| Action Date |
Action |
Description |
DEC Staff |
| 10/1/1990 |
Underground Storage Tank Site Characterization or Assessment |
ST66 is the site of a suspected diesel leak from a UST that failed a tightness test in 1990. The
site is located on a hilltop to the west of Spring Lake on the northern portion of Elmendorf AFB. ST66 is east of the emergency generator building (Building 62-255), in the vicinity
of a radar control building (Building 62-250), and southeast of SERA Phase I site ST36. Site ST36 was combined with adjacent site ST066, |
John Halverson |
| 11/1/1990 |
Update or Other Action |
The two USTs at this site are currently inactive. The aboveground tank currently services the
emergency generator building. Tank 255 was tightness tested in November 1990 and was
identified as potentially leaking at a rate of more than 0.05 gallons per hour. Tank 256 has not
been tightness tested. The Storage Tank Management Plan (STMP) lists different reference
numbers for the tanks at ST66.
* Tank 255 = STMP tank 249
* Tank 256 = STMP tank 250
* Unnumbered aboveground tank = STMP tank 257
· Unnumbered 2,000-gallon UST at site ST36 = STMP tank 510 |
John Halverson |
| 8/20/1991 |
Update or Other Action |
Letter from USAF Donald Creighton, Colonel USAF Commander to Svend Brandt-Erichsen Regional Administrator ADEC. As you know, the Air Force (AF), the Environmental Protection Agency (EPA)-Region 10, & the Alaska Department of Environmental Conservation (ADEC), recently concluded negotiations concerning a Federal Facility Agreement (FFA) for Elmendorf AFB (EAFB). During these negotiations, the parties mutually agreed that certain of the identified contamination sites might be more appropriately addressed outside the FFA.
More specifically, the parties agreed that nonhazardous solid waste disposal sites, releases from petroleum underground storage tanks, & other petroleum contamination not subject to RCRA corrective action, should be investigated &, if necessary, remediated in accordance with regulatory authorities not explicitly integrated into the FFA.
The AF is anxious to begin work at these sites as soon as possible. To that end, the AF believes it would facilitate efforts at these sites if the AF & ADEC were to enter into an agreement outlining the process to be followed at these sites, & containing a tentative schedule for completion of the necessary investigatory work. The AF is prepared to begin negotiating this agreement in mid-August at a time & location of mutual convenience. The AF additionally proposes to invite the EPA's Project Manager under the FFA to participate in these negotiations to further "cement" the team approach that works so well during the FFA negotiations.
Please have your representative contact Mr Joe Williamson (907-552-4157) soon concerning a suggested time & location for this meeting. Any legal questions concerning this proposal may be directed to Captain Richard Myers (907-552-3046).
On behalf of EAFB, I want to express my appreciation for the technical ability & professionalism your representatives brought to the table during the FFA negotiations. Without their assistance & spirit of cooperation- an agreement would not have been concluded so easily. We look forward to reaching a quick agreement concerning the sites identified in this letter so that we can get on with the work necessary to clean up EAFB. |
John Halverson |
| 12/6/1991 |
Site Added to Database |
Petroleum contaminant (diesel). |
Louis Howard |
| 1/13/1992 |
Update or Other Action |
Doreen Sullivan-Garcia sent spill report from AF regarding facility 62-255 4,000 gallon underground storage tank. Tank has been empty for a while and removed. Vapor screening (TRACER) failed tank. Report published in 1/28/1991 and not reported to ADEC by Larry Opperman's predecessor. August 31, 1987 the tank was emptied and it was an emergency generator tank which has not been confirmed to be empty. |
Doreen Sullivan-Garcia |
| 3/26/1993 |
Update or Other Action |
Department of Defense and ADEC joint Technical Memorandum of understanding signed concerning the Base-wide Groundwater. Signatories: ADEC SCRO-Jennifer Roberts Remedial Project Manager and USAF Joseph Williamson Chief Environmental Programs and Restoration.
As a result of the base-wide groundwater study and the FY92 field work that occurred at Operable Units (OUs) 1, 2, and 5 it appears that a large portion of the groundwater flows into OU5 (attachment 1-contour map). based on this information Elmendorf would like to move all upgradient groundwater into the OU5 Feasibility Study, Proposed Plan and Record of Decision. This means we would address all groundwater from upgradient sources (CERCLA (ST20, OU3, and OU4) and OUs 1 and portions of OU2) and SERA) at OU5 instead of at each individual source area (see attachment 2-Area Map). Those sites which have free phased product would be looked at to see if there is an available technology to clean them up in a cost effective way. Soil contamination would still be addressed at the source areas.
NOTE: Soil contamination to be addressed at the source areas is interpreted by ADEC as removal through excavation or active treatment systems (e.g. high vacuum extraction, bioventing, etc...). |
Jennifer Roberts |
| 8/27/1993 |
Update or Other Action |
Site ST36 was investigated in 1993 as part of SERA Phase I for a diesel leak from a pipe elbow
above a UST at the site. This leak was located approximately 80 feet north of site ST66. Site
ST66 was also scheduled for investigation at that time; however, delay in removal of tanks at
ST66 caused postponement of the investigation to the 1994 season. The programs had been
planned to utilize common wells for evaluation of the groundwater gradient and quality. Due to
the deferral of part of the program, the groundwater gradient is not known. |
John Halverson |
| 1/20/1994 |
Update or Other Action |
Janice Adair Regional Administrator Southcentral Regional Office signs the November 29, 1993 Underground Storage Tank Agreement. The Parties enter this Agreement to perform necessary inventory,registratIon, upgrading or closure, and tightness testing associated with USTs at Elmendorf. All draft final work plans for field work must be submitted to ADEC a minimum of 30 days prior to the start of field work or construction. Site Assessment draft reports for closures must be submitted to ADEC within 60 days after completion of field work. All reports of confirmed leaking USTs, or the need for further investigation, will be forwarded to 3 SPTG/CEVR (or its) successor organization) for possible inclusion into the SERA*. Initial
abatement activities required under 18 AAC 78.230 will be conducted by the Air Force prior to
transfer of any site to the SERA.
*SERA=Environmental Restoration Agreement between ADEC and the Air Force dated October 1992.
Discovered USTs-All USTs discovered during the life of this Agreement will be addressed under this Agreement and will be added to Attachment A. The Air Force will notify ADEC by next day mail of any discoverv within five days of the discovery of an UST, unless release notification is required under 18 AAC 78 220, in which case those provisions will control.
Installation: Any new USTs installed by the Air Force shall be installed in accordance with 40 CFR 280 and 18 AAC 78.022 through 18 AAC 78.090 and will have leak detection, corrosion protectlon, overfill protectIon, and spill protection. The Air Force will notify ADEC at least 30 days prior to initiating installation of an UST. UST installation work will be conducted by a certified UST worker as required by 18 AAC 78.030 and 18 AAC 78.400.
Release Detection: The Air Force shall install and perform release detection in accordance with
the schedules outlined in Attachment A. If release detection is not installed or the tank not
previously permanently closed by the date in Attachment A, the Air Force will close the tank in
accordance with the closure requirements in 18 AAC 78. All tightness testing performed to
satisfy these requirements will be conducted bv a certified UST worker as required bv 18 AAC
78.030 and 78.400
Operation and Maintenance of Corrosion Protection: The Air Force shall meet the requirements of 18 AAC 78.045 and 40 CFR 280.31 for any steel USTs, that have corrosion protection systems The testing of the corrosion protection systems shall be done by a certified UST worker as required by 18 AAC 78.400.
Site Assessment or System Tig:htness Test: The Air Force shall either conduct a system tightness test on all regulated USTs located at the Base or permanently close the USTs in accordance with Attachment A. If site assessments or system tests have been conducted, the Air Force shall submit proof of compliance by the deadlines set in Attachment A. All tightness testing work will be conducted by a certified UST worker as required by 18 AAC 78.400.
Release Investigation and Corrective Action: Release investigations, interim corrective action and corrective action on petroleum contamination identified in work conducted pursuant to this Agreement is not within the scope of this Agreement. These activities will be conducted pursuant to the Environmental Restoration Agreement between ADEC and the Air Force dated October 1992. |
Janice Adair |
| 3/24/1995 |
Site Number Identifier Changed |
Reckey 199221X101302, file number CS77-1.36, was same site. |
John Halverson |
| 4/21/1995 |
Update or Other Action |
Air Force AF memo: 18 April 1995 Underground Storage Tank (UST) Meeting. Elmendorf AFB will accomplish the following actions regarding UST Projects. These actions are based upon conversation between, John Mahaffey, Larry Opperman and yourself. EAFB will make every effort to accomplish a clean closure of a UST removal site if possible. UST removal locations requiring cleanup action will be transferred into the State-Elmendorf Environmental Restoration Agreement (SERA).
A list of sites requiring cleanup will be coordinated with your office. The presumptive remedy for contaminated UST sites in the outwash plain only will be bioventing technology. Contaminated soils exceeding cleanup levels may be placed back into the excavation only if the site assessment (SA) indicates a need for further cleanup action. Contaminated UST sites not in the outwash plain will require further investigation to determine appropriate cleanup options. We will make every attempt possible to assure new USTs or new aboveground tanks are not installed in any way that would hamper future access for cleanup. The project will first accomplish removal of all of the USTs. SA information will be used to prioritize sites for cleanup using existing project funds.
Additional funding will be requested to complete cleanup if available. Sites not addressed for cleanup due to exhausted funding will be placed into SERA Phase IV. John Halverson signed on April 21, 1995. Memo was signed by Douglas G. Tarbett, Maj, USAF, Chief, Environmental Compliance. CC: 3 WG/JA and 3 SPTG/CE. |
John Halverson |
| 6/16/1995 |
Site Ranked Using the AHRM |
Initial ranking. Action code added because it wasn't when the site was originally ranked. |
John Halverson |
| 6/22/1995 |
Update or Other Action |
Memorandum letter from the AF regarding contractor problems at Building 62-250. The contractor EA is removing USTs at Building 62-250/255 for the COE under FY93 MCP project. EA has removed monitoring wells at this location which were installed by our contractor ENSR to deal with the contaminated soil at this site. The problems with the removal of these monitoring wells are:
a. The wells are needed to install a bioventing system that is currently under design.
b. The procedures outlined in 18 AAC 80.015 to decommission a monitoring well were not followed.
2. Corrective actions needed by the COE are:
a. New monitoring wells and monitoring points installed for the operation of the required bioventing system at this site.
b. The damage monitoring wells decommissioned according to the procedures outlined in 18 AAC 80.015.
c. A schedule for a. and b. to keep ADEC informed of the corrective action. |
John Halverson |
| 7/31/1995 |
Update or Other Action |
SERA Phase II Site Assessment Report Final received. The investigation was successful in determining that past releases, spills, and/or leaks at and upgradient of site ST66 have contaminated the soil at the site. This investigation was also successful in determining that this contamination has not contaminated the perched aquifer at ST66. The complete areal distribution has not been determined; however, the eastern, western, and southern extent has been limited and access to the north is restricted by Building 62-250.
A matrix score of 27 was computed for the subject site which requires Level B Cleanup standards. The contamination has been approximately determined and limited to the vicinity of 50WL03 from a depth of 24.5 ft. (5,700 mg/kg DRO, 1,900 mg/kg GRO). This soil contamination does not appear to be spatially related to the contamination identified with ST36. Contamination at ST36 could possibly have migrated laterally to 50WL03 following the piping runs between ST36 and ST66. Two 5,000 gallon USTs and/or associated piping are implicated as the probably source. NOTE: GRO was analyzed useing API/EPA 5030/8015 modified, BTEX 5030/8020/8015 modified, DRO 3550/8100 modified, and on a select few samples: TPH 418.1.
However, the limited extent of the contamination suggest that the source could be an intermittant or low-volume leak. The disparity between the aquifer at ST36 (66 ft. bgs) and ST66 (24 ft. bgs and intermittent) indicates that there is a perched aquifer at ST66. ST36 is known to contain high concentrations of petroleum hydrocarbons. The most probable source of this groundwater contamination is the UST investigated under ST36, although it is possible that contamination emanating from ST66 migrated along silt margins to ST36. Bioventing system is recommended at ST66.
Water sample results for ST66 at well 56WL01WGN detected 14000 ug/L or 14 mg/L DRO. |
Louis Howard |
| 8/11/1995 |
Update or Other Action |
ADEC (John Halverson) sent letter to Air Force (L. Opperman) RE: Disposition of petroleum contaminated soil generated during underground storage tank (UST) Closures at Elmendorf AFB. I met with you & Mr. John Mahaffey on April 18, 1995, to discuss UST closures planned at Elmendorf this summer & the issue of how contaminated soil would be handled. We agreed that if "clean closure" could be reached through excavation, all contaminated soil should be removed & taken to an off-site treatment facility.
We also agreed that petroleum contaminated soil could be placed back in the ground, on the condition bioventing systems would be installed starting this year, if clean closure was not feasible. However, it has become apparent the Air Force has not been able to implement corrective action at leaking underground storage tank sites in a timely manner.
Therefore, our April 21, 1995 agreement on soil management must be revoked. Starting immediately, the department requests that all contaminated soil removed from the ground during closure or upgrade of USTs be completely contained in accordance with our petroleum contaminated soil stockpiling guidelines referenced in the UST regulations. Please notify your project managers, the Army Corps of Engineers project manager & all of your UST contractors of this change. The rationale behind the need to contain all excavated petroleum contaminated soil is provided below.
Failure to implement Corrective Action-Tank #805, at building 24-805, failed a tightness test in 1994 & was removed from the ground. Tanks #96-104 were also removed from the ground in 1994. Petroleum contaminated soil was excavated during removal of the tanks. The Air Force requested approval to place contaminated soil back in the ground at both sites. Department approval was granted on the condition corrective action be started at each site no later than June 30, 1995. The Air Force had committed to doing this work under Phase IV of the SERA. However, we have been informed that contracts for SERA Phase IV have not yet been awarded, work plans have not been developed, & it does not appear the field work will be started this year. This is a violation of the corrective action requirements outlined in the UST regulations & our prior agreements.
Management Action Plan (MAP) for transfer of LUST sites into the SERA-On several occasions the department has requested a formalized process for transfer of leaking UST sites from the UST agreement into the SERA. The January 3 1, 1995 annual UST report states that a MAP was being prepared to formalize such a process & that a copy would be forwarded to us as soon as it was completed. We have not received a copy of the MAP. Numerous LUST sites have been identified during the past two years & transfer of sites between the UST & SERA compliance agreements has not been working. It appears the UST agreement needs to be amended to address release investigation & corrective action requirements. Based on the above & the fact that funding for DoD environmental cleanups is being reduced, we are no longer in a position to allow contaminated soil to be placed back in the ground with the hope it will be remediated in a timely manner. |
John Halverson |
| 11/20/1995 |
Update or Other Action |
Letter to Louis Ivers EA Anchorage RE: Damage to groundwater monitoring wells and remediation wells at EAFB during a closure of underground storage tanks (USTs). It has been brought to our attention that during closure of USTs at Building 62-255 (now 27365 on Talley Avenue "BE Storage Shed vacant) on Elmendorf Air Force Base this past summer (1995). EA damaged or destroyed monitoring wells 50WL02 and 50WL03 and that it may have damaged wells at other sites. The current status of these wells is unclear. Please note, the source protection requirements under Alaska's drinking water regulations (18 AAC 80.015(d)) define acceptable decommissioning methods for wells, including monitoring wells. The department requests submittal of additional information on how the wells were repaired or properly abandoned.
Pleases be advised, that monitoring wells at the Base have been installed in accordance with legally binding compliance agreements and are part of an ongoing monitoring and cleanup efforts. In the event such equipment is damaged or destroyed, the appropriate Air Force staff should be contacted immediately and informed of what happened. If wells must be removed, proper procedures need to be followed. Failure to do these things may result in costly steps to remedy the situation and potential enforcement actions.
Please provide specific information, by not later than November 30, 1995, on how EA repaired or abandoned the monitoring wells referenced above. |
John Halverson |
| 12/1/1995 |
Update or Other Action |
SERA II Bioventing Treatability Study received. Ten State-Elmendorf Environmental Restoration Agreement (SERA) sites were selected to be evaluated for remediation of petroleum contaminated soil through bioventing. The sites were
selected for bioventing based on field estimations of physical soil parameters and contaminant characteristics, and following the bioventing decision tree described in the SERA II Work Plan.
Air injection wells and monitoring arrays were installed at each site as described in the SERA II Site Assessment report and summarized as follows.
A field treatability study evaluated initial soil gas composition (carbon dioxide [CO2], oxygen [02], and volatile organic compound [VOC] concentrations); air permeability tests determined the injection well radius of influence; and respiration tests measured the oxygen utilization and carbon dioxide production rates.
ST66 consists of two former diesel fuel underground storage tanks (USTs) adjacent to Building 62-255 and immediately southeast of ST36. Three groundwater monitoring/vent wells were
installed around the two USTs (50WL01, 50WL02 and 50WL03), and three borings were completed as monitoring arrays (50BH01, 50BH04, and 50BH05). The subsurface exploration
program identified a complex geology, including a lobe of silt under the former USTs surrounded by silty sand and gravel. The hydrogeology is similarly complex, including a perched aquifer at approximately 24 feet bgs at the southern extent of the investigation and no defined aquifer to the north within the silt lobe. Groundwater at ST36 and east of ST66 is approximately 70 feet bgs.
A preliminary bioventing test, including a soil gas survey and an air permeability test, were conducted at ST66 in May 1995.
The two USTs were removed after the SERA II site investigation, initial soil gas survey, and air permeability tests were completed. All or portions of 50WL03, 50BH05, 50BH01, 50WL02, and
50BH03 were removed or disturbed during the tank removal.
Samples could not be collected from 59WL10 or at the 29-foot-bgs monitoring point due to a high vacuum generated during purging. Water level measurements suggest that the shallow perched aquifer may have been above the top of the screen in 59WL10 and 59BH04. Initial soil gas concentrations were not significantly depleted in any of the points.
An air permeability test was conducted at ST66, which incorporated wells and monitoring arrays from both ST66 and ST36.The results were not analyzed to evaluate air permeability or anisotropy because the UST removal disturbed the soil sufficiently that the air permeability results no longer will be representative of site conditions.
Preliminary results from the UST removal suggest that soil contamination may exist immediately below the former USTs that was not identified through the SERA II site investigation.
Bioventing is likely to be feasible at ST66; however, the results of the UST removal data should be evaluated along with the data presented here to design the site bioventing system. |
John Halverson |
| 10/17/1996 |
Update or Other Action |
Air Force memo: Restricted Use of the Shallow Aquifer on Elmendorf Air Force Base (EAFB) signed by William R. Hanson P.E. GM-14 Chief Environmental Flight dated October 17, 1996 Memorandum for 3 SPTG/CEC/CEO from 3 SPTG/CEV.
1) Due to the contamination and commitments to regulators the use of the shallow aquifer for any purpose on Elmendorf is not allowed. Please see the attached Facility Board minutes (March 29, 1994 0930-Item 9 of minutes). Mr. William Hanson, Chief of Environmental, briefed to the Facilities Board the policy to not use the shallow water aquifer due to contamination. The Facilities Board approved this policy. Minutes approved by Thomas R. Case Brigadier General USAF Commander. The Installation Restoration Program (IRP) has additional Record of Decisions (RODs) for Operable Units 3 and 6 which require, as a stipulation of the agreement with Environmental Protection Agency and Alaska Department of Environmental Conservation, this aquifer remain unused.
2) Our concern is that key personnel in the review process within Civil Engineer Squadron are aware of these policies and that these policies are reviewed on a recurring basis. It is imperative that this restriction be recognized and observed during engineer reviews and operations.
3) If you have questions on this subject, please contact Mr. Joe Williamson at 552-7229. |
Louis Howard |
| 8/12/1998 |
Update or Other Action |
Letter to AF regarding Response to Comments on draft work plan SERA Phase II Sites ST36/66, ST74, and ST61 Investigation dated July 1998. ADEC disagrees with contractor's response to comments concerning analytical methods discussed in Items 1(i) and 1(m). UST and CS regulations require cleanup levels for GRO/DRO be based on analyticals using AK methods not 8015M/8100M.
The only exception to the analytical methods are found in 18 AAC 78.090: "If site assessment sampling began before November 3, 1995, and if test results satisfy the water quality criteria and cleanup levels referred to in (i) of this section, the owner or operator may continue to use the analytical methods used before that date to complete the site assessment. If a site assessment is begun on or after November 3, 1995, the owner or operator shall use the analytical methods set out in Table G of 18 AAC 78.800(b)."
ADEC requests the AF cease use of alternative lab methods (8015M/8100M) for DRO and GRO analyses by the end of the calendar year for soil and groundwater analysis or long term monitoring which do not include AK 101 or 102. The alternative methods will no longer be acceptable when the new 18 AAC 78 and 18 AAC 75 regulations become final. It is anticipated that the UST and CS regulations will become finalized by the end of this calendar year. Please make changes to any future contracting or scopes of work to ensure that by March 1, 1999 all analyses for gasoline range organics and diesel range organics utilize AK methods for both soil and groundwater. |
Louis Howard |
| 1/10/2000 |
Institutional Control Record Established |
No current receptors exist for the groundwater at the Base due to the institutional controls (ICs). As a requirement of previously signed RODs for Operable Units (OUs) at the Base, ICs have been established to restrict the use of the shallow aquifer in the outwash plain on Base for both SERA and CERCLA sites. These restrictions are enforced through the Base Comprehensive Plan (BCP).
Projects and other activities are reviewed during the planning stage to ensure compliance with the BCP. In addition, construction projects and other activities also undergo an environmental review. This review helps ensures compliance with groundwater use restrictions. |
Louis Howard |
| 1/10/2000 |
Long Term Monitoring Established |
10/99-12/99 Quarterly report received. Of the 34 wells sampled 11 wells remain above the MCL for benzene. Groundwater cleanup levels for petroleum constituents are estimated to be met in September 2010. |
Louis Howard |
| 1/24/2000 |
Update or Other Action |
Bioventing report received for base-wide long-term operation and maintenance of systems. For the purposes of final closure sampling, the required minimum number of samples will be three per boring-at the area with the highest PID reading, at the highest historical contaminant level and at soil/groundwater interface. Analysis of BTEX, DRO and GRO contaminants of concern (PAHs if following Method Two) will be required. |
Louis Howard |
| 4/17/2000 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on draft Base-wide Bioventing Systems Biweekly monitoring and soil gas respiration testing annual report. For the purposes of final closure sampling, the required minimum number of samples (from a minimum of three borings) will be three per boring-at the area with the highest PID reading, at the highest historical contaminant level and at soil/groundwater interface. ADEC will require analysis of benzene, toluene, ethylbenzene, and total xylenes (BTEX), diesel range organics (DRO) and gasoline range organics (GRO) contaminants of concern (sampling for PAHs will be required if the Air Force chooses to cleanup under Method Two). Laboratory analyses, where applicable, will utilize approved AK lab methods, i.e. AK 101 and 102. |
Louis Howard |
| 2/21/2002 |
Document, Report, or Work plan Review - other |
Staff commented on the base-wide annual groundwater report. ADEC recognizes that in some cases it may not be technically practicable to implement an active or passive recovery system for free product. The Elmendorf Remedial Action Report for Operable Unit (OU) 2 (September 1998) set a precedent for defining what is meant by “technically practicable” for free product recovery.
Section 2.4.1 Product Recovery Endpoints at the 1st bullet on page 10 states: “As designed & constructed, the ST41 ground water treatment system cannot recover floating product when there is less than a measurable thickness of 0.1 feet of product. Therefore, as an endpoint for product recovery, if less than 0.1 feet is sustained for one year, recovery at that source can be discontinued. Floating product will be measured monthly. When product thickness falls below 0.1 feet for one year, the recovery of product at that source will not be considered “technically practicable”.
Therefore, where free product is greater than 0.10 feet, ADEC expects corrective action (active or passive) to be implemented for free product recovery. Currently, free product was found to exceed 0.10 feet or more in SERA Phase I well 43-WL-11. This well had the highest level of free product measured at 0.86 feet. The presence of measurable free product is generally not considered conducive for intrinsic (natural) attenuation. ADEC requests the identity of the free product be described in the text at each source area that it is found (e.g. gasoline, diesel, or chlorinated solvents).
3.3.4 Target Analytes Pages 3-10 & 3-11
Benzene & TCE are identified as target analytes to evaluate contaminant of concern (COC) trends in detail & be consistent with the Base-wide Groundwater model. ADEC concurs, however, focusing on these two analytes does not accurately reflect whether diesel range organics (DRO) & gasoline range organics (GRO) plumes are migrating, expanding, steady state, or receding (especially for wells noted to have either free product or fuel odor &/or sheen being observed during sampling). Benzene can be at low levels or even non-detectable while DRO & GRO remain above cleanup levels. Please see the following examples below.
OU 4 - Round 1 sampling at well 49-WL-01 detected benzene at 0.11 ug/L & DRO at 2,400 ug/L & well OU4W-11 detected benzene at 4.3 ug/L while GRO was detected at 3,000 ug/L & DRO was detected at 6,100 ug/L.
OU6- Round 1 sampling at well OU6MW67 detected benzene at 2.8 ug/L, GRO at 2,500 ug/L & DRO at 1,700 ug/L during round 1 sampling. During round 2 sampling, well OU6MW-91 detected GRO at 25,000 ug/L & DRO at 9,500 ug/L while benzene was found to be non-detectable.
See site file for additional information. |
Louis Howard |
| 3/7/2002 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the 2001 Base-wide Bioventing report. General Comments
Decommissioning Bioventing Systems
Where the Air Force is recommending bioventing systems be decommissioned, the Department requests additional clarification if the Air Force has looked at other alternatives to treat the "smear zone" (The smear zone is defined as the range of depths within which the groundwater will fluctuate under normal seasonal conditions, and therefore, in which free product would move and “smear” the soil in response to these seasonal changes in the water level elevation. The smear zone soils may therefore be saturated or unsaturated with groundwater at any given time.) contamination and found it was not practicable to implement them. The basis for not being practicable can be due to reasons such as: reliability of the alternative, alternative is not cost effective, site location, logistics in light of overall project purposes. If an analysis of alternatives was conducted, then it should be stated it is not practicable due to the incremental cost of implementing an alternative is substantial and disproportionate to the incremental degree of protection provided by the alternative as compared to another lower cost alternative.
Well Log Submittal
The Department also wishes to inform the Air Force of the well log recording requirement by the Alaska Department of Natural Resources (ADNR), Division of Mining, Land and Water. The requirement is referenced in the Underground Storage Tank (UST) Procedure Manual, Section 4.7.1 Installing groundwater monitoring wells. Alaska statutes: 38.05.020, 38.05.035, 41.08.020, 46.15.020 and regulations 11 AAC 93.140 require a log of the well be submitted to the ADNR within 45 days after installing a well.
Well logs must be submitted to ADNR/Division of Mining, Land & Water, 550 West 7th Avenue, Suite 900A, Anchorage, AK 99501-3577; (907) 269-8503 or via Fax (907) 269-8947. The detailed official well log reporting form is available from the ADNR/Alaska Hydrologic Survey at the above address or it may be completed online at http://www.dnr.state.ak.us/mlw/forms/welllog.pdf. Enclosed with this letter is a hard copy of the well log form for your information.
See site file for additional information.
|
Louis Howard |
| 10/21/2002 |
Update or Other Action |
J. Roberts sent a letter to Joe Williamson dissolving the State Elmendorf Environmental Restoration Agreement. The Alaska Department of Environmental Conservation (DEC) has reviewed the issue of abolishing the State Elmendorf Environmental Restoration Agreement (SERA) per your recommendation. Elmendorf Air Force Base and DEC entered into the SERA in 1992. The agreement was developed as a tool to bring the Base into compliance with Alaska's regulations addressing underground storage tanks, oil and other hazardous substance releases and solid waste.
Since that time, Elmendorf has made significant progress in investigating and cleaning up historic contamination problems. Many of the sites covered by the SERA have been successfully cleaned up and closed. Cleanup is underway at the remaining sites.
Additionally, Alaska has amended the regulations addressing fuel storage tanks, oil and other hazardous substance spills and solid waste. We concur with you that the SERA is no longer a necessary or beneficial. This letter serves as notice that DEC will end oversight on environmental work at Elmendorf by using the SERA. Instead, it is understood that the sites and programs formerly addressed by SERA: solid waste, underground storage tanks (UST), and oil and other hazardous substance discharges will be addressed in accordance with 18 AAC 60, 18 AAC 78 and 18 AAC 75. |
Jennifer Roberts |
| 7/16/2004 |
Update or Other Action |
2003 Annual Technical Report Environmental Monitoring and System Optimization of basewide bioventing systems. Source Areas ST36 and ST66 are in close proximity; therefore, bioventing systems at these two
locations have been integrated and are treated as a single remedial effort referred to as ST36/66.
Historical: Since no measurable respiration rates were documented at ST36/66 during in-situ respiration testing in 1999, no respiration tests were scheduled or performed in 2000, 2001, or 2002, or 2003. Closure sampling was conducted at ST36/66 in June 2001. Results of this closure sampling, including analytical data and soil boring locations, can be found in the
ST36/66 and ST32, Tank 8 Closure Report.
Subsurface soil data gained from closure drilling at this site in 2001 show that hydrocarbon contamination exists at levels slightly above ADEC Method 2 cleanup levels for the under 40-inch, migration to groundwater category. Most of the contamination found during sampling
exists in the smear zone just above the groundwater surface. Since these soils are constantly being saturated with impacted groundwater and are below the vadose zone, bioventing is not an effective remediation technique for this soil horizon. This contamination should be considered
as part of the groundwater medium for the purposes of evaluating site closure.
Recommendations: In the ST33/66 and ST32, Tank 8 Closure Report, a recommendation was
made that the bioventing blower units be shut down because data indicated that continued
operation would not increase the degradation rate. Draft Decision documents were developed for Sites ST 36/66 and ST68 to record the U.S. Air Force (USAF) decision to
shut down the respective bioventing systems and allow contaminants at this location to naturally attenuate. The decision documents will be coordinated through ADEC. |
Louis Howard |
| 3/1/2005 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Annual technical report for bioventing systems basewide. The Department concurs that the bioventing system for this site be shut down and the remaining contamination in the smear zone be allowed to naturally attenuate. Please identify which groundwater wells near the site will be monitored for contaminants of concern associated with this site. |
Louis Howard |
| 4/29/2013 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft UFP-QAPP Work Plan for ST036/ST066. Main comments were regarding the need for institutional controls for all sites where groundwater under a site or downgradient of a site is contaminated above Table C cleanup levels or MCLs, the maximum allowable concentration in soil is exceeded within the 0 - 15' interval, or if direct contact or inhalation risks are exceeded for residential land use. Finally, staff provided comments regarding the requirement for analyzing for polynuclear aromatic hydrocarbons and other compounds where the vapor intrusion pathway is complete.
See site file for additional comments. |
Louis Howard |
| 9/9/2014 |
Document, Report, or Work plan Review - other |
Staff provided comments on the Draft Site Characterization Report. Main comments were regarding the groundwater being contaminated and that a statistical analysis should be performed to demonstrate the plume is static or decreasing before ADEC will consider granting a "cleanup complete" determination. Finally, staff requested a boring log be provided for the nearby drinking water well BW-27 and demonstrate to ADEC's satisfaction that the screened interval is below a confining layer and therefore not subject to contamination from the existing groundwater contamination at the site. |
Louis Howard |
| 5/11/2015 |
Update or Other Action |
Phone call from JBER regarding ST36. New information has been found during review of the laboratory data regarding trichloroethylene (TCE) in soil. The laboratory mistakenly ran the full analysis for Method 8260 VOCs instead of restricting it to just petroleum related VOCs. 33' below ground surface soil sample results showed exceedances of EPA RSLs for TCE and exceedances of Method Two soil cleanup levels for TCE. Debate is whether to include it as a new site under the Federal Facility Agreement (CERCLA) or to keep it under State oversight using 18 AAC 75 regulations. |
Louis Howard |
| 5/19/2015 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft Annual Report for State Sites which included this site. Main comments were regarding the new found contaminant-trichloroethylene (TCE) in soil at 33' below ground surface after the laboratory mistakenly ran the full suite of volatile organic compounds for the Method 8260 instead of limiting it to petroleum related compounds. The site may be eligible for inclusion under CERCLA Federal Facility Agreement as a new site or existing site with TCE contamination or as a new site or existing site under State oversight using 18 AAC 75.
See site file for additional information. |
Louis Howard |
| 9/15/2015 |
Update or Other Action |
AFSC RECEIVER BUILDING 27369, ELMENDORF AIR FORCE BASE, LOCATED WITHIN NW1/4SE1/4SE1/4SW1/4 SECTION 21, TOWSNHIP 14 NORTH, RANGE 3 WEST, SEWARD MERIDIAN, ANCHORAGE RECORDING DISTRICT, THIRD JUDICIAL DISTRICT STATE OF ALASKA.
File: LAS 25384
Customer 000036133
8/30/2005:
1,315 GPD FROM DRILLED WELL, 210 FT IN DEPTH, FOR AFSC RECEIVER BLD, BLD 27369, LOCATED WITHIN SE1/4SW1/4 SEC. 21,T14N, R3W. S.M. ELMENDORF
USDOD USAF 673 CES/CEIEC
724 QUARTERMASTER ROAD
JBER AK 99505 |
Louis Howard |
| 4/27/2016 |
Document, Report, or Work plan Review - other |
Staff commented on the Draft Annual Report for Monitoring State Sites (including this one) on JBER.
Summary of Previous Investigations
The text states: “Mann-Kendall groundwater concentration trend analysis shows that source area monitoring wells 56WL-01, 56WL-03 and 56WL-04 have decreasing total DRO concentration trends over the period of record (1994/1995 to 2014). Monitoring well 56WL-05 has a decreasing DRO concentration trend over the last 15 years (1999 to 2014), and monitoring well 56WL-01 has a decreasing benzene concentration for the period of record (1993 to 2012). The biodegradation of the dissolved hydrocarbon emanating from the ST036 source area is documented by the low and/or non-detect results of the monitoring conducted in monitoring well 56WL-02, which is less than 100 feet downgradient of the ST036 source (USAF, 2014h).”
Please provide a copy of the Mann-Kendall analysis as an appendix to this report (comment applies to all sites where Mann-Kendall analysis is referenced).
The text states: “The investigation also identified TCE in soil above screening levels at a depth of 54 to 63 feet bgs. The DRO and TCE are thought to be from different sources.”
Please state which sources are thought or are suspected to be the likely sources of DRO and TCE instead of the heating oil UST at Building 27369.
Site Summary and Recommendations
ADEC concurs with the recommendations for the most part in this section.
The text states: “The recently identified TCE represents a new source at ST036. Per the Site Characterization and Risk Evaluation Report ST036 (USAF, 2014h), since there is a potential for vapor intrusion in Building 27369 an additional investigation is recommended for VOCs. This could be accomplished by soil vapor sampling and analysis adjacent to the southeast corner of Building 27369, and by groundwater sampling and analysis at 56WL-01.”
However, based on the potential for TCE to migrate to indoor air, ADEC recommends not only sampling soil vapors, but analyze indoor air at Building 27369 and compare the results to those found in EPA”s December 2012 Memorandum for TCE . The multiple lines of evidence approach [Samples are collected concurrently from indoor air, outdoor air, and subslab or near-slab (within 10 feet of the building) soil gas] is preferred.
|
Louis Howard |
| 8/25/2016 |
Update or Other Action |
Addition to the FFA for ST036 signed by ADEC, AFCEC and EPA.
Further site characterization was conducted in 2013-2014 to fill data gaps and evaluate risk to
human health and the environment. During the 2013-2014 investigation trichloroethene (TCE), a
CERCLA-regulated volatile organic compound (VOC), was detected at depths up to 63 feet bgs in two soil borings south of Building 27369. Based on these results, US Air Force, EPA and ADEC agreed at a meeting on 17 May 2017 that further actions for ST036 should be addressed under CERCLA.
For additional information, see site file. |
Louis Howard |
| 11/30/2017 |
Update or Other Action |
Draft VI report received for review and comment. Building 27369 is located within the buffer zone of a VOC groundwater contamination plume with the depth to groundwater approximately 65 feet bgs. An area of shallow soil TCE contamination is present adjacent to and beneath the southern portion of the building. Soil contamination depths vary from approximately 2 to 70 feet bgs, with the shallowest contamination immediately adjacent to the southwestern corner of the building. The building is relatively airtight during normal operations. Basement floor penetrations include multiple floor drains, a mechanical room sump, and floor seams. No non-VI ambient air COI contaminant sources were identified.
The detections of TCE in soil gas and indoor air (albeit at low, estimated concentrations) suggest the presence of a complete VI pathway. There is no spatial bias apparent in the locations of COI detections in ambient air or soil gas. Based on the above lines of evidence, the VI pathway is considered complete at Building 27369. The building is used to house computer servers and is not regularly occupied. No industrial operations are conducted that could provide an alternate source for the detections of TCE in indoor air.
See site file for additional information. |
Louis Howard |
| 1/8/2018 |
Document, Report, or Work plan Review - other |
Draft Vapor Intrusion study received for review and comment.
Main comments were regarding additional information needed regarding the 5,000 gallon former diesel UST located at building 27369 and adding any existing USTs/ASTs, oil water separators and any tanks connected to the OWSs that serve building 27369.
See site file for additional information. |
Louis Howard |
| 3/13/2018 |
Update or Other Action |
Draft work plan received for ST036, SO552 & TU091. The goals of this LFI are to reevaluate known and potential sources of contamination, and determine the risk posed by contaminants in soil and groundwater to human health and the environment at ST036, TU091, and SO552. These objectives will be achieved by advancing soil borings, collecting surface and subsurface soil samples, and installing and sampling groundwater monitoring wells. As part of the data quality assurance/quality control (QA/QC) process for the LFI, a data quality assessment (DQA), including ADEC Laboratory Data Review Checklists, will be provided with the LFI report.
See site file for additional information. |
Louis Howard |
| 3/22/2018 |
Document, Report, or Work plan Review - other |
Draft LFI work plan comments. Main comments were to require analyses for semivolatile organic compounds (SVOCs) by SW8270 and polycyclic aromatic hydrocarbons (PAHs) by SW8270 selective ion monitoring (SIM) for all soil samples. Staff requested clarification on why SW8260 analyses is being conducted when ALS is accredited to perform SW8260-SIM low level analyses which will achieve lower levels of detection for 1,1,2,2-Tetrachloroethane, 1,1,2-Trichloroethane, 1,1-Dichloroethene, 1,2-Dichloroethane, 1,3 Butadine, 1,4-Dichlorobenzene, Bromodichloromethane, Carbon Tetrachloride, Chlorodibromomethane, Chloroform, Chloromethane, cis-1,2-Dichloroethene, Dichloromethane (Methylene Chloride), Tetrachloroethene, trans-1,2-Dichloroethene, Trichloroethene and Vinyl chloride. Finally, staff requested surface soil sampling occur within 0-2 ft. below ground surface instead of the proposed 0-0.5 ft. interval.
See site file for additional information. |
Louis Howard |
| 7/3/2018 |
Update or Other Action |
Milestone Federal Facility Agreement updates: Draft limited field investigation March 27, 2019, Draft Management Plan June 15, 2020, Draft Remedial Investigation report November 15, 2021, Draft Feasibilty Study report August 15, 2022, Draft Proposed Plan April 15, 2023 and Draft Record of Decision November 15, 2023. Signed by EPA, Air Force and ADEC remedial project managers on July 3, 2018. |
Louis Howard |
| 7/11/2019 |
Document, Report, or Work plan Review - other |
Staff approved the Limited Field Investigation Report for ST036, TU091 and SO552 dated April 2019. |
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 |
| 10/18/2021 |
Offsite Soil or Groundwater Disposal Approved |
DEC approved disposal of 13 cubic yards of IDW waste soil at Columbia Ridge Landfill in Arlington, OR. Investigation-derived waste soil from Limited Field Investigation drilling activities. Maximum soil concentrations for contaminants of concern: TCE=0.24 mg/kg; DRO=1,000 mg/kg; Arsenic=11.2 mg/kg; 1,2,4-TMB=5.4 mg/kg; 1,3,5-TMB=3.0 mg/kg; Ethylbenzene=0.44 mg/kg; Naphthalene=3.8 mg/kg; Pentachlorophenol=0.14 mg/kg; Bromomethane=0.04 mg/kg |
William Schmaltz |
