| Action Date |
Action |
Description |
DEC Staff |
| 12/15/1980 |
Update or Other Action |
The Department of Defense (DOD) initiated the IRP in 1976 to identify, investigate, and
mitigate environmental hazardous waste contamination that may be present at DOD facilities. In June 1980, the DOD issued Defense Environmental Quality Program Policy Memorandum (DEQPPM) 80-6, requiring identification of past hazardous waste disposal site at DOD agency installations. The USAF implemented DEQPPM 80-6 in December 1980. The USAF IRP is designed to identify, confirm/quantify, and remedy problems associated with past and present management of hazardous substances and hazardous wastes at USAF facilities. It is the basis for assessment and response action on USAF installations, under provisions of the CERCLA.
The DOD developed the IRP to meet the objectives of CERCLA and uses CERCLA methodology and terminology to ensure suitable cleanups are achieved at DOD sites. The Tatalina LRRS is not listed on the National Priorities List (NPL) under CERCLA; however, the DOD uses the IRP, under the Defense Environmental Restoration Program, as CERCLA and the National Contingency Plan (NCP) would be used to identify potentially contaminated sites, investigate these sites, and evaluate and select remedial actions for potentially contaminated facilities. |
Louis Howard |
| 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 |
| 7/31/1985 |
Update or Other Action |
1985 IRP Phase I Records Search.An IRP Phase I records search was completed for the Tatalina LRRS as part of a project to conduct record searches at several Alaska Air Command installations throughout Alaska. Site visits were conducted during this project, but no environmental sampling was completed. Site observations and a discussion of the fuel system in operation at the installation at the time of the records search are included in the report. General information on the environmental setting of the Tatalina LRRS area also is presented.
The Phase I records search established 24 initial POIs based on identified previous activities
suspected of potential contamination to the area. On the basis of a score calculated according to the Hazard Assessment Rating Methodology (HARM) for each POI and observations made during a site visit, seven of the POIs were determined to require no further action and were dismissed form further consideration in the report. The remaining 17 POIs were combined into 12 IRP sites.
The Phase I report identified 11 of the 12 IRP sites as potential sites of contamination: four
spill/leak areas, four former dump sites or WAAs, the active landfill/WAA,; and The Lower
Camp road because of past road oiling. The WACS site was determined to have minimal
potential for environmental contamination and was excluded from further discussion in the
report.
Site/POI 3, WIMS-ES: SS-003, Alias: Source 3, Site Type: IRP, Description: Spill/Leak Nos. 1-4, Material Disposed of: Fuel Spills, Date of Operation: 1952 - present (1985), Regulatory Mechanism: IRP, Note 1: No further action per concurrence of EPA, Region 10, to Installation Restoration Program Technical Document for Record of Decision (USAF 1988a). |
Louis Howard |
| 11/14/1986 |
Update or Other Action |
CERCLA outlines the responsibility for identifying and remediating contaminated sites in
the United States and its possessions. The 1986 Superfund Amendments and Reauthorization Act (SARA) extends the requirements of CERCLA and modifies CERCLA with respect to goals for remediation and the steps that lead to the selection of a remedial process. Under SARA, technologies that provide permanent removal or destruction of a contaminant are preferable to action that only contains or isolates the contaminant.
SARA also provides for greater interaction with public and state agencies and extends the role of the U.S. Environmental Protection Agency (EPA) in evaluating health risks associated with contamination. Under SARA, early determination of ARARs is required, and the consideration of potential remediation alternatives is recommended at the initiation of an RI and a feasibility study (FS). SARA is the primary legislation governing remedial action at past hazardous waste disposal sites.
In November 1986, in response to SARA and other EPA interim gmdance, the USAF modffied the IRP to provide for an RI/FS program. The IRP was modified so that RI/FS studies could be conducted as parallel actwities rather than serial activities. The program now includes ARARs determinations, identification and screening of technologies, and development of alternatives. The IRP may include multiple field activities and pilot studies before a detailed final analysis of alternatives. Over the years, requirements of the IRP have been developed and modified to ensure that DOD compliance with federal laws, such as the Resource Conservation and Recovery Act (RCRA), NCP, CERCLA, and SARA, can be met. |
Louis Howard |
| 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 (SS003) and 9 are spill/leak sites, sites 5, 7, 8, and 10 are previously used dumpsites or waste accumulation areas, site 6 is an area of Lower Camp road oiling, and sites 4 and 11 are the active landfill and waste accumulation area, respectively.
Spill/Leak Nos. 1, 2, 3, and 4 - Lower Camp is referred to as site 3 (SS003). This is the site of 4 POL storage tanks in the Lower Camp area. Spill volumes range from 500-1000 gallons of POL products, none of which have been recovered. Spill records indicate in 1980, a 1,000 gallon spill occurred at Tank 3; in 1981 and 1982, approximately 500 gallons each were spilled near Tank 4; and in the 1970's several hundred gallons of diesel spilled from a storage tank and drained to the vicinity of the POL bulk storage tanks. The soil in vegetated areas downslope of site 3 smelled of gasoline and diesel. However, there was no evidence of vegetative stress further downslope. Again, the survey team did not observe any signs of contamination in the vicinity of the tank. There were no records of either a spill from Tank 2 or a MOGAS spill in the area.
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 |
| 4/9/1992 |
Update or Other Action |
EPA Memorandum April 9, 1992 Reply to the ATTN of ES-098. Subject Toxicity of Fuels. From Carol Sweeney, Toxicologist Health and Environmental Assessment Section. To Wayne Pierre Federal Facilities Superfuend Branch (HW-124). A response has been provided to the frequently-asked question of whether a reference dose or other toxicity information can be provided for fuel mixtures so that these mixtures can be addressed quantitatively in Superfund risk assessments. The memo from ECAO Cincinnati is attached (last attachment). They have developed reference doses for gasoline, JP-5/kerosene, and JP-4, and a cancer potency factor for gasoline. The memo emphasizes that these are provisional numbers and that considerable uncertainty is involved in this quantitative assessment, because of data limitations, and because inhalation studies were used to calculate oral reference doses.
I typed up a summary table showing the numbers (first attachment) and calculated some risk-based concentrations (second attachment). On the risk-based concentration table, I also
included ordnance compounds, because I hadn't made a table of those before that I can remember. The risk-based concentrations were calculated the same way as table II-1 and II-2 of the Region
10 Supplemental guidance; for soil, the same limitations apply, that the numbers presented do not consider pathways other than soil ingestion.
Toxicity Reference Vaules for Fuel Mixtures EPA Region 10 4/9/1992 Non-cancer effects-Gasoline (unleaded) RfD (mg/kg-day) Oral: 2.0E-1, Uncertainty Factor-Oral:1000, Level of Confidence-Oral: Low. Toxicity Data Source-Oral RfD: Memo 3/92. Carcinogenicity-Cancer Potency/(mg/kg/day): Oral 1.7E-3, Unit Risk (/ug/m3) 4.8E-7, Cancer Weight Of Evidence-C, Toxicity Data Source-Oral SF and Inhal. SF: Memo 3/1992.
Kerosene/JP-5 RfD2.0E-2, UF Oral: 10,000, LOC Oral: low, TDS Oral RfD: Memo 3/92
JP-4 RfD 8.0E-2, UF Oral: 10,000, LOC Oral: low, TDS Oral RfD: memo 3/92.
Screening Values for Water RBCs based on Ingestion, Residential
Gasoline-Risk = 10-6 (ug/L) 50, 10-4=5000 HI=1 (ug/L) 7000
JP-5 Kerosene Risk 10-6 10-4=NA HI = 1 (ug/L) 700
JP-4 Risk 10-6 10-4 = NA, HI = 1 (ug/L) = 3,000
Screening Values for Soils- RBCs Based on Soil Ingestion Residential
Gasoline-Risk = 10-6 (mg/kg) 400, 10-4 (mg/kg) 40,000, HQ = 1 (mg/kg) 50,000
JP-5 Kerosene Risk 10-6 10-4 NA, HQ =1 5,000
JP-4 Risk 10-6 10-4 NA, HQ = 20,000
USEPA Office of Research and Development, Environmental Criteria and Assessment Office Cincinnati, OH Subj: Oral Reference Doses and Oral Slope Factors for JP-4, JP-5; similar to Kerosene (CAS no. 8008-20-6), Diesel Fuel (CAS No. 68334-30-5), and Gasoline (CAS No. 8006-61-9) (AVGAS) [McChord AFB (Wash Rack/Treatment)/Tacoma, WA]. From Joan S. Dollarhide Associate Director, Superfund Health Risk Techncial Support Center, Chemical Mixtures Assessment Branch TO Carol Sweeney USEPA Region X.
This memorandum is in response to your request for oral systemic and carcinogenic toxicity values for JP-4, JP-5, diesel fuel, and gasoline (AVGAS) found to contaminate soil and
groundwater at McChord AFB (Wash Rack/Treatment), Tacoma, WA. We have attempted to derive RfDs and slope factors for the above fuel mixtures. We have derived provisional RfDs for
gasoline, JP-4, JP-5 and diesel fuel; provisional cancer weight-of-evidence classifications of C for gasoline and D for JP-4, JP- 5 and diesel fuel; and a provisional slope factor (adapted from an interim Agency value) for gasoline
Based on the available evidence, unleaded gasoline can be assigned to U.S. EPA (1986) weight-of-evidence Group C: possible human carcinogen. An earlier U.S. EPA document assigned unleaded
gasoline to Group B2 as a probable human carcinogen (u.s. EPA, 1987a), but that document predates the U.S. EPA (1991d) conclusion that the male rat kidney tumors produced by gasoline
are not predictive for humans, and therefore should not contribute to the weight-of-evidence or dose-response assessment of carcinogenicity. IARC concluded that marine diesel fuel is possibly carcinogenic to humans (Group 2B), but light diesel fuels and jet fuels are not classifiable as to their carcinogenicity in humans (Group 3). |
Jennifer Roberts |
| 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 |
| 3/28/1995 |
Update or Other Action |
Management Action Plan (draft dated Febraruy 1995, received March 28, 1995, no final received). |
Ray Burger |
| 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. |
Gretchen Pikul |
| 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 |
| 2/10/1998 |
Update or Other Action |
Draft Remedial Investigation received. The RI objective at this site was to determine the extent of contamination from past fuel releases at the POL tanks & determine impacts to downgradient soil, GW, & surface water. RI sampling focused on the area downgradient of the POL tanks.
Analytical results (BH1/MW, BH12/MW, & BH20/MW and shallow surface samples THSL38A1 & THSL39A1)
GRO - n.d. to 3,500 mg/kg;
DRO - n.d. to 38,000 mg/kg.
Total BTEX - 0.00036 to 2,600 mg/kg.
The highest GRO, DRO, & BTEX levels were detected in surface samples (THS138A1 & THSL39A1) collected near BHI2/MW, in the area where the stained sorbents were observed below grade in the new road cut. BTEX levels reported were primarily xylenes. Petroleum contamination in subsurface soils generally decreased with increasing distance from the POL tanks.
Analytical results (BHI/MW, BH12/MW, & BH20/MW): GRO, DRO, benzene & BTEX levels detected in GW decreased with increasing distance from the POL Tank Farm. GRO in BH1/MW (nearest the POL tanks) was found at: 7,200 ug/L & 2,200 ug/L in BH12/MW & 1,900 ug/L in BH20/MW. DRO levels was found at 5,355ug/L in BH1/MW, 1,530 ug/L in BH20/MW. Total BTEX was found at 1,460 ug/L in BH1/MW, 146 ug/L in BH20/MW. Benzene was detected at 335 ug/L in BH1/MW & 51 ug/L in BH20/MW.
Analytical results from the sediment & seep sample (THSD07A1/THSW08A1), collected in the creek bottom approximately 270’ beyond BH20/MW, included VOCs & SVOCs at very low levels were below human health & ecological risk-based levels developed in the baseline risk assessments. RI data indicate the GW at the point of discharge in the drainage is not contaminated at levels that pose a risk to receptors.
The presence of GW contamination underneath the SS-003 source area confirms infiltration of petroleum occurred beneath the POL Tanks within the bermed area from fuel releases prior to installation of the liner in 1983. Surface migration of contaminants from past surface releases has also occurred, as indicated by field & lab analytical results & site observations during the 1997 field work. Shallow surface drainage channels were observed that extended southeast from the POL Tank Farm pad toward the creek.
A portion of those channels was obliterated when the access roadway to BH12/MW & BH20/MW was constructed during the RI field activities. It appeared that the site had undergone considerable grading when the old septic system was installed in 1952, as evidenced by the fill slopes beyond BH20/MW. Further modifications to grade likely occurred around the time of one of the diesel spills at the POL Tank Farm, as indicated by the buried oily sorbents observed in the roadcut. Regrowth of vegetation from previous site grading has been vigorous & the source area downgradient from the POL tanks is densely vegetated.
On the basis of RI results, petroleum from surface fuel releases have migrated vertically through subsurface soil to GW beneath the POL tank area & horizontally primarily through surface & shallow subsurface soils in a downgradient direction along the natural drainage channel. GW contamination near the POL tanks exceeds human health risk levels for benzene (5 ug/L) & proposed ADEC cleanup standards in draft 18 AAC 75 regs for DRO, GRO, & benzene; however, levels decrease & do not exceed risk levels or proposed cleanup standards at the point of discharge into the creek drainage. This creek drainage is 350’ downgradient of BW-20.
Sediment & surface water samples THSD07A1 & THSW08A1 were collected from this creek drainage point & are considered representative of GW discharge as surface water at that location. GW is not currently used as a drinking water source or for any other use in this part of Lower Camp, thereby reducing potential exposure. Reported releases occurred over 15 years ago; in addition, the removal of the majority of the fuel tanks at the source area decreases the potential for future contamination at this site.
The full vertical & horizontal extent of petroleum contamination at the POL storage tank locations within the bermed areas was not determined during the 1997 RI. To delineate the existing contamination at the POL tank source area & quantify the amount of affected surface and subsurface soils, additional investigation of soil & GW at the former & current POL tanks is recommended. Sampling should be conducted within the bermed areas & the area immediately surrounding the berms.
Information regarding existing contamination at the POL tanks obtained during the investigation should be combined with follow-up investigation of downgradient soil, GW, surface water, & sediment to determine if the levels of contaminants documented during the 1997 RI continue to decrease. Sampling should be scheduled during periods when GW levels are expected to be highest during the year, to increase the likelihood of sufficient GW in the wells. |
Gretchen Pikul |
| 3/31/1998 |
Document, Report, or Work plan Review - other |
The Department of Environmental Conservation (DEC), DoD Oversight group, received the Draft Remedial Investigation Report (dated February 1998) on February 10, 1998. The Draft Remedial Investigation Report includes a Baseline Risk Assessment, a Human Health Risk Assessment, and Ecological Risk Assessment. We appreciate the extended review deadline of March 31, 1998. We have completed our review of Draft Remedial Investigation Report and provided comments below. Please note, the Draft Risk Assessment sections are currently under review. A separate comment letter will be forwarded shortly.
The Department files include the draft Sampling and Analysis Plan (SAP) (dated August 1996), the draft Quality Program Plan (QPP) – Addendum for Interim Remedial Actions (dated November 1996), and the final Remedial Investigation / Feasibility Study (RI/FS) Workplan (dated June 1997). During a site meeting on January 13, 1998, DEC received a final copy of the workplan. Requests were made by the DEC on January 13 and February 13, 1998 to obtain final copies of the SAP and the QPP documents; no final copies have been forwarded. Therefore, any DEC comments regarding the SAP are based on the draft SAP, and may not be indicative of final decisions incorporated into the final SAP. With that clarified, any deviations from the SAP need to be clearly stated, with the rationale for the changes recorded in Section 8.0 (RI Results and Recommendations) and other appropriate sections.
POL Tank Farm (SS-003): It is stated that the decrease in groundwater contamination with distance from the POL tanks indicates that levels of contaminants from historic releases are naturally attenuating in the area and should continue to attenuate with time. This statement should be reworded or deleted. Decrease in contaminant levels downgradient from historical releases can not be directly related to natural attenuation without fate and transport evaluation parameters to validate the conclusion. |
Gretchen Pikul |
| 6/2/1998 |
Site Visit |
ADEC participated in a facility-wide site visit. |
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. The objectives of the RI were to determine the nature and extent of historic fuel releases
downgradient from the POL storage tank pad, confirm the absence or presence of groundwater, and if present, define the nature of groundwater contamination and flow characteristics.
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 Farm. 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 in BH1/MW and decreased to 51 ug/L in BH20/MW.
On the basis of RI results, petroleum hydrocarbons from surface fuel releases have migrated vertically through subsurface soil to groundwater beneath the POL tank area and horizontally primarily through surface and shallow subsurface soils in a downgradient direction along the natural drainage channel. Groundwater contamination near the POL tanks exceeds human health risk levels for benzene (5 ug/L) and proposed ADEC cleanup standards in draft 18 AAC 75 regulations for DRO, GRO, and benzene; however, levels decrease and do not exceed risk levels or proposed cleanup standards at the point of discharge into the creek drainage. This creek drainage is 350 feet downgradient of BW-20, as shown in Figures 8.5-1 and 8.5-2. Sediment and surface water samples THSD07A1 and THSW08A1 were collected from this creek drainage point and are considered representative of groundwater discharge as surface water at that location.
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. Benzene concentrations in surface soil and in groundwater at the three groundwater monitoring wells installed at this source area during the RI exceeded the ADEC risk management standard for human health. Four fuel-related chemicals detected in surface soil within a new roadcut near one of the monitoring wells were determined to be COECs in the ecological risk assessment for that limited area: 2-methylnaphthalene, benzene, DRO, and xylenes. |
Gretchen Pikul |
| 10/14/1999 |
Site Ranked Using the AHRM |
Initial ranking. |
Gretchen Pikul |
| 12/21/1999 |
Update or Other Action |
Final Post-Closure Report, ADEC UST Number 769-1 through 6,Tatalina LRRS, Alaska (dated, December 20, 1999, prepared by Montgomery Watson) |
Gretchen Pikul |
| 8/10/2000 |
Meeting or Teleconference Held |
Public meeting in Takotna, and site visit to Sterling Landing. |
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, and site visits to all sites with new 611th project manager. |
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 |
Meeting or Teleconference Held |
Air Force field visit and work (including land surveys for institutional controls required by Decision Documents) delayed until mid-September due to in-house crew work conflicts (August 9, 2001); delayed to October due to September 11th terrorist attacks (September 17, 2001); was cancelled for this field season due to bad weather and impassable road conditions (October 10, 2001); field work is scheduled for FY02. ADEC received final Clean Sweep Environmental Survey Report (dated September 2001). |
Gretchen Pikul |
| 10/19/2001 |
Meeting or Teleconference Held |
ADEC particpated in a community meeting in Takotna with Air Force. |
Gretchen Pikul |
| 1/29/2002 |
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 |
| 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. 8.6 SS-003, Former POL Tank Farm: The field activities are acceptable for an interim investigation (based on the limited funding for 2002 and in-house samplers) and will provide useful site information, however, please note that the extent of the contamination will not be delineated with these three monitoring wells, and further investigation will be necessary prior to appropriate remedial action selection and/or site closure.
The amount of soil samples, and the depth of soil sample collection and selection for analytical testing needs to be detailed. |
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 |
Document, Report, or Work plan Review - other |
ADEC and Air Force meeting on 2002 field work and work plan; draft work plan dated April 2002 and received on April 19, 2002; comment resolution meeting on April 30, 2002; 2nd draft work plan received May 9 and 10, 2002; 3rd draft received May 28, 2002; 4th draft received on and comment resolution meeting on June 4, 2002; ADEC approval letter dated June 11, 2002. |
Gretchen Pikul |
| 12/9/2002 |
Update or Other Action |
Draft Annual Report received.
Work accomplished at Tatalina in 2002 took place at seven sites. By category, these projects consisted of:
-Remediation of an area strewn with drums, & cleaning & sampling them as necessary at LF 10, Waste Accumulation Area # 2.
-Drilling & installing Monitor Wells (SS-08, Waste Accumulation Area # 4; SS-03, Former POL Tank Farm; & Sterling Landing, SS-002).
-Collecting soil &/or water samples for analysis (SS-02, Sterling Landing; SS-08, Waste Accumulation Area # 4; Lower Camp drum staging area, SS-03, Former POL Tank Farm; SS-011, Hardfill # 1).
-Investigating sites reported in a community meeting where transformers were reportedly buried. Trenches were excavated in an attempt to locate the transformers.
-Investigating & collecting soil &/or water samples at areas of concern which include: the MEK debris field north of upper camp, the lower camp tram building foundation area, & areas under the deactivated tram cables.
SS-003, Former POL Tank Farm
SS-003 is next to the existing Lower Camp buildings & near the southeastern portion of the Lower Camp (Figure 8). This area was used for aboveground storage & dispensing of diesel & automobile gasoline fuel. In 1997, the USAF removed 3 of the 4 diesel fuel tanks & two automobile gasoline tanks that were no longer in use.
The 1998 RI Report shows that petroleum hydrocarbons are present in the soil & GW immediately downgradient of the POL tanks. Benzene in GW from 3 monitoring wells installed during the RI ranged from 51 ug/l to 335 ug/l. Benzene in surface soil were found up to 3,500 mg/kg.
These benzene levels in both soil & water exceed the ADEC risk-management standard to human health.
Petroleum hydrocarbon levels in surface soil in the area downgradient of the tanks included diesel-range organics up to 38,000 mg/kg, which also exceeds the ADEC recommended cleanup levels. These concentrations were shown to decrease rapidly downward in subsurface soils.
See site file for additional information. |
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.
8.6 SS-003, Former POL Tank Farm: It is stated that petroleum hydrocarbons are present in the soil and groundwater immediately downgradient of the POL tanks. However, the 1997 sample locations are approximately 300, 450, and >600 feet downgradient of the POL tanks, and the 1997 RI report recommended delineating the extent of contamination within the bermed area and the surrounding area. Please revise this statement accordingly.
The benzene concentration of 3,500 mg/kg is not recorded in the 1997 RI report, but there is a soil sample with 3,500 mg/kg of GRO; please address. There are redundant statements regarding groundwater concentration levels within the bottom of page 16 and top of page 17.
It is stated that the groundwater approximately 1,000 feet downgradient of the tank farm had contaminant concentrations below detection limits. Based on the 1997 RI report this statement is incorrect; the most downgradient monitoring well installed and sampled in 1997 is BH20/MW which had DRO, GRO, and benzene concentrations exceeding the groundwater cleanup levels. Please make this correction within this section and the Conclusions and Recommendations section on page 31.
The last paragraph states that further monitoring well installation and additional groundwater monitoring is recommended as a next step. Based on all the available site data, SS-003 has contaminated soil above cleanup levels and an extensive petroleum contaminant plume. A Feasibility Study to evaluate remedial alternatives, followed by a Record of Decision may be more appropriate next steps. A geologic cross-section and extensive subsurface conditions evaluation should be a part of the Feasibility Study, and placement of additional monitoring wells could be better gleaned from this evaluation.
Figure 8 is not in color, therefore the levels noted as exceeding cleanup levels is unclear. Please provide the figure in color or use different symbols so that black and white photocopies can be made and used. In addition, Figure 8 has the benzene level for BH\MW-02-24 labeled as 0.0141 mg/L whereas the analytical data sheets and Table 2.0 have benzene listed as 0.0210 mg/L.
pg. 18-23) Table 1.9:
-There are several blank cells within this table for samples and equipment blanks that have been laboratory analyzed; either ‘NA’ for not analyzed, ‘U’ for undetected, or the analyte concentration should be reported.
-The boring log for BH/MW02-1 notes that the sample collected at 20-22’ was submitted for laboratory analyses, the analytical data sheets have laboratory analyses on this sample, Table 1.9 should have the 4 detections listed above the PQL, and Appendix B table only has the sample listed for PID/FID; please address.
-There is an ‘x’ within the analyte column for BH02-1, 25-27’; please address.
-The rationale for not submitting samples from BH02-9, 40-42’ or 45-47’ is unclear; please clarify.
-The benzene concentration within the analytes column under BH02-9, 55-57’ and BH02-23, 60-62’ should be in bold type.
-Include the rationale for not submitting soil samples on BH02-19, 5-7’, 10-12’, and 20-22’ for laboratory analyses.
-The 1,2,4-trimethylbenzene concentration within the analytes column under BH02-20, 5-7’ should be in bold type.
-Naphthalene is spelled incorrectly.
-Include the rationale for not submitting a soil sample from BH02-20, 10-12’ with a PID reading of 431 and a FID reading of 3,678.
-The methylene chloride concentration within the analytes column under BH02-21, 62.5-64.5’ and BH02-22, 5-7’should be in bold type.
-Based on the analytical data sheets sample 52063028166 has a benzene level of 0.0212 mg/kg whereas 0.212 mg/kg is listed on this table; please address.
-Sample 52063028167 has 10.0 µg/kg benzo(k)fluoranthene and 7.00 µg/kg benzo(g,h,i)perylene listed on the analytical data sheets which differs from this table; please address.
|
Gretchen Pikul |
| 5/2/2003 |
Update or Other Action |
Follow-On RI received. In 2002, 12 shallow borings were drilled inside the bermed POL Tank Farm
area and into the berms to assess potential impacts of past spills on soil on top of the liner. One additional boring and five monitoring wells (BH/MW02-8, BH/MW02-9, BH/MW02-21, BH/MW02-23, and BH/MW02-24) were installed downgradient of the POL Tank Farm to assess potential hydrocarbon migration.
The 2002 RI follow-on report confirmed conclusions made as part of the 1997 RI. Shallow soil concentrations within the bermed areas contained the greatest PHC concentrations and soil located a short distance downgradient of the POL Tank Farm contained moderate concentrations. However, the migration pathway appears to have been near the ground surface rather than through vertical infiltration followed by horizontal migration along the groundwater interface as stated in the 1997 RI. |
Gretchen Pikul |
| 5/27/2003 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (ADEC), DoD Oversight group, received the Draft Follow-on Remedial Investigation at SS03, SS08, and SS011Work Plan (dated April 2003) on April 9, 2003, and the Air Force response to comments on May 27, 2003; the ADEC comment letter was sent on May 1 , 2003. Based on our review of the draft document and the Air Force response to comments, ADEC concurs with the work plan, and therefore approves this document based on the incorporation of these responses, as stated, within the final document.
The Air Force is responsible for the actions of contractors, agents, or other persons who perform work to accomplish 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. Any action taken by the Air Force, or an agent of the Air Force, that increases the project’s overall scope or that negates, alters, or minimizes the intent or effectiveness of any stipulation contained in this plan will be deemed a significant deviation from the approved plan. The final determination as to the significance of any deviation and the need for a permit amendment is the responsibility of the ADEC. Therefore, it is recommended that the ADEC be consulted immediately when a deviation from the approved plan is being considered.
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 this document does not relieve responsible persons from the need to comply with other applicable laws and
regulations. |
Gretchen Pikul |
| 5/29/2003 |
Document, Report, or Work plan Review - other |
Follow-on Remedial Investigation at SS03, SS08, and SS11 Work Plan; draft dated April 2003 and received on April 9, 2003; ADEC comment letter dated May 2, 2003; Air Force Comment Response received on May 27 and ADEC approval letter dated May 27, 2003; final received May 29, 2003. |
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 |
| 9/25/2003 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (ADEC), DoD Oversight group, received the Remedial Action and Monitoring Program, Final Report (dated April 2003) on May 2, 2003. The Draft Annual Report, Remedial Action and Monitoring Program (dated November 2002) was received on December 9, 2002; the ADEC comment letter is dated February 5, 2003. The Air Force Comment Response was received on February 19, 2003, the ADEC reviewed the Comment Response and suggested a comment resolution meeting; the comment resolution meeting was held on March 17, 2003.
The draft final report was received on April 3, 2003 via e-mail; ADEC conducted a cursory review and forwarded an e-mail on April 16, 2003 with comments that had not been revised as stated in the Comment Response. Numerous conversations, e-mails, and letters took place from the initial draft report to September 2003. The following are revisions, which were stated in the Comment Response to be made in this final report, have not been made. Based on the incorporation of these revisions below within the final report, the ADEC concurs with the contents of this document.
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.
1. ADEC Comment #1 - Appendix D (Water Sampling Forms) and F (Soil Boring Logs) are unreadable; please insert a readable copy within the final report. Please note that electronic forms of Appendices C – H are not included within the final CD which are necessary when updating the Administrative Record CD.
2. ADEC Comment #8 –
Table 1.3 presents Sample # 52063028103 with an incorrect analytical result for cadmium at 27.8 mg/kg instead of 0.432 mg/kg.
Table 1.4 groundwater cleanup level is shown as 0.002 µg/L when the correct level is 0.002 mg/L.
Table 1.7 barium result for the stream sample has an ORNL screening level of 4 µg/L. The groundwater cleanup level for 1,1 Dichloromethane is 0.007 mg/L.
Table 1.9 does not have results presented for Sample # 52063028056.
Table 1.9 presents an incorrect cleanup level (Tech Memo 01-007) for Sample #s 52063028144 and 153 of 1,2,4-trimethylbenzene at 92.2 mg/kg for the inhalation pathway instead of 1 mg/kg for the inhalation pathway; the sample result for Sample # 52063028144 should be bold since the cleanup level has been exceeded.
Table 1.9 does not include a cleanup level for chloroform under Sample # 52063028070.
Table 1.9 provides a soil cleanup level for comparison to the liquid equipment blank Sample # 52063028190.
Table 2.1 has incorrect surface water standards and benchmark criteria for arsenic, barium, chromium, lead, mercury, and 4,4’-DDT. Also the word ‘soil’ in the footnotes should be corrected to ‘sediment.’
|
Gretchen Pikul |
| 10/29/2003 |
Document, Report, or Work plan Review - other |
Follow-on Remedial Investigation at SS03, SS08, and SS11 (draft dated October 2003 and received on October 21; ADEC comment letter dated October 29, 2003). |
Gretchen Pikul |
| 11/4/2003 |
Document, Report, or Work plan Review - other |
2002 Annual Report, Remedial Action and Monitoring Program; draft dated November 2002 and received December 9, 2002; ADEC comment letter dated February 5, 2003; Air Force response to comments received on February 19 and ADEC response sent on February 21; comment resolution meeting on March 17, 2003; draft final received on April 3, 2003; ADEC commented via e-mail on April 16, 2003; final dated April 2003 and received May 2, 2003; ADEC conditional approval letter dated September 25, 2003; final report received October 27, 2003 and CD on November 4, 2003. |
Gretchen Pikul |
| 8/9/2004 |
Update or Other Action |
Follow-on Remedial Investigation at SS03, SS08, and SS11 work plan - draft dated June 2004; ADEC received on June 14; ADEC comment letter dated June 16; Air Force Comment Response received on July 6, comment resolution teleconference and ADEC approval letter sent same day. On August 9, 2004, ADEC received 2 calls for field decisions by Air Force contractor. |
Gretchen Pikul |
| 10/21/2004 |
Update or Other Action |
2003 Follow-on RI received. Five surface soil samples were collected from within the POL Tank Farm bermed area to further characterize the contaminant source. Groundwater samples were collected from the eight existing monitoring wells. Monitoring data collected during the 2003 RI supported findings of the previous investigations that contaminated soil in the POL Tank Farm was a continuing source of contamination of groundwater downgradient of the tank farm. The Follow-on RI Report recommended continued monitoring in 2004, along with removing the secondary containment berms, foundations of the former POL Tank Farm impoundments, and associated liner material to fully characterize the site. |
Gretchen Pikul |
| 3/25/2005 |
Update or Other Action |
2004 Follow-on RI received. Based on the recommendations of the 2003 Follow-on RI, monitoring
activities during the 2004 Follow-on RI (USAF, 2005) included removing the liner material from
Tank Pit 1 and Tank Pit 2/3. Soil samples were collected from 10 test pits to evaluate
contaminant source and migration. Two test pits were excavated in Tank Pit 1, three in Tank Pit
2/3, four in areas immediately adjacent to and topographically downgradient of the tank pits, and one upgradient of the tank pits. Groundwater samples were collected from seven of the eight
existing monitoring wells. MW02-8 was dry; therefore, a sample could not be collected.
Monitoring data collected during the 2004 Follow-on RI indicated the presence of POL contaminants in soil immediately below the tank pits and in an area downgradient of Tank Pit 1.
No soil contamination was present immediately upgradient of the POL Tank Farm. Groundwater
located downgradient from the POL Tank Farm contained POL contamination. The RI concluded that the soil and groundwater contamination at SS003 is attributed to historical spills at the POL Tank Farm. |
Jeff Norberg |
| 7/18/2005 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (ADEC), Federal Facilities Oversight group, received the Draft Report - Follow-on Remedial Investigation at SS-003, SS-008, and SS-011 (dated March 2005) on March 25, 2005 and the Air Force Comment Response on July 18, 2005; the ADEC comment letter is dated May 20, 2005. Based on the inclusion of the Air Force Comment Responses within the final report, ADEC concurs with the contents of the document.
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. |
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 Remedial Investigation at SS03, SS08, and SS11; draft report dated March 2005 received on March 25; ADEC comment letter dated May 20; Air Force Comment Response and ADEC approval letter dated July 18; final dated August 2005 received August 31.
Soil-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 (Table 3-1 and Figure 3-2). 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 (Table 3-1 and Figure 3-2). 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-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.
Conclusions:Soil sample results indicate the presence of POL above ADEC Tables B1 and B2 cleanup levels in the soil beneath both of the tank pits, and in an area immediately adjacent to and
topographically downgradient Tank Pit 1. Groundwater at SS03 contains POL above ADEC Table C cleanup levels along the drainage topographically downgradient of the tank pits.
Soil and groundwater contamination is attributed to historical spills at the site. Removal of the liner from Tank Pit 1 and Tank Pit 2/3 will effectively alleviate the ponding of surface water in the tank pits. |
Jeff Norberg |
| 2/1/2006 |
Update or Other Action |
File number issued 2655.38.012. |
Aggie Blandford |
| 9/18/2007 |
Update or Other Action |
Workplan (WP) approval requirements & quality assurance oversight on Performance Based Contracts (PBCs) letter from John Halverson (ADEC) to Scott Hansen (611 CES). ADEC is writing to remind you of contaminated site WP approval requirements in AK’s oil & hazardous substance pollution control regulations & UST regulations. Additionally, ADEC is concerned over quality assurance on PBCs.
WP Approval-Several 611 CES environmental restoration projects were implemented this summer without obtaining prior WP approval from DEC. The site cleanup rules require ADEC approval on WPs before beginning interim removal actions (18 AAC 75.330), site characterization work (18 AAC 75.355), or cleanup operations (18 AAC 75.360). Similarly, the UST regulations specify ADEC may require a corrective action plan be submitted for approval prior to conducting corrective action at an UST release site (18 AAC 78.250).
ADEC staff strives to complete plan reviews & respond to responsible parties within thirty (30) days after receipt of plans, although this is not always possible nor is it a requirement. At times expedited plan reviews are feasible based on project manager work load, adequate up-front planning, & contractors providing complete, well written plans. However, if significant WP revisions are required, additional review & comment resolution time will be needed. To facilitate successful project implementation, I recommend DoD project managers & contracting staff:
• Coordinate schedules with DEC project managers in advance & throughout projects.
• Include DEC project managers in project planning meetings (DQO meetings, UFP QAPP development meetings, Triad & other Technical Project Planning team meetings, etc.).
• Plan & maintain project schedules that include a sixty (60) days for reviewing draft work plans, comment resolution, any necessary revisions & a final review & approval.
• Review contractor planning documents prior to submission to DEC to ensure compliance with state & federal regulations consistency with agreements made during project planning meetings.
Failure to obtain WP approval before implementing site work described above is considered a violation of AK regulations & may result in field work not being approved or additional work being required & may subject responsible parties &/or contractors to a Notice of Violation (NOV).
Independent QA oversight on PBCs-As DoD transitions more ER projects to PBC concerns have risen regarding the level of Quality Assurance (QA) oversight. The site cleanup rules require that “collection, interpretation, & reporting of data, & the required sampling & analysis is conducted or supervised by a qualified, impartial third party”.
Depending upon the specific terms in a PBC, a contractor may no longer be considered an impartial third party with respect to collecting, interpreting & reporting data. This should be taken into consideration when preparing scopes of work. DEC strongly recommends the Air Force provide an on-site Quality Assurance (QA) Representative or a third party QA oversight contractor to monitor fieldwork for consistency with approved plans & contract requirements.
DEC is beginning to conduct more frequent independent QA site inspections to evaluate conformance to approved work plans & regulatory compliance. Because we lack staff resources to conduct independent QA on all of the anticipated PBC projects, we intend to include contracting support for field QA oversight in the DSMOA Joint Execution Plans & budget. |
John Halverson |
| 2/19/2008 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed. |
Louis Howard |
| 3/17/2008 |
Document, Report, or Work plan Review - other |
Staff provided comments on the Draft Follow-On Remedial Investigation at SS03, SS08 and SS 11 Technical Memorandum February 2008 Contract F41624-03-D-8603 Task Order 214.
3.0 Laboratory Results Page 2
The incorrect laboratory methods are cited for several analytes. The correct laboratory methods
are as follows: Method 8081S for Pesticides, Method 8082 for PCBs, Method 6020 and 7471A
for metals. Herbicides were not analyzed for and ADEC requests reference to herbicides needs
to be deleted from this section.
The text states: "A complete analytical data package including case narrative, data sheets, and
completed chain-of-custodies are provided in Appendix C per the Alaska Department of
Environmental Conservation (ADEC) Technical Memorandum: 06-002, dated 9 October
2006."
Please note the tech memo also requires: "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 most current version of the Laboratory
Data Review Checklist is located online at http://www.dec.state.ak.us/spar/guidance.htm#csp
and must be completed, signed and dated by the firm submitting the report to the Department.
3.1 Petroleum Hydrocarbons Page 3 and throughout the document
The text states diesel range organics (DRO) had nine samples above the ADEC Method II soil
migration to groundwater cleanup level of230 mg/kg and five samples for residual range
organics (RRO) were above the ADEC Method II groundwater cleanup level of9,700 mg/kg and ingestion cleanup level of 8,300 mg/kg. ADEC was unaware that Tatalina Long Range Radar Site (LRRS) was in the over 40-inch Zone for precipitation. The correct statement for RRO cleanup level would be the "migration to groundwater" cleanup level not groundwater cleanup level.
An error has been made by the contractor on which zone for cleanup levels at Tatalina LRRS is
applicable. The August 2005 Follow-On Remedial Investigation at SS03, SS08 and SS11 Report states under 2.1.1 Climate at page 2-1 : "The average annual total precipitation is 15
inches, with 84 inches of snowfall." It appears the correct determination for source areas at
Tatalina LRRS would meet the definition of "under 40 inch zone" i.e. a site that receives mean
annual precipitation of less than 40 inches each year.
ADEC will require the Air Force to correct the text throughout the document for proper
cleanup levels appropriate for under 40 inch zone and all tables referencing the incorrect Method Two cleanup levels. Absent a groundwater use determination by ADEC under 18 AAC
75.350, the most stringent cleanup level applies at the site which would be migration to
groundwater cleanup level and therefore any reference to ingestion cleanup levels will be
removed, with the exception for RRO where the most stringent cleanup level is ingestion at
10,000 mg/kg.
Appendix C
Case Narrative
The narrative documents numerous dilutions were required for samples/analyses. However,
they did not evaluate if the elevated detection limits met the ADEC cleanup levels. The data
could not be used to screen COPCS or carried on to the risk assessment if cleanup levels are not
met. ADEC will require the Air Force to identify whether or not the elevated detection levels
actually met or exceeded the ADEC cleanup levels. ADEC will require the Air Force to do a
QA evaluation of the lab data. The narratives states that several DRO/RRO extracts glowed or
"fluoresced" Absent any plausible explanation from the Air Force or its laboratory for this
glowing or fluorescing extracts, ADEC requests the Air Force to field screen for radiation
sources at this site. |
Louis Howard |
| 5/5/2008 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft February 2008 Human Health & Ecological Risk Assessment work plan for SS03, SS08, SS11. ADEC will require the more conservative (higher) concentration between the primary and duplicate sample results should always be presented. ADEC requests the Air Force clarify whether there were any fixed analytical laboratory samples analyzed during the 1997 remedial investigation (RI) from the POL Tank Farm. If so, then the results need to be incorporated into the risk assessment.
ADEC does not consider elimination of anthropogenic sources of contamination from risk assessment. ADEC requests the Air Force also reference ADEC’s Sediment Quality Guidelines (as amended March 2004). ADEC considers the use of one background sediment sample as being insufficient to determine background sediment conditions. Comparison of site sediment samples to this background sediment is therefore not appropriate.
Considering the deficiencies in the Air Force’s background study, human and ecological health risk screening against background and elimination of COPCs is not appropriate at this time.
ADEC requests the Air Force provide additional justification of why consumption of game or fish by contract personnel should not be considered as potential exposure pathways should be provided. (i.e. consumption information). Absence of bioaccumulative contaminants was suggested as rationale for considering this pathway insignificant, but ADEC requests the Air Force provide information on how it will handle the PCBs and DDT detections in soils. Bioaccumulative compounds should not be so readily dismissed by the Air Force without more substantive justification.
ADEC requests the Air Force provide information regarding the site surface water streams and whether they are truly ephemeral. Even if so, they should be evaluated by the Air Force for potential contaminant migration potential to a more permanent surface water body. |
Louis Howard |
| 1/28/2009 |
Update or Other Action |
Draft Human Health and Ecological Risk Assessments at SS03, SS08 and SS11 November 2008 received March 13, 2008 for review and comment. 5.1.1.3 Surface Water and Sediment Exposure Pathways: Three VOCs (1-chlorohexane, 2-chloroethyl vinyl ether, and vinyl chloride) were identified as COPCs for a seep at SS08. However, these COPCs were only detected in one sample each at low concentrations (equal to their method detection limits). In addition, potable water for drinking and bathing at Tatalina LRRS is obtained from wells located at the infiltration gallery. ADEC disagrees. ADEC’s previous comments for this section appears to have been not incorporated into this document. May 5, 2008 comment: “Surface water and sediment data are considered inadequate by ADEC to state that these media pose a potential exposure risk. Reference by the Air Force to low concentrations equal to their method detection limits is considered irrelevant by ADEC. Please refer to detected concentrations in relation to risk screening levels. Sediment background data is considered insufficient by ADEC for comparison to site conditions.”
The Air Force did not remove the statement comparing the VOC detections to MDLs instead of risk based screening criteria as requested by ADEC so ADEC is unable to determine if they are an issue or not. Second, even if the surface water pathway is intermittent & not deemed a potentially complete exposure pathway, the presence of these volatile contaminants in the surface water suggests a source that may have not yet been identified/characterized.
1998 RI Report APPENDIX D Background Sampling Summary: In 1997, twelve background surface soil samples were collected. Five were from Upper Camp, six from Lower Camp, and one from Sterling Landing. One background subsurface soil sample
was also collected from BH13/MW at a depth of 11 feet. In addition, a background sample
was collected from each of the following media: surface water, sediment, and groundwater.
Background samples were analyzed for diesel-range organics (DRO), pesticides, cyanide,
and metals. One of the Upper Camp background samples (THSL23A1) had high values for DRO and anomalously low metal values and was deleted from the background data set. One of the Lower Camp background soil samples (THSL52A1) had high levels of DRO that were anomalous compared to the other background samples. DRO was eliminated from the background data set for the land strip sample, but the other constituents were retained.
Finally, one surface water background sample from the Lower Camp seeps is actually represented by two sampling events. THSW03A1 did not meet laboratory quality assurance/quality control criteria for metals, however it has been used to determine surface water background for organic constituents. Sample THSW05A1 was collected and analyzed to represent background values for metals.
ADEC has concerns with the most of the background samples being used in this risk assessment and their representativeness for background or natural conditions. ADEC does not recognize the use of organic or anthropogenic contaminants for background determinations. The collection of one (1) subsurface, one (1) sediment sample and one (1) groundwater sample and two (2) surface water samples to represent background is questionable at best. However, a qualitative comparison of the data to other comparable background studies (i.e. USGS Element Concentrations in Soils and Other Surficial Materials of Alaska, 1988) would be more appropriate.
|
Louis Howard |
| 8/17/2009 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft Focused Feasibility Study at SS003, SS008, and SS011, Draft Contract F41624-03-D-8608, Task Order 0214 Tatalina LRRS July 2009. Typically, following completion of the remedial investigation/feasibility study (RI/FS), the results of the detailed analyses, when combined with the risk management judgments made by the decision-maker, become the rationale for selecting a preferred alternative and preparing the Proposed Plan. Therefore, the results of the detailed analysis, or more specifically the comparative analysis, should serve to highlight the relative advantages and disadvantages of each alternative so that the key tradeoffs can be identified.
It will be these key tradeoffs coupled with risk management decisions that will serve as the basis for the rationale and provide a transition between the RI/FS report (or in this case the Focused Feasibility Study-FFS) and the development of a Proposed Plan (see EPA/540/G-89/004 OSWER Directive 9355.3-01 October 1988 Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA).
ADEC requests the Air Force remove of all text from the FFS regarding the preferred alternative selection for each site until the Proposed Plan stage where the preferred alternative is selected and presented (see EPA 540-R-98-031 OSWER 9200.1-23P PB98-963241 A Guide to Preparing Superfund Proposed Plans, Records of Decision, and other Remedy Selection Decision Documents July 1999).
ADEC interprets the phrase “subsurface water” to have the same meaning as groundwater. Specifically, 18 AAC 990(46) “groundwater” means: (A) water in the saturated zone, for purposes of evaluating whether the groundwater is a drinking water source under 18 AAC 75.350; or (B) water beneath the surface of the soil, for purposes of evaluating whether the water will act as a transport medium for hazardous substance migration. ADEC requests the Air Force change the text in the document to refer to groundwater instead of subsurface water.
Additionally, the seeps mentioned throughout the FFS are considered to be surface water by ADEC. As the groundwater emerges as surface water, the surface water quality standards apply. The document should point out this distinction and these seeps are regulated by 18 AAC 70 Water Quality Standards (as amended as of July 1, 2008) and the companion document Alaska Water Quality Criteria Manual for Toxic and Other Deleterious Organic and Inorganic Substances (as amended as of May 15, 2003). The word “seep” should be footnoted and defined as “surface water” at least once in the document and then footnotes are to be used for all of the tables where concentration ranges are listed for seeps.
ADEC has a global comment on arsenic risk through the document. Arsenic should not be discounted as a risk driver for a site on the basis that it is within background concentrations. ADEC requests the Air Force rework the text when discussing risk from arsenic to state that although arsenic risk exceeds acceptable risk levels, it is within background concentrations and therefore not considered a contaminant for remedial consideration.
See site file for additional information. |
Louis Howard |
| 8/20/2009 |
Update or Other Action |
Final Risk Assessment for SS03, SS08, & SS11 received.
Titanium was identified as the only COPC for surface water at SS03. Titanium was selected as a COPC because screening criteria were not available. Surface water at SS03, SS08, and SS11 is present only intermittently, so any potential incidental contact with this water would be minimal. Therefore, potential exposure to surface water at ERP Sites SS03, SS08, and SS11 is deemed potentially complete, but insignificant. COPCs identified for subsurface water beneath SS03 and SS08 include various inorganics, VOCs, SVOCs (including PAHs), DRO, GRO, and RRO.
Subsurface water beneath SS03 or SS08 is not currently used as a potable water supply, and it is unlikely that it will be used for such purposes in the future. Potable water for Tatalina LRRS is supplied through an infiltration gallery collection system located at Lower Camp. It is highly unlikely that contamination in subsurface water at SS03 or SS08 has impacted the infiltration gallery, because a water sample collected from the infiltration gallery in 1997 did not contain any VOCs, SVOCs, or pesticides. Low levels of metals and DRO were detected in that sample.
Cumulative carcinogenic risk and noncarcinogenic HI estimates for a current site worker across all exposure media were 2 x 10-5 and 6, respectively, for non-petroleum hydrocarbon (PHC) COPCs. Primary contributors to a carcinogenic risk estimate in excess of ADEC’s acceptable risk criterion of 1 x 10-5 were arsenic (EPC = 16 mg/kg) and naphthalene (EPC = 51 mg/kg) in surface soil. Primary contributors to a noncarcinogenic HI in excess of ADEC’s acceptable HI criterion of 1 were 1,2,4-trimethylbenzene (EPC = 431 mg/kg) and 1,3,5- trimethylbenzene (EPC = 81 mg/kg) in surface soil. The cumulative noncarcinogenic HI estimate for a current site worker exposed to PHC-related COPCs was 0.2. This noncarcinogenic HI is below ADEC’s acceptable HI criterion of 1.
Cumulative carcinogenic risk and noncarcinogenic HI estimates for a current trench worker across all exposure media were 1 x 10-6 and 6, respectively, for non-PHC COPCs. The cumulative carcinogenic risk estimate is below ADEC’s acceptable risk criterion of 1 x 10-5. Primary contributors to a noncarcinogenic HI in excess of ADEC’s acceptable HI criterion of 1 were 1,2,4-trimethylbenzene (EPC = 431 mg/kg) and 1,3,5-trimethylbenzene (EPC = 81 mg/kg) in surface soil. The cumulative noncarcinogenic HI estimate for a current trench worker exposed to PHC-related COPCs was 0.4. This noncarcinogenic HI is below ADEC’s acceptable HI criterion of 1.
See site file for additional information.
|
Louis Howard |
| 10/15/2009 |
Meeting or Teleconference Held |
Meeting minutes from October 15, 1999 meeting. Project: Tatalina Feasibility Study,
Sites SS03, SS008, and SS011, Job Number 1851216. Participants: Louis Howard, ADEC, Marty Brewer, ADEC, Earl Crapps, ADEC, Robert Johnston, 611th CES/CEAR, Michael McCrum, MWH and Aseem Telang, MWH.
Robert indicated that he called the meeting to discuss the next phase of work at Sites SS003,
SS008 and SS011 at Tatalina LRRS. Robert wanted to get ADEC input on appropriate remedial
action at each of these three sites so he can program next year’s work.
The first several minutes of the meeting focused on bringing the ADEC representatives up to
speed on previous characterization efforts, with emphasis on the nature and extent of chemicals
of potential concern (COPCs) at each site. This portion of the discussion led to the
understanding that the primary COPCs at all three sites were petroleum hydrocarbons (and
related organic compounds). There is one location where sampling results indicated a PCB
concentration of approximately 17 mg/kg in surface soils at SS008. ADEC indicated that there
may be some flexibility in remedial action if the concentration is between 1 and 10 mg/kg, but
concentrations above 10 mg/kg require active remedial action.
Site SS003:
MWH briefed ADEC on general site physical setting, nature and extent of COPCs and potential
applicability of MNA as a remedial approach at this site. In response, ADEC indicated that they
would be inclined to:
- Accept Institutional Controls with Long Term Monitoring as a remedial alternative for
groundwater at site SS003.
- Support a removal action that focused on removing stained surface soil in the areas were
analytical results indicate the presence of remnant petroleum hydrocarbons (predominantly
within the bermed areas where the former storage tanks were located). |
Louis Howard |
| 5/7/2010 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the October 15, 2009 Meeting Minutes SS003, SS008, and SS011, Tatalina LRRS. ADEC concurs with the conceptual preferred remedies which will be incorporated in a future Proposed Plan and Record of Decision for these three source areas (SS003, SS008, SS011).
Site SS003:
* Institutional Controls with Long Term Monitoring as a remedial alternative for groundwater at site SS003.
* Vegetative cap consisting of grasses and/or plants native to Alaska will be used to address stained [petroleum constituents only] surface soil in the areas were analytical results indicate the presence of remnant petroleum hydrocarbons (predominantly within the bermed areas where the former storage tanks were located).
Site SS008:
* Actively remediate the area with PCB concentrations exceeding cleanup levels.
* Actively treat sediment near the culvert(s) that contain pesticides.
* Evaluate potential for active remedial action regarding groundwater based on summary of results for the monitoring well with at least one concentration exceeding Method 2 levels
Site SS011:
* Remove any existing visible drums within the area investigated in 2008
* Vegetative cap consisting of grasses and/or plants native to Alaska will be used to address stained [petroleum constituents only] soil associated with the visible drum
While ADEC may comment on other state and federal laws and regulations, our comments do not relieve responsible persons from the need to comply with other applicable laws and regulations.
|
Louis Howard |
| 8/31/2011 |
Update or Other Action |
Draft Proposed Plan received for SS003, SS008, SS011 & LF004. SS003.
Petroleum is the only contaminant of concern which is not included in CERCLA’s definition of hazardous substances &, therefore, not subject to CERCLA reporting, response, or liability requirements; therefore, no action is proposed under CERCLA.
The risk assessment found exposure pathways were complete for both current & future site workers, trench workers, & recreational hunters for surface soil (SS003, SS008, & SS011) & GW (SS003 & S8008). Results of the ADEC-approved human health risk assessment indicate there is a risk to site workers from naphthalene (SS003 & SS011). The risk assessment also indicated there is a risk to site workers from arsenic at SS003, however these levels have been determined to be within the areas background levels.
The Air Force uses the lands at SS003 & LF004 for daily operations. There are no current plans for future development at any of the sites. The current land use is expected to remain the same over the foreseeable future.
The preferred surface soil remedial alternative is Bioremediation through in situ landfarming. There are no Location-Specific or Action-Specific requirements applicable to the remedial alternatives evaluated for SS003. Bioremediation actively attenuates COPC levels, & is considered effective in reducing COPC toxicity, mobility, or volume and effective in reducing or eliminating COPC levels in both the short terms & long term; therefore, it was rated medium for long-term effectiveness & permanence. Bioremediation requires mobilizing heavy equipment to & from the site to execute; therefore, this alternative was rated medium for implementability, reflecting the more difficult constraints associated with mobilization.
The preferred GW remedial alternative is ICs with Long-term Monitoring. ICs would serve to effectively reduce human & ecological exposure to GW by preventing future development of the GW resources in the area; therefore, it is rated high for overall protection of human health & the environment. There are no known Location-Specific or Action-Specific requirements applicable to the remedial alternatives evaluated for SS003. ICs were rated high for compliance with chemical-specific applicable requirements.
ICs were rated high for long-term effectiveness & permanence by preventing future development of resource; ICs would not directly affect COPC toxicity, mobility, or volume & are rated low for this criterion. For short-term effectiveness, ICs were rated high by reducing human exposure. LTM would be conducted to ensure that the ICs remain effective by tracking contaminant levels in the GW to make sure that they remain within the area controlled by the ICs. ICs with LTM requires that a small sampling crew with minimal equipment mobilize to the site periodically; therefore, this alternative was rated high for implementability.
In addition to the above ICs, the following proposed activities would be conducted:
A land survey would be conducted at ERP Sites SS003, 8S008, SS011, and LF004 to identify site boundaries. This information would be used to update land records and the Tatalina LRRS comprehensive map and Base Master Plan. Any activity that is inconsistent with IC requirements, objectives, or controls, or any action that might interfere with protectiveness of the ICs, would be addressed by the Air Force as soon as practicable after discovery. In no
instance would ADEC be notified later than 10 days after the Air Force becomes aware of a deficiency.
The ICs at a site would extend indefinitely, to ensure that human and ecological receptors are protected from potential exposures. Periodic reports of IC monitoring would be prepared at a frequency of at least once every 5 years and provided to ADEC on an informational basis only with copies filed in the Administrative Record.
See site file for additional information. |
Louis Howard |
| 12/22/2011 |
Document, Report, or Work plan Review - other |
Air Force responses to ADEC comments received.
General Comments:The number of acronyms will be reduced. Acronyms that are not used multiple times will be eliminated. A glossary will be added to the end of the document.
Page 2 and 3: Disagree. The PRGs, which based on risk –based cleanup levels (RBCLs) calculated according to ADEC methods, were not part of the baseline risk assessment, but were presented in the FS (RBCLs calculated in Appendix A of the final FS). The PRGs are considered preliminary until they are finalized as cleanup standards in the Record of Decision.
Page 8: A. The following sentence will be inserted to describe the depth to groundwater: “Depth to groundwater at this site ranged from 12.85 ft bgs to 7.70 ft bgs in 2003” The text will be modified to indicate the subsurface soil pathway is incomplete and will not be considered further.
Figure 3: A note will be placed in the legend that all results exceed PRGs and the PRG table will be referenced.
The following text will be added: “The source of this DRO contamination is unknown, but was evident by the petroleum odor and staining found in 1997. No further delineation or surface water samples were collected.”
Figure 4: A. Investigations into PCE and PCB contamination indicated that these contaminants were not found throughout the site. These individual locations were not well delineated and will need to be field screened and/or laboratory tested during remedial action.
With respect to PCE, the sediment sampling location was at the outlet of a drain pipe. The following text will be added: “Surrounding boreholes to the sediment sample did not encounter groundwater, but there was no PCE present in the soil samples.”
BH-21: The following text will be added: “Eleven boreholes were completed in 1997 and 1999. Only one had PCB contamination. This is likely an isolated occurrence due to the borehole’s isolated location in a small clearing.”
Page 12 LF004: The text will be corrected to say: “No contaminants of concern were detected above ADEC method two cleanup levels for surface soil, subsurface soil, groundwater, or downgradient surface water and sediment samples.”
See site file for additional information. |
Louis Howard |
| 1/23/2012 |
Update or Other Action |
Draft Annual Report received.
There are 6 existing monitor wells located at Sterling Landing. BH 14/MW through BH/MW 18 were installed in 1997, & BH 24/MW & BH 25/MW were installed in 1999, by CH2MHill. These were resampled for GRO, DRO, BTEX, & lead. 3 additional monitor wells were to be installed this year near the community boundary line upon concurrence of locations by ADEC, the project manager, & the community. A monitoring well (MW-6) was installed adjacent to the TCA fuel tanks on the bank of the Kuskokwim River.
This well was within several feet of one of the locations selected by the 611th CES. Because of this overlap, the 611th CES did not install a well adjacent to the TCA fuel tanks & only 2 monitoring wells (BH/MW02-15 & BH/MW02-16) were installed by 611th personnel. Three boreholes (BH02-12 to BH02-14) were drilled in the attempt to establish monitoring wells. The aforementioned boreholes were abandoned due to intercepting permafrost & bedrock which resulted in drill refusal. GW & boring samples from the new wells were collected & analyzed by the 611 CES/CEVO for GRO, DRO, RRO, VOC (8021B), SVOC (8270 SIM), PCB/pesticide (8082), & metals (total RCRA).
Water samples from the existing monitoring wells were analyzed only for DRO, GRO, BTEX, & lead because the possibility of elevated levels of other potential contaminants of concern had been deemed neglibible following analysis conducted during their installation in 1997 & 1999. All the soil samples from the borings contained arsenic above ADEC clean up levels. Soil samples from BH/MW02-13,14, & 16 had chromium above ADEC clean up levels. GRO & DRO for all the soil samples from borings were below the PQL detection limits. GW 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 at 0.507 mg/L, which is just above the PQL of 0.500 mg/L.
A duplicate sample from BH/MW02-16 had no detectable DRO above the PQL of 0.500 mg/L. BH/MW02-16 is the farthest away from the SS-02 POL tank farm among any of the boreholes/wells. Two GW samples from monitoring wells at Sterling Landing exceeded ADEC clean up levels for DRO. BH24/MW & BH25/MW are directly down gradient from the old SS-02 POL tank farm. Wells in the proximity of these 2 wells also tested positive for DRO. DRO & GRO values in all the contaminated wells has decreased steadily since the wells were installed.
Contaminants in soil samples from the 5 drill strings above ADEC clean up levels were limited to arsenic & chromium. Background levels of arsenic & chromium from soil samples in the Yukon/Kuskokwim area are naturally elevated. Background soil samples collected & analyzed in 1997 at Sterling Landing contained arsenic concentrations that ranged from 11 to 16 mg/Kg. Chromium in background soil samples in the Tatalina area collected & analyzed in 1993, ranged from 41.4 to 58.7 mg/Kg. GW samples from the 2 new monitoring wells SW of the POL tank farm had no contaminants above ADEC clean up levels. Hydrocarbon levels in monitoring wells down gradient from the POL tank farm have remained near constant or declined slightly since 1997. The boreholes & monitoring wells installed SW of the POL tank farm in FY 2002 define a clear break in contaminant plumes between the USAF tank farm & 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 concentrations & locations.
See site file for additional information. |
Louis Howard |
| 6/13/2012 |
Update or Other Action |
Pre-Draft ROD for SS003, SS008, SS011, LF004 received via electronic mail. Sites SS003, SS008, SS011, and LF004 at Tatalina LRRS cannot support unlimited use and unrestricted exposure due to hazardous substances and contaminants remaining in place after implementation of the selected remedy. Land use restrictions are required as part of this response action and will be achieved through imposition of LUCs that limit the use and/or exposure to those areas of the propery, including water resources, that are contaminated.
At ERP Site SS003, surface soil will undergo Bioremediation through In-situ Landfarming (down to 2 feet below ground surface [bgs]). This will be accomplished over a 2-year period, including application of nutrients and routine tilling and sampling. Long-term monitoring will be conducted for groundwater every 5 years for 20 years, or until contaminants are below ADEC Table C cleanup levels for two consecutive sampling events. A detailed delineation will be completed to determine the extent of diesel range organics (DRO) contamination located downgradient of the site by Sample SL39.
To restrict current and future access or exposure to soil and groundwater at all four ERP Sites, the following proposed ICs would be implemented:
- The Tatalina LRRS comprehensive map and Base Master Plan would be updated to show the boundaries of each site to restrict excavation of soil and disturbance of soil covers, as well as to prevent access to groundwater. The Base master Plan would contain a map indicating site location, with restrictions on any invasive activities that could potentially expose contaminants. Dig permits issued by the Base Operating Contractor are required for any excavation at Tatalina LRRS. Excavation, disturbance, or relocation of contaminated soil and groundwater; and excavation or drilling in areas of groundwater contamination, will be restricted by the ICs. Relocation of petroleum-contaminated soil will require prior ADEC approval. Use or removal of petroleum-contaminated groundwater will require characterization and be managed by the applicable regulations.
Prior to approving a permit, the Tatalina LRRS comprehensive map and Base Master Plan would be reviewed to ensure that invasive activities are not taking place within the boundary of the sites where land use has been restricted. A Notice of Environmental Contamination will be placed on State (Alaska Department of Natural Resources) land records.
See site file for additional information.
|
Louis Howard |
| 7/6/2012 |
Document, Report, or Work plan Review - other |
Staff reviewed & commented on the pre-draft ROD for SS003, SS008, SS011 & LF004.
1.2 Statement of Basis & Purpose
The text states that the Air Force (AF) & EPA have jointly selected the remedy for each site. However, in the very next paragraph, it states that EPA has been given the opportunity to review this document & has chosen to defer to the ADEC for regulatory oversight of the ERP at Tatalina LRRS. This last sentence gives the reader the impression that the EPA has not selected any remedy. Please correct text to reflect EPA’s involvement in this document. Also, ADEC requests the AF delete the sentence: “The Alaska Department of Environmental Conservation (ADEC) concurs with the selected remedy.”
The text states: “As the lead agency, the Air Force has selected the remedy. ADEC concurs with the selected remedy.” ADEC requests the sentence be changed to the following: “ADEC agrees that the selected remedies, when properly implemented, comply with state law.”
1.3.1 Assessment Under CERCLA
The text states: “…land use controls (LUCs) that limit the use &/or exposure…” However, in Section 1.4.1 & elsewhere in the document the AF refers to Institutional Controls (ICs) in the text & tables. Please choose one or the other & be consistent throughout the document.
1.4.1 Remedies Selected Under CERCLA
1st bullet
ADEC requests the AF change the text as follows: “The Base Master Plan would contain a map indicating site location, with restrictions on any invasive activities that could potentially result in exposure contaminants.”
The text states: “Excavation, disturbance, or relocation of contaminated soil & groundwater, & excavation or drilling in areas of groundwater contamination, will be restricted by the ICs.”
ADEC requests the AF ensure other sections of the ROD define the restrictions (e.g. prohibit intrusive work). ADEC will also require text stating ADEC & AF approval of a work plan on how potentially contaminated material will be managed prior to issuing a dig permit.
See site file for additional information.
|
Louis Howard |
| 1/31/2013 |
Long Term Monitoring Established |
The remedies for SS003 include Bioremediation (through in-situ landfarming) of surface
soil, long-term monitoring of groundwater, and ICs for all media. Long-term monitoring will be
conducted for groundwater every 5 years until contaminants are below ADEC Table C cleanup
levels for two consecutive sampling events. |
John Halverson |
| 1/31/2013 |
Site Reopened |
|
John Halverson |
| 1/31/2013 |
Institutional Control Record Established |
Sites SS003 and SS008, at Tatalina LRRS cannot support unlimited use and unrestricted exposure due to hazardous substances and contaminants remaining in place after implementation of the selected remedy. Land use restrictions are required as part of this response action and will be achieved through imposition of ICs that limit the use and/or exposure to those areas of the property, including water resources, that are contaminated. Long-term Monitoring at SS003, and ICs at all sites as the selected remedies for Tatalina LRRS. The major components of the selected response action will be implemented to restrict current and future access or exposure to soil and groundwater at SS003 and SS008.
The land use at SS003 and SS008 is designated as industrial use only currently and in the future in the Base Master Plan. Residual soil contamination is not safe for recreational and/or residential use. ICs are, therefore, necessary to preclude such uses to control the disposition and use of any soil excavated from the site.
The Tatalina LRRS comprehensive map and Base Master Plan will be updated to show the boundaries of each site to restrict excavation of soil, as well as to prevent access to groundwater. As
part of the update to the Base Master Plan, the Air Force will produce maps showing locations of the residual contamination, and will provide these maps to ADEC. The Base Master Plan will contain a map indicating site location, with restrictions on any invasive activities that could potentially result in exposure of contaminants. The ICs will be documented in the Air Force Real Property Records, Tatalina LRRS General Plan, and 611th IRP Records. |
John Halverson |
| 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.
The SS003 land survey performed 6 August 2012 included the outline of the bermed area, the perimeter boundary of SS003, and the centerline of the Sterling Landing Access Road from SS008 to SS003. There were 39 coordinate points collected at SS003.
Photo Photos 10 – 14 were taken at SS003. Photo 10 is a view of the SS003 Tank Farm area, which is currently used as an active fueling station. Photo 12 shows an active fuel tank and series of berms, looking northeast. Photo 14 is a view of the former tank farm bermed area at the far end of SS003. |
Louis Howard |
| 4/1/2013 |
CERCLA ROD Approved |
Record of Decison signed by John Halverson (ADEC). Based on the results of the FS and Proposed Plan, the Air Force selected Bioremediation through In-situ Landfarming at SS003 and SS008, Long-term Monitoring at SS003, and ICs at all sites as the selected remedies for Tatalina LRRS.
At SS003, surface soil will undergo Bioremediation through In-situ Landfarming (down to 2 feet
below ground surface [bgs]). This will be accomplished over a 2-year period, including
application of nutrients and routine tilling and sampling. Long-term monitoring will be
conducted for groundwater every 5 years until contaminants are below ADEC Table C cleanup
levels for two consecutive sampling events. A 20-year timeframe was used in the FS for the
detailed analysis of total costs and is not necessarily the amount of time estimated to achieve
clean-up levels. A detailed delineation will be completed to determine the extent of diesel range organics (DRO) contamination located downgradient of the site by Sample SL39. |
John Halverson |
| 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 a) The site well permitting system will prevent any use of groundwater for drinking water.
b) The site construction review process will prevent damage to existing monitoring wells.
c) All ROD use limitations and exposure restrictions will be entered in the Base Master Plan and the Geographical Information System.
d) The site construction review process will be used to avoid ground-disturbing construction activities and to ensure safe soil management procedures in areas with residual contamination.
e) The site digging permit system will be used to avoid activities that could breach the landfill cover.
f) The site Environmental Impact Analysis Process will be used to assess the potential environmental impact of any action proposed at the site. |
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.
SS003
The IC inspection at Site SS003 noted that the area is infrequently accessed to maintain the AST and as a vehicle turnaround. Warning signs were abundant on-site. No unauthorized activities were evident. |
Louis Howard |
| 4/8/2016 |
Update or Other Action |
Draft WP for Remedial Activities at Sites: SS003, SS008, SS011, SR001.
ROD Selected Remedy Text: "The remedies for SS003 include Bioremediation (through in-situ landfarming) of surface soil, long-term monitoring of groundwater, and ICs for all media. These remedial actions were selected based upon their ability to protect human health and the environment and compliance with applicable requirements. These remedies provide the best balance
among the balancing criteria and appear consistent with comments received from the public and ADEC. The remedies are easily implemented, are cost effective, and are both a short and long-term solution for contamination at the site."
Soil at previously identified POL hot spot locations will undergo bioremediation through In-situ landfarming (down to 2 feet below ground surface [bgs]). This will be accomplished over a 2-year period, including application of nutrients and routine tilling and sampling. Tentative schedule: May 2016 through September 2016 and May 2017 through September 2017 - Every two weeks.
See site file for additional information. |
Louis Howard |
| 4/13/2016 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the draft RA CA WP for Remedial Activities. Main comments were regarding analyzing for all the SS003 and SS008 Records of Decision chemicals of concern not just the ones listed in the WP. At SS003, analysis of soil samples must report and include naphthalene, 1,2,4-trimethylbenzene, 1,3,5-trimethylbenzene and RRO, (and bis-(2-ethylhexyl)phthalate if sediments are to be landfarmed) in addition to those listed in the document (all of which are ROD COCs). At SS008, analysis of soil samples must report and include RRO, this is in addition to DRO and GRO listed in the document.
Finally, staff commented on the potential implications of storing TSCA regulated waste at the site over the winter. EPA Region 10 TSCA Program shall be contacted and their approval sought for the Air Force’s request any necessary waivers or extensions of storage and delayed disposal of TSCA regulated PCB/PCE-contaminated soil should long term staging be required in the event drummed or Super-Sacked waste is not able to be barged out in 2016 due to low river levels or some other reason.
See Site file for additional information. |
Louis Howard |
| 6/26/2017 |
Update or Other Action |
RA Construction Report received. At all landfarming cells located in sites SS003 and SS008, the work plan specifies landfarming will be conducted over a 2-year period, including application of nutrients. Analytical results from baseline samples collected after the initial tilling event
indicated site-specific cleanup levels have been achieved, and further tilling (and the
application of nutrients) will not be necessary.
See site file received. |
Louis Howard |
| 7/13/2017 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the draft RA-C report.
Main comments were identifying the contaminants of concern (COC) which were detected above the revised 18 AAC 75 March 23, 2017 cleanup levels and those which were detected in groundwater above Table C levels but not identified as a migration to groundwater COC. Contaminants were limited in reporting by laboratory for method SW8260 to select contaminants and therefore it could not be determined if certain COCs achieved their migration to groundwater cleanup levels in soil.
See site file for additional information. |
Louis Howard |
| 8/8/2017 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the draft Five-Year Review. Staff requested additional text be provided regarding the timeframe for placing a notice of environmental contamination in ADNR's land records for LF004, SS003, SS008 & SS011. Trimethylbenzene, benzene, ethylbenzene, naphthalene exceed either the residential or commercial target levels in the ADEC VI Guidance Appendix G. The vapor intrusion pathway should be assessed current exposure and future users.
1,2,4-Trimethylbenzene, 1,2-DCA, 1,3,5-Trimethylbenzene, benzene, ethylbenzene, naphthalene and n-propyl benzene in groundwater exceed Table C or 1/10th Table C cleanup levels and need to be evaluated for cumulative risk. GW monitoring should have been conducted in 2013-2016 in anticipation of the 5YR, but since it wasn't the data from the August 2005 follow-on RI report was used.
See site file for additional information. |
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. Conduct and document a visual inspection of ICs as specified LF004 in Section 1.2.1.
See site file for additional information. |
Louis Howard |
| 8/28/2018 |
Cleanup Complete Determination Issued |
ADEC has determined the cleanup is complete as long as the institutional controls are properly implemented and no new information becomes available that indicates residual contamination may pose an unacceptable risk.
The ADEC Contaminated Sites Database will be updated to reflect the change in site status to “Cleanup Complete with Institutional Controls” and will include a description of the contamination remaining at the site.
The ICs will be removed in the future if documentation is provided that shows concentrations of all residual hazardous substances remaining at the site are below the levels that allow for unlimited use and unrestricted exposure to, and use of, the contaminated media and that the site does not pose a potential unacceptable risk to human health, safety or welfare, or to the environment. Standard conditions above will remain in effect after ICs are removed.
This determination is in accordance with 18 AAC 75.380 and does not preclude ADEC from requiring additional assessment and/or cleanup action if the ICs are determined to be ineffective or if new information indicates that contaminants at this site may pose an unacceptable risk to human health or the environment.
See site file for additional information. |
Louis Howard |
| 8/29/2018 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 73831 name: Aboveground storage tanks |
Louis Howard |
| 3/24/2020 |
Document, Report, or Work plan Review - other |
Staff commented on the Draft Remedial Action Operations, Land Use/Institutional Control WP for LF004 and SS003. Main comments was on ensuring the analysis of decision document contaminants of concern for each site and to not use a peristaltic pump for collecting groundwater samples due to potential volatile loss. See site file for additional information. |
Louis Howard |
| 12/16/2020 |
Institutional Control Periodic Reporting |
Groundwater monitoring and institutional control (IC) inspections were conducted at Sites LF004
and SS003 in August 2020. Three monitoring wells were sampled in association with LF004:
BH10-MW, MW-30, and MW-31. These samples were analyzed for the pesticides
4,4'-dichlorodiphenyldichloroethene (4,4'-DDD); 4,4'-Dihlorodiophenyldichloroethylene (4,4'-
DDE); 4,4'-dichlorodiphenyltrichloroethane (4,4'-DDT) by method 8270D-Selected Ion
Monitoring (SIM). One monitoring well was sampled in association with SS003, MW02-24. This
sample was analyzed for diesel-range organics (DRO) by Alaska method (AK) 102. The other
two monitoring wells planned for sampling at this site were either inaccessible due to excessive
vegetation (MW02-23) or were full of bentonite chips and the inner polyvinyl chloride (PVC)
casing could not be located (BH1-MW). |
Darren Mulkey |
| 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 |
