| Action Date |
Action |
Description |
DEC Staff |
| 1/25/1988 |
Enforcement Action |
USEPA Assistant Administrator J. Winston Porter (OSWER) Memorandum for the record to Regional Administrators I-X Subj: Enforcement Actions under RCRA and CERCLA at Federal Facilities. Statutory language makes it clear that Federal facilities must comply both procedurally and substantively with RCRA and CERCLA in the same manner as any non-Federal entity. The purpose of this memo is to lay out the statutory authorities under RCRA and CERCLA that EPA may use at Federal facilities to achieve compliance and expeditious cleanup.
EPA (The Agency) is viewing the Section 120 Interagency agreement as a comprehensive document to address hazardous substance response activities at a Federal facility from the remedial investigation/ feasibility study (RI/FS) through the implementation of the remedial action. All such interagency agreements must comply with the public participation requirements
of Section 117. The timetables and deadlines associated with the RI/FS and all terms and conditions associated with the remedial actions (including operable units or interim actions) are enforceable by citizens and the States through the citizen suit provisions of Section 310 of CERCLA. In addition, Section 122(1) of CERCLA authorizes the imposition of civil penalties against Federal agencies for failure to comply with interagency agreements under Section 120. Procedures for imposing these penalties are provided for in Section 109 of CERCLA.
Executive Order 12580 clarifies that EPA is authorized to issue Section 104 and Section 106 administrative orders to other Federal agencies, with the concurrence of the Department of
Justice. Section 4(e) of the Executive Order provides that: Notwithstanding any other provision of this Order, the authority under Section 104(e)(5)(A) and Section 106(a) of the Act to seek information, entry, inspection, samples or response action from Executive Departments and agencies may be exercised only with the concurrence of the Attorney General.
States also have a variety of enforcement authorities under CERCLA, so the exercise of EPA's enforcement authorities should be closely coordinated with the States.
First, Section 121(e) (2) of CERCLA authorizes States to enforce ANY Federal or state standard, requirement, criteria or limitation to which the remedial action must conform under CERCLA.
Second, Section 310 authorizes citizen suits to require Federal agencies to comply with the standards, regulations, conditions, requirements, or orders which have become effective pursuant to CERCLA including IAGs under Section 120 of the Act.
Third, Section 120(a)(4) clarifies that State laws concerning removal and remedial action, including State laws regarding enforcement, are applicable at Federal facilities not included on the NP. In addition, Section 120(i) states that nothing in CERCLA Section 120 shall affect or impair the obligation of the Federal agency to comply with the requirements of RCRA, including corrective action requirements (see section IV.C., "Importance of the States as a Party to the IAG"). EPA enforcement actions against Federal agencies should therefore be carefully coordinated with States to avoid potentially duplicative or conflicting exercises of authority.
All RCRA Subtitle C permits issued after November 8, 1984, will contain provisions for implementing the corrective action requirements of 40 CFR Part 264 Subpart F (or authorized state requirements), and Section 3004(u) and (v) of RCRA. For facilities that have or are seeking a RCRA permit, the requirements for a "CERCLA" remedial investigation and cleanup could be met by implementing these requirements through RCRA corrective action. It is important to keep in mind, however, that the extent of coverage of the RCRA permit is generally limited to hazardous wastes/constituents (e.g., some CERCLA hazardous substances such as radionuclides are not RCRA hazardous constituents and, therefore, the permit may not be able to address all of the releases at a facility).
The corrective action authority under Section 3008(h) of RCRA can be used at RCRA interim status facilities to address releases from RCRA regulated units and other solid waste management units. At a Federal facility that has interim status, a RCRA corrective action order could address the investigation and clean-up of releases in. lieu of a "CERCLA" response action or as an interim measure. Again, the extent of coverage in the RCRA corrective action order is limited to RCRA hazardous wastes/constituents.)
CERCLA Section 106 can be used to address releases from RCRA units or CERCLA sites when an "imminent and substantial endangerment" is shown. A Section 120 IAG could be drafted to incorporate all RCRA corrective action requirements and CERCLA statutory requirements. Where some or all of a Federal installation has been listed on the NPL, the CERCLA Section 120 IAG is required for remedial action by statute. |
Louis Howard |
| 4/5/1991 |
Enforcement Action |
ADEC receives the EPA/ARMY FFCA for Fort Richardson EPA ID Number AK1210022157 Docket No. 1090-05-29-6001. Federal Facility Compliance Agreement ("Agreement") is entered into pursuant to RCRA, and Executive Order 12088, Federal Comnliance with Pollution Control Standards (43 Fed. Reg. 47707, October 13, 1978).
This Agreement in no way restricts EPA from taking such additional action as it deems appropriate to address past, present and future violations of RCRA or other environmental laws and regulations, other than those specifically addressed by this Agreement. Further, this Agreement is not intended to circumvent the permitting process established under RCRA, nor the statutory requirements of § 120 of the Comprehensive Environmental Response, Compensation, and Liability Act, as amended ("CERCLA"), 42 U.S.C. § 9620.
This Agreement does not address corrective action or response measures pursuant to sections 3004(u), 3004(v) or 3008(h) of RCRA, 42 U.S.C. §§ 6924(u), 6924(v) or 6928(h), or pursuant to CERCLA, 42 U.S.C. § 9601 et seq. This Agreement has been entered into by the Army and EPA to resolve only the matters stated below and to facilitate implementation of the measures
described herein.
Notwithstanding any other provision of this Agreement, EPA expressly reserves all of its statutory and regulatory powers, authorities, rights, defenses, and remedies, both legal and
equitable, including but not limited to the following:
A. the right to disapprove of work performed by the Army;
B. the right to bring any enforcement action against the Army's contractors, subcontractors and/or operators;
C. the right to take further action pursuant to RCRA, or CERCLA, against the Army or any other party subject to such authority; and
D. the right to take or order additional work or other actions, including but not limited to, the investigation, prevention or abatement of a threat to the public health, welfare, or environment arising from conditions at the facility.
Fort Richardson had failed to prepare a hazardous waste manifest for hazardous waste shipped off-site as required by 40 C.F.R. §262, Subparts (A-D) for wastes generated at building 726. Hazardous waste tetrachloroethylene (F002) generated at Fort Richardson's dry cleaners operations was disposed of at the Hiland Road Municipal Sanitary Landfill.
Conclusions of Law and Determinations-Based on the foregoing Findings of Fact and the administrative record, it is hereby determined by EPA that: A. the Army is a Department of the executive branch of the Federal Government;the Army has jurisdiction over Fort Richardson, a solid waste management facility; Fort Richardson has engaged in activities resulting, or
which may result, in the management or disposal of solid waste or hazardous waste; pursuant to 42 U.S.C. §6961, Fort Richardson is subject to and must comply with all Federal, State, Interstate, of solid waste or hazardous waste disposal in the same manner, and to the same extent, as any person is subject to such requirements; and Fort Richardson has violated RCRA, as set forth above in the Findings of Fact.
Fort Richardson shall cease taking hazardous waste from building 726 and any other building to the Hiland Road Municipal Sanitary Landfill. Fort Richardson shall submit a report indicating measures to correct this violation and explain what will be done to prevent it from recurring. |
Tim Law |
| 6/12/1991 |
Update or Other Action |
June 12, 1991 RCRA Hazardous Waste Management Compliance Evaluation Inspection Report documents Tim Law, Daniel Hartung, Vic Vickaryous, Geoffrey Kany, of ADEC's RCRA program inspect the Post for compliance with the provisions of the compliance agreement (FFCA) on April 29, April 30, 1991. Stabilized perchloroethylene (1,1,2,2-tetrachloroethylene) dry cleaning fluid produced by DOW.
DOWPER Perchloroethylene is utilized in the dry cleaning process. DOWPER™ solvent is a high purity solvent with low viscosity and low surface tension to enhance penetration of fibers and dissolve most organic stains. The solvent dries quickly, leaving no residue or odors, and is safe for use with the fabrics and dyes commonly used in the fashion industry. Emissions can be minimized by use in closed systems. DOWPER is non-flammable.
Perchloroethylene, also known as perc or tetrachloroethylene, is a clear, heavy, colorless liquid with a distinctive, somewhat ether-like odor. It is nonflammable, having no measurable flash point or flammable limits in air. perchloroethylene has made a major contribution to the drycleaning industry because of its safe handling characteristics, its efficient solvency and its ease of recycling. Perchloroethylene features a low viscosity and surface tension that allows it to dissolve most organic substances found on soiled garments.
Other applications for perchloroethylene include textile
processing, metal cleaning and degreasing. Perchloroethylene
is also used as an additive in inks and as a catalyst rechloriding
agent in the production of high octane fuels.
The diatomaceous earth and activated carbon still bottoms contaminated with the perchloroethylene solvent become the "cook down residue" or "PERC cleaning residue" hazardous waste. This F002 waste is collected in cardboard boxes and at the time of the April 1991 inspection, two such cardboard boxes were observed adjacent to the distallation units. Each of is considered distinct satellite accumulation point.
Both containers were observed to be open at the time of the inspection. Mr. William E. Byas of E & S Diversified Services, Inc stated that Mr. Ray Burns was just adding waste to the open container and must have just stepped away for a second. Whether or not it was true, it did not hold true for the other open container, in violation of 40 CFR 262.34 (c)(1)(i) as it refers to 40 CFR 265.173(a). According to Mr. Burns during the 1990 inspection, these boxes were filled up at the approximate rate of one every three days. Using twelve data points, this averaged out to 159#/month.
It appears that Fort Richardson has indeed ceased taking hazardous waste from Building 726 to Hiland Road Municipal Sanitary (HRMS) Landfill. (Note: Mr. Jackson and Mr. Burns used to dispose of these containers illegally by placing them in the solid waste dumpster located out the back door (to the west) 25 ft. away from the loading dock and back door of Bldg. 726. Waste placed in this dumpster is destined for the HRMS Landfill. The former placement of the still bottoms into the dumpster constituted an illegal disposal of hazardous waste by Fort Richardson as the owner of Wilsysks Alaska Inc. as the operator). |
Tim Law |
| 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 |
| 11/17/1994 |
Enforcement Agreement or Order |
Federal Facility Agreement (FFA) under CERCLA 120 Administrative Docket # 1093-05-02-120 signed by U.S. Army, U.S. EPA, & ADEC (John Sandor). The agreement ensures that the environmental impacts associated with past & present activities at the Post are thoroughly investigated & that appropriate removal &/or remedial action(s) is/are taken as necessary to protect the public health, welfare, & the environment.
Major sources of contamination at Fort Richardson (referred to collectively here as the Fort) include areas of white phosphorus at Eagle River Flats, PCB contamination at the Roosevelt Road transmitter site, volatile organic compounds at the Poleline Road disposal area, & the fire training pits.
"Agreement" shall mean this document & shall include all Attachments to this document. All such Attachments shall be incorporated by reference & are an integral & enforceable part of this agreement.
The Project Mgrs may decide to address a source area identified in Attachment I within the scope of a Two Party Agreement (TPA) between the ADEC & the Army. In such a case, & upon unanimous written agreement of the Army, US EPA, & ADEC Project Mgrs, the agreed upon activities at the source area may commence pursuant to the TPA, Such source areas will remain within the scope of this Agreement to the extent established in Part 3.5 of Attachment I.
An outline of the planned activities for the upcoming quarter & a revised depiction of the timeline for Attachment I using the CPM process. Any revisions to the primary milestones to this timeline shall be made pursuant to the procedures specified in Part XXXIII of this Agreement.
Enforceable deadlines (subject to extension pursuant to Parts XXV & XXXIII) for the draft primary documents are established in Attachment. The Army will propose secondary document target dates not otherwise established in Attachment. Unless the Parties agree on another disposition, new source areas will be addressed under the last scheduled OU as described in Attachment I.
The purpose of Attachment 1 is to set forth the elements of work required to be performed in responding to hazardous substance/waste releases, or the threat of such releases, at or from source areas at the Fort which pose an actual or potential threat to human health or the environment.
This document provides the site management approach to implement the remedial response process under the FFA entered into by the Army, the ADEC, & the US EPA. The source areas at the Fort have been divided into 4 manageable OUs. A critical path schedule has been developed for performing the general remedial activities at each OU, & an optimal sequence has been established for addressing each OU.
The OUs at the Fort have been divided into three categories of remedial activities:
Remedial Investigation/Feasibility Study (RI/FS) OUs
Interim Remedial Action (IRA) OUs
Preliminary Source Evaluation (PSE) OUs
All response activities performed by Fort Richardson shall be consistent with the Agreement.
See site file for additional information. |
Louis Howard |
| 6/20/2000 |
Site Added to Database |
Chlorinated solvents and PCE contamination. |
Louis Howard |
| 10/19/2000 |
Meeting or Teleconference Held |
Staff attended a restoration advisory board (RAB) meeting at Russian Jack Ski Chalet. Army presented updates on the environmental activities at the two party sites and operable units. No significant comments from the public nor questions were raised at the meeting. |
Louis Howard |
| 10/20/2000 |
Meeting or Teleconference Held |
Remedial Project managers meeting held in the afternoon. Discussions were focused on the CRREL geophysical results from GPR and electronic resistivity screening. Preliminary source evaluation investigation was scoped out with 3 new wells placed at the site. Sampling of these wells and surrounding wells will help scope out the remedial investigation work. |
Louis Howard |
| 2/5/2001 |
Document, Report, or Work plan Review - other |
Staff commented on the Draft scope of work for OUE. Requested that applicable, relevant and appropriate requirements (ARARs) include 18 AAC 60 and 18 AAC 78. |
Louis Howard |
| 8/21/2001 |
Document, Report, or Work plan Review - other |
Staff commented on the Technical Letter Report Number 1 draft records review. ADEC requests clarification from the Army on why analyses for pesticides and PCBs are not being conducted on samples obtained from the AVMA. ADEC realizes that the main focus of the groundwater characterization is for chlorinated solvents, but questions the absence of any analyses for PCBs or pesticides from soil samples obtained during this investigation given the unknown history of what was disposed of at this site. |
Louis Howard |
| 9/19/2001 |
Document, Report, or Work plan Review - other |
Staff commented on the Sampling and Analysis plan for OUE. ADEC requests the Army include pesticides (e.g. aldrin, DDD, DDE, DDT, carbazole) with the parameters listed for groundwater sampling at this Operable Unit. |
Louis Howard |
| 11/8/2001 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the management plan draft for the Operable Unit. Table 4-1 Data Gaps Building 35-752 Page 4-2 - The table does not refer to diesel range organics (DRO), gasoline range organics (GRO), SVOCs, VOCs, being referenced as data to be gathered. ADEC requests the Army include these contaminants of concern (COCs) as a data gap and data to be gathered since it cannot demonstrate that these COCs were not used as a fuel to try and burn transformer oil.
4.1.2 Former Transformer Oil Burn Pit Area Page 4-3 - ADEC believes the document meant to refer to Table 4-1, which lists the number of samples and analyses. ADEC requests the Army include analysis for DRO, GRO, VOCs, and SVOCs at the Former Transformer Burn Pit Area. Currently, the table does not refer to any DRO, GRO, VOCs, and SVOCs being analyzed at this location.
4.2.3 Geophysical Anomalies Page 4-9 - ADEC requests that the Army consider not limiting the excavation depth to ten feet. Also, it is requested that the Army consider whether or not a removal action for the drums is necessary or appropriate at the time of the excavation of the test pits at the Armored Vehicle Maintenance Area.
The ARARs section appears to be referring to outdated regulations. Please refer to section 8.0 of the OUD ROD, which finds ADEC site cleanup regulations to be applicable requirements.
Section 1.1. Introduction - 18 AAC 78 regulations are not referred to as emergency regulations. Please correct text to refer to as Underground Storage Tank Regulations 18 AAC 78 (Effective August 27, 2000).
The statement about Method Two soil cleanup levels for PCBs does not correlate to note 9 of Table B1 and B2. Surface soil is defined as soil that extends no more than two feet below the surface and subsurface soil means soil that is more than two feet below the surface. Please correct text to show that ADEC has two different PCB cleanup levels for residential and industrial land use under 18 AAC 75 Table B1 footnote 9.
Section 1.2 Chemical-Specific ARARs and TBCs - Article 3 regulations contain applicable as opposed to "to-be considered" requirements. The reference to ADEC Guidance for Storage, Remediation and Disposal of Non-UST Petroleum Contaminated Soils is no longer appropriate since it has been incorporated into regulations and is no longer used.
See site file for additional information. |
Louis Howard |
| 11/21/2001 |
Long Term Monitoring Established |
Staff reviewed and commented on the groundwater sampling report. ADEC reviewed the data and wishes to point out that well AP-2982 had detected benzene at 74 ug/L and that is above the 18 AAC 75 Table C Groundwater Cleanup level of l is 5 ug/L. Also well AP-3534 had detected tetrachloroethene at 26 ug/L and the Table C groundwater cleanup level of 5ug/L. ADEC looks forward to reviewing the data from the spring and fall 2002 sampling events to see if there is seasonal fluctuation in the contaminant levels at the site. One last comment, ADEC requests the tabular data presented in the beginning of the document be separated out (see data for AP-2982 VOC footnote 7) for better readability and reviewing. |
Louis Howard |
| 12/12/2001 |
Update or Other Action |
1. All organizations conducting activities on United States Army Alaska (USARAK) controlled land are responsible for complying with established institutional controls (ICs). ICs are administrative, procedural, and regulatory measures to control human access to and usage of property. They are applicable to all known or suspected contaminated sites where contamination has been left in place.
2. These controls have been established to implement the selected remedial actions agreed upon by the U.S. Army (Army), the U.S. Environmental Protection Agency (USEPA), and the Alaska Department of Environmental Conservation (ADEC) in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) as amended by the Superfund Amendment Reauthorization Act (SARA). These controls also apply to remedial actions agreed upon under Two-Party Compliance Agreements. These agreements are concluded between USARAK and ADEC and apply to petroleum/oil/lubricants- (POL) contaminated sites.
3. ICs such as limitations on access, water use, excavations, and property transfers will supplement engineering controls as appropriate for short-term and long-term management to prevent or limit human and environmental exposure to hazardous substances, pollutants, or contaminants. Specific ICs include, among other things: limitations on the depth and location of excavations, prohibition of or restrictions on well drilling and use of ground water, requirements for worker use of personal protective equipment, site monitoring, and prohibition of certain land uses, types of vehicles, etc.
4. Organizational units, tenants, and support/contractor organizations must obtain an Excavation Clearance Request (ECR) for all soil disturbing activities impacting soils six inches or more below the ground surface. The review process for approval of an ECR begins with the identification of the current status (known or suspected hazardous waste site or “clean” site) of a work location. ECR’s for work in known or suspected hazardous waste sites:
a. will include specific limitations and controls on such work;
b. will include specific IC procedures, and notification, monitoring, reporting, and stop work requirements;
c. may include procedures for management, characterization, and disposal of any soil or groundwater encountered or removed;
d. will identify “project managers” for both the unit/contractor requesting the work and DPW Environment Resources.
5. The DPW project manager will conduct on-site inspections of each work site (at which ICs apply) to determine continued compliance with the terms and conditions of the approved ECR. DPW has the authority to revoke ECR approval if the specified terms and conditions are not being met. ECR forms are available at the Customer Service Desks at: a. Building 730 at Fort Richardson; b. Building 3015 at Fort Wainwright; c. Building 605 at Fort Greely.
6. USARAK has negotiated (with USEPA and/or ADEC) decision documents and/or Records of Decision (RODs) that mandate the implementation of ICs USARAK Directorate of Public Works, Environmental Resources Department (PWE), maintains copies of all decision documents and RODs requiring ICs in its real property files. PWE provides regularly updated post maps showing all areas affected by ICs. These maps can easily be accessed by using an approved intranet mapping interface application. Copies of these maps will be available to each directorate, activity, and tenant organization. To ensure the effectiveness of ICs, all organizational units and tenant activities will be informed on an annual basis of ICs on contaminated soils and groundwater in effect near their facilities.
7. ICs are enforceable by the U.S. Environmental Protection Agency (USEPA) and the Alaska Department of Environmental Conservation (ADEC). Failure to comply with an IC mandated in a decision document or ROD will violate the USARAK Federal Facility Agreement and may result in stipulated fines and penalties. This does not include the costs of corrective actions required due to violation of an established IC.
|
Louis Howard |
| 2/20/2003 |
CERCLA ROD Periodic Review |
Jennifer Roberts (ADEC) signed the five year review document for the Post. The objectives of the Five-Year Review are to answer the following questions:
•Are the remedies functioning as intended by the decision document?
•Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives (RAOs) used at the time of the remedy still valid?
•Has any other information come to light that could call into question the protectiveness of the remedy?
The OUD ROD concluded the likely source for groundwater contamination was not from Building 45-590. Therefore, Building 45-590 was considered NFA under CERCLA. In an attempt to identify a source area, the OUE RI investigated the AVMA site.
Based on previous investigations, the primary concern was groundwater contaminated with carbon tetrachloride and PCE. The highest concentrations of carbon tetrachloride and PCE in groundwater were observed up gradient and/or cross gradient to the suspected Building 45-590 source area. Therefore, the OUD ROD concluded the likely source for groundwater contamination was not from Building 45-590. Therefore, Building 45-590 was considered NFA under CERCLA. In an attempt to identify a source area, the OUE RI investigated the AVMA site.
Aerial photos from 1957, 1960 and 1966 show a large disturbed area east of Building 45-590 with trenches, large cylinders, stained areas and buried debris. Interviews with former employees indicated that this area was used as a lower echelon or lowest level of field maintenance for armored vehicles (tanks) with disposal of oil and other waste material. Considering this new information, it was determined that this site would be further investigated as a part of OUE. In the interim, institutional controls will prohibit access to the groundwater as a source of drinking water and, the land use at this source area and neighboring source areas will remain industrial for the foreseeable future.
The Army has completed a pre-RI soil sampling and groundwater well installation at the OUE AVMA site. The result of the soil sampling was inconclusive, but further investigation is planned. Two groundwater wells were installed and groundwater sample results indicated the presence of lead and mercury at levels exceeding drinking water standards. The draft Management Plan for the RI/FS has been prepared, which presents the approach and methodologies that will be used to conduct the remedial investigation for OUE. A groundwater sampling program has been implemented for the OUE sites and the first sampling event was conducted during September 2001. In addition, CRREL has conducted some additional geophysical investigation at the AVMA site to help determine sampling locations during the remedial investigation. Geophysical studies indicated the presence of large areas of buried metallic objects at the site; the nature of the objects will be identified during the RI. Further action requirements for this site will be documented in the OUE ROD.
Based upon new information, two remaining source areas (formerly addressed in the OUD ROD) will require additional characterization to verify the source and extent of contamination. These two sites are building 35-752 and the AVMA. Building 35-752 includes soils contaminated with PCBs and the concern at the AVMA is groundwater contamination with solvents such as TCE. |
Jennifer Roberts |
| 9/29/2003 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the human health risk assessment approach document. Staff approved the document as written pending any EPA comments on it. |
Louis Howard |
| 11/7/2003 |
Update or Other Action |
Staff reviewed and commented on the groundwater monitoring report. Staff concurs with the recommendations with this section and requests the Army consider establishing a post-wide monitoring program to include this operable unit when such a program is developed for all two-party agreement sites, CERCLA source areas, compliance agreement sites and any other site where groundwater monitoring is conducted. |
Louis Howard |
| 12/15/2003 |
Update or Other Action |
Staff reviewed and commented on the Groundwater monitoring report for OUE. Staff concurred with continued monitoring for the same contaminants of concern listed in the document with no changes in the frequency of sampling. |
Louis Howard |
| 1/7/2004 |
Risk Assessment Report Approved |
Staff reviewed and approved on the draft Remedial Investigation and Risk Assessment for OU E.
•Under the current land use scenario, no potential human health risks related to soil and groundwater in the Building 35-752 Area and the AVMA are indicated.
•Potential human health risks for the hypothetical future residential scenario related to groundwater in the 35-752 area and AVMA exceed the applicable regulatory values and require further response action.
•Potential ecological risks posed by contamination related to soil and groundwater in the Building 35-752 Area and the AVMA do not exceed the applicable regulatory values and do not require further response action.
•There is no need for interim remedial action since institutional controls are already in place restricting access to the OUE source areas. The FS will recommend suitable remedial actions.
Note to file: "Interim Remedial Actions" or "IRA" discussed in the Preamble to 40 CFR 300.430(a) (I), 55 Fed. Reg. 8703-8706 (March 8 , 1990), and shall mean all discrete actions
implemented under remedial authority that are taken to prevent or minimize the release of hazardous substances, pollutants, or contaminants so that they do not endanger human health or the environment. Interim actions shall neither be inconsistent with nor preclude implementation of the final expected Site remedy and shall be undertaken in accordance with the NCP, 40 CFR Part 300, as amended, and with the requirements of CERCLA.
The purpose of the interim remedial actions (IRA-OUs) at Fort Richardson is to achieve early action using remedial authority at those sources which meet the IRA general principles discussed in the NCP. If at any time the information submitted to support the IRA is found to be equivalent to that obtained during an RI/FS and the OU is separable, then the IRA may be upgraded to an early final action.
The Preamble of the NCP, 55 Fed. Reg. 8703-8706 (March 8, 1990), states that to implement an early action under remedial authority, an operable unit for which an interim remedial action
is appropriate should be identified. IRA decisions are intended for straightforward sites that are limited in scope. Data sufficient to support the action decision is extracted from the
ongoing RI/FS or from previous studies and an appropriate set of alternatives is evaluated. Few alternatives, and in some cases only one alternative, should be developed for interim remedial
actions.
A completed baseline risk assessment generally will not be available or necessary to justify such an action. Qualitative risk information should be organized that demonstrates that the
action is necessary to stabilize the site, prevent further degradation, or achieve significant risk reduction quickly. Supporting data, including risk information and the alternatives
analysis, can be documented in a focused feasibility study. However, in cases where the relevant data can be summarized briefly and the alternatives are few and straightforward, it may
be adequate and more appropriate to document the supporting information in the proposed plan. |
Louis Howard |
| 1/22/2004 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Feasibility study draft report. While the Department will defer to Environmental Protection Agency (EPA) in matters concerning implementation and interpretation of Toxic Substances Control Act (TSCA 40 CFR 761) the Department does have some concerns regarding the polychlorinated biphenyl (PCB) cleanup levels and Applicable or Relevant and Appropriate Requirements (ARARs) mentioned in this Feasibility Study (FS).
Building 35-752 Soil at the Transformer Mounting Area Page 2-4
The text states that TSCA cleanup level of 10 mg/kg for PCBs will be considered for Area A2. TSCA classifies soil as a remediation waste and uses either a high occupancy scenario or low occupancy scenario in determining cleanup levels:
•PCB remediation waste means soil, rags, and other debris generated as a result of any PCB spill cleanup, including, but not limited to: (1) Environmental media containing PCBs, such as soil and gravel; dredged materials, such as sediments, settled sediment fines, and aqueous decantate from sediment.
•High occupancy area means any area where PCB remediation waste has been disposed of on-site and where occupancy for any individual not wearing dermal and respiratory protection for a calendar year is: 840 hours or more (an average of 16.8 hours or more per week) for non-porous surfaces and 335 hours or more (an average of 6.7 hours or more per week) for bulk PCB remediation waste (soil).
•Low occupancy area means any area where PCB remediation waste has been disposed of on-site and where occupancy for any individual not wearing dermal and respiratory protection for a calendar year is: less than 840 hours (an average of 16.8 hours per week) for non-porous surfaces and less than 335 hours (an average of 6.7 hours per week) for bulk PCB remediation waste (soil).
The Department requests the Army provide clarification on whether or not the present and future use of the area in the vicinity of building 35-752 is either a high or low occupancy area based on the definitions outlined above. The Department believes the area is a high occupancy area unless the Army demonstrates it meets the criteria for a “low occupancy area”.
As a high occupancy area, the Army would be using the cleanup level of 1 mg/kg for PCBs unless a cap is placed over the area as required by TSCA for PCB levels between 1 mg/kg and 10 mg/kg. Additionally, the Army would have to implement institutional controls for the area. TSCA states that the cleanup level for bulk PCB remediation waste in high occupancy areas is less than or equal to 1 ppm (part per million) without further conditions. High occupancy areas where bulk PCB remediation waste remains at concentrations less than or equal to 1 ppm and less than or equal to 10 ppm shall be covered with a cap meeting the requirements of paragraphs (a)(7) and (a)(8) of this section.
See site file for additional information. |
Louis Howard |
| 5/30/2004 |
Document, Report, or Work plan Review - other |
Staff reviewed and approved the revised draft Feasibilty Study for OU E received on July 13, 2004. |
Louis Howard |
| 9/27/2004 |
Meeting or Teleconference Held |
The public meeting for the Proposed Plan will provide an opportunity for interested parties to submit written or verbal comments on this Proposed Plan, the RI/FS, or risk assessment documents. A 30-day comment period is scheduled from September 27 to October 26, 2004. Public meeting for Proposed Plan: Bldg. 35752 and Armored Vehicle Maintenance Area (AVMA). Site investigations and risk evaluations conducted for the Building 35-752 Area indicate that the contaminants found at the site do not pose a threat to human health or the environment and do not require cleanup action. Therefore, no further action is recommended for the Building 35-752 site. However, site investigations and risk evaluations performed for the AVMA indicate that contaminants detected in groundwater at the site do pose a threat to human health if groundwater is ingested. Therefore an action is recommended for the AVMA site to prohibit use of groundwater and to monitor contaminant trends in groundwater to ensure protectiveness. The preferred cleanup technology for groundwater at the AVMA site is land use controls, natural attenuation, and
monitoring.
PCBs were detected in near-surface soils at the site. Contamination in localized areas adjacent to the transformer mounting pad exceeded EPA screening values for industrial sites (concentrations ranged to about 100 mg/kg). In general, where PCBs were detected, they decreased with depth and contamination was limited to near-surface soils.
Although not mandated, the Army has decided to proceed with removal of soil contaminated with PCBs exceeding levels established by regulation (State Regulations and Toxic Substances Control Act). The soil removal will be conducted under the Toxic Substances Control Act [TSCA]) self-implementation rule and will be completed prior to the OUE ROD.
The preferred alternative for treatment of groundwater contaminated with PCE and
dibenzo(a,h)anthracene at the AVMA is Alternative 2 - Land Use Controls, Natural Attenuation, and Monitoring.
Alternative 2 is expected to achieve overall protection of human health and the environment, would be easily implementable, and would meet ARARs. Additionally, this alternative is a cost-effective and permanent solution to groundwater contamination at the AVMA. This alternative also provides
measures to prevent exposure to currently contaminated groundwater and to maintain industrial land use at the site. Because, contaminant concentrations are low and isolated, active treatment is anticipated to be difficult and less effective.
This alternative is subject to public comment and participation. No alternative will be selected until the public comment period ends and all comments are addressed. As with any remedial action under CERCLA, as long as contamination remains on site, the effectiveness of the selected remedy is
subject to periodic reviews, not to exceed 5 years. If groundwater monitoring shows a consistent increase in contaminant levels or if the remedy is no longer protective, additional measures will be evaluated. |
Louis Howard |
| 11/29/2004 |
Update or Other Action |
No written comments about the Proposed Plan for OUE remedial action were received during the comment period. Only one official comment was received during the public comment period. This comment was positive in nature . The individual commented that the Army had spent too much money investigating the site and that no further action should be taken. In general the lack of response from the community and the support from RAB indicates that the public seems to be supportive of the process undertaken at OUE. |
Louis Howard |
| 3/3/2005 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft Record of Decision for OUE. The Department requests the document identify which “screening criteria” “screening level” or “screening value” are being referred to in the document (i.e. 18 AAC 75 or EPA Region 9 Preliminary Remediation Goals (PRGs)). For example: “Only 2 samples contained dioxin/furan compounds at levels exceeding screening criteria…” Table 2-1 Screening Level, Table 5-2 Screening Value. On page 48 is the first mention of EPA Region 9 Preliminary Remediation Goals (PRGs). The words “Proposed Plan” are capitalized in various places in the document and not capitalized in other places in the document. Please ensure capitalization is consistent.
Building 35-752 Area-The text states that there is no unacceptable risk associated with groundwater at this site for unrestricted use. While this may be true, the Army’s policy or position of where there is “no unacceptable risk” and therefore, “no action” need be taken despite concentrations present which exceed an established ARAR (MCL) in groundwater is not acceptable to the Department. This “no action” decision for groundwater at Building 35-752 contradicts the remedial action objectives used for the AVMA (see Sections 1.3 and 8.2) which are to: “Prevent exposure to and use of groundwater with chemical concentrations that pose an unacceptable risk or exceed applicable or relevant and appropriate requirement (ARARs).
The Department has not waived the 18 AAC 80 drinking water MCLs or 18 AAC 75 Table C groundwater cleanup levels as ARARs for groundwater containing TCE above 5 µg/L at Building 35-752. In previous meetings with EPA and the Army, it was informally agreed that the general trend for TCE in groundwater appears to be decreasing at the site, the Department does not dispute this trend.
It may only take one or two additional groundwater sampling events by the Army to confirm that TCE concentration is decreasing further and is either at or below 5 µg/L. The Department requests the Army revise the document to either include monitored natural attenuation for groundwater as the remedy for Building 35-752 or alternatively, state in the document that groundwater sampling will be done before the next five-year review (February 22, 2008) to reconfirm the general trend of decreasing concentrations has continued as predicted and the MCL has been met.
The Department suggests rephrasing the text to include exclusions for wells installed for domestic or industrial uses in addition to drinking water wells being prohibited from installation at the site. |
Louis Howard |
| 5/23/2005 |
Document, Report, or Work plan Review - other |
Staff reviewed & commented on the draft record of decision for OUE. General Comments - ADEC requests the document identify which “screening criteria” “screening level” or “screening value” are being referred to in the document (i.e. 18 AAC 75 or EPA Region 9 Preliminary Remediation Goals (PRGs)). For example: “Only 2 samples contained dioxin/furan compounds at levels exceeding screening criteria…” Table 2-1 Screening Level, Table 5-2 Screening Value. On page 48 is the first mention of EPA Region 9 Preliminary Remediation Goals (PRGs). The words “Proposed Plan” are capitalized in various places in the document & not capitalized in other places in the document. Please ensure capitalization is consistent.
2.2.1 Building 35-752 Area -The Army’s policy or position of where there is “no unacceptable risk” & therefore, “no action” need be taken despite concentrations present which exceed an established ARAR (MCL) in GW is not acceptable to ADEC. This “no action” decision for GW at Building 35-752 contradicts the remedial action objectives used for the AVMA (see Sections 1.3 & 8.2) which are to: “Prevent exposure to & use of GW with chemical concentrations that pose an unacceptable risk or exceed applicable or relevant & appropriate requirement (ARARs).
ADEC has not waived the 18 AAC 80 drinking water MCLs or 18 AAC 75 Table C GW cleanup levels as ARARs for GW containing TCE above 5 µg/L at Building 35-752. In previous meetings with EPA & the Army, it was informally agreed that the general trend for TCE in GW appears to be decreasing at the site, ADEC does not dispute this trend.
It may only take one or two additional GW sampling events by the Army to confirm that TCE concentration is decreasing further & is either at or below 5 µg/L. ADEC requests the Army revise the document to either include monitored natural attenuation for GW as the remedy for Building 35-752 or alternatively, state in the document that GW sampling will be done before the next five-year review (February 22, 2008) to reconfirm the general trend of decreasing concentrations has continued as predicted & the MCL has been met.
2.2.3 Building 955-Sludge Bin Page 20 & 2.2.4 Building 796-Battery Shop - To be consistent, ADEC requests either removing the bold font in 35-752 discussion of soil & GW NFA or to bold the font for 955 & 796.
Tables 2-4 & 2-5 - These tables are the only two in the document that are not discussed in their respective sections where the results are mentioned, but the tables are not. ADEC requests incorporation of text, in the appropriate section, similar to the following: Table 2-4 summarizes the information about the sample locations & concerns related to the Building 955. Table 2-5 summarizes the GW sample results from Building 796.
See site file for additional information. |
Louis Howard |
| 6/24/2005 |
Document, Report, or Work plan Review - other |
Staff reviewed and approved the draft groundwater monitoring report for OUE. |
Louis Howard |
| 7/5/2005 |
Document, Report, or Work plan Review - other |
Staff received and reviewed the draft final version of the OUE Record of Decision. Errors were found in the maximum contaminant level (MCL) column and staff requested they be corrected in the final version of the document. |
Louis Howard |
| 9/15/2005 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the draft final record of decision for operable unit E. ADEC has reviewed the document and based upon our subsequent discussions, it appears that ADEC’s comments provided in July 5, 2005 letter have been addressed. This letter provides our concurrence with the draft-final and requests that a final version of the OU E Record of Decision be prepared for our signature. |
Louis Howard |
| 10/11/2005 |
Institutional Control Record Established |
ADEC signed off on the Record of Decision for Operable Unit E which identified: Land Use Controls/Institutional Controls (ICs)- ICs will be implemented, maintained, reported on, & enforced by the Army to restrict the access to & use of GW at the AVMA until GW quality has been restored (contaminant concentrations are less than MCLs), thereby allowing unrestricted use of the GW. The anticipated time frame to achieve remedial goals is anticipated to be about 30 years, but could be more or less depending upon site conditions.
The performance objectives of the ICs for the AVMA are: The installation or use of GW supply wells at the site is prohibited until the cleanup standards (which would allow for unrestricted use of the GW) are achieved throughout the GW plume. The integrity of any current or future monitoring wells will be maintained. Monitoring wells may be installed/replaced & GW extracted for monitoring purposes.
The details regarding the implementation, monitoring, & periodic inspection, & maintenance of the ICs to attain these objectives will be placed in a remedial design document or in a remedial action work plan prepared by the Army. Within 90 days of ROD signature (estimated to be January 31, 2006), the Army shall prepare & submit to EPA for review & approval an IC remedial design that shall contain implementation & maintenance actions, including periodic inspections. In general, the Army plans that all ICs will be implemented under the Fort Richardson Institutional Control Policy & Master Plan. ICs will be implemented to cover the PCE-contaminated GW area.
The Army also commits that: Any activity that is inconsistent with the IC objectives or use restrictions, or any other action that may interfere with the effectiveness of the ICs will be addressed by the Army as soon as practicable, but in no case will the process be initiated later than 10 days after the Army becomes aware of the activity. The Army shall notify EPA & ADEC 45 days in advance of any proposed land use changes that are inconsistent with land use control objectives or the selected remedy.
The Army will provide notice to EPA & ADEC at least six months prior to any transfer or sale of the AVMA so that EPA & ADEC can be involved in discussions to ensure that appropriate provisions are included in the transfer terms or conveyance documents to maintain effective ICs. If it is not possible for the Army to notify EPA & ADEC at least six months prior to any transfer or sale, then the Army will notify EPA & ADEC as soon as possible but no later than 60 days prior to the transfer or sale of any property subject to ICs. In addition to the land transfer notice & discussion provisions above, the Army further agrees to provide EPA & ADEC with similar notice, within the same time frames, as to federal-to-federal transfer of property.
The Army shall provide a copy of executed deed or transfer assembly to EPA & ADEC. The Army shall not modify or terminate Institutional Controls or Land Use Controls, implementation actions, or modify land use without approval by EPA & ADEC. The Army shall seek prior concurrence before any anticipated action that may disrupt the effectiveness of the ICs or any action that may alter or negate the need for ICs. Monitoring of the environmental use restrictions & controls will be conducted annually by the Army. The monitoring results will be included in a separate report or as a section of another environmental report, if appropriate, & provided to EPA & ADEC.
See site file for additional information.
|
Jennifer Roberts |
| 10/12/2005 |
CERCLA ROD Approved |
ADEC signed off on the Record of Decision for AVMA.
The preferred alternative was chosen after considering very conservative assumptions for determining human health risk. The following are the major components of the remedy: Land Use Controls/Institutional Controls (LUCs/ICs), Natural Attenuation and Monitoring
Monitoring at the OUE source areas would be conducted to ensure that RAOs are achieved. The goals of this monitoring include, but are not limited to, the following: To ensure that migration of contaminated GW from the source areas to downgradient aquifers or surface waters is reduced or prevented, To indicate contaminant levels & compliance with MCLs & Alaska Water Quality Standards, To ensure that natural attenuation is occurring over time within the PCE contaminated GW area of the site to reduce levels of all contaminants & breakdown products to levels less than MCLs within a 30-year time period.
The data collected during the OUE RI strongly suggest that PCE in GW at the AVMA resulted from vehicle maintenance & laundry operations conducted at Buildings 732 & 726, respectively. Historical data show that PCE was used at the laundry facility & low levels of PCE were detected in soils at the Building 726 site during the OUD RI. There appears to be a direct link between the Building 726 site & the downgradient contamination. It is highly likely that PCE contamination from the former underground tanks located at Building 726 had been removed during excavation of the USTs or had migrated downgradient prior to the time the OUD RI had been conducted.
Thus, soil & GW samples collected directly at the site did not contain high levels of solvents. In addition, the OUD data appear to be biased by the fact that the GW samples were not collected from the unconfined aquifer in the area between Building 726 & Building 45-590. GW samples collected during the OUE RI from wells installed in the unconfined aquifer indicated that PCE contamination was present, & that there was a contaminant pathway linking the Building 726 site with the PCE contamination found near Building 45-590.
GW contamination was detected immediately downgradient from the Building 732 location during the OUD RI. Low levels of PCE contamination were detected in well AP-3789 & could indicate a link to vehicle maintenance activities conducted at Building 732.
See Site File for additional information. |
Jennifer Roberts |
| 1/31/2006 |
Update or Other Action |
There are no remedial action capital costs because the remedy for OUE did not involve construction. In addition there are no OU specific monitoring costs because the monitoring costs are included in the site wide operation & maintenance (O&M) costs The estimated cost for operation and maintenance through the post-record of decision (ROD) period between 2006 and 2035 was $465,000. At the present time, the Army’s projected cost-to-complete is $783,000, about 68 percent greater. The difference is the result that the ROD estimate did not account for site documentation and well decommissioning costs that are realized at closure. |
Louis Howard |
| 3/1/2006 |
Document, Report, or Work plan Review - other |
Staff reviewed and approved the Draft Groundwater Monitoring Report OU E-AVMA. In accordance with the OUE ROD, groundwater samples will be collected annually from 15 wells located at the AVMA site. The adapted schedule indicates that 15 wells will be sampled annually for 4 years, biennially for 6 years, and then every 5 years for 20 years following signature of the ROD, or until sampling indicates that contaminant levels have dropped below cleanup standards. Thus, annual sampling is planned during 2006, 2007, 2008, 2009, 2011, 2013, 2015, 2020, 2025, 2030, and 2035 (or as determined necessary).
Sampling will be conducted during the fall to coincide with other annual sampling events, generally late August or September. This sampling schedule would be consistent with on-going monitoring at the site. Monitoring will be discontinued when at least three subsequent sampling events indicate that contaminant concentrations have consistently dropped below cleanup standards. If the monitoring results for any two consecutive sampling events indicate that contaminant concentrations are increasing, then EPA, ADEC, and the Army will reevaluate the remedy to ensure protectiveness.
Staff requested that the chain of custody forms be more legible for samples received at the laboratory. As presented in the document, the forms are too faint to read. |
Louis Howard |
| 10/2/2006 |
Update or Other Action |
Environmental Protection Agency issues a Preliminary Close Out Report (PCOR) which documents that US Army Garrison, Alaska (USAG-AK) has completed all construction activities for the Fort Richardson Superfund Site (“the site”), in accordance with the U.S. Environmental Protection Agency (EPA) guidance, Close Out Procedures for National Priorities List Sites (OSWER Directive 9320.2-09A-P, January 2000). EPA and the Alaska Department of Environmental Conservation (ADEC) have determined that USAGAK constructed and/or implemented the remedies in accordance with remedial design (RD) plans and specifications. USAGAK has initiated activities necessary to achieve performance standards and site completion.
Remedy Selection: The operable unit (OU)E record of decision (ROD) was signed on September 30, 2005. The Building 35-752 site was determined to require no further action (NFA). Solvent contaminated groundwater at the armored vehicle maintenance area (AVMA) was determined to pose a potential risk to human health because calculated risk estimates exceeded acceptable risk ranges and solvent concentrations in groundwater exceeded maximum contaminant levels (MCLs) for drinking water. The remedy selected for the AVMA site included implementation of land use controls (LUCs), reduction of contaminants through natural attenuation (NA), and monitoring to ensure protectiveness. The OUE ROD also presented additional data for the OUD sites, Building 792 and Building 955, and determined that both required NFA under CERCLA.
Remedial Action: The OUE ROD required remedial action at the AVMA site, but the required actions did not involve construction. LUCs have been implemented through an existing enforcement policy and monitoring is being conducted using existing wells. Pre-ROD remedial actions have been taken at the Building 35-752 site.
Remedial actions at OUE have been implemented in accordance with the ROD and the remedial design work plan. Implementation of the remedy at the AVMA site did not require construction of a treatment system. The remedy is complete and operational at this time.
OU-E is the final Operable Unit to be completed at the Ft. Richardson site, however no Final Inspection was necessary as no construction was required. Final Inspections were conducted on various dates at earlier OUs that did require construction, as reported in the RA reports. For OUE the RPMs met several times to review monitoring results and confirm the selected remedy was performing as expected. At the most recent such meeting on September 14, 2006 it was confirmed that the remedy was operational and functional, ICs are in place, and no construction is necessary for OUE. ICs have been implemented to restrict the access to and use of groundwater at Poleline Road (OUB) and at the AVMA (OUE) until groundwater quality has been restored (contaminant concentrations are less than MCLs), thereby allowing for unrestricted use.
Demonstration of Cleanup Activity Quality Assurance and Quality Control: All remedial work has been conducted in accordance with approved Quality Assurance Project Plans (QAPPs) and Sampling and Analysis Plans (SAP) that outlined procedures for collection, handling, and analysis of samples to ensure quality and representativeness. Sample analysis was conducted by laboratories approved to conduct EPA and ADEC analytical procedures. Analytical results have been reviewed and results documented in accordance with QA procedures established through the Corps of Engineers, laboratory data validation process. |
Louis Howard |
| 1/19/2007 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft Groundwater Monitoring Report OUE Armored Vehicle Maintenance Area, Fort Richardson, AK December 2006 Contract# W911KB-05-D-0010, Task Order 05. Appendix C Data Quality Evaluation Report
Analytical Data Pages C-2 and C-5 - The text states the assessment of the data included a review of “the chain-of-custody documentation; initial and continuing calibration information and other method-specific criteria as defined by the Alaska QAPP.”
In future documents submittals which reference and use the Alaska Lab Data Review Checklist, please reference the version and data of the checklist being used (i.e. version 2.2 10/06) in the text of the document. Since this report has been drafted, a newer version of the data review checklist (version 2.3 11/06) has been posted at ADEC’s web page: http://www.dec.state.ak.us/spar/guidance.htm#csp under the Analytical Methods and Quality Assurance section of the web page. For the purposes of this draft groundwater monitoring document, version 2.2 of the check list will suffice.
The text states under “Chain of Custody” section that no other discrepancies were noted. Notably absent from the text or included appendices are the chain-of-custody forms. Without these forms, ADEC nor EPA can verify whether or not any other discrepancies are present. ADEC requests the chain-of-custody forms for samples collected be included in this report and submitted as soon as possible to the agencies for their review.
The ADEC Contaminated Sites Program Technical Memorandum - 06-002, dated October 9, 2006, for Environmental Laboratory Data and Quality Assurance Requirements states:
Laboratory Data: The complete analytical laboratory report(s) shall be included as part of all submittals to the department for which environmental samples have been collected, analyzed and reported. The laboratory reports shall contain, at a minimum, the following information:
Minimum Requirements for Laboratory Data Reports for Samples (absent from this report): ...(20) a sample receipt form documenting the condition of the samples and the ambient temperature of the interior of the shipping container adjacent to the sample container (or temperature blank) WHEN RECEIVED by the laboratory; (21) a copy of the Chain of Custody(ies) (COC) for each sample or group of samples, including COC for samples transferred to alternate locations
*Note: The “raw” analytical data, e.g. bench sheets, chromatograms, calibration data, etc., are not required submittals, however, must be retained on file by the laboratory for at least ten years after the analysis date. |
Louis Howard |
| 2/8/2007 |
Exposure Tracking Model Ranking |
|
Louis Howard |
| 2/27/2008 |
CERCLA ROD Periodic Review |
The United States Army Alaska (USARAK) conducted the second Five-Year Review of the remedial actions at the Fort Richardson National Priorities List (NPL) site, Anchorage, Alaska, from November 2007 through February 2008. This report presents the results of that review.
The purpose of this review is to ensure that remedial actions selected in the Records of Decisions (RODs) for the Fort Richardson Operable Units (OUs) are being implemented and that they continue to be protective of human health and the environment. To achieve this purpose, this review evaluates the status of implementation of the selected remedies, identifies significant variances from the RODs, and makes recommendations for reconciling variances and/or for improving performance of remedial actions.
The remedy at OUE is expected to be protective of human health and the environment upon attainment of groundwater cleanup goals through natural attenuation. In the interim, exposure pathways that could result in unacceptable risks are being controlled and ICs are preventing exposure to, or ingestion of, contaminated groundwater.
ICs are in place per APVR-RPW (200-1) and APVR-RPW-EV-(200-1c) and are effectively controlling exposure pathways that could result in unacceptable risk. Contaminant plume is not growing, although concentrations in some wells within the plume have fluctuated. Groundwater is monitored annually at the site; the data is used to determine concentration trends and is discussed by the RPMs at regularly scheduled FFA Meetings.
Natural attenuation parameters (dissolved oxygen [DO], iron, methane, sulfate, and
nitrate/nitrite) were also analyzed in all the wells. The 2007 results were similar to previous
results. DO concentrations indicate that conditions within the plume are aerobic, which are not
favorable for reductive dechlorination of PCE. The concentrations of the other parameters (along with the lack of PCE daughter products) suggest that biodegradation plays a limited role
in natural attenuation at the site. The primary natural attenuation pathway for PCE at the AVMA
is considered to be dilution. However, it should be noted that because natural attenuation has
only been monitored at this site since 2005, there is limited data and further evaluation may be
necessary to determine if natural attenuation is occurring at the site.
The selected remedy for this site is implementation of ICs for groundwater use at the site, along
with regular groundwater monitoring that includes monitoring of natural attenuation. The ICs for
this site appear to be properly maintained and enforced. Monitoring results indicate that the
contaminant plume is generally stable, although one well within the plume has shown an
increasing trend. Because the plume is stable, natural attenuation appears to be occurring with
the primary process being dilution. The lack of any breakdown products and the stability of the
natural attenuation parameters indicate that no significant biodegradation is occurring.
Based on these results, the existing monitoring network appears to be adequate and there does
not appear to be any reason to make changes to the remedy as specified in the ROD. There are
no recommendations or follow-up actions for the AVMA at this this time. |
Jennifer Roberts |
| 4/8/2008 |
Document, Report, or Work plan Review - other |
EPA comments on the November 2007 groundwater monitoring report. 1. Figure 2-1, Groundwater Monitoring Locations and Results, Page 2-3: Figure 2-1 shows the approximate extent of tetrachloroethylene (PCE) contamination. Please describe the parameters which were used to define the approximate extent of PCE contamination.
2. Section 4.3.1, Analysis of Trends for PCE, Page 4-4: The first three paragraphs presents a discussion of the Mann-Kendall (M-K) analysis performed on the PCE concentration trends for six groundwater monitoring wells, however, the M-K analysis is not provided. Please provide the M-K analysis discussed in the text in table form in which the six wells are listed along with their respective M-K concentration trends.
3. Section 4.3.5, Natural Attenuation Parameters, Page 4-6: The lack of PCE daughter products and historically low presence of petroleum products suggesting that biodegradation plays a limited role in natural attenuation at the site is mentioned at the end of Section 4, Results. The lack of PCE daughter products should be discussed prominently and early in Section 4, Results, preferably in Section 4.2.1, Volatile Organic Compounds, and Section 4.2.3, Natural Attenuation Parameters (Biodegradation Indicators). |
Louis Howard |
| 2/25/2010 |
Update or Other Action |
Dept. of Army Installation Management Command, HQ U.S. Army Garrison Fort Richardson, Office of the Garrison Commander sent letter to ADEC.
This letter serves as formal notice under Paragraph XXXII, Transfer of Property, of the Fort Richardson, Alaska (FRA) Federal Facility Agreement (FFA), that the property under the jurisdiction of the U.S. Army will be transferred to the Joint Base Elmendorf-Richardson (JBER) effective October 1, 2010.
This letter also serves as formal notice that effective October 1, 2010, responsibility for the FRA FFA, dated December 15, 1994, will be transferred to the senior official of the JBER Supporting Component, United States Air Force (USAF). This transfer of responsibility is in accordance with the Memorandum of Agreement (MOA) between the USAF and United States Army (USA), and was signed by the Vice Chief of Staff for the USAF and the Vice Chief of Staff for the USA on October 9, 2009.
Based on the MOA and previous discussions with US EPA (reference March 2009 FRA FFA meeting in Seattle with representatives of the EPA Region 10, Elmendorf AFB and Fort Richardson), it is our understanding your agency agrees the management and oversight of the FRA FFA may properly transfer to the JBER Restoration Project Manager (RPM), and such transfer does not constitute a significant change, such as to require formal renegotiation of the Agreement or the preparation of an amendment to the Record of Decision.
If you have any questions or concerns about this matter, please contact Therese Deardorff, Chief, Environmental Division, U.S. Army Garrison Fort Richardson, Alaska 907.384.3074. |
Louis Howard |
| 6/21/2010 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft OUE Groundwater monitoring report (December 2008).
2.3 Monitoring Frequency Page 2-2
The text states the site is currently being monitored twice a year even though the 2005 Record of Decision states that the wells will be sampled annually for four years, biennially for six years and then every five years following the 20 years. ADEC requests the Army and EPA consider reducing the monitoring frequency to once a year until the next five year review and then to biennially after the five year review. A Memo to the Site File signed by all three agencies is needed on whatever frequency changes are proposed and decided upon which differs from what is in the Record of Decision for cost purposes.
Natural Attenuation and Monitoring Page 87 of the 2005 ROD
“…it is assumed that fifteen (15) existing monitoring wells will be sampled for GRO/BTEX, VOCs, and natural attenuation parameters and that the wells will be sampled annually for 4 years, biennially for 6 years, and then every 5 years for the following 20 years. Monitoring will be discontinued when at least three subsequent sampling events indicate that contaminant concentrations have consistently dropped below MCLs. If the monitoring results for any two consecutive sampling events indicate that contaminant concentrations are increasing, then EPA, ADEC, and the Army will reevaluate the remedy to ensure protectiveness.
The selected remedy uses ground water monitoring:
• To establish concentration trends and provide an early warning if the downward concentration trend does not continue
• To determine the effectiveness of the remedy”
2.4 Groundwater Monitoring Parameters Page 2-2
The text states in addition to VOCs, (as contaminants of concern from the 2005 OUE ROD), groundwater is also being monitored for arsenic and aluminum. ADEC requests the remedial project managers from ADEC, EPA and the Army sign a Memo to the Site File which drops arsenic and aluminum as from the groundwater monitoring program as analytes at OUE.
The OUE ROD states in Table 7-2 Page 53 “Summary of Risk Estimates for Groundwater at the AVMA” that 10% of the primary contributor to total HI included aluminum (HQ=21). Aluminum does not have a drinking water standard (MCL) in 18 AAC 80, nor does it have a groundwater cleanup level in Table C of 18 AAC 75. ADEC considers aluminum a secondary MCL only for those public water systems which ADEC determines that public health is threatened or exceeding a secondary MCL is not in the public interest. ADEC believes the aluminum is an artifact of low flow sampling and suspended soil particles present in the groundwater and has not been released to the environment from past or present site conditions/use/practices at OUE.
EPA treats aluminum as a National Secondary Drinking Water Regulations (NSDWRs or secondary standards) which are non-enforceable guidelines regulating contaminants that may cause cosmetic effects (such as skin or tooth discoloration) or aesthetic effects (such as taste, odor, or color) in drinking water. EPA recommends secondary standards to water systems but does not require systems to comply. However, states may choose to adopt them as enforceable standards.
The OUE ROD states in Table 7-2 that 85% of the primary contributor to Total ELCR is from Arsenic (4.8-04), arsenic. However, there is not a source of arsenic which can legitimately be attributed to OUE past or present site conditions/use/practices. Arsenic is more than likely indicative of natural conditions or background levels in groundwater at OUE.
|
Louis Howard |
| 2/7/2011 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 74296 name: historical surface spills |
Bianca Reece |
| 3/18/2011 |
Update or Other Action |
Staff received the Armored Vehicle Maintenance Area GW Monitoring report for May & September 2009.
Tetrachloroethene (PCE) is the COC at the AVMA & was detected in each of the six wells within the known extent of contamination at concentrations above the MCL documented in the OUE ROD. No other trends are apparent from the historical monitoring data except for the increasing PCE concentration trend interpreted at wells AP-3468 & AP-4342.
To date, PCE has tended to oscillate within two standard deviations of the mean for each well, with very few exceptions. Overall, increasing or decreasing trends are not definitively apparent. Individual well concentrations throughout the area have varied by anywhere from less than 1 µg/L to more than 90 µg/L between events. The most recent results appear to fall within the normal range of variability. Definitive trends in PCE concentrations at the AVMA may become apparent over time as monitoring continues & more data are collected.
A Mann-Kendall (M-K) statistical analysis was performed to help statistically identify PCE concentration trends at the AVMA in wells within the extent of contamination. According to the M-K analysis, a statistically significant increasing PCE concentration trend exists at wells AP-3468 & AP-4342. The results for the four other wells within the extent of contamination do not show a statistically significant trend for PCE.
The use of a “seasonal” version of the M-K analysis was also considered. This version of M-K analysis is useful in identifying trends when seasonal variations (often related to fluctuations in GW levels) are affecting concentrations. At the AVMA, however, GW elevations are not highly variable & do not show strong seasonal variations. In addition, sampling has not been conducted on a consistent seasonal schedule, which makes sorting results into “seasons” difficult. As a result, the use of a seasonal M-K analysis was determined to not be useful at this site.
Samples from the three downgradient wells (AP-3774, AP-3870, & AP-3871) & crossgradient well AP-3893 have historically produced PCE results ranging from non-detect to occasional low-level concentrations that are less than the MCL of 5 µg/L. Except for the PCE detected in well AP-3774 (0.650 J µg/L in May & 0.560J ug/L in September), PCE was not detected in the three downgradient wells or the cross-gradient well. These data suggest that the extent of contamination continues to remain relatively unchanged.
VOC breakdown products (TCE, DCE, cis-DCE, trans-DCE, & VC) of PCE biodegradation were not detected, indicating that these compounds do not exist in the AVMA wells within the extent of PCE contamination. This continued trend suggests that biodegradation is not occurring through reductive dechlorination pathways.
The other detected VOCs, including carbon tetrachloride & chloroform, continue to exist in AVMA wells both within & outside the extent of PCE contamination. These analytes are frequently detected at concentrations less than established MCLs & tend to fluctuate between non-detect & several µg/L (see Figure 2-1).
These compounds are not breakdown products of PCE & appear to exist at the site independently from PCE contamination. Chloroform is a daughter product of anaerobic carbon tetrachloride degradation, which suggests that anaerobic degradation of carbon tetrachloride may be occurring on site. No significant increasing or decreasing trends are evident for these compounds.
See site file for additional information.
|
Louis Howard |
| 5/19/2011 |
Update or Other Action |
Wing Instruction 32-7003 dated May 19, 2011 Land Use Control Management. OPR: 673 CES/CEANR Certified by: 673 CEG/CC (Col Russell R. Hula). This instruction implements AFPD 32-70, Environmental Quality, & is used in conjunction with AFIs 32-7020, The ERP, 32-7066, Environmental Baseline Surveys in Real Estate Transactions, & 673ABWI 32-1007, Safeguarding Utilities From Damage.
It prescribes the processes & responsibilities for the management of & compliance with land use controls on Joint Base Elmendorf-Richardson (JBER) & applies to all military & civilian organizations that occupy facilities, or conduct business, on the installation. This publication does not apply to the USAF Reserve or Air NG units & members. The current land use control areas can be found on the Environmental Restoration map located on the GeoBase webpage.
General:
1.1. Land use controls (LUC), such as limitations on access, water use, excavations, & property transfers, will supplement engineering controls as appropriate for short-term & long-term mgt to prevent or limit human & environmental exposure to hazardous substances, pollutants, or contaminants. Examples include limitations on the depth & location of excavations, prohibition of or restrictions on well drilling & use of GW, mgt. of excavated soils, & prohibition of certain land uses. LUCs, often used interchangeably with (ICs), are administrative, procedural, engineering, & regulatory measures to control human access to & use of property.
1.2. LUCs were established at JBER to prevent exposure to contaminated soil & water, based on agreements between the military services & the EPA & the ADEC. LUCs are used to reduce the potential for exposure to hazardous substances or to enhance the protectiveness of a soil &/or water cleanup remedy. They include restrictions on the use of portions of the shallow aquifer south of the Elmendorf Moraine, limitations on the types of buildings allowed in certain areas – primarily occupancy limitations, & land use designations for certain areas as recreational use only.
The LUCs have been implemented at several sites & operable units (OU) as part of the ERP. LUCs were established for DP98 & OUs 1, 2, 4, 5, & 6 on former Elmendorf AFB property in their respective records of decision (ROD), as a component of the selected cleanup remedy. LUCs were also established for restoration & compliance sites formerly part of Fort Richardson in their respective RODs or Decision Documents. LUCs must be in place as long as a property is not available for UU or UE & may include temporary or permanent restrictions or requirements. When all cleanup goals have been achieved for a given site, temporary controls, such as GW use restrictions, may be removed.
2. Responsibilities:
2.1. JBER personnel, tenants, or contractors whose projects or activities require excavation in areas where site-specific LUCs are in effect will comply with all LUCs, 673ABWI 32-1007, & applicable AF instructions. Base contractors & tenant organizations will have LUC compliance requirements incorporated into their contracts & interagency agreements, as will be necessary. Failure to comply with LUCs will be grounds for penalty, in accordance with provisions specified in applicable contract documents. At project completion, the JBER organization or contractor will sign a certification of LUC compliance & return the compliance statement to 673 CES/CEANR.
See site file for additional information.
|
Louis Howard |
| 7/15/2011 |
Update or Other Action |
Staff received the Draft Work Plan Environmental RA-O & LTM & Maintenance Joint Base Elmendorf-Richardson, Alaska. Field Activities for the JBER-Richardson OUB & OUE sites will include GW sampling, soil sampling (during well installation), GW monitoring, well installation & decommissioning, monitoring well maintenance, & the installation of concrete jersey barriers for site protection. The contractor will coordinate with Base Operations for the OUB & OUE sites to eliminate unnecessary delays or interruptions to military operations.
Samples will be collected in August 2011 for both OUB & OUE. Monitoring activities at each site will include an initial GW level survey for later use in developing potentiometric maps, followed by GW sample collection. A GW level survey will be conducted prior to GW sample collection at each site. Elevations will be determined during the initial visit to the site by using a depth sounder to measure water levels at all the wells to be included in the 2011 sampling program. The depth to water measurements will later be converted to elevations based on known top-of-casing elevation information.
Samples collected at OUE will be analyzed for the following:
-VOCs by SW8260B
-Sulfate by E300.0
-Nitrate/nitrite by E353.2
-Methane/ethane/ethene by RSK175
-Dissolved metals (iron, and manganese) by SW6020
Split-spoon soil sampling will be conducted during well installation at OUB & OUE. The total number of samples designated for each borehole is intended to allow an average of one sample for every 10 feet. Actual sample depths will be determined based on professional judgment or based on other determining factors such as changes in soil conditions, high PID readings or target GW zones.
Sample collection will be conducted using decontaminated or disposable sampling equipment. After collection, all sample containers will be quickly & adequately sealed, & rims will be cleaned before tightening lids; tape will be used only if known not to affect sample analysis. Samples will be field logged according to ASTM D2488-09A & submitted for laboratory analysis.
Wells will be replaced (including the decommissioning of the existing well & installation of a new well in close proximity) at both OUB & OUE. The wells to be replaced include AP-3748 & AP-4019 at OUB, & one undetermined well at OUE. Replacement wells will be installed a minimum of 16 feet from the decommissioned well to avoid impacts from grouting.
See site file for additional information. |
Louis Howard |
| 7/25/2012 |
Update or Other Action |
Draft 2011 GW Monitoring & Borehole Sampling report received.
Ten wells were sampled between August 23 and September 1, 2011, at the AVMA including six wells within the extent of contamination, three downgradient wells, and one cross-gradient background well. Samples were analyzed for VOCs and natural attenuation parameters including iron, manganese, sulfate, methane, and total nitrate/nitrite. Conclusions based on historical and current data through the August and September 2011 monitoring event are as
follows:
- Tetrachloroethene (PCE) is the only established COC for OUE AVMA. The area of the extent of PCE contamination appears to be stable and contained; samples from the three downgradient wells continue to have ND results. No significant increasing or decreasing trends in the PCE-affected area are statistically apparent from the historical monitoring data.
VOC breakdown products (TCE, DCE, cis-DCE, trans-DCE, and VC) of PCE biodegradation were not detected, indicating that these compounds do not exist in the AVMA wells within the extent of PCE contamination. This continued trend suggests that biodegradation is not occurring through reductive dechlorination pathways.
The other detected VOCs, including carbon tetrachloride and chloroform, continue to exist in AVMA wells both within and outside the extent of PCE contamination. These analytes are frequently detected below established MCLs and tend to fluctuate between ND and several µg/L (see Figure 2-1). Because they are not breakdown products of or likely to be associated with PCE, these VOCs appear to exist at the site independently from PCE contamination.
- The results of biodegradation parameters and the absence of PCE breakdown products continue to suggest that biodegradation of PCE may be limited at the AVMA and that the primary mechanism of natural attenuation at the site continues to be dilution. For sites where biodegradation is not playing a key role in the attenuation process, monitoring and evaluation of biodegradation parameters provide very little value towards the understanding of the site contaminant conditions. Detected concentrations of other VOCs (carbon tetrachloride and chloroform), which are considered to be independent of the PCE contamination, continue to exist at low levels (below MCLs) and do not demonstrate increasing or decreasing trends.
- Dissolved aluminum, which has been detected sporadically in some of the OUE AVMA wells, is currently believed to be natural (background).
- Arsenic levels in groundwater at the AVMA remained below MCLs within the area of PCE-affected groundwater through the November 2010 monitoring event. The only MCL exceedances for arsenic continued to be from cross-gradient well AP-3893, and are not believed to be associated with activities at the AVMA and are likely associated with natural sources
- The OUE site has LUCs in place prohibiting the excavation and offsite transport of contaminated soil and the restriction of groundwater use at the site. Based on the LUC site inspection and the Base Civil Engineer Work Clearance Request process JBER-Richardson has in place to perform any intrusive activities at the site, the LUCs appear to be protective and prevent exposure to contaminated soil and groundwater at the site and continue to be effectively implemented. |
Louis Howard |
| 9/21/2012 |
Update or Other Action |
Draft Basewide UFP-QAPP received. This UFP-QAPP encompasses activities at 141 sites on JBER during the 8 year contract POP. The project approach is to advance sites to site closeout utilizing Optimized Exit Strategies (OES). Activities will include investigations/characterizations, remedial actions, active and passive remediation, long term monitoring/management and the use of the Hydrocarbon Risk Calculator (HRC), where applicable. |
Louis Howard |
| 12/18/2012 |
Document, Report, or Work plan Review - other |
EPA provided comments on the draft 3rd 5-Year Review (FYR).
The draft report deviates from the “Comprehensive Five Year Review Guidance”, EPA OSWER No. 9355.7-03 B-P (June 2001) in that for two issues & two OUs the report concludes the answer to the question about whether the issue may affect future protectiveness the answer given is “TBD”. The only options available consistent with the guidance are “yes” or “no”, & when the answer is uncertain, the appropriate response is “Yes” the issue may affect protectiveness, in this case future protectiveness. From that, the appropriate conclusion for each of those OUs in terms of protectiveness is one of the following:
1. “protectiveness deferred”, with recommendations & followup actions to be taken to resolve the uncertainty (which the Guidance calls for the lead agency to do within 1 year);
2. “currently protects, & in order to remain protective for the long term the following factions need to be taken:...” ; or
3. “Not protective” & say what will be done about the issue.
If protectiveness if deferred, the Guidance calls for issues to be resolved in 1 year if at all possible.
Monitored Natural Attenuation (MNA) is a selected remedy for both OUB & OUE, so performance monitoring of MNA is an important component of the FYR Report; however, the FYR Report does not include discussion of geochemical parameters, & it is unclear whether groundwater monitoring even includes geochemical parameters. Changes in the geochemical setting as indicated by geochemical parameters (particularly the redox parameters such as redox potential, dissolved oxygen, nitrate/nitrite, manganese (II), iron (II), sulfate, & methane) may suggest there are changes in biotic or abiotic processes affecting the rate & extent of natural attenuation, so monitoring of these parameters is key for performance monitoring of MNA. Please revise the FYR Report to include discussion of geochemical parameters at OUB & OUE & what the parameters indicate about MNA at these sites.
The Draft Third CERCLA [Comprehensive Environmental Response, Compensation, & Liability Act] Five-Year Review Report (the FYR Report) does not fully demonstrate the selected remedy at Operable Unit (OU) E is protective of potential vapor intrusion (VI) to indoor air exposure. Specifically, the FYR Report states manned facilities are present in the vicinity of the tetrachloroethene (PCE) plume associated with the Armored Vehicle Maintenance Area (AVMA) site, indicating a potential for VI to occur to those buildings. While the FYR Report does conclude that the potential VI exposure pathway will be assessed at the AVMA site, it appears the evaluation will not be performed until the next FYR Report (e.g., “Milestone Date” 2015).
It is recommended the VI evaluation be conducted at this time to determine if additional mitigation/action is necessary. Otherwise, at a minimum, land use controls (LUCs)/institutional controls (ICs) will be required to ensure that site personnel are not utilizing any of the OUE site buildings located within the zone of influence. ICs should be used to help ensure long-term protectiveness effectively prohibiting, restricting, preventing, or informing receptors of the potential impacts regarding VI (U.S. Environmental Protection Agency [EPA] Draft Assessing Protectiveness at Sites for Vapor Intrusion: Supplemental Guidance to the “Comprehensive Five-Year Review Guidance” [the Supplemental Guidance], 2011). Please refer to Questions A through C of the Supplemental Guidance & revise the FYR Report to address these questions in the context of VI.
Further, it should be noted that any building located within 100 feet of groundwater exceedances of VI criteria should be incorporated in the VI assessment. Target groundwater concentrations corresponding to an indoor target risk of 1E-05 or 1E-06 may be calculated using current toxicity criteria as outlined in Appendix D of the EPA 2002 Draft Guidance for Evaluating the Vapor Intrusion to Indoor Air Pathway from Groundwater & Soils (the Subsurface VI Guidance). However, please note the target groundwater concentration should not be truncated to the Maximum Contaminant Level (MCL) as was done for the original Subsurface VI Guidance screening level tables. Please provide a comparison of current groundwater concentrations to groundwater VI criteria to help demonstrate that the current conditions & remedial action objectives (RAOs) are protective of this exposure pathway.
EPA R10 recently published guidance (OEA Recommendations Regarding Trichloroethylene Toxicity in Human Health Risk Assessments, December 13, 2012) for assessing Vapor Intrusion based on TCE toxicity using non-cancer, not-to-be-exceeded. |
Louis Howard |
| 2/19/2013 |
CERCLA ROD Periodic Review |
The Alaska Department of Environmental Conservation (ADEC) has received the above document
for review on February 12,2013. ADEC appreciates the opportunity to review the third Five Year
Review report for the Fort Richardson (now JBER-R) Superfund site, in Anchorage Alaska. ADEC
reviewed this report for technical adequacy, accuracy, and consistency with EPA guidance and the
Fort Richardson Federal Facility Agreement. Also included are additional recommendations and
follow-up actions necessary to address issues raised in the Five Year Review that affect or could affect protectiveness. In general, ADEC agrees with the protectiveness determinations in this report.
OUB Poleline Road
ADEC concurs that the remedy for OUB Poleline Road Disposal Area is currently protective
through implementation of Land-Use Controls (LUCs) However, to be protective in the long-term,
JBER must conduct additional monitoring to augment the monitoring well network in the shallow
aquifer to defme the downgradient limit of the plume. Additionally, the remedial action objectives for OUB COCs need to be updated based on changes in the toxicity factors (e.g. 1,1,2,2- tetrachloroethane for groundwater and soil and tetrachloroethylene for soil). The 1997 Record of Decision RAOs were based on 10-4 risk-based concentrations and a residential exposure scenario.
OUC Eagle River Flats
ADEC concurs that the remedy for OUC Eagle River Flats is currently protective of human health
and the environment based on current use as an active military range. The long term RAO at Eagle
River Flats has been met under current site use: ".Within 20 years of the ROD being signed to
reduce the mortality attributable to white phosphorus to no more than 1 percent of the total annual fall population of dabbling ducks in the ERF". Resumption of year-round flring at Eagle River Flats may change site conditions and waterfowl mortality in such a way that mayor may not affect
protectiveness of the remedy in the future.
OUE Armored Vehicle Maintenance Area (AVMA)
ADEC concurs with the deferred protectiveness determination for OUE AVMA pending an
assessment in 2014 of the vapor intrusion pathway at buildings above the A VMA plume, An
addendum to the Five-Year Review report should be prepared which incorporated the results of the
assessment and any change on protectiveness for OUE.
ADEC appreciates the Air Force's efforts in completing the Third Five Year Review and your
project team on addressing ADEC's comments to fInalize the document. ADEC, EPA and JBER
project managers have an excellent working relationship and ADEC looks forward to continuing
this spirit of cooperation into the future. |
Louis Howard |
| 5/30/2013 |
Update or Other Action |
Draft Annual Field Activities report received for review & comment.
This report summarizes the 2012 annual long-term management activities, including remedial action-operation (RA-O) & Record of Decision (ROD) requirements conducted at Joint Base Elmendorf-Richardson (JBER) CERCLA sites. The United States Air Force (USAF) has mandated a reduction of long-term environmental liabilities & life-cycle costs through accelerated cleanup of contaminated sites.
Acceptance criteria for this project are specified in the Draft Basewide UFP-QAPP, criteria specified in the analytical lab standard operating procedures (SOPs), & accepted analytical methods. Overall, the data have met the quality control acceptance criteria specified for this project. Nonconformances of data are identified, discussed, & qualified in this report. When possible, direction of potential bias is assigned.
In September 2012, samples were collected from 10 groundwater monitoring wells at DA085 and analyzed for VOCs and natural attenuation parameters (including chloride/sulfate, nitrate/nitrite, dissolved iron and manganese, methane, ethane, and ethene). LUC inspections were conducted in September 2012.
As shown in Table 3-1 and Figure 3-1, PCE was detected above the MCL in six of the 10 monitoring wells sampled. Table 3-1 also shows BTEX results. Benzene, which had not previously been detected at the site, was detected in one monitoring well, but at a concentration well below federal MCLs. A graphical representation of PCE trends based on these results is provided on Figure 3-2. A Mann-Kendall statistical analysis with a confidence interval of 90 percent or above was performed to identify any PCE concentration trends at the site. No significant increasing or decreasing trends in the PCE-affected area were identified as statistically apparent from the historical monitoring (see Figure 3-2).
Geochemical results (including laboratory and field measured parameters) were evaluated to assess natural attenuation at DA085. Laboratory measured parameters include VOCs and natural attenuation parameters (including chloride/sulfate, nitrate/nitrite, dissolved iron and manganese, methane, ethane, and ethene). Field measured parameters (using an YSI 556) include pH, conductivity, turbidity, DO, temperature, and ORP.
Site Summary
An OES Performance Plan for DA085 was finalized in February 2013 under the current PBR contract. The OES at DA085 includes performing an in situ treatment treatability study and continuing long-term monitoring as outlined in the OUE ROD. The treatability study will be conducted to assess the viability of enhanced reductive dechlorination (or other appropriate substrates) at the site.
|
Louis Howard |
| 6/12/2013 |
Update or Other Action |
Draft work plan for DA085 received for review and comment.
This Work Plan describes an enhanced reductive dechlorination (ERD) treatability study at
DA085. This site-specific Work Plan follows the Uniform Federal Policy-Quality Assurance
Project Plan (UFP-QAPP) format, and the work will be performed under the Joint Base
Elmendorf-Richardson, Basewide Uniform Federal Policy – Quality Assurance Project Plan
(United States Air Force [USAF], 2013a).
The objectives of the treatability study are to assess the effectiveness of ERD using emulsified
vegetable oil (EVO) injections for the reduction of PCE concentrations in groundwater at the site and to determine injection hydraulics and radius of influence (ROI) of the injections. The
effectiveness of the injections will be evaluated by calculating reductions in the concentration of PCE in the treatment area compared to the baseline concentration.
ERD will be evaluated during this treatability study to meet the objective of enhancing
monitored natural attenuation. It is anticipated that the selected treatment will reduce
contaminant mass in areas of relatively high concentrations, thereby reducing the restoration
timeframe and life-cycle costs. Based on the results of this treatability study, the final selection of the remedial technology will consider technical feasibility of implementation.
The treatability study will consist of injecting a total of 4,000 gallons of an EVO solution (see Appendix A) into four injection wells. The injection wells will be placed perpendicular to
groundwater flow and upgradient from the selected performance monitoring well (AP-4413)
within the target treatment zone. The target treatment zone identified for this treatability study (Figure 3) is the saturated aquifer surrounding monitoring well AP-4413. AP-4413 had a
historical PCE concentration exceeding 100 µg/L.
Treatability study activities will include the following:
Install four injection wells upgradient from AP-4413. Injection wells will be installed
approximately 15 feet apart, generally perpendicular to groundwater flow, and approximately 15 feet upgradient from the performance well.
Install one monitoring well between two of the injection wells to verify ROI.
Collect soil samples for natural oxidant demand (NOD), fraction of organic carbon (foc), and
grain size analysis from the targeted portion of the contaminated aquifer during well
installation to refine understanding of the aquifer conditions relative to injection hydraulics
and, potentially, the applicability of in situ chemical oxidation (ISCO) (as a contingency, in
the event that EVO is not successful).
Collect baseline groundwater samples at the performance well and the four injection wells
after well installation/development and prior to injection.
Inject approximately 1,000 gallons of an EVO solution (Appendix A) in each injection well.
?
Perform quarterly groundwater sampling at AP-4413 (i.e., performance monitoring) for
analysis of chlorinated volatile organic compounds and daughter products, total organic
carbon, volatile fatty acids, dissolved gases, reduced metals, and water quality parameters.
Groundwater monitoring will be performed on a quarterly basis for 1 year following injection
of the EVO solution and biannually thereafter.
|
Louis Howard |
| 6/21/2013 |
Document, Report, or Work plan Review - other |
Staff provided comments on the OUE Treatability Study work plan.
WS #17 Sampling Design and Rationale
Well Installation
The text states: “Prior to drilling, utility locates will be performed in accordance with SOP-04 to identify potential underground hazards. In the event underground utilities or structures cannot be definitively identified, an air knife and vacuum truck may be used to clear the upper 6 feet of the proposed drilling location prior to drilling or conducting other invasive activities. Once clearance activities have been completed in the upper 6 feet of the soil column, soil removed during utility clearance will be placed back into the hole from which it was removed.”
This 6 ft. interval shall not be excluded from field screening, sampling and IDW containerization requirements due to utility investigation activities with an air knife.
While ADEC does not have a RCRA program nor is it a RCRA authorized State, it is providing the following comments (subject to EPA Region 10 official comments regarding RCRA):
There are likely to be RCRA implications for the soil removed in this six foot interval that will not allow it to be replaced back in the “excavation” once removed from the ground. Chlorinated solvents may be present at this site in the soil. The Federal Facility Agreement states:
The purposes of the Federal Facility Agreement list RCRA (among other purposes):
“Assure compliance, through this Agreement, with RCRA and other federal and state hazardous waste laws and regulations for matters covered herein.
RCRA/CERCLA Integration
Therefore, the Parties intend that activities covered by this Agreement will achieve compliance with CERCLA, 42 U.S.C. 5 9601 & seq.; satisfy the corrective action requirements of Sections 3004(u) and (v) of RCRA, 42 U.S.C. § 6924(u) and (v), for a RCRA permit, and section 3008(h), 42 U.S.C. 5 6928 (h) , for interim status facilities; and meet or exceed all applicable or relevant and appropriate federal and state laws and regulations, to the extent required by section 121 of CERCLA, 42 U.S.C. § 9621, and applicable state law.
The Parties agree that with respect to releases of hazardous waste or hazardous constituents covered by this Agreement, RCRA shall be considered an ARAR pursuant to Section 121 of CERCLA, 42 U.S.C. § 9621. Releases or other hazardous waste activities not covered by this Agreement remain subject to all applicable state and federal environmental requirements.”
Subject to EPA comments on the matter, it appears that any drill cuttings or soil from the air knife operations shall need to be contained and characterized to determine whether or not they are a waste under RCRA that requires proper disposal/treatment. Clean fill will need to be stockpiled or available for placement should any of the soil removed be found to exceed applicable cleanup levels.
Table 18-1 Proposed Sampling Locations and Methods
Soil samples for soil extracted during air knifing activities will need to be added to the table.
WS #20 Field QC Summary
Soil
The table will need to include those samples required for VOC analysis from the air knifing activities.
Add VOCs (SW8260 preserved with methanol for ADEC requirements and one set of samples without methanol-low level e.g. sodium bisulfate to satisfy EPA requirements) to soil for any drill cuttings and soil removed during air knifing or drilling operations for waste characterization and disposal requirements.
In this case, it is ADEC’s expectation that when both analyses are performed; the methanol is the primary analysis for all COCs and the low level as the secondary line of evidence for those compounds not meeting required detection levels.
|
Louis Howard |
| 7/18/2013 |
Document, Report, or Work plan Review - other |
EPA comments on the draft OUE AVMA DA085 Treatability Study work plan.
WS #5
Will the EVO injections be subcontracted?
WS #9
Please add notes of 4/30/13 scoping meeting with Louis Howard, Sandra Halstead, & Marcia Knadle (via phone).
notes/comments
Marcia K. provided reference document of Scott Huling's paper on GW monitoring with injections, & the suggestion to use warm water in the injection matrix so the temp change can indicate the distribution of the injection plume.
Page 19
GW
The information presented in Table 10-2 has not been previously reviewed by EPA nor approved. If this data is in the draft 2012 Annual Monitoring Report, the 2012 draft report was distributed for review on June 10, two days prior to this workplan. Suggest a change the introductory sentence to read " Results from the pre-draft 2012 GW..."
Page 24
DQOs
The DQOs presented below are logical, but do not fit into any of the 4 DQOs as offered in WS #11 of the UFP-QAPP. Perhaps a DQO specific to treatability studies should be developed.
WS #14 & 16
Project Tasks
There are no SOPs listed in the UFP-QAPP for injection or injection monitoring. Please provide SOPs for these activities. It is acknowledged W#17 provides a good understanding of the basic premise, but would not be sufficient as a field protocol to conduct injections or injection monitoring.
Page 34
GW Sampling & Analysis (performance monitoring)
The schedule needs to clarify when the quarterly performance monitoring will begin. If it is soon after injection, be aware that the presence of injected chemicals in the sample can bias the results low, effectively by continuing to destroy contaminants in the sample between collection & analysis. It can also cause serious analytical interferences.
The phrase 'full scale remedy implementation' is used a few times throughout the document. By adding 'future full scale remedy implementation' helps to clarify this as a treatability study & not a remedy that has been vetted through the CERCLA process.
Page 35
Contingency Measures
Approval of this work plan does not allow for the contingency plans 1-3 to proceed without additional regulator approval.
WS #17
TS Design
It’s hard to continue to call this natural attenuation when an active treatment is being applied. Please consider removing the references to natural attenuation.
|
Louis Howard |
| 5/12/2014 |
Update or Other Action |
Draft TS Implementation Report received.
An assessment of the current remedy, which consists of institutional controls, natural attenuation of tetrachloroethene (PCE) in GW, & long-term monitoring, has estimated the remedial timeframe to achieve cleanup goals &, subsequently, site closeout (SC) at approximately 120 years. This study will evaluate whether the injection of emulsified vegetable oil (EVO) into a PCE-contaminated aquifer is able to enhance the natural degradation of PCE (known as enhanced reductive dechlorination), speed up the cleanup process, & reduce overall life-cycle costs. Additionally, the treatability study will test how easily EVO can be injected into the ground & how far it will travel.
Based on the performance monitoring data collected during the treatability study, additional remedial actions (contingency measures) may be employed at DA089 if ERD is unsuccessful at reducing PCE concentrations. Contingency measures are outlined in the Work Plan (USAF, 2013a). The decision logic with regard to implementation of contingency actions & subsequent monitoring requirements applies to the periods both during & after the study; the decision logic may be applied to the selected full-scale remedial alternatives, if necessary, for the site in the ROD. Contingency measures will not be implemented without additional regulatory approval.
One contingency outlined in the Work Plan was the use of ISCO by injecting sodium permanganate, depending upon the results of the NOD analyses from DA089. The results of soil NOD & foc analyses show variability in subsurface soils. The subsurface soil type is generally consistent in the target treatment area (typically sands & gravels with silt), & the distribution of NOD & foc do not appear to be related to specific soil types based on the grain size distributions. Typically, NOD results greater than 10 g/kg suggest limited applicability of permanganate treatment. Therefore, because NOD exists at concentrations greater than 10 g/kg within the target treatment zone, it is likely that any potential future contingency use of ISCO would be inefficient & expensive to implement.
PCE Variability within the Target Treatment Zone
Baseline GW samples were collected from one injection well, one ROI well, & one performance monitoring well within the target treatment zone prior to the injection of EVO substrate to assess the variability of PCE concentrations within the target treatment zone. While there is slight variability in PCE concentrations (75.7 to 117 µg/L) within the target treatment zone based on these three data points, PCE concentrations are generally similar to each other (less than half an order of magnitude difference) & to historical PCE concentrations. The lack of variability in PCE concentrations within the target treatment zone suggests that the effects of ERD treatment caused by EVO substrate injection within the target treatment zone should be relatively uniform.
See site file for additional information. |
Louis Howard |
| 5/13/2014 |
Document, Report, or Work plan Review - other |
Staff provided comments on the TS Implementation report (draft).
Executive Summary
The text states: “The Air Force Civil Engineer Center (AFCEC) has implemented a treatability study at DA089 (formerly known as DA085) – Armored Vehicle Maintenance Area (AVMA) to assess the effectiveness of enhanced reductive dechlorination (ERD) for treating contaminated groundwater at the site.”
ADEC requests the text state: “The Air Force Civil Engineer Center (AFCEC) has implemented a treatability study at DA089 (formerly known as DA085) – Armored Vehicle Maintenance Area (AVMA), an Operable Unit (OU) E source area, to assess the effectiveness of enhanced reductive dechlorination (ERD) for treating contaminated groundwater at the site.”
The text states: “An assessment of the current remedy, which consists of institutional controls…”
ADEC requests the text state: “An assessment of the current selected remedy for AVMA source area in OU E, which consists of institutional controls…”
Treatment of the groundwater is not natural attenuation as selected as a remedy in the ROD for AVMA under CERCLA. Discussion on the potential paths forward allowed for under CERCLA as one of the three Post-ROD changes needs to be discussed, if not in this document, in the Treatability Study Completion Report. The categorization of a post-ROD change to the selected remedy is a site-specific determination and must consider the following as set out in NCP §300.435(c)(2):
• Scope. Does the change alter the scope of the remedy (e.g., type of treatment or containment technology, the physical area of the response, remediation goals to be achieved, type and volume of wastes to be addressed)?
• Performance. Would the change alter the performance (e.g., treatment levels to be attained, long-term reliability of the remedy)?
• Cost. Are there significant changes in costs from estimates in the ROD, taking into account the recognized uncertainties associated with the hazardous waste engineering process selected? (Feasibility Study cost estimates are expected to provide an accuracy of +50 percent to -30 percent.)
Based on this evaluation, and depending on the extent or scope of modification being considered, the lead agency (JBER) must make a determination as to the type of change involved (i.e., nonsignificant or minor, significant, or fundamental change).
Post-ROD changes fit into one of the three following categories:
1) Non-significant or Minor Changes usually arise during design and construction, when modifications are made to the functional specifications of the remedy to address issues such as performance optimization, new technical information, support agency/community concerns and/or cost minimization (e.g., value engineering process). Such changes may affect things such as the type or cost of materials, equipment, facilities, services, and supplies used to implement the remedy. The change will not have a significant impact on the scope, performance or cost of the remedy.
2) Significant Changes generally involve a change to a component of a remedy that does not fundamentally alter the overall cleanup approach
3) Fundamental Changes involve an appreciable change or changes in the scope, performance, and/or cost or may be a number of significant changes that together have the effect of a fundamental change. An example of a fundamental change is one that results in a reconsideration of the overall waste management approach selected in the original ROD.
(EPA 540-R-98-031 OSWER 9200.1-23P PB98-963241 July 1999)
Introduction
Page 1-1
1st Paragraph
ADEC requests the text state: “This document provides the details and documentation of the field and construction activities associated with the enhanced reductive dechlorination (ERD) substrate injections for the Treatability Study at DA089 (formerly known as DA085) – Armored Vehicle Maintenance Area (AVMA), a source area in Operable Unit E, located at Joint Base Elmendorf-Richardson (JBER), Alaska (Figure 1-1). An assessment of the current selected remedy, which consists of institutional controls…”
2nd Paragraph
ADEC requests the text state: “A Treatability Study Completion Report will be prepared following four quarters of performance monitoring to document results and conclusions and to provide recommendations for future Post-ROD CERCLA actions for Air Force, EPA and ADEC consideration.”
Page 1-2
1st Bullet
ADEC requests the text state: “Evaluate amendment dosing requirements and lateral spacing of injection points (radius of influence) required for full-scale application at DA089, pending a Post-ROD change (i.e. ROD amendment).”
|
Louis Howard |
| 5/13/2014 |
Document, Report, or Work plan Review - other |
Staff provided comments on the treatability study (draft).
The text states: “The Air Force Civil Engineer Center (AFCEC) has implemented a treatability study at DA089 (formerly known as DA085) – Armored Vehicle Maintenance Area (AVMA) to assess the effectiveness of enhanced reductive dechlorination (ERD) for treating contaminated GW at the site.”
ADEC requests the text state: “The Air Force Civil Engineer Center (AFCEC) has implemented a treatability study at DA089 (formerly known as DA085) – Armored Vehicle Maintenance Area (AVMA), an Operable Unit (OU) E source area,…”
Treatment of the GW is not natural attenuation as selected as a remedy in the ROD for AVMA under CERCLA. Discussion on the potential paths forward allowed for under CERCLA as one of the three Post-ROD changes needs to be discussed, if not in this document, in the Treatability Study Completion Report. The categorization of a post-ROD change to the selected remedy is a site-specific determination & must consider NCP §300.435(c)(2).
Introduction
The text states: “No COCs were identified for soil.” This was technically correct in 2005 when the ROD was signed that no COCs were identified for soils. However it should be noted, for future reference, that the RI results for PCE exceeded the current migration to GW cleanup level (18 AAC 75, October 2012) set at 0.024 mg/kg. The TCE migration to GW cleanup level of 0.020 mg/kg was also exceeded in one soil boring. The Region 9 PRG Industrial PRG (EPA 2002) for PCE of 3.4 mg/kg was used as the cleanup level & the PRG for TCE at 0.11 mg/kg were used for screening levels in the RI & referenced in the 2005 ROD for OU E.
In 2005, when the ROD was signed for OU E, ADEC did not have promulgated cleanup levels for PCE or TCE. The industrial 2002 EPA Region 9 PRGs were used instead for soil. The Third Five-Year Review for OU E AVMA source area does not specifically address newly promulgated standards for PCE & TCE under Changes to Standards & ARARs discussion.
While not a part of this particular treatability study, this overlooked issue will need to be addressed at the next (Fourth) Five-Year Review in 2018. PCE & TCE soil contamination will need to be incorporated as part of the 2014 vapor intrusion study that was recommended as a follow-up action in the Third Five-Year Review for AVMA source area since the majority of the PCE soil contamination is within 100’ of the ground surface. The pilot test (aka treatability study) will not address the potential vapor intrusion issues with the soil contaminated with PCE at AVMA.
See site file for additional information.
|
Louis Howard |
| 5/14/2014 |
Update or Other Action |
Draft 2013 Annual Field Activities Report received. This report summarizes the 2013 annual long-term management activities, including remedial action-operation (RA-O) and Record of Decision (ROD) requirements, conducted at Joint Base Elmendorf-Richardson (JBER) Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) sites. The United States Air Force (USAF) has mandated a reduction of long-term environmental liabilities and life-cycle costs through accelerated cleanup of contaminated sites. As such, the Performance-Based Remediation (PBR) initiative has been developed to protect human health and the environment in a cost-effective manner, while at the same time reducing life-cycle costs.
In April 2012, Weston Solutions, Inc. (WESTON) was awarded a PBR contract from the Air Force Civil Engineer Center (AFCEC) (Contract Number FA8903-09-D-8589, Task Order No. 0016). The contract includes performing RA-O and ROD requirements at several JBER sites. The WESTON team performing the activities summarized in this report consists of WESTON and CH2M HILL Constructors, Inc. (CH2M HILL). WESTON executed project work on sites located within JBER-Elmendorf, while CH2M HILL executed project work on sites located within JBER-Richardson.
In August 2013, samples were collected from 10 groundwater monitoring wells at DA089 and
analyzed for VOCs and natural attenuation parameters (including chloride/sulfate, nitrate/nitrite,
dissolved iron and manganese, methane, ethane, and ethylene). LUC inspections were also
conducted; inspection forms are included in Appendix B. Field forms are included in Appendix
A. The project location on the field forms and notes is labeled as DA085 because the site name
change to DA089 was not requested by AFCEC until October, 2013; after the field effort had
been completed.
As shown in Table 16-1 and Figure 16-1, PCE was detected above the MCL in five of the 10
monitoring wells sampled. The PCE concentration in AP-4411 was previously above the MCL,
but dropped below it in this year’s sampling event. Other analytes were detected but were below
the associated cleanup level. Table 16-1 shows the laboratory results of all detected analytes. A
graphical representation of PCE trends based on these results is provided on Figure 16-2. A
Mann-Kendall statistical analysis with a confidence interval of 90% or above was performed to
identify any PCE concentration trends at the site. Well AP-4413 has a decreasing trend. No other
wells show a statistically significant trend in the PCE-affected area.
An Optimized Exit Strategy Performance Plan for DA089 was finalized in February 2013 under
the current PBR contract. The Optimized Exit Strategy at DA089 includes performing an in-situ
treatment treatability study and continuing LTM as outlined in the OUE ROD. The treatability
study is currently being conducted to assess the viability of enhanced reductive dechlorination
(or other appropriate substrates) at the site. |
Louis Howard |
| 6/12/2014 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (ADEC) has received the above document electronically on June 11, 2014. Upon review of the responses by the Air Force, ADEC has no objection to the responses and the Air Force may finalize the document, pending incorporation of EPA comments on the document. ADEC’s review and comment on this work plan is to ensure that the work is done in accordance with State of Alaska environmental conservation laws and regulations. While ADEC may comment on other state and federal laws and regulations, our comments on the work plan do not relieve responsible persons from the need to comply with other applicable laws and regulations.
The Air Force is responsible for the actions of contractors, agents, or other persons who perform work to implement the approved work plan. For any activity that significantly deviates from the approved plan, the Air Force shall notify the ADEC and EPA to obtain written approval in the form of a work plan amendment before beginning the activity. |
Louis Howard |
| 6/13/2014 |
Document, Report, or Work plan Review - other |
The Alaska Department of E nvironmental (ADEC) has received the responses to ADEC's
comments for review and comment on June 13, 2014 via electronic mail. AD EC concurs with the
responses to its comments for DA089 CS DB Hazard ID 3321. Pending incorporation of EPA's
comments, the document may be finalized. |
Louis Howard |
| 9/4/2014 |
Document, Report, or Work plan Review - other |
ADEC has reviewed the addendum to the Final Uniform Federal Policy-Quality Assurance Project Plan (UFP-QAPP), DA089 –Armored Vehicle Maintenance Area Treatability Study Work Plan (Treatability Study Work Plan) (United States Air Force [USAF], 2013). ADEC approves the Air Force's implementation of Contingency 1 as presented below and further clarified in the draft work plan addendum, pending incorporation of any EPA comments/concerns. ADEC has no further comments on the work plan addendum.
" After 1 year of quarterly monitoring, if the concentration of PCE in groundwater measured in the performance monitoring well (AP-4413) has not been reduced by at least 50 percent or groundwater geochemical parameters do not indicate that the aquifer has become sufficiently anaerobic to support ERD, then Contingency 1 will be implemented.
• Contingency 1: Conduct another round of EVO injections, possibly with the addition of a ferrous sulfate solution, depending upon the success of the treatability study at CG039, or injection of ISCO using sodium permanganate, depending upon the results of the NOD analyses and effectiveness of ISCO injection during the treatability study at CG039. Similar subsurface geology at CG039 and DA085 should allow for similar results of various treatments."
|
Louis Howard |
| 11/5/2014 |
Document, Report, or Work plan Review - other |
EPA provided comments on the draft CERCLA report.
Comment: There are seven LUC well security/integirty concerns for DA089 in App B; how are those incorporated into the report or repaired prior to the next sampling event? |
Louis Howard |
| 7/23/2015 |
Update or Other Action |
Draft Field Activities Report received for review & comment.
An OES Performance Plan for DA089 was finalized in February 2013 under the current PBR contract. The OES at DA089 includes performing an in situ bioremediation treatability study & continuing long-term monitoring as outlined in the OUE ROD. Implementation of the treatability study began in 2013, when injection wells were installed & an EVO substrate was injected into the shallow perched aquifer near AP-4413. Following the initial EVO injection (September 2013), three quarters of GW monitoring followed. Results showed that, although geochemically reducing conditions were evolving, PCE concentrations were not decreasing.
Therefore, contingency decisions were made prior to analyzing the final round of quarterly performance monitoring data in an effort to implement the contingency action during the 2014 field season. The contingency action included conducting another round of EVO injections & adjusting the design parameters as follows:
The EVO volume was tripled to increase the mass of carbon in the aquifer. The total injection volume was tripled to improve distribution.
The mass of lactate injected into the aquifer was tripled to accelerate the evolution of anaerobic conditions. The EVO substrate was changed to 100 percent Terra Systems SRS-FR (5-micrometer [µm] droplet size) which has larger droplets to help retain more EVO near the injection zone.
This second round of EVO injections was completed on October 15, 2014. The first quarterly GW sampling of monitoring well AP-4413 to further evaluate the performance was conducted on March 17, 2015, & monitoring is currently ongoing.
Five-Year Review
DA089 is required to have CERCLA five-year reviews conducted until such time as the cleanup goals are achieved. The purpose of the five-year review is to evaluate the implementation & performance of the remedial actions. To date, three CERCLA five-year reviews have been performed for JBER-Richardson (which includes DA089), in 2003, 2008, & 2013. The third five-year report conducted in 2013 recommended that the potential vapor intrusion pathway be assessed for the site. Additionally, because natural attenuation had been shown to be limited at DA089, & in an effort to meet the 30-year time frame stated in the OUE ROD, a pilot study of an enhanced natural attenuation technology (Anaerobic Biodegradation using EVO) was recommended.
The first recommendation is being addressed by a forthcoming vapor intrusion investigation. The ongoing treatability study satisfies the second recommendation
Future Five-Year Reviews for OUs B, C, and E are necessary because COC concentrations remain above levels that allow for unlimited use of the site and unrestricted exposure to the air,
soil, and water. The next JBER-R Five-Year Review will be in April 2018.
|
Louis Howard |
| 8/10/2015 |
Document, Report, or Work plan Review - other |
Staff provided comments on the Annual CERCLA Report. Staff commented on the need to conduct groundwater sampling for 1,4-dioxane associated with TCE contamination. |
Louis Howard |
| 10/27/2016 |
Update or Other Action |
Draft Treatability Study (TS) Report received for review & comment. The following conclusions have been drawn based on pre-injection data collection, 2 rounds of EVO injections, & 8 rounds of quarterly GW monitoring at AP-4413:
• Use of sodium permanganate was not a viable treatment option because of the high & heterogeneous NOD results from across the site. Results from GW samples collected from injection wells prior to substrate injections indicated that PCE within each target treatment zone were similar to each other & to historical PCE levels.
• Design of the TS was sufficient to distribute substrate throughout the target treatment zone. The aquifer readily accepted the injection of EVO substrate at rates between 20 to 35 gpm, with an observed distribution radius of influence of at least 15 feet. Geochemical parameters indicate that the injection of EVO has proven effective in generating anaerobic conditions necessary for reductive dechlorination in the aquifer. However, there are indications (such as increasing ORP & decreasing TOC) that anaerobic conditions in the aquifer may only be sustainable for short time frames (2 to 3 years) after injection.
• As of December 2015, PCE in GW at well AP-4413 have been reduced by 70% when compared to the 2013 pre-injection levels. However, PCE has begun to increase (23.7 µg/L in December 2015) since reaching a low of 5.56 µg/L (over 90% reduction) in March 2015. Generation of vinyl chloride & ethene through the degradation of DCE indicates that a microbial consortium capable of facilitating complete dechlorination of PCE is present in the subsurface. However, while the appropriate microbes are present, it is not yet known if the population is sufficiently robust to effectively reduce all CAHs.
Based on the results of this treatability study, the following actions are recommended:
• Annual GW monitoring for 2 years (2016 & 2017) to assess potential rebound of PCE, continued degradation of PCE daughter products, & persistence of reducing GW conditions.
- The annual GW monitoring will be modified to better monitor the progress of the TS. Analytical & field parameters will be added as necessary so that performance monitoring well AP-4413 continues to be monitored as outlined in Table 18-1 of the Work Plan. 2016 & 2017 GW monitoring work plans will formally outline this plan.
- Continuing TS monitoring results from AP-4413 will be reported in a distinct section of the annual GW monitoring report
See site file for additional information. |
Louis Howard |
| 1/13/2017 |
Update or Other Action |
ADEC received a GW monitoring report for several JBER sites which summarizes the 2015 annual long-term management (LTM) activities, including remedial action-operation (RA-O) & ROD requirements conducted at JBER CERCLA sites.
Site DA089 has been identified as a Yellow priority because there are no significant decreasing
PCE trends outside of the well within the target treatment zone of the treatability study.
Based on the results of this annual field activities report and the treatability study implementation report (USAF, 2014e), the following actions are recommended:
In accordance with the recommendation from the 2014 Field Activities Report CERCLA Sites (USAF, 2014f), groundwater sampling and analysis at monitoring wells AP-3870 and AP-3893 will cease in 2016. Measurement of water levels will continue at these wells during annual monitoring events.
Continue annual groundwater monitoring at the remaining wells within the monitoring program. |
Louis Howard |
| 11/7/2017 |
Update or Other Action |
Letter report received for CY2016 [January 1, 2016 - December 31, 2016] Annual Land Use Control (LUC) and Institutional Control (IC) Monitoring at Joint Base Elmendorf-Richardson (JBER). This letter serves as the annual monitoring report on the status of LUCs/ICs in place on JBER-Elmendorf (JBER-E) and JBER-Richardson (JBER-R). The Air Force ensures compliance with LU Cs by conducting periodic monitoring and site inspections. Formal LUC/IC inspections occur annually on JBER during late spring through early fall and are typically conducted by contract. A total of 55 sites were formally inspected. Random site inspections are also conducted throughout the year by JBER Restoration staff.
Discrepancies: 2 of the 3 protective bollards surrounding monitoring well AP-3870 are broken;
one lying on the 1?round, the other severally bent. No damage to the well.
See site file for additional information. |
Louis Howard |
| 11/30/2017 |
Update or Other Action |
Draft VI report received for review & comment. Drums containing ExxonMobil DF-2000 dry cleaning solvent were identified at Building 726 during the building survey. The DF-2000 dry cleaning solvent is chemically similar to the MIL-PRF-680 Type II solvents identified in solvent parts cleaners in Buildings 6211 & 17534, & consists of naphtha/synthetic isoparaffinic hydrocarbons (petroleum distillates). Available historical information confirms that PCE was used as a dry cleaning solvent at Building 726 until the mid to late 1990s (U.S. Army, 1998), but no information is available regarding when PCE use was discontinued. Building 726 is located partially within the DA089 GW contamination plume boundary & PCE is the only COI. The depth to GW is approximately 70 feet bgs.
Based on the maximum detected indoor air results, which was for a sample location in the basement, the total HI exceeded 1 at a value of 3 & the cumulative cancer risk was below 1x10-4 at 1x10-5 (see Table 10.1) for an indoor worker at Building 726.
The highest PCE level, by one order of magnitude, was identified in the northernmost sample location (nearest to the GW contamination plume boundary). The highest indoor air sample result for PCE also was located in the northernmost portion of the basement. Basement indoor air levels also were higher than first floor indoor air levels. These results suggest the presence of a complete VI pathway. Based on the above lines of evidence, the VI pathway is considered complete at Building 726.
Most of Building 728 is located within the DA089 GW contamination plume boundary & PCE is the only COI. PCE was detected in indoor & outdoor air during both sampling events, with indoor & crawlspace air levels higher than outdoor air results during FSE2. The crawlspace air concentration during FSE1 was two orders of magnitude higher than the indoor air level. During FSE2, the concentrations in the crawlspace & indoor air were similar. The highest PCE result in outdoor air during FSE1 was located near the crawlspace air sample, & could have been impacted by crawlspace air conditions during sampling. These results suggest the presence of a complete VI pathway. Based on the above lines of evidence, the VI pathway is considered complete at Building 728
PCE was detected in indoor & outdoor air during both sampling events, with indoor & crawlspace air levels higher than outdoor air results during FSE2. The crawlspace air concentration during FSE1 was two orders of magnitude higher than the indoor air level. During FSE2, the concentrations in the crawlspace & indoor air were similar. The highest PCE result in outdoor air during FSE1 was located near the crawlspace air sample, & could have been impacted by crawlspace air conditions during sampling. These results suggest the presence of a complete VI pathway. Based on the above lines of evidence, the VI pathway is considered complete at Building 728,
PCE concentrations in crawlspace air were two orders of magnitude higher than outdoor air levels during both sampling events. PCE was detected in all soil gas samples during FSE1, with the highest level located along the eastern exterior wall (location 730-SG002). This result generally coincides with the highest indoor sample result located in the mechanical room in the southeastern portion of the building (location 730-AA005). There is no spatial bias apparent in the locations of the other PCE detections in ambient air. Based on the above lines of evidence, the VI pathway is considered complete at Building 730
See site file for additional information. |
Louis Howard |
| 1/18/2018 |
Document, Report, or Work plan Review - other |
Draft Fourth Five-Year review received for review and comment.
Main comments were to develop a task list of when the decision will be made to amend the record of decision and implement full scale treatment based on results of the treatability study to treat groundwater. Other comments were to add a notice of environmental contamination with Alaska Dept. of Natural Resources land records.
See site file for additional information. |
Louis Howard |
| 1/29/2018 |
Document, Report, or Work plan Review - other |
EPA provided comments on the FYR. The following issues should be included in the protectiveness statement along with a timeline for implementing the OUE-DA089 recommendations: "Cancer risks exceed 1 x 10-4 or have an HQ greater than 1 for the following non-COC chemicals (in GW): 2-hexanone, cis-1,2-DCE, TCE, and vinyl chloride." and "Limited natural attenuation of PCE in groundwater is occurring at the site, indicating that RAOs may not be achieved within the projected timeline of 30 years."
Any modifications to the issues and recommendations for any of the sites made as result of addressing comments on the FYR should be included in the protectiveness statement.
EPA comment: There should be one protectiveness statement for each OU. OUE-DA089 and OUE-SS044 should be grouped into one protectiveness statement. The AF can say in that protectiveness statement that OUE-DA089 is protectiveness deferred using the language in the 2012 EPA memorandum but they can include a statement that that OUE-SS044 is protective (if that is the final determination after all comments are addressed – if monitoring for PFAS is included in the issues and recommendations then the protectiveness statement should be “protectiveness deferred” for SS044 also).
For DA-089, the following issues should be included in the protectiveness statement along with a timeline for implementing the recommendations: "Cancer risks exceed 1 x 10-4 or have an HQ greater than 1 for the following non-COC chemicals (in groundwater): 2-hexanone, cis-1,2-DCE, TCE, and vinyl chloride." and "Limited natural attenuation of PCE in groundwater is occurring at the site, indicating that RAOs may not be achieved within the projected timeline of 30 years.
Suggested revision:
A protectiveness determination for OU E cannot be made at this time until further information is obtained. Further information will be obtained by taking the following actions: completing the vapor intrusion assessment at DA-089 and evaluating PFAS detections in groundwater at concentrations above the EPA Health Advisory at SS-044. It is expected that these actions will take approximately (Air Force – please enter in a time frame) to complete, at which time a protectiveness determination will be made. In addition, to ensure future protectiveness at DA-089, the following actions need to be taken: incorporate chemicals with cancer risks exceeding 1 x 10-4 or have an HQ greater than 1, including 2-hexanone, cis-1,2-DCE, TCE, and vinyl chloride as COCs in groundwater in a decision document; and evaluate a remedy change to in-situ groundwater treatment because PCE concentrations will not meet RAOs in the 30 year timeframe identified in the ROD (2035).
See site file for additional information. |
Louis Howard |
| 2/13/2018 |
Document, Report, or Work plan Review - other |
Staff commented on the draft UFP-QAPP Work Plan. Main comments were on requesting AFCEC analyze for diesel range organics (DRO) at this site since the RI did detect DRO* at 1.8 mg/L (Table C Groundwater Cleanup Level for DRO is 1.5 mg/L) for one sampling event across all wells at the site. If not detected above 1.5 mg/L, then DRO need not be sampled for again at the AVMA site. *Also, see table B-60 Criteria Evaluation – Groundwater – AVMA BTEX_TPH Well AP-4338 Sample ID 02AVMA26WA.
If sampling for DRO is not conducted under CERCLA, then ADEC will require that groundwater sampling be conducted under State authority as required by 18 AAC 75 for petroleum releases.
See site file for additional information. |
Louis Howard |
| 2/13/2018 |
Document, Report, or Work plan Review - other |
Staff commented on the draft RA-O & M Report for select CERCLA Sites. Main comments were on requesting AFCEC analyze for diesel range organics (DRO) at this site since the RI did detect DRO* at 1.8 mg/L (Table C Groundwater Cleanup Level for DRO is 1.5 mg/L) for one sampling event across all wells at the site. If not detected above 1.5 mg/L, then DRO need not be sampled for again at the AVMA site. *Also, see table B-60 Criteria Evaluation – Groundwater – AVMA BTEX_TPH Well AP-4338 Sample ID 02AVMA26WA.
If sampling for DRO is not conducted under CERCLA, then ADEC will require that groundwater sampling be conducted under State authority as required by 18 AAC 75 for petroleum releases.
See site file for additional information. |
Louis Howard |
| 2/26/2018 |
CERCLA ROD Periodic Review |
Staff reviewed and concurred with the protectiveness statements, in general, for the Fourth Five-Year Review report at JBER-Richardson. Main comments were: The vapor intrusion assessment at DA089 requires completion, and recent detections of Per- and Polyfluoroalkyl Substances (PFAS) in groundwater at concentrations above the EPA Health Advisory at SS044 require additional evaluation either under CERCLA authority or State regulatory authority. It is expected that these actions will be completed by December 31, 2020 at which time a protectiveness determination will be made. Staff requested the daughter products for PCE in groundwater should be included as chemicals of concern and the current cleanup levels used. Finally, staff requested a remedy change be evaluated since the 30 year timeframe for cleanup won't be met and recent treability studies show promise with emulsified vegetable oil (95% reduction in contaminant levels). Due to uncertainty regarding exposures to vapor intrusion from OU E, ADEC cannot draw conclusions as to whether human exposures to subsurface chlorinated solvent vapors are controlled in the manned facilities in the vicinity of the Armored Vehicle Maintenance Area site DA089 in OU E. There is also uncertainty regarding potential exposures to PFAS contamination at SS044 and the Ruff Road Fire Training Area AT029 (formerly a source area for OU A) which needs to be addressed prior to the next FYR.
See site file for additional information. |
Louis Howard |
| 4/12/2021 |
Document, Report, or Work plan Review - other |
DEC submitted comments on Draft JBER Basewide UFP-QAPP dated February 2021. |
William Schmaltz |
| 5/19/2021 |
Document, Report, or Work plan Review - other |
DEC Reviewed and approved of Basewide Uniform Federal Policy - Quality Assurance Project Plan. QAPP summarizes general activities for a 5 year period on JBER. |
William Schmaltz |
| 5/28/2021 |
Document, Report, or Work plan Review - other |
DEC Approved of Final LTM and LUC Inspection Work Plan for select CERCLA sites dated May 2021. |
William Schmaltz |
| 8/9/2021 |
Document, Report, or Work plan Review - other |
DEC staff reviewed and provided comments on Draft 2020 Land Use Control report for Select CERCLA sites dated June 2021. Report summarized LUC inspections performed in December 2020. Most sites were covered in snow and a full inspection could not be performed until spring 2021. DEC requested that the spring 2021 inspections are included in the 2020 report or as a separate cover because they are a continuation of the 2020 inspections and separate of the 2021 inspections. |
William Schmaltz |
| 7/20/2022 |
Document, Report, or Work plan Review - other |
DEC reviewed and provided comments on DA089 RI/RA Management Plan. |
William Schmaltz |
| 2/16/2023 |
Document, Report, or Work plan Review - other |
DEC reviewed and provided comments regarding the 2023 Letter Work Plan Remedial Action Operations and Long-Term Management, Draft, dated January 2023.The work plan describes the site inspections, maintenance activities, and groundwater, seep, and surface water monitoring, at multiple sites located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. The scope of work briefly summarizes the site locations, sampling/monitoring schedules, and activities such as free-product removal from monitoring wells and monitoring/maintenance activities at the Operable Unit 5 wetlands. The details regarding the procedures for the remedial action operations and long-term management activities will remain consistent with the 2021 Uniform Federal Policy Quality Assurance Project Plan (UFP-QAPP). |
Ginna Quesada |
| 4/20/2023 |
Document, Report, or Work plan Review - other |
DEC reviewed and provided comments for the 2021 Annual Remedial Action-Operations and Long-Term Management Report for Select CERCLA Sites, Draft, dated December 2023. The report describes the site inspections, maintenance activities, and groundwater monitoring, at multiple sites located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. Site inspections and sampling were recommended to continue for all applicable sites to ensure that conditions remain protective of human health and the environment. |
Ginna Quesada |
| 1/29/2024 |
Document, Report, or Work plan Review - other |
DEC reviewed the 2022 Annual Remedial Action-Operations and Long-Term Management Report for Select CERCLA Sites, Draft, dated October 2023. The report describes the site inspections, maintenance activities, and groundwater monitoring, at multiple sites located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. Site inspections and sampling were recommended to continue for all applicable sites to ensure that conditions remain protective of human health and the environment. |
Ginna Quesada |
