, Alaska Oil and Hazardous Substance Pollution Control Act, 18 Alaska Administrative Code (AAC) 75.” Since the Air Force is establishing no further action is required under CERCLA, this section should be revised or another paragraph or sentence should be added noting that Executive Order 12580, CERCLA and the NCP do not apply to cleanup work under 18 AAC 75. Text within the Remedial Action Objectives and Selected Remedy section states that approximately six monitoring wells will be sampled immediately prior to soil excavation activities, once a year for two years and then once every two years thereafter. However, analytical results from the June 2004 sample from monitoring well BH25/MW include DRO at 470 mg/L (18 AAC 75.345, Table C cleanup level is 1.5 mg/L), which is a significant increase from prior monitoring results. This raised concern over the extent and magnitude of groundwater contamination at the site. ADEC has requested annual groundwater monitoring, during low-water elevation following spring thaw, for two years followed by data evaluation and then determination of future monitoring requirements rather than automatically defaulting to sampling every other year. The same section states that the site will be closed when groundwater monitoring results are below cleanup levels for two consecutive monitoring events. However, complete site closure would occur when all cleanup levels have been achieved in all media. A conditional closure, with suitable institutional controls, may be appropriate sooner. The ROD specifies that Air Force approval is required prior to using untreated groundwater and that institutional control tracking and enforcement reports will be provided to the department for informational purposes only. We disagree with the “for informational purposes only” clause. Per State regulations contaminated soil and groundwater can not be moved off-site without prior department approval and the department may take a variety of actions in response to a failure of institutional controls. The document describes using the nine criteria to evaluate remedial alternatives per the national contingency plan (NCP); however, State acceptance is not a modifying criteria in selecting a cleanup methodology under 18 AAC 75. Department approval of cleanup plans is required and thus is a threshold criterion. Rather than signing the ROD that contains wording we disagree with, the department is issuing this letter of concurrence on the general approach (no further action under CERCLA and cleanup of petroleum contamination under 18 AAC 75). We look forward to continuing to work with the Air Force on cleanup of the site. Jeff Norberg
4/25/2006 Update or Other Action Todd Fickel (USAF) sent letter to John Halverson (ADEC) RE: Record of Decision (ROD) SS-002 Sterling Landing. The ROD had a two-fold approach: 1) to document a No Further Action decision under CERCLA and 2) to document the proposed remedial approach in accordance with ADEC regulations. It is unfortunate that the wording required by USAF policy for RODs addressing CERCLA sites conflicted with the State of Alaska's authority to conduct cleanup in accordance with 18 AAC 75. Regardless of these conflicts, the USAF 611 CES/CEVR (611) is committed to meeting ADEC regulations as they pertain to this site. With that understanding, the 611 is rescinding the previously submitted ROD for further consideration and signature by ADEC. The 611 will pursue site closure using current USAF policy and contracting methods in accordance with applicable ADEC regulations. John Halverson
2/27/2007 Meeting or Teleconference Held Meeting with ADEC, USAF, BEM Systems Inc. (AF contractor), AFCEE. Objectives of the meeting as defined by BEM were to: Discuss the USAF proposed Cleanup Action for SS002 at Sterling Landing; Provide for common understanding of the technical basis for the proposed action that is: Protective of human health and the environment, Compliant with (State of Alaska) regulations and Air Force policy, Cost effective for the U.S. Taxpayer,and Implemented in FY07. Receive preliminary feedback from ADEC; Resolve any issues prior to completion and submittal of the Cleanup Plan to allow corrective action to be completed in FY07. BEM summarized the technical basis of the proposed cleanup plan and made the following recommendations: Treatment or removal of DRO-contaminated vadose zone soil in the Truck Stand Area to alternative cleanup levels (ACL) equivelant to Method Two (Method Three is ACL not Method Two Table B1) for protection of human health; Monitoring of natural attenuation in groundwater until concentrations of diesel range organics (DRO) and gasoline range organics (GRO) fall below Table C Groundwater Cleanup Levels; Institutional controls by Dept. of Natural Resources (DNR) to prevent use of the groundwater as a water supply until contaminant concentrations in groundwater fall below Table C groundwater cleanup levels. BEM presented the technical basis for determination that only the Truck Stand Area warrants remedial action for vadose zone because the other two areas: the Tank Farm Area and the Landing Area are not "adversely" affecting groundwater and do not pose an unacceptable risk to human health. BEM noted that the DRO-contaminated soil removed from the Truck Stand Area would be either treated on site using an in-situ blending/sodium persulfate oxidation approach previously discussed with ADEC or hauled off for off-site disposal, depending on the volume of contaminated soil being addressed. See site file for additional information. Jeff Norberg
4/2/2007 Update or Other Action Summary of Meeting to Discuss Site Closure, Sterling Landing (Site SS-002), Tatalina Long-Range Radar Station (LRRS), Alaska. On 27 February 2007, the Alaska Department of Environmental Conservation (ADEC), Contaminated Sites - Federal Facilities Environmental Restoration Program received a letter from Air Force performance-based contractor, BEM Systems, Inc. (BEM), summarizing the minutes of our meeting on 9 February 2007. ADEC met with the Air Force and BEM to discuss options for a revised cleanup approach to address petroleum contamination in soil and groundwater associated with the former Air Force tank farm at Sterling Landing (Site SS-002). Site SS-002, situated on a 1.7 acre parcel adjacent to the Kuskokwim River, was used by the Air Force under a joint use agreement with the State of Alaska between 1950s and 1994 in support of the Air Force installation at Tatalina LRRS, Alaska. In his letter Richard Newill, BEM Director of Southwest Region, requested that the department provide additions, clarification, and/or corrections as deemed necessary to accurately capture the important issues and decisions discussed at the meeting. I have since had the opportunity to brief ADEC management and review historical data and public documents related to this site. As result of this review, we have determined that additional information is required to ensure that the revised proposal for minimal contaminant source reduction and passive treatment will be protective to human and ecological receptors. Critical to these requirements is a consultation with the property owner [Alaska Department of Natural Resources (ADNR)] to obtain official concurrence for long-term conditional closure with institutional controls (ICs) on soil and groundwater at Site SS-002. Notice of this concurrence is mandatory before ADEC can fully assess the cleanup approach outlined in Mr. Newill’s letter. Our primary concerns are summarized as follows: According to Mr. Newill’s letter he indicated that, “Only the Truck Stand Area warrants remedial action for vadose zone soil because the other two areas, the Tank Farm Area and the Landing Area, are not adversely affecting groundwater and do not pose an unacceptable risk to human health.” This statement appears contrary to information that has been presented to ADEC; ADNR; and the public during numerous meetings and historical documents/fact sheets prepared for the site over the past ten years. Prior to the award of the performance-based contract to BEM, ADEC agreed with the Air Force’s plan to remediate the site through soil excavation using Method Two migration to groundwater cleanup levels; onsite treatment by low-temperature thermal desorption (LTTD); soil reuse; and monitored natural attenuation (MNA) of groundwater. By using this approach, source removal would result in the treatment and reuse of approximately 6,000 cubic yards of petroleum contaminated soil in the vicinity of the former truck fill stand and tank farm areas. This treatment alternative was selected based on the results of the 2002 Focused Feasibility Study (FFS) and summarized in the publicly reviewed Proposed Plan for Cleanup of Site SS-002, dated July 2003 to achieve the largest degree of contaminant reduction because they would eliminate the toxicity, mobility, and volume of contaminants in the soil through thermal destruction. According to the FFS, this cleanup alternative “would meet the threshold criteria for overall protectiveness because thermal treatment of POL-contaminated soil and attenuation of contaminated groundwater would reduce constituent concentrations to levels protective of human health and the environment.” Furthermore, “After the treatment of overlying contaminated soils, groundwater will naturally attenuate to concentrations below cleanup levels. Without a new source of petroleum hydrocarbon contamination, natural attenuation will have a high degree of long-term effectiveness on groundwater.” “It is expected to take 2 or 3 years after soil treatment before contaminated groundwater reaches cleanup goals by natural attenuation.” Based on the 2003 Proposed Plan for this site, “The evaluation of the remedial alternatives for contaminated soil determined that all passive treatments (such as institutional controls, capping, and natural degradation) did not provide adequate reduction of contamination and were not effective in both the short and long term. These alternatives therefore were eliminated from further evaluation. Alternatives that required long-term operation, monitoring, and maintenance (such as in-situ and onsite biodegradation) could not be effectively executed and were thus eliminated. Implementation difficulties and high costs further eliminated the on-site high temperature thermal desorption and offsite disposal alternatives. For additional information see site file. Jeff Norberg
7/2/2007 Document, Report, or Work plan Review - other The Alaska Department of Environmental Conservation (ADEC), received the Draft Cleanup Plan for SS002: Sterling Landing Tatalina Long Range Radar Station, Alaska (dated May 2007) on May 22nd. We have completed our review, and have provided comments below. Given that text within the Plan is often reiterated within more than one section, please ensure that appropriate revisions are made to related sections throughout this document. To restate ADEC's position, as a prerequisite for ADEC to approve this Plan it is a critical to consult with the property owner [Alaska Department of Natural Resources (ADNR)] to obtain official concurrence for long-term conditional closure with institutional controls (ICs) on soil and groundwater at Site SS002. As indicated in Section 7.3, as the responsible party the Air Force will assist the property owner in maintaining ICs on soil and groundwater at Site SS-002 until the time when contaminant concentrations meet the most stringent cleanup levels defined in 18 AAC 75, required for unrestricted use. The Air Force also needs to install and maintain appropriate signage indicating that the land and groundwater is impacted by petroleum contamination and land use is restricted by ADNR. Text throughout the document proposes that a soil cleanup level less stringent than Method Two migration to groundwater is appropriate for Sterling Landing (Site SS002). Historical sample results indicate that fuel contamination has migrated to impact groundwater at the Former Tank Area; Former Truck Stand Area; and the Landing Area. Before ADEC can evaluate the applicability of an alternative soil cleanup level, additional site characterization is necessary at the Former Tank Area and the Landing Area. If groundwater contamination has the potential to migrate off-site to impact the Kuskokwim River, as it has been determined for the Former Truck Stand Area, then soils will need to be cleaned up to Method Two migration to groundwater levels (18 AAC 75.341). Based on the contaminant sources (i.e., gasoline/diesel tanks; associated pipeline and fuel dispenser), soil and groundwater samples should be analyzed for GRO, DRO, BTEX, and PAH. Natural attenuation parameters should also be collected for groundwater to confirm hydrogeologic conditions are conducive for this remedial approach. The Air Force should conduct a comprehensive review of site data at least every five years to evaluate the effectiveness of natural attenuation on groundwater. An alternate treatment technology may be required at any point if MNA is deemed not protective of human health and the environment. Text in Section 3.2 reads that, “Soil contaminated with petroleum in excess of Method Two Soil Cleanup Levels for protection of human health is limited to three areas of limited areal extent: immediately south of the former diesel storage tank, near the former truck stand, and in the landing area.” Over the last ten years, ADEC has reviewed/approved several field sampling plans with proposed sample locations for Site SS-002 based on the premise that surface and subsurface soil above Method Two migration to groundwater cleanup levels would be excavated and treated on-site and that soil samples would be collected to confirm “clean” excavation sidewalls. Based on information presented in Section 2.5 of the Sterling Landing Focused Feasibility Study, dated January 2003, there is approximately 6,000 cubic yards of soil which exceed migration to groundwater cleanup levels. For ADEC to evaluate the suitability of approving a less stringent cleanup level at Sterling Landing, the Air Force will need to conduct additional sampling to better delineate horizontal and vertical extent of residual contamination; provide sufficient evidence that there is not a continued contaminant source impacting groundwater and calculate the volume of soil that is impacted with petroleum in excess of Method Two migration to groundwater and ingestion/ inhalation soil cleanup levels. While the prior cleanup approach documented in the 2003 Proposed Plan for Sterling Landing may have been more conservative, ADEC had a higher level of confidence that through source reduction human and ecological receptors would be protected and contaminants would not potentially migrate off-site to adversely impact the Kuskokwim River. Given the Air Force’s recent proposal to leave significant petroleum soil contamination in place ADEC needs greater assurance that human health and the State’s resources are protected. For additional information see site file. Jeff Norberg
8/22/2007 Document, Report, or Work plan Review - other Jeff Norberg (ADEC PM) sent letter to Todd Fickel (USAF PM) RE:Draft Final Cleanup Plan for SS002: Sterling Landing, Tatalina Long-Range Radar Station (LRRS), Alaska. The Alaska Department of Environmental Conservation (ADEC), Contaminated Sites - Federal Facilities Environmental Restoration Program received the Draft Final Cleanup Plan for SS002: Sterling Landing Tatalina Long Range Radar Station, Alaska (dated August 2007) during our resolution meeting for the Draft Cleanup Plan on August 10th. While many of the issues identified in our 2 April 2007 and 2 July 2007 letters have been addressed and satisfied, there are other issues which remain. These issues have been reiterated within this comment letter; however, for a more comprehensive understanding of the department’s position all three letters should be reviewed in series. 1. As indicated in our 2 July 2007 comment letter for the Draft Cleanup Plan for SS002, given that text within this document is often reiterated within more than one section, please ensure that appropriate revisions are made to related sections throughout this document. While modifications were made to the previous document, revisions have not been made consistently throughout this version. For example, text in Section 3.1.1.3 was revised based on a previous ADEC comment; however, similar text related to benzene data in the subsurface soil at the Landing Area in Section 4.3.2.3 is still inaccurate. Please review/ revise this and other text as appropriate. 2. As indicated in Section 7.4, as the responsible party the Air Force will assist the property owner in implementing, monitoring, maintaining, reporting institutional controls (ICs) on soil and groundwater at Site SS-002 until the time when contaminant concentrations meet the most stringent cleanup levels defined in 18 AAC 75, required for unrestricted use. The Air Force is required to install and maintain appropriate signage indicating that the land and groundwater is impacted by petroleum contamination and land use is restricted by ADNR [18 AAC 75.375(b)(1)]. Please include text to indicate that the Air Force agrees to install appropriate signage at SS002 to inform public of ICs. This signage should be installed as soon as possible following and based on the results of the supplemental characterization. 3. Based on incomplete site data, the Air Force has agreed to conduct additional sampling to better delineate horizontal and vertical extent of residual contamination; provide sufficient evidence that there is not a continued contaminant source impacting groundwater and calculate the volume of soil that is impacted with petroleum in excess of Method Two migration to groundwater and ingestion/ inhalation soil cleanup levels. Since the supplemental characterization has yet to be completed it is premature to conclude that “there is no significant continuing source of groundwater contamination” at the Former Tank Area or Landing Area (as indicated in Section 3.2 and others). Once again, before the department can evaluate the appropriateness of an alternative soil cleanup level, it is necessary to complete this supplemental site characterization. As such, many sections of this document are currently written in a manner which assumes that no further action will be necessary with the exception of groundwater monitoring for natural attenuation. Please revise text throughout document to indicate that ADEC will determine the applicability of alternative cleanup levels and proposed site remedy(s) based on the findings of the supplemental characterization. 4. Based on the contaminant sources (i.e., gasoline/diesel tanks; associated pipeline and fuel dispenser), both soil and groundwater samples should be analyzed for GRO, DRO, BTEX, and PAH. Please review Table 2A of the ADEC UST Procedures Manual for analytical requirements for related petroleum products (http://www.dec.state.ak.us/spar/ipp/docs/ust_man02_10_07.pdf). 5. The Air Force should conduct a comprehensive review of site data at least every five years to evaluate the effectiveness of natural attenuation on groundwater. Please revise text to include this evaluation. An alternate treatment technology may be required at any point if MNA is deemed not protective of human health and the environment. 6. The Air Force is required to assess the affect of seasonal variations in ground-water flow direction on contaminant transport to be protective of the Kuskokwim River [18 AAC 75.345(h)]. Contrary to the proposed scheduled identified in Section 7.3, groundwater sampling and water level survey should be conducted at least three times during the first year in the spring, summer, and fall. This data will be used to determine optimal strategy for future annual sampling events and to assess the appropriateness of decreased sampling frequency, in the future. For additional information see site file. Jeff Norberg
8/31/2007 Document, Report, or Work plan Review - other Staff reviewed and commented on the Draft Final Cleanup Plan for SS002: Sterling Landing, Tatalina Long-Range Radar Station (LRRS), Alaska. Based on the inclusion of the Air Force Comment Responses within the Final Cleanup Plan, the department agrees with the contents of this document with the following exceptions. Response to Comment No. 4: Text indicates that, “the Final Cleanup Plan and Supplemental Site Characterization Plan will be modified to include the possible analysis for polynuclear aromatic hydrocarbons (PAHs) in accordance with this reference. Specific attention will be paid to the following footnote #1 of the referenced Table 2a.” Given that PAHs must be analyzed within fourteen (14) days of sample collection, it is important to provide sufficient time for analyses by selecting at least one soil sample for PAHs from each boring and directly submitting it to the off-site laboratory. The sample with the highest concentration based on screening data (i.e., field GC/ PID/ PetroFlag) should be chosen. Response to Comment No. 5: Text reads that, “The USAF will endeavor to review site data every 5 years, subsequent to initiating the supplemental site characterization and possible remedial actions, for the evaluation of effectiveness of natural attenuation at the site.” Delete the word “endeavor.” The USAF should review/evaluate site data at least every 5 years, not just make an attempt. Response to Comment No. 12: Text indicates that, “All borings will be extended to a minimum of 15 feet bgs or to the soil-groundwater interface, whichever comes first.” All borings should extend to the soil-groundwater interface, not just to 15 feet bgs. This provides additional assurance that a surface spill/release has not migrated and impacted groundwater via preferential pathways in soil. Response to Comment No. 12: Text reads that, “A total of about 25 samples will be submitted to an off-site laboratory for TPH-GRO and BTEX and another 25 for TPH-DRO.” As per Comment No. 4 above, please select at least one soil sample for PAHs from each boring and directly submit to off-site laboratory for analysis. The sample with the highest concentration based on screening data (i.e., field GC/ PID/ PetroFlag) should be chosen. Jeff Norberg
9/11/2007 Document, Report, or Work plan Review - other Final SS002 Sterling Landing Cleanup Plan received. Groundwater contamination: June 2004 well BH25/MW 2.7 mg/L GRO, DRO at 470 mg/L however in Sept 1999 it was 3.79 mg/L for DRO and July 2002 it was 2.37 mg/L for DRO. Remedial Action Objectives (RAOs) for the truck stand are to allow for unrestricted land use* and improve the effectiveness and efficiency of the groundwater remedy, and to reduce the concentrations of DRO and GRO in groundwater and prevent potential adverse impacts to surface water in the Kuskokwim River. *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. EO 12580 paragraphs 2(d) and (e)(1) delegates the authority in CERCLA §104 and §121 to the Federal agencies or departments for selecting and conducting remedial actions addressing releases or threatened releases at sites that are not on the NPL. Consistent with CERCLA §121, Federal agencies or departments should conduct five-year reviews for all CERCLA non-NPL remedial actions that require a review. Truck Stand Area-DRO at 75,000 mg/kg in BH15/MW at 5' bgs and 29,000 mg/kg at 10'bgs, 71,100 mg/kg and benzene at 3.11 mg/kg, at 4' bgs, 30,200 mg/kg 1.5' bgs with GRO at 2,820 mg/kg and 36,800 mgkg and GRO at 1,970 mg/kg at ground surface all in SLSB01. Soil cleanup level is Method Two for Migration to groundwater at 300 mg/kg GRO, 250 mg/kg DRO and 0.02 benzene. Proposed Action: Soil removal or in-situ treatment of vadose zone soil in the truck stand area to reduce DRO and GRO concentrations to below the proposed soil cleanup levels specified in Table 3. Supplemental characterization soil sampling and analysis in the former tank area and landing area to confirm that contamination in the vadose zone exceeding human health risk based levels is limited in extent and magnitude, and is not likely to pose an unacceptable risk under unrestricted use. See site file for additional information. John Halverson
9/21/2007 Update or Other Action Memo for the Record by John Halverson (ADEC) to Todd Fickel (USAF) re: Tatalina-Sterling Landing. Per our discussion earlier this week, ADEC understands that the contractor is stopping work on this project due to contract issues related to the fact the contract covered work both at Tatalina and Oliktok. The Air Force is working with the contractor to ensure a logical wrap-up occurs, meaning the site will be left in a secure, environmentally stable condition and adequate records are produced to document work that has been conducted to document work that has been conducted (a complete report will not be produced under the current contract). My understanding is some assessment/characterization work was conducted, but cleanup (excavation of contaminated soil) was not initiated. Please let ADEC know if this is not the case, keep ADEC informed if new information becomes available, and provide copies of records produced by the contractor for work that has been implemented. John Halverson
2/19/2008 Exposure Tracking Model Ranking Initial ranking with ETM completed. Louis Howard
5/29/2008 Update or Other Action The Alaska Department of Environmental Conservation (ADEC), Contaminated Sites (CS) Program has reviewed the information provided on the chemical pentanonic dated April 30, 2008 and received in our office on May 1, 2008. Additional review and discussion occurred during the requested meeting on May 8, 2008, between Ms. Teresa O'Carroll of Iliaska Environmental LLC, Mr. Earl Crapps of ADEC, and yourself. All of the technical information provided on the chemical pentanonic, including but not limited to, its chemical composition and toxicity data has been evaluated and the CS program has determined that it is acceptable for use as a remediation technique for petroleum contaminated sites within the State of Alaska. The following conditions apply to the use of pentanonic for all CS projects. Alternative additives fiom the standards discussed must be proposed and approved by the department on a site specific basis. The standard additives are Magnesium oxide (builder), Sodium 1-butanesulfonate (anionic surfactant) and Sodium stearate (nonionic surfactant). Additives should be identified in a work plan submitted to the department for approval. The minimum dilution ration of pentanonic prior to application is seven parts water to one part pentanonic (7:l). Additional dilution of the chemical pentanonic may be required on a site specific basis, e.g. applications on or near environmentally sensitive areas (*NOTE to File:18 AAC 75.990(35) “environmentally sensitive area” means a geographic area that, in the department's determination, is especially sensitive to change or alteration, including (A) an area of unique, scarce, fragile, or vulnerable natural habitat; (B) an area of high natural productivity or essential habitat for living organisms; (C) an area of unique geologic or topographic significance that is susceptible to a discharge; (D) an area needed to protect, maintain, or replenish land or resources, including floodplains, aquifer recharge areas, beaches, and offshore sand deposits; (E) a state or federal critical habitat, refuge, park, wilderness area, or other designated park, refuge, or preserve; and (F) an area that merits special attention as defined at 6 AAC 80.170;). NOTE: 6 AAC 80.170 was repealed see AS 46.40.210(1) "area which merits special attention". The dilution ratio should be identified in a work plan submitted to the department for approval. Monitoring for pentanonic breakdown, as well as contaminants of concern (COCs), should occur. Pentanonic breakdown will be demonstrated through pH monitoring, with a basic pH indicating the presence of the chemical and a neutral pH indicating pentanonic breakdown. COCs should always include Volatile Organic Compounds (VOCs) by SW-846 method 8260B to confirm any short chain petroleum compounds produced through the reaction with pentanonic are below applicable cleanup levels. All other applicable regulations and guidance for the characterization, remediation and/or cleanup of petroleum contaminated sites must be adhered to. Please note that site specific workplans must be submitted and approved by the department prior to implementing cleanup work at contaminated sites or leaking underground storage tank sites. This letter should not be considered an endorsement, nor approval, of the chemical pentanonic or its effectiveness. It may be considered a determination, based on a review of the provided information, that its use under department approved conditions on a site specific basis will not pose an unacceptable risk to human health, safety, or the environment. Thank you for providing requested information on the chemical pentanonic for department review. If you have any questions regarding this letter, please contact me at (907) 269-7545 or john.halverson@alaska.gov. Signed by John Halverson Environmental Program Manager. John Halverson
9/5/2008 Document, Report, or Work plan Review - other Staff provided comments on the Draft Supplemental Characterization Report & Revised Cleanup Plan for SS002 Sterling Landing August 2008. Executive Summary Pages vi & vii-First bullet-The text references diesel range organics exceeding the ADEC cleanup level in the former tank area, however it does not specify which cleanup level is being exceeded. ADEC requests clarification on which cleanup level is being referenced. Also the text goes on to state there are 360 cubic yards of petroleum-impacted soil(s) above the protection of human health level is present in this area. ADEC requests clarification from the Air Force on which level is being referenced since both are protective of human health for the pathway (ingestion or inhalation). ADEC requires the Air Force to use the most stringent cleanup level of the two pathways identified in 18 AAC 75.341 Tables B1 & B2. Second bullet-The text references 750 cubic yards of petroleum-impacted soil are present above the protection of human health cleanup level is present in this area. ADEC requests the Air Force provide clarification as to which soil cleanup level pathways (ingestion or inhalation) are being exceeded. ADEC does not recognize nor regulate cleanups conducted by the Air Force which are based on selection of the remedial alternative with the lowest “carbon footprint”. ADEC requests the Air Force delete reference to this term throughout the document since it is not a statutory requirement for compliance with “Oil & Other Hazardous Substances Pollution Control” regulations Title 18, chapter 75, Article 3 (a.k.a. 18 AAC 75) as amended through July 1, 2008. ADEC requests the Air Force correct references & text to reflect the latest promulgated regulations & citations. 2.0 Site Information/Background Page 2-The text states that groundwater is not currently used as drinking water in the area & is not likely to be used in the future. ADEC requests the following clarifying information be provided in this particular section- The groundwater is not: within the zone of contribution of an active private or public drinking water system; or within a recharge area for a private or public drinking water well, a wellhead protection area, or a sole source aquifer. The groundwater is not a reasonably expected potential future source of drinking water (simply stating it is not likely to be used in the future is not sufficient), based on an evaluation of • the availability of the groundwater as a drinking water source, including depth to groundwater, the storativity & transmissivity of the aquifer, & other relevant information; • actual or potential quality of the groundwater, including organic & inorganic substances, & as affected by background & known or existing areawide contamination; • the existence & enforceability of institutional controls described in 18 AAC 75.375 or municipal ordinances or comprehensive plans that prohibit or limit access to the groundwater for use as drinking water; • land use of the site & neighboring property, using the factors in EPA's Land Use in the CERCLA Remedy Selection Process, adopted by reference in 18 AAC 75.340; • the need for a drinking water source & the availability of an alternative source; & • whether the groundwater is exempt under 40 C.F.R. 146.4, revised as of July 1, 1997, & adopted by reference. The Air Force may have already considered this information & evaluated groundwater use prior to the report, but additional information will help support its statements in this section. 3.2.3 Groundwater Monitoring Page 9-The text states BH16/MW had less than one foot of groundwater in the well & BH24/MW was dry. Monitoring wells MW-02, BH15/MW & BH25/MW, which contained free product, are all located within the former truck stand area, where the highest concentrations of diesel range organics (DRO) in soil have been identified. Due to the presence of free product in three of the wells & the lack of a sufficient water supply in the other two wells, no groundwater samples were collected in September 2007 (BEM, 2007). Depth to Product and Depth to water (ft. bgs) BH/MW02 12.69’ 12.70’ (screened interval 9.70-19.70’) BH15/MW 19.10’ 19.11’ (screened interval 18.00-28.00’) BH25/MW 14.50’ 14.51’ (screened interval 9.00-19.00’) For additional information see site file. Louis Howard
1/12/2009 Document, Report, or Work plan Review - other Staff reviewed & commented on the Final Supplemental Characterization Report & Revised Cleanup Plan for SS002 Sterling Landing December 2008. General Comment Unless there is a reasonable basis as to why sampling should not occur at wells with 0.01 ft. of “product”, ADEC will require all GW wells be sampled unless measurable free product is detected &/or reappears after purging the wells prior to sampling. Free product is defined as greater than a tenth (0.1) of a foot & not 0 .01 ft. or a hundredth of a foot (Table 3.2.3.1). 3.2.4 Supplemental Characterization Analytical Data Evaluation Page11 The text states the lab analytical data package was validated utilizing the SW846 standard methods & a review of the lab’s quality assurance/quality control (QA/QC) protocol to ensure compliance with the standard methods assigned to the project. ADEC requests copies of the lab reports be provided as an appendix to the report or on CD-ROM. According to ADEC’s Technical Memorandum -06-002 (October 2006): The complete analytical lab report(s) shall be included as part of all submittals to ADEC for which environmental samples have been collected, analyzed & reported. The “raw” analytical data, e.g. bench sheets, chromatograms, calibration data, etc., are not required submittals, but ADEC is requesting them be submitted electronically on CD-ROM for the 2007 supplemental characterization work. The text states the analytical results for the 3 duplicate samples (boring locations SS002-SB07, SS002-SB26 & SS002-SB28) are comparable to their corresponding sample’s analytical results, with the exception of the GRO & DRO results for samples from the SS002-SB07 & SS002-SB26 locations (BEM, 2008a). The different concentration of GRO & DRO within the original & duplicate samples for these 2 locations could be attributed to the composition of the soil & the lack of homogenous distribution of the contaminant within the original sample & its duplicate sample. ADEC disagrees. ADEC requests the AF elaborate on how the duplicate samples were collected. For example, were the samples homogenized & split for DRO? Table 5.0.1 Proposed Soil & GW Cleanup Levels Page 15 ADEC notes the October 9, 2008 contaminated site regulations have listed a revised cleanup level for naphthalene at 20 mg/kg. Please revise the table & anywhere else in the document where cleanup level for naphthalene in soil is mentioned. 6.1.1 Treatment Cell Construction Page 17 Per ADEC approval letter (Appendix M), ADEC will require the AF to analyze for the full list of analytes from lab method 8260B & not just BTEX. The contaminants of concern (COCs) shall always include Volatile Organic Compounds (VOCs) by SW-846 method 8260B to confirm any short chain petroleum compounds produced through the reaction with pentanonic are below applicable cleanup levels. Table 6.1.3.1 Proposed Number & Type of Land Farm Biodegradation Monitoring Samples Page 21 Per ADEC approval letter (Appendix M), ADEC will require the AF to analyze for the full list of analytes from lab method 8260B & not just BTEX. The contaminants of concern (COCs) shall always include Volatile Organic Compounds (VOCs) by SW-846 method 8260B to confirm any short chain petroleum compounds produced through the reaction with pentanonic are below applicable cleanup levels. Appendix E BEM QA/AC Report 6.0 Quality Assurance Summary Page QA-11 The text states field duplicates were collected at a rate that exceeds the 10% goal set in the Quality Assurance Project Plan (QAPP). The disparity between the native & duplicate samples was raised to the lab during initial sample result receipt & discussed with the project sampling team. ADEC requests the AF include the field duplicate results in this section or the appendix in which they can be found. Appendix G Field Sampling Plan 3.3.1 Confirmation Soil Samples Page 5 The text states: All confirmation soil samples will be analyzed for GRO by Method AK101, DRO by Method AK102, BTEX by Method 8260B & PAHs by Method 8270C. Please note the ADEC approval letter (Appendix M) for use of pentanonic requires the contaminants of concern (COCs) always include Volatile Organic Compounds (VOCs) by SW-846 method 8260B to confirm any short chain petroleum compounds produced through the reaction with pentanonic are below applicable cleanup levels. 3.3.3. GW Samples Page 6 ADEC requests the AF provide the full list of results (volatile organic compounds) provided by 8260B & not just BTEX. General note: ADEC will require GW wells be sampled unless NAPL thickness is greater than 0.1 ft. in thickness & not 0.01 ft. in thickness as observed in the past. If NAPL is measured between 0.01 ft. & 0.1 ft. in thickness, attempts shall be made to sample after purging the well to ensure that it is not an artifact of the well acting as a sump for “product” to collect versus actual free “product”. Louis Howard
6/15/2009 Update or Other Action Final Site Characterization Report & Revised Cleanup Plan For SS002 Sterling Landing, Tatalina Long Range Radar Station received. Four distinct areas at SS002 have been investigated historically for impacts to soil & GW: Former Tank Area, Former Truck Stand Area, Barge Landing Area, & the Pipeline area. Contaminants of concern (COC) levels at the Pipeline area are below Alaska Department of Environmental Conservation (ADEC) cleanup levels; therefore, the Pipeline is not the focus of cleanup under this plan. In 2006, the USAF contracted BEM Systems, Inc. (BEM) to: conduct cleanup activities; conduct a supplemental characterization to define the lateral & horizontal extent of soil contamination exceeding Method Two Soil Cleanup Levels; & monitor site GW monitoring wells. Supplemental characterization & GW monitoring fieldwork was conducted in 2007. GW monitoring revealed the presence of free product in the 3 monitoring wells at the Former Truck Stand Area &, therefore, no GW samples were collected for analysis. Soil samples were collected at 51 locations around the site during 2 separate sampling events: the initial event, consisting of test pit excavations; &, the subsequent event, consisting of discrete soil borings. Samples were analyzed for diesel range organics (DRO), gasoline range organics (GRO), & Benzene using both an on-site gas chromatograph & offsite lab. Polynuclear aromatic hydrocarbons (PAH) were analyzed using an off-site lab. Analytical data indicated the following: - Presence of DRO in the Former Tank Area between 302 milligrams per kilogram (mg/kg) & 17,310 mg/kg - exceeding ADEC Method Two Soil Cleanup Level for migration to GW (250 mg/kg), ingestion (10,250 mg/kg), & inhalation (12,500 mg/kg). An estimated 1,350 cubic yards of petroleum-impacted soil above ADEC Method Two soil cleanup level for migration to GW cleanup level & an additional 360 cubic yards of petroleum-impacted soil above ADEC Method Two soil cleanup level for ingestion is present in this area. - Presence of DRO in the Former Truck Stand Area between 830 mg/kg & 38,880 mg/kg - exceeding ADEC Method Two soil cleanup level for migration to GW (250 mg/kg), ingestion (10,250 mg/kg), & inhalation (12,500 mg/kg). An estimated 750 cubic yards of petroleum-impacted soil above the ingestion level is present in this area. - One level (1,460 mg/kg) of DRO exceeded ADEC Method Two soil cleanup level for migration to GW in the Barge Landing Area. It is estimated that approximately 12 cubic yards of petroleum-impacted soil above the migration to GW cleanup level is present in this area. The USAF Remedial Action Objective (RAO) for SS002 is: - Reduce DRO, GRO, Benzene & Naphthalene in soil to ADEC Method Two Soil Cleanup levels for ingestion at the Former Tank Area & migration to GW in the Former Truck Stand & Barge Landing Areas to allow for unrestricted land use, - Improve the effectiveness & efficiency of the GW remedy at the Former Truck Stand Area, & - Reduce DRO & GRO in GW to levels that allow for unrestricted use of GW & prevent potential adverse impacts to surface water in the Kuskokwim River. The USAF proposes to implement a Treatment Cell/Land Farm with biochemical augmentation approach, to treat petroleum-impacted soils & monitor natural attenuation for contaminated GW at the site to successfully achieve its RAO. ICs are integral to the selected remedy & will be implemented at the site during the period that GW is undergoing natural attenuation. The USAF, in cooperation with ADNR, & the landowner, will be responsible for IC implementation, monitoring, maintenance, & reporting. The 611th Civil Engineering Squadron/Civil Engineer (CES/CE) is the USAF point of contact for the ICs. The USAF will install & maintain signage, as appropriate, indicating that the land & GW is impacted by petroleum contamination & land use is restricted by ADNR [18 AAC 75.375(b)(1)]. In addition, the ADNR will cooperatively manage & enforce the ICs at the site. The ADNR will place a “reserve use” designation on the property. This designation will alert ADNR land managers to the ICs detailed in this Cleanup Plan (ADEC, 2006). The ICs at SS002 are designed to limit resource use & prevent or control exposure & to protect human health & the environment until the time when contaminant levels meet the cleanup levels defined in 18 AAC 75, required for unrestricted use. The ICs will be designed to: - Restrict the excavation, grading, or disturbing of soil that contains chemicals of concern at levels exceeding the remedial action goals; - Restrict the installation of drinking water wells; & - Restrict the use of untreated GW for any purpose. The boundary of the area subject to the ICs is shown on Figure 6.3.1. Once contaminants in soil & GW decline to the most stringent cleanup levels for unrestricted use, the ICs will be terminated. ADEC will be consulted prior to termination of the ICs. Louis Howard
4/1/2010 Update or Other Action Cleanup Plan Addendum received. 2010 Treatment Cell Confirmation Sampling A final round of confirmation samples will be collected from stockpiled soil in the treatment cell to document contaminant levels prior to breakdown of the treatment cell. A minimum of 20 soil samples will be collected from random locations on a three-dimensional grid established across the stockpile. The soil samples will be analyzed for GRO using ADEC Method AK102, DRO using ADEC Method AK102, and BTEX constituents with naphthalene using SW8260B. The analytical results will be evaluated using a statistically valid approach. The 95% Upper Confidence Limit (UCL) of the mean will be calculated for any analytes with any values exceeding 18 AAC 75, Tables B1and B2 Soil Cleanup Levels for migration to groundwater (ADEC, 2008). The 95% UCL values will be compared to these applicable cleanup levels. Laboratory DQOs/QC is discussed in Section 5.0. Should analytical results be reflective of Method Two Cleanup Levels, the Treatment Cell will be dismantled, and clean site soils will remain in place at the Former Tank Area. Land Spread of Treatment Cell Soils Should 2010 confirmation sampling results continue to not reflect Method Two cleanup levels, soil from the treatment cell will be transported to a temporary 10 mm liner placed over the Former Tank Area excavation area. The treatment cell liner will then be removed, footprint samples will be collected and analyzed for POL constituents to confirm clean soil. Upon confirmation, soil placed on the temporary liner will be land spread in areas determined to have no contamination based on previous site assessments and 2009 field screening. Soil will be land spread with a maximum thickness of 24 inches. Figure 4.0 presents a proposed land spread footprint, based on treatment cell soil volume calculations and areas eligible for soil spreading. Contaminant concentrations within the smear zone (area of soil between seasonal low and seasonal high water tables) and saturated zone are expected to decline over time through natural attenuation processes. USAF will conduct long-term groundwater monitoring to verify contaminant reduction over time. Institutional Controls (ICs) are integral to the selected remedy and will be implemented at the site during the period that groundwater is undergoing natural attenuation. The USAF, in cooperation with Alaska Department of Natural Resources (ADNR), and the landowner, will be responsible for IC implementation, monitoring, maintenance, and reporting. The 611th Civil Engineering Squadron/Civil Engineer (CES/CE) is the USAF point of contact for the ICs. The USAF will install and maintain signage, as appropriate, indicating that the land and groundwater is impacted by petroleum contamination and land use is restricted [18 AAC 75.375(b)(1)]. In addition, the ADNR will cooperatively manage and enforce the ICs at the site. The ADNR will place a “reserve use” designation on the property. This designation will alert ADNR land managers to the ICs detailed in this Cleanup Plan (ADEC, 2008). The ICs at SS002 are designed to limit resource use and prevent or control exposure and to protect human health and the environment until the time when contaminant concentrations meet the cleanup levels defined in 18 AAC 75, required for unrestricted use. The ICs will be designed to (ADEC, 2006): -Restrict the excavation, grading, or disturbing of soil that contains chemicals of concern at concentrations exceeding the remedial action goals; -Restrict the installation of drinking water wells; and -Restrict the use of untreated groundwater for any purpose. Once contaminant concentrations in soil and groundwater decline to the most stringent cleanup levels for unrestricted use, ICs will be terminated. ADEC will be consulted prior to termination of the ICs. Louis Howard
4/20/2010 Document, Report, or Work plan Review - other Staff reviewed and commented on the Air Force's Draft Cleanup Plan Addendum for SS002 Sterling Landing April 2010. 4.1 2010 Treatment Cell Confirmation Sampling Page 6 The text states: “A final round of confirmation samples will be collected from stockpiled soil in the treatment cell to document contaminant levels prior to breakdown of the treatment cell. A minimum of 20 soil samples will be collected from random locations on a three-dimensional grid established across the stockpile. The soil samples will be analyzed for GRO using ADEC Method AK102, DRO using ADEC Method AK102, and BTEX constituents with naphthalene using SW8260B. The analytical results will be evaluated using a statistically valid approach. The 95% Upper Confidence Limit (UCL) of the mean will be calculated for any analytes with any values exceeding 18 AAC 75, Tables B1and B2 Soil Cleanup Levels for migration to groundwater (ADEC, 2008). The 95% UCL values will be compared to these applicable cleanup levels. Laboratory DQOs/QC is discussed in Section 5.0” Method AK 101 is used to analyze for gasoline range organics (GRO), Method AK 102 is for DRO. ADEC requests the text be corrected to reflect proper analytical method for GRO. ADEC will require the use of Method 8270D for analyzing for naphthalene. ADEC also requests a listing of the rest of the PAHS detected by the method be provided. ADEC requests a figure be provided showing the three-dimensional grid established across the stockpile for collection of the twenty samples. The 95% UCL of the mean will include analytes with all values [from all 20 samples] whether or not they exceed Table B1&B2 soil cleanup levels. In accordance with 18 AAC 75.380(c) ADEC will determine final compliance with the (1) applicable soil cleanup levels, based on sampling results from onsite contaminated soil and from contaminated soil moved offsite for treatment or disposal, and based on the maximum concentrations detected, unless ADEC approves an appropriate statistical method, in which case compliance will be based on the mean soil concentration at the 95th percent upper confidence limit; approval of a statistical method will be based on (A) the number and location of samples taken; (B) whether large variations in hazardous substance concentrations relative to the mean concentration exist; and (C) whether a large percentage of concentrations are below the method detection limit. 5.0 Laboratory/DQOs/QC Page 7 ADEC will require compliance with the latest version of the ADEC Technical Memorandum “Environmental Laboratory Data and Quality Assurance Requirements” (March 2009) and completion of the ADEC “Laboratory Data Review Checklist” (January 2010). Both are available on ADEC’s website: http://www.dec.state.ak.us/spar/guidance.htm#csp The technical memorandum summarizes the minimum requirements for both laboratory data packages and QA Summaries (data reduction, verification, evaluation, etc.) that must be included in all reports containing analytical data submitted to the CS program under the 18 AAC 75 and 18 AAC 78 regulations. ADEC has determined that the QA submittals described below are necessary to meet requirements of 18 AAC 75.335 (b) (2) (B) & (G), 75.335 (c) (3) & (4), 75.355 (a), 75.360 (2) and 18 AAC 78.007. All reports submitted to the Department containing analytical laboratory sample results shall contain a completed Laboratory Data Review Checklist and a Quality Assurance (QA) Summary. The QA Summary must be included as a specific text section of the report. Louis Howard
5/28/2010 Cleanup Plan Approved Staf reviewed and approved the Final 2010 Work Plan Addendum for SS002 Sterling Landing Tatalina Long Range Radar Site, Alaska May 2010 The Alaska Department of Environmental Conservation (ADEC) received the above document for review and comment on May 27, 2010. ADEC has reviewed the document, the response to comments and will approve the work plan addendum for SS002 (CS DB Hazard ID 2854). ADEC review and concurrence on this work plan 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 the plan does not relieve responsible persons from the need to comply with other applicable laws and regulations. Louis Howard
6/9/2010 Site Characterization Report Approved Staff reviewed and approved the Draft Remedial Action Report for SS002 Sterling Landing Tatalina Long Range Radar Site, Alaska May 2010 The Alaska Department of Environmental Conservation (ADEC) received the above document for review and comment on May 21, 2010. ADEC has reviewed the document and will approve the remedial action report for SS002 (CS DB Hazard ID 2854). ADEC review and approval of this report 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 approval does not relieve responsible persons from the need to comply with other applicable laws and regulations. Louis Howard
9/30/2010 Update or Other Action Remedial Action Report Final September 2010 received. Supplemental characterization & GW monitoring fieldwork was conducted in 2007 & was previously discussed in the Supplemental Characterization Report & Revised Cleanup Plan for SS002: Sterling Landing. Remediation activities consisting of contaminated soil excavation; floor & sidewall confirmation sampling; treatment of contaminated soils; backfilling excavations; & GW monitoring /sampling were completed between the months of June & September 2009. Analytical data collected in 2007 indicated the following: - Presence of diesel range organics (DRO) in the Former Tank Area at 302 milligrams per kilogram (mg/kg) & 17,310 mg/kg, which exceed ADEC Method Two Soil Cleanup Levels for migration to GW (250 mg/kg), ingestion (10,250 mg/kg), & inhalation (12,500 mg/kg). An estimated 1,350 cubic yards (cy) of petroleum-impacted soil above ADEC Method Two Soil Cleanup Levels for migration to GW & an additional 360 cy of petroleum-impacted soil above ADEC Method Two Soil Cleanup Levels for ingestion was present in this area; - Presence of DRO concentrations in the Former Truck Stand Area at 830 mg/kg & 38,880 mg/kg, which exceed ADEC Method Two Soil Cleanup Levels for migration to GW. An estimated 750 cy of petroleum-impacted soil above the ingestion level was present in this area; & -1,460 mg/kg of DRO exceeded ADEC Method Two Soil Cleanup Levels for migration to GW in the Barge Landing Area. It is estimated that approximately 12 cy of petroleum-impacted soil above the migration to GW cleanup level was present in this area. The USAF selected Remedial Action Objectives (RAO) for SS002 were: - Reduce petroleum concentrations (DRO, gasoline range organics [GRO], Benzene, & Naphthalene) in soil to ADEC Method Two Soil Cleanup Levels for ingestion at the Former Tank Area & migration to GW in the Former Truck Stand & Barge Landing Areas to allow for unrestricted land use; - Improve the effectiveness & efficiency of the GW remedy at the Former Truck Stand Area; & - Reduce concentrations of DRO & GRO in GW to levels that allow for unrestricted use of GW & prevent potential adverse impacts to surface water in the Kuskokwim River. The USAF implemented a Treatment Cell/Land Farm with biochemical augmentation approach to treat petroleum-impacted soils & monitor natural attenuation for contaminated GW at the site to successfully achieve its RAO. In order to achieve these RAOs, the USAF completed the following closure activities at SS002 between the summer of 2007 & the summer of 2009: - Excavation of heavily contaminated soil from the Former Truck Stand Area; - Supplemental soil characterization within the Former Tank Area, Former Truck Stand Area, & Barge Landing Area; - Placement of previously excavated soil to its original location at the Former Tuck Stand Area; - GW monitoring; - Excavated soil with concentrations above ADEC Method Two Soil Cleanup Levels for protection of human health (ingestion/inhalation) at the Former Tank Area; - Excavated soil with concentrations above ADEC Method Two Soil Cleanup Levels for migration to GW at the Former Truck Stand & Barge Landing Areas; Land Farmed impacted soils to reduce DRO, GRO, Benzene, & Naphthalene concentrations to below ADEC Method Two Soil Cleanup Levels for migration to GW; - Collected four rounds of post-treatment confirmation soil samples in 2009; - Implemented long term monitoring of the GW to monitor natural attenuation of GRO, DRO, volatile organic compounds (VOCs), & polynuclear aromatic hydrocarbons (PAHs); - Implemented institutional controls (ICs) at the site; & - Determined additional soil sampling of soils in treatment cell was necessary, which was completed in summer 2010. At the end of the 2009 field season, all contaminate concentrations had been reduced through the biochemical augmentation process. However, DRO concentrations remained above the ADEC Method Two Soil Cleanup Level of 250 mg/kg for migration to GW in nine of the twelve samples & the duplicate sample collected on September 22, 2009. DRO was detected in all samples at concentrations ranging from 110 to 534 mg/kg. A 95% UCL of 395 mg/kg was calculated for the DRO results using the ProUCL software. GRO, VOCs, & PAHs were not detected in any samples at concentrations that exceeded ADEC Method Two Soil Cleanup Levels for migration to GW. This is the last round of sampling collected in 2009. The soil stockpile was left in place & covered with a 10-mm cover for the Winter-Spring of 2009-2010. For additional information see site file. Louis Howard
10/1/2010 Document, Report, or Work plan Review - other Staff reviewed and commented on the Draft Decision Document and Letter Report for SS002 Sterling Landing Tatalina Long Range Radar Site, Alaska August 2010 received on September 28, 2010. Conclusions (applies to both documents) The text states that all ADEC required and approved activities at the Tatalina LRRS Sterling Landing SS002 site has been completed and the Air Force is requesting closure for this site. ADEC will not grant closure for the site until the following conditions are demonstrated to have been met and outlined in the decision document: For sites to be evaluated for closure (Cleanup Complete with ICs), the following conditions must be met unless ADEC makes a determination under 18 AAC 75.325 (d)(I) or 18 AAC 78.270 (b) that the discharge or release does not pose a threat to human health, safety, or welfare, or to the environment. ADEC will also consider other site-specific factors when reviewing a site for closure. The determination that cleanup is complete is subject to a potential future determination that the cleanup or applicable ICs are not protective per 18 AAC 7S.380(d)(2) and 18 AAC 78.276(f)(2). If ADEC makes a determination that conditions at a site are no longer protective of human health, safety or welfare, or of the environment, additional actions will be necessary to meet the requirements of the site cleanup rules. After the above conditions have been demonstrated to have been met, then ADEC will assign the site a "Cleanup Complete-with Institutional Controls" status. For those sites assigned a "Cleanup Complete with Institutional Controls", ICs must be applied where current or potential future exposure to contaminated soil or groundwater does not allow for unrestricted land and groundwater use. If ICs are required, ADEC must validate their effectiveness through periodic reporting by the responsible person or landowner. In addition to showing that the conditions above have been met, ADEC requests the Air Force incorporate the following into the final decision document: Long Term Monitoring section Contaminant concentrations within the smear zone (area of soil between seasonal low and seasonal high water tables) and saturated zone are expected to decline over time through natural attenuation processes. USAF will conduct long-term groundwater monitoring to verify contaminant reduction over time. Long-term monitoring of groundwater will be discontinued once cleanup levels have been met for two years of consecutive sampling for all contaminants of concern for the site. Institutional Controls Institutional Controls (ICs) are integral to the selected remedy and will be implemented at the site during the period that groundwater is undergoing natural attenuation. The USAF, in cooperation with Alaska Department of Natural Resources (ADNR), and the landowner, will be responsible for IC implementation, monitoring, maintenance, and reporting. The 611 th Civil Engineering Squadron/Civil Engineer (CES/CE) is the USAF point of contact for the ICs. The USAF will install and maintain signage, as appropriate, indicatIng that the land and groundwater is impacted by petroleum contamination and land use is restricted [18 AAC 7S.37S(b)(1)]. In addition, the ADNR will cooperatively manage and enforce the rcs at the site. The ADNR will place a "reserve use" designation on the property. This designation will alert ADNR land managers to the ICs detailed in this Cleanup Plan (ADEC, 2008). The ICs at SS002 are designed to limit resource use and prevent or control exposure and to protect human health and the environment until the time when contaminant concentrations meet the cleanup levels defined in 18 AAC 75, required for unrestricted use. The ICs will be designed to: -Restrict the excavation, grading, or disturbing of soil that contains chemicals of concern at concentrations exceeding the remedial action goals; -Restrict the installation of drinking water wells; and -Restrict the use of untreated groundwater for any purpose. Once contaminant concentrations in soil and groundwater decline to the most stringent cleanup levels for unrestricted use ICs will be tenninated. ADEC will be consulted prior to termination of the ICs. Louis Howard
5/3/2011 Update or Other Action Tatalina Long Range Radar Station Final Decision Document for SS002: Sterling Landing received. The chosen remedy for Site SS002 is Institutional Controls (ICs) for groundwater. No further action is warranted for the soil at SS002. The ICs at Site SS002 will be reviewed at least once every five years, to ensure that land use has not changed & ICs remain effective in limiting public access due to the remaining presence of fuel contamination in groundwater. The USAF is committed to implementing, monitoring, maintaining, & enforcing all components of the selected remedy to ensure that it remains protective of human health & the environment. ICs are legal or administrative measures taken to limit human exposure to contaminants by restricting use of the Site SS002 as follows: Restrict the installation of drinking water wells; & Restrict the use of untreated groundwater in order to prevent direct human contact &/or migration of DRO contaminated water. IC management of groundwater conditions will be discontinued once the ADEC cleanup level for the remaining COC of DRO has been met for two consecutive sampling events. ADEC will be consulted prior to termination of the ICs. The selected remedy satisfies the Remedial Action Objectives (RAOs) for the Tatalina LRRS Site SS002. These RAOs are as follows: Prevent human ingestion or direct contact of contaminants in groundwater containing DRO concentrations in excess of ADEC groundwater & surface water cleanup levels of 1.5 mg/L. Comply with applicable federal & state laws & regulations. This signature sheet documents the decision made for petroleum contamination at Tatalina LRRS. By signing this declaration, ADEC concurs that proper implementation of the selected remedy will comply with state environmental laws. This decision will be reviewed & will be modified in the future if information becomes available that indicates the presence of contaminants or exposures that may cause unacceptable risk to human health or the environment. If additional contaminants are discovered, the USAF & ADEC will determine compliance levels for groundwater cleanup actions. The selected remedy satisfies the RAOs for the Tatalina LRRS, Sterling Landing Site SS002. These RAOs are as follows: Prevent human ingestion or direct contact of contaminants in groundwater containing DRO concentrations in excess of ADEC groundwater & surface water cleanup levels of 1.5 mg/L (18 AAC 75.345, Table C). Compliance with applicable federal & state laws & regulations. The chosen remedy for Site SS002 is ICs. ICs are legal or administrative measures taken to limit human exposure to contaminants by restricting use of the site. ICs will be implemented at the site during the period that groundwater is undergoing natural attenuation. The ICs at Site SS002 will be reviewed at least once every five years to ensure that land use has not changed & ICs remain effective in limiting public access due to the remaining presence of fuel contamination in groundwater. The USAF, in cooperation with ADNR, & the landowner, will be responsible for IC implementation, monitoring, maintenance, & reporting. The 611th CES/Civil Engineer is the USAF POC for the ICs. The USAF will install & maintain signage, as appropriate, indicating that the land & groundwater is impacted by petroleum contamination & land use is restricted [18 AAC 75.375(b)(1)]. In addition, the ADNR will cooperatively manage & enforce the ICs at the site. The ADNR will place a “reserve use” designation on the property. This designation will alert ADNR land managers to the ICs detailed in this Decision Document (18 AAC 75 et seq.). The USAF is committed to implementing, monitoring, maintaining, & enforcing all components of the selected remedy to ensure that it remains protective of human health & the environment. For groundwater, the specific ICs are required to comply with state law & implemented by the USAF to restrict access & limit human & ecological exposure to & use of petroleum-contaminated groundwater in Site SS002, & to prevent the disturbance & spread of petroleum contamination include the following: Restrict the installation of drinking water wells; Restrict the use of untreated groundwater in order to prevent direct human contact &/or migration of DRO contaminated water. Document ICs in the Tatalina LRRS General Plan, the 611th IRP & real estate records, & ADNR records as applicable, including information regarding the following: Current land uses & allowed site uses, Geographic boundaries of ICs, & Performance reports detailing site inspections of the ICs & long-term monitoring of groundwater contamination submitted to ADEC at least once every five years. IC management of groundwater conditions will be discontinued once the ADEC cleanup level for the remaining COC of DRO has been met for two consecutive sampling events. ADEC will be consulted prior to termination of the ICs. Louis Howard
5/26/2011 Document, Report, or Work plan Review - other John Halverson had additional comments on the Record of Decision. Requested clarification on the status of the Joint Use Agreement with the State of Alaska for the former fuel facility operated at SS002. Requested clarification regarding the LNAPL in the wells between the Truck Loading Rack and the river. BTEX in wells now require analyses for TAH and TAqH. Table 1: Add footnoot for basis of cleanup levels and include migration to groundwater cleanup level for soil. Add TAH/TAqH and no sheen criteria for groundwater discharging inot the river. Table 2: Method Two is for soils only not groundwater cleanup criteria and add TAH/TAqH, no sheen for groundwater discharging into river. 1.4 Add bullet for 611 CES LUC plan to be documented in USAF Real Property Records. 1.6 Verify whether Air Force implmented the 2007/2008 work plans where ICs would include signs and maintain them, "reserve use" designation setup in ADNR records and monitoring and reporting of ICs. 2.2 Verify whther the Air Force has updated the community on the remedial actions being proposed at SS002. 2.3.7.1 No copy of the final Supplemental Characterization Report and Revised Cleanup Plan for SS002: Sterling Landing and May 2010 Final Work Plan Addendum for Site SS002: Sterling Landing on adminrec.com. Provide the levels of contamination left behind due to jeopardization of integrity of the riverbank. Provide an estimated volume left behind and distance from excavation to river. Verify that Method Two migration to groundwater cleanup level will apply to treated excvated soils now landspread on site. Verify resampling frequency of landspread soils. 2.3.7.2 Clarification requested on why only two monitoring wells are being sampled and whether or not the long term monitoring plan will include replacement of the destroyed monitoring well and the two wells that were dry during the second sampling round. Table 3: Add TAH/TAqH. 2.3.8 Add long term monitoring (LTM) for groundwater and method two migration to groundwater for soil cleanup level. 2.4 Add Subsistence to the listed uses for the river: “Small riverside communities or outposts utilize the river for sport fishing, recreation, and transportation.." Delete reference from text regarding 350 determination on groundwater not being a drinking water source. Groundwater is protected for all use classifications at SS002. More figures needed such as a: Figure with monitoring wells shown needs to be added to this decision document; Figure with Soil excavation and sampling results figure needs to be added to this decision document; and a Landspread soil figure with location of landspreading operation needs to be added to this decision document. John Halverson
7/8/2011 Document, Report, or Work plan Review - other Responses to comments received with draft final version of ROD. 1.1 The following statement has been modified to read “The facility owner was the United States Government. The facility was managed by the United States Air Force (USAF). The statement remains valid: “The USAF operated the fuel facility under a joint use agreement with the State of Alaska for 1.7 acres of land, which is still in effect.” 1.3 Past activities at the Tatalina LRRS have resulted in the release of petroleum into the environment during facility operation. All COPCs at SS0002 are from petroleum releases & due to the petroleum exclusion, 42 USC 9601 (14), Comprehensive Environmental Response & Liability Act (CERCLA), there no CERCLA COPCs at SS002. The State of Alaska cleanup criteria for soil: 18 AAC 75.341, Tables B1 – Migration to Groundwater & B2 – Under 40 Inch Zone, Migration to Groundwater were used for the Former Truck Stand Area & the Barge Landing Area. The State of Alaska cleanup criteria for soil: 18 AAC 75.341, Tables B1 – Under 40 Inch Zone, Inhalation & B2 – Under 40 Inch Zone, Ingestion were used for the Former Tank Farm Area. The State of Alaska cleanup criteria for groundwater: 18 AAC 75.345, Table C was used for the Tatalina LRRS Site SS002. Due to the proximity of Site SS002 to the Kuskokwim River, TAH & TAqH (including a no sheen criteria) have been additionally been identified as COCs (18 AAC 70.020). 1.4 Description of Selected Remedy The chosen remedy for Site SS002 is LTM with ICs for soil & groundwater. The ICs at Site SS002 will be reviewed within a five year period. The ADNR will place a “reserve use” designation for the SS002 property. 1.4.1 Petroleum Contaminated Soil For soil, the specific ICs required to comply with state law & implemented by the USAF to restrict access & limit human & ecological exposure to & use of petroleum-contaminated soil in Site SS002, & to prevent the disturbance & spread of petroleum contamination include the following: ? Implementation of ICs to restrict access to & limit exposure to & use of petroleum contaminated soil at Site SS002, including the following: ? Restricting excavation or disturbance of petroleum-contaminated soil to prevent additional groundwater contamination or placement of petroleum-contaminated soil in environmentally sensitive areas. ? Restricting movement of petroleum-contaminated soil without prior ADEC approval (pursuant to 18 AAC 75.325[i]) ? Inclusion & documentation of ICs in the USAF Real Property Records, Tatalina LRRS General Plan, & 611th IRP Records, including information about the following: ? Current land uses & allowed uses of Site SS002. ? Geographic boundaries of the ICs, as shown in Figure 1-3. ? An inspection of the site & submittal of a Performance Report on ICs to ADEC at least once every five years after implementation of the remedial action, beginning in 2012. ? Submittal of a sampling plan & sampling report to ADEC for approval prior to removal of ICs. When cleanup levels are achieved in soil as shown in Table 1-2, ICs may be terminated with ADEC agreement. ? LTM with ICs of DRO-contaminated groundwater to include: ? Sampling groundwater monitoring wells at Site SS002 annually for volatile organic compounds, polynuclear aromatic hydrocarbons, & DRO, after implementation of the remedial action. The monitoring frequency may be revised after five years by agreement with ADEC. ? Providing a sampling report annually to ADEC with results of the current groundwater sampling event compared to historical results, beginning in 2012. ? Implementation of specific ICs to restrict access & limit exposure to & use of petroleum-contaminated groundwater in Site SS002 & to prevent discharge & spread of petroleum contamination, including the following ICs: ? Limiting excavation or drilling in areas containing petroleum-contaminated groundwater. ? If petroleum-contaminated groundwater is used or removed from the site, characterizing & managing the groundwater by following regulations applicable at the time. ? Obtaining ADEC approval before removing or disposing of petroleum-contaminated groundwater at the site (pursuant to 18 AAC 75.325[i]). ? Inclusion & documentation of ICs in the USAF Real Property Records, Tatalina LRRS General Plan, & 611th IRP Records, including information about the following: ? Current land uses & allowed uses of Site SS002. ? Geographic boundaries of the ICs, as shown in Figure 1-3. ? Inspecting the site & submittal of a Performance Report on ICs to ADEC once every five years after implementation of the remedial action, beginning in 2012. Louis Howard
9/27/2011 CERCLA ROD Approved The Decision Document Installation Restoration Program for non-CERCLA Site SS002: Sterling Landing signed by John Halverson (ADEC). This Decision Document presents the final selected remedy for petroleum contamination in soil & GW at the Sterling Landing (SS002) site associated with the Tatalina LRRS. The selected remedies were chosen in accordance with State of AK regulations (AK Oil & Hazardous Substance Pollution Control Act, Title 18, Chapter 75, of the AK Administrative Code [18 AAC 75, revised October 9, 2008]; 18 AAC 60). All COPCs at SS0002 are from petroleum releases & due to the petroleum exclusion, 42 USC 9601 (14), CERCLA, there no CERCLA COPCs at SS002. COPCs were previously identified in the soil & GW above the State of AK cleanup levels. Petroleum is addressed under AK State law (18 AAC 75 Article Three). The chosen remedy for Site SS002 is LTM with ICs for soil & GW. ICs are legal or administrative measures taken to limit human exposure to contaminants by restricting use of the site. No further excavation is recommended or proposed at this time. The ICs at Site SS002 will be reviewed within a 5 year period & at least once every 5 years thereafter to ensure that land use has not changed & ICs remain effective in limiting public access due to the remaining presence of fuel contamination in soil & GW. The USAF, in cooperation with ADNR, the landowner, will be responsible for IC implementation, monitoring, maintenance, & reporting. The 611th CES/Civil Engineer is the USAF POC for the ICs & is responsible for coordination with ADNR. The USAF will maintain signage, as appropriate, indicating that the land & GW is impacted by petroleum contamination & land use is restricted. In addition, the ADNR will cooperatively manage & enforce the ICs at the site. The ADNR will place a "reserve use" designation for the SS002 property. This designation will alert ADNR land managers to the ICs detailed in this Decision Document (18 AAC 75 et seq.). The USAF is committed to implementing, monitoring, maintaining, & enforcing all components of the selected remedy to ensure that it remains protective of human health & the environment. The ROD documents the decision made for petroleum contamination at SS002 (Sterling Landing). By signing this declaration, ADEC concurs that proper implementation of the selected remedy will comply with state environmental laws. This decision will be reviewed & will be modified in the future if information becomes available that indicates the presence of contaminants or exposures that may cause unacceptable risk to human health or the environment. If additional contaminants are discovered, the USAF & ADEC will determine compliance levels for cleanup actions. Signed by Robyn M. Burk Colonel, USAF, Commander 611th Air Support Group & John Halverson Environmental Program Mgr. Federal Facilities Section, CS Program. Although other chemicals were detected at SS002, DRO, GRO, benzene & naphthalene in soil/GW were retained as the primary risk-driving COCs. Following the completion of remedial activities, DRO, GRO, benzene & naphthalene in soil & GW were screened against State of AK risk-based cleanup levels. DRO, GRO, benzene & naphthalene in the soil & GW at Site SS002 exceeded the cleanup criterion (18 AAC 75.341, Tables Bl & B2; 18 AAC 75.345, Table C). Therefore, action is required under State of AK regulations to protect human health & the environment. The risk for animals was deemed to be low; the only presence of potential contamination is contained underground & within the GW, & thus unlikely to be encountered by animal activities. There is a potential risk for surface water discharge for remaining contamination along the river, which may pose an ecological risk within the river. Subsequent monitoring will be conducted to evaluate any potential risk & to determine compliance with ADEC cleanup standards. The selected remedy satisfies the RAOs for SS002. These RAOs are as follows: • Prevent human exposure to or direct contact with contaminants in soil containing DRO, GRO, benzene & naphthalene levels in excess of ADEC Method Two Migration to GW cleanup levels of (18 AAC 75.341, Tables B1 & B2). • Prevent human ingestion of, or direct contact with, contaminants in GW containing DRO levels in excess of ADEC GW cleanup levels of 1.5 mg/L (18 AAC 75.345, Table C). • Compliance with applicable federal & state laws & regulations. The response action selected in this Decision Document is necessary to protect the public health or welfare &/or the environment from actual or threatened releases of petroleum-based hazardous substances to the environment due to exceedances of risk-based cleanup levels at SS002. After the implementation of LTM & ICs, human health & the environment will be protected from the risks of exposure to DRO, GRO, benzene, & naphthalene contamination at SS002. The RAOs will be met after the selected remedy is implemented. John Halverson
10/5/2011 Institutional Control Record Established Signing of the decision document (ROD) the USAF agrees to institutional controls for the contaminated soil and contaminated groundwater at SS002. Petroleum Contaminated Soil For soil, the specific ICs are required to comply with state law and implemented by the USAF to restrict access and limit human and ecological exposure to and use of petroleum-contaminated soil in Site SS002, and to prevent the disturbance and/or spread of petroleum contamination include the following: - Implementation of ICs to restrict access to and limit exposure to and use of petroleum contaminated soil at Site SS002, including the following: - Restricting excavation or disturbance of petroleum-contaminated soil to prevent additional groundwater contamination or placement of petroleum-contaminated soil in environmentally sensitive areas. - Restricting movement of petroleum-contaminated soil without prior ADEC approval (pursuant to 18 AAC 75.325[i]) - Inclusion and documentation of ICs in the USAF Real Property Records, Tatalina LRRS General Plan, and 611th IRP Records, including information about the following: - Current land uses and allowed uses of Site SS002. - Geographic boundaries of the ICs, as shown in Figure 1-3. - An inspection of the site and submittal of a Performance Report on ICs to ADEC at least once every five years after the date of the signed decision document. - Submittal of a LTM sampling plan and sampling report to ADEC for approval prior to removal of ICs. LTM and IC management of soil conditions will be discontinued once the ADEC cleanup level for the remaining DRO (petroleum) has been met for two consecutive sampling events. ADEC concurrence will be obtained prior to termination of the ICs. Petroleum Contaminated Groundwater The remedy selected for petroleum-contaminated groundwater with concentrations above State of Alaska cleanup levels (18 AAC 75.345, Table C) is LTM and ICs. The major components of the selected remedy for petroleum-contaminated groundwater are as follows: - LTM with ICs to include: - Installation of two additional groundwater monitoring wells near the Kuskokwim River. - Sampling groundwater from all monitoring wells at Site SS002 annually for volatile organic compounds, polynuclear aromatic hydrocarbons, and DRO, after implementation of the remedial action. The monitoring frequency and number of wells sampled may be revised after five years by agreement with ADEC. - Providing a sampling report annually to ADEC with results of the current groundwater sampling event compared to historical results, beginning in 2012. - Implementation of specific ICs to restrict access and limit exposure to and use of petroleum contaminated groundwater in Site SS002 and to prevent discharge and spread of petroleum contamination, including the following ICs: - Limiting excavation or drilling in areas containing petroleum-contaminated groundwater. - If petroleum-contaminated groundwater is used or removed from the site, characterizing and managing the groundwater by following regulations applicable at the time. - Obtaining ADEC approval before removing or disposing of petroleum-contaminated groundwater at the site (pursuant to 18 AAC 75.325[i]). - Inclusion and documentation of ICs in the USAF Real Property Records, Tatalina LRRS General Plan, and 611th IRP Records, including information about the following: - Current land uses and allowed uses of Site SS002. - Geographic boundaries of the ICs, as shown in Figure 1-3. - Inspecting the site and submittal of a Performance Report on ICs to ADEC once every five years after the date of the signed decision document. LTM and IC management of groundwater conditions will be discontinued once the ADEC cleanup levels for the remaining petroleum have been met for two consecutive sampling events. ADEC concurrence will be obtained prior to termination of the LTM and ICs. Louis Howard
7/6/2012 Update or Other Action Draft Work Plan for Environmental Long Term Management of Sterling Landing received. The following work shall be performed: Conduct land survey using a Global Positioning System (GPS) receiver (or equivalent) to identify site boundaries for LF004, SS002, SS003, and SS008. Install two groundwater monitoring wells near the Kuskokwim River to be included within annual LTM program well network for Site SS002; Collect groundwater samples from four existing (BH02/MW, BH16/MW, BH24/MW and BH25/MW) and from the two new proposed groundwater monitoring wells (designated as MW-26 and MW-27), and analyze for DRO, VOCs, and PAH. Annual groundwater monitoring will continue for a minimum of five years, after which the monitoring program may be revised by an agreement between ADEC and the USAF. Groundwater samples will be collected using a peristaltic pump and clean Teflon® tubing, in accordance with ADEC’s Draft Field Sampling Guidance (ADEC 2010a) from each of the six groundwater monitoring wells installed around Site SS002. Prior to sample collection, depth to water and presence of non-aqueous phase liquid (NAPL) will be quantified with the use of a properly inspected, cleaned, and maintained NAPL/water interface meter. Wells that contain NAPL shall not be purged or sampled because of the difficulties involved in handling purge water with product and the increased potential for contamination of sampling equipment. Prior to sample collection, water quality parameters will be measured using a flow-through cell and documented. Purge water and rinse liquids from decontamination procedures will be visually inspected for obvious signs of contamination, and treated through a portable five-gallon granular activated carbon (GAC) filter and discharged on-site. Filtered purge water and rinse liquids will be discharged to the ground surface at least 100 feet from any surface water body, such as the Kuskokwim River. Samples will be analyzed by an ADEC-approved fixed base laboratory for DRO by ADEC Method AK102, target compound list VOCs by EPA Method SW846 8260B, and PAH by EPA Method SW846 8270. The laboratory analytical data package will be validated utilizing the Department of Defense (DoD) Quality Systems Manual for Environmental Laboratories (DoD QSM v4.2), SW846 standard methods and a review of the laboratory’s quality assurance/quality control (QA/QC) protocol to ensure compliance with the standard methods assigned to the project. Additionally, laboratory data will be validated in accordance with current ADEC regulations, including the Technical Memorandum “Environmental Laboratory Data and Quality Assurance Requirements” (March 2009). This technical memorandum summarizes the minimum requirements for both laboratory data packages and QA Summaries (data reduction, verification, evaluation, etc.) and will be utilized during data validation and preparation of the QA Summary, which will be submitted with the Technical Project Report. The QA Summary will be in compliance with 18 AAC 75.335 (b) (2) (B) & (G), 75.335 (c) (3) & (4), 75.355 (a), 75.360 (2) and 18 AAC 78.007. The ADEC “Laboratory Data Review Checklist”, version 2.7 (January 2010) will be completed and submitted for each analytical data package received from the offsite laboratory. A detailed analytical QA Summary and the data package will be submitted with the Technical Project Report Louis Howard
7/10/2012 Document, Report, or Work plan Review - other Staff reviewed and commented on the Air Force's Draft Environmental LTM Plan. Table 2-1 COCs Identified at Site SS002 The actual cleanup level for gasoline range organics (GRO) in soil for the Former Tank Area is 1,400 mg/kg for ingestion not 10,250 mg/kg. The actual cleanup level for diesel range organics (DRO) is 10,250 mg/kg for ingestion not 1,400 mg/kg. The signed decision document and the draft work plan in the tables are incorrect for the cleanup levels of DRO/GRO at the Former Tank Area. The footnote in the draft work plan and text in the decision document are correct. 2011 Decision Document Section 1.3 Page 3: “The State of Alaska cleanup criteria for soil: 18 AAC 75.341, Table B2 - Under 40 Inch Zone, Ingestion were used for the Former Tank Farm Area, based upon previous and current groundwater monitoring in the Former Tank Farm Area indicate there are no groundwater impacts pre- and post excavation.” The maximum allowable cleanup levels shall not be exceeded as defined by 18 AAC 75 Table B2. Method Two and the numbers appear to be reversed in the original decision document. The Air Force was also notified of this error in an electronic email from ADEC dated March 30, 2012 1:38 p.m. Table 3-1 Control Limits for Groundwater Parameters The control limits for water quality parameter-temperature are: ± 3% for temperature (minimum of ± 0.2o C) not 2o C or just 3%. It appears a decimal has been misplaced in the table. A minimum of three (minimum of four if using temperature as an indicator) of these parameters should be monitored and recorded. Low flow purging and sampling are particularly useful for wells that purge dry or take one hour or longer to recover. 3.4 Groundwater Sampling Peristaltic pumps (section D2 of Groundwater Sample Equipment) and bailers (section D1) are not the preferred method for the collection of volatiles (e.g. VOCs) or other air sensitive parameters. Rather the use of bladder pumps (section D3), positive pressure submersible pumps (section D4), gear pumps (section D5), passive diffusion bag samplers (section D6), or samplers like HydraSleeve (section D8) or Snap Samplers (section D9) are preferred to reduce the loss of volatiles during sampling (ADEC Field Sampling Guidance May 2010). Appendix A Qualified Persons Jennifer Diep is not a “qualified person” as defined by 18 AAC 75.990(100). Soon to complete her Bachelor’s Degree from Alaska Pacific University and any relevant experience/work she has conducted while completing her degree does not count towards the required 12-months of environmental science experience AFTER obtaining her degree. She can conduct sampling under direction of other “qualified persons” who will directly supervise her in accordance with 18 AAC 75.990(125). Please remove her name from the list of “qualified persons” in Appendix A. The Air Force shall ensure that the collection, interpretation, and reporting of data, and the required sampling and analysis is conducted or supervised by a qualified, impartial third party. 2.2.2 Well Purging For low-flow sampling the goal is minimum drawdown (<0.1 m) during purging. Temperature and pH, while commonly used as purging indicators, are insensitive in distinguishing between formation water and stagnant casing water; nevertheless, these are important parameters for data interpretation purposes and should also be measured and recorded. Peristaltic pumps have some disadvantages as noted in the ADEC Field Sampling Guidance (May 2010): Disadvantages: • Depth limitation of ~25 feet. • Potential for loss of volatile fraction due to negative pressure gradient. • Unless using an in-line flow through cell for field readings, may not provide reliable or reproducible data for air sensitive parameters e.g. dissolved oxygen, pH, carbon dioxide or iron and its associated forms. The 2008 Supplemental Characterization Report noted that depth to groundwater for BH16/MW was at 37.66’ below ground surface. The screened interval for BH16/MW is from 28.75 to 38.75’ below ground surface. Louis Howard
7/13/2012 Document, Report, or Work plan Review - other Revised work plan approved by ADEC. Louis Howard
1/24/2013 Update or Other Action Staff received a copy of the Environmental Long Term Management at Multiple 611 Civil Engineering Squadron Locations Transmittal of Draft Technical Project Report for Tatalina Long Range Radar Station Contract/Delivery Order FA8903-10-D-8593-0019. Field activities were conducted in accordance with the Final Work Plan dated July 2012. Field activities for Tatalina LRRS sites included: ? Performed a land survey using a Global Positioning System (GPS) receiver (or equivalent) to identify site boundaries for LF004, SS002, SS003, and SS008. ? Installed two groundwater monitoring wells near the Kuskokwim River and included them within the annual LTM program well network for Site SS002; ? Collected groundwater samples from two existing MWs (designated as BH16/MW and BH24/MW) and from two newly installed groundwater MWs (designated as MW-26 and MW-27), all analyzed for DRO, VOCs, and PAH. The land survey for LF004, SS002, SS003, and SS008 was conducted during the period between 6 August and 8 August 2012. On 7 August 2012, two new groundwater MWs (MW-26 and MW-27) were installed along the bank of the Kuskokwim River, at Site SS002. Between 6 August and 8 August 2012, MWs BH16/MW, BH24/MW, MW-26 and MW-27 were sampled, with appropriate quality control samples collected at Site SS002. As described in Section 1 of this Technical Project Report, there were originally four existing MWs planned for sampling. Two of the four existing MWs (BH02/MW and BH25/MW) were not sampled because they were found to be destroyed beyond use. On 9 August 2012, BEM-Bay West notified the 611th CES of the damaged wells at the site however a task order modification for their replacement, could not be issued prior to de-mobilization of the well drilling contractor. which exceeded the ADEC groundwater cleanup level of 5.0 µg/L. Monitoring results also indicated exceedances of the 1,500 µg/L DRO ADEC groundwater cleanup level in groundwater samples collected from all four MWs. DRO concentrations were as follows: 3,200 µg/L at BH16/MW, 1,900 µg/L at BH24/MW, 3,100 µg/L at MW-26, and 29,000 µg/L at MW-27. The Long Term Management activities for SS002 at Tatalina LRRS are complete for 2012, as per the 2011 Decision Document. A Land Survey was completed to identify site boundaries and distinct site features for LF004, SS002, SS003, and SS008. Two groundwater monitoring wells (MW-26 and MW-27) were installed along the Kuskokwim River, to augment the existing monitoring well network at the site. Four groundwater monitoring wells (MW-26, MW-27, BH16/MW and BH24/MW) were sampled and analyzed for VOCs, DRO and PAHs, to monitor SS002 groundwater for petroleum contamination. Photo documentation has also been completed to illustrate current conditions at Site SS002, monitoring well installation activities, and groundwater monitoring activities. Two SS002 monitoring wells (BH02/MW and BH25/MW) were not sampled during the 2012 event because they were found to be destroyed beyond use. Although these two wells were active in the SS002 monitoring well network, with the addition of the two groundwater monitoring wells MW-26 and MW-27, the remaining monitoring well network is sufficient for annual monitoring of the remaining groundwater contamination, and no further well replacement should be required unless future monitoring results indicate such need. Analytical results of the 2012 LTM groundwater sampling effort conducted between 6 August and 8 August 2012 confirmed that PAH concentrations remain below ADEC groundwater cleanup levels, as per 18 AAC 75.345, Table C (AAC 2012). However, analytical results for VOCs indicated that the benzene concentration in groundwater collected from MW-27 (11 µg/L) exceeded the ADEC groundwater cleanup level of 5.0 µg/L. DRO results in groundwater collected from all four monitoring wells exceeded the ADEC groundwater cleanup level of 1,500 µg/L as follows: 3,200 µg/L at BH16/MW, 1,900 µg/L at BH24/MW, 3,100 µg/L at MW-26, and 29,000 µg/L at MW-27. As part of the required Environmental Long Term Management at Tatalina LRRS, petroleumimpacted groundwater will continue to be monitored annually at SS002 for a minimum of five years, or until deemed complete by the USAF and ADEC. As prescribed by the 2011 Decision Document, the Site SS002 ICs are to be reviewed once every five years, to ensure that land use has not changed and ICs remain effective in limiting potential exposure to the remaining fuel contamination in soil and groundwater. An ICs inspection was not included in the 2012 Environmental Long Term Management activities at Tatalina, LRRS. The final ADEC-approved remedial action for SS002 is to continue with land use controls and long term monitoring. However, in the future, should the USAF decide that Site SS002 conditions require more or less stringent control than ICs and LTM, the selected remedy will need to be reevaluated at that time Louis Howard
3/20/2013 Update or Other Action Environmental Long-Term Mgt Technical Project Report received. This Technical Project Report details the implementation of Environmental Long Term Management (LTM) actions for Sites LF004, SS002, SS003, and SS008, Tatalina Long Range Radar Station (LRRS) in Sterling Landing, Alaska. SS002 continues to operate as an active barge landing area. The Takotna Community Association (TCA) currently owns and operates a fuel storage facility approximately 100 feet (ft) west of Site SS002, where fuel and supplies/equipment are delivered periodically by barge for the Takotna community and mining operations. There is no current residential use of the site or surrounding vicinity, and residential use is unlikely in the future. Some local residents from adjacent areas use the land surrounding SS002 for transportation or industrial purposes; this use is likely to continue in the future The SS002 land survey performed 7 August 2012 included the boundary of Site SS002, the outline of Sterling Landing Access Roads at the site, as well as coordinates of the newly installed groundwater monitoring wells (MW-26 and MW-27) near the Kuskokwim River. There were 50 coordinate points collected at SS002. As defined in the 2011 Decision Document, the remedy selected for petroleum-contaminated groundwater with concentrations above State of Alaska cleanup levels, as per 18 Alaska Administrative Code (AAC) 75.345, Table C, is LTM with ICs (AAC 2012). This included the installation of two additional groundwater monitoring wells, and annual sampling of all active monitoring wells at Site SS002 for laboratory analysis of VOCs, DRO and PAHs for a minimum of five years, or until deemed complete by the USAF and ADEC. Environmental LTM activities at Site SS002 included the installation of two new wells, MW-26 and MW-27. These monitoring wells were installed in accordance with the July 2012 Final Tatalina LRRS Work Plan, and the November 2011 Contaminated Sites Program Monitoring Well Guidance Document (ADEC 2011, USAF 2012). On 7 August 2012, MW-26 and MW-27 were installed utilizing Hollow Stem Auger (HSA) drilling techniques, near the Kuskokwim River at Site SS002, Tatalina LRRS. Site SS002 groundwater monitoring yielded a concentration of 11 µg/L benzene at MW-27, which exceeded the ADEC groundwater cleanup level of 5.0 µg/L. Monitoring results also indicated exceedances of the 1,500 µg/L DRO ADEC groundwater cleanup level in groundwater samples collected from all four MWs. DRO concentrations were as follows: 3,200 µg/L at BH16/MW, 1,900 µg/L at BH24/MW, 3,100 µg/L at MW-26, and 29,000 µg/L at MW-27. MW-26 results for TAH and TAqH were found to be below cleanup levels. MW-27 results exceeded TAH (10 ug/L)and TAqH (15 ug/L) cleanup levels with a concentrations of 33.91 µg/L and 54.32 µg/L, respectively. NOTE to file: Methods 624 and 625 are required for closure for anything that comes back with the other methods. 18 AAC 70.020 Water Quality Standards for Designated Uses table, note 7 currently reads: 7. Samples to determine concentrations of total aromatic hydrocarbons (TAH) and total aqueous hydrocarbons (TAqH) must be collected in marine and fresh waters below the surface and away from any observable sheen; concentrations of TAqH must be determined and summed using a combination of: (A) EPA Method 602 (plus xylenes) or EPA Method 624 to quantify monoaromatic hydrocarbons and to measure TAH; and (B) EPA method 610 or EPA Method 625 to quantify polynuclear aromatic hydrocarbons listed in EPA Method 610; use of an alternative method requires department approval; the EPA methods referred to in this note may be found in Appendix A of 40 CFR 136, Appendix A, as revised as of July 1, 2003 and adopted by reference. Photos 1 – 7, and 20 - 35 were taken at SS002. Photo 6 shows the destroyed well BH02/MW, from what was potentially a result of snow plowing during the winter. Photos 20 and 21 are views of the damaged well BH25/MW on the southeast side of the Sterling Landing Access road, which was found to be damaged down hole at approximately 6 feet below grade. Photos 22 – 24 show well BH16/MW location, well cap, and sampling activities. Photos 25 – 27 show well BH24/MW location, well cap, and sampling activities. Photos 28 – 35 are views of the drilling, installation, development and sampling of MW-26 and MW-27 along the bank of the Kuskokwim River at SS002. Louis Howard
9/9/2013 Update or Other Action Draft Work Plan for Environmental Long Term Monitoring received. The primary objectives of the tasks being performed under this Work Plan are to monitor groundwater contamination associated with operations at the Sterling Landing Barge Landing (SS002) and Lower Landfill No. 2 (LF004), and to evaluate the condition of the landfill cover at LF004. In order to achieve these objectives, two replacement monitoring wells will be installed and four existing wells will be sampled at site SS002, two monitoring wells will be installed and one existing well will be sampled at site LF004, and a visual inspection of the landfill cover will be completed at site LF004. Groundwater samples from site SS002 will be analyzed for volatile organic compounds (VOC), polynuclear aromatic hydrocarbons (PAH), and diesel range organics (DRO), and groundwater samples from the LF004 site will be analyzed for pesticides (4,4’-DDD, 4-4’-DDE, and 4,4’-DDT). Groundwater sampling results will be compared to previous sampling results and the 18 Alaska Administrative Code (AAC) 75.345, Table C, groundwater cleanup levels (Alaska Department of Environmental Conservation). Louis Howard
9/10/2013 Document, Report, or Work plan Review - other Staff provided review comments on the draft LTM work plan. 3.5 Groundwater Sampling The text states: "If poor well recharge prohibits the use of a submersible pump, groundwater samples will be collected using a Teflon-lined disposable bailer." Volatile organic analytical results will be noted as estimated and biased low (due to aeration if roundwater is sam led with bailers. 3.7 Investigation-Derived Waste Management The text states: "IDW Soil. Any soil cuttings exhibiting visual or olfactory evidence (i.e., staining and hydrocarbon odor) as well as field screening evidence (PID reading greater than 20 ppm) of contamination will be containerized. The remaining soil cuttings will be used to backfill borings or will be spread on site." IDW soil shall not be spread on site or as backfill for borings until laboratory results show the soil cuttings to be below applicable cleanup levels. Bentonite may be used to backfill borings or clean soil from an uncontaminated area. The PID is not to be used to determine whether or not soil is "clean" or "dirty" at 20 ppm or any arbitrary number. All soil from borings shall be contain erized and await laboratory results prior to reuse. Soil from LF004 shall not be spread on s ite until there is laboratory results below applicable cleanup levels for all contaminants of concern, not just pesticides. In ADEC's experience PID screening results do not necessarily correlate with laboratory analysis. For example, the following PID readings from soil samples obtained from another 611 th site and diesel range organics (DRO) laboratory analyses demonstrates there is a wide variance in readings versus actual results. 3.2.7 Groundwater Parameters Stabilization Groundwater will be considered stable after well development under the following conditions per ADEC Draft Field Sampling Guidance May 2010: Water quality parameters are considered stable when three successive readings, collected 3-5 minutes apart, are within: • ± 3% for temperature (minimum of± 0.2°C), • ± 0.1 for pH, • ± 3% for conductivity, • ± 1 0 mv for redox potential, • ± 10% for dissolved oxygen (DO), and • ± 10% for turbidity. A minimum of three (minimum of four if using temperature as an indicator) of these parameters should be monitored and recorded. Low flow purging and sampling are particularly useful for wells that purge dry or take one hour or longer to recover. If a well is low yield and purged dry, do not collect a sample until it has recharged to aooroximatelv 80% of its pre-oure:e volume, when practical. Louis Howard
9/10/2013 Document, Report, or Work plan Review - other Staff provided review comments on the draft LTM work plan. 3.5 Groundwater Sampling The text states: "If poor well recharge prohibits the use of a submersible pump, groundwater samples will be collected using a Teflon-lined disposable bailer." Volatile organic analytical results will be noted as estimated and biased low (due to aeration if roundwater is sam led with bailers. 3.7 Investigation-Derived Waste Management The text states: "IDW Soil. Any soil cuttings exhibiting visual or olfactory evidence (i.e., staining and hydrocarbon odor) as well as field screening evidence (PID reading greater than 20 ppm) of contamination will be containerized. The remaining soil cuttings will be used to backfill borings or will be spread on site." IDW soil shall not be spread on site or as backfill for borings until laboratory results show the soil cuttings to be below applicable cleanup levels. Bentonite may be used to backfill borings or clean soil from an uncontaminated area. The PID is not to be used to determine whether or not soil is "clean" or "dirty" at 20 ppm or any arbitrary number. All soil from borings shall be contain erized and await laboratory results prior to reuse. Soil from LF004 shall not be spread on s ite until there is laboratory results below applicable cleanup levels for all contaminants of concern, not just pesticides. In ADEC's experience PID screening results do not necessarily correlate with laboratory analysis. For example, the following PID readings from soil samples obtained from another 611 th site and diesel range organics (DRO) laboratory analyses demonstrates there is a wide variance in readings versus actual results. 3.2.7 Groundwater Parameters Stabilization Groundwater will be considered stable after well development under the following conditions per ADEC Draft Field Sampling Guidance May 2010: Water quality parameters are considered stable when three successive readings, collected 3-5 minutes apart, are within: • ± 3% for temperature (minimum of± 0.2°C), • ± 0.1 for pH, • ± 3% for conductivity, • ± 1 0 mv for redox potential, • ± 10% for dissolved oxygen (DO), and • ± 10% for turbidity. A minimum of three (minimum of four if using temperature as an indicator) of these parameters should be monitored and recorded. Low flow purging and sampling are particularly useful for wells that purge dry or take one hour or longer to recover. If a well is low yield and purged dry, do not collect a sample until it has recharged to aooroximatelv 80% of its pre-oure:e volume, when practical. Louis Howard
11/14/2014 Update or Other Action Draft LTM Tatalina LRRS SS002/LF004 report received for review & comment. SS002 DRO levels exceeded the ADEC cleanup level (1,500 µg/L) in four of the six wells in June 2014. • BH16/MW – within the former Tank Area berm: The DRO result in 2014 was 1,930 µg/L. This result was less than the 2012 detection, but was within the range of concentrations observed at the site since 1997. • BH24/MW – downgradient of the former Tank Area berm, between the berm & the Kuskokwim River: The 2014 DRO concentration (729 µg/L) was less than the cleanup level. This is the third time in four sampling events that the DRO concentration has been less than the cleanup level. • MW-26 – between the former Truck Stand & Barge Landing areas along the bank of the Kuskokwim River: The 2014 DRO concentration (1,640 µg/L) was approximately half of the 2012 result, but still exceeded the cleanup level. (NOTE To File: Benzene was found to exceed the cleanup level for the 1st time in this well. TAH/TAqH exceedances were also observed for the 1st time in MW-26.) • MW-27 – downgradient of the Former Truck Stand area along the bank of the Kuskokwim River: The 2014 DRO concentration (3,820 µg/L) was an order of magnitude less than the 2012 result; however the concentration still exceeded the cleanup level. • MW-28 (replacement well for BH/MW02) – north of the Barge Landing Road along the bank of the Kuskokwim River: The 2014 DRO concentration (2,020 µg/L) in this replacement well exceeded the cleanup level & was the highest concentration observed in this location. This was the second consecutive exceedance & third exceedance in six sampling event in this location. • MW-29 (replacement well for BH25/MW) – near the former Truck Stand area along the bank of the Kuskokwim River: The 2014 DRO concentration measured in this well (976 µg/L) was below the cleanup level & was the lowest concentration measured at this location. Benzene was detected above the cleanup level in one well (MW-26) during 2014. • MW-27: Benzene exceeded the cleanup level in this well during 2012, but was below the ADEC Cleanup Level (5 µg/L) at a concentration of 2 µg/L in 2014. This is the second time this well was sampled, & the first time benzene was observed below the cleanup level. • MW-26: Benzene exceeded the cleanup level in 2014 at the highest concentration observed in any of the wells (62.2 µg/L). This is the second time this well was sampled, & the first time an exceedance was observed. The only well where TAH & TAqH exceedances were observed in 2014 was MW-26. In general, the TAH & TAqH levels are highly influenced by BTEX concentrations as the PAH levels were mostly non-detect. The summation of the Limits of Detection (LOD) was used to determine the TAH & TAqH in accordance with ADEC Guidance (ADEC, 2012b). (NOTE to file: exceedances are exceedances, regardless of whether based on elevated VOCs or elevated PAHs for Water Quality Criteria). • MW-27: The TAH & TAqH levels were below the AWQS in 2014. This well has been sampled two times, & TAH & TAqH exceedances were observed in 2012. • MW-26: The TAH & TAqH levels exceeded the AWQS in this well due to the high benzene concentration observed in 2014. PAHs were generally not detected in the sample from this well. This is the second time the well has been sampled & the first time TAH & TAqH exceedances have been observed. Based on the results of the June 2014 field activities, the following actions are recommended to maintain compliance with the Decision Document: • Continue annual long term GW monitoring at the six existing monitoring wells to comply with Decision Document requirements. o The next sampling event should be conducted in summer 2015. o Evaluate exceedances of the ADEC cleanup level & AWQS for benzene & TAH/TAqH respectively, & continued effectiveness of the selected remedy. o Annual GW monitoring may be discontinued following two consecutive sample events with results below ADEC cleanup levels. o If contaminant concentrations remain above ADEC cleanup levels after five years, the sampling frequency may be revised upon agreement between the Air Force & ADEC. • Conduct an inspection of the site & complete a Performance Report on soil & GW Institutional Controls (IC) in 2015 or 2016 to maintain compliance with Decision Document requirements (evaluation of ICs at least once every five years). • Consider redevelopment of MW-26 & MW-27 to reduce turbidity & evaluate the impact on contaminant concentrations in GW samples. Louis Howard
3/18/2015 Update or Other Action 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 & 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, & that is not an application site, injection well, reserve pit, or waste pile.” This definition applies to most PRSC ERP & non-ERP sites in Alaska designated as landfills, dumps, or caches. Small PRSC ERP & 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 & included in Table 2-2. However, alternative criteria can & 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 & to potential future landowners, are summarized in Table 2-3. Tables 2-2 & 2-3 both generally assume the subject landfill is closed, has been reasonably well characterized, & a monitoring program for media of concern has been established & 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 & Upper Landfill No. 1 LF010 Tatalina LRRS Former WACS Facility OT012 Tatalina LRRS Minimally Attended Radar Site SS001 Tatalina LRRS Barge Landing & 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 controls include: Soil - Implementation of ICs to restrict access to & limit exposure to & use of petroleum contaminated soil at Site SS002, including the following: 1) Restricting excavation or disturbance of petroleum-contaminated soil to prevent additional GW contamination or placement of petroleum-contaminated soil in environmentally sensitive areas. 2) Restricting movement of petroleum-contaminated soil without prior ADEC approval (pursuant to 18 AAC 75.325[i]) - Inclusion & documentation of ICs in the USAF Real Property Records, Tatalina LRRS General Plan, & 611th IRP Records. - An inspection of the site & submittal of a Performance Report on ICs to ADEC at least once every five years after the date of the signed decision document. - Submittal of a sampling plan & sampling report to ADEC for approval prior to removal of ICs. GW - Implementation of specific ICs to restrict access & limit exposure to & use of petroleum contaminated GW in Site SS002 & to prevent discharge & spread of petroleum contamination, including the following ICs: 1) Limiting excavation or drilling in areas containing petroleum-contaminated GW. 2) If petroleum-contaminated GW is used or removed from the site, characterizing & managing the GW by following regulations applicable at the time. 3) Obtaining ADEC approval before removing or disposing of petroleum-contaminated GW at the site (pursuant to 18 AAC 75.325[i]). - Inclusion & documentation of ICs in the USAF Real Property Records, Tatalina LRRS General Plan, & 611th IRP Records. - Inspecting the site & submittal of a Performance Report on ICs to ADEC once every five years after the date of the signed decision document. Louis Howard
5/13/2015 Document, Report, or Work plan Review - other ADEC will approve the final work plan and has no further comments on it. ADEC’s review and comment on this work plan 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 comments on the work plan does not relieve responsible persons from the need to comply with other applicable laws and regulations. The Air Force is responsible for the actions of contractors, agents, or other persons who perform work to implement the approved work plan. For any activity that significantly deviates from the approved plan, the Air Force shall notify the ADEC and obtain written approval in the form of a work plan amendment before beginning the activity Louis Howard
1/5/2016 Update or Other Action Report for Environmental Long Term Monitoring at Tatalina Long-Range Radar Station Sites received for review and comment. SS002 The IC inspection at Site SS002 noted that the area is accessed frequently for both recreational and travel purposes by McGrath/Takotna residents, and for industrial purposes including fuel delivery. Area restriction signs were found on-site. No evidence of unauthorized actives was observed that could result in exposure to contaminated materials. Results of the groundwater monitoring conducted at Site SS002 indicated the presence of DRO at concentrations exceeding the ADEC Cleanup Level at monitoring wells MW-27 and MW-29. VOCs and PAHs were not detected or were detected at concentrations below ADEC Cleanup Levels at all locations sampled at Site SS002. In 2014, the groundwater sample from MW-26 had calculated TAH and TAqH results exceeding the cleanup criteria. The 2014 LTM results indicated that the PAH concentrations were mostly non-detect with no exceedances, but that BTEX compounds were the cause of the TAH and TAqH calculated exceedances. This was also the case in 2012 for the groundwater sample collected from MW-27 (USAF 2015a). Based on the PAH results over the last three monitoring events, it is recommended that sampling for PAH be discontinued, and that DRO and VOCs continue to be monitored at this Site until applicable ADEC cleanup levels and ROD objectives have been met. Louis Howard
2/4/2016 Document, Report, or Work plan Review - other Staff provided comments on the draft report for environmental long-term monitoring at several sites which includes this one. After reviewing the information presented, it appears the institutional controls at LF004, SS002, SS003, SS008, and SS011 are working as designed. See site file for additional information. Additional comments were made regarding flagging groundwater results for BH24/MW since low volume of water was recovered with a bailer instead of a pneumatic bladder pump. Staff requested the ROD requirement for comparing current groundwater sample results to historic groundwater results be part of the report and future reports/work plans. See site file for additional information., Louis Howard
9/16/2016 Update or Other Action Draft RA Operations, LU/ICs Supplemental work plan received for review and comment. Minor amendments are specified for each first occurrence and are considered applicable throughout the Work Plan and appendices. ? The Contractor anticipates commencing field work and sampling associated with the 2016 LTM at the Tatalina AFS in September 2016. ? The Contractor will continue to use qualified environmental professionals to conduct or directly supervise all field activities at Tatalina AFS for the 2016 LTM, in accordance with 18 Alaska Administrative Code (AAC) 75.333 (b). The current ADEC Qualified Environmental Professionals form and resumes are presented in Attachment 2. ? The Contractor will perform a statistical evaluation of the wells at Site SS002 and estimate a date that cleanup levels are achieved. ? All reports will be submitted to the USACE project manager (PM) and the U.S. Air Force (USAF) point of contact (POC) for review. The Contractor will revise the pre-draft report as necessary based on all review comments received and submit draft final reports within 15 days of receipt of review comments. The draft final and final reports will be submitted both electronically (in native file and PDF formats) and as hard copies (five copies required). All electronic deliverables shall be compliant with the requirements set forth in the Manual for Electronic Deliverables, USACE, 2011. ? The Contractor will utilize TestAmerica Sacramento as a primary laboratory and Accutest San Jose as a backup laboratory for analysis of the groundwater samples associated with the 2016 LTM. Both are off-site, ADEC-approved, Environmental Laboratory Accreditation Program (ELAP)-accredited fixed-base laboratories, located in West Sacramento, California and San Jose, California, respectively. Current ELAP and ADEC certificates and approved analytical parameter and method lists are presented as Attachment 3 and Attachment 4, respectively. See site file for additional information. Louis Howard
9/23/2016 Document, Report, or Work plan Review - other Staff reviewed and approved the draft supplemental work plan addendum for SS002, LF004, SS008, and SS011. Louis Howard
2/14/2017 Update or Other Action LTM Report (draft) received for review and comment for sites SS002, SS003, LF004, SS008 & SS011. The analytical results of the 2016 LTM GW sampling effort conducted 12 & 13 October are presented in Table 2-2. The VOC analysis of GW reported 19 µg/L for benzene at MW-27 & 5.2 µg/L for naphthalene at MW-29, which exceeds the ADEC Table C GW Cleanup Level of 4.6 µg/L & 1.7 µg/L, respectively. The PAH analysis of GW at SS002 reported 7.9 µg/L for naphthalene at MW-29, which exceeds the ADEC Table C GW Cleanup Level of 1.7 µg/L. Monitoring results also indicated concentrations of DRO in GW samples collected from four of the six MWs exceeded the ADEC Table C GW Cleanup Level of 1,500 µg/L. DRO concentrations were as follows: 1,700 µg/L at BH16/MW, 2,100 µg/L at MW-26, 14,000 µg/L at MW-27, & 2,900 µg/L at MW-29. TAH & TAqH were reported for MW-26, MW-27, MW-28, & MW-29, due to their proximity to the Kuskokwim River surface water. Results for all four wells exceeded TAH & TAqH Water Quality Standards (10 µg/L & 15 µg/L, respectively) with concentrations ranging from 28.0 µg/L to 43.0 µg/L for TAH & 28.4 µg/L to 52.3 µg/L for TAqH (18 AAC 70). As part of the required Environmental LTM at Tatalina LRRS, petroleum-impacted GW will continue to be monitored annually at SS002 for a minimum of 5 years, or until deemed complete by the USAF & ADEC. As prescribed by the 2011 Decision Document, the Site SS002 ICs are to be reviewed once every 5 years, to ensure that land use has not changed & ICs remain effective in limiting potential exposure to the remaining fuel contamination in soil & GW. An IC inspection was conducted on 12 & 13 October 2016. Photos were taken for each site to visually document the current status of the ICs, as observed during the annual inspection event. Two new LUC notification signs were installed at each of the five sites. The ICs appeared to be functioning as intended to protect human receptors from exposure to contaminated soil & GW. At this time, no additional actions are necessary to improve &/or correct ICs at these sites. Continued LTM inspections are recommended to confirm ICs remain protective of human health & well-being of the environment. The final ADEC-approved remedial action is to continue with LUCs and LTM. However, in the future, should the USAF decide that site conditions require more or less stringent control than ICs and LTM, the selected remedy would need to be reevaluated at that time See site file for additional information. Louis Howard
3/10/2017 Document, Report, or Work plan Review - other Staff reviewed and approved the Draft Summary Report for SS002, SS008, LF004, SS002, SS003, and SS011 at Tatalina LRRS dated February 2017. Minor comment about including the hazard IDs from the CS database for each site in the report. Louis Howard
8/14/2017 Update or Other Action Draft 2017 Supplemental Work Plan W911KB-14-D-0007-0008 Remedial Action Operations, Land Use/Institutional Control received for review and comment. Collect and analyze groundwater samples from monitoring wells BH16/MW, BH24/MW, MW-26, MW-27, MW-28 and MW-29 for diesel-range organics (DRO), polycyclic aromatic hydrocarbons (PAHs), and volatile organic compounds (VOCs). Sampling will be conducted and reported in accordance with the 2012 Work Plan (Appendix A). Field activities will be documented using the forms provided in Appendix F. Perform statistical evaluation of the wells and estimate a date that cleanup levels are achieved. Conduct and document a visual inspection of ICs as specified LF004 in Section 1.2.1. See site file for additional information. Louis Howard
4/24/2018 CERCLA ROD Periodic Review Staff approved the First Five-Year Review Report for SS002, SS003, SS008, SS011 and LF004 at Tatalina LRRS. See site file for additional information. Louis Howard
2/12/2019 Document, Report, or Work plan Review - other Staff approved the draft project report and requested future sampling of groundwater for volatile organic compounds (VOCs) not use a peristaltic pump or bailer which would bias the results low. Louis Howard
1/13/2020 Document, Report, or Work plan Review - other Staff approved the draft project report for long term monitoring activities. See site file for additional information. 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
5/3/2021 Document, Report, or Work plan Review - other Staff provided comments on the Draft 2021 Remedial Action-Operation and Long-Term Management Work Plan, Tatalina Long Range Radar Station, Sites LF004, SS002, SS003, SS008, and SS011, March 2021. The Work Plan described the approach and procedures for site-specific long-term management and remedial action-operation activities at Tatalina long-range radar site, including annual groundwater sampling for sites SS002 and SS008. The Work Plan covers work being performed over a 5-year period and will be reviewed on an annual basis between field seasons. Axl LeVan
6/22/2021 Document, Report, or Work plan Review - other DEC provided comments for the Draft 2020 Remedial Action-Operation, Institutional Control/Land Use Control Report, Tatalina Long Range Radar Station, Alaska, Sites LF004, SS002, SS003, SS008, and SS011, March 2011. The Alaska Department of Environmental Conservation Contaminated Sites Program received a copy of the above referenced document on May 24, 2021. The report presents the results and recommendations of the 2020 Environmental Long-Term Management (LTM) program at the Tatalina Long Range Radar Station (LRRS). The 2020 LTM activities included annual visual inspection of site intuitional controls/land use controls at Sites SS002, SS003, LF004, SS008, and SS011. Annual groundwater sampling also took place at Site SS002 and Site SS008. All efforts took place in August of 2020. Axl LeVan
9/8/2021 Document, Report, or Work plan Review - other DEC approved the Final 2020 Remedial Action-Operation, Institutional Control/Land Use Control Report, Tatalina Long Range Radar Station, Alaska, Sites LF004, SS002, SS003, SS008, and SS011, September 2021. The Alaska Department of Environmental Conservation Contaminated Sites Program received a copy of the above referenced document on September 7, 2021. The report presents the results and recommendations of the 2020 Environmental Long-Term Management (LTM) program at the Tatalina Long Range Radar Station (LRRS). The 2020 LTM activities included annual visual inspection of site intuitional controls/land use controls at Sites SS002, SS003, LF004, SS008, and SS011. Annual groundwater sampling also took place at Site SS002 and Site SS008. All efforts took place in August of 2020. Axl LeVan
7/26/2022 Document, Report, or Work plan Review - other The Alaska Department of Environmental Conservation (DEC) Contaminated Sites Program received a copy of Draft-Final 2021 Remedial Action-Operation and Long-Term Management Report, Tatalina LRRS Sites LF004, SS002, SS003, SS008, and SS011, Alaska, June 2022 on June 30, 2022. This report presents the long-term management and remedial action-operation (RA-O) activities performed at sites LF004, SS002, SS003, SS008, and SS011 at Tatalina long range radar site (LRRS) between 13 September and 15 September 2021. Axl LeVan
8/24/2022 Document, Report, or Work plan Review - other The Alaska Department of Environmental Conservation (DEC) Contaminated Sites Program received and approved a copy of Final 2021 Remedial Action-Operation and Long-Term Management Report, Tatalina LRRS Sites LF004, SS002, SS003, SS008, and SS011, Alaska, August 2022 on August 23, 2022. This report presents the long-term management and remedial action-operation (RA-O) activities performed at sites LF004, SS002, SS003, SS008, and SS011 at Tatalina long range radar site (LRRS) between 13 September and 15 September 2021. All DEC comments were addressed and appropriate changes were integrated into the document. In the approval letter DEC noted that landfill ponding, an unidentified well at SS003, and riverside erosion near SS002 should be closely monitored moving forward. Axl LeVan
8/17/2023 Document, Report, or Work plan Review - other DEC approved the Final 2022 Five-Year Review for Sites LF004, SS002, SS003, SS008, and SS011 at Tatalina Long Range Radar Station, Alaska, June 2023. The Five-Year review describes the progress since the last Five-Year Review and documents issues and recommendations for the five sites. Axl LeVan
8/22/2023 Document, Report, or Work plan Review - other DEC provided comments on the "Draft-Final 2022 Remedial Action-Operation and Long-Term Management Report, Tatalina LRRS". The report presents the long-term management and remedial action-operation (RA-O) activities performed at sites LF004, SS002, SS003, SS008, and SS011 between 11 August and 13 August 2022. Axl LeVan
1/18/2024 Document, Report, or Work plan Review - other DEC reviewed and approved the "Final 2022 Remedial Action-Operation and Long-Term Management Report, Tatalina LRRS Sites LF004, SS002, SS003, SS008, and SS011, Alaska, January 2024". The report presents the long-term management and remedial action operation (RA-O) activities performed at sites LF004, SS002, SS003, SS008, and SS011 at Tatalina Long Range Radar Site (LRRS) between 11 August and 13 August 2022. Axl LeVan

Contaminant Information

Name Level Description Media Comments
DRO > Human Health/Ingestion/Inhalation Soil
GRO Between Method 2 Migration to Groundwater and Human Health/Ingestion/Inhalation Soil
Benzene Between Method 2 Migration to Groundwater and Human Health/Ingestion/Inhalation Soil
Naphthalene Between Method 2 Migration to Groundwater and Human Health/Ingestion/Inhalation Soil
DRO > Table C Groundwater

Control Type

Type Details
Notice of Environmental Contamination The ADNR will cooperatively manage and enforce the ICs at the site. The ADNR will place a “reserve use” designation for the SS002 property.
Land Use Plan / Maps / Base Master Plan Inclusion and documentation of ICs in the USAF Real Property Records, Tatalina LRRS General Plan, and 611th IRP Records.

Requirements

Description Details
Excavation / Soil Movement Restrictions Restricting movement of petroleum-contaminated soil (PCS) w/o prior ADEC approval (pursuant to 18 AAC 75.325[i]). Restricting excavation or disturbance of PCS to prevent additional GW contamination or placement of PCS in environmentally sensitive areas.
Groundwater Monitoring Installation of 2 GW monitoring wells near the Kuskokwim R. Sampling all GW monitoring wells annually for VOCs, PAHs, & DRO for a minimum of 5 yrs. The monitoring frequency may be revised after 5 yrs by agreement between the AF & ADEC.
Advance approval required to transport soil or groundwater off-site. Obtaining ADEC approval before removing or disposing of petroleum-contaminated groundwater at the site (pursuant to 18 AAC 75.325[i]).
New Construction Restrictions If petroleum-contaminated groundwater is used or removed from the site, characterizing and managing the groundwater by following regulations applicable at the time.

There are no documents for this site report.

No associated sites were found.

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