| 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 |
| 9/4/1992 |
Site Added to Database |
Petroleum contaminant. |
Louis Howard |
| 12/31/1992 |
Update or Other Action |
RCRA Closure Status Building 755
History/Summary of Closure-Building 755 is the Auto Hobby and Crafts Center for Fort Richardson. Wastes associated with car maintenance activities were found to be dumped in the woods to the northeast of this building. Upon discovering this condition, the EPA issued a Notice of Noncompliance (Docket No. 1090-05-29-6(01). As a result. the site must undergo a RCRA closure/post closure procedure.
In July, 1991 the Corps of Engineers (COE) performed a site characterization of the wooded area near Building 755. As part of the investigation. ten shallow (2 ') borings were acquired as was one deep (11') sample. Analysis of these samples indicated that the soil did not appear to be a hazardous waste although it does require remediation.
ENSR was contracted to perform the closure plan for this site. Their initial closure draft was submitted to the EPA in Dec. 1992 and we are currently awaiting the EPA's reply.
Costs Associated With This Closure
SAMPLING-ENSR suggests that four samples be acquired in undisturbed areas to determine background concentrations, with each of the samples being tested for the entire list of metal and volatile organic COCs. In addition, they recommend removing non-native soil and two feet of native soil. If staining is observed, another two feet of soil will need to be removed. During excavation the soil will be sampled for TCLP analysis at the rate of one sample for every 25 cubic yards of soil removed. Confirmation samples (a total of 22) of the underlying soil will be
collected from the excavated area and analyised. Sample collection and handling will be in accordance with EPA Guideline SW-846, Volume II, Chapter 9.
Soil removal estimates are: 1,300 cu. yds. assuming a disposal area of 120 x 50 feet and a pile height of 6 feet. Note: After this, if the soil under the excavated soil is still contaminated, an additional 1.100 cu. yds. will need to be removed.
POTENTIAL COSTS-If the area is found to be contaminated deeper than expected. additional soil will need to be removed and soil sampling procedures will need performed. Gound water testing and monitoring may also have to done. Also. if hazardous substances are discovered, the soil may have to be disposed of as a hazardous waste. |
Louis Howard |
| 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.
Introduction: Text states that if contamination is present above ADEC recommended cleanup levels, a risk- and leachability-based analysis of alternative cleanup levels will be developed, and a CAP will be prepared as appropriate. Clarification requested on whether the Army proposes 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 work plan.
Project Description: Two former USTs identified: a gasoline tank and a diesel fuel tank at site F. A 1,500 gallon used oil tank (Tank #27) was also reportedly removed from the site and residual petroleum contamination was reported at the limits of the excavation. The release investigation should include investigating the area around Tank #27.
UST #43 at Building 955, the used POL Holding Facility, is listed as a site to be investigated. On November 3, 1992, the Department sent the Directorate of Public Works (DPW), Ms. Jane Smith, a letter noting that tank #43 was reportedly to have stored waste from the Sludge Pit Tank, which appears to be a hazardous waste tank. Therefore, Tank #43 and any associated contamination may have to be closed out as a RCRA hazardous waste tank and spill rather than the UST regulations. Our files do not indicate a response to the letter. This issue needs to be addressed prior to conducting field work.
Soil Borings: The first paragraph states if groundwater is encountered at a depth of greater than 20 feet, but less than 50 feet, two soil borings will be terminated at approximately 20 feet and the third will be converted to a monitoring well. This type of determination should be based on information obtained during field investigations. Terminating borings at 20 feet is not desirable if contamination extends to greater depths.
If groundwater is, or may be, impacted, one monitoring well most likely will not provide sufficient information to determine the presence or extent of contamination and evaluation options for corrective action. If there is not enough flexibility to make such a decision in the field, it may result in another phase of release investigation prior to developing a corrective action plan and would ultimately cost more money.
Plate 5 for Site C, Building 755, identifies a pipeline valve near the former excavation. Please clarify what the pipeline is constructed of and what type of fluid it holds.
Plate 10 for Site H, Building 47-438, shows proposed locations for four soil borings. If possible, a couple of borings should be located inside the former excavations as close as possible to the actual points of release. |
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 |
John Halverson |
| 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. The petroleum site restoration agreement would function as a "two-party agreement" under the FFA. It would track the basic provisions of the 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 |
| 4/26/1994 |
Site Characterization Report Approved |
Release investigation report FTR Project # 21844 received from Army on UST 17 that proposed closure for soil contamination at site. Based on groundwater leachability modeling it appears to be a candidate for closure. |
Louis Howard |
| 11/3/1994 |
Enforcement Agreement or Order |
Janice Adair, Regional Administrator Southcentral Regional Office (ADEC) signs the Fort Richardson-State Environmental Restoration Agreement. The Parties enter this Agreement to perform necessary assessment, remediation, & closure of source areas identified in Attachment A of this Agreement. These activities will follow the schedules listed in Attachment B. A companion Federal Facility Agreement (FFA) for Ft. Richardson has been entered into between the U.S. Environmental Protection Agency, the United States Army, & the ADEC pursuant to section 120 of the Comprehensive Environmental Response, Compensation & Liability Act (CERCLA), 42 U.S.C. 3 9601 et. seq., to address the Army’s obligations under CERCLA.
This agreement does not include source areas which are addressed in the Ft. Richardson FFA. After completion of all required actions, the source area(s) addressed in this Agreement will be included in a Record of Decision in the companion FFA.
ADEC finds that releases of petroleum products & oil within the meaning of AS 46.03.826, AS 46.03.740 & 19 AAC 75.990(35) have occurred at the source areas identified in Attachment A, & have contaminated the land & waters of the State of Alaska.
The petroleum contamination source areas will be remediated pursuant to the levels set forth in 18 &K 75 (non-UST petroleum); the interim soil guidance for non-UST soil cleanup levels, dated July 17, 1991; the guidance for storage, remediation & disposal of non-UST petroleum contaminated soils, dated July 29, 1991; & for water, the applicable water standards set out in 18 AAC 70; & the applicable federal regulatory requirements for Maximum Contaminant Levels for drinking water; & interim guidance for surface & groundwater cleanups, dated September 26, 1990.
If the Army wishes to reduce water contamination concentrations to levels which exceed levels specified above, the Army may prepare a risk assessment which sets forth the justification for the proposed elevated clean-up levels. The risk assessment shall include an exposure assessment. toxicity assessment & risk characterization.
Free product recovery & soil remediation plans shall contain the following information: a schedule for implementation, support for choice of remedial technology, engineered system plans (where applicable), available equipment & skilled personnel, efficiency, reliability (life & difficulty of maintenance, costs & other associated impacts), compatibility of proposed actions with other reasonably foreseeable requirements, need for an on-site pilot scale study, third-party field supervision of remedial actions, procedures for equipment monitoring during remediation, contaminant media analysis to ensure remediation is progressing, & provisions for work documentation. Each plan shall reference the QAPP that will be followed & shall address any source area specific modifications necessary to conduct field work.
Remedial Action Plans for each source area with groundwater contamination shall contain the following information:
a schedule for implementation, support for choice of remedial technology, engineered system plans [where applicable, available equipment & skilled personnel, efficiency, reliability (life & difficulty of maintenance), costs & other associated impacts], compatibility of proposed actions with other reasonably foreseeable requirements, need for an on-site pilot scale study, qualified 3rd-party field supervision of remedial actions in accordance with 18 AAC 75.995(70), procedures for equipment monitoring during remediation, contaminant media analysis to ensure remediation is progressing, & provisions for work documentation.
Each plan shall reference a QA/QC plan addressing all reasonably foreseeable planned activities & shall address any source area specific modifications necessary to conduct field work.
Modifications, extensions, &/or actions taken pursuant to paragraphs 8(Schedule of Actions); 9-16 (Review & Comment on Documents); 17 (Subsequent modification); 37 (Progress Reports); 54-57 (Sampling & Data Document Availability); 63-65 (Extensions/Force Majeure) & Attachment B may be effected by the agreement of the Project Managers. Any modification approved orally under this paragraph must be reduced to writing within 10 days.
Sites covered by Attachment A at time of signing: Bldg. 755 Auto & Craft Shop: waste paints, grease mineral spirits, & oil, Status: RCRA Closure 1990 RFA SWMU: 27 & 72. Bldg. 794 Cannibalization Yard, Bldg. 45590 Motor Pool: waste oil, lubricants, antifreeze, acid, & solvents.
Status: RCRA Closure 1990 RFA SWMU 83. Bldg. 47431 Aircraft Maintenance Facility: drycleaning solvents, grease, hydraulic fluid, methyl ethyl ketone, naptha & waste fuels/oil. 1990 RFA SWMU 87. Bldg. 39800 (Upper Site Summit) & Lower Site Summit Former Nike Missile Site: water with residual solvents, fuels, radioactive material, asbestos. |
Janice Adair |
| 11/14/1994 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Release Investigation Report, Bldg 755, Former UST 17, Fort Richardson Project# 21844
The Alaska Department of Environmental Conservation-Defense Facilities Oversight group (ADEC)
has received, on April 26, 1994 a copy of the above referenced report. Below are ADEC's
comments.
6.5.1 Site C Building 755, Auto and Crafts Center page 6-18
The text recommends closure for UST 17 based on ACLs calculated using SESOIL contaminant
loading model. Based upon a review of the information submitted, no further assessment or
remediation of the site is requested at this time. This does not preclude future remediation or site investigation if new information indicates there is previously undiscovered contamination or exposures that may cause risk to human health or the environment. The department reserves all of its rights under Title 46 of Alaska Statutes to request additional activities in the future if necessary.
The Army is still obligated to comply with all relevant State and Federal regulations to report, investigate and cleanup any/all past, present, and future releases relating to Army activities. ADEC requests MW AP-3167 be included with the areawide monitoring well network for groundwater sampling and not be decommissioned as proposed. |
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 |
| 6/2/1998 |
Institutional Control Record Established |
Based on contamination at site remaining above levels which would allow unlimited access and use (residential) the site has institutional controls placed on it in the Post-Wide general land planning records and maps. |
Louis Howard |
| 6/2/1998 |
Conditional Closure Approved |
Staff reviewed the Release Investigation Report Bldg. 755 Former UST 17 Project # 21844. Site C Building 755 Auto and Crafts Center-The text recommends closure of UST #17 based on alterntive cleanup levels using SESOIL a draft leachability and risk assessment for soil contamination in vicinity of building 755. After briefing section manager and Program manager, received concurrence from program manager on ACL of 3,900 RRO.
This determination does NOT preclude further remediation or site investigation if new information indicates there is previously undiscovered contamination or exposures that may cause risk to human health, welfare, safety or the environment. ADEC reserves all of its rights under Title 46 of Alaska Statutes to request additional activities in the future if necessary. The Army is still obligated to comply with all relevant State and Federal regulations to report investigate and cleanup any/all past, present and future releasses relating to Army activities. ADEC requests monitoring well AP-3167 be included with the areawide monitoring well network for groundwater sampling and not be decommissioned as proposed in the document.
In the future, should contaminated soil or groundwater be discovered on site that exceeds state cleanup standards, appropriate site assessment and cleanup would be required in accordance with applicable State regulations. |
Louis Howard |
| 2/22/2001 |
Update or Other Action |
EPA sent letter regarding RCRA closure under the 1991 Fort Richardson FFCA. December 1992 closure plan appears to contradict the ROD in that the plan refers to soil sampling taken in July 1991 in an area east of 755 that was used to dispose of floor dirt sweepings from Building 755. According to the plan, the results show that the area was contaminated with metals and petroleum hydrocarbons and should be considered hazardous. However, the undated RCRA closure status report for 755 appears to contradict the status report states the July 1991 samples indicated that the soil did not appear to be a hazardous waste although it did require remediation. Therefore, EPA requested USARAK provide the 1991 and 1994 sampling analyses and conclusively demonstrate that these wastes were not hazardous before EPA would agree with USARAK that this unit does not have to be closed under RCRA and FFCA.
In summary, CERCLA actions conducted to date appear to be consistent with RCRA requirements. However, for five of the units, USARAK must supply additional documentation and/or conduct additional cleanup actions before these units can be considered closed in accordance with requirements of RCRA and the FFCA. In addition, USARAK must be responsive to EPA's previous comments and submit a revised interim closure plan for the OB/OD Pad at Eagle River Flats. |
Louis Howard |
| 9/14/2001 |
Update or Other Action |
ICs report for site was received by ADEC. Area where former tank was removed has been asphalted over, eliminating the potential inhalation, ingestion or dermal contact as potential exposure pathways for the RRO contamination at 3,900 mg/kg. April 30, 1998 a Draft Leachability Assessment and risk assessment was received. After review of the information provided, ADEC (Lynn Kent Program Manager) has approved the closure under the Draft 18 AAC 75 Contaminated Sites Regulations as an alternative cleanup level. The approval is for the residual range organics (RRO) present at 3,900 mg/kg in the wooded area near Building 755. This closure does not preclude future remediation or site investigation if new information indicates there is previously undiscovered contamination from the former source areas or other exposures which cause or exceed an unacceptable risk to human health or the environment.
ADEC reserves all its rights under Title 46 of Alaska Statutes and 18 AAC 75 to request additional activities in the future if necessary to address these risks. Future investigation or remedial actions may be required if the Army for any reason excavates the contaminated soils at Building 755 in the future. This site and others that were closed out at levels above those found in the Alaska Soil Cleanup Matrix (A, B, C, or D) will need to be referenced in the final Record of Decision (ROD) for the Post (Currently at 9/26/01 it is Operable Unit E).
ADEC requests monitoring well AP-3167 be included with the area-wide monitoring well network for groundwater sampling and NOT be decommissioned as proposed. |
Louis Howard |
| 9/28/2001 |
Document, Report, or Work plan Review - other |
Staff commented on ICs report for Two Party Sites which includes Building 755 UST 17 FTRS-19. ADEC does not concur that the Army does not need to conduct a five-year review for this site. Hazardous substances remain above levels that would allow for unlimited use and unrestricted exposure.
Please refer to Draft Leachability Assessment and Risk Assessment April 1998 where the Army requested an alternative cleanup level for residual range organics at 3,900 mg/kg. ADEC concurred with the proposed cleanup level on June 2, 1998. As an alternative cleanup level, ADEC expects the Army to impose institutional controls upon the contaminated soils at the site to reduce exposure of workers to contamination at the site.
Also, ADEC expects any excavated soils, which are contaminated to be treated and disposed of in accordance with 18 AAC 78 Underground Storage Tank regulations. Hazardous substances remain at the site above levels, which would allow for unlimited use and unrestricted exposure.
A [periodic] review will need to be conducted within five years (e.g. 2006, 2011, 2016) after commencement of the remedial action to ensure that the remedy continues to provide adequate protection of human health and the environment. |
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 |
| 1/24/2003 |
Site Number Identifier Changed |
Changed Workplan from X0 to X1. |
Louis Howard |
| 8/29/2007 |
GIS Position Updated |
61.2599 N latitude -149.6993 W longitude |
Louis Howard |
| 6/6/2012 |
Update or Other Action |
Draft Project Management Plan received.
Performance objective: Site closure
Performance Indicators:
· Complete an approved Characterization/Cleanup Plan by May 2013
· Coordinate, mobilize, and execute characterization/cleanup by July 2013
· Complete an approved Characterization/Cleanup Report by January 2014
· Achieve SC in 2014
Potential Risk: The nature and extent of soil contamination in the upper 25 feet is greater than anticipated. Groundwater impacts are discovered.
Risk Mitigation:
Excavate soil as needed (estimate 300 yd3) to achieve SC. Monitoring wells will be installed,
and groundwater contamination will be addressed with a technology that is appropriate to the
nature and extent of the plume to achieve SC within the Period of Performance.
Date of acheiving performance objective: 1st Quarter 2013.
Planned Approach
Prepare an approved Characterization Workplan and coordinate, mobilize and execute Characterization by installing and sampling two soil borings and collect one hydropunch groundwater sample.
Use HRC to evaluate SC based on risk to future residential receptors for all pathways.
Prepare an approved Site Characterization Report documenting HRC risk evaluation. Prepare and submit a request for Cleanup Complete without ICs.
Receive concurrence from ADEC that site has achieved Cleanup Complete without ICs and provide documentation to AFCEE. |
Louis Howard |
| 6/22/2012 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the draft Project Management Plan.
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).
7.1.2
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.
However, if significant work plan revisions are required, additional review and comment resolution time will be needed. To facilitate successful project implementation, it is recommended that DoD project managers and contracting staff:
•Coordinate schedules with ADEC in advance and throughout projects.
•Include ADEC in project planning meetings (DQO meetings, UFP QAPP development meetings, Triad and other Technical Project Planning team meetings, etc.).
• Plan and maintain project schedules that include a minimum of forty-five (45) days for reviewing draft work plans, comment resolution, any necessary revisions to the draft-final version and a final review and approval.
See also the Fort Richardson 1994 Environmental Restoration Agreement “Review and Comment on Documents” which states at Section 9. “All draft final work plans for field work, site assessments or remedial actions (both interim and final) must be submitted to ADEC a minimum of 45 days prior to the start of field work or construction. Site Assessment and Remedial Action draft reports must be submitted to ADEC within 120 days after completion of field work.”
• Review contractor planning documents prior to submission to ADEC to ensure compliance with state and federal regulations consistency with agreements made during project planning meetings.
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 |
| 2/12/2013 |
Update or Other Action |
Draft UFP-QAPP received for SS019 Building 755.
Three borings will be drilled near former location AP-3166 to investigate the area of residual
contamination at the former UST/OWS. One boring, SS019-SB01, is located where the vadose zone is interpreted to be contaminated. Two borings, SS019-SB02 and SS019-SB03, are located outside the contaminated zone to assess the lateral extent of soil contamination. Soil borings will be advanced using a direct-push technology drill rig to depths up to 25 feet bgs.
Soil samples will be collected at 5-ft intervals between 5 and 25 feet bgs. If contamination is
observed in the bottom of the boring, the boring will be continued until the last evidence of contamination; two soil samples will be collected beyond that depth; and the boring will be
terminated. Soil cores will be examined for evidence of hydrocarbons (e.g., staining or odor) and will be screened for organic vapors using a PID.
Lithologic descriptions, observations of staining or odor, and the results of field screening with the PID will be recorded on borehole log forms. If borings are advanced to groundwater (which is not anticipated), a HydroPunch groundwater sample will be collected at the water table from each boring. However, if visual observations indicate the presence of potential contamination at or near the water table, then monitoring wells may be installed in the soil borings.
Based on field observations and the results of the PID screening, soil samples within each planned sampling interval throughout the boring will be selected for laboratory analyses. All
soil samples (up to 15 primary samples) will be analyzed for GRO, DRO, RRO, and petroleum-related VOCs. To facilitate HRC calculations, a subset of soil samples will be collected and analyzed as follows:
? Approximately one primary sample from more heavily contaminated soils (as observed at the time of sampling based on PID readings and visual/olfactory evidence of contamination) will be analyzed for PAHs, VPH, and EPH.
? Approximately one sample representative of the site subsurface conditions will be analyzed for bulk density, grain size distribution, specific gravity, and moisture content.
? Approximately one sample from uncontaminated soils that are representative of the source zone will be analyzed for foc.
If the borings are drilled to groundwater (which is not anticipated), one groundwater sample will be analyzed for petroleum-related VOCs, GRO, DRO, RRO, PAHs, VPH, and EPH.
Observations of odor, turbidity, and color will be recorded on the groundwater sample collection
log.
Four borings will be drilled to investigate the area of residual contamination in the wooded area. One deep boring, SS019-SB04, is located at previous sample location AC-02. Three shallow
borings are planned: one near previous location AP-3034 (SS019-SB05) and two shallow borings
(SS019-SB06 and SS019-SB07) to assess the lateral extent of soil contamination. Soil borings will be advanced using a direct-push technology drill rig to depths up to 5 feet bgs.
Soil samples will be collected from 0 to 2 and 3 to 5 feet bgs. If contamination is observed at
5 feet bgs, the boring will be continued to reach the bottom of contamination, two soil samples
will be collected beyond that depth, and the boring will be terminated. Soil cores will be
examined for evidence of hydrocarbons (e.g., staining or odor) and will be screened for organic
vapors using a PID. Lithologic descriptions, observations of staining or odor, and the results of field screening with the PID will be recorded on borehole log forms. |
Louis Howard |
| 3/4/2013 |
Document, Report, or Work plan Review - other |
Staff reviewed & commented on the draft UFP-QAPP.
WS #14 & 16
Post-Investigation Activities
ADEC will require JBER to include the following with the draft report as stated in ADEC’s “Implementing Guidance for the Method 3 Hydrocarbon Risk Calculator” (February 25, 2011).
5.1 95 UCL vs. Maximum Concentration
When using ProUCL with the HRC (similar to when using the ADEC online calculator or in a Method 4 risk assessment) both hard copies & electronic copies of the input & output data from ProUCL shall be submitted to ADEC as part of the written report. JBER must provide supporting documentation for the ProUCL input values. Sites with large source areas that exhibit significant variability in contaminant levels &/or heterogeneous soil properties across soil horizons may require additional data &/or separate evaluation.
8 HRC Submittals
As part of the report, the RP shall submit both an electronic version & a hard copy of the MS Excel calculator with all site-specific inputs & accompanying results. A table listing the site-specific inputs & how the values were derived (data collection method, model, literature source, etc.) shall also be provided as part of the site characterization report.
WS #17 Sampling Design & Rationale
2nd Bullet
The text states: “Calculation of representative 95% UCLs will commonly require 10 or more sample results from within the contaminated soil source area.”
Section 5.1 Page 4 of ADEC's "Implementing Guidance for the Method 3 Hydrocarbon Risk Calculator" February 25, 2011 states:
“ADEC recommends a minimum of 10 data points be used to calculate the 95 UCL.
However, RPs should bear in mind that even 10 data points may not yield a stable UCL if there is higher than normal heterogeneity in contaminant levels."
Page 28
Site-Specific Sampling Plan
The text states: “In the event underground utilities or structures cannot be definitively identified, an air knife & vacuum truck may be used to clear the upper 6 ft of the proposed drilling location prior to drilling or conducting other invasive activities.”
This 6 ft. interval shall not be excluded from field screening & sampling requirements due to it being previously removed & replaced during utility investigation activities. ADEC expects in most cases, that JBER staff can definitively identify the underground utilities at most of the PBR sites for the contractor & the use of the air knife & vacuum truck will be used very infrequently.
Page 29
3rd Bullet
The text states that to facilitate HRC calculations, a subset of [primary] soil samples will be collected & analyzed as follows:
“Approximately one sample from uncontaminated soils that are representative of the source zone will be analyzed for foc.”
Please be aware that the HRC User Manual (January 2011) states:
Section 1 INTRODUCTION Page 1
“Users of the hydrocarbon risk calculator must follow applicable ADEC regulations & guidance documents including, but not limited to, the following:
Title 18, Chapter 75, of the Alaska Administrative Code (18 AAC 75); 18 AAC 78;
Cleanup Levels Guidance (ADEC, 2008);
Cumulative Risk Guidance (ADEC, 2008);
Risk Assessment Procedures Manual (ADEC, 2010);
Guidance For Data Reporting, Data Reduction, & Treatment of Non-Detect Values (ADEC, 2008);
Draft VI Guidance for Contaminated Sites (ADEC, 2009 NOTE: this guidance has been superseded by October 2012 VI guidance);
Guidelines for Total Organic Carbon (TOC) Sample Collection & Data Reduction for Method Three & Method Four (ADEC, 2008); &
Draft Field Sampling Guidance (ADEC, 2010).”
Page A-14 of HRC User Manual
“The default ADEC foc may be used in calculations OR the soil foc values may be measured in (FOUR OR MORE) soil samples collected from the impacted soil strata & near or below the water table depth, outside the NAPL-contaminated soil source area …”
Where the HRC User Manual & the 08-002 Technical Memo differ, the 08-002 Technical Memo shall be followed.
The 2008 Tech Memo 08-002 Guidelines for Total Organic Carbon (TOC) Sample Collection & Data Reduction for Method Three & Method Four states:
“TOC samples must be collected from a minimum of four (4) borings or test pits adjacent to but outside of the zone of contamination. Soil type(s) analyzed for TOC must be representative of the impacted soil type(s). It is recommended the sampling locations be selected at points surrounding (on each side of) the contaminated zone to ensure adequate characterization of the soil TOC variability. If the zone of contamination extends over a significant area, additional samples may need to be collected from the soil horizon below the impacted soils.”
1 sample collected for foc will not suffice. A minimum of 4 or more soil samples must be collected from the uncontaminated soils that are representative of the source zone. |
Louis Howard |
| 5/3/2013 |
Document, Report, or Work plan Review - other |
ADEC has received the final version of the UFP-QAPP SC Work Plan for Building 755 ADEC CS DB Hazard ID 1240 (aka Auto and Crafts Center, Site # R057, 1990 RCRA Facility Assessment SWMU 27 and 72) on JBER-Richardson on April 18, 2013. ADEC has reviewed the document and has no further comments on it. The document is approved. |
Louis Howard |
| 6/10/2013 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 72219 name: auto-generated pm edit Ft. Rich Bldg. 755 UST 17 SFRERA |
Louis Howard |
| 2/4/2014 |
Update or Other Action |
Draft Site Characterization report received for review & comment.
The limit of detection (LOD) for 10 VOCs in soil (2-hexanone, 1,2,3-trichloropropane,
1,2,3-trichlorobenzene, 1,2-dibromo-3-chloropropane, 1,2-dichloroethane, 1,1,1,2-tetrachloroethane, 1,1,2,2-tetrachloroethane, methylene chloride, ethylene dibromide [EDB], and vinyl chloride) exceeded their respective screening levels, as shown in Table 4-3. These non-detect exceedances were either analytes listed in the Basewide UFP-QAPP (USAF, 2013a) where
meeting a lower LOD was not achievable, or the analyte was called out in the Basewide UFPQAPP
as not achievable by the methanol VOC method, and a sample using the low-level method (i.e. low level 8260 with a water carrier) was NOT collected. None of the 10 VOCs were detected in soil at SS019 above the screening levels, and the VOCs are not considered to be COPCs.
PCE was also detected in soil within the vicinity of SS019-SB03-ST, located adjacent to Building 755 (Auto & Crafts Center), at concentrations up to 0.0487 mg/kg (5 to 10 feet bgs). Data indicate that PCE in soil near Building 755 is likely a release separate from the former OWS/UST source area. The lateral extent of PCE in soil in this area needs to be further
delineated.
The lateral & vertical extent of contamination in the wooded debris disposal area located east of Building 755 has been delineated, & all detected concentrations in 2013 are below screening levels. Sample SS019-SB05 was collected from the vicinity of historical borings AP-3034 & AC-02, which had historical exceedances of DRO. SS019-SB05 results for DRO are well below screening levels, & the historical DRO contamination from 1991 & 1995 appears to be no longer present.
Wooded Area
No potential risks to the environment/ecological receptors were observed, & petroleum hydrocarbon contamination in soil is considered insignificant (less than 0.5 acre).
Former OWS & UST Area
In 2013, DRO, RRO, 1,2,4-trimethylbenzene, benzene, m- & p-xylene, PCE, & total xylenes were detected in soil near the former OWS & UST at concentrations above project screening levels. This covers an area approximately 20 by 25 feet & extends vertically from approximately 5 to 30 feet bgs. The total volume of contaminated soils in this area is approximately 12,500 cubic feet.
PCE was also detected in soil at step-out boring SS019-SB03-ST, located adjacent to
Building 755 (Auto & Crafts Center) at concentrations above project screening levels, & suggests a source other than the former OWS/UST. No other COPCs were detected in this area at concentrations above screening levels. PCE in soil at concentrations above the screening level in this area extends from 5 to 20 feet bgs. The lateral extent of the PCE in this area needs to be further delineated.
GW was not encountered during the investigation. The maximum vertical extent of contamination is approximately 40 feet above the unconfined aquifer at 70 to 90 feet bgs.
Cumulative carcinogenic risk & noncarcinogenic HI estimates are above the regulatory risk standards for both the commercial/industrial & future residential use scenarios. Primary risk drivers for carcinogenic risk include benzene, ethylbenzene, & PCE for the indoor air inhalation pathway. The primary risk drivers for noncarcinogenic risk include benzene, xylenes, & 1,2,4-trimethlybenzene for the indoor air inhalation pathway.
The site meets the ADEC risk criteria for bulk hydrocarbons.
No potential risks to the environment/ecological receptors were observed, & petroleum hydrocarbon contamination in soil is considered insignificant (less than 0.5 acre).
Recommendation
No further action is recommended for the wooded debris disposal area to the east of Building 755.
Recommend conducting additional investigation of the former OWS/UST area, as follows:
Perform a soil gas screening evaluation in the area between Building 755 & Second St (& the access road south to the southern extent of the building) to delineate the extent of VOC COPCs (benzene, xylenes, & PCE) in shallow soil gas in relation to the former OWS/UST. Screening would be conducted in a grid-type pattern via temporary vapor probes installed approximately 5 feet bgs. Soil gas samples would be screened with a portable gas chromatograph (GC) with a photoionization detector (PID) (FROG-4000™ by Defiant Technologies, Inc).
Install one soil boring between SS019-SB03ST & SS019-SB01 to collect samples to 25 feet bgs. Analyses would include COPCs (BTEX, PAHs, & PCE) to determine whether contamination near Building 755 is related to former UST 17.
Work would be conducted under a work plan to be submitted under separate cover. Recommendations for further investigation or action would be decided after receipt of result of the screening evaluation. |
Louis Howard |
| 3/4/2014 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft SC report.
Summary of 2013 Site Characterization Activities
The text states: “All samples were submitted to Applied Sciences Laboratory for analysis of gasoline-range organics (GRO), DRO, residual-range organics (RRO), and volatile organic compounds (VOCs).”
Please state here and elsewhere as applicable that Applied Sciences Laboratory (ASL) is the CH2M Hill-Corvalis laboratory, UST-079.
Nature and Extent
The text states: “Five VOCs were also detected above the project screening levels: 1,2,4-trimethylbenzene, benzene, m- and p-xylene, tetrachloroethene (PCE), and total xylenes.”
PCE was not identified previously linked to this site. This document states that there is potentially a separate [new] source of PCE adjacent to Building 755.
In accordance with the requirements of the Fort Richardson Federal Facility Agreement, Part Paragraph 24.3 and 24.4:
“24.3 The Army shall provide notification to U.S. EPA and ADEC within thirty (30) days of identifying a new potential source area. Unless the Parties agree on another disposition, new source areas will be addressed under the last scheduled OU as described in Attachment I.
24.4 The final deadlines established pursuant to this Part shall be published by U.S. EPA, in conjunction with ADEC.”
Nature and Extent
The text states: “The lateral extent of PCE in the soil in this area needs to be further delineated.”
The text shall state: “In accordance with 18 AAC 75.335 , the lateral extent of PCE in the soil in this area needs to be further delineated.”
Human Health Risk Evaluation
Add sentence to discussion on risks outside of the OWS/UST source area (here and on Page 5-2): “Because no groundwater samples have been collected at SS019, the EPCs for groundwater are the concentrations predicted by the “migration to groundwater” calculations (Table C-1.6, page 7).”
Recommendations
The text states: “Recommendations for further investigation or action would be decided after receipt of result of the screening evaluation.”
The text shall state: “Recommendations for further investigation or action under CERCLA as a new source area under the Federal Facility Agreement instead of the State Fort Richardson Environmental Agreement (SFRERA) would be decided after receipt of result of the screening evaluation.”
Regulatory Framework
The text states: “The HRC (version 1.1), a peer reviewed Microsoft Excel spreadsheet model, approved by ADEC as a Method Three and Four tool, is available at http://www.dec.alaska.gov/spar/csp/guidance/hrc/Hydrocarbon%20
Risk%20Calculator.xls.”
ADEC has not approved the use of the HRC for use as a Method Four tool by itself. The HRC can only be used for Method Four if it is part of the risk assessment performed under ADEC’s Risk Assessment Procedures Manual. Otherwise the HRC is merely a risk evaluation allowed for by ADEC under Method Three.
The revised text shall state:
“The HRC (Version 1.1), a peer-reviewed Microsoft Excel™ (Excel™) spreadsheet model approved by the ADEC as a Method Three tool, is available at: Hydrocarbon Risk Calculator (Ver. 1.1) - Excel 1.9MB. When the HRC is used under Method Four, to support alternative groundwater cleanup levels derived as part of a risk assessment, responsible parties must follow the ADEC’s Risk Assessment Procedures Manual.”
|
Louis Howard |
| 5/7/2014 |
Document, Report, or Work plan Review - other |
ADEC finds the responses to ADEC's comments acceptable. Please finalize the document for SS019 Bldg. 755. |
Louis Howard |
| 5/22/2014 |
Update or Other Action |
JBER Text: “Quality control (QC) samples will include field duplicates (FDs), matrix spike / matrix spike duplicates (MS/MSDs), and equipment blanks (EBs) collected as OUTLINED IN Worksheet #20 of the Site Characterization Work Plan (10 percent for FDs, and 5 percent for MS/MSDs). Five primary samples, one FD, one MS/MSD, and one EB will be collected at the site. Table 1 presents a summary of samples and analyses, and rationale for collection.”
JBER Work Plan WS#20 Field QC Summary: “Field QC summary follows the JBER Basewide UFP-QAPP (USAF, 2013) and includes collecting duplicates and MS/MSDs at rates of 10 and 5 percent, respectively. The anticipated number of duplicates and MS/MSD samples are presented in Table 20-1 of this Work Plan (a lower number of duplicates and MS/MSD samples may be collected if the SS019 samples are collected as part of a program and submitted for laboratory analysis with samples from other sites).”
ADEC: Comment
1) ADEC will REQUIRE that all QC samples (e.g. duplicates, MS/MSD, etc) will be collected as required by the UST Procedure Manual Table 4 on a SITE-SPECIFIC basis (no pooling of QC samples as part of a “program” or larger “JBER Project”).Table 4 shows the minimum level of sample QC scrutiny that must be applied to field sampling. A description of each type of field QC sample appears in Sections 9.1.2. - 9.1.5 of this chapter. Reference to sets of samples in this and subsequent subsections refers to samples taken from the same site (or, for multiple sampling points within a single project, from the same area within a site that has uniform characteristics such as grain size and organic content) during the same sampling event during a discrete time period. It does NOT apply to sampling points from DIFFERENT sites, samples taken at significant time differences from each other, nor multiple samples from the same site, but with non-uniform site characteristics.
Allowable Tolerance shall be equivalent to UST Procedure Manual Table 1 for soil (Part A) and groundwater samples (Part B) as specified by the method listed.
JBER Response:
1. As described in the text (“Five primary samples, one FD, one MS/MSD, and one EB will be collected at the site.”) and shown in Table 1, QC samples will be collected from SS019 to meet the requirements of 10 percent for FDs and 5 percent for MS/MSDs, in accordance with the WS#20 of the Site Characterization Work Plan, the JBER Basewide UFP-QAPP, and the UST Procedure manual Table 4. QC samples will be collected on a site-specific basis rather than on a program wide basis.
JBER Comment:
“A soil gas screening evaluation will be performed in the area between Building 755 and Second Street, and the access road north of the building to the southern end of the building, to further characterize PCE in soil. Ten temporary soil gas probes will be installed in a grid-type pattern to approximately 8 feet bgs (Figure 1 and Table 1) using the methods outlined in SOP-5a. Soil gas samples will be screened with a portable gas chromatograph (GC) with a photoionization detector (PID) (FROG-4000 by Defiant Technologies, Inc.) using the methods outlined in SOP-5f.
ADEC Comment
2) Request JBER discuss the process of collecting soil gas samples to be analyzed by an approved laboratory and not just rely on an evaluation of the screening data for VI risk determination.
JBER Response:
1.
2. Collection and laboratory analysis of soil gas samples is not proposed at this time. As noted at the Soil Vapor Sampling Approach Meeting on April 14, 2014, the objective of this investigation is similar in approach to a Gore-Sorber Survey and will be used to help determine whether the PCE detected in soil is indicative of a separate source area, requiring further action under CERCLA. Further actions necessary to define the nature and extent of PCE under CERCLA will be conducted separately. After completion of the screening, Triad style decision making will be used to determine whether further action is necessary for petroleum-related VOCs under the Two-Party Agreement.
|
Louis Howard |
| 5/22/2014 |
Document, Report, or Work plan Review - other |
Responses to ADEC’s comments for SS019 additional site characterization work plan addendum are acceptable. Please finalize the document |
Louis Howard |
| 1/16/2015 |
Document, Report, or Work plan Review - other |
Staff provided comments on the SC Soil gas sampling addendum.
2.0 Site Location and Description
ADEC requests the Air Force discuss the characteristics of the on-site building (i.e. Building 755 Auto and Crafts Center). Building characteristics reduce or dilute vapor intrusion (e.g., vapor barriers and ventilation systems). ADEC requests the Air Force elaborate in the text of the document on whether it is occupied and for how many hours per day and how many days per week. ADEC requests the Air Force to elaborate on what the building used for currently.
Finally, ADEC requests a building survey be conducted if it has not been conducted during the site characterization addendum work or prior during the work plan development stage as recommended by ADEC VI Guidance for Contaminated Sites (October 2012). The questionnaire will help the investigator identify building characteristics (residential, industrial, commercial/Multi-use-what type, floors, insulated, air tight, air flow, etc..) and possible vapor-entry points that will influence the vapor intrusion pathway. This comment is applicable to all contractors that conduct soil gas sampling for JBER-E and JBER-R.
4.2 Soil Gas Screening
ADEC requests the Air Force to please describe the grade of helium utilized for the leak check procedure. Please clarify if the helium verified to be 99.99% pure.
5.2 2014 Soil Gas Screening Results
The text states: “At all 10 soil gas screening locations, concentrations of TCE were below the calibrated detection limit of 137 µg/m3.” The FROG-4000 (a portable GC with a PID) field screening results were used to determine presence or absence and a rough order of magnitude to assess the distribution of PCE and TCE in the subsurface.
Please be aware that there may or may not be a concern for TCE in the soil with a maximum detection of 0.0927 mg/kg. However, this concentration of TCE is still above Table B1 Method Two Migration to Groundwater cleanup level for TCE (0.020 mg/kg). Also, EPA’s screening criteria at Commercial/Industrial buildings for indoor air is much lower than the screening level used by JBER: 8.4 µg/m3 for Short-term noncancer, 0.88 µg/m3 for Chronic noncancer (HQ of 0.1) and 3.0 µg/m3 for Cancer risk of 1x10-6 (Table 1. EPA Region 10 Recommended Media Concentrations of TCE in Standard Environmental Media for Use at Superfund and RCRA Waste Sites). Soil gas samples taken from outside surrounding a building may be quite different (most of the time lower) than indoor air samples taken inside due to a number of factors.
ADEC requests the Air Force to provide a discussion of the duplicate soil gas sample results in this section or reference Appendix B-1.
App. A-1 Field Notes
Field notes are not complete. There are no page numbers, a list of people/team members located on-site is not given. Field measurements and calibration documentation are not provided.
Barometric pressure, and temperature readings would be useful information to provide in field notes for future reference (Applicable to all contractors on JBER-E and JBER-R who conduct soil gas sampling for vapor intrusion pathway).
App B-1 Data Quality Evaluation Report
ADEC requests the Air Force to provide a list of samples that are qualified due to QC failures. Just stating “associated sample results” is not helpful for a reviewer. Additionally, please document in this report the QC measurements that did not meet criteria. A generic statement stating a QC parameter did not meet acceptance criteria is not sufficient. Please provide in this report the actual QC parameter measurement and the associated acceptance criteria.
|
Louis Howard |
| 2/9/2015 |
Update or Other Action |
Staff reviewed response to ADEC comments and approved responses for finalization into the final document for SS019 Bldg. 755 SC Addendum. |
Louis Howard |
| 12/30/2015 |
Update or Other Action |
Soil gas report addendum received for review and comment.
PCE, TCE, and cis-1,2-dichloroethene (cis-1,2-DCE) were detected in samples from SS019-SB09 at
concentrations above their respective project screening levels (ADEC Table B1 Method Two –
Migration to Groundwater cleanup levels). PCE was detected at concentrations above screening
levels in all five samples collected to a depth of 22.5 feet bgs. The highest detected concentration of PCE was 0.119 mg/kg in the sample collected from 7.5 to 12.5 feet bgs. TCE and cis-1,2-DCE were detected at concentrations greater than the screening levels (0.0927 mg/kg and 0.265 mg/kg, respectively) in the sample collected from 12.5 to 17.5 feet bgs. Results of the 2014 soil sampling are consistent with 2013 soil sampling results and confirm that VOCs are present in soil in the vicinity of the piping connecting UST 17A to Building 755.
The data quality evaluation report for the soil samples, presented in Appendix B-1, indicates that
QC requirements have been met and that overall precision and accuracy of the data are sufficient
for project objectives.
PCE was detected in soil gas at concentrations above the calibrated detection limit (172 micrograms per cubic meter [µg/m3]) at two locations: SS019-SV03 (3,080 µg/m3) and SS019-SV07 (1,428 µg/m3). Location SS019-SV03 is located adjacent to the UST piping, and location SS019-SV07 is located just outside the excavation limits of UST 17 (Figure 2). PCE was observed at concentrations below the calibrated detection limits at three other locations: SS019-SV01, SS019-SV04, and SS019-SV06. At all 10 soil gas screening locations, concentrations of TCE were below the calibrated detection limit of 137 µg/m3
Results of the soil gas screening are consistent with soil sampling results and indicate that the
highest concentrations of VOCs (particularly PCE) in soil and soil gas are located near UST 17A
and its piping.
Conclusions
The results of the 2013/2014 soil sampling and soil gas screening indicate that PCE contamination
is limited in extent to the footprint of the UST and to the piping connecting the UST to
Building 755. Comparison of co-located sample locations AP-3166 (1993) and SS019-SB01
(2013) indicates that concentrations of PCE, 1,2,4-trimethylbenzene, and xylenes were at least an
order of magnitude greater (PCE was four orders of magnitude greater) in 2013 than in 1993.
Detection limits for the 1993 PCE data were well below the current project screening level. In the
20 years since the 1993 soil samples were collected, even when taking into account any uncertainty
associated with soil sampling, concentrations of VOCs should have decreased. In addition,
contamination detected in soil in 2013 is shallower, at 5 to 10 feet bgs, compared with 15 feet bgs in 1993.
Based on the nature and extent of contamination, presence at a shallower depth in 2013 than in
1993, and orders of magnitude higher concentrations in 2013 than in 1993, contamination in soil
is not considered to be associated with the historic release from former UST 17, but rather is from a more recent release likely associated with the current UST 17A and its piping. The more recent release prevents completion of an HRC risk evaluation for just the historic contamination
associated with former UST 17 (Site SS019) because data required to run an HRC evaluation (extractable petroleum hydrocarbons/volatile petroleum hydrocarbons [EPH/VPH] and residual range
organics [RRO]) were not collected in 1993. Based on current concentrations of contaminants in soil, it is anticipated that ADEC will require further action for soil, such as additional delineation or remediation of the contaminants associated with UST 17A and its piping,
to achieve site closure. |
Louis Howard |
| 9/16/2016 |
Update or Other Action |
Supplemental work plan received for review to address the groundwater sampling, institutional controls (IC) inspection, and landfill cap inspection activities associated with the 2016 Long Term Monitoring (LTM) at the Joint Base Elmendorf-Richardson (JBER), Sites PL081, CG551, ST408, CG530, SO510, SS522, SO507, SS418, TS003, CG543, CG529, TU107, ST048, CG509, SO508, SO549, AT035, AT029, SS019, and DP009.
As a requirement of the 2016 Environmental Long Term Monitoring contract, the following work shall be performed at JBER Site SS019:
? Perform IC inspection |
Louis Howard |
| 3/22/2017 |
Update or Other Action |
2016 Draft Report for Remedial Action Operation and Land Use/Institutional Control at JBER received for review and comment.
The USAF SS019 Site Characterization Report (2014c) states the lateral extent of PCE in soil
near Building 755 needs to be further delineated, in accordance with 18 AAC 75.335. This site
has been added to the JBER-R FFA for further delineation of PCE.
The USAF SS019 Site Characterization Report (2014c) indicates that the lateral and vertical
extent of contamination in the wooded debris disposal area located east of Building 755 has
been delineated, and all detected concentrations in 2013 are below screening levels. Sample
SS019-SB05 was collected from the vicinity of historical borings AP-3034 and AC-02, which had
historical exceedances of DRO. SS019-SB05 results for DRO are well below screening levels,
and the historical DRO contamination from 1991 and 1995 appears to be no longer present.
The inspection of Site SS019 revealed no revegetation occurring at the site as it is used as a
parking/loading zone and soil stockpile staging area. The monitoring wells located at the site
were observed to be in good condition. Two soil stockpiles were observed on site and both
stockpiles were covered with a liner. No evidence of ground disturbance was observed at the
previously excavated area of the site. No warning signs relevant to the area of concern were
observed and no erosion was observed along the parking/loading zone. Photographs 1 through
4 in Photograph Log A15 present the general condition of Site SS019.
See site file for additional information. |
Louis Howard |
| 8/24/2017 |
Document, Report, or Work plan Review - other |
Staff commented on the Draft Supplemental Work Plan for JBER-E and JBER-R sites [PL081 N. Jet Pipeline, CG551 Bldg. 4314, ST408 Bldg. 9569, CG530 ST526, SO510 Bldg. 9480, SS522 Hardstand #39, SO507, Bldg. 9669, SS418, ST532, TS003 Skeet Range, CG543 Bldg. 18877, CG529 ST529, ST048 Bldg. 11-490, CG509 Bldg. 4347, SO508 ST508, SO549 Bldg. 4913, AT035 MEB Complex, AT029 Ruff Road FTA, SS019 Bldg. 755, DP009 Bldg. 986 POL Lab, LF002, LF002 OU6 Disposal Site, CG536 ST510, CG539 Bldg. 15380, CG702 Bldg. 31562, SO544 Bldg. 10334, SO547 Bldg. 4913, CG704 Southern Plume, CG527 ST538, SO501 ST427, TU064 Bldg. 740, SS013 MP Barracks, SS014, SS041 Roosevelt Road Transmitter Site, TU107, ST048] which include this one.
ADEC concurs with the scope of work for the current work outlined in this section. Note: there is a RI/FS planned for this site Define nature and extent of contamination in soil and groundwater associated with the former UST and its associated piping. |
Louis Howard |
| 12/29/2017 |
Update or Other Action |
Draft Uniform Federal Policy—Quality Assurance Project Plan (UFP-QAPP) presents the proposed
objectives, methods, and procedures for limited field investigations of Sites AT029, DP009, SS019, and SS120 received for review and comment.
The remedial investigation needs to achieve the following objectives:
• Characterize the nature of soil contamination. This will include drilling soil borings to collect two samples from each boring to fill any data gaps identified during review of historical site data. One sample from shallow soils will be collected in the first 15 feet of the boring and the second sample will be collected at the bottom of the boring. In the case of the deep borings, samples will be collected from the deepest unsaturated interval.
• Define the lateral and vertical extent of contamination in soil. This will include drilling and sampling soil both inside and outside the source area.
• Determine if groundwater has been impacted. This will include drilling, installing, and sampling monitoring wells upgradient and downgradient of the source area. Depth-to-groundwater
measurements will help refine the CSM.
• Collect a sufficient number of samples to support risk assessment. Exposure point concentrations
for soil and groundwater will be either the 95 percent upper confidence limit or the maximum
concentration, depending on the available data and exposure scenario being evaluatedSee site file for additional information. |
Louis Howard |
| 2/14/2018 |
Update or Other Action |
Staff reviewed and commended on the draft UFP-QAPP LFI and had the following comments: Soil and groundwater samples will be analyzed for the following analytes: PAHs by SW8270C-SIM. ADEC requests the analysis and reporting of the following per 8270C-SIM (in addition to PAHs):
3,3-dicholorbenzidine, 4-chloroaniline, bis(2-chloroethyl)ether, hexachlorobeznene, hexachlorobutadiene, hexachloroethane, nitrobenzene, N-Nitrosodimethylamine, N-Nitrosodi-n-propylamine, N-Nitrosodiphenylamine, and pentachlorophenol. Staff requested three (3) soil samples per boring to achieve the desired number of observations for ProUCL (e.g. 15 to 20 observations).
See site file for additional information. |
Louis Howard |
| 4/3/2019 |
Update or Other Action |
Remedial investigation (RI) report received for review and comment. This report summarizes the results of the previous investigations, presents the results of the 2018 RI, & evaluates potential risks to human health & the environment. The nature & extent of petroleum hydrocarbons, VOCs, SVOCs, PAHs, & metals in soil & groundwater (GW) were adequately characterized. Contamination exists in less than 0.1 acre between 10 & 30 feet bgs. No petroleum-related COCs in soil, soil gas, or GW were identified in the baseline HHRA, though PCE & naphthalene were detected at Building 755 in indoor air & soil gas. DRO in soil exceeds the migration to GW criteria; however, the GW cleanup criteria are met (i.e., DRO in GW are below the Table C cleanup levels), therefore the migration to GW pathway is insignificant under current conditions. The RI is complete, & the site is recommended to move to a Feasibility Study. Additional consideration of the VI pathway may be needed in Building 755.
See site file for additional information. |
Louis Howard |
| 5/30/2019 |
Document, Report, or Work plan Review - other |
Staff commented on the Draft SS019 – RI Report JBER-Richardson Contract No. FA8903-16-D-0026/ Task Order 0075 dated April 2019. Main comments were to ensure for multiple pathways and multiple contaminants, the target noncnancer hazard quotient should be based on 0.1 not 1. Total petroleum hydrocarbons HQ info does not need to be included in cumulative risk as it is a separate calculation.
See site file for additional information. |
Louis Howard |
| 4/12/2021 |
Document, Report, or Work plan Review - other |
DEC submitted comments on Draft JBER Basewide UFP-QAPP dated February 2021. |
William Schmaltz |
| 5/19/2021 |
Document, Report, or Work plan Review - other |
DEC Reviewed and approved of Basewide Uniform Federal Policy - Quality Assurance Project Plan. QAPP summarizes general activities for a 5 year period on JBER. |
William Schmaltz |
| 5/28/2021 |
Document, Report, or Work plan Review - other |
DEC Approved of Final LTM and LUC Inspection Work Plan for select CERCLA sites dated May 2021. |
William Schmaltz |
| 8/9/2021 |
Document, Report, or Work plan Review - other |
DEC staff reviewed and provided comments on Draft 2020 Land Use Control report for Select CERCLA sites dated June 2021. Report summarized LUC inspections performed in December 2020. Most sites were covered in snow and a full inspection could not be performed until spring 2021. DEC requested that the spring 2021 inspections are included in the 2020 report or as a separate cover because they are a continuation of the 2020 inspections and separate of the 2021 inspections. |
William Schmaltz |
| 7/26/2022 |
Cleanup Complete Determination Issued |
The Alaska Department of Environmental Conservation, Contaminated Sites Program (ADEC) has completed a review of the environmental records associated with the JBER-Ft. Rich SS019 Bldg 755 UST 17 FRSERA 2 Party USTA 2 Party, located at 2nd Street between D Street & E. Davis Hwy. FTRS-19. Based on the information provided to date, it has been determined that the contaminant concentrations remaining on site do not pose an unacceptable risk to human health or the environment and no further remedial action will be required unless information becomes available that indicates residual contaminants may pose an unacceptable risk. |
Daniela Fawcett |
| 4/20/2023 |
Document, Report, or Work plan Review - other |
DEC reviewed and provided comments for the 2021 Annual Remedial Action-Operations and Long-Term Management Report for Select CERCLA Sites, Draft, dated December 2023. The report describes the site inspections, maintenance activities, and groundwater monitoring, at multiple sites located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. Site inspections and sampling were recommended to continue for all applicable sites to ensure that conditions remain protective of human health and the environment. |
Ginna Quesada |
| 1/29/2024 |
Document, Report, or Work plan Review - other |
DEC reviewed the 2022 Annual Remedial Action-Operations and Long-Term Management Report for Select CERCLA Sites, Draft, dated October 2023. The report describes the site inspections, maintenance activities, and groundwater monitoring, at multiple sites located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. Site inspections and sampling were recommended to continue for all applicable sites to ensure that conditions remain protective of human health and the environment. |
Ginna Quesada |
| 6/27/2024 |
Document, Report, or Work plan Review - other |
DEC approved the No Action Proposed Plan for SS019 – Building 755 UST 17 Joint Base Elmendorf-Richardson, Alaska. The report describes the preferred alternative of no action under the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) at the SS109 Building 755 site at the Joint Base Elmendorf- Richardson (JBER) located in Anchorage, Alaska. The report summarizes the site investigation activities and conclusions from the human health risk assessment at the site. While no CERCLA contaminants exceeding screening levels remain at the site, petroleum contamination remains that exceeds DEC’s migration to groundwater cleanup levels.
Based on the information provided to date, it has been determined that the contaminant concentrations remaining on site do not pose an unacceptable risk to human health or the environment and no further remedial action will be required unless information becomes available that indicates residual contaminants may pose an unacceptable risk.
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Ginna Quesada |
