| Action Date |
Action |
Description |
DEC Staff |
| 5/8/1990 |
Document, Report, or Work plan Review - other |
ADEC sent Col. Edwin Ruff letter re: USTs at Fort Richardson. Staff reviewed the draft SOPs for Site Investigation of UST removals dated April 11, 1990.
Screening Method: Soil samples collected when HNU [photoionization analyzer] readings are consistently less than 50 ppm. Recommend excavating until the readings with Hnu are non-detectable (or equal to the background readings) and then collecting soil samples for laboratory analysis.
Sample location: The department has not been accepting composite sampling from within excavation as a means of determining adequacy of cleanup. Composite sampling has been approved as a method of characterizing spoils piles after excavation.
Sample collection procedure: Sample collection jars should be obtained from the laboratory that will perform the analyses. Samples must be stored at 4 degrees celsius from the time of collection until analyzed (within 14 days of collection).
Analysis: All soil samples should be analyzed for Total Petroleum Hydrocarbons (EPA Method 418.1) and BTEX (EPA Method 8020) unless a hydrocarbon identification test (EPA Method 8015) clearly shows that the contamination is ONLY diesel or another non-gasoline fraction hydrocarbon such as heating fuel. Under these conditions, samples need only be analyzed for TPH.
If the tank was used for waste oil, soil samples should be analyzed for PCBs (EPA 8080), total arsenic, cadmium, chromium, and lead as proposed in your SOPs. If the total lead content is above allowable limit, additional sampling and analysis should be conducted following the toxic characteristic leaching procedure (TCLP). Rather than testing the soils for total organic halides by EPA Method 9020, the department is requesting analysis of total organic halides by EPA Method 8010.
If a site cannot be cleaned up adequately through the tank removal and initial excavation efforts, a site assessment may be requested including individual work plans and QA/QC plans. For the initial tank removals this letter and your SOP for tank removals, dated April 11, 1990, will suffice as a generic work plan. |
Ron Klein |
| 9/26/1990 |
Update or Other Action |
INTERIM GUIDANCE FOR SURFACE AND GROUNDWATER CLEANUP LEVELS SEPTEMBER 26, 1990
Interim cleanup guidance for contaminated surface and groundwater remediation is necessary to ensure that consistent cleanup levels are being applied by district and regional program staff. The following guidelines should be implemented under 18 AAC 75.140 which specifies that a "discharge must be cleaned up to the satisfaction of the Regional Supervisor or his designee.
Final cleanup levels shall be determined by the Regional Supervisor or his designee based on site-specific conditions. Staff should be aware that if a facility is regulated under RCRA, that RCRA corrective action and cleanup standards should enter into development of final site cleanup levels.
Groundwater should be cleaned up to levels not exceeding the more stringent of the final State or Federal Maximum Contaminant levels (MCLs) for Organic and Inorganic Chemicals. If final MCLs have not been adopted for a contaminant, then groundwater should be cleaned up to levels not exceeding proposed Federal MCLs. The group of compounds collectively identified as total petroleum hydrocarbons (TPH) should be cleaned, up to non-detectable levels as measured by EPA Method 418.1.
Final State MCLs are specified in 18 AAC 80.050 and final Federal MCLs are specified in 40 CFR 141 and 142. Proposed Federal MCLs are specified in the May 22, 1989, Federal Register Vol. 54, No. 97, pages 22155 - 22157 and the July 25, 1990, Federal Register Vol. 55, No. 143, pages 30408 - 30448. Appendix I provides a summary listing of State and Federal Final and Proposed MCLs for selected organic and inorganic contaminants.
For organic and in organic contaminants that have not been assigned a final or proposed MCL, cleanup levels should be based on criteria cited in EPA's Water Quality Criteria. 1986 using a health risk factor of 10-6. EPA's water quality criteria identify concentrations of elements and compounds which have toxic effects on aquatic organisms or toxic and carcinogenic effects on humans.
If groundwater is being used as a drinking water source and alternative water supplies or point of use water treatment cannot be provided, then final or proposed secondary maximum contaminant levels (SMCLs) may be used as cleanup target levels. SMCLs are based on aesthetic properties such as taste and odor, whereas MCLs are based on human health risks. For compounds such as xylenes, the SMCL maybe several hundred times lower than the MCL.
Surface waters used for drinking water should also be cleaned up to levels not exceeding the final or proposed MCLs for organic and inorganic chemicals, as specified above. Under the authority of 18 AAC 70.020, surface waters important to the growth and propagation of aquatic life should be cleaned up to the listed criteria which includes EPA's Water Quality Criteria. 1986. These criteria identify concentrations of specific elements or compounds which have toxic effects on aquatic organisms. The group of compounds collectively identified as total petroleum hydrocarbons (TPH) should be cleaned up to non-detectable levels as measured by EPA Method 418.1.
Alternative Cleanup Levels (ACLs) may be adopted for a site if a risk assessment approved by the department is performed and cleanup to levels identified above is technically infeasible. Risk assessments will not by themselves establish ACLs. Determination of cleanup levels is a risk management decision that the department must make based on results of a quantitative risk assessment and other pertinent information.
The responsible party (RP) may prepare at its own expense a risk assessment which shall include an assessment of both human health and environmental risks. Specific components of the risk assessment should include an exposure assessment, toxicity assessment, risk characterization, and justification of ACLs. A general description of these risk assessment components is provided in Appendix II.
General technical requirements for risk assessments should be based on EPA risk assessment guidance for superfund sites. A site specific risk assessment procedure must be prepared by the RP and submitted to the department for review and approval prior to conducting a risk assessment. The RP, at the department's discretion, must agree to reimburse the department for expenses incurred by the department if it chooses to contract for a risk assessment review. |
Louis Howard |
| 9/20/1991 |
Site Added to Database |
Petroleum contaminant. |
Louis Howard |
| 9/24/1991 |
Update or Other Action |
ADEC (John Halverson) sent a Notice of release letter (NORL) in response to a 9/16/91 report of a petroleum release from an underground storage tank system at Building #28004.
On September 16, 1991 we received a report of a petroleum release from an underground storage tank (UST) system at Fort Richardson's water treatment plant, Building #28004.
This letter confirms that the release was reported. Enclosed Is a copy of 18 AAC 78, the Alaska Underground Storage Tank Regulations, governing releases from regulated underground storage tanks (USTs). In accordance with 18 AAC 78.220, within 24 hours of the discovering a release from an UST, the owner or operator must report the release to ADEC, take immediate action to prevent any further release & Identify & reduce any fire & safety hazards.
The following information Is provided as a summary of current laws, regulations & guidelines to further assist you In responding to the release.
In accordance with 18 AAC 78.210 & 18 AAC 78.230, following the discovery & reporting of a petroleum release, the owner or operator of the UST must perform a Site Assessment. A site assessment includes, at a minimum, the following:
inspecting the UST site to check for obvious leaks & obvious soil or water contamination,
reviewing inventory control records & repair records,
determining the type of product stored in the UST,
determining the type of backfill used around the UST,
estimating the depth to the groundwater, &
measuring for the presence of a release where contamination Is most likely to be found (In accordance with an approved Quality Assurance Program Plan (QAPP)).
If a release is confirmed, the owner or operator must conduct an Initial Abatement & Release Investigation, in accordance with 18 AAC 78.230. The Initial Abatement & Release Investigation includes, at a minimum, the following:
preventing further release of product.
continuing to monitor & reduce fire & safety hazards,
storing excavated contaminated materials In a manner that prevents further migration of contaminants,
measuring the extent & location of soils & ground water contaminated by the release, &
Investigating the possible presence of free product &, if present, initiating removal of free product.
Collection of field data & submittal of reports shall be conducted by, or supervised by, a qualified, impartial, third party with an approved QAPP on file with ADEC. The requirement for an impartial third party may be waived by ADEC if:
1) it is documented that a qualified, objective, person will conduct the work,
&
2) ADEC reviews & approves the documentation pertaining to "qualified" & "objective" prior to initiation of the field work.
Reports on the Site Assessment & the Release Investigation shall be submitted to ADEC within 30 days after confirmation of the release. Upon request, fourteen (14) day extensions may be granted for submittal of these reports. ADEC will review each request for an extension on a case-by-case basis. Please include a copy of a completed cleanup matrix form & documentation as to how the specific score for the site was derived.
In addition, upon confirmation of a petroleum release, the owner or operator of the UST must undertake Corrective Action In accordance with 18 MC 78.240. Corrective Action includes, at a minimum, the following:
conducting a preliminary risk evaluation (see attached form),
determining the full extent & location of soils conl8minated by the release,
determining the presence & concentration of dissolved contamination in the ground water,
removing free product (if present) from soils & ground water,
treating or removing contaminated son & ground water. &
treating &/or disposing of contaminated cleanup materials, including soil &/or water removed from the area affected by the release. Treatment &/or disposal of cleanup material must be conducted with prior approval from ADEC. |
John Halverson |
| 3/13/1992 |
Site Number Identifier Changed |
Workplan changed to reflect LUST workplan. |
Louis Howard |
| 2/17/1993 |
Update or Other Action |
A Plan Prepared for U.S. Army Corps of Engineers, Alaska District Project Support Section
Post Office Box 898 Anchorage, Alaska 99506-0898 Contract No. DACA85-91-0-0008 Delivery Order No. 0008 RELEASE INVESTIGATION PLAN/QUALITY ASSURANCE PROJECT PLAN UNDERGROUND STORAGE TANK SITES FORT RICHARDSON, ALASKA HLA Project No. 21844 received for review and comment.
Sites include the following Buildings: 45590 Old Auto Hobby Shop, 750 Motor Pool, 755 Auto and Crafts Center, 756 Motor Pool, 974 Special Purpose Equipment Repair Shop, 796 Vehicle and Weapons Repair Shop, 47811 Veterinary Clinic, 47438 Bryant Army Airfield Fuel Facilty Tanks 65, 67 and 68, 47438 Bryant Army Airfield Fuel Faiclity Tank 69, 47641 Former Aero Club, and 28004 Chlorination Facility. |
John Halverson |
| 3/12/1993 |
Document, Report, or Work plan Review - other |
ADEC letter to Army re: Draft Release Investigation Plan/QAPjP UST Sites Ft. Richardson, HLA Project No. 21844, dated January 29, 1993 which was received on February 17, 1993.
Intro., pg. 1-2. states that if contamination is present above ADEC recommended cleanup levels, a risk- & leachability-based analysis of ACLs will be developed, & a CAP will be prepared as appropriate.
Does the Army want to propose ACLs on all sites where contamination is present? It is not clear what amount of detail will be included in the analysis to be done under this WP (i.e. will it include development of a plan for conducting a leaching assessment or risk assessment or will it include actually conducting the assessment & providing proposed ACLs?).
Project Objectives, pg. 3-21, Includes preparation of an Interim release Investigation (RI) report to meet regulatory reporting requirements. In accordance with the on-going Compliance Order negotiations, submittal of the draft RI report within sixty (60) days of completion of the field work is acceptable to ADEC. It does not appear necessary to submit & Interim RI report, the draft report & then a final report
Project Objectives, pg. 3-21, states the work will be conducted to evaluate the need for corrective action (CA) & the possibility of developing ACLs. ADEC recommends including an objective of conducting the field work In a manner that will aid in future CA at sites where It appears CA may be necessary (ie. installation of vapor recovery wells in soil borings).
Project Organization & Responsibility, pg. 4-1, states the NPD may have project samples analyzed at a USACE-validated lab. In order to meet the requirements of the UST Regulations (18 AAC 78), the lab must be in an approved QAPP & have SOPs & a QA/QC plan on file with ADEC (our Juneau lab).
Project Organization & Responsibility, pg. 4-2, states one copy of the lab data report & QA report will be submitted to HLA. Please note ADEC has specific data reporting & data deliverable requirements for samples collected during UST investigations. Is HLA going to copy the required deliverables & distribute them to all parties which need them?
Soil Borings, pg. 5-3, the first para. states if GW is encountered at a depth greater than 20’ but less than 50’. 2 soil borings will be terminated at approximately 20’ & the 3rd will be converted to a monitoring well. This type of a determination should be based on information obtained during field investigations.
Terminating borings at 20’ is not desirable if contamination extends to greater depths. If GW is, or may be, impacted one monitoring well most likely will not provide sufficient information to determine the presence or extent of contamination & evaluate options for CA. If there is not enough flexibility to make such decisions in the field, it may result in another phase of RI prior to developing a CA plan & would ultimately cost more money.
Soil Borings, pg. 5-3, the second paragraph discussed termination of soil borings if GW is not encountered within fifty (50’) of the ground surface. Again, this is a call that may need to be made in the field based on depth of petroleum impacts.
Soil Borings, pg. 5-3, the third paragraph states auger refusal in two adjacent borings at a depth of 50’ or less will be interpreted to be due to bed rock. This may not be the case in area where large cobbles or boulders are present.
Waste Handling, pg. 5-9, states, "The USACE will be responsible for identifying suitable stockpile locations & for subsequent handling of these cuttings. HLA will dispose of contained water following well development.” Ultimately the responsibility for compliance falls on the Army.
Table 14, Soil Sampling Analytical Summary, pg. 6-2, Identifies analytical methods & the number of samples proposed to be analyzed by each method. While it may not affect this contract, please note QAPP requirements are undergoing review & amendment.
A Standard QAPP has been developed which includes use of new sample collection techniques & analytical methods for measuring petroleum hydrocarbons in soil. The new methods call for conducting a methanol extraction in the field when collecting samples to be analyzed for VOCs. Also, a lab approval program is proposed & the labs may be required to use the new methods discussed above.
Field Measurements, pg. 7-1, states an OVM will be used to field screen drill cuttings during drilling operations. It is not clear whether field screening will be conducted on split spoon samples. Several of the sites have been impacted by heavier hydrocarbons from waste oil tanks. It is recommended that field IR or another appropriate field screening mechanism be used to screen for longer chain hydrocarbons. It is also recommended that each split spoon sample be field screened for contaminants. |
John Halverson |
| 9/2/1993 |
Update or Other Action |
Preliminary Release Investigation Report Underground Storage Tank Sites Fort Richardson, Alaska, dated July 6, 1993 received by ADEC for review and comment. The report covers the following sites:
Plate 3 Site A, Building 45590, Old Auto Hobby Shop
Plate 4 Site B, Building 750, Motor Pool
Plate 5 Site C, Building 755, Auto and Crafts Center
Plate 6 Site D, Building 756, Motor Pool
Plate 7 Site E, Building 974, Special Purpose Equipment Repair Shop
Plate 8 Site F, Building 796, Vehicle and Weapons Repair Shop
Plate 9 Site G, Building 47811, Veterinary Clinic
Plate 10 Site H, Building 47438, Bryant Anny Airfield Fuel Facility
Plate 11 Site I, Building 47641, Former Aero Club
Plate 12 Site J, Buildi ng 28004, Chlorination Facility
Plate 13 Site K, Building 955, Used POL Holding Facility |
Louis Howard |
| 9/21/1993 |
Update or Other Action |
A.G. letter (Breck Tostevin) to Tamela J. Tobia, OS Judge Advocate for the Army. Letter states that a separate petroleum site compliance agreement should be separate from the CERCLA federal facility agreement (FFA). The petroleum site restoration agreement would function as a "two-party agreement" under the FFA. It would track the basic provisions of the underground storage tank (UST) Agreement but be tailored to the State's contaminated site regulations and would interface with the FFA. All petroleum sites addressed under the Two Party agreement would be reviewed in the final operable unit of the FFA and actions taken would be memorialized in a Record of Decision (ROD) under the FFA. |
Louis Howard |
| 11/8/1993 |
Document, Report, or Work plan Review - other |
Letter to Army re: Draft Corrective Action Plan - UST Sites Dated September 14, 1993. We received the document on September 28, 1993 and met with the Army, Harding Lawson and the CORPS to discuss the project on October 21, 1993. The document appears to meet the requirements for a release investigation (RI) report, but does not appear to be a corrective action plan (CAP). A CAP should contain details on how remedial action will be conducted. Site specific CAPs will be necessary for each site requiring action.
Section 3.2.5, Waste Handing - Drill cuttings with PID reading > 5 were placed in drums, labeled, and sent to Building 45125 for storage. Cuttings with readings <5 were stockpiled on polyethylene at each site. Wastewater (930 gallons) generated during the investigation was drummed and sent to APC for treatment. The report states the Army will assume responsibility for the remainder of the wastes. Please include any additional information the Army has regarding disposition of the wastes.
Section 3.3.1, Analytical Methods - The section references a "Method for determination of Gasoline-Range Organics and Method for Determination of Diesel-Range Organics" (API. 1992). It is unclear from this reference whether the methods used include modifications specified by the State of Alaska's underground storage tank program.
Section 4.3, Soil Cleanup Levels - The report includes matrix cleanup level calculations for each site. All of the sites were determined to be Level "C". On sites where the extent of contamination has not been fully defined (for example, site G where DRPH were present at the maximum depth of boring AP-3178) the matrix score may need to be adjusted as more site information is developed.
Page 5-10 of the report states, "The perched groundwater zone observed at the site forms a lower barrier to contaminant migration; thus, the potential extent of contamination is limited to approximately 5 feet below the new tanks." Three out of four monitoring wells installed at the site were found to be dry after well development and during sample collection. The tank removal excavation was reopened to be up to 15’ in depth and contamination was present at the bottom of the excavation. Therefore, ADEC cannot concur with the statement contamination is limited to approximately 5’ below the new tanks.
Due to the high concentrations of petroleum contaminants documented in earlier work and the fact no borings could be located directly in the location of the former tanks, it appears additional site investigation work will be necessary before ADEC makes a determination on the need for corrective action at this site.
Section 5.11 Site J-Bldg. 28004 Chlorination Facility-Trace concentrations of PCBs were detected in samples collected during the UST closure. The report states no PCBs were detected in samples collected during release investigation work in 1993. However, the sampling summary (Plate D10) does not indicate PCBs analyses were conducted.
The report identified DRPH in a surface sample at a concentration of 1,390 mg/kg, slightly above the matrix cleanup level for the site. Pursuit of ACLs for the surface contamination and closure of the UST site was recommended. ADEC does not object to these recommendations, however, the question of possible PCB contamination remains.
Section 5.13, Summary - The summary states contaminant levels observed in borings at sites B. D, E. F, H, and I are below the cleanup levels estimated using the matrix, sites A and G need additional investigation to fill information gaps and direct remedial actions, and sites C. J. and K have been designated for evaluation of ACLs.
Based on review of the draft RI report, ADEC requests the final report include additional information on sites E, F, and I to support the sampling rationale used and the conclusions of the work. It appears there may be data gaps associated with these sites. It also appears additional site investigation work is necessary at site H.
At site J, the chlorination facility, a question remains over potential PCB contamination |
John Halverson |
| 11/12/1993 |
Enforcement Agreement or Order |
State-Fort Richardson Underground Storage Tank Compliance Agreement signed by ADEC (Janice Adair Regional Administrator-Southcentral Office) and U.S. Army. The purpose of the agreement is to bring Fort Richardson into compliance with the Underground Storage Tank (UST) regulations and avoid the expense of formal enforcement proceedings.
The Army agrees to perform the necessary inventory, record keeping, registration, upgrading or closure, tightness testing, site assessment, release reporting, release investigation, and corrective action (remediation) associated with USTs at Fort Richardson (excluding Alaska Department of Military and Veterans Affairs and Army National Guard USTs). All petroleum sites addressed under the Two Party agreement would be reviewed in the final operable unit of the FFA and actions taken would be memorialized in a Record of Decision (ROD) under the FFA.
Site Assessment or Svstem Tightness Test
29. The Army shall conduct a site assessment* or a system tightness test, as required by AS 46.03.380(b) and 18 AAC 78.01S(i)(3), on all USTs located at Ft. Richardson, or permanently close the USTs in accordance with 40 CFR 280 and 18 AAC 78. If site assessments or system tests have been conducted, the Army shall submit proof of compliance by the deadlines set forth in the USTMP. Site Assessments or System Tightness Tests shall be conducted under the schedules in 18 AAC 78.015(i)(3) or, in order to come into compliance, as scheduled in the USTMP.
All tightness testing work will be conducted by a certified UST worker as required by 18 AAC 78.400. Site Assessment work will be conducted pursuant to 18 AAC 78 and an ADEC-approved Quality Assurance Program Plan (QAPP). With respect to UST recordkeeping requirements, the Army shall compile all required records by the date set forth in the USTMP and shall thereafter maintain and update those records as required by 18 AAC 78 and 40 CFR 280.
Release Investigation Reports
31. The Army shall submit to ADEC a Release Investigation* report for each UST site having a documented release* of petroleum products or hazardous substances. These reports will be submitted by the deadlines in the USTMP. The Release Investigation report shall contain all information required by 18 AAC 78.230(b), 18 AAC 78.240(c) and the following:
1) a detailed written or, if applicable, visual description of all work performed and summary of all pertinent data prepared by the Army and its consultants,
2) monitoring well construction data and
3) soil boring logs;
4) site maps detailing existing improvements and (if known)
5) the location of former fuel dispensing equipment,
6) water table elevation maps,
7) petroleum-product level and thickness (isoplot) maps,
8) organic-contaminant concentration maps,
9) aquifer interpretations,
10) other potential source areas within 1/4 mile,
11) data deliverables as outlined in 18 AAC 78,
12) interpretations of field observations and analytical data,
13) a completed Site Assessment/Release Investigation Summary Form, and
14) recommendations for any follow up work.
32. If upon review of a Release Investigation report the ADEC reasonably determines additional contamination assessment is required, ADEC shall notify the Army in writing. This writing will set forth the reason(s) the ADEC concluded that additional assessment is required.
111. "Site" shall mean a distinct area of contamination or potential contamination.
112. "Site assessment" shall mean the investigation of suspected contamination resulting from an unpermitted release of oil or hazardous substance as further defined in 18 AAC 78.090 (Site characterization and assessment).
110. "Release" shall have the meaning in AS 46.03.826 [(9) "release" means any spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping, or disposing into the environment, including the abandonment or discarding of barrels, containers, and other closed receptacles containing any hazardous substance.]
Originally listed in Attachment B as requiring a release investigation for UST 111. Listed on Attachment D as either requiring an upgrade or closure for USTs 48 &49. Listed in Attachment I as requiring complete treatment of existing stockpile at the Landfill for SP 15. |
Janice Adair |
| 4/26/1994 |
Update or Other Action |
Draft RI report received which covers multiple sites including this one under contract DACA85-95-D-0008, Delivery order No. 0004.
The sampling results for Building 28-008 indicate soil contaminated with diesel range organics
in excess of 100 mg/Kg in four of the five borings. GRO contamination in excess of 50 mg/Kg
can be found in several samples in two of the borings. Semi-volatile analysis indicated the
presence of several PAHs at concentrations less than soil risk based contaminant levels.
Vertical extent of contamination extends to the ground water as evidenced by water samples
from AP-3691, AP-3692, and AP-3695. The horizontal extent of the soil contamination has not
been established.
Water analysis revealed DRO levels from 2,000 ug/L in AP-3695 to l80,000 ug/L in AP-3692. GRO contamination of the ground water was found in AP-3692 at a level of 4,900 ug/L. Benzene was found in AP-3690 and AP-3692 at 16 ug/L and 3.7 ug/L, respectively.
Ethylbenzene was also found in monitoring wells AP-3690 at 27 ug/L and AP-3692 at 32 ug/L.
Toluene was present in AP-3692 at a level of 5.6 ug/L. Xylenes were present in all three
monitoring well samples, AP-3690 at 30 ug/L, AP-3692 at 67 ug/L, and AP-3695 at 1 ug/L. The Horizontal extent of the ground water contamination has not been established.
There is extensive soil and ground water contamination at this site. Contaminated soil can be
found from the surface to ground water. The horizontal extent of the surface contamination has
not been established. The contaminated soils will continue to leach to ground water.
Ground water samples have DRO, GRO, and Benzene levels in excess of ADEC guidance for clean-up. Ground water contamination is seen in all the monitoring wells.
In order to confirm the existing underground storage tank is not contributing to the current levels of contamination, tank integrity testing should be performed.
It is recommended at least two additional monitoring wells be placed in the area around Building
28-008 to further establish the extent of groundwater contamination. One well should be placed
on the west side of Building 28-008, west of the existing wells. The second monitoring well
should be placed down gradient and down slope of Building 28-008. The recommended location
for the second monitoring well is at the west base of the hill on which Building 28-008 is located.
The information the additional wells will provide is necessary to adequately perform a Risk
Assessment of the Building 28-008 contamination.
It is recommended monitoring wells AP-3690, AP-3692, and AP-3695 be sampled for polynuclear aromatic hydrocarbons (EPA Method 610). This will identify any PAH's associated with the diesel or gasoline contamination that may be present.
It is recommended the two new monitoring wells be sampled for DRO (8100 Modified), GRO (8015 Modified), volatile organic hydrocarbons (EPA Method 8260), and polynuclear aromatic hydrocarbons (EPA Method 610).
Based on the depth, extent, and nature of contamination, a risk assessment is recommended for
the contamination associated with Building 28-008. Since the groundwater is already contaminated, a leachability assessment is inappropriate. The additional groundwater information provided by the additional monitoring wells is necessary to establish gradient and
extent of contamination required for the risk based analysis. |
Louis Howard |
| 11/30/1994 |
Document, Report, or Work plan Review - other |
Building 28004 is now Building 28008. Staff received the March 1994 Release Investigation Report, UST Sites, HLA Project No. 21844, Fort Richardson, Alaska on April 26, 1994. Section 5.7 Site J, Bldg. 28-004, Chlorination Facility, UST 111, Page 5-21.
The text states alternative cleanup levels be accepted for the site based on SESOIL fate and transport modeling of the contaminants present at AP-3189. ADEC accepts the modeling data as presented in the document by the Army and will consider the site closed**. However, closing out of this site does not limit nor preclude ADEC from requesting future remediation or site investigation at a later date.
If construction activities or excavation activities cause contamination to become exposed, or new information indicates that there is a risk to human health or the environment, then future investigation and/or remedial actions may be required by ADEC.
**In 1998, free product was discovered and closure action with ACLs was rescinded by ADEC. NOTE to File: “free product” means a concentration of a hazardous substance that is present as a nonaqueous phase liquid; for purposes of this paragraph, a “nonaqueous phase liquid” is a liquid that is not dissolved in water.
“Hazardous substance” has the meaning given in AS 46.03.826
AS 46.03.826(5) states: "Hazardous substance" means (A) an element or compound which, when it enters into the atmosphere or in or upon the water or surface or subsurface land of the state, presents an imminent and substantial danger to the public health or welfare, including but not limited to fish, animals, vegetation, or any part of the natural habitat in which they are found; (B) oil; or (C) a substance defined as a hazardous substance under 42 U.S.C. 9601(14).
TITLE 42 CHAPTER 103 SUBCHAPTER I § 9601. Definitions -The term “hazardous substance” means
(A) any substance designated pursuant to section 311(b)(2)(A) of the Federal Water Pollution Control Act [33 U.S.C. 1321 (b)(2)(A)],
(B) any element, compound, mixture, solution, or substance designated pursuant to section 9602 of this title,
(C) any hazardous waste having the characteristics identified under or listed pursuant to section 3001 of the Solid Waste Disposal Act [42 U.S.C. 6921] (but not including any waste the regulation of which under the Solid Waste Disposal Act [42 U.S.C. 6901 et seq.] has been suspended by Act of Congress),
(D) any toxic pollutant listed under section 307(a) of the Federal Water Pollution Control Act [33 U.S.C. 1317 (a)],
(E) any hazardous air pollutant listed under section 112 of the Clean Air Act [42 U.S.C. 7412], and
(F) any imminently hazardous chemical substance or mixture with respect to which the Administrator has taken action pursuant to section 7 of the Toxic Substances Control Act [15 U.S.C. 2606]. The term does not include petroleum, including crude oil or any fraction thereof which is not otherwise specifically listed or designated as a hazardous substance under subparagraphs (A) through (F) of this paragraph, and the term does not include natural gas, natural gas liquids, liquefied natural gas, or synthetic gas usable for fuel (or mixtures of natural gas and such synthetic gas). |
Louis Howard |
| 5/26/1995 |
Update or Other Action |
Two 10,000-gallon UST (Tank Nos. 48 and 49) on the east side of Building 28-008 were removed and replaced with a single tank in May 1995. Tanks 48 and 49 were 21 feet long and nine feet two inches in diameter. Both tanks had a four-inch vent pipe and a four-inch fill pipe. These USTs were installed approximately three feet below ground and had no surface dispensers. Information provided by Brown & Root Services Corporation stated Tanks 48 and 49 contained diesel fuel for emergency use. Laboratory analysis performed by CT & E Environmental Services, Inc. confirmed that.
The two 10,000-gallon USTs (Tank 48 and 49) were removed in May 1995. Soil surrounding
the tanks were sampled to determine if petroleum hydrocarbon contamination had occurred.
Eight soil samples were collected at each tank location. The laboratory results of the soil
samples near Tank 49 indicated the highest concentration of contaminants was DRO at 4,300 mg/kg The soil sample results from Tank 48 indicated the highest concentration of DRO at
3,700 mg/Kg, Benzene at 0.59 mg/Kg, and BTEX at 55.00 mg/Kg. |
Louis Howard |
| 6/16/1995 |
Site Ranked Using the AHRM |
Initial ranking. Action code added because it wasn't when the site was originally ranked. |
Louis Howard |
| 7/19/1995 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Site Assessment Tanks 48 & 49 Bldg 28008, Fort Richardson, Alaska June 30, 1995
The Alaska Department of Environmental Conservation-Defense Facilities Oversight group
(ADEC) has received, on July 18, 1995, a copy of the above referenced reports for building
28008. ADEC concurs that the level B cleanup criteria was exceeded at this site and will require
further investigation to delineate the vertical and horizontal extent of the contamination at the site prior to implementing corrective action. ADEC looks forward to receiving a copy of the
workplan for the release investigation with schedules of action for review and comment no later
than November 1995. |
Louis Howard |
| 11/17/1995 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on a remedial investigation for multiple buildings including 28008 dated June 1995. Staff requested future diesel range organics (DRO), benzene, toluene, ethylbenzene, xylenes (BTEX), polynuclear aromatic hydrocarbons (PAHs) analyses be conducted at the site. Monitoring well installation and sampling to be conducted in accordance with the UST Procedures Manual. |
Louis Howard |
| 12/15/1995 |
Update or Other Action |
Letter Sent to Sam Swearingen (Army) Waiver No. #A 001 RE: Waiver From Requirement to Use AK 101, AK 102, or AK 103 Analytical Procedures For Hydrocarbon Analyses
This waiver is issued to allow the above named person or firm to avoid the requirement to analyze soil samples in accordance with analytical methods AK 101, AK 102 and AK 103 for the specific project listed below. The waiver further specifies that analytical methods specified below shall be used for the project, with slight modifications in integration ranges.
This letter, when signed with an original signature by the appropriate Department official, will serve as a waiver solely from the portion of the following regulations that refer to use of analytical methods AK 101, AK 102, and AK 103: 18 AAC 78.090(e), 18 AAC 78.235(b), 18 AAC 78.300(c), and 18 AAC 78.312(f)(2) requiring the use of analytical methods AK 101, AK 102, and AK 103 for analysis of hydrocarbons in soils, and from 18 AAC 78.315(d)(3) specifying the integration range for analysis of residual range organics, and only for the specific project listed as follows:
Underground storage tank release investigation, in association with buildings 47-203, 955, 979, 45-070 and 28-008 at Fort Richardson Alaska.
Note that all other portions of these regulations cited must be adhered to, including the requirements to take samples for petroleum hydrocarbons and for data collection and interpretation by a qualified, impartial third party in accordance with the UST Procedures Manual.
The conditions for issuance of this waiver are:
1. During the waiver period, laboratory analyses performed in support of activities regulated by 18 AAC 78, ADEC Underground Storage Tank Regulations, must be performed by a laboratory that is approved by the Department. Further, the analytical methods used for soil and water analyses for gasoline range, diesel range, and residual range petroleum hydrocarbons must be:
a) for gasoline range hydrocarbons, EPA method 8015 Modified, and integrated from the beginning of C6 to the beginning of C10 and a boiling point range between approximately 60oC and 170oC;
b) for diesel range hydrocarbons, EPA method 8100 Modified, and integrated from the beginning of C10 to the beginning of C25 and a boiling point range between approximately 170oC and 400oC;
c) for residual range hydrocarbons, the analytical measurement for the total concentration of petroleum hydrocarbons as derived by using EPA method 418.1, minus the concentration quantified in the gasoline range and diesel range (the ranges listed in a) and b) above).
2. Subject to Condition 3, this waiver becomes void on the effective date of Underground Storage Tank Regulations containing updated procedures for AK 101, AK 102, and AK 103 hydrocarbon analyses revised after November 3, 1995. Thereafter, or beginning August 1, 1996, whichever occurs first, the recipient of this waiver must conform to the requirements of those updated procedures or to the analytical procedures promulgated in the November 3, 1995 version of the regulations, whichever is applicable.
3. This waiver becomes void if the Department, in its discretion, issues a 30 day notice of its intent to revoke this waiver.
4. Because use of the new analytical methods may increase yields from analyses, the person or firm receiving this waiver is advised to plan for the transition to the new methods when considering actions involving the specific project listed above.
cc: Marliyn Plitnik DOWL Engineers. |
Ben Thomas |
| 8/15/1996 |
Update or Other Action |
Remedial Investigation Report for Buildings: 47-203, 955, 975, 979, 45-070, and 28-008 received (DOWL/Ogden Joint Venture). Building 28-008 is located off of Arctic Valley Road, east of the Glenn Highway.
Soil samples collected during the remedial investigation were analyzed for BTEX, GRO and DRO. Five soil samples were analyzed for SVOCs and two samples were analyzed for TOC. Ground water samples were collected and analyzed for BTEX, GRO, and DRO.
Ground water flows in an westerly direction across the site towards the Ship Creek Drainage. AP-3690 was located in the upgradient direction, AP-3692 and AP-3693 were located in the downgradient direction. Ground water was encountered at approximately 35 feet bgs. AP-3690, AP-3692, and AP-3693 were installed in the shallow unconfined aquifer that exists at Fort Richardson.
DRO was detected in borehole AP-3690 in concentrations ranging from 13 to 3,600 mg/Kg with the highest concentration at 15 feet. GRO was detected at concentrations ranging from 7.2 to 840 mg/Kg with the highest concentration detected at 15 feet. DRO was detected in borehole AP-3692 at concentrations ranging from 44 to 370 mg/Kg with the highest concentration at 35 feet.
DRO was detected in borehole AP-3693 at concentrations ranging from 120 to 980 mg/Kg with the highest concentration at 30 feet.
DRO was detected in borehole AP-3694 at concentrations ranging from 150 to 1,100 mg/Kg with the highest concentration detected at 15 feet.
DRO was detected in ground water samples collected from monitoring well AP-3690 at a concentration of 140 ug/L. Other contaminants detected included total xylenes at 30 ug/L, benzene at 16 ug/L, and ethylbenzene at 27 ug/L.
DRO was detected in ground water samples collected from monitoring well AP-3692 at a
concentration of 180 mg/L. Other contaminants detected included GRO at 4,900 ug/L, total
xylenes at 67 ug/L, benzene at 3.7 ug/L, ethyl benzene at 32 ug/L, and toluene at 5.6 ug/L.
Ground water samples collected from AP-3695 detected DRO at a concentration of 2 mg/L and
total xylenes at 1.0 ug/L.
The matrix score for Building 28-008 is 46, or Category A. This requires the following soil clean-up levels: DRO 100 mg/kg, GRO 50 mg/kg, TPH (TRPH) RRO 2,000 mg/kg, Benzene 0.1 mg/kg, and Total BTEX 10 mg/kg.
There is extensive soil and ground water contamination at this site. Contaminated soil can be found from the surface to ground water. The horizontal extent of the surface contamination has not been established. The contaminated soils will continue to leach to ground water.
Ground water samples have DRO, GRO, and Benzene levels in excess of ADEC guidance for clean-up. Ground water contamination is seen in all the monitoring wells. In order to confirm the existing underground storage tank is not contributing to the current levels of contamination, tank integrity testing should be performed.
It is recommended at least two additional monitoring wells be placed in the area around Building 28-008 to further establish the extent of ground water contamination. One well should be placed on the west side of Building 28-008, west of the existing wells. The second monitoring well should be placed down gradient and down slope of Building 28-008. The recommended location for the second monitoring well is at the west base of the hill on which Building 28-008 is located.
The information the additional wells will provide is necessary to adequately perform a Risk Assessment of the Building 28-008 contamination.
It is recommended monitoring wells AP-3690, AP-3692, and AP-3695 be sampled for polynuclear aromatic hydrocarbons (EPA Method 610). This will identify any PAH's associated with the diesel or gasoline contamination that may be present.
It is recommended the two new monitoring wells be sampled for DRO (8100 Modified), GRO (8015 Modified), volatile organic hydrocarbons (EPA Method 8260), and polynuclear aromatic hydrocarbons (EPA Method 610).
Based on the depth, extent, and nature of contamination, a risk assessment is recommended for the contamination associated with Building 28-008. Since the ground water is already contaminated, a leachability assessment is inappropriate. The additional ground water information provided by the additional monitoring wells is necessary to establish gradient and extent of contamination required for the risk based analysis. |
Louis Howard |
| 9/3/1996 |
Document, Report, or Work plan Review - other |
Staff commented on the 12/95 Draft Remedial Investigation report for Building 28008. The report stated that the soils from the surface to the groundwater are heavily impacted and the groundwater is contaminated. Staff requested the Army cleanup the site to meet the applicable water quality criteria (18 AAC 70.020(b) or alternative cleanup levels approved by ADEC using a risk assessment prepared under 18 AAC 78.350.
After conducting the work, ADEC may approved an alternative cleanup level if the Army agrees to place institutional controls on the site, and ADEC determines that the controls placed on the site are necessary to protect human health and the environment. ADEC requested the Army conduct a source removal of the heavily impacted areas in the soil (near AP 3684, AP 3686, and AP 3687) irregardless if the Army decides to pursue a risk assessment or perform an aggressive remedial treatment. This removal action will accelerate remediation of the site by removing a continuing source of petroleum contamination to the soil/groundwater. Staff requested substituting lab method 610 or 625 for method 8270 since either method has a lower detection limit for PAHs than 8270 and will be more useful in a risk analysis of PAHs associated with diesel. |
Louis Howard |
| 2/10/1997 |
Update or Other Action |
Staff received thermal remediation sampling results from the soils removed from the site. All samples were below level "A" criteria and may be disposed of anywhere the Army sees fit. |
Louis Howard |
| 6/16/1997 |
Update or Other Action |
Staff received notification from the Army that a contractor detected free product on the groundwater table from one of monitoring wells at approximately 50 feet below ground surface (bgs). Amount of free product detected was approximately one-quarter of an inch in thickness. |
Louis Howard |
| 12/1/1997 |
Document, Report, or Work plan Review - other |
Staff commented a Draft Release Investigation for the site. Staff clarified that there are maximum contaminant levels (MCLs) established for gasoline range organics (GRO) and diesel range organics (DRO) in groundwater. Staff concurred with the recommendations listed in the document, however staff requested that the Army undertake corrective action to remove the free product at the site. Finally, staff requested whether the Army will be cleaning up to matrix levels, alternative cleanup levels via a risk assessment. |
Louis Howard |
| 1/3/1998 |
Site Reopened |
Site reopened due to presence of free product found on water table at site. Army investigating source of petroleum and recovering free product. |
Louis Howard |
| 7/2/1998 |
Institutional Control Record Established |
Updated USARAK institutional control policies and procedures received. The draft USARAK Command Policy Memorandum, Ics standard operating procedure and revised excavation clearance request have been finalized. To ensure the effectiveness of institutional controls, all organizational units and tenant activities will be informed on an annual basis of the institutional controls on contaminated soils and groundwater in effect on USARAK property. Where institutional controls are applicable to any organization, tenant, or activity, land use restrictions shall be incorporated into either a lease or Memorandum of Agreement, as appropriate. Costs for any and all rfemedial actions and fines and/or stipulated penalties levied as a result of a violation of an established institutional control shall be funded by the violating activity or organization. |
Louis Howard |
| 7/31/1998 |
Document, Report, or Work plan Review - other |
Staff received a progress report by CRREL "Hydrogeological Investigations and Mapping of the Subsurface Contamination Zone." A borehole (1 of 8 planned) was completed at a depth of 68.5 feet below ground surface and encountered groundwater at 55 feet below ground surface. 12 shallow monitoring wells were also installed at the site to help constrain the area of the plume as well as provided date on the ground water levels. Resistivity measurements were also taken to attempt to measure the near surface spills that affect soil conductivity. Ground-penetrating radar will be used to supplement the resistivity data. |
Louis Howard |
| 9/10/1999 |
Long Term Monitoring Established |
Staff reviewed and commented on the Draft groundwater sampling and modeling report for the site. Staff concurred with the conclusions that the report does not provide and accurate representation of the plume growth dynamics. Staff requested the Army continue long-term monitoring of the groundwater and the parameters necessary to justify natural attenuation.
Staff also reiterated that free product recovery is paramount under 18 AAC 78.230. Finally, staff stated that the Army must bear in mind that vapors may collect under buildings from the free product that is present at the site. |
Louis Howard |
| 11/2/2000 |
Update or Other Action |
Technical Memorandum dated January 1999 received. Five new wells installed at the site by Corps of Engineers. One well was dry and never produced any groundwater for sampling. Upgradient well AP-4007 located approximately 250 feet east of Building 28008 did detect some petroleum contamination above cleanup levels. Benzene was detected at 5.5 ug/L. |
Louis Howard |
| 11/13/2000 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the draft workplan. The text states that ten wells will be sampled and analyzed for various petroleum constituents as listed in Table 3-1. ADEC requests including monitoring well AP-4007 as an upgradient well which showed benzene contamination slightly above the cleanup criteria of 5 ug/L (AP-4007 5.5 ug/L Corps of Engineers 1999 Technical Memorandum Well). ADEC requests well AP-4008 be sampled in future monitoring events since it had diesel range organics detected at the action level of 1.5 mg/L and may be the leading edge of a plume at the site (COE 1999 Technical Memorandum). This would be in addition to well AP-4006 which was recommended in the workplan as a well for future groundwater sampling. |
Louis Howard |
| 5/29/2001 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on a groundwater sampling and limited feasibility study report. Staff requested the Army continue groundwater monitoring at the site for all wells that are above current state cleanup levels. Until two consecutive years of bi-annual monitoring (at a minimum) monitoring show contamination below state cleanup levels, ADEC will require continued monitoring of groundwater wells at this site. The text states institutional controls (ICs) as a separate remedial action. ADEC disagrees and wishes to state that ICs would be a requirement for all remedial actions except the “no action” scenario. Costs for ICs and monitored natural attenuation shall be for a time period of at least 30 years or until cleanup levels are achieved. ICs are required for all scenarios where groundwater contamination remains above 18 AAC 75 Table C action levels, state and federal drinking water maximum contaminant levels. ADEC requests a meeting with the Army and U.S. EPA project managers to discuss the results from the latest sampling efforts and potential remedial actions for Building 28-008. |
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 |
| 1/31/2002 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Groundwater Sampling Report for October 2001 Building 28-008 Fort Richardson, AK Contract GS10F0115K Delivery Order DAPC49-01-F-0332. Staff concurred with the recommendations made in the document. |
Louis Howard |
| 2/11/2002 |
Document, Report, or Work plan Review - other |
Staff reviewed and approved groundwater sampling report for December 2001. |
Louis Howard |
| 8/13/2002 |
Document, Report, or Work plan Review - other |
Staff reviewed and concurred with the recommendation on the groundwater sampling report for the building. |
Louis Howard |
| 11/18/2002 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the draft management plan for monitoring wells on the Post, dated October 23, 2002. The Department has reviewed the document and approves the document as written. Please note that the Department’s review and concurrence on this monitoring approach is to ensure that the work is done in accordance with State of Alaska environmental conservation laws and regulations. While the Department may comment on other state and federal laws and regulations, our concurrence on the monitoring approach does not relieve the U.S. Army, agent of the U.S. Army, civilian personnel, contractors or their subcontractors, from the need to comply with other applicable laws and regulations. |
Louis Howard |
| 12/27/2002 |
Document, Report, or Work plan Review - other |
Staff reviewed and concurred on the recommendations for the groundwater sampling report for the site. |
Louis Howard |
| 1/24/2003 |
Site Number Identifier Changed |
Changed Workplan from X0 to X1. |
Louis Howard |
| 8/16/2004 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the groundwater monitoring report for bldg. 28008. The Department concurs with the reduction of groundwater monitoring from semi-annual to an annual basis. The Department is willing to review and comment on any work plan developed for actively remediating the lingering source area. However, it would be in the Army’s best interest to conduct a limited feasibility study prior to pursuing active treatment versus long term monitoring combined with natural attenuation and limited product removal. |
Louis Howard |
| 8/18/2005 |
Document, Report, or Work plan Review - other |
Staff reviewed and approved the groundwater monitoring report for bldg. 28008. |
Louis Howard |
| 7/12/2006 |
Document, Report, or Work plan Review - other |
Staff reviewed and approved the groundwater monitoring report for bldg. 28008. |
Louis Howard |
| 2/23/2007 |
Exposure Tracking Model Ranking |
|
Louis Howard |
| 7/15/2011 |
Update or Other Action |
Staff received the Draft Work Plan Environmental RA-O and LTM and Maintenance Joint Base Elmendorf-Richardson, Alaska. The JBER-Richardson Installation Restoration Program (IRP) sites include Building 28008, Former Building 987, Building 59000, the Biathlon Range, Former Building 762, and Building 786. These are petroleum-contaminated sites within a long-term monitoring program under a two-party agreement between the U.S. Army and ADEC. The and LTM for the JBER Richardson Multiple IRP sites includes groundwater sample collection and analysis at six sites, replacement of damaged wells at three sites (and associated soil sample collection), installation of new wells at one site, maintenance of existing monitoring wells, and monitoring and maintenance of product collection devices at two sites.
Remedial action objectives for Building 28008 were established in the Remedial Action Work
Plan, Building 28008 (ENSR, 2002) and include the following:
-Restore groundwater to state drinking water quality.
-Prevent further leaching of contaminants from soil to groundwater.
-Minimize potential migration of contaminants to Dishno Pond, located approximately
-2,200 feet north of the site.
-To fulfill these objectives, current activities include annual groundwater monitoring and passive recovery of free product in source area wells.
Building 28008 is located across the Glenn Highway from the main cantonment area, just east southeast of the Moose Run Golf Course at the base of the Chugach Mountains. Constructed in the 1950s, Building 28008 serves as the drinking water treatment facility for the Ship Creek drainage and provides drinking water for JBER. Around the time of construction, two 10,000-gallon underground storage tanks (USTs) were installed on the east side of the building to store diesel fuel for emergency operations.
Field activities for the six JBER-Richardson sites include passive free product skimmer monitoring and maintenance (Building 59000 and Building 28008), groundwater sampling (all sites), soil sampling (during well installation at Building 987, Building 59000, the Biathlon Range, and Building 786), well installation and decommissioning (installation only at the Biathlon Range, installation and decommissioning at Building 987, Building 59000, and Building 786), and monitoring well maintenance (all sites).
With the exception of the monthly maintenance of product skimmers at Building 59000 and Building 28008, all field activities for these sites are currently scheduled to be conducted in the fall (August–September) timeframe. The contractor will coordinate with Base Operations for access to the Building 28008, Building 59000, and Biathlon Range sites (which require special clearance) to eliminate unnecessary delays or interruptions to military operations.
Passive free product skimmers are currently in place in four wells (AP-3796, AP-3876, AP-3885, and AP-3886) at Building 28008 (Figure 8.2) and three wells (AP-3875, AP-5013, and AP-5014) at Building 59000 (Figure 8.6). These skimmers will be monitored and maintained on a monthly basis throughout the period of performance starting in June of 2011 and going through September 2012. During the maintenance events, each skimmer will be removed from the well and examined. Any free product will be transferred to appropriate Department of Transportation-(DOT-) approved sealed containers. The skimmers will be inspected and wiped clean of buildup that might interfere with function. The recovered product will then be transferred to the JBER Richardson IDW facility for processing and disposition.
The site-specific analyses for groundwater sampling each of these sites are listed below.
- Building 28008 - GRO, DRO, RRO, BTEX, SVOCs
- Former Building 987 - GRO (AP-3462, AP-4343, AP-4372), DRO (AP-3460, AP-3462 [replacement], AP-4343, AP-4372), BTEX (AP-3460, AP-3462 [replacement], AP-4343, AP-4372), SVOCs (AP-3462 replacement), 1,2-DCA (AP-3462 replacement)
- Building 59000 - DRO, BTEX, SVOCs, sulfate, nitrate/nitrite, dissolved iron,
manganese, methane/ethane/ethene
- Biathlon Range - DRO, BTEX, SVOCs (two of three wells)
- Former Building 762 - DRO, VOCs, PAH
- Former Building 786 - DRO, GRO, BTEX/VOCs, SVOCs |
Louis Howard |
| 7/26/2011 |
Update or Other Action |
Staff received the fall 2010 Groundwater Monitoring Report for Bldg. 28008.
Groundwater monitoring at Building 28-008, Joint Base Elmendorf-Richardson (JBER)-Richardson (Formerly Fort Richardson), Alaska was conducted in December 2010. The scope of work designated 10 monitoring wells for monitoring. Six wells were sampled for laboratory analysis of fuel constituents (see Section 2.3 for a list of performed tests and Section 4 for a discussion of the analytical results). The remaining four wells contained free product and were not sampled for dissolved-phase constituents. Additional activities included a groundwater elevation survey.
Based on historic and current groundwater sampling results, the following conclusions can
be drawn:
- Although there has been an overall reduction in product thickness since monitoring commenced in the late 1990s, light nonaqueous phase liquid (LNAPL) continues to be present in AP-3794, AP-3796, AP-3876, and AP-3885 in a layer less than or equal to 0.24 foot in thickness. The horizontal extent of free product within the source area appears to be stable.
- Diesel-range organics continue to be present at concentrations exceeding Alaska
Department of Environmental Conservation (ADEC) cleanup levels in the source area.
- Benzene has been detected above the ADEC cleanup level consistently at well AP-3796. Benzene has also been detected above the cleanup level at upgradient well AP-4007 twice, once in 1999 and once in 2007. The source of benzene at the upgradient well is unknown.
- Contaminant concentrations continue to fluctuate within individual wells, making overall trends difficult to identify. Source area wells are particularly difficult to analyze
for trends because of the frequent presence of LNAPL
|
Louis Howard |
| 8/3/2011 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the work plan for environmental remedial action and LTM.
8-8 and 8-9 8.2.2 Water quality parameters are considered stable when three successive readings, collected
3-5 minutes apart, are within:
• ± 3% for temperature (minimum of ± 0.2 oC),
• ± 0.1 for pH,
• ± 3% for conductivity,
• ± 10 mv for redox potential,
• ± 10% for dissolved oxygen (DO), and
• ± 10% for turbidity.
A minimum of three (minimum of four if using temperature as an indicator) of these parameters should be monitored and recorded (ADEC May 2010 Draft Field Sampling Guidance A. General Guidelines Page 29).
ADEC will require that a fourth field parameter be used in addition to the three proposed in the document (pH, specific conductivity and temperature) to determine when a well is considered stable or stabilized. This comment is applicable for sampling activities of any monitoring well on JBER. The variance allowed for considering temperature and conductivity “stable” is a three percent (3%) variance not ten percent (10%) as stated in the document.
The text states: “Trip blanks will be kept with samples and analyzed whenever volatile organic samples are required.” ADEC will require one trip blank per analysis and cooler for all water samples being analyzed for GRO, BTEX or VOCs. The allowable tolerance for trip blanks will be less than the practical quantitation limit (ADEC May 2010 Draft Field Sampling Guidance Table 3).
1-8 1.3.6 Lack of PID readings, visual or olfactory observations shall not preclude the collection of the required soil samples from borings on JBER.
2-8 2.1.5 The following applies to existing monitoring wells on JBER: At sites with long-term detection monitoring, survey the location of each well, the elevation of the land surface, and the top of each well casing. A registered professional surveyor or registered civil engineer engaged in the practice of surveying must conduct this work.
Sites undergoing contaminant assessment monitoring with a large number of monitoring wells should have the wells surveyed as described above. Re-survey monitoring wells every five years, or more frequently, if freeze-thaw processes compromise the well (Pages 7 and 8 from ADEC’s Monitoring Well Design and Construction for Investigation of Contaminated Sites, February 2009)
2-10 2.2.2 The text states: “In the event that floating product is detected in the well, a disposable polyethylene bailer will be used to first remove the product from the top of the water column. The bailer will be lowered to just above static water level and purging cycles performed until no visible product remains at the groundwater interface. After the field crew has determined that no product remains in the casing, actual sampling procedures will commence.”
The statements in this section are in conflict with the statements from Section 2.2.1 Well Purging on Page 2-9: “Samples will not be collected from wells with measurable product because the samples would contain light nonaqueous phase liquids (LNAPL) that is not representative of dissolved phase concentrations.” Please clarify whether or not wells containing measurable free product will be sampled. |
Louis Howard |
| 6/6/2012 |
Update or Other Action |
Draft Project Management Plan received for review and comment.
Performance Objective
Optimized Exit Strategy for Site Closure
Performance Indicators
· Annual RA-O/LTM and associated reporting under existing work plan
· Complete an approved OES Plan by May 2013
· Complete an approved Characterization/Cleanup Plan by May 2013
· Coordinate, mobilize, and execute characterization/cleanup by October 2013
· Complete an approved characterization/cleanup report in 2014
· Complete OES Implementation Plan and Confirmation Report
Potential Risk
Extent of impacted soil presenting a direct contact risk to site workers is greater than
anticipated. DRO or product plume appears to be expanding.
Risk Mitigation
Excavate additional soil as needed from the upper 15 feet bgs (250 yd3) to eliminate direct
contact risk. Install additional wells to better define plume boundaries or for use in passive
product recovery. Product thickness is too thin for efficient active recovery (pumping).
Access to CC-FTRS-01 (Bldg 28-008 UST Site) must be coordinated with the privatized
utilities contractor, Doyon Utilities. Bldg 28-008 is the water treatment plant.
Date of Achieving Performance Objective
2nd Quarter FY2013
Planned Approach
Prepare an approved OES Plan and coordinate, mobilize, and execute Site Characterization by
installing and sampling two soil borings and collect groundwater samples.
Use HRC to evaluate SC based on risk to future residential receptors for all pathways.
Perform cleanup/monitoring actions for soil by thermal treatment and groundwater with LTM.
Prepare an approved OES Plan to achieve SC. |
Louis Howard |
| 6/22/2012 |
Document, Report, or Work plan Review - other |
Staff provided review comments on the draft PMP.
2.3 Quality Control Documents
Please be aware that the federal facility agreements and Ft. Richardson Environmental Restoration Agreement require submittal of laboratory data to the agencies for review as follows:
The Parties shall make available to each other quality-assured results of sampling, tests, or other data generated by or on behalf of any Party under this Agreement within sixty (60) days of field testing or the submittal of data to the laboratory.
If quality assurance is not completed within sixty (60) days, preliminary data or results shall be made available within the sixty (60) day period and quality assured data or results shall be submitted as they become available but in no event later than one hundred (100) days after testing or the submittal of data to the laboratory. These periods can be extended upon mutual agreement among the Project Managers.
Page 2-31
The text states: “The WPs will be submitted in the initial phases of the project for Air Force and regulatory review and concurrence according to the schedule outlined in the IMS. If regulatory agencies elect not to review/approve documents, approval will be sought through the Secretary of the Air Force/Installations and Environment (SAF/IE) to proceed with execution of the plan activities. The WESTON Team understands that a procedure has been established for this situation, and that the Air Force controls this process.”
Failure to obtain work plan approval before implementing site work described above is considered a violation of Alaska regulations and may result in field work not being approved or additional work being required and may subject responsible parties and/or contractors to a Notice of Violation (NOV).
In addition, proceeding with unapproved work plans and finalizing documents which are not approved by EPA or ADEC will likely cause the regulatory agencies to invoke dispute resolution as allowed for under the respective Federal Facility Agreements (XXI Dispute Resolution).
7.1.2
Document Preparation and Version Control
Draft and Draft Final Versions of documents
Agency review of draft/draft-final version of documents are subject to those review time frames for primary and secondary documents and conditions as specifically identified in the respective Federal Facility Agreements for JBER or a mutually agreed upon schedule agreed to in writing by the three agencies’ remedial project managers.
For petroleum sites (aka Two Party sites) overseen by ADEC refer to the following:
ADEC will strive to complete plan reviews and respond to JBER within thirty (30) days after receipt of plans, although this is not always possible nor is it a requirement. At times, JBER requested expedited plan reviews are feasible based on project manager work load, adequate up-front planning, and contractors providing complete, well written plans.
Independent QA Oversight on Performance Based Contracts
The site cleanup rules require that “collection, interpretation, and reporting of data, and the required sampling and analysis is conducted or supervised by a qualified, impartial third party”. Depending upon the specific terms in a performance based contract, a contractor may no longer be considered an impartial third party with respect to collecting, interpreting and reporting data.
This should be taken into consideration when preparing scopes of work. ADEC strongly recommends the Air Force provide an on-site Quality Assurance Representative or a third party QA oversight contractor to monitor fieldwork for consistency with approved plans and contract requirements.
|
Louis Howard |
| 7/25/2012 |
Update or Other Action |
Draft 2011 GW Monitoring & Borehole Sampling report received for TPA 28008, 59000, former blgs. 987, 762, 786 on JBER-Richardson.
- Although there has been an overall reduction in product thickness since monitoring commenced in the late 1990s, LNAPL continues to be present in AP-3794, AP-3796, AP-3876, & AP-3885 in a layer that has been 0.08 foot or less in thickness since October 2004. The LNAPL source area appears to be stable.
- DRO continue to be present exceeding ADEC cleanup levels in the source area.
- Benzene has been detected above the ADEC cleanup level consistently at source area well AP-3796. Benzene has also been detected above the cleanup level at upgradient well AP-4007 twice, once in 1999 & once in 2007. The source of benzene at the upgradient well is unknown.
- Contaminant levels continue to fluctuate within individual wells, making overall trends difficult to identify. The cause of these fluctuations is not known.
The Building 28-008 site has LUCs in place restricting soil excavation & transport offsite & use of GW onsite is prohibited. The LUCs appear to be protective & prevent exposure to contaminated soil & GW at the site, remain effective, & are being correctly implemented.
A water level survey of the 10 monitored wells at Building 28-008 was conducted on August 25, 2011. During this survey, LNAPL was detected in wells AP-3885 & AP-3794 & also in well AP-3876, which contains a passive recovery device & had a strong fuel odor.
During the water level survey, measurable LNAPL was detected in source area wells AP-3794 (0.08 foot) & AP-3885(0.01 foot). Non-measureable LNAPL was detected in well AP-3876 when an LNAPL layer developed during purging. Passive sorbent socks in source area wells AP-3796 & AP-3876 were temporarily removed during the water level survey. Both socks contained sorbed LNAPL; however, no measurable LNAPL was present in either well.
Because the presence of LNAPL will cause dissolved-phase analyses to be biased high, wells containing LNAPL (measurable product layer &/or where purge water developed a visible sheen that coated most of the surface) were not sampled. Measurable LNAPL was detected in source area wells AP-3885 at a thickness of 0.01 inch & in AP-3794 at a thickness of 0.08 inch.
A measurable LNAPL thickness in source area well AP-3876 was not detected, however, an LNAPL layer developed during purging. GW samples were not collected from source area wells AP-3885, AP37-94 or AP-3876 due to the presence of LNAPL.
Source area well AP-3796 has historically contained LNAPL & the DRO & benzene levels of the sample collected in August 2011 exceeded ADEC cleanup criteria at 5400 µg/L & 9.7 µg/L, respectively. Samples from downgradient well AP-3884 & source area well AP-3796 contained detectable levels of other target analytes, but less than ADEC cleanup levels. The following discussion summarizes the analytical results for the 2011 sampling event.
DRO was detected in source area well AP-3796 & downgradient well AP-3884 at concentrations of 5400 & 960 µg/L, respectively. The DRO was detect at 5,400 µg/L in AP-3796 is more than 3 times the 1,500 µg/L ADEC cleanup level for DRO & demonstrates the biased high nature of analytical results from sampling wells that contain or have contained NAPL. DRO was not detected in the upgradient or other downgradient wells that were sampled.
GRO was detected in source area well AP-3796 & downgradient well AP-3884, at concentrations of 1,100 & 100 µg/L, respectively. These results are below the 2,200 µg/L ADEC cleanup level for GRO.
RRO was not detected in the samples submitted for analysis.
BTEX constituents were detected in both source area well AP-3796 & downgradient well AP-3884. The benzene level of 9.7 µg/L detected in the GW collected from well AP-3796 was the only result to exceed its respective ADEC cleanup level (5 µg/L for benzene). The benzene level for well AP-3884 was estimated at 0.21 µg/L. Ethylbenzene & xylenes were less than their ADEC cleanup levels.
PAHs were detected in two of the wells sampled: source area well AP-3796 & downgradient well AP-3884. All were less than their respective ADEC cleanup levels.
The following presents deviations from the Work Plan and the reasoning behind the deviation.
- CH2M HILL did not perform monthly monitoring and maintenance of the passive LNAPL skimmers in 2010 because this effort was performed by the previous contractor.
- Source area wells AP-3876, AP-3794, and AP-3885 were not sampled because of the presence of LNAPL.
- Analytical results are not provided for RRO at wells AP-4006, AP-3881, AP-3880, and AP-4007 because of incorrect designation of selected analyses on the contaminant of concern (COC). |
Louis Howard |
| 4/30/2013 |
Update or Other Action |
Draft Annual Monitoring Report received for review and comment.
Historical sampling results for TU101 have indicated that fuel constituents are present in groundwater above State cleanup levels in 18 AAC 75 Table C and fuel constituents in soil above 18 AAC 75 Tables B1 and B2. DRO, GRO, RRO, and benzene have been historically detected at concentrations exceeding the cleanup criteria for groundwater. Free product has been historically present at wells AP-3794, AP-3796, AP-3876, and AP-3885.
DRO was detected above cleanup levels in monitoring wells AP-3796 and AP-3885, and benzene exceeded the cleanup criteria at well AP-3796. Measurable free product was observed during the September 2012 sampling event at wells AP-3794, AP-3796, AP-3876, and AP-3885 at thicknesses ranging from 0.01 foot at wells AP-3796 and AP-3885, to 0.04 foot at well AP-3794. Samples were not collected. During the November 2012 sampling effort, after permanent bladder pumps had been installed, free product was observed at wells AP-3794 and AP-3876, and samples were not collected.
An OES Plan is in development for TU101 under the current PBR contract. Proposed actions include additional characterization, analysis of site risk using the HRC calculator, removal of free product from source area wells, and (if needed) excavation of contaminated soil. Annual groundwater monitoring and evaluation of natural attenuation will continue at wells included in the JBER Groundwater Monitoring Program until concentrations of DRO, GRO, RRO, and benzene are below groundwater cleanup levels. Monitoring wells for the site included in the groundwater monitoring program may be adjusted with ADEC approval and as supported by annual long-term monitoring results. |
Louis Howard |
| 5/14/2013 |
Update or Other Action |
Draft UFP-QAPP SC Work Plan received for review and comment.
The overall objective for the site is to meet “unrestricted or residential site use” criteria and achieve a “cleanup complete without institutional controls (ICs)” determination. To meet this objective, soil and groundwater samples will be collected to characterize risk to human health and the environment within the framework of the ADEC site cleanup process (Title 18 Alaska Administrative Code Chapter 75 [18 AAC 75] Sections 325 to 390; and 18 AAC 78, Section 600).
If 18 AAC 75 Method Two soil cleanup criteria are exceeded, the Hydrocarbon Risk Calculator (HRC) approach under Method Three will be used to assess whether site conditions meet ADEC risk criteria (in which case, a “cleanup complete without ICs” determination will be requested) or whether the site poses unacceptable risk (in which case further remediation may be required).
If unacceptable risk is indicated by the HRC, or if contaminants in vadose zone soils exceed maximum allowable concentrations, then remedial options will be evaluated that address the contaminants of concern and associated exposure routes that contribute enough risk to cause the cumulative risk estimate to exceed the risk standard.
Up to three new soil borings will be drilled and groundwater samples collected as shown on Figures 2 and 3 and as discussed below:
• Soil:
– One boring will be drilled near former boring AP-3690 to resample the soil at the location and depth where previous sampling showed exceedances of the migration to groundwater criteria for DRO, GRO, and benzene, and to collect source area soil samples for polycyclic aromatic hydrocarbon (PAH), volatile petroleum hydrocarbons (VPH), and extractable petroleum hydrocarbons (EPH) analysis.
– Two borings will be drilled downgradient of the former tanks to assess the lateral extent of soil contamination.
– Up to 27 new primary soil samples will be collected and analyzed for GRO, DRO, RRO, and petroleum-related volatile organic compounds (VOCs). Three of those soil samples will also be analyzed for PAHs, EPH, and VPH. One of the soil samples will be analyzed for soil bulk density, grain size distribution, specific gravity, and soil moisture content.
• Groundwater:
– Newly installed bladder pumps will be maintained in DRO-affected wells AP-3794, AP-3885, AP-3796, and AP-3876 to ensure groundwater samples are not affected by sheen.
– Annual monitoring will continue to be performed at up to 10 existing monitoring wells (AP-3794, AP-3796, AP-3876, AP-3880, AP-3881, AP-3883, AP-3884, AP-3885, AP-4006, and AP-4007) as part of the long-term groundwater monitoring program. If free product remains in the wells, the product will continue to be passively removed with sorbent socks.
– Up to approximately 10 new primary groundwater samples will be collected and analyzed for GRO, DRO, RRO, VOCs, PAHs, lead, and ethylene dibromide (EDB) as part of the long-term groundwater monitoring program. |
Louis Howard |
| 5/31/2013 |
Update or Other Action |
Staff reviewed & commented on the draft UFP-QAPP work plan.
Table 10-2 Historical GW Data
AP-3796 (screened at 53.5’)
Ethylbenzene
Every instance where ethylbenzene was detected from August 1997 at 57 µg/L to November 2012 at 49 µg/L is above the Appendix G GW screening level for unrestricted use/unlimited exposure (residential) at 30 µg/L.
It appears that a vapor intrusion pathway evaluation (per ADEC’s October 2012 VI Guidance for Contaminated Sites) is warranted for TU101 based on these exceedences of ethylbenzene in GW & the proximity of AP-3796 to Building 28008 (See Figure 1). Also, the executive summary to this draft work plan states: “The overall objective for the site is to meet “unrestricted or residential site use” criteria & achieve a “cleanup complete without institutional controls (ICs)” determination.”
Table 15-2
PAHs
Add the following to the list of PAHs as target analytes if VI pathway is determined to be complete per ADEC’s VI guidance:
1-methylnaphthalene (150 µg/L Table C or 15 µg/L screening level for Table 15-2)
Be aware that the GW vapor intrusion screening level for 1-methylnaphthalene for unrestricted use/unlimited exposure (residential) is set at 140 µg/L which is below the Table C cleanup level of 150 µg/L (Appendix G: Target Levels for GW-VI Guidance for Contaminated Sites October 2012).
Be aware that the GW vapor intrusion screening level for naphthalene for unrestricted use/unlimited exposure (residential) is set at 40 µg/L which is below the Table C cleanup level of 730 µg/L & the screening level of 73 µg/L in this table. The commercial vapor intrusion GW screening level at 200 µg/L is below the Table C cleanup level (Appendix G: Target Levels for GW-VI Guidance for Contaminated Sites October 2012).
Add the following the list of VOCs (including BTEX) as target analytes if VI pathway is complete per ADEC VI guidance:
Cyclohexane (13,000 µg/L tapwater SL November 2012 EPA RSL), n-Hexane (250 µg/L GW SL November 2012 EPA RSL).
Be aware that the unrestricted use/unlimited exposure (residential) vapor intrusion screening level in GW for 1,2,4-Trimethylbenzene is set at 29 µg/L which is lower than the screening level of 180 µg/L in Table 15-2 & the Table C cleanup level of 1,800 µg/L. The commercial vapor intrusion screening level in GW is set at 120 µg/L which is also lower than Table 15-2 & Table C.
Be aware that the unrestricted use/unlimited exposure (residential) vapor intrusion screening level in GW for 1,3,5-Trimethylbenzene is set at 20 µg/L which is lower than the screening level of 180 ug/L in Table 15-2 & the Table C cleanup level of 1,800 µg/L. The commercial vapor intrusion screening level in GW is set at 86 µg/L which is lower than Table 15-2 & Table C.
Be aware that the unrestricted use/unlimited exposure (residential) vapor intrusion screening level in GW for Xylenes (total) is set at 490 µg/L which is lower than the screening level of 1,000 µg/L in Table 15-2 & the Table C cleanup level of 10,000 µg/L. The commercial vapor intrusion screening level in GW is set at 2,070 µg/L which is lower than the Table C cleanup level for Xylenes (total).
The soil gas & GW target levels discussed in Step 4 (of the VI Guidance) may underestimate vapor intrusion when certain site conditions are present (EPA, 2002). ADEC recommends that soil gas & GW data not be used for screening in Step 4 when the following precluding conditions are present:
• Do not use soil gas data for screening when NAPL is in contact with the building foundation.
• Do not use GW data for screening when GW contamination is present within 5 feet of a foundation.
• Do not use soil gas or GW data for screening when a vapor source is present within 15 feet of a foundation, & one or more of the following exists:
o Buildings with significant open-ings to the subsurface (e.g., sumps, unlined crawl spaces, earthen floors);
o Significant preferential pathways, either naturally occurring or anthropogenic; or
o Buildings with very low air exchange rates (< 0.25 air exchanges/hour) or very high sustained indoor/outdoor pressure differentials (> 10 Pascals).
When precluding conditions are present, indoor air samples may be the best option for evaluating exposure within the building.
|
Louis Howard |
| 6/10/2013 |
Update or Other Action |
Draft Letter Work Plan received for review and comment.
This letter work plan serves as an addendum to the 2013 Joint Base Elmendorf-Richardson (JBER) Basewide Uniform Federal Policy – Quality Assurance Project Plan (UFP-QAPP) (USAF, 2013) for annual long-term monitoring and associated field activities at Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and State regulated sites.
This letter work plan includes three tables which list the sites, sampling locations, and constituents to be collected and analyzed during 2013. Tables 1 and 2 are for sites CERCLA and State sites, respectively, on JBER-Elmendorf, and Table 3 is for sites on JBER-Richardson.
Passive free-product recovery (of measurable LNAPL) with sorbent socks will continue at Sites TU058, TU101, and TU103 TU058 in accordance with the Final Work Plan Environmental Remedial Action-Operations and Long-Term Monitoring and Maintenance (USAF, 2011). Wells identified in Table 3 will be inspected monthly, free-product measurements will be collected and recorded at each well, socks will be replaced, and spent absorbent socks disposed of (as necessary). |
Louis Howard |
| 7/24/2013 |
Document, Report, or Work plan Review - other |
ADEC has reviewed the responses to comments for TU101 and TU103 and finds the responses acceptable. Please finalize the documents. |
Louis Howard |
| 3/13/2014 |
Update or Other Action |
Draft 2013 Annual report received for review and comment. The overall project objectives included collecting sufficient data to:
• Monitor concentrations of contaminants of concern (COCs) at each site with sufficient precision and accuracy to evaluate their concentrations with respect to cleanup goals.
• Identify potentially toxic and/or mobile transformation products.
• Verify individual plume characteristics, such as downgradient, lateral, or vertical expansion or retraction.
• Evaluate groundwater flow directions and hydraulic gradients to monitor plume migration and assess contaminant sources.
• Evaluate the effectiveness of land use controls/ institutional controls (LUCs/ICs) to protect human health and the environment.
• Identify and repair damaged monitoring wells to protect groundwater.
• Identify monitoring wells that are no longer needed or are damaged beyond repair.
Historical sampling results for TU101 have indicated that fuel constituents are present in
groundwater above State cleanup levels in 18 AAC 75 Table C and in soil above 18 AAC 75
Tables B1 and B2. DRO, GRO, RRO, and benzene have been historically detected at
concentrations exceeding the cleanup criteria for groundwater. Free product has been historically
present at wells AP-3794, AP-3796, AP-3876, and AP-3885.
DRO was detected above cleanup levels in monitoring wells AP-3796 (2.72 mg/L), AP-3876 (12.3 mg/L), and AP-3885 (5.88 mg/L). Benzene exceeded the cleanup criteria at well AP-3796 (5.42 ug/L) and RRO exceeded the cleanup criteria in well AP-3885 (1.44 mg/L). Measurable free product was not observed during the August 2013 sampling event, however sheen was observed at well AP-3876.
Annual groundwater monitoring and evaluation of natural attenuation will continue at the site
until concentrations of DRO, GRO, RRO, and benzene are below groundwater cleanup levels.
The Air Force recommends that groundwater monitoring at well AP-4006 is ceased since no
constituents have been detected in the well above Table C cleanup levels since 2007, and there
are multiple other downgradient wells nearer to the site that are being monitored. In addition,
absorbent socks will only be deployed in well AP-3876, since it is the only location where sheen
was observed. Monitoring wells for the site included in the groundwater monitoring program
may be adjusted with ADEC approval and as supported by annual LTM results. |
Louis Howard |
| 6/30/2014 |
Document, Report, or Work plan Review - other |
Staff commented on the draft SC report.
ADEC concurs with the recommendations for TU101 and since the groundwater is above Table C cleanup levels for DRO at levels as high as 12.3 mg/L (AP-3876 aka the source well which is higher than the well used as the “source well” AP-3885), the most this site could ever achieve for closure is “cleanup complete with institutional controls” and long-term monitoring regardless of the HRC risk evaluation across all pathways (including groundwater ingestion). Please provide a Mann-Kendall analysis of all wells above Table C cleanup levels not just a source well and downgradient well. It does not appear that AP-3876 is stable or decreasing. UU/UE will not be granted at sites with groundwater contamination above Table C cleanup levels. 12.3 mg/L DRO is above the solubilty limit (~5 mg/L) for DRO which has to have a source in soil contributing to this high level. |
Louis Howard |
| 11/20/2014 |
Update or Other Action |
Draft SC addendum received for review & comment.
The nature & extent of contamination observed in 2014 is consistent with 2013 results, & defined the lateral extent of PAHs where historical data was limited. The maximum levels observed in 2014 are as follows, for analytes detected above the project screening levels (PSL):
• DRO (3,100 milligrams per kilogram [mg/kg], 10 to 15 feet bgs, TU101-SB04)
• GRO (450 J mg/kg, 10 to 15 feet bgs, TU101-SB04)
• Benzene (0.031 J mg/kg, 10 to 15 feet bgs, TU101-SB04)
• 1-Methylnaphthalene (22 mg/kg, 10 to 15 feet bgs, TU101-SB04)
• 2-Methylnaphthalene (32.3 mg/kg, 10 to 15 feet bgs, TU101-SB04)
• Benzo(a)anthracene (3.16 mg/kg, 5 to 10 feet bgs, TU101-SB06)
• Benzo(a)pyrene (2.89 mg/kg, 5 to 10 feet bgs, TU101-SB06)
• Benzo(b)fluoranthene (3.12 mg/kg, 5 to 10 feet bgs, TU101-SB06)
• Dibenz(a,h)anthracene (0.397 mg/kg, 5 to 10 feet bgs, TU101-SB06)
• Indeno(1,2,3-cd)pyrene (1.23 mg/kg, 5 to 10 feet bgs, TU101-SB06)
• Naphthalene (14.5 mg/kg, 10 to 15 feet bgs, TU101-SB04)
The following PAHs were detected at higher levels in 2014: 1-methylnaphthalene, 2-methylnaphthalene, benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, dibenz(a,h)anthracene, & indeno(1,2,3-cd) pyrene.
The source area is approximately 95’ long & 110’ wide, & extends from approximately 10 to 40’ bgs. PAH data was limited in previous investigations, so the 2014 investigation provided additional data to evaluate the extent of PAHs in the source area. The lateral extent of PAHs in soil was defined in 2014 to the PSL except for benzo(a)pyrene, which was detected above the PSL of 0.049 mg/kg in surface soil (0 to 5’ bgs) at the three lateral borings (TU101-SB07, -SB08, & -SB09). Results from the lateral borings were all below the ADEC Table B1 Soil Cleanup Level for benzo(a)pyrene (0.49 mg/kg).
Soil Gas Results
Soil gas screening indicated that the soil is well oxygenated (16.5 to 19.2%), with relatively low concentrations of carbon dioxide (0.6 to 2.3%) & methane (0 to 0.2%). PID readings for the soil gas samples ranged from 2.2 to 63.7 ppm.
No analytes were detected above ADEC shallow (4.5 to 5’ bgs samples) or deep (9.5 to 10’ bgs samples) commercial soil gas target levels. For the future residential exposure scenario, naphthalene was the only analyte detected in soil gas above ADEC residential shallow & deep soil gas target levels at the site. Naphthalene was detected above the ADEC residential shallow soil gas target level of 7.2 micrograms per cubic meter (µg/m3), & deep soil gas target level of 72 µg/m3 at 4.5 to 5’ bgs at TU101-SV01 (36 µg/m3), & 4.5 to 5 (16 µg/m3) & 9.5 to 10’ bgs (76 µg/m3) at TU101-SV02.
HRC results indicate that unacceptable risk is present to onsite workers & potential future residents from direct contact with PAHs in soil. The primary PAHs contributing to the soil direct contact risk include benzo(a)pyrene (66%), dibenz(a,h)anthracene (11%), benzo(b)fluoranthene (8%), benzo(a)anthracene (7%), & indeno(1,2,3-cd)pyrene (6.5%).
In 2013, DRO, RRO, & benzene were detected in GW above the 18 AAC 75 Table C GW Cleanup Levels. Based on 2013 results, HRC results indicate unacceptable risk through the GW ingestion exposure pathway. Benzo(a)pyrene (26%) & dibenz(a,h)anthracene (56%) are the primary risk drivers for the GW ingestion pathway for the current industrial & hypothetical residential scenarios. The EPC for dibenz(a,h)anthracene is an MDL that exceeds the PSL; dibenz(a,h)anthracene has not been detected above the PSL at the site. The cumulative noncancer HI estimates for the hypothetical residential exposure scenario are above the regulatory risk standard for GW ingestion. 1-methylnaphthalene (42%), 2-methylnaphthalene (39%), & naphthalene (16%) are the primary risk drivers for the GW ingestion exposure pathway.
Multiple lines of evidence indicate that the current indoor air exposure pathway at Building 28-008 is insignificant. Specifically, no volatile compounds were detected in soil gas above ADEC’s commercial target soil gas levels; well-oxygenated soil indicates that the subsurface conditions are sufficient to support biodegradation and attenuation of petroleum hydrocarbons in soil gas; and the building compartment nearest the subsurface contamination is only occupied for approximately 10 minutes per week. The VI pathway is potentially complete for a future residential exposure scenario since naphthalene was detected in soil gas above ADEC target soil gas levels. |
Louis Howard |
| 12/4/2014 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft SC Report Addendum.
Building Survey
Page 4
The text states: “Onsite workers include one full-time (24-hour) worker and three to four 8-hour shift workers from Monday to Friday. The compartment of the building nearest to the former tank area is the boiler room, which is located in the basement level (which walks out to grade-level in this portion of the building) and is occupied for approximately 10 minutes each week.”
ADEC VI Guidance states: “If individual workers are present for more than a standard work week, or if sensitive receptors are present, DEC may require the use of the residential level or development of a site-specific target level.” A person staying 24 hours a day at Building 28-008 is inconsistent with the definition of commercial land use. Please include text why a current residential use of the building shouldn’t be applicable at TU101.
There are other building compartments being used by the workers besides the boiler room which may within 30 feet horizontally and/or vertically of the subsurface contamination (see Figures 2 and 3 of the addendum). Please include the cross section from the August 2014 Site Characterization Report TU101 (Figure 4-4 Cross Section A-A’ Page 117 of the PDF) with the addendum’s figures. Please elaborate why the other worker areas (besides the boiler room) are not of concern for vapor intrusion purposes at Building 28-008.
Page 5
The font in this section appears to have changed between paragraphs. Additionally, recommend the location of the building survey and differential pressure readings be identified for reference
Data Quality Evaluation
Page 7
Please identify which samples were qualified in this section due to QA/QC issues.
Page 8
Please explain why VPH results were not rejected for samples analyzed past holding time. Please also document how many days past holding time samples were analyzed.
Site-Specific Risk Evaluation Summary
The text states “Specifically, no volatile compounds were detected in soil gas above ADEC’s commercial target soil gas concentrations; well-oxygenated soil indicates that the subsurface conditions are sufficient to support biodegradation and attenuation of petroleum hydrocarbons in soil gas; and the building compartment nearest the subsurface contamination is only occupied for approximately 10 minutes per week.”
ADEC requests the Air Force state in this section that at least 7 feet of clean (uncontaminated), oxygenated soil is present between the source area and the building foundation which would act as a sufficient barrier to eliminate the petroleum vapor intrusion risk for commercial/industrial use. The vapor intrusion pathway is potentially complete for a future residential exposure scenario since naphthalene was detected in soil gas above ADEC target soil gas concentrations.
Photoionization Detector
Please note that there is no discussion that the PID was calibrated before use on this day.
Leak Check
Please note there is no discussion of a leak check before soil gas sampling on this day.
Please note there is no discussion in field notes of collecting oxygen, carbon dioxide and methane readings. Where is this documented? Is there documentation that the soil gas meter was calibrated before use?
Exterior Soil Gas Probe Installation and Sampling Logs
Please note helium concentration under the shroud is not documented as discussed in earlier reports. |
Louis Howard |
| 1/30/2015 |
Update or Other Action |
TU101 Bldg. 28-008 Site Characterization Report addendum received.
In 2013, DRO, RRO, and benzene were detected in groundwater above the 18 AAC 75 Table C Groundwater Cleanup Levels. Based on 2013 results, HRC results indicate unacceptable risk
through the groundwater ingestion exposure pathway. Benzo(a)pyrene (26 percent) and dibenz(a,h)anthracene (56 percent) are the primary risk drivers for the groundwater ingestion pathway for the current industrial and hypothetical residential scenarios.
The EPC for dibenz(a,h)anthracene is an MDL that exceeds the project screening level; dibenz(a,h)anthracene has not been detected above the project screening level at the site. The cumulative noncancer HI estimates for the hypothetical residential exposure scenario are above the regulatory risk standard for groundwater ingestion. 1-methylnaphthalene (42 percent), 2-methylnaphthalene (39 percent), and naphthalene (16 percent) are the primary risk drivers for the groundwater ingestion exposure pathway
Multiple lines of evidence indicate that the current indoor air exposure pathway at Building 28-008 is insignificant. Specifically, no volatile compounds were detected in soil gas above ADEC’s
commercial target soil gas concentrations; well-oxygenated soil indicates that the subsurface
conditions are sufficient to support biodegradation and attenuation of petroleum hydrocarbons in
soil gas; and the building compartment nearest the subsurface contamination is only occupied for
approximately 10 minutes at the start of each 8-hour shift.
LUCs will be implemented to restrict residential land use in areas where VOC concentrations in
soil gas do not allow for unlimited use and unrestricted exposure (UU/UE) because of potential
indoor air vapor intrusion risks. The LUCs will be designed to prevent or control exposure to
VOCs and to protect human health.
Other rooms of the building that are potentially located within 30 feet horizontally or vertically from the source area include the first floor lab level (occupied 8 hours per day on weekdays and 1 hour per day on weekends), the second floor operator level (staffed 24 hours per day), and the third (top floor) chemical supply level (occupied approximately 5 minutes per hour) (Willis, 2014).
The vapor intrusion pathway is potentially complete for a future residential exposure scenario
since naphthalene was detected in soil gas above ADEC target soil gas concentrations |
Louis Howard |
| 3/24/2015 |
Update or Other Action |
Distance to Surface water right location LAS 21450 is 4,927 feet, File # 21450, Customer Name: USDOD USAF 673 CES/CEIEC (http://dec.alaska.gov/eh/dw/DWP/protection_areas_map.html).
Legal Description
260,000 GALLONS PER DAY FOR GOLF COURSE IRRIGATION FROM THE
SHIP CREEK RESERVOIR WITHIN THE NW1/4NE1/4 SECTION 16, TOWNSHIP
13 NORTH, RANGE 2 WEST, SEWARD MERIDIAN.
THE LOCATION TO WHICH THIS WATER RIGHT APPERTAINS IS:
THE MOOSE RUN GOLF COURSE WITHIN SECTIONS 5, 7, 8, AND 9, TOWNSHIP
13 NORTH, RANGE 2 WEST, SEWARD MERIDIAN, ANCHORAGE RECORDING
DISTRICT, THIRD JUDICIAL DISTRICT, STATE OF ALASKA |
Louis Howard |
| 3/26/2015 |
Update or Other Action |
Result from the required 5 year EPA DW Program UCMR sample results received from EPA 3/26/2015 Sandy Halstead.
JBER is required to test the public water supply for the UCMR (unregulated) compounds at two locations – the initial point of distribution (ship creek) and the furthest end point in the system (pit 18 – don’t know where this is but suspect it’s on the west end of Elmendorf out near Government Hill).
PWS: AK2211423 / USAF Elmendorf AFB Facility: 32229 / Ship Creek TP Sample Point: 34516 / Ship Creek DS EP Monitoring Type: Assessment Monitoring (List 1) Facility Type: treatment plant.
ANALYTE, METHOD, SE1 results SE2 results
chromium (total) EPA 200.8 .4 µg/L .6 µg/L
cobalt EPA 200.8 < 1 µg/L < 1 µg/L
molybdenum EPA 200.8 < 1 µg/L < 1 µg/L
strontium EPA 200.8 200 µg/L 200 µg/L
vanadium EPA 200.8 < 0.2 µg/L .2 µg/L
chromium-6 EPA 218.7 .33 µg/L .5 µg/L
chlorate EPA 300.1 1600 µg/L < 20 µg/L
1,4-dioxane EPA 522 < 0.07 µg/L < 0.07 µg/L
1,1-dichloroethane EPA 524.3 < 0.03 µg/L < 0.03 µg/L
1,2,3-trichloropropane EPA 524.3 < 0.03 µg/L < 0.03 µg/L
1,3-butadiene EPA 524.3 < 0.1 µg/L < 0.1 µg/L
bromochloromethane EPA 524.3 < 0.06 µg/L < 0.06 µg/L
bromomethane EPA 524.3 < 0.2 µg/L < 0.2 µg/L
chlorodifluoromethane EPA 524.3 < 0.08 µg/L < 0.08 µg/L
chloromethane EPA 524.3 < 0.2 µg/L < 0.2 µg/L
PFBS EPA 537 < 0.09 µg/L < 0.09 µg/L
PFHpA EPA 537 < 0.01 µg/L < 0.01 µg/L
PFHxS EPA 537 < 0.03 µg/L < 0.03 µg/L
PFNA EPA 537 < 0.02 µg/L < 0.02 µg/L
PFOA EPA 537 < 0.02 µg/L < 0.02 µg/L
PFOS EPA 537 < 0.04 µg/L < 0.04 µg/L
PWS: AK2211423 / USAF Elmendorf AFB Facility: 45005 / Pit 18 Sample Point: PIT18 / Pit 18 Monitoring Type: Assessment Monitoring (List 1) Facility Type: consecutive connection
chromium (total) EPA 200.8 .3 µg/L .5 µg/L
cobalt EPA 200.8 < 1 µg/L < 1 µg/L
molybdenum EPA 200.8 < 1 µg/L < 1 µg/L
strontium EPA 200.8 210 µg/L 200 µg/L
vanadium EPA 200.8 .2 µg/L .2 µg/L
chromium-6 EPA 218.7 .26 µg/L .42 µg/L
chlorate EPA 300.1 < 20 µg/L < 20 µg/L
1,4-dioxane EPA 522 < 0.07 µg/L < 0.07 µg/L
1,1-dichloroethane EPA 524.3 < 0.03 µg/L < 0.03 µg/L
1,2,3-trichloropropane EPA 524.3 < 0.03 µg/L < 0.03 µg/L
1,3-butadiene EPA 524.3 < 0.1 µg/L < 0.1 µg/L
bromochloromethane EPA 524.3 < 0.06 µg/L < 0.06 µg/L
bromomethane EPA 524.3 < 0.2 µg/L < 0.2 µg/L
chlorodifluoromethane EPA 524.3 < 0.08 µg/L < 0.08 µg/L
chloromethane EPA 524.3 < 0.2 µg/L < 0.2 µg/L
PFBS EPA 537 < 0.09 µg/L < 0.09 µg/L
PFHpA EPA 537 < 0.01 µg/L < 0.01 µg/L
PFHxS EPA 537 < 0.03 µg/L < 0.03 µg/L
PFNA EPA 537 < 0.02 µg/L < 0.02 µg/L
PFOA EPA 537 < 0.02 µg/L < 0.02 µg/L
PFOS EPA 537 < 0.04 µg/L < 0.04 µg/L
As of March, 2014, it is not completely clear how USEPA will handle chlorate in its preliminary third regulatory determination that is expected to be published later in 2014. However, chlorate should at least be considered a potential positive regulatory determination, i.e., a national regulation will eventually be developed.
The timing for such a national regulation is also not completely clear. The third regulatory determination would have to be finalized (maybe late 2015 or early 2016). Then, USEPA would have 24 months to publish a proposed regulation (late 2017 or early 2018), and 12 months thereafter to publish a final regulation (late 2018 or early 2019). Water systems would have the typical three years to come into compliance with the final regulation.
It is also not clear what the final Maximum Contaminant Level (MCL) might be. While the current chlorate HRL of 210 µg/L is certainly some form of current benchmark, establishing an MCL is complex process that takes into account several additional benefit-cost considerations.
|
Louis Howard |
| 7/31/2015 |
Update or Other Action |
Annual field activities report received. A LUC inspection conducted on September 23, 2014, did not identify any LUC issues at TU101; the LUC form is included in Appendix B. A groundwater level survey was also conducted in September. A broken lock was replaced at well AP-3884 and the PVC casing of AP-3796 was cut back after it had frost heaved, to ensure that the well could be secured. The well was resurveyed on October 3, 2014.
Site TU101 has been identified as a Yellow priority because additional data are necessary to
perform Mann-Kendall trend analyses. While it is currently not feasible to perform Mann-Kendall analyses for the wells in the groundwater plume, there is clear evidence that the plume is stable (i.e., not migrating downgradient) and shrinking. Groundwater concentrations at three downgradient wells (AP-3883, AP-3884, and AP-4006) that were previously above Table C cleanup levels have been below cleanup levels since 2007 or earlier.
The use of absorbent socks was discontinued in all wells at TU101 with the exception of AP-3876 in 2014. In accordance with 18 AAC 78.240, free product has been recovered to the “maximum extent practicable” at the site. Although sorbent socks are dirtied by degraded fuel when placed in well AP-3876, no product has been recovered, and no measurable thickness of free product (= 0.01 foot) has been reported in the well since 2013. Therefore, it is recommended that (1) the sorbent sock in well AP-3876 be removed, and (2) one follow-up product level measurement be collected in April 2015 when water levels are typically at their annual low point.
If no measurable product is detected in the well at that time, further attempts to recover free
product will be suspended.
In addition, based on 7 to 10 years of petroleum hydrocarbon concentrations below the cleanup levels at wells AP-3880, AP-3881, AP-3883, AP-3884, AP-4006 (removed from monitoring program in 2013), and AP-4007 (Figure 16-1), it is recommended that groundwater sampling and analysis be ceased at those wells, but that the wells continue to be used for water level measurements during annual monitoring events. Annual groundwater sampling will continue at the four remaining wells included in the TU101 JBER Groundwater Monitoring Program until concentrations of DRO are below groundwater cleanup levels or are otherwise supported by annual long-term management results.
See site file for additional information. |
Louis Howard |
| 8/10/2015 |
Document, Report, or Work plan Review - other |
Staff agreed with the recommendations for 28008 as presented in the Annual report for CERCLA sites. |
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.
Please change the text from “alternative points of compliance” for wells AP-3880, AP- 3881, AP-3883, AP-3884, and AP-4006. These wells are more correctly referred to as sentry wells.
18 AAC 75.345(e) describes what an alternative point of compliance is:
“The point of compliance where groundwater cleanup levels must be attained is throughout the site from each point extending vertically from the uppermost level of the zone of saturation to the lowest possible depth that could potentially be affected by the discharge or release of a hazardous substance, unless the department approves an alternative point of compliance as part of the cleanup action under 18 AAC 75.360.”
“For the department to approve an alternative point of compliance under this subsection, the
(1) alternative point of compliance MUST BE WITHIN the existing groundwater contamination plume; and
(2) the cleanup levels in Table C at (b)(1) of this section must be met at the property boundary in an area where the current use or reasonably expected potential future use of groundwater in the neighboring property is determined to be a source of drinking water, unless a responsible person
(A) demonstrates that attainment of the applicable groundwater cleanup levels is not practicable; and
(B) provides an alternative source of water for affected persons.”
It cannot be determined whether monitoring well locations AP-3794 (a downgradient well of USTs 48 and 49) and AP-3876 (downgradient and slightly cross-gradient from former USTs 48 and 49) have stable or decreasing trends since a sheen was noted during monitoring and no samples were taken. Sheen or free product has been persistent at AP-3794 since 2004 and has resulted in no groundwater samples being taken to document or verify any decrease or increase of DRO (or RRO) in groundwater.
Data from AP-3794 from 1997, 2001, 2002 & 2003 (four years of monitoring) shows LNAPL present at
4,400 mg/L, 2,200 mg/L (1997),
180 mg/L, 21.9 mg/L (2001),
173 mg/L, 166 mg/L (2002),
and 703 mg/L (2003).
These results are significantly above the solubility limit for DRO (~ 5 mg/L) and any statistical analysis of such values is dubious at best when trying to extrapolate any trends years later without any more recent laboratory data to confirm the trends (positive or negative).
RRO appears to have increased from less than 1 mg/L in 2001 to 13.2 mg/L in 2003 in well AP-3794. There are no data points after 2003. There appears to be a continuing source of contamination in the soil contributing to groundwater contamination in the vicinity of AP-3876, AP-3796, AP-3885, AP-3794.
However, ADEC concurs that the sentry wells located further downgradient (AP-3883, AP-4006, AP-3881, AP-3884 and AP-3880) are consistently below Table C and demonstrate that the contamination from AP-3876, AP-3796, AP-3885 and AP-3794 is not migrating any further “off-site”.
ADEC will still require groundwater cleanup levels be attained throughout TU101 from each point extending vertically from the uppermost level of the zone of saturation to the lowest possible depth that could potentially be affected by the discharge or release of a hazardous substance (e.g. diesel fuel from USTs 48 and 49).
|
Louis Howard |
| 8/8/2017 |
Document, Report, or Work plan Review - other |
Staff commented on the draft monitoring well installation. Staff requested that the latest 2016 ADEC field sampling guidance be used instead an outdated 2014 basewide UFP-QAPP. |
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 LUCs 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: The concrete bases ofMWs AP-3876 and AP-3880 have cracked and will be repoured
to secure outer casing in the spring of 2017. No apparent issues with the stability of the well and outer casing were observed at the time of inspection. |
Louis Howard |
| 11/15/2017 |
Update or Other Action |
Draft 2016 Annual Report Monitoring of State-Regulated Sites received. TU101 has been identified as a Yellow priority because: 1) there are no statistically significant increasing COC trends at AP-3796 and AP-3885, 2) statistically significant decreasing trends are present for benzene, ethylbenzene, and naphthalene at AP-3796, and 3) additional representative
groundwater data are necessary to perform Mann-Kendall trend analyses at AP-3794 and AP-3876.
There is clear evidence that the plume is stable (i.e., not migrating downgradient) and shrinking.
Groundwater (GW) concentrations at three downgradient monitoring wells (AP-3883, AP-3884, and
AP-4006) that were previously above Table C cleanup levels have been below cleanup levels since
2007 or earlier. There is also a statistically significant decreasing trend for benzene, ethylbenzene, and naphthalene at AP-3796.
Due to the continuing presence of sheen, a representative sample was not collected from monitoring well AP-3794 in 2016. Further evaluation of monitoring well AP-3794 revealed
that the water column height above the top of the dedicated pump was approximately 3 ft. During
the extended low-flow purge, continual drawdown occurred while purging at a very low flow rate,
indicating a very slow recharge rate at AP-3794. As a result, a new deeper monitoring well is
proposed to be installed in 2017 near AP-3794 in an effort to collect a representative sheen-free sample in that area. A letter work plan for the installation of the new monitoring well at TU101 is currently being prepared.
See site file for additional information. |
Louis Howard |
| 11/15/2017 |
Update or Other Action |
Draft 2016 Annual Report Monitoring of State-Regulated Sites received. Several maintenance issues were identified during the LUC inspection. Findings such as fading/missing labels and placing flagging to ensure wells are visible were remedied at the time of inspection (see well inspection form).
The following well locations and actions were noted for future maintenance:
1) The concrete bases of MWs AP-3876 and AP-3880 have cracked and will be re-poured to secure outer casing in the spring of 2017. No apparent issues with the stability of the well and outer casing were observed at the time of inspection.
See site file for additional information. |
Louis Howard |
| 5/15/2018 |
Document, Report, or Work plan Review - other |
Staff approved the work plan for well installation at TU101. |
Louis Howard |
| 9/5/2018 |
Meeting or Teleconference Held |
Teleconference call with AFCEC, EPA, STANTEC, DOYON UTILIITIES staff re: 28-008 update on sampling inside the building and outside. Doyon's consultant's preliminary SGS laboratory data shows sediment samples obtained from filter backwash area outside of Bldg. 28-008 up to 450 feet away contaminated with detectable amounts of PCBs above 1 mg/kg (1.04 - 5.26 mg/kg). Paint samples contain up to 88,400 mg/kg PCBs (Sample ID 2047030008-PCB BULK-055* from 2nd Floor, Filter Room-Filter Bank #8, Wall Paint-Lt. Green. Sample ID 2047030008-PCB BULK-042* 3rd Floor Filter Room-Filter Bank#6 60,800 mg/kg). Lead Results: Basement up to 52,000 mg/kg [Sample ID 2047030004-PB BULK-010 Raw Water B14. Tank Exterior Paint (Blue)]. 2nd Floor up to 16,000 mg/kg (Sample ID 2047030004-PB BULK-003 Sedimentation Bay 207. Wall Paint-Blue).
See site file for additional information. |
Louis Howard |
| 9/20/2018 |
Document, Report, or Work plan Review - other |
Staff provided comments on the follow-on work plan for sampling. Main comments were to ensure an adequate number of field duplicates were taken as part of the sampling. More duplicates would be required if the sampling occurred over multiple days vs a single day's sampling effort. Staff requested clarification on the term "paint histories" in the context of paint applied in the eight filter bays and clarification on what will be used for cleanup concentration for each media sampled (e.g. paint, soil, concrete, sediment and water).
See site file for additional information. |
Louis Howard |
| 9/28/2018 |
Document, Report, or Work plan Review - other |
Staff commented on the follow-on sampling plan. Main comments requested elaboration on the cleanup levels to be used and the regulatory basis/citation for the site to be provided in the text. Duplicate samples need to be taken at a rate of 10% per day in the field. Clarification was requested on the three paint histories referenced in the text.
See site file for additional information. |
Louis Howard |
| 10/16/2018 |
Document, Report, or Work plan Review - other |
Staff commented on the Site Assessment Plan Addendum for the Water Treatment Plant's backwash discharge channel. Main comments were to request clarification on who is going to conduct the cleanup after assessment is performed (DOYON or JBER).
See site file for additional information. |
Louis Howard |
| 7/11/2019 |
Document, Report, or Work plan Review - other |
Staff provided comments on the Draft Final SI of the Backwash Discharge Area-H2O Treatment Plant
JBER-Richardson dated June 2019. Main comments: A cap can be used for the contaminated soils and/or sediments in the Backwash Channel for the PCBs above 1 mg/kg, however it cannot be simply soil, gravel or rock since it will not be impervious and able to stop the transport of contaminated soil and sediments further into the surrounding environment.
See site file for additional information. |
Louis Howard |
| 9/25/2019 |
Cleanup Plan Approved |
Staff approved the P8233 PCB Removal WP DOYON UTILITIES Joint Base Elmendorf-Richardson
WTP Backwash Channel AKR000204883. |
Louis Howard |
| 9/26/2019 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the draft 2019 Remedial Action Operations, Land se/Institutional Control report. Staff requested clarification on which contaminants had Limits of Detection and Method Detection Limits above the Table C Groundwater Cleanup levels in 18 AAC 75.
See site file for additional information. |
Louis Howard |
| 10/16/2019 |
Cleanup Plan Approved |
Staff reviewed and approved the backwash channel work plan (aka P8233 PCB REMOVAL WORK PLAN, DOYON UTILITIES, JOINT BASE ELMENDORF-RICHARDSON, WTP BACKWASH CHANNEL AKR000204883) for Bldg. 28008. |
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 |
| 2/7/2023 |
Document, Report, or Work plan Review - other |
DEC reviewed 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 |
| 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 |
| 4/25/2023 |
Document, Report, or Work plan Review - other |
DEC approved the 2023 Letter Work Plan Remedial Action Operations and Long-Term Management, Final, Dated April 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 |
| 5/2/2024 |
Document, Report, or Work plan Review - other |
DEC provided comments regarding the Decommissioning Plan for Monitoring Wells AP 3881 and AP 4028, dated April 2024. |
Ginna Quesada |
| 5/15/2024 |
Document, Report, or Work plan Review - other |
DEC approved the Decommissioning Plan for Monitoring Wells AP 3881 and AP 4028, dated April 2024.The work plan describes the procedures for decommissioning two wells (AP 3881 and AP 4028) at the TU101 site on Fort Richardson located at the Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. |
Ginna Quesada |
| 5/15/2024 |
Document, Report, or Work plan Review - other |
DEC approved the Decommissioning Plan for Monitoring Wells AP 3881 and AP 4028, dated April 2024.The work plan describes the procedures for decommissioning two wells (AP 3881 and AP 4028) at the TU101 site on Fort Richardson located at the Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. |
Ginna Quesada |
| 5/15/2024 |
Document, Report, or Work plan Review - other |
DEC approved the Decommissioning Plan for Monitoring Wells AP 3881 and AP 4028, dated April 2024.The work plan describes the procedures for decommissioning two wells (AP 3881 and AP 4028) at the TU101 site on Fort Richardson located at the Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. |
Ginna Quesada |
| 5/18/2024 |
Document, Report, or Work plan Review - other |
DEC submitted comments regarding the 2023 Annual Remedial Action-operations And Long-term Management Report for Select State-regulated Sites Draft, Dated April 2024. 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 were recommended to continue for all sites to ensure that conditions remain protective of human health and the environment. The report recommends updating land use controls (LUC) site boundaries at CG534, a ‘Cleanup Complete’ determination without institutional controls (ICs) for SS522, the removal of groundwater LUCs at SS041, and a ‘Cleanup Complete with ICs determination for TU101. |
Ginna Quesada |
| 6/25/2024 |
Document, Report, or Work plan Review - other |
DEC approved the 2023 Annual Remedial Action-operations And Long-term Management Report for Select State-regulated Sites Final, dated June 2024. 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 were recommended to continue for all sites to ensure that conditions remain protective of human health and the environment. The report recommends updating land use controls (LUC) boundaries at CG534, a ‘Cleanup Complete’ determination without institutional controls (ICs) for SS522, the removal of groundwater LUCs at SS041, and a Cleanup Complete with ICs determination for TU101. |
Ginna Quesada |
| 1/30/2025 |
Document, Report, or Work plan Review - other |
DEC approved the 2025 Remedial Action–Operations and Long-term Monitoring Work Plan Addendum Final, dated January 2024.The work plan describes the site inspections, maintenance activities, and groundwater, seep, and surface water monitoring, activities that will be conducted at multiple sites located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. The scope of work briefly summarizes the site locations, sampling/monitoring activities and schedules. This workplan will remain consistent with the procedures outlined in the 2023 Letter Work Plan Remedial Action-Operations and Long-Term Management. |
Ginna Quesada |
| 4/15/2025 |
Document, Report, or Work plan Review - other |
DEC provided comments for the 2024 Annual Remedial Action-Operations and Long-Term Management Report for Select State-Regulated Sites Draft, dated April 2025.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 were recommended to continue for the majority of the sites to ensure that conditions remain protective of human health and the environment. DEC concurs with the recommendation to close SS522 site without ICs, discontinue groundwater sampling at TU107, and reducing the sampling frequency for some wells at TU103. |
Ginna Quesada |
