| Action Date |
Action |
Description |
DEC Staff |
| 6/5/1941 |
Update or Other Action |
Jun 1941: The U.S. Army Corps of Engineers awarded a $3,110,364 cost-plus-fixed fee contract to West Coast Construction Company of Boston, MA, to drill a tunnel that connected Portage on the west side of the Chugach Mountains with the Passage Canal of the east side. The amount was later increased by $7,724,236 to accommodate additional construction requirements for facilities at what would become known as the Port of Whittier.
They included a railroad terminal and depot, tracks, railroad repair facilities, coal storage bins, oil and sand storage buildings, a sorting yard, coach and engine house, a dock, warehouses and cold storage, a power and heating plant, gravity water system with dam and reservoir, two deep water wells, section housing and mess halls for railroad employees, barracks and mess halls to support 50 officers and 1,100 enlisted men, and a 50-bed hospital.
The project was divided into three phases, the first involved the railroad and tunnel construction and the third phase the construction of port facilities. The first two phases were begun in January 1942 and the third phase in June 1942. The garrison area was built on lands that had been set aside for a town site. Construction of a town was deferred until after the war. In addition to West Coast, the 42nd Engineer Regiment (General Service) was employed in the construction of the port facilities. Resident engineers were Mr. F.A. Hansen, Maj. Caleb B. Burgoyne, CE and Lt. Col. J. Burleson, CE. |
Louis Howard |
| 7/1/1958 |
Update or Other Action |
HQ US Army Alaska APO 949, General Description of Facilities: USARAL Petroleum Distribution System (Alaska) prepared by USARAL Petroleum Distribution System, Office of the Quartermaster.
Anchorage-Whittier Division
Anchorage Terminal
Whittier Terminal
USARAL Petroleum Products Lab
PERFORMANCE OF MISSION.
a. Bulk petroleum products for installations south of the AK mountain range are received at the USARAL PDS terminal at the Port of Whittier during the winter months, & shipped by rail to the Anchorage Terminal by rail tank cars. During the summer months tankers deliver products to the Anchorage Terminal. Distribution is made from the Anchorage Terminal to Elmendorf AFB, Ft. Richardson & Wildwood Station by rail, barge, tank truck, & pipelines.
WHITTIER PETROLEUM TERMINAL
1. GENERAL. Consists of 2 sites:
Area Nr. 1, 85 acres located west of the main facilities of the Port of Whittier & Area Hr. 2, 4 acres located adjacent to the petroleum pier, Port of Whittier.
2. FACILITIES.
a. Pier.
b. Gravitometer Building.
c. Product Pipelines.
d. Manifolds.
e. Tank Farms.
f. Pump Stations.
g. Tank Car Loading Racks.
h. Tank Truck Loading Racks.
i. Combination Building.
3. PIER. Located north of the Whittier townsite, consisting of a "T” shaped, wood decked, wood piling structure. The stem of the "T" extends 700’ due north into the bay. Water depth at mean low tide is from 35 to 50’ at the face of the dock. There are 6 dolphins capable of mooring tankers up to 26,000 DWT. Facilities on the pier include:
a. 6 fire hydrants & hose houses connected to a six-inch fresh water line. Pressure is furnished from a heated pump house located on shore.
b. An emergency fire reporting telephone.
c. 10 electric light poles equipped with floodlights.
d. A gravitometer building.
See site file for additional information.
|
Louis Howard |
| 3/24/1964 |
Update or Other Action |
Fuel Spill occurred at Tank 807 with unknown volume/product due to seismic shock during earthquake. |
Louis Howard |
| 11/28/1969 |
Update or Other Action |
In the late 1960s at the Pump Building a fuel spill of unknown volume/product occurred due to failed gasket. |
Louis Howard |
| 5/2/1983 |
Update or Other Action |
Tank 807 valve released 300 gallons of JP-4 due to a failed valve.
NOTE TO FILE: UST Procedures Manual (Nov. 7, 2002) JP-4 releases require the following analyses: GRO, DRO, BTEX, PAHs. PAHs must include acenaphthene, acenaphthylene, anthracene, benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, benzo(k)fluoranthene,
benzo(g,h,i)perylene, chrysene, dibenzo(a,h)anthracene, fluoranthene, flourene, indeno(1,2,3-cd)pyrene, naphthalene, phenanthrene, and pyrene. |
Louis Howard |
| 6/28/1985 |
Update or Other Action |
Eleven temporary wells were installed at the tank farm by Quadra Engineering, Inc*. (1985) to monitor groundwater levels for a tank farm expansion project. Over the period of one year, groundwater in those wells fluctuated by as much as 36 feet. The 11 wells have since been removed. The lowest groundwater levels were recorded in February, during minimal recharge. The highest levels were recorded in June during maximum recharge from rain and snowmelt.
*Quadra Engineering, Inc., 1985, Monitoring Well Installation within the Army Tank Farm,
Whittier, Alaska (submitted to Army DEH). |
Louis Howard |
| 10/30/1986 |
Update or Other Action |
Letter from EPA Alaska Operations Office (Irene Alexakos) to Superfund Branch (Michelle Anderson) Subject: U.S. Army Whittier Oil Storage Tank.
I spoke with Ray Morris of the U.S. Army at Fort Richardson, Alaska, to address a question he had as to whether or not the Oil Storage Tank site in Whittier was the same site as the Whittier Old Creosote Plant. They are in fact two different sites. However, some additional questions arose as a result of my conversation with Mr. Morris & Kathy Bennedickson.
The Army is concerned about this site being included on CERCLIS as it was an oil spill reported in 1981. Apparently, the public was told that there are two hazardous waste sites in their community--this site & the Old Creosote Plant--& the Army feels the site should be removed from CERCLIS.
Based on the information contained in our file, there does not appear to be a problem that falls under CERCLA, since the oil spill is the only contamination reported. The latest SPCC inspection was conducted on July 1, 1985; a copy is attached. Also attached is a copy of the PA from 1981.
The Army has offered to do a PA in order to provide more information which they think would allow us to close our file. However, we feel it is more appropriate for EPA to look into the site rather than the Army. We would appreciate your assistance in looking into this site to determine if any additional problems exist.
It is probably not necessary to do a complete PA for this site based on the history. We are really interested in confirming the fact that the 1981 oil spill is the only reason the site was included 1n CERCLIS. If you have any questions or require more information, please contact either me or Debbie Flood. If possible, we would like to resolve this matter by November 28, 1986.
attached: SPCC Compliance Inspection Sheet EPA Region X
Petroleum Division Terminal, Owner/Operator: Jack Walty, General Foreman. Persons contacted: Clyde M. Wooten, Foreman & Adrian Stuart Fuel Distributions Systems Operator.
Tank numbers : capacity (gallons) - 801:32,200 diesel, 802:38,100 JP-4, 803:30,000 JP-4, 804 27,500 JP-4, 805:28,500JP-4, 806:29,700 JP-4, 807:29,200 AV-Gas, 808:26,000 Mo-Gas, 809:30,500 JP-4 & 810:34,800 JP-4. Oil Storage tanks continued: B 1,000 gallons Mo-Gas, B 1,000 gallons Diesel.
Date of most recent review: 9/29/83.
The Petroleum Division Terminal in Whittier is an Army facility which was reactivated in 1966. Fuel is received by tanker or barge about once a month. The fuel is then shipped via pipeline to the military bases in Anchorage. The annual throughput is approximately 320,000 bbl. per year.
See site file for additional information.
|
Jennifer Roberts |
| 8/27/1987 |
Update or Other Action |
Tank 801 valve released 200 gallons diesel arctic grade due to failed gasket.
NOTE to FILE: DF-1, winter grade diesel fuel, has a flash point of 100degrees F (38 degrees C) and a viscosity of 1.4 to 2.6 x10-5 ft2/s (1.3 to 2.4 cSt) at 104 degrees F (40 degreesC).
KEROSENE NO. 1 FUEL OIL,ARCTIC GRADE FUEL
Ingred Name:BENZENE (SARA III) CAS:71-43-2
RTECS #:CY1400000
Fraction by Wt: 0.24%
Ingred Name:ETHYL BENZENE (SARA III)
CAS:100-41-4
RTECS #:DA0700000
Fraction by Wt: 0.12%
Ingred Name:NAPHTHALENE (SARA III)
CAS:91-20-3
RTECS #:QJ0525000
Fraction by Wt: 0.34%
Ingred Name:1,2,4-TRIMETHYLBENZENE (SARA III)
CAS:95-63-6
RTECS #:DC3325000
Fraction by Wt: 0.82%
Ingred Name:TOLUENE (SARA III)
CAS:108-88-3
RTECS #:XS5250000
Fraction by Wt: 0.28%
Ingred Name:XYLENES (O-,M-,P- ISOMERS) (SARA III)
CAS:1330-20-7
RTECS #:ZE2100000
Fraction by Wt: 1.94% |
Louis Howard |
| 9/9/1987 |
Update or Other Action |
Tank 820 released 2,100 gallons of diesel fuel arctic grade (DFA) due to a failed gasket. |
Louis Howard |
| 9/15/1988 |
Update or Other Action |
Letter from Army that it intends on meeting its obligation concerning correction of leaking underground storage tanks. Our current inventory of 225 tanks has a capacity of less than 50,000 gallons of which 26 were found to be "non-tight" when tested using the Ainlay Tank Tester. Of these "non-tight" tanks, three were located at the Whittier Terminal, two at the Anchorage Terminal, eight at Fort Richardson, ten at Fort Wainwright and three at Fort Greely. (*NOTE: The Ainlay method does not test the lines; i.e. piping. Thus, there also may be line leaks which were not identified. EPA indicates in their literature, that leaking lines are a significant concern. The tank test itself has certain inaccuracies. The test, according to EPA Edison Report, can identify a leak of 0.1 gallons/hour with about a 95% confidence factor. That is, if the tank is leaking at a rate of less than 0.1 gallons/hour, the tank may not be identified as "not-tight". Since 0.1 gallons/hour accumulates as 2.4 gallons/day or 876 gallons/year, significant leakage COULD be occurring at tanks which did test "tight".)
Upon receipt of the test results and to stop any further pollution, we arranged to take out of service and empty all of the leaking tanks at the Whittier Terminal, Anchorage Terminal, Fort Richardson, and Fort Greely. (NOTE: Fort Wainwright Non-Tight tanks are STILL in Service). We have a contract, at Fort Wainwright, to replace six of the ten "non-tight" tanks this fall before freeze-up. We expect to have a contract awarded before the end of the fiscal year for the remaining four "non-tight" tanks.
Our first priority has been to replace the most essential tanks first and take the others out of service until repairs/cleanup can be effected. Tanks no longer required are taken out of operation and removed from the site. |
Bill Lamoreaux |
| 4/25/1989 |
Update or Other Action |
Statement of work for removal and disposal of petroleum contaminated soil encountered during underground storage tank (UST) system removals/new UST installation. Scope assumes that only five cubic yards of contaminated soil will be encountered, except as otherwise noted in the UST Schedule. Allow fifteen working days after excavation at Fort Richardson and DESC Anchorage Terminal sites for the Army to sample and test the petroleum, oils, and lubricants (POL) contaminated soil stockpile, prepare paperwork for MOA for soil disposal at their landfill. The purpose of the testing is to determine eligibility for soil disposal at the landfill.
Haul all MOA ineligible soil to the government POL-contaminated soil storage area at Fort Richardson for disposal by the government. Assume that there will be no MOA ineligible POL-contaminated soil present. UST Cleaning Stations: The following UST cleaning stations (including steam and oil water separator) are authorized for use: Fort Richardson - Bldg. 704 Exterior Wash Facility.
Site ID 17301 Mogas ID#803 1000 gallon UST a.k.a. Vehicle Fuel Point. Assume 100 cubic yards of POL-contaminated soil. Site# 17301 Diesel ID# 804 1000 gallon UST a.k.a. Vehicle Fuel Point. Assume 100 cubic yards of POL contaminated soil. |
Ron Klein |
| 7/3/1989 |
Update or Other Action |
Tank 808 valve released 200 gallons of JP-4 jet fuel due to a failed gasket.
Note to file: JP-4 constituents
Ingred Name:BENZENE (SARA III)
CAS:71-43-2
RTECS #:CY1400000
Fraction by Wt: 0.78%
Ingred Name:CYCLOHEXANE (SARA III)
CAS:110-82-7
RTECS #:GU6300000
Fraction by Wt: <4.0%
Ingred Name:ETHYL BENZENE (SARA III)
CAS:100-41-4
RTECS #:DA0700000
Fraction by Wt: 0.85%
Ingred Name:2-METHOXYETHANOL (EGME) (SARA III)
CAS:109-86-4
RTECS #:KL5775000
Fraction by Wt: 0.17%
Ingred Name:1,2,4-TRIMETHYLBENZENE (SARA III)
CAS:95-63-6
RTECS #:DC3325000
Fraction by Wt: 0.81%
Ingred Name:TOLUENE (SARA III)
CAS:108-88-3
RTECS #:XS5250000
Fraction by Wt: 3.33%
Ingred Name:XYLENES (O-,M-,P- ISOMERS) (SARA III)
CAS:1330-20-7
RTECS #:ZE2100000
Fraction by Wt: 2.60%
|
Louis Howard |
| 8/10/1989 |
Update or Other Action |
August 10, 1989 Tank 805 valve released 50 gallons of JP-4 jet fuel due to a failed gasket.
NOTE TO FILE: Jet fuel 4 (JP-4) is a form of no. 1 fuel oil, and was one of the most commonly used petroleum products in the US Military. Jet fuel no. 4 is a middle distillate refined petroleum product that was primarily used in military planes. JP-4 was the standard fuel of the US Air Force and Army Aviation, and at one time constituted 85% of the turbine fuels used by the Department of Defense.
JP-4 is essentially a 50:50 mixture of heavy naphtha fraction (like gasoline) and kerosene. This fuel is not considered to be an acceptable substitute/alternate for diesel fuel. JP-4 is interchanged within NATO under NATO Code Number F-40. JP-4 is mainly procured as ASTM D 975 Jet B (or perhaps as CAN/CGSB 3.22). The chief difference between JP-4 and Jet B is that JP-4 contains the three mandatory additives while Jet B does not unless requested during procurement.
In terms of refining crude oil, JP-4 is a middle distillate. The middle distillates include kerosene, aviation fuels, diesel fuels, and fuel oil #1 and 2. These fuels contain paraffins (alkenes), cycloparaffins (cycloalkanes), aromatics, and olefins, from approximately C9 to C20. Aromatic compounds of concern included alkylbenzenes, toluene, naphthalenes, and polycyclic aromatic hydrocarbons (PAHs). Compositions range from avgas and JP-4, which are similar to gasoline, to Jet A and JP-8, which are kerosene-based fuels. JP-4 is a volatile, complex mixture of aliphatic and aromatic hydrocarbons that was principally used in military aircraft. The volatility meant that inhalation exposure is a potential problem near fueling facilities, either from spills or leaks. Once the soil has become saturated, remedial activities create both fire and inhalation hazards.
The conversion of Air Force bases from JP-4 to JP-8 has been completed. The need for and availability of JP-4 for new air vehicles remains unclear. Reference Technical Order (T.O.) 42B-1-14 for a more detailed definition of primary, alternate, and emergency fuel. Consult Air Standardization Coordinating Committee (ASCC) AIR STD 15/1Y for allied country fuel designations. When using a fuel other than JP 4, it may be necessary to manually adjust fuel controls of turbine engines to avoid exceeding engine operating limits, particularly RPM and EGT. Applicable flight manuals and engine technical orders should be consulted for specific operation and adjustment instructions when using alternate fuels.
|
Louis Howard |
| 10/31/1989 |
Update or Other Action |
Defense Fuel Support Point-Whittier (DFSP-W) bulk fuel terminal located in Whittier was operated and maintained by the U.S. Army until October 1989, when Defense Energy Support Center (DESC) took over operational responsibilities as a tenant on the property. DFSP-W operated as a bulk fuel storage and distributing facility from 1949 to closure on November 1, 1996. |
Louis Howard |
| 8/28/1990 |
Site Visit |
On July 23 & 24, 1990, I (Ken Rogowski) performed an initial inspection of the Defense Fuels Center (DFC) facilities at Whittier & the Anchorage Port Terminal, respectively. Although DFC owns the product & facilities, the Army owns the land & TECOM is contracted to operate & maintain both facilities. All personnel working at these facilities are TECOM personnel. The Whittier facilities employ about 6 operational persons & the ANC facility about 15 personnel, the remainder are security personnel.
WHITTIER DOCK FACILITIES:
DeLong Dock is located at the eastern edge of Whittier. It is used to offload refined fuels (diesel, JP-4 & unleaded gas) from tanker vessels & store the product in above ground tanks located at the west edge of Whittier near the train tunnel. The tanker vessels are chartered by the Military Sealift Command (MSC). Currently, these vessels are operating under a C-Plan variance approved by this Department. Fuels are pumped through two sets of control valves on the dock & through four (4) parallel 12 inch buried lines between the dock & the tank farm. Vessel transfers occur on the average about once per month with the majority taking place during the summer months.
Pipe & valves on the dock appeared to be in good condition & were recently painted. The dock deck was in poor condition, but is scheduled for major construction during 1990/91 which will include a concrete deck & new storage buildings on the dock. Also on the dock was a hydraulic crane for lifting eight (8) inch transfer hoses to tanker vessels. A containment basin was built into the dock around the crane pedestal, but its effectiveness in containing hydraulic oil spills is questionable.
Also located near the end of the dock was a steel building & three wooden crates containing about 2,000 ft. of eight (8) inch containment boom. An unknown amount of absorbent pads were stored in a building just outside the dock gate. A boom loading/unloading spool at the end of the dock was operational, but the adjacent motor was not installed. This is to be corrected when the new deck is installed.
The only outside oil spill response capability available to Whittier facilities is through a verbal agreement with the Harbor Master for two boats to assist with deployment of the booms. Discussions were held on the need for contracts for additional response capability if adequate support was not available through their own resources. By pursuing this, they will apparently develop new oil spill contingency plans for all of DFSC facilities in Alaska. Other options for a response capability discussed included those with Alyeska Pipeline & the Alaska Railroad. They have already been talking with Alyeska.
According to the dock manager, their first priority of a spill into the waters is deploy the boom as an exclusionary measure to deflect or prevent the fuel from approaching the city & to deflect it toward open water where it will dissipate. Since the only fuels handled are diesel, JP4 & unleaded gas, it is probably not feasible to expect to recover much through adsorbents or skimming.
See site file for additional information regarding Whittier tank farm and the Whittier to Anchorage Pipeline. |
Ken Rogowski |
| 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.
See site file for additional information. |
Louis Howard |
| 10/12/1990 |
Update or Other Action |
Letter from Dept. Of Army HQ 6th ID (Light) and U.S. Army Garrison Alaska Edwin Ruff Colonel DEH to Mr. Frost Environmental Engineer Underground Storage Tank (UST) Program-Juneau AK. This is in reference to the ADEC letter of October 2, 1990 for underground storage tank (UST) closures at Whittier Terminal.
The UST closures at Whittier Terminal have been postponed until the spring 1991. Point of contact (POC) is Lori Tussey Lay Environmental Engineer. |
Ron Klein |
| 4/30/1991 |
Update or Other Action |
April 1991 Tank 810 valve released unknown volume of JP-5 jet fuel. Cause Failed gasket.
Note to file: JP-5 releases require the following analyses: GRO, DRO, BTEX, PAHs. PAHs must include acenaphthene, acenaphthylene, anthracene, benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, benzo(k)fluoranthene, benzo(g,h,i)perylene, chrysene, dibenzo(a,h)anthracene, fluoranthene, flourene, indeno(1,2,3-cd)pyrene, naphthalene, phenanthrene, and pyrene.
Jet fuel 5 (JP-5) is a form of no. 1 fuel oil. Many commercial jet fuels have basically the same composition as kerosene, but they are under more stringent specifications than those for kerosene. JP-5 is a military aircraft turbine fuel. JP-5 is considered to be the naval equivalent of JP-4, the former standard fuel of the US Air Force and Army Aviation. Naval aircraft have somewhat different requirements from those for land-based planes, such as less volatility and higher flash points, in order to minimize vapor exposure of personnel as well as reduce fire risk in enclosed areas below decks. This led to the development of JP-5, a 60 degree C minimum flashpoint kerosene-type fuel for use in shipboard service. The flash point is the temperature the fuel ignite. JP5’s flash point is 140 degrees Fahrenheit.
If there’s too much water in JP5, it may freeze in aircraft that fly at high altitudes, such as the SH-60. Sediment, or small foreign particles, presents another problem. Too much sediment will clog up certain intakes on an aircraft, putting an aircraft out of service for labor-intensive maintenance for weeks. To check for these JP5-spoiling elements, the QA Lab uses a combined contaminated fuel detector, or CCFD.
In terms of refining crude oil, JP-5 is a middle distillate. The middle distillates include kerosene, aviation fuels, diesel fuels, and fuel oil #1 and 2. These fuels contain paraffins (alkanes), cycloparaffins (cycloalkanes), aromatics, and olefins from approximately C9 to C20.
Aromatic compounds of concern included alkylbenzenes, toluene, naphthalenes, and PAHs. Compositions range from avgas and JP-4, which are similar to gasoline, to Jet A and JP-8, which are kerosene-based fuels. JP-4 and JP-5 are volatile, complex mixtures of aliphatic and aromatic hydrocarbons and are principally used in military aircraft. The volatility means that inhalation exposure is a potential problem near fueling facilities, either from spills or leaks. Once the soil has become saturated, remedial activities create both fire and inhalation hazards. Toxic effects are similar to those described for gasoline. Chronic effects associated with middle distillates are mainly due to exposure to aromatic compounds, which are found primarily in JP-4 and JP-5. |
Louis Howard |
| 5/20/1991 |
Update or Other Action |
US Army letter to Jennifer Roberts (ADEC). Purpose of the letter is to confirm the agreement between ADEC (Ms. Jennifer Roberts) and the 6th Infantry Division (Light) (Ms. Jane Smith and Cristal Fosbrook of this office), which was discussed during a meeting on May 9, 1991. The agreement consists of leaving the soil from the removal of underground storage tank systems (USTs) at Whittier rather than transporting the soil to Fort Richardson.
If gross contamination is found in the tank pits, soils may be used as backfill and placed back in the pits. Should the pits be slightly contaminated, soils may be removed and stockpiled. Removed soils will be stored in accordance with the ADEC's guidance for Storage, Remediation and Disposal of Petroleum Contaminated Soil of March 15, 1991. The level of contamination will be based on laboratory results and on the observations by the government environmental employee.
The ADEC will be advised of the laboratory results, and consulted during the decision making process. The agreement is made based on the fact that a site investigation will be performed at Whittier during July 1991. The site investigation will include the subject of the UST sites. |
Jennifer Roberts |
| 7/5/1991 |
Update or Other Action |
Scott Bailey (ADEC) received letter from Army (Edwin Ruff) re: underground storage tank (UST) excavation activities at Whittier. Letter is in reference to conversation ADEC had with Jane Smith on June 4, 1991 concerning the discovery of groundwater during the excavation of underground storage tanks (spill# assigned was 91-211-277-1). Four samples were taken of each UST site. One of the four soil samples for UST 801 [near the manifold building] revealed low level of PCBs (1.23 mg/kg).
During a telephone conversation with Jennifer Roberts (ADEC) and Mrs. Smith (Army) on June 19, 1991, the decision was made to temporarily close both UST sites. The decision was made on the following facts: the contractor was unqualified to work in a Toxic Substance Control Act (TSCA) site and it was feared that higher levels of PCB contamination may be present; the site could not easily be protected from the public; the site investigation is forthcoming in July 1991 for the Whittier Area. Replacement USTs were not installed in the same areas but were installed in new locations next to Building 17-305. |
Scott Bailey |
| 10/16/1991 |
Site Added to Database |
Gasoline range organics, diesel range organics, BTEX, PCE contamination |
Louis Howard |
| 11/15/1991 |
Update or Other Action |
November 1991 Mogas unleaded medium grade (MUM) pipeline near the southeast corner of tank farm spilled fuel (approximately 1,218 gallons estimated to be released). Cause was the pipeline being penetrated by during drilling phase of study of facility to install monitoring well MW-12.
NOTE TO FILE: the UST Procedures Manual (November 7, 2002) states that Gasoline releases require the following analyses: GRO, BTEX, PAHs. For unleaded gasoline only naphthalene is required. Naphthalene can be analyzed by 8021B or 8260C, if naphthalene is the only PAH contaminant of concern; however, methods 8270D or 8310 are preferred. |
Louis Howard |
| 11/26/1991 |
Update or Other Action |
Spill Summary 91-211-331-1 11/26/1991 AK State troopers (AST) received notification from Doug Johnson (ARMY) of the petroleum contamination discovered at the DFSP facility in Whittier. 11/27/1991 Anchorage District Office (ADO) received report form via fax from AST. ADO contacted Lt. Col Bob Dreyer regarding initial report. DFRA's environmental consultant, conducting an environmental assessment of the Whittier facility, discovered soil and groundwater contamination. Floating product detected in two wells at 3' to 11' in thickness.
DFRA plans to transport heavy equipment to Whittier to drill additional monitoring wells, initially six (6) four inch wells, and an interception trench to start defining the extent of contamination. Possible source is the 2 mile by 12" diameter gasoline pipeline from the marine header. As a precaution the line is being purged of product. Capacity is 73,000 gallons. |
Scott Bailey |
| 12/3/1991 |
Spill Transferred from Prevention Preparedness and Response Program |
Oil program emergency response closed. Case is transferred to Contaminated Sites section for long-term remediation. |
Scott Bailey |
| 12/4/1991 |
Update or Other Action |
Case investigation report authored by Doreen Sullivan-Garcia (ADEC) on 12/04/1991. DFSP-Whittier Groundwater Contamination spill date 11/26/1991 spill# 91-211-331-1. Received call from Pam Miller at Greenpeace around 11:23 a.m. inquiring about Whittier groundwater contamination and following up on an anonymous call they received. The anonymous caller reported that contamination was leaking up to five miles away from the tanks. She called to verify this information.
Doreen had no first hand knowledge of the spill, only had heard about it. It was being handled through the DEC Federal Facilities Coordinator and the ADO Contaminated Sites Program. The discovery of the problem was part of a CERCLA project requiring all federal installations to do a preliminary assessment/site investigation for the purpose of ranking DERA sites and possibly to allow the Army to transfer properties to DFSP. |
Doreen Sullivan-Garcia |
| 12/18/1991 |
Update or Other Action |
E & E discovered 7.9 feet of floating product on the groundwater in monitoring well MW-12. 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.
On November 29, 1991, E & E was tasked by the CORPS to install up to 12 additional wells around MW-12 to delineate the extent of contamination and recover fuel if possible. Martech USA under subcontract to E & E arrived on site December 6, 1991 to attempt fuel recovery services. Hughes Drilling Company was remobilized to assist drilling on December 8, 1991.
Eight monitoring wells were installed and sampled on December 18, 1991. MW-12 was destroyed during excavation of the damaged pipeline, which was the source of the fuel. Sufficient floating product was not present in any of the wells to allow for product recovery. Estimates of the fuel spill are at 10,000 to 20,000 gallons of unleaded gasoline being released. |
Louis Howard |
| 12/18/1991 |
Site Visit |
WHITTIER DFSA FUEL SPILL FIELD TRIP
12/18/91
Keven Kleweno and Scott Bailey met with Defense Fuels Supply Administration, Corp of Engineers, environmental contractor and drilling contractor staff to review the recent work to determine
the extent of a fuel spill estimated at 10,000 to 20,000 gallons of unleaded gasoline. The spill was caused .by a contractor who was working on an area wide soil/ground water assessment (by drilling) of previous above and below grade fuels spills. The direct cause of the spill was the contractor drilling through the 12 inch gasoline pipeline which was incorrectly located by the Defense Fuels Supply Administration (DFSA).
A total of 27 monitoring wells and 10 boreholes have been drilled. A summary of events, field data logs and a gradient map were presented to DEC. We oversaw two well sampling events which
did not show any significant fuel amount floating top of the ground water. At this time DEC staff are satisfied that the DFSA has taken the steps needed to determine the extent of a fuel
plume-if one exists. Based on the results to date, one possibility is that the fuel was absorbed in the silt layer(s) and has not migrated along the pipe line corridor or in gravelly
strata to the surface water. Another possibility is that the gasoline never made it to the existing groundwater. Based on discussions with the driller and the geologists logging all the
monitoring wells, the gasoline may have encountered a less dense soil with a higher permeability several feet above the groundwater.
When a monitoring well was completed that during installation a strata with trace oj gasoline was encountered above the groundwater, no gasoline was found on the groundwater in the monitoring well. If the strata is above the groundwater, it may not have the same gradient or strike and dip. This could result in the gasoline moving in a completely different direction
from the groundwater.
Additional monitoring well sampling at breakup and in mid-summer 1992 will be requested. This monitoring and a closer review of the soil logs for all monitoring wells and boreholes may result in additional monitoring wells during the 1992 construction season. As-builts of the fuel lines are being completed by another contractor. There may be information included on the asbuilt drawings that may have us request additional monitoring wells.
Overall, the investigation into the movement or migration of the gasoline has been very professional. All parties were very helpful during the inspection and meeting.
In regards to the existing Class C Public water System, the new source well was installed in 1990. It appears that everything has been completed and once the distribution system is correctly flushed, the new well will be placed on line. The operator of the facility knows that written approval is necessary before providing water to the staff and understands what information will need to be submitted to obtain that approval. |
Kevin Kleweno |
| 2/19/1992 |
Update or Other Action |
EPA MEMORANDUM
SUBJECT:Permits and Permit "Equivalency" Processes for CERCLA On-site Response Actions
FROM: Henry L. Longest II, Director, Office of Emergency and Remedial Response
TO: Director, Waste Management Division, Regions I, IV, V, VII, and VIII; Director, Emergency and Remedial Response Division, Region II; Director, Hazardous Waste Management Division, Regions III, VI, and IX; Director, Hazardous Waste Division Region X
PURPOSE: The purpose of this directive is to clarify the Environmental Protection Agency (EPA) policy with respect to attaining permits for activities at CERCLA sites. CERCLA response actions are exempted by law from the requirement to obtain Federal, State or local permits related to any activities conducted completely "on-site". It is our policy to assure all activities conducted "on site" are protective of human health and the environment. It is not Agency policy to allow surrogate or permit equivalency procedures to impact the progress or cost of CERCLA site remediation in any respect.
BACKGROUND: In implementing remedial actions, EPA has consistently taken the position that the acquisition of permits is not required for on-site remedial actions. However, this does not remove the requirement to meet (or waive) the substantive provisions of permitting regulations that are applicable or relevant and appropriate requirements (ARARs). (For definitions of "substantive" and "administrative," see 55 FR 8756-S7 and the CERCLA Compliance with Other Laws Manual, Part I, pages 1-11-12.) The proposed and final 1982 National Oil and Hazardous Substances Pollution Contingency Plan (NCP) made no mention of the permit issue. However, EPA addressed the issue in a memorandum entitled "CERCLA Compliance with Other Environmental Statutes" which was attached as an appendix to the proposed 1985 NCP (50 FR 5928, February 12, 1985). The memorandum stated: "CERCLA procedural and administrative requirements will be modified to provide safeguards similar to those provided under other laws. Application for and receipt of permits is not required for on-site response actions taken under the Fund-financed or enforcement authorities of CERCLA."
EPA determined in the final rule [1985 NCP section 300.68 (a)(3)] that "Federal, State, and local permits are not required for Fund-financed action or remedial actions taken pursuant to Federal action under section 106 of CERCLA." The 1986 amendments to CERCLA codified section 300.68(a)(3) of the 1985 NCP with a statutory provision, section 121(e) (I). CERCLA section 121(e) (1) provides that no Federal, State, or local permit shall be required for the portion of any removal or remedial action conducted entirely on-site, where such remedial action is selected and carried out in compliance with section 121.
The 1990 NCP [section 300.400(e)(1)] implements this permit exemption for "on-site" actions, defining "on-site" as "the areal extent of contamination and all suitable areas in very close proximity to the contamination necessary for implementation of the response action." The preamble to the NCP (at 55 FR 8689, March 8, 1990) explains that "areal" refers both to the surface areas and the air above the site. EPA policy further defines "on-site" to include the soil and the groundwater plume that are to be remediated. On-site remedial actions may involve limited areas of noncontaminated land; for instance, an on-site treatment plant may need to be located above the plume or simply outside of the waste area itself.
See site file for additional information. |
Jennifer Roberts |
| 4/9/1992 |
Update or Other Action |
EPA Memorandum April 9, 1992 Reply to the ATTN of ES-098. Subject Toxicity of Fuels. From Carol Sweeney Toxicologist Health and Environmental Assessment Section. To Wayne Pierre Federal Facilities Superfund Branch (HW-124). A response has been provided to the frequently-asked question of whether a reference dose or other toxicity information can be provided for fuel mixtures so that these mixtures can be addressed quantitatively in Superfund risk assessments. The memo from ECAO Cincinnati is attached (last attachment). They have developed reference doses for gasoline, JP-5/kerosene, and JP-4, and a cancer potency factor for gasoline. The memo emphasizes that these are provisional numbers and that considerable uncertainty is involved in this quantitative assessment, because of data limitations, and because inhalation studies were used to calculate oral reference doses.
I typed up a summary table showing the numbers (first attachment) and calculated some risk-based concentrations (second attachment). On the risk-based concentration table, I also included ordnance compounds, because I hadn't made a table of those before that I can remember. The risk-based concentrations were calculated the same way as table II-1 and II-2 of the Region 10 Supplemental guidance; for soil, the same limitations apply, that the numbers presented do not consider pathways other than soil ingestion.
Toxicity Reference Values for Fuel Mixtures EPA Region 10 4/9/1992 Non-cancer effects-Gasoline (unleaded) RfD (mg/kg-day) Oral: 2.0E-1, Uncertainty Factor-Oral:1000, Level of Confidence-Oral: Low. Toxicity Data Source-Oral RfD: Memo 3/92. Carcinogenicity-Cancer Potency/(mg/kg/day): Oral 1.7E-3, Unit Risk (/ug/m3) 4.8E-7, Cancer Weight Of Evidence-C, Toxicity Data Source-Oral SF and Inhal. SF: Memo 3/1992.
Kerosene/JP-5 RfD2.0E-2, UF Oral: 10,000, LOC Oral: low, TDS Oral RfD: Memo 3/92
JP-4 RfD 8.0E-2, UF Oral: 10,000, LOC Oral: low, TDS Oral RfD: memo 3/92.
Screening Values for Water RBCs based on Ingestion, Residential
Gasoline-Risk = 10-6 (ug/L) 50, 10-4=5000 HI=1 (ug/L) 7000
JP-5 Kerosene Risk 10-6 10-4=NA HI = 1 (ug/L) 700
JP-4 Risk 10-6 10-4 = NA, HI = 1 (ug/L) = 3,000
Screening Values for Soils- RBCs Based on Soil Ingestion Residential
Gasoline-Risk = 10-6 (mg/kg) 400, 10-4 (mg/kg) 40,000, HQ = 1 (mg/kg) 50,000
JP-5 Kerosene Risk 10-6 10-4 NA, HQ =1 5,000
JP-4 Risk 10-6 10-4 NA, HQ = 20,000
IARC concluded that gasoline is possibly carcinogenic to humans (Group 2B). IARC concluded that marine diesel fuel is possibly carcinogenic to humans (Group 2B), but light diesel fuels and jet fuels are not classifiable as to their carcinogenicity in humans (Group 3). |
Louis Howard |
| 2/2/1993 |
Update or Other Action |
WHITTIER FUEL TERMINAL (WFT) SITE INVESTIGATION PROJECT REPORT CONTRACT NO: DACA85-91-D-0003 DELIVERY ORDERS NOS. 2 & 15 January 1993 received February 2, 1993.
Sample Results in mg/kg
BH/MW Soil:
Acetone 0.006 - 0.11, Sediment: 0.012 (18 AAC 75 Oct. 2008 Table B1 Method Two Migration – GW 88 mg/kg)
2-Butanone 0.05 – 5.6 Sediment: ND (Method 2 MEK migr. – GW 59 mg/kg)
Methylene chloride 0.005 - 2.4 Sediment: 0.007 - 0.012 (MGW 0.21 mg/kg)
Toluene 0.005 - 5.8 Sediment: ND (MGW 6.5 mg/kg)
Total xylenes 0.005 - 98.0 Sediment: ND (MGW / outdoor inhal: 63 mg/kg)
Total BTEX 0.02 – 109 Sediment: ND (Category “A” 10 mg/kg)
1,2-Dichlorobenzene 0.008 Sediment: ND (M GW 5.1 mg/kg)
1 A-Dichlorobenzene 0.017 Sediment: ND (M GW 0.64 mg/kg)
Acetone & methylene chloride were detected in a number of samples, & are considered common lab contaminants when detected in associated method blanks. Both of these compounds were detected in many of the method blanks. Therefore, most acetone & methylene chloride results for soil & sediment samples were flagged B (detected in associated method blanks). However, the following samples show relatively high levels of methylene chloride (greater than 10X the method blank level) which may not be attributable to lab contamination: 052SL (1 mg/kg), 055SL (1 mg/kg), 056SL (1.1 mg/kg), 065SL (1.1 mg/kg), 066SL (1.1 mg/kg), & 070SL (1.0 mg/kg).
Benzene was not detected in any soil or sediment sample above the detection limit. However, the detection limits for some samples were elevated above the cleanup level of 0.1 mg/kg due to matrix interference & subsequent sample dilution. This is true for the following samples: MW-B (099SL, 100SL), MW-9 (037SL, 03SSL, 039SL), MW-13 (065SL, 066SL)' MW-22 (069SL, 070SL), & BH-9 (052SL, 053SL, 055SL, 056SL). (NOTE TO FILE Benzene cleanup level is now 0.025 mg/kg)
The highest levels of VOCs were detected in subsurface soil samples collected from 10 to 10.5’ bgs from MW-8 & MW-9. Both wells are downgradient with respect to GW flow from the 2,100-gallon diesel fuel release from Tank S20 (see Table 2-3), which likely contributed to contamination. The levels of total BTEX in both wells exceeded the cleanup level of 10 mg/kg. The subsurface soil samples from MW-8 & MW-9 were the only soil samples at the WFT that contained VOCs above the cleanup limits.
See site file for additional information. |
Louis Howard |
| 2/24/1993 |
Document, Report, or Work plan Review - other |
Letter to Doug Johnson (Army) re: Whittier Fuel Terminal Site Investigation Project Report Contract No. DACA85-91-D-003 Order Nos. 2 and 15 Dated January 1993. The Department of Environmental Conservation (DEC) Department of Defense (DOD) Facilities Group received the above mentioned document on January 26, 1993. The site investigation report appears to be in its final form. DEC has not been given the chance to comment on the draft copy as presented for viewing during the December 16, 1992 tour of the Whittier Fuel Terminal (WFT) facilities with Defense logistics Agency staff. A copy of the draft document was requested for review; however, none was received at the DEC southcentral regional office. For the reasons listed below
DEC does not accept this document as a final report. Please incorporate our comments on the document.
2.3 Storage Tanks pages 2-1 and 2-2
The underground storage tank systems (USTs) at the tank farm and Delong Dock were noted to have been installed between 1950 and 1986. The text does not state whether or not they are registered with DEC. Please submit proof of registration with DEC's underground storage tank program. For all tanks and lines installed before 1980, release detection is currently required. For tanks installed between 1980 and 1988 release detection is required to be installed by December 22, 1993. In addition, for tanks installed after May 1986, they must have corrosion protection already in place. Please note that release detection has been required on all pressurized lines since December 1990 (18 MC 78.060 Table A). All USTs must have corrosion protection and spill/overfill prevention measures installed by December 1998. Work performed for upgrading the USTs must be done by a state certified worker as specified in 18 MC 78.400-495. This requirement applies for any and all UST work associated with: installations, repairs, reconfigurations, closures (including removal), tank tightness tests, or cathodic protection tests.
2.4 Drum Storage page 2-2
The 15 or more drums were mentioned as not being properly labeled or characterized. These drums must be adequately characterized, labeled and disposed of properly after sampling of the contents contained in them. All of the drums must be documented as to whether the contents are either product or a waste. In cases where the drums have been damaged or corroded so badly then the contents can no longer be considered product but must be treated as a waste.
Drums that have been allowed to leak or are damaged must be placed in sound drums or overpacks to disposed of appropriately after determination of whether the contents were a hazardous waste or not. DEC requests that the Army provide proof of the hazardous waste characterization of the contents of the drums, proof of ultimate disposal of the drums and their contents.
4. Field Investigation
Table 4-3 Sample Analytical Methods
Using method 50309/8015 for VPH is not acceptable to quantify both gasoline and diesel range organics (GRas & DROs) for work associated with underground storage tanks. Footnotes for table 5-5 on page 5-34 noted for example: that gasoline and diesel for MW-21 was quantitated using USACE modified method 8015 (fuel identification), MW-13 was a result quantitated as kerosene using USACE modified Method 8015 by QA laboratory, and MW-9 was quantitated as bunker C using USACE modified Method 8015 by QA laboratory. Modified 8015 is acceptable as a screening method but not for clean closure. In order for DEC to accept the lab data generated during any work associated with USTs, the standard operating procedures (SOPs) must be on file and approved by DEC's Juneau laboratory. DEC requests that Ecology and Environment apply for and receive approval from DEC's Juneau laboratory to analyze samples under the DEC UST Regulations.
To become fully approved, a laboratory must:
1) Submit a request on company letterhead.
2) Submit an acceptable quality assurance manual (See appendix J) and have the
manual approved by DEC.
3) Submit a copy of its Standard Operating Procedures, and have the procedures
approved by DEC.
4) Successfully analyze required performance evaluation samples.
5. Results and Significance of Findings
5.3.2 Groundwater Cleanup Levels
With regards to cleanup levels for groundwater, 18 AAC 78.345 states that water and groundwater that has been contaminated will be deemed treated adequately if a sufficient reduction of contaminants will allow the water to meet the applicable water quality criteria of 18 AAC 70 (Water Quality Standard regulations) 18 AAC 78 does not state that the RPH compounds in the groundwater shall be remediated to "nondetectable" levels using method 418.1.
For additional information see site file. |
Louis Howard |
| 3/29/1993 |
CERCLA SI |
Mark Ader, EPA Federal Facilities, Site Assessment Manager sent Col. Wrentmore DEH 6th ID USAG-Alaska a letter. This letter is to inform you that EPA Region 10 has completed the review
of the Whittier Fuel Terminal site Investigation Project Report. The report has been evaluated in accordance with 40 CFR Part 300 Appendix At which is EPA's Hazard Ranking System (HRS) used to evaluate federal facilities for inclusion on the National Priorities List (NPL).
From our evaluation, EPA has determined that all sources at the facility are exempted by the petroleum exclusion provision of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). Therefore, a recommendation of no further remedial action planned (NFRAP) on the EPA's part will be included in our Federal Agency Hazardous waste Compliance Docket tracking system. If new or additional information becomes available that suggests the facility may score high enough to be proposed for the NPL, EPA must reevaluate your facility accordingly.
EPA's NFRAP designation will not relieve your facility from complying with appropriate Alaska state regulations. The Superfund Amendments and Reauthorization Act (SARA) of 1986*, section 120(a) ,(4) requires federal facilities to comply with state cleanup requirements and standards when not listed on the NPL.
This facility will not be removed from the Federal Agency Hazardous Waste Compliance Docket, but as noted earlier, will be listed for no further action. If you have any questions regarding EPA's evaluation of this site, please contact me, at (206}553-1808. |
Louis Howard |
| 4/14/1993 |
Update or Other Action |
Response from Army to ADEC concerning the WFT Site Investigation report. DFOA will respond directly to ADEC on summary comments 1, 2 and 3 since Defense Fuel Office is responsible for all underground storage tank (UST) compliance issues at the Terminal. Item 4: At the start of this contract, the ADEC did not require ADEC approved labs. Currently it is the Army's policy that all new contracts on Army lands, petroleum contamination investigations, shall have an ADEC approved lab.
Item 5:
The analytical method used to determine volatile organic compounds (VOCs) was U.S. Environmental Protection Agency (EPA) SW-846 Method 8240. This method is specific for target contaminants specified by the Comprehensive Environmental Response, Compensation, and Liability Act and the Resource Conservation and Recovery Act. However, the method does not identify many of the volatile compounds found in petroleum products. If fuels, benzene, toluene,
ethylbenzene, and xylene (BTEX) compounds are the most common VOCs expected. The test for volatile petroleum hydrocarbons (VPH) is not analyte-specific, but it encompasses all flame-ionizable compounds eluting over a specific boiling-point range. VPH results show
all compounds present in the" sample with boiling points indicative of petroleum hydrocarbons ranging from approximately C6 to C10.
Tables 5-5 and 5-8 of the project report exhibit analytical results for soil samples. For a given sample, high VPH concentrations are generally accompanied by elevated VOC concentrations. For example, sample 099SL has VPH quantitated at 2,300 milligrams per kilogram (mg/kg) and BTEX, primarily consisting of xylenes, at 14.5 mg/kg. Sample l00SL has VPH at 1,200 mg/kg and BTEX, comprised of xylenes only, at 3.3 mg/kg. Since xylenes are the least volatile of the BTEX compounds, they are the most likely to be detected following any degree of volatilization. It is likely that the more volatile compounds, such as benzene, had volatilized, and hence
were not detected.
Nothing in the collection, transportation, or analysis of Whittier samples suggests that VOCs were lost. E & E believes the data presented in tables 5-5 and 5-8 fairly represent site conditions at the time of sampling.
Item 7: The plan on validating VOCs and BNAs will be addressed in the sampling and analysis plans for each individual projects.
Item 8: E & E report 9102.646 includes the following samples:00ISL, 002SL, 003SL, 004SL, 005SL,
006SL, 007SL, 008SL, 009SL, 010SL, 011SL,514WA, 515WA, and 902WA. Only the soil samples (SL) from this list were affected because their containers were not quite full.
E & E report 9102.874 includes the following samples: 009GW, OlOGW, OllGW, 012GW, 014GW, 015GW, 016GW, 017GW, 018GW, 019GW, 021GW, 022GW, 023GW, 024GW, 025GW, 026GW, 027WA, 542WA, 543WA, 544WA, 545WA, 546WA, 547WA, and 548WA. These samples were 20 degrees celsius when received at the laboratory and so were potentially affected.
Item 9: DFOA and the Army are researching the best approach to conduct a small scale remedial project at the WFT. Currently this project is only at the scoping phase. When project plans are finalized they will be submitted to ADEC for comment. |
Louis Howard |
| 5/27/1993 |
Update or Other Action |
Whittier Terminal Groundwater Sample and Analysis Plan received by Southcentral Regional Office on May 27, 1993 and Anchorage District Office on June 18, 1993. Written comments requested by June 11, 1993. Sampling Objectives: The purpose of this investigation is to monitor the
quality of groundwater at the Whittier Fuel Tenninal tank farm over a five-year period. The 29 groundwater monitoring wells will be sampled twice yearly.
A trip report will be prepared after each sanpling event, with a chemical data report prepared after each year's sampling. Water samples from the wells will be tested for aromatic volatile organics [benzene, toluene, ethylbenzene and xylenes (BTEX)], gasoline-range organics (GRO), diesel range organics (DRO), residual range petroleumn hydrocarbons, and lead. All existing monitoring wells on site will be sampled twice yearly.
Quality assurance (QA) and quality control (QC) duplicates shall each comprise at least 10% of project samples. Rinsate samples will be analyzed to confinn the adequacy of decontamination procedures. At least two rinsate samples will be collected during each sampling event. Trip blanks will accompany all samples for volatiles analysis. A more detailed description of
the project QA/QC sampling can be found in the Quality Assurance Project Plan.
Wells With Floating Product: If a floating product layer is detected by the interface probe, the well shall be considered to contain floating product. Generally, this category includes wells with 0.01 feet or more of floating product. Wells with a detectable floating product layer shall not be purged before sampling. Samples shall be collected from the unpurged
water in the well.
If a well contains a measurable floating prcx:luct layer, it shall be sanpled without purging. The initial bailer of water shall be used to measure field parameters (including pH, temperature, conductivity, flame ionization or photoionization detector readings, oxidative/reductive potential) and to fill containers for volatiles analysis. Aliquots from
subsequent bailers shall be allocated among the remaining containers to be filled, so that all scurples shall contain similar proportions of product and water.
Care shall be exercised to ensure that each sample container holds a sample representative of the well's contents, and to ensure that all sarnples from a given well are identical in composition. The presence and thickness of a floating product layer shall be documented in the field notebook and trip report. Samples containing aqueous and. petroleum layers shall be so noted in the field notebook, trip report, and chain of custody forms.
Investigation-Derived Waste: Purge water will be disposed on the ground. on site if there is no evidence of contamination. If there is any indication that the water may be contaminated, it will be contained in drums. Drums will be labeled with the project name, well number, and the
date. Drums will be stored on site near Building 17-304 until analytical data have been received. Data will be tranmsitted to Whittier Fuel Terminal staff so that drum contents may be properly disposed. Disposal will be under the direction of the Defense Reutilization and Marketing Office. |
Louis Howard |
| 6/24/1993 |
Document, Report, or Work plan Review - other |
Staff reviewed and commentd on the Whittier Fuel Terminal (WFT) Sampling and Analysis Plan on May 27, 1993.
General Comments
ADEC appreciates the opportunity to review the documents submitted. While a groundwater monitoring program is needed at WFT, ADEC requests that a more comprehensive plan be submitted addressing remedial actions being considered at WFT. The Directorate of Public Works' fax from Cristal Fosbrook, dated April 9, 1993 in response to ADEC's letter dated February 24, 1993, stated that a small scale remedial project at WFT was being considered, but it was only in the scoping phase. ADEC requests that if the plans been finalized and remedial options decided upon,
then they will need to be submitted for review and comment.
I. Field Sampling Plan
2. Sampling Objectives page 2 and 3. Sample Location page 3
The sampling plan states that the sampling frequency of the twenty-nine monitoring wells will be sampled twice yearly. ADEC questions the validity of sampling of the twenty-nine wells only twice a year will be adequate to fully characterize the full extent of the contamination at WFT and to determine the optimum remedial option. ADEC requests a specific schedule of when sampling will occur (i.e. spring, summer, or when groundwater is at its seasonal low or high). ADEC requests, at a minimum, that a quarterly sampling schedule be utilized that would include the seasonal high and low water table fluctuations, instead of two sampling events per year, to better define the hydrogeologic conditions at WFT.
6.3 Investigation-Derived Waste
The text states that purge water will be disposed of on the ground on site if there is no
evidence of contamination. ADEC requests additional information on how the COE will determine that there is no evidence of contamination of the purge water prior to disposal. Information submitted should include how the purge water will be screened or analyzed for contamination prior to disposal. Lacking that information, ADEC requests that all purge water be held in drums and treated as contaminated until lab analysis results determine the water to be clean. Only then can the purge water be disposed of unconditionally to the ground without creating another above ground contaminated site.
II. Quality Assurance Project Plan
2.1.7 Final Report page 2
The text states that CENPA-EN-EE-AI will provide reports to the DFSC. ADEC requests that reports be submitted to the South central Regional Office, Defense Facilities staff also. Merely reporting site contamination to ADEC by DFSC is not enough since ADEC will need the results and reports generated to adequately comment on any contamination found at WFT. |
Louis Howard |
| 6/25/1993 |
Document, Report, or Work plan Review - other |
Letter to Capt. Mark Beyea Richardson Resident Office RE: ADEC/ADO review work plan/sampling and analysis 02055-1 contract DACA85-93-C-0028. The temporary stockpile plans, drawings 8.1 and 8.2 should incorporate a sand liner under the edges of the stockpile. The plans as shown only included a sand base on the bottom of the pile. Temporary stockpiling is for up to ninety (90) days. Prior to the close of the 1993 field season all temporary stockpiles must be moved to a long-term stockpile site on level terrain. No stockpiles are to be left in the tank diked/bermed areas due to spring flooding. The current liner on the tank dike walls may be suitable and properly welded to be a base for the long-term stockpile.
The sampling plan under 2.5.2 (d.(2)) references a five point sampling composite. The department requests the five areas which exhibit the highest field screening readings on a test instrument be included in the five point sampling. If the subsoil appears uniform in contaminant level, the department requests a five point composite sampling consisting of one sample from the tank mid-radius line at 0, 90, 180, 270 degrees and 1 sample from the tank bottom. |
Scott Bailey |
| 7/19/1993 |
Update or Other Action |
Anchorage District Office (S. Bailey) received the Army COE Richardson Resident Office: Work Plan/Sampling & Analysis Plan 02055-1B, Contract DACA85-93-C-0028, Repair Fuel Storage Tanks, Whittier, Alaska. Please review these responses & advise this office if the plan, with these amendments, will receive ADEC approval. Two copies of the original plan were provided at the initial review. As these were not returned with the original review comments, we assume they were retained by the department & are still available for your reference.
This revised document includes not only answers to ADEC comments, but also revisions in response to Corps of Engineers comments. Two copies of the Corps review comments are included for your reference. Your expeditious review of these documents would be greatly appreciated, as the work covered by this plan cannot begin without ADEC approval. If any additional information is required, please direct questions to captain Mark Beyea or Mr. Karl Harvey at 384-7440.
S. Bailey comment: Okay as response to ADEC letter of 6/25/1993.
The project involves the repair of eight fuel storage tanks at the DLA Bulk Fuel Storage Facility. The Contractor for this project is Rockford Corporation of Anchorage, Alaska. QUEST ENVIRONMENTAL (QE) of Anchorage, Alaska, has been retained to conduct a site assessment for POL constituents within the boundaries of the contract specifications.
The purpose of QE's site assessment activities will be to field screen excavated soils for POL constituents, to segregate soils based upon field screening activities, to submit soil. & water samples from excavated areas & stockpiles for laboratory analyses, to document contaminant levels within &/or at specified boundaries (clean lines), to communicate to the COR discovered conditions of concern which lie outside the boundaries of the contract requirements, & to report assessment findings in a manner consistent with the contract specifications. In addition, QE will submit soil samples from the oil sands beneath each tank for laboratory analysis in order to confirm POL contamination levels prior to disposal.
In addition, the oil sand below tank floors is assumed to be hydrocarbon contaminated at a level greater than 1000 ppm, (EPH by 8100 mod.). The eight fuel storage tanks which are addressed in the contract specifications, are located in one main work area within the DLA Bulk Fuel Storage Facility. Historical soil & water laboratory analyses results from test borings & surface samples in the project area show that POL constituents have been released primarily through leakage from the storage tanks & possibly their supply lines & other support structures.
Secondary sources of contamination appear limited to soils, with contamination of groundwater possible due to secondary release mechanisms such as percolation, infiltration, storm water runoff, & the use of contaminated soils as sources of fill material.
See site file for additional information.
|
Scott Bailey |
| 8/23/1993 |
Update or Other Action |
DFSC J. O'Donavan reports to ADEC spill report 93-2-1-1-237-1. Disposal: Older construction practice-all DFSC tanks? Comments: Replacing ring wall in tank farm. Tank Repair jacked up six feet. Contamination has not spread. Less than 100 ppm outside tank (4-5 ft. around). Plan: 2 floors-6" sand, second floor-remove newest sand and leave original. Location: Whittier Tank#805. Area affected: Identified perimeter 4-5 ft. down, 1-2 ft. sand. 16,000 ppm TPH. May need to remove all floors, may need to replace floors all tanks.
Architect Engineer/Resident Engineer/ADEC: practical approach to remove-dig most contamination w/field screening, stockpile. Bring clean fill in, sitewide assessment with ACOE. Contractor to obtain approved disposal plan. Tank Construction correspondence in DFSC Whittier OPC Facility file. |
Doreen Sullivan-Garcia |
| 8/31/1993 |
Update or Other Action |
DFSC DFO-Alaska sent correspondence to ADEC (D. Sullivan-Garcia) RE: Removal and Disposal of Hydrocarbon Contaminated Soil Defense Fuel Support Point-Whittier (ADEC No. 93-211-237-1).
Hydrocarbon contamination has been identified with excavations under above ground storage tank floors which are being replaced as part of an on-going storage tank repair project at DFSP Whittier. At present, no evidence exists that contamination is due to any recent release of product. No excavations have been made in which any groundwater has been observed. Observations were made by U.S. Government employees monitoring the construction project.
The project is being implemented in a phased approach in which four tanks are being repaired in 1993, four tanks will be repaired in 1994, and the dikes of these eight tanks will be repaired during the 1994 and 1995 construction seasons.
The construction contract is being administered by the Army Corps of Engineers through the Resident Office at Ft. Richardson. The ACOE construction contract number is DACAB5-93-C-002B. Due to the critical nature of the work, there is full time on site surveillance of the construction by the COE. The construction is also observed approximately twice per week by an employee of the engineering firm which performed the tank repair design, who is certified in accordance with API's Aboveground Storage Tank Inspection and Certification Program.
Two areas of contaminated soil have been identified and are described as follows. Sample location are shown on the attached sketches (Encl 1). Analytical test results are also attached (Encl 2).
(1) A 6" thick layer of "oil sand" has been identified beneath the floors of B03 and 805. This oil sand has been identified as containing approximately 1,600 mg/kg of Extractable Petroleum Hydrocarbons (EPH) by method 8l00M. This material was not identified prior to construction due to the presence of the original concrete ringwall and the lack of original construction documentation. Although this material was not anticipated here, the use of "oil sand" under tank bottoms has been a common construction practice nationwide until recently.
(2) One small location of "stained" gravel was observed below a portion of the "oil sand" described above, at Tank 803. This material has been identified as containing approximately 2,100 mg/kg of Extractable Petroleum Hydrocarbons (EPH) by method 8100M.
(3) The tank repair contract includes provisions for continuous on site soil monitoring and screening by the contractor during all excavation activities, segregated stockpiling of all excavated materials until laboratory evaluations confirm the preliminary screening results, and disposal of contaminated soil by the Contractor in accorddance with all applicable Federal and State regulations. The specific requirements are in section 02055 of the project Specifications, which is attached for reference (Encl 3).
Our proposed remedial measures are to remove and dispose of soils/sand and gravel below the remaining floor with a hydrocarbon contamination level greater than 100ppm. The contract will be modified to include quantities encountered and not previously defined. The contractor will perform this work in accordance with the existing contract documents. Continuous monitoring will be employed to ensure that all contaminated material encountered is removed.
The Government is currently in the process of modifying the contract to direct the Contractor as described above. The construction schedule is critical and will be impacted by this remedial action. The contractor will be directed to proceed immediately to minimize the impact to the schedule. Please advise with any comments or concerns so that we can in corporate these into the plan. Should you require any additional information, please advise Jack O'Donovan in
our Indian field office at 653-7043. |
Doreen Sullivan-Garcia |
| 9/20/1993 |
Update or Other Action |
During the tank restoration project in 1993, indications were present that soil contamination was present beneath above-ground storage tanks (ASTs) 801 through 803 and 805. Therefore, each of the large ASTs (especially the older tanks, Tanks 801 through 810), is suspected to be a potential source of petroleum hydrocarbon contamination.
Because the fuel content of each tank has varied over time, any of multiple fuel types may have been released into the subsurface (NOTE TO FILE: if the Product type is unknown then the following soil and groundwater analyses are required: GRO, DRO, RRO, BTEX, PAHs, Other VOCs, EDB, 1,2-DCA, MTBE (may be required by PM), Metals, PCBs. The department will waive the requirement that a product be identified by analysis if the owner or operator demonstrates that only one type of product was stored or distributed during the facility’s operational life.).
Tank 820 had a recorded release of 2,100 gallons of diesel fuel in 1987. This spill may have contributed to the petroleum hydrocarbons detected in soil and groundwater at locations of monitoring wells MW-08 and MW-09. Additionally, spills or releases from the Laboratory underground storage tank (UST) may be the source of contamination in soil and groundwater at monitoring well MW-22.
Tanks 801 through 803 and Tank 805 were restored in 1993. GSI notes that the restoration work included removal for offsite treatment and disposal of bedding sand and soil containing GRO, BTEX and DRO. |
Louis Howard |
| 7/12/1994 |
Update or Other Action |
Sound Environmental Services, Inc. submits to the ADEC Anchorage District Office the Whittier Treatability Study.
Fixation Application
It is proposed that contaminated material excavated from beneath the tanks in 1994 be stabilized using the DCR process & replaced as fill in the new tank construction. Treated material would be used as foundation material beneath the restored tanks. In order to implement this option it is first necessary to perform treatability studies in accordance with the ADEC draft guidance document for fixation applications.
Proposed Treatability Study
Samples from beneath the four tanks to be moved this year cannot be taken until actual construction activities are initiated. At that time, schedule constraints will not allow for the use of actual samples from these excavations for treatability studies. Thus, it will not be possible to perform treatability work on actual contaminated site samples. However, contaminated soil characterization data are available from the restoration of the first four tanks on site.
It is proposed that representative soil samples taken from the immediate vicinity of the tanks scheduled for restoration in 1994 be spiked to contaminant levels in excess of the maximum levels found in the 1993 excavations, &, these spiked samples then be used for treatability testing.
The maximum contaminant levels found under each of the tanks restored in 1993 are shown below:
Tank 801: GRO 520 mg/kg, BTEX 7.3 mg/kg, DRO 5,900 mg/kg, Tank 802 GRO 180 mg/kg, BTEX 2.7 mg/kg, DRO 2,900 mg/kg Tank 803: GRO 330 mg/kg, BTEX 6.06 mg/kg DRO 1,700 mg/kg & Tank 805 GRO: N.D. BTEX N.D. DRO 1,700 mg/kg.
It is proposed that treatability testing be performed on two samples spiked with diesel & gasoline to the following levels:
Treatability sample 1 (minimum spiked amount): GRO 520 mg/kg, BTEX 7.3 mg/kg, DRO 5,900 mg/kg
Treatability sample 2 (minimum spiked amount): GRO/BTEX none DRO 1,700 mg/kg.
Each of these samples will be treated using the DCR process to stabilize the liquid organic phase. Samples will also be treated with Portland cement to reduce sample permeability to less than 1-10-5 cm/sec. Spiked samples will be thoroughly homegenized & characterized for Gasoline Range Organics & BTEX by EPA Method 602 & Diesel Range Organics by EPA Method 3550/8015 Mod. Likewise, treated samples will be thoroughly homogenized* & subjected to the following tests. An independent analytical laboratory will be used for all evaluations.
See site file for additional information.
|
Eileen Olson |
| 8/5/1994 |
Meeting or Teleconference Held |
ADEC Eileen Olson called Jim P. of Sound Environmental. Contamination levels are based on 1993 contamination estimates. Soil type: Glacial till, poorly sorted, fintes to pea size. 5,900 mg/kg highest expected diesel range organic (DRO). Verbal approval given. Work must be done in accordance with leaching guidance (NON-UST Soil CleanuP Interim Guidance July 17, 1991).
Hazardous Substances Other Than Petroleum Products.
Soil contaminated by hazardous substances other than crude oil or refined petroleum fuel products must be cleaned to background levels or to levels that are shown through a contaminant leaching assessment to not lead to groundwater contamination through leaching nor pose a risk to potential surface receptors. Soils meeting the definitions of RCRA hazardous wastes shall be treated and disposed of as required by RCRA.
The contaminant leaching assessment should include:
(A) An evaluation of soil type, using the Unified Soil Classification System, or another similar soil classification system;
(8) samples, collected from the excavations, borings, and other soils at the site, which are representative of the contamination detected, and which constitute potential migration routes to groundwater or other receptors;
(C) an evaluation of hydraulic conductivity, adsorptive capacity, potential migratory routes, depth to groundwater, and hydrogeologic conditions at the site;
(D) an estimate of annual precipitation at the site;
(E) a contaminant leachability analysis appropriate to the contaminants identified on the site, based on a procedure approved by the department, which evaluates the potential concentration of each contaminant that could migrate from the contaminated zone into groundwater or adjacent surface waters;
and
(F) an exposure evaluation that addresses the nature and estimated amount of release in relation to surrounding human populations, including impacts to water quality, use and approximate locations of wells and surface water potentially affected by the release, and current and potential land use.
|
Eileen Olson |
| 2/22/1995 |
Update or Other Action |
Tank 813 released 113,000 gallons of JP-5 jet fuel due to a ruptured pressure relief line. An icefall caused the rupture of a ¾-inch diameter pressure relief line on Tank 813. The rupture resulted in the discharge of approximately 2,700 barrels of JP-5 fuel to the secondary containment area surrounding the tank.
A February 22, 1995 release of JP-5 fuel from Tank 813 resulted in spill response and a subsequent release investigation (RI). The purpose of the RI was to determine the possible mechanism for escape of released fuel from the secondary containment area. The report presented soil analytical results from new borings BH-13 through BH-21, and monitoring wells MW-31, -32, -34, -44 and -45. The GSI Tank 813 Release Investigation Report also identified a multi-phase plume (liquid phase, adsorbed phase, and dissolved phase) that resulted from the release at Tank 813. The RI included results of forensic geochemistry indicating the presence of JP-5 fuel of varying vintage, suggesting a history of release. |
Louis Howard |
| 2/23/1995 |
Update or Other Action |
SITUATION REPORT: DFSC Whittier Tank Farm Spill NUMBER: 1
LOCATION: Whittier, Alaska
SPILL #:
LEDGER CODE #: Has been requested.
TIME AND DATE OF REPORT: February 23, 1995; 1600
TIME AND DATE OF NEXT REPORT: February 24, 1995 at approximately 1530
TYPE AND AMOUNT OF PRODUCT SPILLED: 10,500 gallons of JP8; DFSC- Cpt.McCaw
CAUSE OF SPILL: Ice 4-6 inches thick fell from the side of the tank #813 onto the 3/4 inch pressure relief line and broke it.
TIME AND" DATE OF SPILL: February 22, 1995 at 0915
RESPONSIBLE PARTY: Defense Fuel Supply Center; Major Bob Wholley
CURRENT SITUATION: This spill is contained within the lined, diked containment area. The containment area has approximately 4-6 inches of ice frozen on the liner. Burlington Environmental was activated by DFSC. One vacuum trucks is being utilized to recover the free product. Additional vacuum trucks have been dispatched by Burlington Environmental and are expected to arrive in Whittier at 1800. Approximately 1200 gallons have been recovered. The fuel from the diked area is being stored in tank #808. The entire contents of tank #813 is being transferred to other tanks in the terminal. Due to the limited winter train schedule, the earliest a DEC responder can arrive in Whittier is 1400 on February 24.
ACTIONS TAKEN: On February 22, 1995, the Terminal Superintendent initiated first responder procedures within 15 minutes of identifying the discharge. The 3/4 inch pressure relief line was plugged by 1000 hr. Removal of the product from the diked area via pump truck began at approximately 1010. Snow was removed from all the dike drain valves to verify that no product was released outside of the dike.
POTENTIAL HAZARDS: Winter weather conditions, frostbite, hypothermia
PLANS AND RECOMMENDATIONS: Bill Lamoreaux, Anchorage District Manager is coordinating via telephone with DFSC. Due to the limited rail schedule, the earliest a DEC responder could be dispatched is February 24 at 1400. |
Bill Lamoreaux |
| 2/27/1995 |
Update or Other Action |
SITUATION REPORT: DFSC Whittier Tank Farm Spill NUMBER: 2 and Final
LOCATION: Whittier, Alaska
SPILL #:
LEDGER CODE #: 14873060
TIME AND DATE OF REPORT: February 27, 1995; 1030
On February 24, 1995, Jeff Ginalias, ADEC/ADO conducted a field assessment of the spill site. The spill was contained in the lined diked containment area of Tank #813. DFSC and Burlingtion Environmental recovered 900+ barrels of product, and snow/ice. The contaminated snow/ice/product mixture is being stored in the vacant tanks within the farm. The anchor ice that lines the containment area is contaminated and will need to be removed and collected. The
vacuum trucks have been demobilized from the site. ADEC/ ADO anticipates a waste management plan from DFSC this week.
On February 22, 1995, the Terminal Superintendent initiated first responder procedures within 15 minutes of identifying the discharge. The 3/4 inch pressure relief line was plugged by 1000 hr. Removal of the product from the diked area via pump truck began at approximately 1010. Snow was removed from all the dike drain yalves to verify that no product was released outside of the dike.
This spill was contained within the lined, diked containment area. The containment area has approximately 4-6 inches of ice frozen on the liner. Burlington Environmental was activated by DFSC. One vacuum trucks is being utilized to recover the free product. Additional vacuum trucks were dispatched by Burlington Environmental. The fuel from the diked area is being stored in tank #808. The entire contents of tank #813 was transferred to other tanks in the terminal. |
Jeff Ginalias |
| 3/9/1995 |
Update or Other Action |
SITUATION REPORT: DFSC Whittier Tank 813 Spill NUMBER: 3
LOCATION: Whittier, Alaska
SPILL #: 95-211-058-2
LEDGER CODE #: 14873060
TIME AND DATE OF REPORT: March 9, 1995; 4:00 pm
TIME AND DATE OF NEXT REPORT: Thursday, March 16, 1995
On March 9, DFSC reports to ADO that 85,000 gallons have been recovered and transferred to storage tank #808. The remaining 28,000 gallons are trapped in snow and ice within the lined containment dike. DFSC has contracted with VRCA Environmental for a portable heating unit to melt the ice and gather the liquid product.
DFSC's proposed February 28, 1995 remediation plan consists of melting the contaminated ice/snow, gathering the liquid in tank cars for separation, skimming the fuel, and shipping the water to Anchorage for treatment and disposal. DFSC has shipped two rail cars accordingly. Due to the unanticipated large volume of treated water, DFSC is now storing the remainder of the
melted water in the original storage tank, #813. After separation, DFSC is considering treatment methods on-site, and is considering a modified treatment plan.
ADEC has approved DFSC's submitted plan addressing spill cleanup, fuel recovery and wastewater disposal. |
Jeff Ginalias |
| 3/10/1995 |
Offsite Soil or Groundwater Disposal Approved |
ADEC (B. Lamoreaux P.E. District Mgr.) sent W.E. Good DFM DLA DFSC a letter. Subject: Defense Fuel Supply Command - Whittier Tank Farm Spill Disposal of Contaminated Snow and Ice
This letter is in response to your disposal plan submitted on February 28, 1995 for the
treatment of contaminated ice and snow from the February 22, 1995 spill from tank number 813 at the Whittier Tank Farm. In your proposal, you described a procedure whereby the remaining contaminated ice and snow would be thawed, delivered to a rail tank car and delivered to Anchorage for further treatment and ultimate disposal into Anchorage's sanitary sewer.
The procedures you outlined are acceptable to the Department of Environmental Conservation as long as these procedures prevent the spillage of any untreated water. As to the final disposal to the sanitary sewer, it is the responsibility of Anchorage's Water and Waste Utility to oversee and control discharges to their sewer system and as such, you will need permission from that authority for the final discharge.
Should you have any questions or find it necessary to deviate from the submitted plan, please let us know. |
Bill Lamoreaux |
| 3/13/1995 |
Update or Other Action |
SITUATION REPORT: DFSC Whittier Tank 813 Spill NUMBER: 4
LOCATION: Whittier, Alaska
SPILL #: 95-211-058-2
LEDGER CODE #: 14873060 ['3;>
TIME AND DATE OF REPORT: March 1995; 4:00 pm
On March 9, DFSC reports to ADO that 85,000 gallons have been recovered and transferred to storage tank #808. The remaining 28,000 gallons are trapped in snow and ice within the lined containment dike. DFSC has contracted with VRCA Environmental to provide spill response.
On March 10, Bauer-ADO inspected site. VRCA has removed all free liquids from secondary containment. VRCA has scraped all contaminated snow from the ice covered secondary containment and has stockpiled the contaminated snow within the secondary containment. VRCA is using the snow melter to process the stockpiled contaminated snow stockpile. Meltwater from the snow water is pumped into tank 813 (DFSC transferred the remaining fuel from the tank after .the spill event). Recovered fuel skimmed from the snow melter is stored on site and gauged. Since 3-7 VRCA's daily fuel recover figures were 2000, 1356, 2403, 1000, and 400 gallons. On 3-10
VRCA started using a steam unit to thaw the remaining ice in an attempt to recover the fuel trapped in the ice. There is approximately 20,000 to 25,000 gallons of spilled fuel remaining in the ice.
DFSC used a dozer to remove snow from the secondary containment drain outlet to permit visual observation of any leakage past the drain valve. There has been no discharge observed from the drain outlet.
ADO has approved DFSC's submitted plan addressing spill cleanup, fuel recovery and wastewater disposal. |
John Bauer |
| 3/17/1995 |
Potentially Responsible Party/State Interest Letter |
ADEC letter to DLA W. Barnum RE: Spill# 95-211-054-2 DFSC Whittier Tank Farm.
This letter is to advise you that on or about February 22, 1995 a pollution incident occurred at the Whittier DFSC Tank Farm, Tank #813, at Whittier, Alaska, for which you will be financially responsible. Under Alaska Statutes, the State government has an interest in this incident, and further; may take appropriate action to minimize the damages that are threatened, or which may be caused, by this incident.
Alaska Statute, Title 46, authorizes the State government to respond to this pollution incident. Under this Act, if the owner or operator of the source fails to take adequate removal actions, the owner or operator may be held financially responsible for any actions taken by the State government. Removal is adequate and being done properly if it is done in accordance with Federal and State statutes, and Regulations 18 AAC 75. If you undertake removal actions, the adequacy of such actions shall be determined by the undersigned as a representative of the State On-Scene Coordinator.
As long as you are taking adequate actions in this matter, State action will be limited to monitoring the progress of your activities and to provide .guidance as necessary.
Alaska Statute 46.08.070 requires recovery be sought for costs incurred by the State in response to this incident,which includes our oversight activities.
18 AAC 75.307, requires that a final written report be submitted for all discharges of oil and hazardous substances within 15 days after cleanup has been completed. If no cleanup occurs, the report must be submitted within 15 days of the discharge.
Enclosed are the final reporting requirements.
Please be advised that we will be billing you at a later date for those expenditures associated with this spill. Your response actions will be considered by the Department of Law in determining the amount of civil penalty assessed as a result of the discharge, if any. |
Jeff Ginalias |
| 3/20/1995 |
Update or Other Action |
SITUATION REPORT: DFSC Whittier Tank 813 Spill NUMBER: 5
LOCATION: Whittier, Alaska
SPILL #: 95-211-058-2
LEDGER CODE #: 14873060
TIME AND DATE OF REPORT: March 20, 1995; 4:30 pm
DFSC is estimating current fuel recovery at 100,000 gallons. ADEC has requested and is awaiting daily logs to verify recovery rate. Blizzard conditions followed by heavy rains March 16-19 brought cleanup operations to a halt. VRCA has stopped the snowmelt operations. DFSC will submit a revised water disposal plan to DEC for approval which includes proposing allowing spring conditions to allow for melting and skimming of product. Daily monitoring for discharge continues. Groundwater Technology, Inc. took water quality samples of the secondary containment water to establish existing contaminant levels.
ADO has approved DFSC's initial plan addressing spill cleanup, fuel recovery and wastewater disposal. DFSC is preparing a revised treatment plan for the remaining fuel recovery and wastewater disposal. |
Jeff Ginalias |
| 3/21/1995 |
Update or Other Action |
ADEC letter to DFSC RE: Whittier Tank Farm Spill
As response to the February 22, 1995, Whittier Tank Farm Spill continues, it appears that the cleanup has now entered a different stage. As I understand it, approximately 90% of the spilled fuel has been recovered, and DFSC has now contracted with Groundwater Technology, Inc. (GTI) for completion of the cleanup.
As the status of the cleanup has changed from the initial response plan, submitted February 28 and approved March 10, the Department requests the following information:
1. An amended cleanup plan. The Department was in discussions with GTI staff Friday, March 17, regarding submittal of a proposed plan for treatment and discharge of water from the containment dike. On March 20, you presented to us the proposal to resume snowmelt operations. The amended plan should address both your and GTI's proposals and provide an integrated cleanup plan.
2. Interim reports. The last DFSC spill report update was submitted March 1, 1995. Since then, ADEC has made a subsequent field inspection of the site, and has been in constant contact with DFSC regarding field operations, fuel recovery, waste disposal, and site safety, but none of this information has been provided by formal, written report. ADEC requests an interim report, pursuant to and in compliance with 18 MC 75.307(a) and (c).
Additionally, the following specific information is requested:
a) a chronology of the events of cleanup from initial response to the present;
b) the amount of fuel recovered, its location, and the basis for the estimation as to the amount of recovery;
c) the amount of water recovered by the snow.,melting operation, the location of storage, and proposed plan for its ultimate disposal; and d) the status of monitoring activities around the site, including preestablished monitoring wells, as well as outside the discharge drain and
the nearby stream and coastal shoreline. Also, please advise as to the availability of sorbents and boom in the event fuel appears outside the dike.
Signed
Jeffrey L. Ginalias
Environmental Specialist. |
Jeff Ginalias |
| 3/23/1995 |
Update or Other Action |
SITUATION REPORT: DFSC Whittier Tank 813 Spill NUMBER: 6
LOCATION: Whittier, Alaska
SPILL #: 95-211-058-2
LEDGER CODE #: 14873060
TIME AND DATE OF REPORT:. March 23, 1995; 4:00 pm
DFSC estimates current fuel recovery at 103,000 gallons. ADEC has requested and is awaiting verification logs. Blizzard conditions, followed by heavy rains March 16-19, brought cleanup operations to a halt. The snowmelt operations have stopped. SUPSALV has demobilized its equipment.
March 22 - Ginalias (ADO) and Pearson (SCRO) inspected the site and met with cleanup officials. The rains resulted in a large amount of water accumulating within the containment area. This was followed by cold temperatures and wind, resulting in frozen surface conditions. The remaining fuel is trapped in the ice and snow. Cleanup will resume when temperatures rise and melting occurs.
DFSC will submit a revised water disposal plan for DEC approval which proposes allowing spring conditions to allow for melting and skimming of product. Daily monitoring for discharge continues. Groundwater Technology, Inc. (GTI) , on behalf of DFSC, took water quality samples of the secondary containment water to establish existing contaminant levels. They report that the sample contaminant levels exceed drinking water discharge limits. GTI estimates water and ice in the containment area at one million gallons. Accordingly, GTI's proposed wastewater disposal plan may require a special permit application and public notice.
ADO has approved DFSC's initial plan addressing spill cleanup, fuel recovery and wastewater disposal. DFSC is preparing a revised treatment plan for the remaining fuel recovery and wastewater disposal. |
Jeff Ginalias |
| 4/4/1995 |
Update or Other Action |
DFO-AK Reggie McCaw sent fax to ADEC (Jeff Ginalias) regarding Monitoring Well Data (Wells 3, 4, & 5)/Fingerprint data Well 4. April 3, 1995 Fax from Groundwater Technology (GTI) Steve Teller to Randy Banez DFSC. Technical director at CT&E laboratories reviewed the chromatograms from the water well sample (950329-1) and a sample of fule collected from inside the containment dike and said they are a "Peak For Peak Match". The two samples are from the same product. April 4, 1995 fax from DFSP Whittier to DFO-A Attn: Karolyn. Cpt. McCaw called this morning. He needs this information on monitoring wells 3, 4, & 5. Please pass this on to him.
|
Jeff Ginalias |
| 4/6/1995 |
Update or Other Action |
Fax from DFO-AK (R. Banez) to ADEC (J. Ginalias) Subj: Addtl. Monitoring wells at Whittier. Have not heard any word back on the status of this permit. Most likely will require some help. GTI is currently working on getting a drill rig into Whittier earlier than Sunday.
Easterly of the government owned Whittier Tank Farm, Whittier AK. Drill an estimated seven (7) four-inch (4") diameter monitoring/recovery wells to locate a possible underground plume of fuel. Work to begin on April 10, 1995 and to be completed by June 1, 1995. |
Jeff Ginalias |
| 4/6/1995 |
Update or Other Action |
SITUATION REPORT: DFSC Whittier Tank 813 Spill NUMBER: 7
LOCATION: Whittier, Alaska
SPILL #: 95-211-058-2
LEDGER CODE #: 14873060
TIME & DATE OF REPORT: April 6, 1995; 1:00 pm
DFSC estimates current fuel recovery at 103,000 gallons, leaving approx. 10,000 gallons not recovered. Skimming operations resumed within the diked area on April 2. DFSC estimates fuel recovery from skimming operations April 2-5 at 2200 gallons.
The skimming operation consists of allowing natural melting to liberate fuel & allow it to rise to the surface. The crew (3-5 persons) then booms the fuel & herds it to recovery areas. Wind often helps move the fuel to a recovery area. At the recovery area, a skim pack collects the fuel off the surface & pumps it to a fuel truck. After time for separation, the water in the tank is decanted back into the diked area, & can be used as a header to push more product towards the skim pack. During the ADEC April 5 inspection, slush ice conditions was hindering recovery. After start up recovery of 100 gallons of fuel on April 2, recovery over the last three days has been 900, 500, & 700 gallons respectively, per DFSC reporting. Skimming operations are projected to continue for another couple of weeks, until it ceases to be productive.
On April 4, ADEC received field logs that Monitor Well #4, located outside of the secondary containment for tank #813, tested positive for JP-8 fuel. Following draw down pumping of the monitor well, confirmation sampling from the well indicates 1-2 inches of floating product on the ground water. Chromatograph tests show a match with the fuel spilled from tank #813. Confirmation tests indicate 1-2 inches of floating product in the well.
On April 6, Bauer & Ginalias (ADO) inspected the site, met with cleanup officials, & reviewed operations. Water in the diked area is at the ringwall, & is estimated at over 1 million gallons. The dike liner is attached to the side foundation of the tank, about 3 feet below the current water line. While it's apparent that there is a leak somewhere in the liner, the free fuel should be floating above the liner & the leak.
Skimming operations remain successful in recovering significant amounts of fuel, so while some fuel may be getting through the leak in the liner, the concentrations should be low enough to justify retaining fuel in the dike & continuing skimming operations. ADEC officials agreed that as long as significant fuel recovery continues through the skimming operation, that the water may be retained in the dike. When skimming operations cease, or a change in circumstance occurs, the water will be pumped into tank #813 for storage, treatment & discharge. The water level will be managed by periodic pumping into the tank, to maintain a level above the tank/liner attachment, but low enough to maintain a safe working & storage depth.
See site file for additional information.
|
John Bauer |
| 4/17/1995 |
Update or Other Action |
Following the meeting with all the principal parties to the cleanup of the Whittier Tank Farm Spill, the parties agreed to an approach towards cleanup of the spill. This letter formalizes some of the terms and understanding of the parties.
Containment dike.
All parties agree that there isa leak somewhere in the liner from which water and fuel has escaped. Having reviewed the operations, and especially in light of the successful fuel skimming operations, the Department agrees with DFSC that, at present, leaving the water in the diked area, allowing fuel to liberate to the top and be skimmed off, seems the best approach. As long as skimming operations continue to recover significant amounts of fuel, which could possibly escape by draining the dike, or get caught up or remain in the sediments anchoring the bottom of the dike, the water may remain in the dike.
However, when skimming operations cease, or if a change in circumstance warrants, the water shall be pumped into tank 813, or other suitable storage facility, pending ultimate treatment and discharge. The containment dike shall not be used as a water storage lagoon once recovery stops. The Department should be kept apprised, of the fuel recovery from skimming operations, most notably when recovery numbers plummet, as well as the water levels, in the tank and dike.
Discovery/monitoring wells.
It is the Department's understanding that all necessary permits have been obtained, that the drilling rig equipment is on site, and that drilling of additional discovery and monitoring-wells has commenced. The Department should be apprised of the specific drilling plan, from conception through development; followed by the status of wells, their location, and the results. The Department requests daily logs from the wells.
If this proves burdensome, the information may be provided in some synopsis form. Copies of data transmitted between the parties may be sufficient. The parties should apprise the Department early of the drilling results and the recovery plan, in order for the Department to make informed decisions and provide input. The Department requests a list of the equipment brought on site, especially the number of pumps, and wishes to be informed of changes in the use and inventory of equipment.
Daily monitoring of streams and shoreline.
With the fuel plume so close to Passage Canal, DFSC shall twice daily visually monitor the stream channel near the #4 monitoring well, and any other watershed area where fuel might surface, plus the shoreline, to see if fuel is present. As much as possible, at least one of these monitoring trips should be conducted on an outgoing tide, as this seems the most likely time for the fuel to flow. Once the extent of the plume is defined, this monitoring aspect may be revised to better address the location of the fuel.
Site Specific Response Plan.
Due to the proximity of the fuel to the waters of Prince William Sound, the Department requests a copy of the SUPSALV's site specific plan for response to any fuel which may migrate or escape to the streams or shoreline of the Sound. The plan should include the vessels available, boom, pumps, and other equipment or personnel necessary and available.
Wildlife Protection.
The large amount of water in the dike may become an attraction for migrating birds. DFSC has agreed to maintain some water in adjacent containment dikes as an alternative area in the event birds are insistent on resting in the area. DFSC will conduct initial, low impact hazing operations to deter birds from the area, and will contact the Department immediately, plus the Department of Fish and Game, 267-2336, attention Claudia Slater or Mark Fink, if more aggressive hazing techniques are necessary. Bird use of the area should be documented. |
Jeff Ginalias |
| 5/4/1995 |
Update or Other Action |
Interim Status Report (GSI)
DLA DFSC DFO-Alaska (R. W. McCaw Cpt.) sent a status report on the cleanup & investigation of the fuel spill within dike 813 at Defense Fuel Support Point (DFSP) Whittier on February 22, 1995. Fuel recovery operations within the dike are nearly complete with only a residual sheen occasionally appearing due to release from contaminated dike ballast material.
We are continuing to draw off dike water & transferring to tank 813 for future treatment prior to discharge. To minimize volume of water requiring treatment, thus costs, we request your approval of the conceptual design of the proposed water treatment system described on page 10 of this report. Our goal is to construct an ADEC approved treatment system as soon as possible to take full advantage of limited favorable weather conditions.
GSI Status Report briefly summarizes the history of the release & emergency actions performed prior to GSI involvement, the interim corrective actions performed by GSI, &, the preliminary results of that action. This report includes the interim plan for recovering released fuel & an estimate of the amount of fuel recovered, a water treatment plan for hydrocarbon-impacted water within Tank 813's containment, the drilling plan for determining the extent of contamination of the subsurface & preliminary results, the plan for recovering fuel from monitoring well(s) & results, the contingency plan in the event of impact to the marine environment, & the plan for dealing with any use of the Tank 813 containment area by waterfowl.
On February 22, 1995, falling ice ruptured a 3/4-inch pressure relief line on Tank 813. DFSC estimates that 2695 barrels (1 bbl = 42 U.S. gallons) were released from the tank into the diked containment area that surrounds the tank. Fuel was pumped off the ice & snow in the containment after the ruptured line was plugged. After the majority of the fuel was removed, fuel saturated snow was stockpiled within the containment & melting operations were initiated to liberate the fuel. On March 16, 1995, the emergency response phase of the cleanup was terminated. As of March 29, 1995 DFSC estimates that 2361.16 bbls have been recovered leaving 334.05 bbls (14,030 gallons) unrecovered.
Wells
All wells in the section of the site potentially affected by the release from Tank 813 have been monitored on a daily basis since April 2, 1995. The depth to GW, the depth to free product (if any), & the thickness of free product (if any) were recorded (Table 1). The measured wells include pre-existing wells MW3 through MW7 & all new monitoring wells (MW31 through MW45) as they were installed.
MW4 is the only well in which free product has been observed. The WTF operator, Northern Management (NM) initially discovered 16.13” of free product in MW4 on March 24, 1995. The amount of free product in a well is normally greater than the actual thickness of the layer of free product on the GW surface near the well. A bail down test performed by GSI on March 29 estimated that the free product thickness in the formation surrounding MW4 was 0.14’. The thickness of free product in MW4 remained at approximately 0.16’ & then gradually decreased until April 18 after which no free product was observed. Based on monitoring data, the water table began rising & correlates with the gradual disappearance of the product within MW4 (i.e. the product became immobilized within the pore spaces of the formation & below the water table).
See site file for additional information.
|
Jeff Ginalias |
| 5/5/1995 |
Update or Other Action |
Letter from ADF&G to Groundwater Technology, Inc. Mr. Jerry Harris, 19033 W. Valley Highway, Ste D-104, Kent, Washington 98032
FG 95-II-0217
Re: Outfall Structure - Unnamed Stream SE 1/4 Section 15, T. 8 N., R. 4 E., S.M.
Pursuant to AS 16.05.870 and AS 16.05.840, the Alaska Department of Fish and Game (ADF&G) has reviewed your letter dated April 11, 1995, inquiring about the discharge of treated water into an ephemeral stream at the referenced location.
The unnamed stream has not been specified as important for the spawning, rearing, or migration
of anadromous fish pursuant to AS 16.05. 870(a). It is not known if this stream supports resident species of fish in the area of your proposed operation. Therefore, a permit from the ADF&G is not required at this time for your proposed water discharge. If, in the future, fish are found in the unnamed stream in the vicinity of your activities, we will require that your water discharge operation not restrict the upstream and downstream movement of fish. Regarding the question number 1 of the Coastal Project Questionnaire, the answer should be "yes" even though the stream is ephemeral.
Please be advised that this determination does not relieve 'you of the responsibility for securing other permits: state, federal or local, and that you are still required to comply with all other applicable laws. Signed David Benton, Deputy Commissioner - Dept. of Fish & Game, Habitat & Restoration Division |
Louis Howard |
| 5/8/1995 |
Update or Other Action |
SITUATION REPORT: DFSC Whittier Tank 813 Spill NUMBER: 8
LOCATION: Whittier, Alaska
SPILL #: 95-211-058-2
LEDGER CODE #: 14873060
TIME AND DATE OF REPORT: May 8, 1995; 10:00 am
On May 4, Bauer and Ginalias (AWDO) inspected the site,met with cleanup officials and reviewed operations.
1. Containment Dike Skimming Operations. DFSC estimates fuel recovery from skimming operations April 4-May 5 have recovered 12,600 gallons. Of the 113,000 gallons spilled, only 1,430 gallons now remain unaccounted for. All the ice in the diked area has melted, and all the fuel should now be liberated. Skimming operations will cease by today, and final cleanup of the diked area will consist of dragging ~ sorbent pads or sorbent boom across the water to recover remaining sheens. The water in the dike will be subject to a wastewater treatment permit, discussed at paragraph 4 below. After treatment and discharge of the water, the liner will be inspected to determine the apparent source of the leak, as well as a determination of whether to repair or replace the liner. The gravels/soils used to stabilize the liner most likely will show contamination and should require a remediation plan. This plan should also encompass remediation of the soils beneath the liner, if necessary.
2. Monitoring/Recovery Well Operations. As a result of the fuel "hit" reported April 4 at Monitor Well #4, fifteen monitor/recovery wells drilled between April 9-May 1 to define the plume and recover fuel. Four wells "down slope" of Monitoring Well #4 show fuel contamination in the soil, apparently at low numbers. ADEC is waiting for final lab result confirmation numbers. All wells show fuel in dissolved phase in the water column. DFSC's contractor advises that this is consistent with all other monitor wells at the Tank Farm, and mayor may not be indicative of fuel from this incident.
Fuel recovery from MW #4 yielded one gallon, first by bailing and then by a skimmer pump. Monitoring Well #4 is the only well to show free product, and no free product has been observed in this well since April 18. DFSC estimates the size of the plume at 300' x 200'. It appears to extend from DFSC property onto Alaska Railroad property. DFSC is monitoring the wells daily and taking twice weekly samples. Based on the information provided, at present it does not appear that free product is recoverable from any of the monitoring wells, or that the plume is spreading. No site remediation plan has been proposed.
3. Shoreline Monitoring and Spill Response. SUPSALV, DFSC's spill response contractor, has prepared a spill response plan and has equipment poised, in the event recoverable fuel surfaces on the land or the water. DFSC staff is walking the streams, shoreline and potential impact areas twice daily.
4. Wastewater Treatment and Discharge. At present, DFSC estimates the diked area holds between 750,000-1,000,000 gallons of water. In addition, several thousand gallons of water have been pumped back into the tank, to keep the water level below the ringwall, but above the side of the liner's attachment to the tank wall. The amount of water will require qFSC to submit an application for an individual wastewater permit. ADEC and DFSC staff met with Whittier officials and advised them of the status of operations.
DFSC's contractor will submit an application and plan for treatment and discharge of the water from the diked area.
As spill response cleanup appears to have reached its end, the AWDO SPAR group is coordinating with ADEC Contaminated Sites Group for continued response to the site. Plan submittals which will be required include review of the liner and associated soils; wastewater treatment and discharge; contaminated site remediation at the monitoring well area; and API 653 tank integrity inspection. |
John Bauer |
| 5/18/1995 |
Update or Other Action |
GTI sent Whittier Fuel Release, Water Sampling Plan to John Bauer (ADEC). All recoverable fuel in the Tank 813 diked containment area has been recovered. The last ice in the containment area melted on May 4, 1995, and we terminated our fuel skimming operation on May 8, 1995.
We have continued using sorbent pads and booming to collect any recoverable fuel. remaining after the end of the skimming operation. No recoverable. fuelremains on the water in the Tank 813 containment area and we plan to discontinue product recover activities on Friday, May 19, 1995. Pursuant to our onsite discussions of May 4, 1995, we propose collecting water samples from the water in the containment area and from the water in Tank 813 upon termination of the fuel recovery operation.
The objective of this sampling is to determine concentration of dissolved hydrocarbon compounds in the water in these two areas for the purpose of treatment system design and to evaluate the possibility of direct discharge of the water in the containment area should the level of dissolved compounds in that water meet the applicable regulatory standards. This letter presents our sampling plan, including the number of samples to be collected, the method of sample collection, and the analyses to be performed on the samples.
We propose collecting four grab samples of the water in the diked containment area. One sample will be collected from each quadrant of the containment area. A duplicate sample will be collected at one of the four sample locations. We propose collecting 4 samples of the water in Tank 813. The water in Tank 813 is approximately 10 feet deep; we will collect the samples at various depths in the tank. Specifically, we shall collect samples at approximately two foot intervals ranging from 2 feet above the bottom of the tank to just below the water surface. A duplicate sample will be collected at one of the four sample depths.
In accordance with the State of Alaska Water Quality Standard Regulations (18 MC 70), we shall analyze all samples for benzene, toluene, ethylebenzene, and total xylenes using EPA method 602 in order to determine the total aromatic hydrocarbon (TAH) concentration in the water. We shall also analyze· all samples for polynuclear aromatic hydrocarbons (PAH) using EPA method 610 in order to determine the total aqueous hydrocarbon (TAqH) content of the water. The presence or absence of petroleum hydrocarbon sheen and odor will be recorded for all samples.
In order to insure that the samples represent the dissolved phase hydrocarbon compounds, special
precautions will be taken in sampling. Samples of the water in the containment area will be collected by submerging the unopened sample bottle in the water, opening the bottle under water and filling it, and then securely replacing the lid prior to removing the bottle from the water. The water in Tank 813 will be collected using a stainless-steel water sampler designed to enable sampling at discrete depths. In all other regards, the sampling, sample handling, etc. will follow the procedures set forth in our QAPP on file with the ADEC. |
John Bauer |
| 6/6/1995 |
Update or Other Action |
Fax from DFO-AK (R. Banez) to ADEC (J. Ginalias) re: Whittier Spill. I talked to steve Teller reference the water samples that were taken from the containment area and tank 8125 in Whittier. The prelimInary results in the contaInment area 1s that the water meets all regulatory standards for discharge (for prelimInary sample results see table on second pageL The laboratory however, did have an error in the processing of the samples and although they do not feel it effected the results, the results can not be used due to the error.
New samples will be taken tomorrow (7 June 1995) by OT[. The laboratory wfll process the samples in a RUSH priority, new results will be ready on Tuesday 13 June 1995, which will confirm or deny the prelim1nary results. The water in the tank however does not meet discharge standards which is no surprise, but to limit the amount of water that we have to process to meet discharge standards we will limit the amount of water pumped Into the tank from the containment area. |
Jeff Ginalias |
| 6/12/1995 |
Update or Other Action |
DFO-AK (R. Banez) fax to ADEC (J. Ginalias). I received the results for samples taken on Wednesday, 7 June. The results confirm earlier results on water In the containment area meetIng Alaska water Qualltv standards. The water In tanK 813 did not meet standards and we are waiting for the final reSUlts of the polynuclear aromatic hydrocarbons {PAH} analyses. wtllch I am expecting them today or tomorrow.
NOW that the water In the containment area has been verified to meet water Quality
Standards, we will need to discuss our o~tlons on release of water from containment area.
Containment Area Water
The water in the containment area meets all quantitative regulatory standards as specified in State of Alaska Water Quality Standard Regulations (18 MC 70.020) and by reference Alaska Drinking Water Standards (18 AAC 80) and EPA Quality Criteria (54 FR, 5/22/89 and 56 FR, 1/30/91). All samples have a benzene content that is less than the detection limit of 1.0 ppb and therefore meet the maximum contaminant level (MCL) for benzene of 5 ppb. The total aromatic hydrocarbon (TAH) content of the samples ranges from 6.7 to 7.4 ppb with and average content 7.0 ppb. I have calculated the 95% upper confidence level of the mean.
The actual mean TAH content of the water is probably slightly different than that of the four samples collected, however, there is a 95% confidence that the actual mean does not exceed the 95% UClM (95% confidence level is a standard level). The 95% UClM for TAH is 7.4 ppb which is less than the MCl forTAH of 10 ppb. All PAH concentrations are below the detection limit.
Therefore, the total aqueous hydrocarbons (TAqH - total of TAH and PAH) mean is 7.0 ppb and the 95% UCLM is 7.4 ppb. which is less than the MCl of 15 ppb.
Water in Tank 813
The water in Tank 813 does not meet regulatory standards and will req.uire treatment prior to release. The benzene content of the water ranges from 13 to 14 ppb with an average of 14 ppb. The 95% UCLM is 14 ppb which exceeds the MCl of 5 ppb. The TAH content ranges from 261 to 271 ppb with an average of 266 ppb. The 95% UClM is 271 which exceeds the MCl of 10 ppb. The total PAH results range from 76 to 372 ppb. The average PAH content is 293 ppb and the 95% UCLM is 384 ppb. The average TAqH content is 559 ppb with a 95% UCLM of 656 ppb which exceeds the MCL of 15 ppb. A QAQC review of the PAH results indicates that there is a high level of variability between field duplicates. The source of this variability is being investigated.
GTI Steve Teller Project Geologist. |
Jeff Ginalias |
| 7/26/1995 |
Public Notice |
Letter from ADEC (Robert Dolan - Major Facilities & Water Permits) to DFSC (J. R. Banez). Subject: Application for WW Disposal Permit ADEC File No. 9521-DB002.
We have received your application for a Wastewater Disposal permit for the Defense Fuels Supply Center's bulk fuel plant at Whittier, AK. and have determined it to be complete. We will be sending your application through our review and public notice process. During the approximately 6O-days that this process requires, you may be contacted by Department staff to clarify points in your application. At the end of this time, a decision on your application will be made by the Department. In the interim, should you have any questions concerning this matter, please contact me, at the above address, or at (907) 269-7565.
PUBLIC NOTICE STATE OF ALASKA DEPARTMENT OF ENVIRONMENTAL CONSERVATION
An application for a Wastewater Disposal Permit, under Alaska Statutes 46.03, has been received by the Department of Environmental Conservation. The details are as follows:
Applicant: Defense Fuels Supply Center
6920 12th Street
Elmendorf AFB, AK. 99506-2857
Proposed Activity: The one-time discharge of approximately 5 million gallons of treated hydrocarbon contaminated water. The contaminated water is the result of a spill at the fuel storage facility. The treated water will be discharged to an ephemeral creek at the facility that drains to Passage Canal.
Location of Activity; Whittier, AK.
T8N, R4E, Section 15, Seward Meridian
This Activity is Identified as 9521-DBOO2
Any person wishing to present comments regarding this application may do so by writing to Robert Dolan of the Department of Environmental Conservation, Major Facilities & Water Permits Section, 555 Cordova St, Anchorage, Alaska 99501, (907) 269-7500, by August 29, 1995. A copy of the application may be obtained by writing to the above address. The hearing or speech impaired may contact Mr. Dolan through text telephone (TDD) #269-7511.
The Department will hold a public hearing on the permit application if it determines that good cause exists. Residents in the affected area or the governing body of an affected municipality may request a public hearing by writing to the Department of Environmental Conservation, at the above address, by August 29, 1995.
This projec is also being reviewed against the standards of the Alaska Coastal Management Program (ACMP). Comments concerning the proposed project's consistency with the ACMP should be addressed in writing to the Division of Governmental Coordination (DGC), 3601 C Street, Suite 370, Anchorage, Alaska 99503. A citizen of an affected coastal district may petition the Alaska Coastal Policy Council (CPC) if they disagree with a proposed consistency determination issued by this agency during a consistancy review. Contact DGC at phone #269-7470 for details concerning the ACMP review and ACMP comment deadline. Dated July 26, 1995 signed Robert Dolan. |
Louis Howard |
| 7/27/1995 |
Update or Other Action |
Letter from ADEC (Robert Dolan) to DFSC. Defense Fuels Supply Center, Whittier Plant
ADEC Permit No. 9521-DBOO2, Fee Invoice #400994
The Department has received your initial application for a State of Alaska wastewater disposal permit. The application was received at this office on June 23, 1995. State regulations contained in 18 AAC 72, effective 2/19/93, require a fee to be submitted at the time of application. The calculation of the fee amount for your permit application is as follows:
The proposed disposal is of nondomestic wastewater as defined in 18 AAC 72.990(43). The fee is $200.00 as per 18 AAC 72.61O(a) (copy enclosed). I have enclosed a completed fee form for your use, the file copy has been retained at this office and the fiscal copy forwarded to Juneau. Payment should be remitted within 30 days to the address listed on that form.
Please be advised that an engineering plan review by the Anchorage/Western Public Service Area Office (269-7506) will also be required prior to construction and operation of the wastewater treatment/disposal system. There will also be a fee for this service, the amount of which must be determined in coordination with the Anchorage/Western Public Service Area Office. |
Louis Howard |
| 9/14/1995 |
Update or Other Action |
No. DACA85-1-95-81 Whittier-Anchorage P.O.L. Pipeline lease agreement filed with Commission on October 13, 1995 was executed on September 14, 1995, and is for lease of a pipeline system, "consisting of an eight (8) inch diameter pipeline for use, transportation, maintenance, repair and delivery of natural gas to rural areas South of, and from Anchorage to Whittier Alaska." The term of the lease agreement is 33 years commencing September 15, 1995 and ending September 14, 2028, however, it is revocable at will by the Secretary of the Army. In consideration for the lease, Alaska Pipeline Company (APLC) is required to pay, in advance, $76,000 per annum. Sanctions are imposed for late payment.
According to Ms. Patty Moore, Reality Specialist for the U.S. Army Corp of Engineers (COE), the lease was competitively advertised in local newspapers on several occasions during the month of August 1995. There were two respondents to the advertisements, namely APLC/ENSTAR and AIGC. The proposals were opened on September 5, 1995, and evaluated them.
The COE and Army reviewed the proposals, and jointly determined that APLC/ENSTAR was the most responsive proposer. The pipeline was consequently leased to the applicants. The Army will be preparing an environmental assessment report which will document the amount of environmental damage which has occurred as a result of the Army's operation of the pipeline. It is stated in the agreement that the Army has retained its responsibility for environmental cleanup of damages resulting from its past use of the pipeline. |
Louis Howard |
| 9/19/1995 |
Cleanup Plan Approved |
The Department of Environmental Conservation has reviewed your Waste Disposal Permit
Application for the discharge of treated oil contaminated water. Based on our evaluation, Permit No. 9521-DB002 is hereby granted and found to be consistent with the Standards of the Alaskan Coastal Management Program, 6 AAC 80.
Please note the conditions in Appendices A and B. This permit expires September 1,2000 and must be renewed by that date for continued operation of the facility .. Department regulations require that renewal requests be received at least 30 days prior to expiration of a wastewater disposal permit. Requests not received prior to this date cannot be renewed and must be reissued as a new permit. This process takes a minimum of 60 days during which time the facility may be prohibited from operation.
Department of Environmental Conservation regulations provide that any person who disagrees with any portion of this decision, may request an adjudicatory hearing in accordance with 18 AAC 15.200-920. The request should be mailed to the Commissioner of the Alaska Department of
Environmental Conservation, Pouch 0, Juneau, Alaska 99811-1800, or delivered to his office at 410 Willoughby Ave., Ste. 105, Juneau. Please send a copy of any such requests to the undersigned. You are reminded that, even if an adjudicatory hearing has been requested and granted, all permit conditions remain in full force and effect. Failure to submit a hearing request within thirty (30) days of receipt of this letter shall constitute a waiver of that person's right to judicial review of this decision.
This permit is issued to Defense Fuels Supply Center at Whittier AK. This permit is subject to the conditions contained in Appendices A and B which are incorporated herein by reference. This permit is issued under provisions of Alaska Statutes 46.03, the Alaska Administrative Code as amended or revised, and other applicable State laws and regulations.
This permit is effective on issuance and expires September 1,2000, unless superseded before that time by State Certified NPDES permit. It may be terminated or modified in accordance with AS 46.03.120.
See site file for additional information.
|
Tim Wingerter |
| 11/22/1995 |
Update or Other Action |
ADEC letter to Colonel Robert Wholey, Defense Fuel Supply Center, Defense Fuel Office - Alaska 6920 12th Street, Elmendorf AFB, Alaska 99506-2570. Re: Whittier Tank Farm Spill Status.
Based on conversations with yourself, Captain McCaw and Steve Teller over the past couple of weeks, it appears the seasonal cleanup of the Whittier Tank Farm #813 is over. As a significant number of activities took place this summer, the Department requests an interiin status report, pursuant to 18 AAC 75.307(a), to clarify the status and set forth the remaining issues. As I understand it, the following is an assessment of the current situation and projects that remain to be completed: If this information is incorrect, please advise me.
Tank 813
The information provided indicates that all the wastewater in Tank #813 has been reinoved. Wastewater that was being stored in Tanks #804 and #808 was pumped into Tank 813, and then in early November, all this water was loaded onto a departing barge for treatment in facilities in the lower 48. The estimated volume was 3.5 million gallons. For issues related to returning Tank #813 to service, the ADEC contact person is Ted Moore, 269-7569.
Wastewater in Containment Dike
The wastewater in the containment dike was discharged pursuant to the ADEC Waste Disposal Permit No. 9521-DB002, issued September 19, 1995. Paragraph E of the Permit requires submittal of the monitoring results from the discharge. Mr. Teller has advised that he would provide me copies of these.
Based on conversations, it is my understanding that the containment dike still holds some residual water, which is now frozen. This water will need to be discharged in compliance with the permit, along with other water that accumulates over the winter. I was advised that the drain valve is closed. It will need to remain so.
To the best of my knowledge, over 3 million gallons of water was in the dike. Please provide an estimate of the remaining water, and the plans to deal with the accumulation that occurs over the winter.
Containment liner
Related to returning Tank #813 to service is the issue of the integrity of the liner, which includes the contaminated ballast soils holding the liner in place, as well as the soils beneath the liner. Again, the department contact for the liner issues is Ted Moore, 269-7569.
Monitoring Wells
In addition to the monitoring data from the wastewater discharge referenced above, I also requested from Mr. Teller the logs from the Monitoring Well Gauging efforts, plus some recent sample results from the monitoring wells, which were taken as part of the larger scale Whittier Tank Farm remediation plan. This data is necessary for formulation of a long term remediation plan for the spill site.
Remediation of the site down gradient of Tank #813, where the additional monitoring wells were placed last spring will need to be coordinated with the ADEC DOD Contaminated Sites program. The contact person for this is John Halverson, 269-7545. |
Jeff Ginalias |
| 12/15/1995 |
Update or Other Action |
2nd Interim Status report sent by Groundwater Technology Governement Services (GSI) which was authorized by DFSC Fort Belvoir Virginia. It is intended to provide information requested of Lt. Colonol Robert Wholey, DFSC, DFO-Alaska, in an ADEC letter dated November 22, 1995.
CONTAMINATED WATER DISPOSAL
Water stored in Tanks 813 and 806 exceeded the allowable contaminant levels stipulated in the
Wastewater Disposal Permit. The analytical results for water samples collected from these tanks are presented in Table 1, and the analytical reports are in Appendix 1. Approximately 63,000 bbls and 20,000 bbls of water were stored in Tank 813 and Tank 806, respectively.
The contaminated water stored in these two tanks was shipped offsite for treatment. A fuel tanker under contractto DFSC docked at Whittier after delivering fuel at other Alaskan points and took the water on as ballast water. Prior to arrival, the water in Tank 806 was transferred into Tank 813. The final volume of approximately 83,000 bbls of contaminated water was transferred from Tank 813 to the tanker from 5 November to 8 November, 1995. The tanker left Whittier for the west coast on 8 November, 1995. The water was off-loaded at DFSP Manchester and DFSP San Diego and treated in the ballast water treatment plants at those locations.
WASTEWATER DISPOSAL
Water stored in the 813 containment area, and in Tanks 804 and 808, was suitable for discharge
under the conditions of the Wastewater Disposal Permit. Analytical results of samples collected from these tanks are presented in Table 2, and the analytical reports can be found in Appendix 2. Discharge limits in the Permit are the State of Alaska Clean Water Standards (18 A.A.C. 70.020). Under the permit conditions, water was discharged from the storage units until discharge of petroleum sheen was imminent, sheen was observed in the discharged water, or a sample from discharged water contained contaminant concentrations above permit limits. GSI had an observer onsite during all discharge events.
The observer monitored, at regular intervals, the discharged water for sheen and collected a sample from the discharged water daily. The water sample was sent to an Anchorage analytical laboratory as soon as possible and analyzed on an overnight rush basis. Preliminary water
sample results were faxed to the designated, responsible GSI individual at work or at home. Final results followed by fax as soon as they were available. No discharge samples had concentrations of any contaminants that were at, or above, the permitted concentrations.
Following modification of the dike-drain inlet to prevent sheen or product discharge, a pilot discharge event for the 813 containment water occurred on 20 September. Discharge of water from the 813 containment area began on 22 September, 1995, and continued through 24 September. A second, one day, event took place on 27 September. The last discharge from the 813 containment area took place from 25 October through 26 October, 1995. The wastewater was discharged from Tank 804 in one event from 26 September through 30 September. Water was discharged from Tank 808 in two separate one day events on 18 October and 25 October, 1995. Water in the 813 containment area was discharged until sheen break-through was judged to be imminent, at which time discharge was terminated and the containment area was allowed to collect further precipitation. Due to the amount of precipitation in Whittier, there have been repeated discharge events from the 813 containment area. The last discharge event occurred from 25 October to 26 October, 1995, just prior to winter "freeze up."
Currently, there is roughly 15,000 gallons (approximately 360 bbls) of wastewater frozen in the bottom of the 813 containment area. The water covers roughly half of the bottom of the western halfof the containment area in the vicinity of the dike drain. The dike drain is closed. No further discharge is planned during the winter months. After spring breakup, periodic discharge of wastewater will be necessary due to continuing precipitation and will be performed under the existing Wastewater Disposal Permit. Current procedures for monitoring and sampling the discharged water will be followed unless different procedures have been submitted to ADEC and approval of those procedues has been received.
For additional information see site file. |
Jeff Ginalias |
| 1/19/1996 |
Site Ranked Using the AHRM |
Initial ranking. |
Jeff Ginalias |
| 4/4/1996 |
Document, Report, or Work plan Review - other |
ADEC SPAR Tanks and Tank Farms Section sent DLA EQ Division a comment letter RE: intended closures of DFSC bulk fuel storage facilities at Anchorage and Whittier.
Your letter also requests that the Department waive the requirements of 18 AAC 75.005 -- 18 AAC 75.090 for a few months beyond the January 1, 1997 deadline for the Whittier facility in order to facilitate complete deactivation of the tanks. Subsequent to your request for a waiver the Department has learned from DFSC staff in Anchorage that defueling of the Whittier terminal will begin in the first week of April and is expected to be completed by the end of August. The waiver was intended as cushion in the event there was a disruption of the train schedule and deactivation of the facility could not be accomplished before January 1, 1997.
In accordance with 18 AAC 75.015(c) the Department may waive a requirement of 18 AAC 75.005 -- 18 AAC 75.090 provided an equivalent level of protection is provided. However, DFSC letter has requested additional time to defuel the facility, and has not proposed any equivalent level of protection. Therefore a waiver could not be granted at this time.
In the event it is not possible to deactivate the DFSC Whittier facility before January 1, 1997 under the provisions of 18 AAC 75.015(b) DFSC may request approval for an Alternate Compliance Schedule (ACS) for meeting the requirements of the referenced regulations.
Be advised, once deactivated the facilities will have to meet the requirements of a new installation in the event of any reactivation effort. Additionally, ownership of the DFSC plans for these facilities cannot be transferred once deactivated. Furthermore, it will be necessary to subject any application for a plan approval for these facilities to the Alaska Coastal Management Program (ACMP) review process. Signed Ted Moore for Larry Katkin, Manager, Terminals and Tank Farms. |
Louis Howard |
| 8/12/1996 |
Update or Other Action |
ADEC letter to DFSC DFSP Alexandria VA Fac ID# 817 Tank ID# 803 804 RE: Requirement to close an UST that has been temporarily out of service for more than 12 months. Based on the information DFSC provided, the ADEC has determined the subject tank(s) is hereby: Not Regulated. We determined based on the information DFSC provided, the subject tank(s) was incorrectly registered in our UST database, and is therefore not subject to 18 AAC 78 UST regulations. |
Cindy Thomas |
| 8/19/1996 |
Update or Other Action |
Letter from DLA DFSC Ft. Belvoir VA to UST Program D. Allen. The DFSC is submitting the updated notification forms and diskette for USTs located at DFSP Anchorage and Whittier. The DFSP Whittier Terminal Tanks 900A, 900B, 901, 904 are required to be registered. All other tanks listed for the facility are either: spill containment tanks, process flow through tanks, ASTs or field constructed cut and cover bulk storage tanks. All are deferred/exempt from registration requirements. For your information, DFSC will be closing both terminals later this year. Certified UST contractors will be directed to complete closure action on these facilities if required. |
David Allen |
| 9/25/1996 |
Site Ranked Using the AHRM |
Site reranked. Toxicity Value changed from 2 to 3; Quantity Value changed from 2.1 to 2; GW Usage Value changed from 0.1 to 0.4; and GW Exposure Index Value changed from 0.4 to 1. |
Scott Pexton |
| 9/25/1996 |
Update or Other Action |
Received draft Remedial Pilot Testing workplan. |
Scott Pexton |
| 9/26/1996 |
Update or Other Action |
Dave Allen received updated notification forms from DLA DFSC W.E. Goode. The DFSP Whittier facility has tanks 900A, 900B, 901 and 904 which require registration. All other tanks are either: spill containment tanks, process flow through tanks, aboveground tanks or field constructed cut and cover bulk storage tanks. All are deferred from registration requirements.
For your information DFSC will be closing out Whittier terminal this year. Certified UST contractors will be directed to complete closure action on these facilities if required. DFSP Whittier may be leased to a commercial company by the Army, thus, tank closure may not be necessary. |
David Allen |
| 11/1/1996 |
Update or Other Action |
When fully operational prior to its November 1, 1996 closing, the 85 acre DFSP-W site was fenced on all sides apparently with secure access through a gated entrance. At the time of closure, the facility included 26 fuel storage tanks, a railroad loading rack, access roads and support buildings. Five buildings were present at the site:
• Office/shop (Building 17-302)
• Manifold Building (Building 17-303)
• Water Pumphouse (Building 17-304)
• Pumphouse Building (Building 17-305) and
• Guard Shack |
Louis Howard |
| 11/5/1996 |
Document, Report, or Work plan Review - other |
Letter sent with comments on draft workplan. |
Scott Pexton |
| 6/16/1997 |
Update or Other Action |
Received Site Characterization and Remedial Pilot Testing Report, prepared by Groundwater Technology Government Services, Inc. PCE (tetrachloroethylene) was found in soil from MW-54, MW-60, MW-62, MW-64 and BH-23 with estimated values up to 2.0 mg/kg PCE (NOTE-migration to groundwater cleanup level is 24 ug/kg or 0.024 mg/kg, direct contact 13 mg/kg and 7.3 mg/kg for outdoor inhalation Over 40 Inch Zone is applicable since Whittier receives on average 190 inches of precipitation per year).
Sampling for PCBs was conducted and no PCBs were found at the historic location of UST 801 where PCBs were report at 1.3 mg/kg.
In 1997, GSI conducted a comprehensive site characterization that provided follow-up to results of the Tank 813 RI. As part of the full characterization, a GORE-SORBERSM Soil Gas Survey (SGS) was conducted in 1996. The study measured volatile compounds in shallow soil gas at 202 monitoring points installed to a depth of 2 feet below ground surface (bgs). The results of the screening indicated possible contamination in the following locations:
• Gasoline, jet fuel, and chlorinated contamination near the train loading racks.
• Jet fuel and possible gasoline contamination near the main buildings and to the
east.
• Chlorinated compounds near the office/shop, pumphouse, and truck rack.
• Chlorinated compounds near Tanks 805 and 806.
• A diesel-range anomaly near Tank 813.
• The MUM gasoline release near MW-12.
• Possible jet fuel contamination near Tanks 801-810 and east of Tank 809.
four tanks (Tanks 801 through 803 and Tank 805) were restored in the early 1990s. Gasoline range organics (GRO)-, diesel range organics (DRO)-, and benzene, toluene, ethylbenzene and xylenes (BTEX)- contaminated soil with maximum concentrations of 520 milligrams per kilogram (mg/kg), 5,900 mg/kg, and 7.3 mg/kg respectively was removed and transported offsite for treatment. GRO 260 mg/kg migration to groundwater cleanup level, DRO 230 mg/kg migration to groundwater cleanup level for Over 40 Inch Zone. However, it was noted that contaminated soil (as evidenced by high photo ionization detector (PID) readings) remained beneath the new foundations of Tanks 801 and 802. GSI noted that it is assumed that the remaining tanks (Tank 804 and Tanks 806 through 808), whose planned restoration was canceled due to site closure, were likely to have similar contaminant levels.
In the area of a recently ruptured pipeline, approximately 1,218 gallons of MUM gasoline was released. The rupture occurred in 1991 during the drilling of MW-12 (located southeast of the loading racks). Six monitoring wells were subsequently drilled to delineate the extent of the resultant plume. Both BTEX and PCE were found downgradient of this plume. Chlorinated solvents, specifically PCE, are present at spotty locations and with a maximum concentration of 0.895 mg/kg at the site. GSI had concluded that the concentrations detected do not pose a threat to human health or the environment. |
Scott Pexton |
| 8/28/1997 |
Update or Other Action |
Letter from ADEC to DFSC RE: Department Review of 1997 Site Characterization and Remedial Pilot Testing Report, Defense Fuel Support Point, Whittier Alaska (Database Record Key No. 95-21-01-058-02). On June 16, 1997, the 1997 Site Characterization and Remedial Pilot Testing Report for
the Defense Fuel Support Point in Whittier Alaska was received in this office.
Groundwater Technology Govennnent Services (GSI) performed a site environmental investigation between October 1996 and January 1997.
Alaska Department of Environmental Conservation (ADEC) Contaminated Sites Remediation Program has completed review of the report and provides the following comments. Please provide written responses to me on or before September 30, 1997.
Page iii Executive Summary
When will the integrity testing of the pipe to Tank 813 be conducted? ADEC requests a report that describes the testing performed and summarizes the test results.
Page iii Executive Summary
Prior to submittal of a risk assessment work plan, a conceptual site model must be developed and approved for the site .. This will help to define potential exposure points and pathways of contaminant migration. When will a conceptual site model be submitted to the ADEC Contaminated Sites Remediation Program for review and approval? Also, when do you anticipate submitting the risk assessment work plan?
Page 3 Site History
Text indicates that privately owned homesteads exist south of the railroad portal. Please depict the homestead parcels on a figure that shows their position in relation to the site.
Page 33 Sample Analyses
Text indicates that all groundwater samples were analyzed for BTEX by EPA Method 602 and for PAHs by EPA Method 610, but does not mention groundwater analysis for halogenated compounds.. How many groundwater samples were analyzed for halogenated volatile compounds such as tetrachloroethylene? If analyzed, what analytical methods were used to analyze groundwater samples for halogenated compounds?
Page 44 Liquid-phase Petroleum
a.) Please provide a summary table that lists each well that has had a past detection of liquid-phase petroleum, the date(s) of detection, and the product thickness levels detected.
b.) Describe the methods that were used to measure the separate-phase liquid discovered in the wells.
Page 63 Bioremediation Bench Test
Describe the bioremediation bench tests to be conducted and identify when the test results will be submitted to the ADEC project manager.
Page 66 Conclusions
It is stated that PCE has never been detected in groundwater at the site. However, it is unclear how many groundwater samples were analyzed for PCE during the scope of this investigation.
Figures
Please provide a figure that delineates the extent of known or suspected liquid-phase petroleum product at the site. |
Scott Pexton |
| 9/30/1997 |
Update or Other Action |
Fluor Daniel GTI sent ADEC (S. Pexton) a response to comments letter RE: Department Review of 1997 Site Characterization and Remedial Pilot Testing Report, Defense Fuels Supply Point, Whittier, Alaska Database Record Key No. 95-21-01-058-02.
The integrity testing of the pipe to Tank 813 will be performed in the fall of 1997. A copy of the test results will be provided to ADEC.
The following is a tentative schedule for the initial stages of the Risk Assessment for DFSP
Whittier:
Risk Assessment Scoping Meeting 10/16/97
Submit Conceptual Site Models (CSMs) 10/31/97
Receive ADEC comments on CSMs 11/14/97
Submit final CSMs 12/05/97
Receive ADEC approval of CSMs 12/12/97
Submit Risk Assessment Work Plan (RAWP) 01/09/98
Receive ADEC Comments on RAWP 02/20/98
Submit response to ADEC RAWP comments 03/09/98
Comment resolution meeting 03/17/98
Submit final RAWP 03/30/98
ADEC approval of RAWP 04/13/98
Submit Human Health & Ecological Risk Assessment (RA) 04/20/98*
Receive ADEC comments on RA 06/15/97
Submit response to ADEC Comments 06/29/98
Comment resolution meeting 07/06/98
Submit final RA 07/24/98
ADEC approves final RA 08/14/98
*Note: This assumes that the data already collected will be sufficient for RA preparation.
We do not have any additional information on the old homesteads. Figure 1, included with this response to comments, shows the current land status in the area south of the railroad portal, and the former location of the homesteads.
The December 1996 quarterly groundwater sampling event was reported in the Site Characterization Report and did not include sampling for halogenated volatile organic compounds (HVOC). HVOC analysis of groundwater samples began with the January 1997 monthly sampling and has been included in all monthly and quarterly groundwater sampling since that time. The HVOC analysis is performed using by EPA Method 601.
See site file for additional information.
|
Scott Pexton |
| 10/9/1997 |
Site Ranked Using the AHRM |
Site reranked by staff. Changed Quantity Value from 2.1 to 3; and Air Exposure Index Value from 0.1 to 0.2. Former score was 26. |
Scott Pexton |
| 12/2/1997 |
Conceptual Site Model Submitted |
Department Review of 1997 Preliminary Conceptual Site Model, Defense Fuel Support Point, Whittier Alaska (Database Record Key No. 95-21-01-058-02) letter sent to DFSC R. Banez.
On November 7, 1997, the 1997 Preliminary Conceptual Site Model for the Defense Fuel Support Point in Whittier Alaska was received in this office. The Alaska Department of Environmental Conservation (ADEC) Contaminated Sites Remediation Program has completed review of the model and provides the following comments. Please revise the conceptual site model to address the following comments and resubmit it to me for approval.
1. Please note that the risk assessment and the conceptual site models must address the entire site including the known plumes of petroleum contaminated groundwater and any facility related contamination in soil or other media that extends beyond the facility boundaries.
2. Delete the following boxes from the "Sources" category: Former Shooting Range, Alaska Railroad, Landfill, Former Lumbar Yard, and Airstrip. These potential sources were not investigated as part of the site characterization and should not be included in the Conceptual Site Model. Delete the "surface dispersion" primary release mechanism.
3. Add two more bOfCeS to the Secondary Release Mechanism category: one box or "Erosion/Runoff" and one box for "Excavation/Redistribution." Erosion/runoff may lead to impacts to surface water and sediment. Excavation/redistribution may lead to subsurface soil being redistributed as surface soil.
4. As there are no restrictions on groundwater use within or downgradient of the facility, change the groundwater ingestion exposure route to indicate a complete pathway exists for all future potential human receptors. This pathway should be further evaluated to determine if risk exists if groundwater from the site is ingested in the future. While a potential exists for saltwater intrusion to limit groundwater use in some areas downgradient of the facility boundary, it does not appear that saltwater intrusion is a factor within or near the facility boundary.
5. Add ingestion and direct contact as exposure routes for surface soil. Indicate as complete
the ingestion and dermal contact pathways to current and future on-site workers, construction workers, and trespasser/visitors. Note that according to the work plan for assessment of the site dated September 5, 1996 (page 34), "surface soil/sediment sampling and laboratory analysis has confIrmed that there are four distinct surface areas that were impacted at levels exceeding regulatory cleanup standards for soil at the time of their discovery." These areas (and any additional areas where surface contamination is identified) should be further evaluated in the risk assessment work plan to screen potential contaminants of concern/exposure routes.
6. Add a subsistence human receptor column and evaluate whether or not current or future complete exposure pathways exist.
7. A separate conceptual site model should be developed and submitted for ecological receptors. It should have a format similar to this model, but should include representations for terrestrial, freshwater, and marine receptors. Expand the potential ecological receptors category to identify specific types of terrestrial and aquatic receptors that could be exposed to site-related contaminants. Identify fish, birds, mammals, plants, aquatic organisms, etc.
and whether or not exposure pathways are complete for specific exposure routes. |
Scott Pexton |
| 3/23/1998 |
Document, Report, or Work plan Review - other |
ADEC sent comment letter to DESC RE: Risk Assessment Work Plan.
The Alaska Department of Environmental Conservation (ADEC), Contaminated Sites Remediation Program received a copy of the Risk Assessment Work Plan for the Defense Fuel Support Point in Whittier Alaska on January 26, 1998. ADEC review of the plan is complete and the following comments are provided. Please provide written comment responses to me on or before May 1, 1998.
Page ii Executive Summary
In addition to data presented in the 1997 "Site. Characterization and Remedial Pilot Testing Report", groundwater monitoring data from quarterly monitoring activities from January 1996 through December 1997 should be evaluated in the risk assessment report.
Page 1 Purposes and Objectives
Revise this section to state that one of the main objectives of the risk assessment process is to develop site-specific alternative cleanup levels for contaminated soil and groundwater.
Page 1 Scope of the Risk Assessment
Data collected during quarterly groundwater monitoring activities from January 1996 through December 1997 should be evaluated in the risk assessment report. This data should be used to develop reasonable maxYmum exposure estimates for the groundwater ingestion pathway.
Page 6 Chemicals in Groundwater
Total Aqueous Hydrocarbons and Total aromatic hydrocarbons are not MCLs; they are water quality standards under 18 AAC 70. MCLs are identified in the Drinking Water regulations under 18 AAC 80.
Page 7 Conceptual Site Model(CSM)
Potential risks to aquatic receptors, outside of the facility boundary, must be evaluated regardless of the presence or absence of risk to ecological receptors within the facility boundaries.
Page 7 Human Health Conceptual Site Model
Outside of the facility boundary, groundwater exposure may occur if adjacent land holders drill water supply wells within or near plume boundaries. 'Therefore, in addition to inhalation of volatile emissions and dermal contact with groundwater, ingestion of groundwater must be quantitatively evaluated within the known plumes outside of the facility boundaries.
The use of fate and transport models to predict possible migration of chemicals from the site to surface water bodies may be employed. However, confIrmation samples may be needed to verify the modeling results.
See site file for additional information.
|
Scott Pexton |
| 4/24/1998 |
Risk Assessment Workplan Approved |
Approval of Risk Assessment Work Plan, Defense Fuel Support Point, Whittier Alaska (Database Record Key No. 95-21-01-058-02). On April 3, 1998, the Alaska Department of Environmental Conservation (ADEC), Contaminated Sites Remediation Program received the Risk Assessment Work Plan for the Defense Fuel Support Point in Whittier Alaska. This submittal modified text from the January 23, 1998 work plan to address my comments provided in a letter dated March 23, 1998.
I have completed a review of the revised plan and on behalf of the ADEC Contaminated Sites Remediation Program, I approve the April 3, 1998 risk assessment work plan for the Whittier Defense Fuel Support Point. Please submit two copies of the draft risk assessment report to me at the ADEC offices at 555 Cordova Avenue in Anchorage. Additional copies wi11 likely be needed at a later date for distribution to other interested stakeholders. |
Scott Pexton |
| 4/24/1998 |
Update or Other Action |
Baseline Risk Assessment, Defense Fuel Support Point Whittier, Whittier, Alaska, April 24, 1998. An evaluation of contaminants of potential concern (COPC) was conducted by GSI as presented in the Risk Assessment developed for the DFSP-W site. USEPA Level III data evaluation criteria were applied to a comprehensive data set that included soil results from the Tank 813 release investigation, the area-wide site characterization (GSI, 19971), and from two years of quarterly groundwater monitoring.
Contaminants of Potential Concern for soil and groundwater: BTEX, GRO, DRO, HVOC (PCE) and PAHs(only in groundwater). PAH compounds have been detected in soil from the site at concentrations below risk-based screening levels. Lead detected at concentrations above ADEC cleanup levels in groundwater (Tank 813 Plume) was determined to be due to suspended solids. HVOCs in groundwater were identified in the risk assessment as a COPC due to sample quantitation limits being more than half the ADEC screening level although no PCE was detected in groundwater prior to 2010. Analysis of VOCs during groundwater sampling in September 2010 showed PCE above ADEC cleanup level in groundwater in downgradient wells MW-41 and MW-42.
At one point PCBs were a contaminant of interest due to a detection in soil of 1.3 mg/kg during the excavation of UST 801 (not to be confused with AST 801) near the manifold building 14-305. UST 801 was used for storing various fuels and may have been thought to be a potential source of PCB. However, RW-10 was drilled in the location of the former UST 801 in 1997 and soil samples were non-detect for PCBs. As no other potential sources are thought to exist at the site for PCBs, it is not considered a contaminant of concern.
The human health and ecological risk assessment conducted by GSI was based on a premise that ALL separate-phase (i.e. free product LNAPL) petroleum hydrocarbons will be removed from the site. The cumulative hazard index and cumulative carcinogenic risk for the following potential current and future on-site receptors was evaluated: worker, construction worker, trespasser/recreational user. The evaluation was also conducted for the following potential current and future off-site receptors: resident and construction worker.
Based on results of the risk assessment, cumulative risks for all evaluated receptors were found to be within 1989 USEPA guidelines for acceptable risk (1x10-6 to 1x10-4). In addition, no adverse ecological effects to receptors were identified through the ecological assessment. Alternative cleanup levels were calculated for both on- and off-site soil and groundwater at the site.
GSI established 12 surface water sampling locations providing baseline data for their 1997 Risk Assessment. TAH and TAqH were calculated and found below the ADEC cleanup levels. The risk assessment states that no surface water COPCs pose a risk to human health or to the environment based on evaluation of the individual contaminants.
See site file for additional information.
|
Louis Howard |
| 7/1/1998 |
Update or Other Action |
ADEC (S. Pexton) sent DESC a letter RE: Interim Remediation and Fuel Recovery System, Defense Energy Supply Point, Whittier Alaska, ADEC Reckey 95-21-01-058-02.
I am writing to request a written interim report from your office regarding the performance and effectiveness of the interim fuel recovery system at the Whittier Defense Energy Supply Point. Please provide the report to me on or before August 1, 1998.
Approximately one year ago, the Alaska Department of Environmental Conservation (ADEC) Contaminated Sites Remediation Section received a copy of the operations and maintenance manual prepared by Fluor Daniel GTI on your behalf. The system consists of a vapor extraction system and fuel recovery system connected to seventeen recovery wells through arctic pipe.
The interim report should discuss and evaluate the effectiveness of the remediation system with respect to cleanup of petroleum contaminated soil and·groundwater. Please include the following sections in the report: purpose, system description and history, performance evaluation, conclusions, and recommendations.
The conclusions section of the report should provide estimates of the amount of free product recovered, the amount of hydrocarbons removed, costs of system operation, and optimum performance criteria. The recommendations section should indicate any needed changes to how the system is operated and estimate how long the existing system will be operated to effectively reduce soil and groundwater contaminate levels. |
Scott Pexton |
| 7/22/1998 |
Update or Other Action |
ADEC (S. Pexton) sent John Esada (Lt. Col) DESC a letter. RE: Baseline Risk Assessment report,Defense Fuel Support Point, Whittier Alaska Database Record Key 95-21-01-058-02.
On April 27, 1998, the Alaska Department of Environmental Conservation (ADEC), Contaminated Sites Remediation Program received a Baseline Risk Assessment report for the Defense Fuel Support Point in Whittier Alaska. Your consultant, Groundwater Technology Government Services, Inc, prepared the report.
The facility is a bulk fuel terminal located on the western shore of Passsage Canal in Prince William Sound, approximately 60 miles southeast of Anchorage. The purpose of the risk assessment was to assess human health and ecological risks due to chemical compounds identified in soil, groundwater, sediments and surface water and to propose site-specific alternative cleanup levels for contaminated soil and groundwater.
ADEC has completed a review of the risk assessment report and provides specific comments on the enclosure. ADEC requests that the Defense Energy Supply Center or their contractor provide written responses to all of the comments by August 31, 1998.
Other stakeholders may wish to acquire copies of the risk assessment report.· If requested, please provide copies of the report to other interested parties. After receipt of the comment responses, an attempt will be made to meet with other interested stakeholders to discuss site-related issues.
Because several technical problems were noted, the conclusions of the risk assessment could not be confirmed. Until the assumptions and references are provided, the risk estimates cannot be verified.
Consistent with guidance, the authors include chemicals with an sample quantitation limit (SQL) higher than a risk-based value in the risk assessment. Many of The risks are driven by these compounds, most of which are not typically associated with petroleum sites (i.e., chlorinated compounds and nitrosoamines). Therefore, it is recommended highly that a discussion be included in the uncertainty section to outline the risks if these compounds were not included.
2.0
The assumption that the facility will remain an industrial area by issuance of a deed restriction is noted. However, the current land owner will need to be consulted and the
Department of Defense must be capable of enforcing this land use control, particularly if the land ownership changes. Additional description of current land use off site is needed. For example, do recreational users currently visit the site or surrounding areas?
3.1
Chemicals identified as common laboratory contaminants should not be excluded from the risk assessment unless they are present at concentrations less than 10 times the concentration in the associated blank. Excluding these compounds without making this comparison could result in an underestimation of site risks.
3.3
All values used as screening levels should be discussed thoroughly and documented. Sources such as the AQUIRE database and United States Fish and Wildlife Service Contaminant Hazard Reviews present toxicity data rather than screening levels. Uncertainty factors should be applied to these toxicity data to derive no observed adverse effect levels.
4.1.1.1
The reference to a deed restriction prohibiting land use other than industrial activities is noted. However, does the DESC have the authority to implement land use controls on future property owners? Would a deed restriction limit access to groundwater to use for drinking water or other beneficial uses? Also, how were future exposures to subsurface soil that is transferred to the surface considered? Surface and subsurface soil concentrations should have been combined for future on-site receptors. It is unclear whether this was done. |
Scott Pexton |
| 11/30/1998 |
Update or Other Action |
Letter from DLA DEO-Alaska to STP David Allen. Re: Change of ownership for USTs at DFSPs Fairbanks, Whittier, and Anchorage. The Defense Energy Support Center (DESC) request a change of Ownership for the USTs listed in the UST database under DESC be transferred to the US Army Ft. Richardson, Dept. of Public Works, Real Property. The Defense Fuel Support Points (DFSPs) Fairbanks, Whittier, and Anchorage are owned by the U.S. Army and were operated by DESC until their closures in 1993, 1994 and 1995 respectively. As explained in our meeting on October 23, 1998, DESC no longer operates these DFSPs. Also that the U.S. Army is the owner of the DFSP's real estate, facilities, ASTs and USTs. Mr. Thorson also received from ADEC a Notification of Change of Ownership Form to be signed by the owner, U.S. Army and returned to you. This signed form, as agreed upon by all parties in attendance, would have rightfully transferred ownership of the mentioned USTs to the U.S. Army. |
David Allen |
| 12/18/1998 |
Interim Removal Action Approved |
Letter sent to DEO-Alaska RE: ADEC Approval of Amended Interim Corrective Action Plan, Tank 813 Ballast Material Defense Fuel Supply Point, Whittier Alaska ADEC Database Record Key 95-21-01-058-02.
On December 2, 1998, the Alaska Department of Environmental Conservation (ADEC), Contaminated Sites Remediation Program received a letter requesting an amendment to the October 12, 1998 Tank 813 Interim Corrective Action Plan. The amendment reflects your preference to use a thermal desorption technology to treat petroleum contaminated soil excavated from the Tank 813 containment area. The original plan proposed the use of a bioremediation technology.
On behalf of the ADEC Contaminated Sites Remediation Program, I approve the amended Interim Corrective Action Plan for the Tank 813-ballast material. This amended Interim Corrective Action Plan will be considered an interim removal action as described in the draft 18 AAC 75 regulations.
Please send copies to me of the laboratory analytical results of all soil samples collected beneath the containment liner within thirty days of your receipt of this letter. Within sixty days after completion of the thermal treatment of excavated soil and prior to disposal, please submit a corrective action report to me that includes copies of the laboratory analytical results of all confIrmation soil samples.
Additional soil and groundwater cleanup options will be further evaluated for remaining contaminated soil and groundwater near Tank 813 and at other areas of the site after the completion of the site baseline risk assessment report. |
Scott Pexton |
| 1/13/1999 |
Update or Other Action |
US Army letter to Tim Stevens (ADEC) re: USTs at Whittier Fuel Terminal Facility ID number 817. USARAK recently assumed operation of the Whittier Fuel Terminal in Whittier back from Defense Energy Office-Alaska (DEOA). There are five (5) USTs associated with this facility. ADEC Tank Numbers 1, 2, 3, 5, and 8.
Per conversation with Jack Appolloni of DEOA, these tanks are currently empty. However, USARAK cannot complete the "Empty Tank Affidavit" required by ADEC, as no USARAK employee has personal knowledge of how and when these tanks were emptied, as is required by the affidavit. Attached is a "Notification of Taken Out-Of-Service" for the USTs identified above, while USARAK pursues completion of the affidavit by DEOA. Pending receipt of this affidavit, USARAK will consider these tanks temporarily closed.
USARAK is currently pursuing disposition of the Whittier Fuel Terminal as excess to US Army requirements. The final disposition of the Whittier Fuel Terminal USTs will depend on requirements of the GSA which will determine the requisite condition of the property prior to GSA's acceptance. |
Tim Stevens |
| 3/3/1999 |
Interim Removal Action Approved |
Letter sent to Jack Appoloni (DEO-Alaska) RE: ADEC Approval of Interim Corrective Action Plan, Steam Sparging Combined with Air Sparging and Vapor Extraction Defense Fuel Supply Point, Whittier Alaska ADEC Database Record Key 95-21-01-058-02.
The Alaska Department of Environmental Conservation (ADEC), Contaminated Sites Remediation Program has completed a review of an Interim Corrective Action Plan, dated October 1, 1998, that proposes remedial actions at the Whittier Tank Farm site. The proposed remedial system's overall strategy is to inject steam under the water table to elevate groundwater temperatures within the treatment area and to use existing soil vapor extraction wells to remove volatized contaminants. Air sparging combined with soil vapor extraction is proposed outside of the fenced facility area.
After the interim plan was originally submitted to the ADEC, the Defense Energy Supply Center had their contractor perform additional pilot tests of the proposed remediation system. On February 12, 1999, the ADEC Contaminated Sites Remediation Program received a report entitled "Vapor Extraction and Air Sparging Pilot Test Report". The report is dated February 10, 1999. The report indicates that pilot testing results were favorable and confirms that the proposed remediation technology is viable under site-specific conditions in Whittier.
The Department considers the October 1, 1998-Interim Corrective Action to be an interim removal action in accordance with 18 AAC 75.330. Based on the information provided in the submitted plan and the subsequent pilot test results, it appears that execution of the interim plan will significantly contribute to the overall long-term cleanup goals at the site. Therefore, on behalf of the ADEC Contaminated Sites Remediation Program, I approve the October 1, 1998 Interim Corrective Action Plan for the Defense Fuel Supply Point in Whittier Alaska. Please send me a schedule for implementing the interim corrective action by April 2, 1999. |
Scott Pexton |
| 4/6/1999 |
Update or Other Action |
ADEC Letter granted closure on 4/6/99, for tank site near Bldg 17-302. |
Louis Howard |
| 4/26/1999 |
Update or Other Action |
Letter sent to DEO-Alaska. On behalf or the Alaska Department of Environmental Conservation (ADEC), Contaminated Sites Remediation Program, I request that you initiate formation of a
Restoration Advisory Board for the Defense Fuels Supply Point at the Whittier Alaska facility. We believe that the formal creation of a Restoration Advisory Board (RAB) will foster better communications between the agencies, interested parties, and the public regarding environmental cleanup activities at the Defense Fuel Support Point-Whittier facility. DEC staff have participated on RABs at other facilities and have found them to be good venues to share information, express concerns, and develop workable solutions to various environmental problems and land use issues.
DEC asks that you coordinate with the Department of the Army, the Bureau of Land Management, the State of Alaska, the City of Whittier, and other interested parties to cooperatively solicit membership to form a RAB. We believe the creation of a RAB is in the best interest of the community, and look forward to assisting you with coordination of future RAB issues. |
Scott Pexton |
| 6/24/1999 |
Document, Report, or Work plan Review - other |
Staff sent letter to DEO-Alaska re: Groundwater Monitoring Program Whittier Defense Fuel Supply Point, ADEC Database Record Key 95-21-01-058-02.
I'm writing to request that you revise the current groundwater-monitoring program at the
Whittier Defense Fuel Support Point site. On behalf of the Alaska Department of
Environmental Conservation (ADEC), Contaminated Sites Remediation Program, I have reviewed several quarterly groundwater monitoring reports and other information provided on your behalf by your contractor. Based on the information provided, changes to the current groundwater monitoring strategy are warranted regarding the wells to be sampled, the sampling frequency, and the laboratory analysis requirements.
On or before August 15, 1999, please submit a new Whittier Support Point groundwater monitoring plan to me for ADEC review and approval. If necessary, we can meet to discuss the monitoring plan before it is formally submitted. The following changes will likely reduce the current sampling costs, but still provide adequate monitoring information to the ADEC Contaminated Sites Remediation Program. Some of the changes are necessary to comply with sampling and analysis requirements under 18 AAC 75.
Due to the well location and lack of detection of petroleum-related contamination, you may discontinue monitoring of the following list of wells. Further monitoring of these wells does not appear to be needed to protect human health or the environment. These wells should be decommissioned in accordance with the ADEC guidance Recommended Practices for Monitoring Well Design, Installation, and Decommissioning, April 1992.
Monitoring Wells to be Decommissioned
MW-02, MW-03, MW-47, MW-48, MW-73, MW-81, MW-82
Sample the following list of wells on a quarterly basis (four times yearly).
Well Identification analyses for GRO, DRO, BTEX for all wells and PAH as indicated (PAH)
MW-04 PAH, MW-05, MW-06, MW-07, MW-14, MW-15, MW-20, MW-31, MW-33, MW-34, MW-44, MW-50, MW-51 PAH, MW-55, MW-56, MW-57, MW-63, MW-65 PAH, MW-66, MW-67, MW-68, MW-69, MW-72, MW-75, MW-76, MW-78 PAH, MW-79 PAH, RW-01, RW-02, RW-03, RW-05, RW-06, RW-09, RW-14
RW-16
Sample the following list of wells on a semi-annual basis (twice yearly).
Well Identification all analyzed for GRO, DRO, BTEX
MW-05, MW-lO, MW-ll, MW-22, MW-23, MW-30, MW-32, MW-35, MW-37, MW-38, MW-39, MW-40, MW-42, MW-43
MW-45, MW-46, MW-49, MW-54, MW-59, MW-61, MW-71, MW-74, MW-77, MW-80
Sample surface water at the following locations on a quarterly basis (four times yearly).
SW Location Identification all analyzed for TAH and TAqH
SW-07, SW-08, SW-09, SW-10 |
Scott Pexton |
| 7/23/1999 |
Update or Other Action |
Email notification to rescind ADEC approval of the 3/3/99 interim action due to the number of changes required for the new system. Requested submittal of a new Interim Action work plan for the steam and air sparging/vapor extraction system. |
Scott Pexton |
| 9/15/1999 |
Update or Other Action |
Received Interim Corrective Action Plan for steam and air sparging system/fuel and vapor recovery system. |
Scott Pexton |
| 9/16/1999 |
Update or Other Action |
Letter from ARMY to Tim Stevens (ADEC) re request for waiver of 15 day notification period for removal of USTs at Whittier Fuel terminal Fac. ID 817. US Army Alaska intends to remove three temporarily closed USTs from the Whittier facility between September 11 and September 15, and requests a waiver of the usual 15 day notification period. The removal was originally planned for late September but is occurring earlier due to changes with the Whittier rail shuttle schedule. The tanks to be removed are ADEC tank ID numbers 1, 5, and 8. In January 1999, ADEC received notification from USARAK of their intent to take five tanks out of service. However, records research and an on site visit by USARAK and Defense Energy Support Center-Anchorage personnel revealed that two of the five tanks (ADEC Tank ID Numbers 2 and 3) were removed in 1991, leaving three tanks to be removed. |
Tim Stevens |
| 9/17/1999 |
Update or Other Action |
Corrective Action Report DFSP Whittier, Tank 813 Ballast Material, September 17, 1999. Report details onsite remediation by thermal desorption of 5,510 tons of contaminated “ballast” from within the Tank 813 containment area. The material was impacted in February 1995 due to a 100,000 gallon spill of jet fuel (JP-5) from Tank 813. The successfully treated material had been excavated from above the containment area liner.
Subsequent testing from beneath the liner detected DRO impacted soil with concentrations ranging from 6 to 7,370 mg/kg. It is unclear, but appears that the material located under the liner was not part of the remediation.
|
Scott Pexton |
| 10/6/1999 |
Document, Report, or Work plan Review - other |
Provided comments via Email on the Interim Corrective Action Plan. |
Scott Pexton |
| 10/12/1999 |
Site Ranked Using the AHRM |
Site reranked based on 1997 Site Characterization Report and 1998 quarterly monitoring reports. |
Scott Pexton |
| 11/4/1999 |
Meeting or Teleconference Held |
T. Stevens met with Scott Pexton, Kevin Gardner, Jack Appolloni and Steve Teller to discuss the regulated underground storage tank (UST) at the Whittier Defense Fuel Terminal.
Tank 801A, replaced tank 801 which was closed in 1991.
Tank 802A, replaced tank 802, which was closed in 1991 along with tank 801.
Bldg. 305, North and South Tanks. Both USTs are located inside Building 305 (Pumphouse). Tanks are embedded in concrete and are thought to be either 1,000 or 500 gallons in capacity. Gardner to register the USTs. Tanks may be filled with an inert foam, if so tanks to be considered taken out of service (TOS) until the building is demolished or a reused for a different use. At which time would be removed as an unregulated tanks.
Other option is to fill tanks with sand and do a permanent closure. Gardner to make that decision (soon). Soil beneath tanks are currently being addressed through corrective action as part of a larger site under Contaminated Sites oversight, therefore no confirmation samples to be taken.
DeLong Dock Tanks 1 and 2. Gardner to determine if the tanks exist and register tanks if regulated. Tanks 803 and 804. Appolloni to determine if tanks were USTs or ASTs. If USTs, then reregister tanks. |
Tim Stevens |
| 2/7/2000 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation, Contaminated Sites Remediation
Program (ADEC) received a copy of a draft monitoring plan for the Whittier Tank Farm site
on January 19, 2000. ADEC makes the following comments for your consideration when
preparing the final plan.
Change the title to "Groundwater Monitoring Plan". Here and throughout the report, all references to the "Compliance Monitoring Plan" or "CMP" should be changed to "Groundwater Monitoring Plan" or "GMP".
Page ii Executive Summary
-In the fifth paragraph, delete the phrase in the second sentence that says "for which this is the selected remedial method."
- In the sixth paragraph, change the third sentence which says: "a well will have achieved the applicable cleanup goal when monitoring shows that the well has met the cleanup goals for two consecutive years" to "ADEC will evaluate the monitoring program yearly in accordance with 18 AAC 75.345 (h)."
Page 1 1.0 Introduction
• Change the wording from "2) final compliance with" to "2) groundwater concentrations of chemicals as compared to"
• Here and throughout the document, change the term "cleanup standards" to "cleanup levels" to be consistent with regulatory terms at 18 AAC 7S.
Page 3 2.0 Objectives and Scope
• Delete the bullet on site compliarlce and closure. These issues can be addressed in a proposed plan and finalized in a site cleanup plan.
• Do not refer to samples as compliance samples at this time. They are monitoring or performance samples.
Page 4 3.0 Performance Well Selection
Modify this section ofthe report to add the following monitoring wells, as discussed in our meeting of January 27, 2000. Other monitoring wells may be added at this time at the discretion of the DESC project manager.
Tank 813 Plume (Semi-annual sampling)
MW-03, MW-O5, RW-Ol (free product), RW-02 (free product), RW-03 (free product), RW-O5 (free product), RW-06 (free product)
Tank 808 Plume (Semi-annual Sampling)
MW-20
MOGAS & Rail Rack Plume (Semi-annual Sampling)
MW-10, MW-ll, MW-23, MW-30,MW-71
Pump Building Plume (Quarterly Sampling)
MW-07, MW-S6, MW-S7, MW-67, MW-69, VE-23
Pages 9 and 10 3.7 Groundwater Compliance and 3.8 Site Compliance
Delete these sections from this plan. These issues can be addressed later in a Proposed Plan or a site cleanup work plan.
Page 12 4.2.1 Gauging and Field Monitoring
Revise the plan to state that the ADEC project manager will be notified by Email, telephone, or fax within 24 hours of all monitoring wells that have a detection of petroleum hydrocarbon product thickness greater than 0.1 feet.
Page 14 5.1 Water Analytical Methods
Correct the typographical error regarding Alaska Method 101
Page 15 6.0 Reporting
Add bullets to include the following items:
• Tables to indicate water level elevations that the time of sampling
• Tables to list the free product thickness found in each well, if encountered in any wells. |
Scott Pexton |
| 3/7/2000 |
Interim Removal Action Approved |
Letter sent with approval of October 1999 interim corrective action plan to combine a steam and air sparging with soil vapor extraction to reduce the mass of hydrocarbons in the contaminated plume area near Building 17-303 and Building 17-305.
The Alaska Department of Environmental Conservation (DEC), Contaminated Sites Remediation Program has completed a review of an Interim Corrective Action Plan, dated October 25, 1999. Groundwater Technology, Inc prepared the plan, which proposes interim cleanup actions at the Whittier Tank Farm site. The proposed interim system will inject steam into the aquifer to raise groundwater temperatures within the trc;atment area and will remove volatile compounds using soil vapor extraction wells. Air sparging combined with soil vapor extraction is proposed outside of the fenced facility area.
Based on the information provided, DEC has determined that the interim corrective action will provicie for a partial cleanup of the site by significantly reducing the mass of petroleum compounds. Therefore, DEC approves the plan in accordance with 18 AAC 7S.330(c), subject to the following conditions that the Defense Energy Support Center must meet before the startup operation of the interim system:
1. DEC receipt of written notification to permanently close two underground storage tanks (USTs) within Building 17-305 in accordance with 18 AAC 78;
2. DEC receipt of written confirmation that both USTs within Building 17-305 have been drained and inerted by a qualified person in accordance with 18 AAC 78, such that the atmosphere within and around the tanks is confirmed to be nonexplosive;
3. DEC receipt of as-built engineering diagrams of the installed interim corrective action system ,(including the water supply well);
4. DEC approval of a sampling schedule to implement the March 6, 2000 groundwater monitoring plan; and,
5. DEC approval of an interim corrective action plan addendum that details system modifications to recycle wastewater and that provides contingency plans to supply back-up electrical power generation at the site.
It is your responsibility to obtain any permits or authorizations from landowners or land
managers to access any equipment and wells used during all cleanup operations at the site. |
Scott Pexton |
| 3/8/2000 |
Long Term Monitoring Established |
Letter sent with approval of Groundwater Monitoring Plan prepared by Groundwater Technology, Inc.
The Alaska Department of Environmental. Conservation (DEC), Contaminated Sites Remediation Program has completed a review of a March 6, 2000 groundwater monitoring plan for the Defense Energy Support Center Whittier Tank Fann site. Groundwater Technology, Inc prepared the plan, which specifies the methods and protocols to evaluate progress of interim cleanup actions approved under the 1999 Interim Corrective Action Plan. The groundwater monitoring plan meets the requirements of 18 AAC 75.330 (d) and is consistent with the regulations at 18 AAC 75.345(h). Therefore, the groundwater monitoring plan is approved, subject to the following conditions:
1. The initial round of groundwater sampling and analysis must be completed before operational startup of the approved interim corrective action treatment system; and,
2. DEC approval of a written groundwater sampling schedule that specifies the time periods that wells will be sampled over the next two years.
Please also note that it is your responsibility to obtain any permits or authorizations from
landowners or land managers to access any equipment and wells during monitoring activities. |
Scott Pexton |
| 3/13/2000 |
Update or Other Action |
During removal of 2 underground storage tanks polychlorinated biphenyls was found in soils of excavations. Site backfilled to temporarily close site to protect the public. |
Scott Pexton |
| 6/20/2000 |
Meeting or Teleconference Held |
Meeting held from 6:00 to 7:30 PM at the P12 Shop conference room in the Public Works Building. Representatives of the U.S. Army, DESC, City of Whittier, ARRC, and ADOT&PF attended along with a few local community members. |
Scott Pexton |
| 8/28/2000 |
Update or Other Action |
ADEC received Spring 2000 Water Sampling Results prepared for DESC by Michael L. Foster and Associates. |
Scott Pexton |
| 9/1/2000 |
Site Visit |
Site visit to check progress with interim treatment system installation and to look for potential UST locations. |
Scott Pexton |
| 9/12/2000 |
Update or Other Action |
Mark Prieksat (Army) conveyed the following information obtained from a recent field trip to Whittier. Army plans on closing two tanks inside building 305, will empty tanks of all product and water, steam clean and fill with an inert material. Army does not plan to conduct a site assessment. Site assessment will be conducted with building 305 is demolished. The building lies within the corrective action treatment area. In theory, any contamination associated with these tanks would be remediated as part of the area-wide treatment.
Approximately 100 yards west of Building 305, a UST is suspected and may exist below existing AST. Army to investigate for the presence of UST. Possible UST located outside Building 305, three pipes were noted during an on-site visit. The piping was stuck and it is believed that a tank may exist. Building 303 a slop tank may exist. Building 304 a tank may exist. |
Tim Stevens |
| 9/21/2000 |
Meeting or Teleconference Held |
Meeting at ADEC offices with Lieutenant Colonel Redmon and Jack Appolloni (DESC), Mark Prieksat (Army), Mike Foster and Michele Turner (consultants) and Linda Nuechterlein (ADEC Storage Tanks Program) to review UST inventory information.
UST
Review spreadsheet summary, tanks registration, tank removal, notification/closure forms, site assessments/waste disposal, and coordination/operation of interim treatment system.
DESC Cleanup Plans
Review two-year plans, water well permit application, building 305 USTs, schedule for startup of interim system, operation and maintenance plan, groundwater monitoring reports, proposed cleanup levels and proposed plan.
Summary: UST Status-Tank#1 (ALT ID 800) is associated with building #17-012 (Delong Dock Fire Pump House). RP states that tank is no longer there. It is possible that #1(800) and #15 are the same tank. Scott Pexton requested further investigation to determine status before removing from the list.
Tanks#2(801) and #3(802) were removed in 1991; no site assessment was done, but the former tank locations appear to be within the proposed treatment zone of the interim treatment system. Although there was some confusion with these tank numbers: #2 and #3 and tanks #10 (900A) and #11 (900B), these two tanks were originally registered by the Army and removed by the Army contractors in 1991. Tanks #10 and #11 were different replacement tanks installed by the Army at different locations near Building 305.
Tank#4(804) and #5(806) show up on Scott's list as still in the ground. RP says these are not tanks but piping that went to a 20,000 gallon UST #8 (808) which has been removed but no site assessment was done. Mark Prieksat said he would investigate next spring (2001) with "year end money". If it turns out this is piping associated with the removed 20,000 gallon UST, a closure site assessment will be required for the piping as well as the tank since this area is not covered by the (interim) remediation system.
Tank #6-No problem as this tank was removed and a site assessment was conducted.
Tank#7-Building 304-Status unknown, RP says tank not there but needs to be investigated.
Tank#8 (808) Removed and no site assessment done. See above. NOTE: There may be two additional tanks of unknown volume near #8 (808) and/or the rail rack, as the drawing indicated that two tanks existed (see As-Built Mylar F78-18-53 Sheet 82).
See site file for additional information.
|
Scott Pexton |
| 9/25/2000 |
Update or Other Action |
Michael Foster and Associates sent work plan for Pumphouse UST closures MLFA Job# DESC-DESC-002. As part of the Pumphouse reconfiguration activities at the DFSP-Whittier, two USTs located at the Pumphouse will be closed in place (UST 17-305E and 17-305F). Because the USTs are located within the area of treatment of a contaminated site, no site assessment will be performed and no effort will be made to assure clean closure. Tank closure completion date for field work is October 9, 2000. A post closure form will be submitted to ADEC within 30 days of UST closures and a report will be submitted to ADEC within 60 days of UST closures. |
Scott Pexton |
| 9/26/2000 |
Update or Other Action |
Tim Stevens sent letter to Army (Mark Prieksat) re: Waiver of 15 day closure notification period and site assessment deferral for two UST located at DESP Facility in Whittier. Fac. ID 00817 Tank numbers 9 and 10.
ADEC grants waiver, allowing the USTs closures to begin on October 9, 2000, as requested. Please contact Linda Nuechterlein, at (907) 269-7562, if the closure activities are rescheduled, or if there is a change in the certified worker. Closure activities must be supervised by a person certified under, 18 AAC 78.400 - 78.495.
State and federal UST regulations require a site assessment of the tank excavation or tank location is performed during the UST closure process. ADEC has discussed the site assessment requirement with the US Army and has agreed to defer the site assessment until : 1) the building (17-305) containing the USTs is demolished, 2) the corrective action being performed to cleanup petroleum contamination associated with the tank farm facility is completed or 3) ADEC determines a site assessment is needed at an earlier date.
In accordance with 18 AAC 78.085 (f), please submit the post-closure notice to David Allen at ADEC/STP, 555 Cordova Street, Anchorage, Alaska 99501, within 30 days of completing closure activities. |
Tim Stevens |
| 10/20/2000 |
Update or Other Action |
Michael Foster and Associates sent letter to Mark Prieksat re: Pumphouse UST closures Defense Fuel Support Point MLFA Job# DESC-DESC-002. As part of the Pumphouse reconfiguration activities at the DFSPW, 2 USTs located within the Pumphouse were closed in place. A copy of the Notification Waiver and Pre-Closure Notification forms are included as an attachment. Both tanks were cleaned in accordance with API Method 1604, as required by Title 18, Alaska Administrative Code, Chapter 78. The required Post-Closure forms for USTs 503-E and 503-F are included as an attachment. Disposal certificates for tank liquids and sorbents will be forwarded to ADEC upon receipt. A site assessment was not performed as part of closure activities because the work took place within a contaminated site and as per the ADEC UST closure waiver. |
Louis Howard |
| 11/8/2000 |
Update or Other Action |
Letter from Mark Prieksat (Army) to Dave Allen RE:Registration of UST at Whittier Tank Farm. Tank 817 is a sump or SLOP tank installed into the foundation of the Transfer Pump Building (17-303). The tank is currently empty and is suspected to have been pumped when the facilities closed in 1994. The Army would like to register this tank with the intent to close and remove the tank when the building is demolished in the near future. |
David Allen |
| 3/6/2001 |
Update or Other Action |
ADEC received Quarter 4 - 2000 Water Sampling Report prepared for DESC by Michael L. Foster and Associates. |
Scott Pexton |
| 3/29/2001 |
Meeting or Teleconference Held |
Meeting held at ADEC offices in Anchorage with Lieutenant Colonel Redmon, Jack Appolloni, Michael Foster, and Michele Turner to discuss monitoring results and plans to begin operation the interim system later this year. |
Scott Pexton |
| 6/26/2001 |
Update or Other Action |
Received Punchlist/Start-up Plan, prepared by Michael L. Foster and Associates for DESC. |
Scott Pexton |
| 10/25/2001 |
Meeting or Teleconference Held |
Met with Lieutenant Colonel Redmon and Jack Appolloni of DESC and Mike Foster of Michael L. Foster and Associates to discuss groundwater monitoring results, funding issues under DSMOA, and future actions at the site. |
Scott Pexton |
| 10/26/2001 |
Update or Other Action |
Piping Analysis Defense Fuel Support Point - Whittier Whittier, Alaska MLFA Job No. DESC-DESC-002-0016 received by ADEC. This Report documents the piping network analysis and design review of the as-built steam sparge/soil vapor extraction system at the Defense Fuel Supply Point—Whittier (DFSP-W) in Whittier, Alaska in accordance with ACO-0016. The Report concludes with specific, detailed recommendations to accommodate thermal movement and support reactions.
The piping geometry and load conditions were modeled using specialty software specific to piping. Pipe stresses induced by internal pressure, thermal expansion, snow load, wind load, and earthquake loading were compared to the ASME B31.1 Power Piping Code. Structural supports were reviewed for reactions caused by the piping load conditions. Displacements of the piping were reviewed to determine areas of concern.
The pipe for the system is adequate for the design operating pressure and temperature ranges. However, the pipe structural supports and provisions for thermal expansion are inadequate and must be modified to safely operate the system.
The analysis concludes that the following modifications to the piping support system are required.
• Modify exterior piping supports for gravity, longitudinal, and lateral loads.
• Provide one braced support for stability from overturning.
• Provide one braced anchor support on exterior piping.
• Provide pipe saddle slide supports on exterior piping.
• Provide one spring hanger support on the steam header at the boiler.
• Provide two pipe roller supports along steam header piping inside the Pump Building.
|
Scott Pexton |
| 10/31/2001 |
Update or Other Action |
Received copy of a permit application and Notice of Disposal, prepared by Michael L. Foster and Associates and submitted to the ADEC Drinking Water and Wastewater program. |
Scott Pexton |
| 12/12/2001 |
Institutional Control Record Established |
Fort Richardson owns the Whittier DFSP property and therefore the Fort Richardson ICs apply to it. NOTE TO FILE(BRAC 2005 caused the property to be transferred from Fort Richardson to Fort Wainwright for management and ownership-which is still the U.S. Army).
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.
See site file for additional information.
|
Louis Howard |
| 2/11/2002 |
Meeting or Teleconference Held |
Met at ADEC offices in Anchorage with Lieutenant Colonel Redmon and Jack Appolloni of DESC and Mike Foster and Michele Turner of Michael L. Foster and Associates to discuss groundwater sampling plans to establish baseline levels of DRO and GRO/BTEX before starting operation of the steam injection/air sparging/soil vapor extraction system. Over 60 wells were identified for sample collection. |
Scott Pexton |
| 3/20/2002 |
Update or Other Action |
Received Baseline Sampling Plan prepared by Michael L. Foster & Associates for Defense Energy Support Center. The plan specifies 71 monitoring wells to be sampled to provide baseline data to help evaluate the effectiveness of the steam sparge/soil vapor extraction remediation system. All 71 wells will be sampled for DRO and 20 of the wells will also be sampled for GRO/BTEX. Prior to sampling groundwater water levels will be measured to the nearest 0.01 foot and a determination made if free product is present. If any wells have a product thickness greater than 0.1 feet, the well will not be sampled. Wells will be sampled using a "no-purge" procedure to minimize wastewater handling. |
Scott Pexton |
| 3/21/2002 |
Document, Report, or Work plan Review - other |
Letter sent to Lieutenant Colonel Redmon (copies sent to Jack Appolloni, Richard Kennedy & Mike Foster) with approval of the groundwater Baseline Sampling Plan. |
Scott Pexton |
| 12/26/2002 |
Document, Report, or Work plan Review - other |
Reviewed and commented on the Groundwater Monitoring Plan for the site.
4.0 Sample Collection Procedures Page 5
The text states “In general, samples will be collected in accordance with ADEC’s Guidance of Petroleum Contaminated Sites, dated September 2000.” It appears that the sampling is not following the requirements found in the guidance. According to the guidance, BTEX analyses is required for all JP-4 releases in conjunction with gasoline range organics (GRO) and diesel range organics (DRO). The Department requests DESC-A provide information on whether or not BTEX analyses has been conducted on wells where only GRO or DRO analyses is performed. If not, then please provide the Department with justification on why the following wells have been excluded from BTEX analyses: MW-31, 32, 33, 44, 45, 46, 47, and 54.
The Department requests that future sampling results be compared to historical sampling events in a graphical format. This would be in addition to using a table for the current sampling event for each monitoring point. For example, use a line graph with concentrations detected, cleanup level of the various contaminants of concern (COCs) displayed as a threshold criteria and sampling date (month and year). In lieu of a line graph, a table listing the wells sample, analytical method, cleanup level, and date of sampling would suffice.
This graphical representation would allow the reader to see the historical data against the current data and determine if there is a trend in groundwater or surface water contamination levels. The Department is aware that different laboratory methods have been used for analysis of petroleum contamination at the site instead of the approved AK methods required by regulation in the past. However, it would be helpful to see what the general trend of contaminant concentrations have been at the site.
Finally, while the Department has approved the “no-purge” sampling procedure in March 2002 for groundwater sampling, it has researched the procedure and found that a no-purge sampling procedure may actually be not to DESC-A's advantage since the Western States Petroleum association and others have found a bias towards higher sampling results with this procedure. For determining whether or not to discontinue sampling of a particular COC at a particular well or wells, or in an area, the Department will require DESC-A to employ traditional purge and sample procedures at its site located in Whittier.
6.0 Reporting Format Page 6
The text does not state what the results will be compared against for action levels. The Department expects and requires the results from both the quarterly and annual reports include a comparison to Table C action levels for: DRO (1.5 mg/L), GRO (1.3 mg/L), benzene (0.005 mg/L), ethylbenzene (0.7 mg/L), toluene (1.0 mg/L) and total xylenes (10.0 mg/L). Finally, the Department requests DESC-A provide additional site information on the groundwater elevation, groundwater contour, estimated flow direction, and gradient in its reports. |
Louis Howard |
| 5/15/2003 |
Meeting or Teleconference Held |
Staff met with Defense Energy Support Center and Army project managers to discuss the former Whittier Tank Farm remediation system feasibility study. Currently three million dollars a year are being expended by Defense Energy to operate, maintain the system combined with groundwater monitoring. The cost benefit of continuing the steam sparging and vapor extraction system in its current form is not apparent for the amount of remediation that may be occurring.
The Defense Energy agency will be completely shutting down the system and use baseline groundwater monitoring data combined with this year’s quarterly monitoring results to determine if remediation has occurred, whether the plume size has decreased and remains stable and if free product rebounds to pre-treatment levels. Alternative remedial actions are being conceptually developed in lieu of continuing to use the steam sparging system on a broad basis, such as hotspot soil removal in an area contributing to the groundwater contamination and possibly focusing the steam sparging system in this hot spot area. |
Louis Howard |
| 6/18/2003 |
Document, Report, or Work plan Review - other |
Staff received and approved the Defense Logistic Agency-Defense Fuel Supply Center's memorandum for shut down of the steam sparge/vapor extraction system at the facility. The memorandum confirms the mutual agreement that the shutdown of the steam sparge/vapor extraction system will occur during the 2nd O&M period closeout ending June 30, 2003. This agreement was determined after review of the technical memorandum submitted by the contractor that included costs to remediate and estimated gallons of product recovered from March 2002 through June 2003. Review of the monitoring data strongly indicated a stationary contamination plume was also a factor in the decision.
*NOTE to file: 18 AAC 75.345 Groundwater and Surface Water cleanup levels (h)(2) states: "If the monitoring indicates that the concentration trend is stable or decreasing, and that hazardous substance migration is not occurring, the department will decrease or discontinue the monitoring frequency and locations, if the responsible person demonstrates that continued monitoring is not necessary to ensure protection of human health, safety, and welfare, and of the environment." The use of steam sparging and vapor extraction at the site is not “practicable” which means capable of being designed, constructed, and implemented in a reliable and cost-effective manner, taking into consideration existing technology, site location, and logistics in light of overall project purposes; “practicable” does not include an alternative if the incremental cost of the alternative is substantial and disproportionate to the incremental degree of protection provided by the alternative as compared to another lower cost alternative.
Total free product removed was 146 gallons and vapor (hydrocarbon) removed was 14,000 gallons (44 tons) from March 18, 2002 through June 30, 2003. The cost of operating the system including snow removal, operation and maintenance (7 days per week 24 hrs a day) and natural gas was 3,746,554.59. $25,661 per gallon w/o vapors removed included. Assuming 10% of vapor recovered was actually fuel: costs for 1,546 gallons was $2,423 per gallon to treat. |
Louis Howard |
| 6/18/2003 |
Update or Other Action |
Memorandum from DESC-ALASKA/CC SUBJECT: Shut Down of the Steam Sparge/Vapor Extraction System at DFSP Whittier, Alaska. This is to confirm the mutual agreement between the Alaska Department of Environmental Conservation (ADEC), the Defense Energy Support Center (DESC), and the U.S. Army Garrison Alaska (USAG-AK) concerning shutdown of the steam sparge/vapor extraction system at DFSP Whittier during the 2nd O&M period closeout ending June 30, 2003. This agreement was determined after review of the technical memorandum submitted by Michael L. Foster and Associates (MLFA) that included costs to remediate and estimated gallons of product recovered from March 2002 through June 2003. Review of monitoring data strongly indicating a stationary contamination plume was also a factor in the decision. All parties listed above mutually agreed the system would be shut down for a 12-month period.
This 12-month shutdown will be used to study product rebound, if any, and the timeframe for natural attenuation to achieve cleanup goals without further operation of the remediation system. DESC will continue to conduct quarterly monitoring and model/calculate natural attenuation of contaminants in groundwater. The fate and transport model will be used and will remain in public domain, not proprietary, peer reviewed, and will follow the CSRP Guidance for Fate and Transport Modeling (CSRP 98-001) July 1998.
Depending on outcomes of the product rebound, natural attenuation studies and the modeling effort, the steam sparge/vapor extraction system may not be restarted These outcomes will be used to determine if monitored, natural attenuation, without operation of the treatment system, will be protective and achieve cleanup goals, to be specified in the future record of decision. The information will also be used to decide on long-term disposition of the steam sparge/vapor extraction system. If product is discovered, other means of recovery will be conducted such as: hand bailing of monitoring wells, use of skimmer pumps and/or any other technically practicable means. We appreciate your assistance in moving towards an exit strategy for former DFSP Whittier and will notify you of all results received during the 12-month shutdown. |
Louis Howard |
| 6/30/2003 |
Update or Other Action |
Operations & Maintenance Reports-
A treatment plant was constructed at the site consisting of multiple systems to remediate hydrocarbons from the smear zone in the vicinity of manifold, office/shop, and pumphouse buildings. The system operated from March 18, 2002 through June 30, 2003 and included the following components:
• Steam Sparge System. The SS system operated with an average daily volume of 17,590 gallons with an average wellhead pressure of 5 - 11 psi.
• Air Sparge System. The AS system operated with an average wellhead pressure of 5 - 11 psi.
• Soil Vapor Extraction System operated with a wellhead vacuum pressure of 0.5 to 1.5 psi. A total volume of 6,200 gallons of condensate was recycled through the first 270 days. The system was also installed with skimmer pumps to recover free product.
Weekly free product and groundwater monitoring was conducted in conjunction with system operation. |
Louis Howard |
| 5/21/2004 |
Site Number Identifier Changed |
Corrected Region from 21 to 24. |
Former Staff |
| 9/23/2004 |
Update or Other Action |
Interim Action Work Plan received for DFSP-W. The purpose of the interim action work plan is to remove contaminated soil from underneath and around the former manifold building. The estimate of contaminated soil and transported to Anchorage for thermal remediation is up to 20,250 tons. After excavation, a long term monitoring plan will be prepared for the site.
The plan will be used to evaluate the effectiveness of the site cleanup. After two years of groundwater sampling results demonstrate the size of the dissolved plume is at steady state or shrinking, not migrating off site, and concentrations are decreasing, a no further remedial action decision may be applied for by DESC to ADEC.
The strategy is to excavate the source material near the former manifold building that exhibits free product during periods of low groundwater. Surface soil extending from the ground surface to the highest groundwater elevation in the area of the manifold building will be removed. The groundwater elevation is approximately 9 to 10 ft. bgs following a storm event. The cost of on-site versus off-site treatment was compared. Based on this analysis it was determined that the contaminated soil would be transported to Anchorage Soil Recycling (ASR) facility in Anchorage for thermal treatment.
Also analyzed was the cost of loading soil onto Alaska Railroad's rail cars versus truck and haul and use of semi-trucks and bell dump trailers was cheaper and selected by DESC. Excavations will be backfilled with on-site soil. Previously stockpiled overburden soil and stockpiled soil near Tank 813 will be used for fill at the excavation. No soil will be transported to the site.
A completion report will be prepared summarizing the interim action activities. The report at a minimum will contain: as-built of the excavation, field screening results, laboratory analyses, and disposition of the contaminated soil. |
Louis Howard |
| 9/23/2004 |
Update or Other Action |
File number issued 2114.38.011 |
Aggie Blandford |
| 9/30/2004 |
Update or Other Action |
Report received documenting the removal of the external soil and groundwater remediation system and the demolition of the Office/Shop Manifold Building and Guard House at the Defense Fuel Support Point - Whittier (DFSP-W) facility. Five buildings were onsite prior to the demolition project: Bldgs- 17-302 (Office/Shop), 17-303 (Manifold Bldg.), 17-304 (Water Pump Bldg.), 17-305 (Pump Bldg.), and a small guard house located next to the Pump Bldg.
The Office/Shop, Manifold Building, remediation system and infrastructure were demolished. The small guard house was decommissioned and moved. Asbestos in the Office/Shop was confirmed in approximately 500 lineal feet of thermal insulation applied to the piping, 400 square feet of floor tile in the laboratory, the glazing for six windows and the mastic applied to the flashing on the roof edge. The asbestos was handled and contained friable material.
At the Manifold Bldg. during demolition, asbestos was also found. Approximately 75 linear feet of thermal system insulation applied to piping, joint compound on approximately 1,200 square feet of wall board, and mastic around three roof openings. It was handled and contained friable material. 69 steam sparging wells, 14 air sparging wells and 15 soil vapor extraction wells that were not included in the quarterly sampling were decommissioned. |
Louis Howard |
| 11/1/2004 |
Update or Other Action |
Groundwater monitoring report received. Of the 73 wells sampled, 5 wells exceeded ADEC Table C criteria for at least one parameter (free product was not observed in the wells). The majority of these wells are located within the SS/SVE remediation system (MW-56, MW-68DUP, VE-07, VE-20, VE-20DUP, and VE-28DUP). |
Louis Howard |
| 3/7/2005 |
GIS Position Updated |
Based on report information provided by DESC the locational data has been updated with regards to "site legal description". |
Louis Howard |
| 4/19/2005 |
Update or Other Action |
Whittier Defense Fuel Support Pt. 2005 Quarter 1 (Q1) report received. Free Product analysis: MW-05 light sheen, MW-34 fuel odor light sheen, MW-56 light sheen, MW-68 fuel odor light sheen, MW-72 fuel odor light sheen. Vapor extraction (VE) wells: VE-23 light sheen, VE-30 fuel odor light sheen, VE-42 light sheen, VE-47 light sheen.
MW-04 10.9 mg/L DRO [NOTE TO FILE:LNAPL is considered present where analytical data shows DRO concentrations above the theoretical solubility limit for diesel of 3.9 mg/L], MW-05 2.76 mg/L DRO, MW-15 1.7 mg/L GRO, MW-33 3.33 mg/L DRO, MW-34 28.9 mg/L DRO, MW-41 2.04 mg/L GRO 0.0122 mg/L benzene, MW-56 32.7 mg/L DRO (Highest recorded DRO this quarter), MW-68 2.76 (D 2.79) mg/L GRO 0.0141 (D 0.0136) mg/L benzene, Duplicate had 1.98 mg/L DRO, MW-72 3.3 mg/L (D 3.46 mg/L highest GRO recorded this quarter) GRO, Duplicate had 5.55 mg/L (J). Vapor Extraction wells: VE-23 4.60 mg/L DRO, VE-30 3.42 mg/L and VE-42 6.71 mg/L (highest DRO for VE wells this quarter). |
Louis Howard |
| 8/31/2005 |
Update or Other Action |
2005 Quarter 2 sampling report received for DFSP-Whittier received. Free product analysis: MW-56 fuel odor, no sheen, MW-68 no odor, light sheen, MW-72 no odor, light sheen. VE-40 fuel odor, medium sheen, VE-43 fuel odor medium sheen, VE-44 fuel odor, no sheen. Monitoring well MW-56 was the only well with contaminants above cleanup level for DRO (1.5 mg/L) at 2.34 mg/L. All other wells were below cleanup levels for all contaminants of concern. Vapor extraction wells VE-27 had 1.76 mg/L DRO, VE-40 had 2.62 mg/L DRO and VE-43 had 22.1 J mg/L DRO (estimated). All others were below cleanup levels for petroleum constituents. |
Louis Howard |
| 9/23/2005 |
Update or Other Action |
As a result of 2005 Base Realignment and Closure decisions, Elmendorf AFB and Fort Richardson were realigned and began combining to establish Joint Base Elmendorf Air Force Base and Fort Richardson (JBER). The new joint base became fully operational on October 1, 2010. The property was not included as part of JBER and was subsequently transferred from Fort Richardson to Fort Wainwright for management of institutional controls. Dave Fish is the Army’s project manager for Fort Wainwright that would manage any ICs assigned to the DFSP-Whittier site.
"BRAC" is an acronym that stands for Base Realignment and Closure. It is the congressionally authorized process DoD has previously used to reorganize its base structure to more efficiently and effectively support our forces, increase operational readiness and facilitate new ways of doing business. (The original legislation actually states that the title of the process is Base Closure and Realignment.)
|
Louis Howard |
| 10/31/2005 |
Update or Other Action |
2005 Quarter 3 Sampling Report received for Defense Fuel Support Point - Whittier. Free Product Analysis: MW-34 no odor, light shee, MW-56 fuel odor, light sheen, MW-68 fuel odor, light sheen. VE-27 fuel odor, medium sheen, VE-31 no odor, light sheen, VE-40 no odor, light sheen, VE-41 no odor, light sheen, VE-43 fuel odor, light sheen.
No groundwater wells had any samples with contamination above cleanup levels specified in 18 AAC 75 Table C for GRO, DRO, toluene, ethylbenzene, total xylenes, benzene.
Vapor extraction well VE-27 had DRO above 1.5 mg/L at 9.99 mg/L (Dup at 19.3 J mg/L). All other VE wells were below cleanup levels. |
Louis Howard |
| 1/17/2006 |
Update or Other Action |
2005 monitoring report for Quarter 4 at Def. Fuel Support Pt.-Whittier. Free-product Analysis for monitoring wells: MW-04 light sheen, MW-68 fuel odor light sheen, MW-72 fuel odor light sheen. Vapor extraction wells: VE-31 fuel odor light sheen and VE-44 fuel odor light sheen.
MW-41 had the only exceedance of GRO at 1.53 mg/L and for benzene at 0.0128 mg/L. MW-68 and duplicate had the only exceedance this quarter for DRO at 6.08 and 6.62 mg/L respectively. All vapor extraction wells this quarter had no exceedances for any contaminant of concern. |
Louis Howard |
| 5/3/2006 |
Document, Report, or Work plan Review - other |
Staff reviewed and approved the 2006-Quarter 1 Sampling Report, Defense Fuel Support Point Whittier, AK MLFA Job No. DESC-DESC-008-0007. Results did not deviate significantly from previous year's sampling efforts. |
Louis Howard |
| 2/9/2007 |
Exposure Tracking Model Ranking |
|
Louis Howard |
| 6/15/2007 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (ADEC) has received the First Quarter 2007 report with information regarding free product occurring in at least nine (9) wells (2007 – Quarter 1 Sampling Report). ADEC requests DESC conduct a source removal involving building demolition and soil removal from underneath and around the Pump Building (a.k.a. Building 17-305). This would be similar to the removal to the work conducted for the Manifold Building source removal. Approximately 20,000 cubic yards was removed during that action.
After excavation, it is expected that a long term monitoring plan will be prepared for the site. The plan will be used to evaluate the effectiveness of the site cleanup. Groundwater sampling results will need to demonstrate the size of the dissolved plume is at steady state or shrinking, not migrating off site onto non-DESC property, and concentrations are decreasing. Without such action the time frame until free product ceases to be an issue would be much longer.
The strategy is to excavate the source material near Building 17-305 that is contaminated, exhibits free product during periods of low groundwater and acts as a continuing source for groundwater contamination. Surface soil extending from the ground surface to the highest groundwater elevation in the area of Building 17-305 will be removed. The groundwater elevation is approximately 8 to 10 ft. bgs following a storm event. Excavations will be backfilled with clean soil.
A completion report will be prepared summarizing the interim action activities. The report at a minimum will contain: as-built of the excavation, field screening results, laboratory analyses, Laboratory Data Review Checklist that summarizes the minimum requirements for both laboratory data packages and QA Summaries (data reduction, verification, evaluation, etc,), and disposition of the contaminated soil.
ADEC requests a work plan be submitted for review and comment at least 30 days prior to field work commencing.
|
Louis Howard |
| 9/25/2007 |
Document, Report, or Work plan Review - other |
Staff received and commented on the 2007 Quarter 2 Sampling Report Defense Fuel Support Point-Whittier, MLFA Job No. DESC-DESC-008-0014 dated September 12, 2007. Cooler ID number 3 does not list a temp blank (temp indicator). The notation on the receipt form was “N/A”. The cooler temp was reported as 9.9° C. All samples associated with Cooler ID number 3 will be flagged as “J”. The quantitation is an estimation and is biased low. This is especially true for gasoline range organics (GRO) and benzene, toluene, ethylbenzene, and total xylenes (BTEX) analyses. Data may be usable, but more than likely is biased low. |
Louis Howard |
| 4/25/2008 |
Document, Report, or Work plan Review - other |
Draft Pumphouse Site Characterization Work Plan, DFSP-Whittier March 31, 2008 reviewed and nd approved.
ADEC concurs with the sampling approach for the Pumphouse site installing ten groundwater monitoring wells and collecting two soil samples per boring during well installation as specified in the plan. ADEC will approve the work plan as submitted. Please note, ADEC review and concurrence on this work plan is to ensure that the work is done in accordance with State of Alaska environmental conservation laws and regulations. While DEC may comment on other state and federal laws and regulations, our concurrence on the plan does not relieve responsible persons from the need to comply with other applicable laws and regulations |
Louis Howard |
| 11/24/2008 |
Document, Report, or Work plan Review - other |
2008 Quarter 3 Sampling Report Defense Fuel Support Point-Whittier, MLFA Job No. DESC-DESC-008-0020 October 27, 2008 reviewed and approved by staff.
The Alaska Department of Environmental Conservation (ADEC) has received the above document for review and comment. ADEC will approve the report as submitted. ADEC requests DLA consider reducing the frequency of monitoring to three times a year and eliminating the sampling period which has the most frozen wells (i.e. 4th Quarter or 1st Quarter) since well data could not be obtained. Additionally, ADEC requests DLA either repair damaged wells at the site or properly decommission them if not repairable (i.e. MW-03, MW-35, MW-36, MW-34, MW-40, MW-78, VE-44).
ADEC’s review and concurrence on the document is to ensure compliance with State of Alaska environmental conservation laws and regulations. While ADEC may comment on other state and federal laws and regulations, our concurrence on the document does not relieve the Defense Logistics Agency or its consultants, contractors, or civilian personnel from the need to comply with other applicable laws and regulations.
|
Louis Howard |
| 2/24/2009 |
Document, Report, or Work plan Review - other |
Pumphouse Site Characterization Report DFSP-Whittier January 5, 2009 reviewed and commented on by staff.
3.1 Drilling and Environmental Soil Sampling Page 4
The text states the soil samples were collected in October 2008 at 5-foot intervals until groundwater was encountered. Groundwater was first encountered at 9-10 feet below ground surface (4.1.1 Test Methods). There is no mention of testing of the soil cuttings generated from the drilling of the wells. The cuttings were placed in 1.5 cubic yard super sacks and stored on site.
Petroleum contamination was noted in each borehole at 30 ft. bgs and extending to the end of the borings at 50 ft. bgs. While ADEC does not typically require analysis of soil samples below the water table, in this case it is of interest since the field observations presented in the document text and in Appendix B indicated strong presence of petroleum contamination but was not represented as expected in the summary of results of groundwater samples in Table 5. |
Louis Howard |
| 3/25/2009 |
Document, Report, or Work plan Review - other |
Pumphouse Well Sampling Report Defense Fuel Support Point-Whittier, MLFA Job No. DESC-DESC-008-0023 March 17, 2009 reviewed and commented on. ADEC will approve the report as submitted. Future submittals for groundwater monitoring are requested to be provided electronically (CD-ROM with ADOBE PDF file) and one hard copy.
|
Louis Howard |
| 8/12/2009 |
Update or Other Action |
Baseline Sampling Report received. Groundwater from monitoring wells, product recovery wells, and vapor extraction wells were analyzed for GRO, BTEX, and DRO. GRO results ranged from non-detect (ND) to 19.6 milligrams per liter (mg/L); benzene results ranged from ND to 1.02 mg/L; toluene results ranged from ND to 0.0477 mg/L; ethylbenzene results ranged from ND to 0.0941 mg/L; total xylene results ranged from ND to 0.277 mg/L; and DRO results ranged from ND to 16,800 mg/L.
The DRO chromatographic patterns for MW-77, VE-02, VE-03, VE-06, VE-07, VE-09, VE-16, VE-31, VE-33, VE-36, and VE-37 contained an unknown hydrocarbon with several peaks present. A mass spectrometer analysis of a representative sample shows the presence of organic acids. One possible source of organic acids is from a septic leachfield. The presence of these hydrocarbons may not be due to the presence of petroleum products.
DRO samples VE-12, VE-22, VE-25, VE-26, VE-27, VE-29, and VE-41 contained a layer of free-product. The free-product was decanted and the aqueous layer analyzed for all samples except VE-27 and VE-41, which were analyzed without decanting. Results for all samples with free-product should be considered estimated.
Of the 66 wells sampled, 23 wells contained water that exceeded ADEC Level C criteria for at least one parameter (eight wells contained a measurable amount of free-product on the water table). The majority of these wells are located within the area of the SS/SVE remediation system, but there were also wells downgradient of the SS/SVE remediation system and downgradient of Tank 808 that contained amounts of contaminants above Level C criteria. The data is accepted as representative of the site at the time of sampling with the qualifications noted above. |
Louis Howard |
| 10/14/2009 |
Document, Report, or Work plan Review - other |
Free-Product Survey Report Defense Fuel Support Point-Whittier, Alaska MLFA Job No. DESC-DESC-008-0024 October 8, 2009 received and commented on by staff. ADEC will approve the report as submitted and has the following comments on the document.
5.0 Recommendations Pages 8 and 9
ADEC concurs with the recommendation for a source removal approach, outlined below, to address the Pumphouse plume in an effort to further remediate the site.
1. Demolish the Pumphouse building to make way for further site remediation.
2. After demolition, the contaminated source material can be excavated from the site.
3. Re-evaluate the groundwater monitoring well network.
4. Develop a long-term groundwater monitoring plan at the conclusion of the source material removal. |
Louis Howard |
| 11/17/2009 |
Document, Report, or Work plan Review - other |
Interim Action Work Plan Defense Fuel Support Point-Whittier, Alaska MLFA Job No. DESC-DESC-008-0027 October 29, 2009 reviewed and commented on by staff.
4.3 Excavate Contaminated Soil Page 3
The text states laboratory analyses of soil samples will not be used to determine excavation limits, but for future reference only. ADEC concurs. However, ADEC will require a minimum level of sample quality control scrutiny for this project’s field sampling in accordance with the UST Procedures Manual (November 7, 2002) adopted by reference by 18 AAC 75 (October 9, 2008).
Reference to sets of samples in the table below 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.
5.0 Completion Report Page 4
ADEC will require the laboratory analyses include a completed ADEC Laboratory Data Review Checklist (March 2009) in accordance with the Laboratory Data and Quality Assurance Policy-Technical Memorandum (March 2009). These two documents can be found online at: http://www.dec.state.ak.us/spar/guidance.htm#csp under Analytical Methods and Quality Assurance section.
Upon incorporation of the required items mentioned in this letter, ADEC will approve the final work plan for this project. ADEC review and comment on this work plan is to ensure that the work is done in accordance with State of Alaska environmental conservation laws and regulations. While ADEC may comment on other state and federal laws and regulations, our comments on the plan do not relieve responsible persons from the need to comply with other applicable laws and regulations. |
Louis Howard |
| 1/21/2010 |
Offsite Soil or Groundwater Disposal Approved |
Letter sent to Traci Bradford acting on behalf of DESC. ADEC has received your request via electronic mail on January 20, 2010, acting on behalf of Defense Energy Supply Center, regarding covered loads on the dump trucks going through the Whittier Tunnel. You ask specifically if you could delay tarping the dump trucks on the Bear Valley side of the Whittier Tunnel instead of on the Whittier side dependent on the weather conditions (e.g. safety concerns with high winds) and truck cycle time. ADEC concurs with your request as a one-time approval which is applicable only to this project. This approval expires in three (3) weeks (February 11, 2010) or for the duration of the project, whichever is shorter. At that time another request will be required and considered by ADEC. Also the following are conditions of the approval:
1. All loads of contaminated soil shall be transported from Bear Valley as a covered load, as soon as possible, in compliance with 18 AAC 60.015.
2. 18 AAC 60.015. Transport. (a) A person who transports solid waste shall keep the waste contained during transport. (b) A person who spills solid waste during transport shall promptly pick up the waste and any waste residue resulting from the spill. (Eff. 1/28/96, Register 137)
3. ADEC shall be notified as soon as possible, via phone, fax or email if loads spill in the tunnel and if that occurs, then the approval for uncovered loads through the tunnel shall be revoked immediately and loads shall be covered on the Whittier side regardless of conditions or truck cycle time. |
Louis Howard |
| 2/16/2010 |
Offsite Soil or Groundwater Disposal Approved |
Letter sent to Traci Bradford acting on behalf of DESC. ADEC has received your voice mail request on February 15, 2010, acting on behalf of Defense Energy Supply Center, regarding covered loads on the dump trucks going through the Whittier Tunnel. This particular request was for an extension of the original January 20, 2010 request to delay tarping the dump trucks on the Bear Valley side of the Whittier Tunnel instead of on the Whittier side dependent on the weather conditions (e.g. safety concerns with high winds) and truck cycle time. ADEC concurs with your request for an extension and will grant a second approval which is applicable only to this project. This approval expires in four (4) weeks (March 9, 2010). At that time another request will be required and considered by ADEC. Also the following are conditions of ADEC’s approval:
1. All loads of contaminated soil shall be transported from Bear Valley as a covered load, as soon as possible, in compliance with 18 AAC 60.015.
2. 18 AAC 60.015. Transport. (a) A person who transports solid waste shall keep the waste contained during transport. (b) A person who spills solid waste during transport shall promptly pick up the waste and any waste residue resulting from the spill. (Eff. 1/28/96, Register 137)
3. ADEC shall be notified as soon as possible, via phone, fax or email if loads spill in the tunnel and if that occurs, then the approval for uncovered loads through the tunnel shall be revoked immediately and loads shall be covered on the Whittier side regardless of conditions or truck cycle time.
|
Louis Howard |
| 3/2/2010 |
Offsite Soil or Groundwater Disposal Approved |
Whittier March 2010 Third Request for Uncovered Loads through Whittier Tunnel reviewed and commented on by staff.
ADEC has received your electronic mail request on March 2, 2010, acting on behalf of Defense Energy Supply Center, regarding covered loads on the dump trucks going through the Whittier Tunnel. The is an extension of the original January 20, 2010 request and subsequent request on February 15, 2010, to delay tarping of the dump trucks on the Bear Valley side of the Whittier Tunnel instead of on the Whittier side dependent on the weather conditions (e.g. safety concerns with high winds) and truck cycle time.
ADEC concurs with your request for an extension and will grant a third approval which is applicable only to this project. This approval expires on April 30, 2010. At that time another request will be required and considered by ADEC. Also the following are conditions of ADEC’s approval:
1. All loads of contaminated soil shall be transported from Bear Valley as a covered load, as soon as possible, in compliance with 18 AAC 60.015.
2. 18 AAC 60.015. Transport. (a) A person who transports solid waste shall keep the waste contained during transport. (b) A person who spills solid waste during transport shall promptly pick up the waste and any waste residue resulting from the spill. (Eff. 1/28/96, Register 137)
3. ADEC shall be notified as soon as possible, via phone, fax or email if loads spill in the tunnel and if that occurs, then the approval for uncovered loads through the tunnel shall be revoked immediately and loads shall be covered on the Whittier side regardless of conditions or truck cycle time. |
Louis Howard |
| 8/9/2010 |
Document, Report, or Work plan Review - other |
Staff reviewed and approved the Excavation Report, Defense Fuel Support Point – Whittier dated July 27, 2010.
5.2 Results Page 4
The text states: “The GRO, BTEX, and PAH concentrations were well below ADEC cleanup levels.” However, for Sample ID SP-A-12-10, the detection limit of 34.4 ug/kg is above the 25.0 ug/kg cleanup level for benzene. This is more than likely an artifact of dilution factor of ten (10) which was used in Analytical Batch VFC9902 for SGS Ref. # 1101512025. The result was flagged “U” which indicates the analyte was analyzed for but not detected (Appendix C Soil Analytical Results, Page 94 of 126).
7.0 Recommendations Page 9
ADEC concurs with the recommendations presented in the report. |
Louis Howard |
| 9/30/2010 |
Update or Other Action |
A groundwater monitoring event was conducted at 5 downgradient wells in September 2010 in preparation for well decommissioning. The results show PCE contamination in groundwater above ADEC cleanup levels (0.005 mg/L). MW-41 5.8 ug/L, MW-42 5.8 ug/L, DUPLICATE ESC Sample# L481802-06: 5.2 ug/L, |
Louis Howard |
| 10/1/2010 |
Update or Other Action |
JBER MOA effective October 1, 2010.
ANNEX E. Real Property
6. OTHER AGREEMENTS
a. Transfer of real property will be in accordance with Joint Base Elmendorf-Richardson
MOA, Attachment 1, Joint Base Elmendorf-Richardson Implementation Plan.
b. The Army has identified nineteen (19) facilities that require demolition. The facilities
are listed in Attachment 2 to Annex E. These facilities fall into three (3) categories:
(1) Building 60600 at Fort Richardson, licensed to the Army National Guard (ARNG),
will be demolished by ARNG when funded by the National Guard Bureau;
(2) Buildings 47434 and 47435 on Fort Richardson and Building 17305 at the Whittier POL site. By FOC, the supported Component will demolish these buildings or transfer funds to the supporting Component for these demolition projects; and
(3) Fifteen (15) steel structures at the Whittier POL site have been designated for demolition when economically feasible.
i. The following GSL will not transfer to the supporting Component; rather, it will transfer
to Fort Wainwright: Seward Recreation Area. The Army is responsible for the provision
of all installation support to Seward Recreation Area. All personnel and resources at JBER
that provide installation support are under the command of the JBC for that purpose.
Those personnel and resources shall not be used to perform installation support functions
at Seward Recreation Area.
The supported Component will transfer the following two (2) GSLs to the supporting
Component, despite having a legal basis to be retained:
(1) PD Tok Junction
(2) Whittier Anchorage Pipeline
NOTE TO FILE: As a result of 2005 Base Realignment and Closure decisions, Elmendorf AFB and Fort Richardson began combining to establish Joint Base Elmendorf Air Force Base and Fort Richardson (JBER). The new joint base became fully operational on October 1, 2010. The property (DFSP-Whittier) was not included as part of JBER and was subsequently transferred from Fort Richardson to Fort Wainwright for management of institutional controls. Dave Fish is the Army’s project manager for Fort Wainwright that would manage any Institutional Controls assigned to the DFSP-Whittier site. |
Louis Howard |
| 12/1/2010 |
Update or Other Action |
Final Site Summary Report received.
Pumphouse-Manifold Bldgs. Plume: The current status of this plume is largely UNKNOWN following extensive remediation efforts. PCE was also found in the Pumphouse & Manifold buildings plume. It was detected at 0.869 mg/kg in MW-66 at 10 feet bgs & at 0.895 mg/kg at MW-65 at 40 feet bgs. In most of the samples, the detection limit was above the ADEC cleanup level. Adequate data to delineate the PCE plume do NOT exist.
Tank 813 Plume-Soil samples were taken in the area surrounding tank 813 in 1991, 1995, & 1996. Monitoring wells & borings that were placed prior to the tank release in 1995 were NOT assessed for this plume characterization. The soil samples show a strong DRO signature that is consistent with JP-5 (GSI, 1997). The plume has boundaries on the east, north, & west. The south has NOT been delineated beyond MW-46. BH-05 & MW-06 are NOT deep enough to evaluate the smear zone. The plume is delineated vertically showing soils with DRO concentrations between 20 & 50 feet below ground surface. Maximum DRO concentrations were 12,900 mg/kg at MW-34 at 20 feet & 2,670 mg/kg at MW-44 at 40 feet.
PCE was also found in this area in MW-46 & MW-47. In MW-46 the concentration was 0.571 mg/kg at a depth of 40 feet & in MW-47 it was 0.208 mg/kg at a depth of 35 feet. PCE has NOT been evaluated surrounding these two wells, so the PCE plume is UNDEFINED.
Benzene was found above the ADEC cleanup level of 0.025 mg/kg in MW-46. In most of the wells in the Tank 813 plume the detection limit for benzene was above the ADEC cleanup level. Data does not exist to delineate the benzene plume.
RR Loading Rack-The railroad loading rack area was found to be impacted by DRO, BTEX, & PCE. The source was potentially attributed to surface fueling spills, the nearby oil-water separator (OWS) tank or the 8-inch diameter pipeline to Anchorage, but was NOT definitively identified. Soil samples were taken in the area surrounding the rail racks on the southern end of the site. DRO, benzene, & PCE were found between 10 & 40 feet below ground surface in this area above the ADEC cleanup levels. The DRO plume is bounded on the west & on the south but appears to be undefined to the east & southeast. To the north, the DRO plume is adjacent to the Tanks 808 & 804 area. The benzene & PCE plumes are NOT defined. Wells to the south of this plume were removed for the placement of the Whittier Tunnel waiting area & further assessment of this area has NOT been completed.
See site file for additional information.
|
Louis Howard |
| 2/7/2011 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 72292 name: storage tanks |
Bianca Reece |
| 2/15/2011 |
Update or Other Action |
Draft Fiscal Year 2011 Work Plan received from DLA Energy for Defense Fuel Support Point Whittier.
NAPL gauging will be conducted at 18 wells within the two LNAPL plumes to obtain data on presence & extent of the remaining LNAPL during low GW in February. Bail-down tests will be conducted at 5 selected wells to determine the recoverability of the LNAPL.
The LNAPL level will be read when the probe indicates the LNAPL surface has been reached after slowly lowering the probe into the well (steady tone). The probe will then be lowered slowly through the LNAPL layer until the probe indicates it is fully submerged in the GW (beep). The GW level will be read upon slowly withdrawing the probe back through the LNAPL. This care will be taken to ensure that the probe does not smear the oil/water interface resulting in an inaccurate reading. The thickness of the LNAPL will be calculated by subtracting the GW level from the LNAPL level.
The LNAPL & GW level readings will be measured from the top of the well casing. If a mark is present on the casing that indicates where the historical readings were collected, the levels will be read at this point. If a mark is not present, the reading will be collected on the north edge of the well casing & that edge marked for the future with a permanent marker or notch.
Bail-down testing will be performed on five of the 18 gauged wells. The bail down test will be used as an empirical method to determine if LNAPL in the subsurface is sufficiently mobile to flow into a well & support recovery. If the LNAPL is sufficiently mobile to make liquid-phase recovery feasible, LNAPL should continue to flow into the well throughout multiple short-term bail-down recovery tests.
Data from the bail down tests will be used to estimate the sustainable recovery rate for each monitoring well by calculating LNAPL recovered in gallons per hour (gph). The rate of recovery over time & the total volume recovered will aid in determining whether liquid-phase recovery is practicable. Regulatory basis for practicability is variable throughout the United States & is currently changing. A determination of practicability will be examined once data is obtained. However, an established basis of product recovery feasibility is stated in a 1998 technical memorandum by the Naval Facilities Engineering Service Center that product recovery may not be warranted if the calculated rate of recovery is less than 0.005 gph (NFESC 1998). Other established basis endpoints of product recovery include the site specific metric of having a product thickness less than 0.1 feet for an entire year (USAFEAFBA 1998).
OASIS will subcontract with an Ultraviolet Optical Screening Tool (UVOSTTM) operator, possibly Hammer Environmental, to advance approximately 8 soil borings using a directpush drill rig. UVOSTTM uses LIF to provide data on the extent & relative concentration of contaminants in the subsurface.
See site file for additional information.
|
Louis Howard |
| 2/23/2011 |
Update or Other Action |
Staff reviewed and commented on the draft fiscal year 2011 work plan. General Comments-When reports will be submitted for ADEC review, ADEC will require a cover page with: Name and signature of qualified person responsible for collecting samples, name and signature of qualified person responsible for interpreting the data, and the name and signature of qualified person responsible for reporting the data.
1.1 Site Description and Brief Site History Page 4
For all remaining wells that will remain after decommissioning and are deemed usable, ADEC requests clarification on when the last time the wells were resurveyed. ADEC requires that monitoring wells are re-surveyed every five years, or more frequently, if freeze-thaw processes compromise the well. 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. The location survey should achieve a horizontal accuracy of 0.2 foot, and the elevation surveys should achieve a vertical accuracy of 0.01 foot. Vertical elevation control should be the National Geodetic Vertical Datum 1929, and the horizontal control should be the North American Datum 1983. Sites undergoing contaminant assessment monitoring with a large number of monitoring wells should have the wells surveyed as described above (ADEC Monitoring Well Design and Construction for Investigation of Contaminated
Sites, February 2009).
1.3 Hydrology Pages 5 and 6
Groundwater that is closely connected hydrologically to nearby surface water may not cause a violation of the water quality standards in 18 AAC 70 for surface water or sediment [18 AAC 75.345(f)]. The department will, in consultation with local, state, and federal officials and the public, establish points of compliance with this subsection, taking into account the following factors:
(1) groundwater travel time and distance from sources of hazardous substances to surface water;
(2) the contribution of the groundwater to the chemical and physical quantity and quality of the surface water;
(3) organisms living in or dependent upon the groundwater to surface water ecosystems;
(4) climatic, tidal, or seasonal variations;
(5) feasibility of attaining applicable water quality standards to support the designated uses of the surface water;
(6) presence of sediment contamination;
(7) if conducted for the site, the conclusions of a site-specific risk assessment conducted under the Risk Assessment Procedures Manual, adopted by reference in 18 AAC 75.340.
See site file for additional information.
|
Louis Howard |
| 5/16/2011 |
Update or Other Action |
DESC's contractor had concerns and issues with the dredged material stockpile adjacent to DESC's property in Whittier and requested Bill O'Connel (ADEC PM for the dredging project) respond.
Does the stockpile comply with ADEC requirements for either short or long term stockpiles? If so which and if not are there plans to require upgrading so that it is in compliance. The stockpile is placed on a liner that conforms to 18 AAC 75.370 standards for long term storage. The stockpile is covered, with a runoff collection basin at the downgradient edge. I have not conducted a site visit since the stockpile was covered, but I intend to do so this week, so if there is anything not up to spec, I can have them fix it. I’ve attached the figure that accompanied the work plan for you reference.
Have there actually been any run-off situations from the stockpile or is it just rumor? I am not aware of any run-off situations from the stockpile. The material was allowed to dewater before being placed into the stockpile and the standing water I observed within the cell during my last visit did not have any sheen on it. It’s certainly possible that something happened since my last site visit, but I would tend to doubt it as there have been multiple parties keeping an eye on things in Whittier and there has been no lack of reports on the situation.
If the stockpile is not in compliance and run-off has occurred will the PRP be required to perform characterization of the stockpile site? Specifically our concern is to ensure the DLA property or groundwater has not been affected. DLA doesn't want to end up selecting groundwater remedial alternatives or monitoring well locations based on a secondary release not associated with their property. I understand Max, the material that was placed into the stockpile was not segregated due to the difficulty in screening and segregating this quantity of material in such a short period of time, so the end result was that all 15-20,000 cy of material went into the stockpile regardless of the presence of contamination, so the overall effect should be an averaging-down of the contaminant concentrations. Please let me know if there are any indications of transport from the stockpile onto DLA property.
What are the long term plans for the stockpile, i.e. long term storage, remediation by some date, etc.? The agreement between ARRC and Whittier allow for stockpiling of the dredge spoils for up to two years. Currently there are no plans in place to deal with the stockpile, but the project is just wrapping up and I intend to address this with the City in the near future.
Has any data been collected from the stockpile or the ground beneath the stockpile? If so I'd like to request a copy of the lab report, QA plan and sampling plan used. Digital is fine, the less paper the better. I have attached data collected by ARRC prior to approving the stockpile and I have also attached data collected by BGES in support of the upland disposal of material from the boat grid, which originally contained tributyltin (TBT) in pore water. TBT was not detected in the sediment at the boat basin, so this material was approved for upland disposal along with the rest. The stockpile location had to be grubbed before building the stockpile and no samples were collected from the underlying soil. Below is the BGES work plan, the sampling conducted by ARRC was done without a work plan for their own information. |
Louis Howard |
| 1/23/2012 |
Update or Other Action |
Defense Fuel Support Point-Whittier FY2011 Characterization Report received.
The GW temperature in MW-95 fluctuated with the tides & also in response to other influences, presumably including precipitation events. Similar to MW-95, MW-79 experienced frequent GW temperature fluctuations, which are assumed to be related to tidal influences & precipitation events. The 2010-2011 datalogger study shows that tidal influence on GW elevation ranges from a maximum of approximately 2 feet near Passage Canal to a minimal of no tidal influence across the central portion of the site where siltier soils of lower permeability were encountered. Tidal influence was found in monitoring wells in the glacial moraine materials north & west of MW-95 to MW-33 & MW-04. Tidal influence was also found in monitoring wells MW-85 & MW-89 in the western portion of the site. The maximum tidal range within Passage Canal is approximately 18 feet.
The well showing the maximum tidal influence is MW-95, which is located adjacent to Passage Canal. In order of decreasing amplitude of tidal fluctuation were monitoring wells MW-89, MW-85, MW-33, & MW-91.
Tidal influences may have very minor effects on the GW when it is at its relatively higher level (i.e., between September 5 & 9) in MW-47, MW-88, & MW-69. MW-30 shows no evidence of any tidal fluctuations between September 5 & 9 but shows SOME minor fluctuations that may be tidally influenced during the period of GW rise on September 4-5, 2011.
There are greater tidal influences on more of the newly-installed monitoring wells than the initial set of wells with dataloggers. The well showing the maximum tidal influence is MW-43, followed by MW-79 & MW-04. None of the other monitoring wells show clear tidal influence.
Over the period between February 26 & March 12, 2011, there was observed tidal influences on the GW elevations in MW-79 & MW-68. Overall, the area of tidal influence includes MW-95 & MW-79 along the slough, MW-33, & to a lesser degree MW-04 to the north, & MW-89 & MW-85, which are located over 1000 feet upgradient of MW-95 & MW-79. Only minor tidal influence is observed in MW-91, which is completed through a relatively thick sequence of fine-grained materials.
Note to file: 18 AAC 75.345(f) states: GW that is closely connected hydrologically to nearby surface water may not cause a violation of the water quality standards in 18 AAC 70 for surface water or sediment.
Soil contamination was not found at the surface, except in one area to the south west near the former rail racks. The soil plume boundary is defined horizontally & vertically. Horizontally the various plumes have comingled & produced a nearly-site wide area of impact. Vertically the contamination is bounded at approximately 5’ below sea level. GW contamination is bounded horizontally, but not vertically. Like soil, the dissolved-phase plumes have comingled & produced a nearly site wide area of impact, with benzene extending to the eastern slough & ocean boundary. Due to the strong vertical gradient, it is likely that the dissolved-phase plume extends below the current depth of monitoring wells.
See site file for additional information.
|
Louis Howard |
| 2/22/2012 |
Document, Report, or Work plan Review - other |
Staff received and approved final Winter GW monitoring work plan via email. |
Louis Howard |
| 5/15/2012 |
Update or Other Action |
Staff reviewed and commented on the characterization report for Whittier. see site file for further details (18 page comment letter). |
Louis Howard |
| 6/22/2012 |
Document, Report, or Work plan Review - other |
Winter 2011-2012 GW Monitoring Report dated June 20, 2012 received. This report details groundwater monitoring activities conducted during February and March 2012 by OASIS Environmental, Inc. an ERM company. Monitoring was conducted to evaluate contaminate levels during a period of low groundwater. Activities included: retrieval and download of datalogging pressure transducers; measurement of groundwater depth; and collection of groundwater samples for contaminants of concern, monitored natural attenuation parameters and water quality parameters. Monitoring wells were assessed for usefulness and condition and following the completion of field activities a list of wells recommended for potential decommissioning was compiled.
Groundwater sample results indicated diesel-range organics, gasoline-range organics, and lead exceeded ADEC Table C groundwater cleanup levels in 16 monitoring wells. All other contaminants of concern analyzed for were either reported non-detect or at levels below ADEC cleanup levels.
The highest concentration of wells with COC exceeding cleanup levels occurred within the former vapor extraction system (monitoring well ID’s beginning with the well identifier “VE-”). Eleven former vapor extraction wells were sampled during March 2012 and four exceeded ADEC cleanup levels for DRO and 10 exceeded cleanup levels for GRO. However, as depicted in Figures 3 and 4, GRO and DRO results were observed both up and down gradient of the vapor extraction well cluster. Benzene results were not detected in any wells during this sampling event above associated ADEC cleanup levels.
The absence of high conductivity readings may imply a limited influx or contribution of salt water from nearby Prince William Sound. If salt water from the Sound was considerably infiltrating monitoring wells during this sampling event it is assumed conductivity readings would have been much higher. The maximum conductivity reading was recorded in MW-93 as was 4.692 mS/cm.
By way of comparison, sew water has a conductivity of about 56 mS/cm http://www.hannacan.com/conseils_EC_en.htm ). Groundwater up gradient from the site tends to be aerobic. For instance MW-83 contained 11.7 mg/L dissolved oxygen and MW-86 contained 9.69 mg/L dissolved oxygen. Low dissolved oxygen readings collected during February and March beneath and down gradient from areas of fuel contamination indicate that aerobic degradation of fuel is likely limited by the available oxygen supply.
Under these conditions if microbial degradation of contaminants was to occur, a different terminal electron acceptor (other than oxygen) would be required. MNA results do indicate consumption of such electron acceptors (manganese [Mn+4], sulfate, ferric iron, and nitrate) as well as the byproducts of these alternate respiratory processes. The presence of methane in large portions of the aquifer indicates that methanogenesis is occurring and that anaerobic conditions are present. Low, and frequently negative, OPR readings also indicate an anaerobic
environment. Contaminant concentrations in the most down gradient monitoring wells (MW-33, MW-77, MW-79, MW-92, and MW-94) were all below cleanup levels, indicating that MNA processes are limiting contaminant migration. |
Louis Howard |
| 7/3/2012 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the 2011 GW Monitoring report.
3.3 MNA and Water Quality Parameters
Correct text as follows: “By way of comparison, sea water has a conductivity of about 56 mS/cm.”
3.6 Well Decommissioning Recommendations
ADEC concurs with the text that wells recommended for decommissioning be removed from routine groundwater monitoring but left in place to allow for future sampling if necessary.
4 References
18 AAC 75 has been amended as of April 2012, please correct reference.
18 AAC 70 has been amended as of April 2012, please correct reference.
|
Louis Howard |
| 7/11/2012 |
Update or Other Action |
Draft comprehensive planning document received. This document is being provided to the Alaska Department of Environmental Conservation (ADEC) by the Defense Logistics Agency – Energy (DLA) in order to establish a framework and schedule for selecting a remedy to address environmental
contamination at the Defense Fuel Storage Point (DFSP) – Whittier, in Whittier, Alaska.
Over the past 20 years, numerous investigations have been conducted to define the nature and extent of contamination at the site. In addition, a variety of remedial technologies have been used to address site contamination. Selecting a remedy for the site is an important step in allowing DLA to fulfill its regulatory obligations at the site and ensuring that potential risks to human health and the environment are addressed. Upon receipt of ADEC comments on this document, it will be finalized to reflect those comments and form the basis for establishing a framework and schedule for selecting a remedy for the site.
Two groundwater monitoring events were conducted at high groundwater levels in 2011.
One groundwater monitoring event was conducted at low groundwater levels in March
2012. Each of these monitoring events collected samples from all monitoring wells
which could be safely accessed. Together the data present an accurate baseline of
current contaminant concentrations in groundwater.
Data from these events can be used to focus future groundwater monitoring events without causing a decrease in data quality. The following optimization steps are recommended; they are detailed below.
• Replace full list SW8260B analysis with BTEX-only analysis
• Limit total aromatic hydrocarbon (TAH) and TAqH analysis to tidal wells
• Modify groundwater sample collection techniques to minimize the potential for contaminant volatilization
• Decommission selected wells
• Eliminate 1,2-dibromoethane (EDB) analysis
Standards for TAH and TAqH are set in 18 AAC 70, Water Quality Standards. These
standards are directly applicable to fresh and marine surface water bodies. In addition, it
is not permissible to cause groundwater contamination that would result in an
exceedence of these standards in a surface water body.
Under high groundwater conditions, only MW-56 exceeded the TAH standard and only MW-43 exceeded the standard for TAqH.
TAH and TAqH are calculated based on the results of PAH and BTEX analysis. As discussed in the previous section, it is desirable to include BTEX analysis in future monitoring events. However, it is recommended that PAH analysis be limited to the tidally influenced wells as listed in the Winter 2011-2012 Groundwater Monitoring Work Plan. This would eliminate unnecessary data generation, but still allow assessment of potential impacts per the 18 AAC 70 standard. |
Louis Howard |
| 7/17/2012 |
Document, Report, or Work plan Review - other |
Staff provided commented on the draft comprehensive planning document.
2.2 GW Contamination at High & Low GW Levels
Notably absent is data from 2009 & 2010. Tetrachloroethene was detected in GW above Table C in monitoring wells MW-41 & MW-42 on 10/04/2010.
2.4.4 Biodegradation in the Saturated Zone (under High GW Conditions).
The text states that the analysis represents high GW flow conditions & may not be representative of conditions at low GW levels. ADEC concurs.
Upgradient: Monitoring well MW-83 has its well screen installed above the average low GW depth. MW-83’s screened interval is not appropriate for sampling at low GW events & not likely to be acceptable for demonstrating the presence or absence of contamination likely to be present during low GW events.
Crossgradient: Monitoring well MW-10 has its well screen installed above the average low GW depth. MW-10’s screened interval is not appropriate for sampling at low GW events & not likely to be acceptable for demonstrating the presence or absence of contamination likely to be present during low GW events.
3.1.1 Replace full list SW8260B Analysis with BTEX Analysis
ADEC disagrees. One more sampling round of full list SW8260B is required to demonstrate that volatile organic compounds (e.g. chlorinated solvents) are not present in GW above Table C. In 2010, tetrachloroethene was detected at 0.0058 mg/L which is above the 0.005 mg/L Table C GW cleanup level. This approach is consistent with ADEC’s approved GW monitoring requirements at other installations (i.e. JBER long-term GW monitoring program).
In these cases, monitoring would continue until GW contamination is no longer a threat to human health & the environment, verified by two years of consecutive sampling events where analytical results show that the contaminants of concern are less than the chemical-specific cleanup levels. Finally, during the final two rounds of GW monitoring, samples will be collected & analyzed for all of the contaminants of concern that ever exceeded Table C values during the previous site investigations. Therefore, ADEC will not approve replacing full list SW8260B analysis with BTEX analysis at this time. Especially since peristaltic pumps were historically used to sample wells where water was present above 25 feet from top of casing.
3.1.2 Limit TAH/TAqH analysis to Tidal Wells
ADEC requests text be added to this section to discuss whether or not total aromatic hydrocarbons/total aqueous hydrocarbons (TAH/TAqH) were ever exceeded during low GW conditions in any of the wells. ADEC reserves the right to require compliance monitoring in surface water for water quality standards (in addition to TAH/TAqH criteria) should data indicate sentinel wells are contaminated above water quality standards. ADEC concurs with the approach which will have to be formalized in a future decision document or long-term monitoring plan developed after the decision document.
See site file for additional information.
|
Louis Howard |
| 11/8/2012 |
Update or Other Action |
Draft 2012 Ecological Survey, Vertical Profiling, Surface Soil Sampling and Demolition Work Plan received.
Objectives of the tasks described in this work plan include:
• Assess potential ecological impacts due to site contamination to understand whether the site contamination is impacting down gradient surface waters;
• Collect depth-specific groundwater samples when groundwater levels are high to provide a better understanding of contamination in the deep aquifer and seasonal trends in contaminant concentrations;
• Asses surface soils and surface waters to understand whether surface soil contamination poses a potential human health risk and whether additional measures are necessary to prevent exposure; and
• Decommission remaining structures and equipment: pump house building, aboveground storage tank (AST), and several light towers.
All of the work outlined in this work plan is intended to support the broader goal of
selecting a permanent remedy to address site contamination.
On November 1, 2012, an OASIS field team performed a site walk around all wells to be sampled, performed brush clearing around the proposed demolition locations, and performed a hazardous building materials survey of the pump house in which samples were collected to be analyzed for asbestos and total lead of paint.
Groundwater and surface soil sampling will take place in November or December of 2012 along with the ecological assessment. The exact date of mobilization will be based on review and finalization of this document. However, all work associated with these tasks is scheduled to be completed prior to Christmas.
The decommissioning event will occur in April of 2013. OASIS will prepare a draft sampling report within 30 days of receipt of analytical results. |
Louis Howard |
| 11/14/2012 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft 2012 ecological survey, vertical profiling & surface soil sampling work plan.
1.4 Project Organization
SGS Environmental Services, Inc (SGS) Anchorage, AK is identified as the primary laboratory providing contaminated sites analyses. ADEC will require any “network”, subcontracted or backup laboratory to be current in their ADEC approvals for contaminated sites analyses that they are approved for. ADEC will request DLA provide a copy of the laboratory’s current ADEC approval letter. The letter will detail the methods, matrices, & dates for which the lab has approval. Labs must renew their approval & pass performance evaluation samples annually. Failure to do so results in the revocation of a lab's approval. SGS (UST-005) ADEC approval expires on December 18, 2012. The lab approval letter will be included as an appendix to the work plan. The laboratory shall also be current in their NELAP-certification.
2.1 Planning Documents
ADEC does not review nor approve health & safety plans, but will keep a copy on file for the record.
3.3.3 Surface Soil Sampling
Soil results which are above maximum allowable concentrations for GRO, DRO, RRO, & direct contact for benzene, toluene, ethylbenzene, total xylenes, & PAHs will need to be addressed in the top two feet. If the land ownership changes or the land use changes, then this approach will need to be readdressed by the RP & ADEC.
5 Quality Assurance
The ADEC laboratory data review checklist (currently amended as of September 2012) must be completed by DLA or the consultant for all data packages submitted to ADEC. The quality assurance (QA) summary must be included as a specific text section of the report. All laboratory results, including laboratory quality control (QC) sample results, must be reviewed & evaluated for quality, validity &
usability. The text must include any affects on data validity &/or usability due to field sampling & laboratory quality control discrepancies (Technical Memorandum “Environmental Laboratory Data & Quality Assurance Requirements” March, 2009).
4 General Comment
ADEC requests DLA be more specific on the type of fuel contaminants (e.g. DRO, GRO, BTEX, PAHs) will be tested to assess fuel concentrations in the soil underlying the AST. If there is any indication that either of the two transformers leaked, then DLA will test the underlying concrete or soil as applicable.
See site file for additional information.
|
Louis Howard |
| 3/7/2013 |
Update or Other Action |
Draft Work Plan Winter 2013 Groundwater Monitoring, dated March 2013 received for review & comment.
The proposed monitoring event discussed in this work plan will be scheduled to occur under low groundwater water conditions (typically February to March). Groundwater monitoring will be conducted & samples collected from 42 monitoring wells. After the March 2012 sampling event, 17 wells were recommended for decommissioning.
ADEC has also indicated that wells MW-83, MW-10, & MW-34 are not appropriate for sampling at low groundwater due to screen installations above the average low groundwater depth (OASIS, 2012a). A demolition event of the former pump house, AST, & light towers on the DFSP-W site is scheduled for April 2013. Following demolition, ERM will also attempt to sample the fire water well during the following sampling event.
Data generated will be used for evaluation of the contaminant plumes. Additional sample volumes will be submitted from a subset of 20 monitoring wells to develop data on MNA parameters.
In order to ensure that the March 2013 monitoring event is performed at a sufficiently low water level, ERM will carefully monitor weather conditions to identify the best possible time for sample collection.
Low flow sampling methodology will be used for groundwater monitoring & sample collection. Monitoring wells will be purged at a rate no greater than 500 milliliters per minute. Purge rates will be kept low enough to prevent water level drawdown from exceeding 0.3 foot. Monitoring wells will be purged & sampled using a variable speed submersible centrifugal pump. According to ADEC Draft Field Sampling Guidance, the submersible pump is a preferable method for VOC sample collection (ADEC, 2010). Water quality parameters will be measured during purging using a YSI 556 multiparameter meter & a flow-through cell. Multiparameter meters will be calibrated daily using manufacturer-recommended techniques.
PAH analysis will only be performed at the tidally influenced wells. These well are: MW-30, MW-69, MW-76, MW-93, MW-72, MW-77, MW-79, MW-91, MW-94, MW-95, MW-33, & MW-92.
To help better understand contaminate fate & transport under low groundwater conditions, ERM will collect additional MNA parameters from 20 wells as part of this field effort, including wells that were historically contaminated & wells located upgradient & down gradient from the known contamination plumes.
Assuming prompt approval of this work plan by DLA and ADEC, tracking of weather conditions in Whittier is scheduled to occur during the week of 18 March 2013. Mobilization is scheduled for the following week (25 March). It is anticipated that groundwater monitoring will require approximately 11 days. If the weather warms up above freezing during the monitoring event resulting in a significant rise in the groundwater table, the rest of the sample collection event may be postponed or cancelled until a period of low water level can be achieved.
Data from the two drinking water wells at the site will be important in assessing potential future use of these wells as drinking water sources. These wells lie upgradient of the site to the north and west. They are marked as “Drinking Water Well” and DW-01 of Figure 1. DW-01 lies within the avalanche risk area. Samples will be collected from these wells, even if it is necessary to collect these samples during a period of higher groundwater elevation.
To the extent practicable, samples from tidally influenced wells will be collected at low
(or as close to low) tide as possible. However, this will necessarily be balanced with other logistical priorities, such as snow clearance. The wells include MW-30, MW-69, MW-76, MW-93, MW-72, MW-77, MW-79, MW-91, MW-94, MW-95, MW-33, and MW-92. The Whittier 2013 tide table has been included in Appendix H.
Samples will be shuttled from Whittier to Anchorage for shipment every three days. A courier will travel to Whittier every other day to pick up samples, perform a quality assurance check of labels and custody forms, repack the coolers with fresh ice, prepare shipping paperwork, and deliver the samples.
|
Louis Howard |
| 3/12/2013 |
Update or Other Action |
Draft 2012-2013 summary report received.
As part of the ecological survey to investigate the beach downgradient of the site, an ERM field team surveyed the study & comparison areas. More live specimens were observed & collected from the comparison area beach transect (transect B). Additionally, the field crew noticed a high volume of rusty metal debris located throughout the study area of the beach (transect A) during the ecological survey.
Although no sheen was observed, there may have been some residual staining present due to the large amount of rusty metal debris. Collected data, however, is not conclusive & the differences between the study area & the comparison area illustrated in Tables 5 & 6 could be the result of other factors not associated with upgradient fuel contamination. Other factors resulting in the variability of the two transects include the following:
• Recreational use of the investigation areas;
• Changes in water regimes due to upgradient roads & parking lots;
• Preferential use of either investigation area by benthic predators; &
• Disproportionate freshwater contributions from upgradient sources between investigation areas.
It is recommended that an investigation be conducted during the 2013 spring or summer using a similar approach. Work should again be conducted at a spring low tide. One change in the approach is recommended based on lessons learned during this initial ecological assessment. Transects described here run from the water line (basically the lower low tide level) to the drift line.
Given the long screened length of the monitoring wells located at the DFSP-W site, analysis of historical GW monitoring data raised a question of whether the observed variation in contamination concentrations from low to high GW was really a function of time or if deeper sections of the aquifer are in fact contaminated throughout the year. The use of HydraSleeve GW samplers appears to have been an effective method for vertical profiling at the site. Based on analytical data from this vertical profiling effort, it appears that sections of the aquifer are in fact contaminated throughout the year.
Review of the data indicates that residual GW & soil contamination appears to be located primarily near the average low GW level. It is believed that this is because historically, when mobile free product was still present at the site, it migrated to this level under the influence of gravity. GW contaminant concentrations were below 18 AAC 75 Table C cleanup levels in both the shallower portions of the aquifer & at depths well below the average low GW level. As was detailed in the Comprehensive Planning Document, the primary sources of electron acceptors to biodegrade fuel at the site appear to be atmospheric oxygen diffusing into the vadose zone & the flushing action of changing GW levels pulling atmospheric air into the subsurface.
See site file for additional information.
|
Louis Howard |
| 4/10/2013 |
Document, Report, or Work plan Review - other |
Staff provided comments on the Hazardous Bldg. Materials Survey, Eco Survey, Vertical Profiling and Surface Soil Sampling Summary Report.
Table 1 Cleanup Levels
RRO-most stringent cleanup level is 8,300 mg/kg for ingestion and this value should be shaded not the 9,700 mg/kg migration to groundwater cleanup level.
3.1.2 Conclusions and Recommendations
ADEC concurs with the statements in this section.
3.2.2 Conclusions and Recommendations
ADEC concurs with the statements in this section and requests that any observed seeps be sampled for TAH and TAqH from any seeps observed at the same time the survey is conducted.
Handling of Non-Detects (NDs) in the summation of the Total Aromatic Hydrocarbons (TAH) and Total Aqueous Hydrocarbons (TAqH) Water Quality Standards for Contaminated Sites.
Until recently, the department had recommended one-half the Practical Quantitation Limit (PQL) be used to substitute for non-detect (ND) results when calculating and reporting TAH and TAqH for contaminated sites. The Contaminated Sites Program now recommends the following revised requirements for calculating TAH and TAqH for contaminated sites management:
For contaminated site projects where these water quality parameters will be reported, all
laboratory data reports must include reporting to the detection limit (DL) for each compound analyzed (BTEX and PAHs). TAH and TAqH summations should be calculated using the Limit of Detection (LOD) values for non-detects. If the laboratory data does not report a LOD, two times (2x) the Method Detection Limit (MDL) should be used for ND results.
If a compound is reported as estimated, e.g., J-flagged, the estimated value should be used to calculate and report TAH and TAqH, instead of the LOD. If the laboratory data only reports a PQL, then one-half the PQL level should continue to be substituted for NDs for summation calculations of TAH and TAqH [ADEC Technical Memorandum Guidelines for Data Reporting, Data Averaging, and Treatment of Non-Detect Values (June 2012)].
3.3.1 Results
The text refers to both primary and duplicate sample results. Be aware that ADEC requires the higher of the two be reported and used regardless if it is a primary or duplicate sample. ADEC regulates based on the maximum result or statistically valid 95% upper confidence limit (UCL) per 18 AAC 75.380(c)(1). Therefore, ADEC requires that the most conservative detectable sample result of the primary and duplicate results be used for management decision making purposes (ADEC Risk Assessment Procedure Manual Data reduction and field duplicate samples November 2011).
Be aware that for groundwater, the maximum detected value shall be used [18 AAC 75.380(c)(2) and a 95% UCL value is not allowed.
3.3.2 Conclusions and Recommendations
ADEC concurs with the statements in this section.
3.4.2 Conclusions and Recommendations
ADEC concurs with the statements in this section with the exception of the PAH above direct contact cleanup levels in the surface soil. It is requested that DLA excavate the benzo(a)pyrene detected at 0.932 mg/kg (sample ID 12-DLA-SO-31) and 0.477 mg/kg (Sample ID 12-DLA-SO-28). Existing institutional controls at the site for surface contamination will not suffice. |
Louis Howard |
| 5/14/2013 |
Update or Other Action |
Draft Summer 2013 GW Monitoring Work Plan received for review and comment.
Hydrasleeve samplers will be assembled and then installed in 9 selected monitoring
wells.
• The selected wells are VE-37, VE-40, VE-45, VE-46, MW-34, MW-68, MW-72, MW-74, and MW-89.
• Tidally influences wells will also be sampled for PAH. Of the 9 wells being sampled, MW-72 is the only tidally influenced well.
• Initially, the depth to groundwater and total well depth will be recorded. This information will be used to assemble the Hydrasleeve sampling string.
• Following an approximate 10-day period to allow groundwater within the well to return to equilibrium, the samplers will be retrieved and analytical samples will be collected.
• All locations will be analyzed by the laboratory for GRO, volatile organic compounds (VOC), DRO/ RRO, sulfate, sulfide, nitrate/nitrite, methane, dissolved lead, iron and manganese, total lead iron and manganese, and TOC.
The drink water well known as DW-01 was scheduled to be sampled during the March 2013 low-groundwater sampling effort. Heavy snowfall and blizzard conditions made sampling at this location impossible due to avalanche concerns. ERM plans to return to DW-01 during the summer 2013 field effort to collect MNA and contaminant analytical samples.
Ecological Survey of Tidelands
• The team will identify the study area and comparison area where groundwater discharges to surface water along the beach.
• During a seasonal low tide, one transect will be marked in both the study and comparison areas. The transects be roughly horizontal to the spring low tide water line. The transects will be laid out so as to intersect zones where groundwater appears to be discharging to surface water. Two to four macroinvertibrate samples will be collected along the transect length.
• A clam gun, shovel, or post-hole digger will be used to sample sediment along each transect line to look for macroinvertebrates. Macroinvertibrate samples will be approximately 10 centimeter (cm) in diameter by 10-20 cm in depth. Sediment will be placed into marked Ziploc® bags or buckets to be washed and evaluated after collection.
• Samples will be stored in an insulated cooler. Samples will be taken back to the field trailer, rinsed, and sieved over a fine mesh screen, and species will be counted and identified to the lowest possible taxa. Magnifying binoculars, a dissecting scope and/or a magnifying lamp will be used. Field guides will be used for identification.
• All field-collected data will be recorded in a designated field notebook. The survey will be photo-documented (and if necessary video-documented) and will serve as baseline data against which future survey results could be compared.
To best evaluate the conditions of discharge and transition zones, the assessment will be
conducted during a seasonal low tide. Based on predicted low tides, the investigation is
scheduled to occur between June 23, 2013 and June 25, 2013. |
Louis Howard |
| 5/20/2013 |
Document, Report, or Work plan Review - other |
ADEC has received the final version of the 2012-2013 Hazardous Building Materials Survey, Ecological Survey, Vertical Profiling, and Surface Soil Sampling Summary Report (ADEC CS DB Hazard ID 1314) on April 26, 2013. ADEC has reviewed the document and has no further comments on it. The document is approved. |
Louis Howard |
| 6/3/2013 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft GW monitoring work plan.
Drink Water Well Sampling
Please clarify in the text whether well DW-01 is being used for drinking water purposes or any other purpose, including but not limited to irrigation, fire control, dust control, or any activity on a temporary, intermittent or permanent basis. If this well is used for providing drinking water, then sample collection and laboratory analyses for water collected from drinking water sources must be done in accordance with 18 AAC 80 and appropriate drinking water methods by a laboratory certified by the State of Alaska for drinking water analysis. For contaminated sites, the most common methods will be VOCs by Method 524.2 and SVOCs by Method 525.2.
A complete list of drinking water certified laboratories and the specific methods they are approved for can be found on the Environmental Health website at: http://www.dec.state.ak.us/eh/lab/index.htm.
For example, drinking water samples must be analyzed by the appropriate drinking water analytical methods as follows:
Volatile Organic Compounds (including BTEX, 1,2-DCA, MTBE); EPA 524.2
Ethylene Dibromide (EDB): EPA 504.1
Semi volatile Organic Compounds (including PAHs): EPA 525.2
Polychlorinated Biphenyls (PCBs), Pesticides: EPA 508.1
Metals: EPA 200.8
The text states: “Appendix F provides a comparison of the 18 AAC 75 Table C groundwater cleanup level and the SGS Detection Limit and Limit of Detection for each analyte. Contaminants for which the detection limit is higher than the cleanup level (1,2,3-trichloropropane and 1,2-dibromomethane) are highlighted.”
Unless there is previous analysis with EPA Method 504.1 or SW 8011, to definitively rule out 1,2,3-TCP and 1,2-dibromoethane [a lead scavenger and required analysis for releases from waste oil, aviation gasoline, leaded gasoline (MOGAS) and unknown releases], either use EPA Method 504.1 or EPA Method 8011 and not SW8260 which is not acceptable for EDB analysis . Please provide a reference for the historical EDB results below cleanup levels if applicable for the well(s) being samples.
See site file for additional information.
|
Louis Howard |
| 6/7/2013 |
Update or Other Action |
Draft Biosparge work plan received for review and comment.
This work plan was prepared by ERM Alaska, Inc. (ERM [formerly OASIS Environmental, Inc.]) on behalf of Defense Logistics Agency – Energy (DLA) for conducting biosparge and biovent pilot studies to address contamination that has migrated downgradient from the Defense Fuel Support Point – Whittier (DFSP-W) in Whittier, Alaska.
The objectives of the activities described in this work plan are presented below:
• Determine if biosparging and/or bioventing are feasible remediation alternatives to address off-property fuel contamination at DFSP-W.
• Determine if increased oxygen into the vadose and saturated zone will enhance biodegradation of fuel contamination.
• Collect the necessary information to determine full-scale system design parameters including biovent and biosparge pressures, flow rates, and well spacing required to address off-property, downgradient fuel contamination.
The scope of work described in this work plan is presented below:
• Install a single vent/sparge well in a highly contaminated area located downgradient and off-property.
• Install ten pilot test monitoring points (six biosparge monitoring points and 4 biovent monitoring points).
• Conduct a biosparge pilot test to determine the required discharge pressure and flow rate and the zone of influence in the saturated zone.
• Conduct a biovent pilot test to determine the required discharge pressure and flow rate, radius of influence, and required oxygen for biodegradation in unsaturated zone.
|
Louis Howard |
| 6/24/2013 |
Update or Other Action |
Draft ICs plan received for review & comment.
The purpose of this document is to lay the groundwork for redevelopment of the site in a manner that provides for continued protection of human health in light of the contamination & the goals of the various stakeholders:
• DLA
• City of Whittier
• ADEC
• ARRC
• Department of the Army (DOA)
• (USACE)
The CSM for the DFSP-W property identifies the following potentially complete exposure pathways for the site: incidental soil ingestion, dermal absorption of contaminants in soils, dermal adsorption of GW, & ingestion of GW. The CSM for contamination downgradient of the DFSP-W property identifies ingestion & dermal adsorption of GW as potentially complete exposure pathways.
It is recommended that the feasibility study consider remedial alternatives to address surface soil contamination & near surface soil contamination associated with Tank 813. ERM recommends amending some of the ICs for the site in consideration of the current extent & location of contamination, CSMs, & current & future zoning determinations for the Head of Passage Canal. As recommended by ADEC, layering of ICs is an effective means of limiting exposure to human health.
Recommendations, therefore, include:
• An informational deed notice,
• Propriety controls regulating actions on the DFSP-W property, &
• Governmental controls applicable to the site’s zoning
• Periodic reviews of the effectiveness of the ICs, once they are established
It is recommended that a deed notice be filed with the state recorder’s office to notify interested parties concerning the nature & extent of contamination & providing contact information (DLA & ADEC) should the party want additional information.
See site file for additional information.
|
Louis Howard |
| 7/24/2013 |
Document, Report, or Work plan Review - other |
Staff provided review comments on the Defense Fuel Support Point – Whittier Institutional Controls Plan.
Executive Summary
The text states: “USACE, acting on behalf of the Department of the Army, may transfer the property to the City of Whittier in accordance with Public Law 111-383. The City of Whittier has indicated the desire to move ahead with property transfer in accordance with Public Law 111-383.”
The Department of the Army may be able to get the City of Whittier or others to take over management of the institutional controls (ICs) if they acquire the land, but the Department of the Army would still have responsibility for the residual contamination & should set up the ICs in a manner that provides for them to enforce the controls.
1 Introduction
DLA must also comply with the Land Use Controls (LUCs) as specified in the DoD Manual for DERP Management dated March 9, 2012 (or the most recent version) NUMBER 4715.20. See pages 41-43 for
(1) LUCS Associated with Environmental Restoration Activities for Active Installations; &
(2) LUCs Associated with Environmental Restoration Activities on Property Being Transferred Out of Federal Control [More applicable to DFSP-Whittier]: a. Pre-Transfer, b. At Transfer, c. Post Transfer.
For example:
Page 41
4. DoD ERP
(b)Environmental Process
(17) LUCs. LUCs may be required while conducting environmental restoration investigations, during implementation of remedial actions, or after remedial actions are complete.
(a) The DoD Component shall put appropriate mechanisms in place to manage LUCs for which they are responsible. They shall incorporate LUCs into the land use mgt systems for installations or shall seek incorporation of LUCs into the land use mgt processes of the locality for FUDS or property being transferred out of Federal control. The DoD Component should use a layering strategy or system of mutually reinforcing controls to implement LUCs effectively.
Also see DUSD(ES/CL) January 17, 2001 Memorandum – Subject: Policy on LUCs Associated with Environmental Restoration Activities & see EPA’s Institutional Controls: A Guide to Planning, Implementing, Maintaining, & Enforcing ICs at Contaminated Sites, Interim Final, OSWER 9355.0-89, November 2010. The purpose of this EPA guidance is to provide site managers of contaminated sites, site attorneys, & other interested parties with information & recommendations that should be useful for planning, implementing, maintaining, & enforcing ICs for Comprehensive Environmental Response, Compensation, & Liability Act (CERCLA, or Superfund); Brownfields; federal facility; underground storage tank (UST); & Resource Conservation & Recovery Act (RCRA) site cleanups.
The text states: “However, contaminant concentrations at the site exceed values that will allow for unlimited use & unrestricted exposure (UU/UE ). Thus, continued protection of human health & the environmental at the site will likely depend on the development & enforcement of appropriate ICs.”
DLA should specify at this point what the expected use will be in order to develop & enforce appropriate ICs (e.g. commercial or industrial land use).
Future Land Use at the Head of the Passage Canal
The City anticipates designating the head of Passage Canal as a Planned Unit Development (PUD) under Chapter 17 of the Whittier Municipal Code. The intent of this designation is to allow flexibility in an area where standard commercial development is balanced with a mix of open space & recreational areas.”
The Planned Unit Development (PUD) for the DFSP-W property shall be restricted to commercial &/or industrial land uses as defined by 18 AAC 75.990 or recreational uses [as defined at 18 AAC 75.990(19) “commercial or industrial land use”].
|
Louis Howard |
| 8/6/2013 |
Update or Other Action |
Winter GW Monitoring report received.
In 2012 however, nine locations exceeded GRO cleanup levels, eight locations exceeded DRO cleanup levels, and four exceeded lead cleanup levels. As documented during the 2012 March event, benzene results were again not detected in any wells during this sampling event above associated ADEC cleanup levels. These well are: MW-30, MW-69, MW-76, MW-93, MW-72, MW-77, MW-79, MW-91, MW-94, MW-95, MW-34, MW-33, and MW-92.
PAH analysis was performed at all tidally impacted wells shown in Figure 2. Results were compared to both 18 AAC 75 Table C groundwater cleanup levels and 18 AAC 70 water quality standards. 18 AAC 70 standards for TAH and TAqH were calculated to provide an initial understanding of whether ecological impacts may be of concern. PAH results collected from the tidally influenced wells identified in Figure 2 were used to calculate TAH and TAqH concentrations and are presented in Table 6. Monitoring wells MW-30, MW-69, MW-72, and MW-77 exceeded 18 AAC 70 Water Quality Standards for TAH (0.010 mg/L). Monitoring well MW-72 also exceeded the above referenced standard for TAqH (0.015 mg/L).
Although the 18 AAC 70 criteria were developed for surface water, groundwater samples were collected to predict potential sources of ecological impact from daylighting groundwater. Surface water samples may be collected during the summer 2013 from any seeps located downgradient of these wells during the summer Ecological Impact Study (ERM 2013c). These samples will be collected for PAHs and BTEX and used to calculate TAH and TAqH concentrations. These results will be compared to data collected during these 2013 winter groundwater sampling activities.
MNA results varied across the site and between monitoring well locations, however the only parameter not regularly detected by the laboratory was total nitrate/nitrite (EPA Method 4500NO3 F). Compared to 2012, dissolved iron was also noticeably absent from multiple wells. Total nitrate/nitrite was also noticeably absent in laboratory results from March 2012. Sulfide, which was present in almost every sample submitted in 2013, was not however a widely detected parameter in 2012. A discussion of MNA results is included in Table 3-1. MNA Calculations and a more detailed discussion has been included in Appendix G.
Water quality parameters were collected at each monitoring well during purging activities at three to five minute intervals up till sample collection. Table 5 presents the final readings for water quality parameters prior to sample collection. Noticeable trends observed from these final readings include predominately low conductivity, low dissolved oxygen and low (frequently negative positive) ORP readings.
See site file for additional information.
|
Louis Howard |
| 8/23/2013 |
Update or Other Action |
Draft Feasibility Study received for review & comment.
Soil COPCs include DRO, GRO, BTEX, benzo(b)fluroanthene, benzo(a)pyrene, & lead. Of 132 samples collected, only one location contained lead above this concentration. A surface soil sample from BH-09 exhibited a lead concentration of 770 mg/kg.
The following COPCs are listed with the maximum detection & cleanup levels listed:
• DRO has been detected up to 17,300 mg/kg (migration to GW cleanup level 230 mg/kg).
• GRO has been detected up to 7,200 mg/kg (migration to GW cleanup level 260 mg/kg).
• Benzene has been detected up to 13.4 mg/kg (migration to GW cleanup level 0.025 mg/kg).
• Benzo(b)fluroanthene has been detected up to 6.02 mg/kg (direct contact cleanup level 4.0 mg/kg).
• Benzo(a)pyrene has been detected up to 2.28 mg/kg (direct contact cleanup level 0.40 mg/kg).
Approximately 410,000 cubic yards of soil is expected to exist in the smear zone. An estimated 620,000 gallons of fuel exist in this portion of the soil matrix.
Based on the COPC screening process described in the DFSP - Whittier Institutional Controls Plan (ERM 2013b), COPCs in GW are DRO, GRO, lead, & benzene. DRO is the most wide-spread contaminant, however, elevated levels of GRO, & benzene have been recorded at concentrations above 18 AAC 75.345 Table C GW cleanup levels:
• DRO has been detected up to 214 mg/L (cleanup level 1.5 mg/L).
• GRO has been detected up to 165 mg/L (cleanup level 2.2 mg/L).
• Benzene has been detected up to 0.216 mg/L (cleanup level 0.005 mg/L).
See site file for additional information.
|
Louis Howard |
| 8/30/2013 |
Document, Report, or Work plan Review - other |
Staff provided review comments on the draft FS for the site.
2.1 Investigation Summary
The text states: “Extensive site investigation and remediation work has been performed at the site to evaluate sub-surface conditions. Environmental site characterization began in 1991 with an investigation by Ecology and Environment.”
ADEC requests DLA provide the citation in section 9 for the 1991 Ecology and Environment site characterization and note it in the text (e.g. Ecology and Environment. Whittier Fuel Terminal Site Investigation Project Report. January 1993. CONTRACT NO: DACA85-91-D-0003 DELIVERY ORDERS NOS. 2 AND 15).
Table 1 Summary of Soil Contamination
Footnotes to the tale state: “This estimated does not include soil contaminated with benzene and GRO, but not with DRO.”
This sentence does not make any sense. ADEC requests the Defense Logistic Agency (DLA) clarify which contaminant is being referenced and whether it applies to “Volume of Contaminated Soil” or “Volume of Fuel in Soil”. Perhaps another footnote is needed to keep the “Volume of Contaminated Soil” and “Volume of Fuel in Soil” separated.
2.3 Soil Contamination Summary
The text states that benzo(b) fluoranthene and benzo(a)pyrene exceed the direct contact cleanup levels. Please state whether these contaminants are in the surface soil [0-2’ below ground surface (bgs)] or subsurface (2-15’ bgs).
2.4.1 Groundwater Contamination near the Smear Zone
The text states: “DRO is the most wide-spread contaminant, however, elevated levels of GRO, and benzene have been recorded at concentrations above 18 AAC 75.345 Table C groundwater cleanup levels:…”
Please provide the context of the time the wells were sampled, e.g. 2010-2013 or 1991-2013) so the reader has an idea on when the DRO was detected at 214 mg/L, GRO at 165 mg/L and benzene at 0.216 mg/L. It makes a bit of a difference if these were recent results in 2012/2013 or from an earlier sampling event in 1991 and the actual site conditions are much lower. The detailed summary in the ICs Plan would be more informative to the reader; however some context is needed in this document.
See site file for additional information.
|
Louis Howard |
| 9/12/2013 |
Document, Report, or Work plan Review - other |
Staff reviewed DLA's responses to ADEC's comments. The comments were deemed acceptable and the Feasibility Study may be finalized. |
Louis Howard |
| 12/18/2013 |
Update or Other Action |
GW monitoring recommendations received for review and comment.
GW monitoring recommendations were developed considering the ADEC Draft Field Sampling Guidance (May 2010) & site-specific data. Volatile GW contaminants are present at the site. The ADEC guidance recommends the use of bladder pumps, positive pressure submersible pumps, gear pumps, passive diffusion bag samplers, or samplers like HydraSleeve or Snap Samplers to reduce the loss of volatiles during sampling. Passive diffusion bag samplers will not work for semivolatile & non-volatile contaminants that are present at the site. Snap Samplers were previously investigated & will not provide sufficient sample volume. Thus samples could be collected using either low flow techniques or HydraSleeve samplers.
Both low-flow sampling during low GW & HydraSleeve sampling during high GW have potential to provide meaningful data needed to assess contaminant concentrations, plume size, & contaminant fate & transport. However, the monitoring well network at the DFSP-W site is highly variable. In some cases, wells are screened above the average low GW level & have been recommended for decommissioning. Various other wells have extremely long screened intervals & samples collected via low–flow sampling techniques are highly influenced by vertical gradients & potential dilution effects. This is particularly true at high GW levels. The remaining wells at the site are well suited for low flow sampling during low ground water levels, & use of HydraSleeve samplers at these wells would be unnecessary. For determination of appropriate sampling techniques ERM recommends a well-by-well analysis with additional input from ADEC. A recommended procedure is outlined below:
Assessment of vertical GW flows could be conducted.
Additional monitoring with pressure transducers could be conducted. Pressure transducers were placed into wells in November of 2013. Continued monitoring with pressure transducers could be useful for continued study of the site’s hydrology.
ERM also recommends placement of in-well flow meters within select wells to measure vertical GW flow within those wells.
Each well within the DFSP-W monitoring well network could be evaluated for the most effective approach for determining contaminant concentrations (low-flow sampling vs. HydraSleeve samples, appropriate sample collection depth).
Separate evaluation could be conducted for low & high GW levels.
See site file for additional information.
|
Louis Howard |
| 7/31/2014 |
Update or Other Action |
Winter GW monitoring report received for review and comment. During the March 2014 sampling event, three monitoring wells were either damaged (monitoring well or monument severely jacked) or obstructed (assumed frozen) above depths determined to be the well casing bottom.
Samples collected from three monitoring wells in March 2014 (MW-72, MW-05, and VE-45) reported contaminant concentrations above ADEC cleanup levels. These contaminants include GRO in the sample from MW-72, at a concentration of 2.2 mg/L; and lead in samples from MW-05 and VE-45, at concentrations of 0.0524 mg/L and 0.0188 mg/L, respectively. GRO and lead contaminant concentrations were also detected above cleanup levels during the March 2013 low groundwater sampling event; however, exceedances were detected at different monitoring well locations. Lead
concentrations in March 2013 were detected above cleanup levels at four locations (MW-59, MW-61, MW-93, and VE-37). GRO concentrations in March 2013 were detected above cleanup levels at one location (MW-68).
Monitoring wells MW-69 and MW-77 exceeded 18 AAC 70 Water Quality Standard of 0.010 mg/L for TAH. Monitoring well MW-69 also exceeded the Water Quality Standard of 0.015 mg/L for TAqH.
A recommendation that full list SW8260B (VOC) analysis be replaced with BTEX analysis only was first presented in the Comprehensive Planning Document finalized in September 2012 (DLA 2012). ADEC provided comments in response to the Comprehensive Planning Document and advised one additional sampling event to demonstrate “VOCs (e.g. chlorinated solvents) are not present in groundwater above Table C.” Review of analytical data since 2012 confirms that there have not been any exceedances above 18 AAC 75 Table C cleanup levels for VOCs, with the exception of
benzene, in any of the samples collected at high or low groundwater. Given the results of the last 4 sampling events, there is no reason to continue monitoring using full list SW8260B analysis indefinitely.
ADEC policy for eliminating a contaminant as a COC requires verification based on two years of consecutive sampling events where analytical results show the COC’s concentration to be less than the chemical-specific cleanup level. As these requirements have been met, ERM recommends that full list SW8260B analysis be replaced with BTEX analysis. It should be noted that during the final two rounds of groundwater monitoring before site closure, ADEC policy requires that samples be collected and analyzed for all of the COCs that ever exceeded 18 AAC 75 Table C cleanup levels
during the previous site investigations. |
Louis Howard |
| 7/31/2014 |
Update or Other Action |
Biosparge & Biovent Pilot Study received for review & comment.
BIOSPARGE & BIOVENT FULL SCALE DESIGN
CONSIDERATIONS
The DFSP-W is a complex site. Remediation at the site faces significant hurdles:
• The contamination is generally deep, at or below the water table, making excavation & ex situ remediation impractical.
• The extent of contamination is very large (approximately 20.5 acres) & the mass of fuel contamination is high.
• The majority of the contamination is trapped as immobile droplets in the smear zone.
• The water table can rise rapidly, as much as 25 feet in a 24 hour period.
Historically, a number of remedial technologies have been used to address fuel contamination at the site. These technologies include air sparging, free product recovery, steam sparging, soil vapor extraction, & excavation & offsite disposal. However, as detailed in the Comprehensive Planning Document, the available data suggests that naturally occurring processes have been more effective at decreasing contaminant mass than these active remedial technologies (OASIS 2012c). Monitored natural attenuation calculations indicate that diffusion of air from the atmosphere & changing GW elevations periodically pulling air into the vadose zone is resulting is significant rates of aerobic biodegradation of fuel. However, the rate of fuel biodegradation appears to be limited by the availability of oxygen. For this reason, enhancing the subsurface supply of oxygen (using either biosparging or bioventing) appears to be the most practical method of reducing the mass of contaminants at the site.
An advantage of biosparging is that it is feasible to operate a biosparging system at the site throughout the entire year & operation of a biosparge system would not be limited by water elevation. Although the ZOI attained in the biosparge pilot study (18 feet) is reasonable for biosparging, the relatively small ZOI compared to the large area of contamination would require hundreds of wells to cover the contaminated areas of the site. Full scale design of sparge well screen lengths could be adjusted to span different lithologies which may slightly improve the ZOI, but is unlikely to significantly increase the overall performance. In addition, effective biosparging relies on transferal of atmospheric oxygen to GW; the rate of transfer is limited by the low solubility of oxygen in water (approximately 12.58 mg/L) & the lithology of the site. Data from the pilot test suggests that oxygen transfer is relatively inefficient, with most oxygen passing out of the aquifer in air bubbles, rather than dissolving in GW.
See site file for additional information.
|
Louis Howard |
| 8/8/2014 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft GW monitoring report.
ADEC requests the use of the CS Database Hazard ID 1314 as well as the file number which can change. The Hazard ID never changes.
ADEC requests the center of the former DFSPW’s latitude and longitude (e.g. 61.xxxxxx 149.xxxxxx), date of collection be referenced in the text as well as the datum (i.e. WGS84 or NAD83 are preferred).
The text states: “Groundwater at the site discharges to Passage Canal.” The text should state: “Groundwater at the site discharges to a surface water body (Passage Canal). Therefore, 18 AAC 70 Water Quality Standards (2012) are also applicable at the site. “Groundwater that is closely connected hydrologically to nearby surface water may not cause a violation of the water quality standards in 18 AAC 70 for surface water or sediment [18 AAC 75.345(f)]. Where groundwater at a site is determined to be hydrologically connected to surface water, it must meet the more stringent or more protective of either the Table C criteria in 18 AAC 75 or the Alaska Water Quality Standards under 18 AAC 70 in order to be protective for use as a drinking water source and to protect potential ecological receptors.
Add another table for surface water quality criteria: TAH and TAqH and their cleanup levels.
Conceptual Site Model Overview
ADEC requests a few sentences be dedicated to ecological risk and a CSM model be developed or at the very least an ecological scoping form (Appendix C of the ADEC Ecoscoping Guidance March 2014) be filled out which demonstrates any potential or current risk to ecological receptors from the site.
ADEC requests the text clarify on whether or not there are any known endangered or threatened species are present or within the vicinity of the site.
This systematic evaluation includes “off-ramps” from the scoping process at various steps, thereby reducing the level of effort required for many sites. For example, it may be unnecessary to evaluate habitat, contaminant quantity, and toxicity if no terrestrial or aquatic exposure routes are present.
It is important to note that, with the exception of endangered or threatened species, ecological risks are evaluated on a population basis. The formal ecological definition of a population is a group of organisms within the same species that freely interbreed. Trying to define this at a site is not expected during a scoping level evaluation.
The area of contamination is probably the greatest issue, but concentration or sheer quantity should also be considered, especially if the compounds are persistent and bioaccumulative. Bioaccumulative compounds may affect species beyond the area of contamination because they accumulate in the food chain and the food chain is mobile.
|
Louis Howard |
| 8/8/2014 |
Document, Report, or Work plan Review - other |
Staff provided comments on the pilot studies report.
Introduction
1st Paragraph
The text states: “The Alaska Department of Environmental Conservation (ADEC) File No. for the DFSPW project is 2114.38.011.”
ADEC requests the use of the CS Database Hazard ID 1314 as well as the file number which can change. The Hazard ID never changes.
Biosparge and Biovent Full Scale Design Considerations
There needs to be a discussion among DLA and ADEC project managers with regards to the application of bioventing at DFSP – Whittier and continued MNA with LTM of groundwater monitoring especially with the limited treatment window of 2 – 3 months for treatment. The downside of such treatment is that 9-10 months of the year there would be no active treatment when water levels are too high and cover contaminated soil within the vadose zone.
|
Louis Howard |
| 8/25/2014 |
Document, Report, or Work plan Review - other |
ADEC has reviewed the responses to comments on the Whittier GW Report. The responses are acceptable. Finalize the document. |
Louis Howard |
| 9/10/2014 |
Document, Report, or Work plan Review - other |
Staff provided comments on the Draft Decision Document dated August 2014.
2.15.7 Table of Contents
Five Year Reviews
ADEC requests the heading be changed to “Periodic Reviews” instead of Five Year Reviews. Comment applies throughout document.
1.1 Site Name & Location
The text states: “The Alaska Department of Environmental Conservation (ADEC) File No. for the DFSP-W project is 2114.38.011.”
ADEC request the identifier for DFSP-W also include the contaminated sites database hazardID which is 1314 in addition to the file number.
1.2 Statement of Basis & Purpose
The text states: “ADEC concurs with the selected remedy.
ADEC requests DLA use this text instead:
“ADEC agrees that the remedy selected, when properly implemented, for petroleum sites complies with Alaska state law.”
1.4 Description of the Selected Remedy Cleanup Action
ADEC requests DLA remove reference to “remedial action objectives (RAOs)” & replace it with “cleanup levels” throughout the document.
ADEC requests DLA strike text “No additional active remediation is planned for contamination remaining the DFSP-W property.”
The text states: “The available data suggest that contaminants are not currently…”
ADEC requests DLA remove the word “suggest” from the sentence & replace with demonstrates.
3rd Bullet
ADEC requests DLA change the text to state: “Until cleanup levels are attained, periodic reviews (no less than every 5 years)…”
See site file for additional information.
|
Louis Howard |
| 9/12/2014 |
Update or Other Action |
High Water Groundwater Sampling plan received for review and comment.
The groundwater monitoring event scheduled for October of 2014 will apply the same vertical profiling and targeted depth sampling methodology as executed in 2012 and 2013, but on a site-wide scale. Data collected from this investigation will provide the most comprehensive vertical delineation of contamination performed at the site thus far.
To better characterize the depths of contamination within sections of the aquifer, depth specific
samples will be collected from 43 monitoring wells. This is planned to include all of the monitoring wells at the DFSP-W site with the exception of those scheduled for decommissioning and Drink Water Well # 1 which will be under repairs.
ADEC advised one additional sampling event to demonstrate “VOCs are not present in groundwater above Table C.” Review of analytical data since 2012 confirms that there have not been any exceedances above 18 AAC 75 Table C cleanup levels for VOCs, with the exception of benzene, in any of the samples collected at high or low groundwater. Per ADEC’s guidance, VOC analysis has
been replaced in this work plan with BTEX analysis.
Wells exhibiting such high turbidity are recommended for redevelopment. DFSP-W wells noted for high turbidity are MW-61, MW-59, Drinking Water Well #2, MW-23, MW-74, MW-47, MW-76, MW-30, MW-32, MW-68, MW-72, MW-84, MW-88 and MW-93. Given the likelihood that groundwater monitoring will be necessary for many years, it seems prudent to ensure well integrity remains high.
One to three HydraSleeve® samplers will be deployed per well; at depths believed to be within the contaminated portion of the aquifer. Duplicate samples will likely be collected among the sampled wells and collected per analyte/sample container to ensure enough volume is present to collect duplicates for every analytical method. Once deployed, the HydraSleeve® samplers will remain in place for approximately 7 to 10 days to allow groundwater within the well to return to equilibrium. The samplers will be retrieved after this time and analytical samples will be collected. All locations will be analyzed by the laboratory for GRO, BTEX, DRO/ residual-range-organics (RRO), dissolved and total lead. Tidally influences wells will sampled for polycyclic
aromatic hydrocarbons (PAH). These wells are: MW-30, MW-69, MW-76, MW-93, MW-72, MW-77, MW-79, MW-91, MW-94, MW-95, MW-33, and MW-92. |
Louis Howard |
| 3/3/2015 |
Update or Other Action |
Draft GW monitoring report received for review & comment.
Review of the video files indicated subsurface well-casing damage was not present in any of the assessed wells; however, debris was observed in various wells & included the following:
• Plastic Bailers in wells MW-04, MW-10, & MW-80,
• Pressure Transducers in wells MW-30, MW-33, MW-69, & MW-85, &
• HydraSleeve® Samplers in vapor extraction wells VE-45 & VE-46.
Possible clogging of screened intervals was observed in 7 of the wells (MW-15, MW-32, MW-33, MW-67, MW-69, MW-74, & VE-41). Clogging at this site is generally caused by biofouling associated with the presences of naturally-occurring iron &/or manganese, as well as bacteria. Biofouling consists of biofilms which include living & dead bacteria, their sheaths, stalks, secretions, & embedded metal hydroxide particles. Biomass accumulation associated with the biodegradation of certain target substances, such as fuels, may also be a cause of biofouling at this site.
Dissolved oxygen (DO) results ranged from 0.23 milligrams per liter (mg/l) (MW-68 at 31’ btoc) to 14.95 mg/l (MW-30 at 25’). Areas of relatively lower oxygen concentrations can sometimes be attributed to microbial fuel degradation &/or organic matter consumption by aerobic respiration. For instance MW-34, MW-68, & the Fire Water Well had relatively low DO concentrations of 2, 1.8, & 0.23 mg/l, respectively, & exceeded GCLs for certain fuel-related contaminants.
MW-91 & MW-95 also had low DO concentrations, but did not contain elevated concentrations of fuel-related contaminants; however, the environment in which the wells were installed is currently heavily vegetated & likely contains buried organic matter. It should be noted that the majority of the wells contained relatively high concentrations of DO, which is beneficial to microbial bioremediation.
Free Product was detected in well MW-72.
Benzene exceeded the 18 AAC 75 Table C GCL of 0.005 mg/l at wells FWW (0.009 mg/l) & MW-68 (0.00596 – 0.00802 from five depth intervals).
DRO exceeded the 18 AAC 75 Table C GCL of 1.5 mg/l at three depth intervals in well MW-34 (3.23 to 7.51 mg/l).
Lead exceeded the 18 AAC 75 Table C GCL of 0.015 mg/l at three wells; FWW (0.0241 mg/l)[same well exceeded benzene cleanup level), MW-77 (0.0250) & MW-30 (0.0323 mg/l).
See site file for additional information.
|
Louis Howard |
| 3/9/2015 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft 2014 high water groundwater monitoring report.
3.2 Collection of Depth-Specific Water-Quality Parameters
The text state: “In addition, 6 of the wells were deeper than 60 feet and were not able to be assessed beyond the 60-foot reach of the probe and cable.”
ADEC requests Defense Logistics – Energy (DLA) ensure that they have a longer cable for reaching the bottom of the wells (e.g. 90’ or longer cable).
3.4 Groundwater Sample Collection
The text states: “All samples were immediately placed into a cooler with gel ice, maintaining the required temperature range (0°C to 6°C).”
Sample receipt form for Lab report# 1145420 notes that cooler temperature was 6.1 C. All samples which require thermal preservation shall be considered acceptable if the arrival temperature is either within 2°C of the required temperature or the method specified range. For samples with a specified temperature of 4°C, samples with a temperature ranging from just above the freezing temperature of water to 6°C shall be acceptable. Samples that are hand delivered to the laboratory on the same day that they are collected may not meet these criteria. In these cases, the samples shall be considered acceptable if there is evidence that the chilling process has begun such as arrival on ice (DOD QSM 4.2 2010 5.8.3.1 Sample Receipt Protocols).
ADEC requests DLA to provide clarification on whether the samples associated with SDG 1145420 were received by the laboratory with ice still present in the cooler.
3.6 Drinking Water Well #1 Assessment and Repair
The text states: “A new well seal was installed, but the cast-iron vault cover and retainer ring were not replaced.”
ADEC requests DLA to clarify in the text of the document whether or not the iron vault cover and retainer ring will be replaced for this well.
3.7 Recording of Downhole Camera Observations
The text states: “Review of the video files indicated subsurface well-casing damage was not present in any of the assessed wells; however, debris was observed in various wells and included the following:
• Plastic Bailers in wells MW-04, MW-10, and MW-80,
• Pressure Transducers in wells MW-30, MW-33, MW-69, and MW-85, and
• HydraSleeve® Samplers in vapor extraction wells VE-45 and VE-46.
Possible clogging of screened intervals was observed in seven of the wells (MW-15, MW-32, MW-33, MW-67, MW-69, MW-74, and VE-41).”
ADEC requests DLA to provide clarification in the text on whether the presence of the debris will hinder future sampling and whether or not the debris can be removed from the wells. If sampling is hindered and debris cannot be removed, then ADEC will request that DLA decommission the wells and reinstall monitoring replacement wells for each well decommissioned to be documented in a work plan for ADEC review and approval. The same request applies to those wells that have clogged screened intervals (i.e. MW-15, MW-32, MW-33, MW-67, MW-69, MW-74, and VE-41).
App. D ADEC Checklists
Laboratory reports: 1145397, 1145398, 1145420, & 1145434
Laboratory Sample Receipt Documentation
Question: d. If there were any discrepancies, were they documented? - For example, incorrect sample containers/preservation, sample temperature outside of acceptance range, insufficient or missing samples, etc.?
Answer: Yes.
Merely answering "Yes" does not help the reader on what discrepancies there were. ADEC requests DLA to elaborate in a similar manner as was done for Lab report# 1145396 on why the answer is “Yes”.
|
Louis Howard |
| 4/20/2015 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (ADEC) has received the revised document: 2014 High Groundwater Monitoring Report Defense Fuels Supply Point – Whittier Dated February 2015, on April 20, 2015. The responses to comments have been satisfactorily addressed. The final version of this document is approved by ADEC.
|
Louis Howard |
| 11/19/2015 |
Document, Report, or Work plan Review - other |
Staff reviewed and approved the 2016 High GW Monitoring report.
ADEC looks forward to receipt of the draft work plan for installation of additional groundwater monitoring wells to supplement the existing monitoring well network currently in place at the site as recommended in ERM’s November 3, 2015 letter. |
Louis Howard |
| 5/2/2016 |
Document, Report, or Work plan Review - other |
Staff reviewed the High GW monitoring work plan.
Main comments were regarding use of updated regulations and guidance, use of a registered professional surveyor or professional engineer for surveying, and quality assurance reviews must also comply with the tech memo on lab data and quality assurance requirements (2009).
See site file for additional information. |
Louis Howard |
| 8/29/2016 |
Update or Other Action |
Staff provided comments on the draft remedial implementation (action) work plan. Main comments were to ensure that the work is conducted by an qualified environmental professional as defined by 18 AAC 75.333 for the vapor intrusion investigation. Also commented on the need to coordinate with EPA Region 10 UIC program and seek determination whether or not the biovent wells are Class 5 injection wells. Finally, staff notified DLA that prior approval is required by ADEC for any transport for disposal and/or treatment of contaminated media from the site.
See site file for additional information. |
Louis Howard |
| 11/17/2016 |
Document, Report, or Work plan Review - other |
Staff provided comments on the winter GW monitoring plan.
Main comments were to evaluate the wells for decommissioning that have reported blockages in them and to assess whether or not replacement wells will need to be installed or will nearby wells serve as replacements. Other comments were made to include analysis and report on petroleum related VOCs not just BTEX.
See site file for additional information. |
Louis Howard |
| 12/28/2016 |
Update or Other Action |
Summer High Groundwater (GW) Level report received for review & comment. May 2016 GW contamination concentrations are consistent with those measured in 2015 & as shown in recent years, few wells consistently display contamination concentrations above cleanup levels. The previously defined contamination up gradient of MW-34 was not evident based on analytical data collected during summer (high) GW monitoring this year; nor has the shape of the contaminant plume been reflected year to year in the results (2012 – 2016).
The 2015 & 2016 summer (high) GW monitoring results are quantitatively comparable; some contaminant concentrations were higher, while some contaminant concentrations were lower in summer 2016 versus summer 2015. Variability in concentrations could be due to redistribution, GW flushing through the Site, dissolution (LNAPL into the aqueous phase), volatilization (gaseous phase), dispersion, sorption, or biodegradation. Approximately 6,000 gallons of fuel are estimated to biodegrade each year (DLA. 2016). It appears the GW contamination levels in monitoring wells BS-06 & FSW are reducing as levels of benzene measured during the 2016 field effort were an order of magnitude lower than those recorded in 2015.
Lead concentrations in monitoring wells appear to be reduced to no detectable concentrations or no results above cleanup levels reported from both 2015 & 2016 field efforts. Monitoring wells MW-05, MW-30, MW-77, BS-06, & FSW where reductions were observed are all sampled using traditional low flow sampling methodologies (without a packer) & GW elevation was higher in May 2016 than August 2015, so dilution could have played a role in benzene & lead reductions.
See site file for additional information. |
Louis Howard |
| 1/10/2017 |
Document, Report, or Work plan Review - other |
Comments on the draft summer (high) GW monitoring report. Main comments were on requiring Petroleum-VOCs via Method 8260: Cyclohexane, N-Hexane, Propylbenzene, 1,2,4-Trimethylbenzene for the next two future sampling events in addition to the analytes being currently analyzed for at the site. It should be noted in the text that twenty GRO samples were analyzed between 6 and 44 hours past the holding times for AK101 analysis requirements. Therefore, the results are biased low and will not be used for any statistical trend analysis (e.g. Mann-Kendall) or general discussion purposes of groundwater contamination trends.
20 Samples past holding times: 16-DFSPWH-BS-06, 16-DFSPWH-FSW, 16-DFSPWHMW-05, 16-DFSPWH-MW-34,
16-DFSPWH-MW-47, 16-DFSPWH-MW-69, 16-DFSPWHMW-71, 16-DFSPWH-MW-83, 16-DFSPWH-MW-83 MS, 16-DFSPWH-MW-83 MSD, 16-DFSPWH-MW-84, 16-DFSPWH-MW-92, 16-DFSPWH-MW-92 MS, 16-DFSPWH-MW-92 MSD, 16-DFSPWH-MW-93, 16-DFSPWH-TB-03, 16-DFSPWH-MW-102 (HydraSleeve™ duplicate of 16-DFSPWH-MW-47), 16-DFSPWH-MW-103 (Solinst 407 bladder pump duplicate of 16-DFSPWH-MW-71), 16-DFSPWH-MW-110 (duplicate of 16-DFSPWH-FSW), and 16-DFSPWH-MW-111 (equipment blank).
See site file for additional information. |
Louis Howard |
| 8/28/2017 |
Update or Other Action |
Draft Final Remedial Implementation Work Plan received with new appendix B "Draft Vapor Intrusion Work Plan".
Information presented in the approved 2016 decision document indicates vapor intrusion at the Site could be an issue if buildings are constructed in the future. Historical data collected at the Site is insufficient to determine the potential for future vapor intrusion; therefore, CES-AQVIQ will collect soil gas data in accordance with ADEC Vapor Intrusion Guidance (ADEC. 2017a) proximal to the former loading rack and monitoring well MW-08. The field work is proposed to occur concurrently with the remedial well installation. Should vapor intrusion be identified as an issue at the Site, the DLA will propose and implement an appropriate institutional control (IC).
Bioventing (BV) causes air to flow through the subsurface, but treatment of contaminants takes place in situ rather than aboveground, thereby reducing remediation costs. Naturally occurring microorganisms in the unsaturated zone biodegrade the contaminants. BV airflow rates need to be sufficient to provide oxygen to the microorganisms, which are usually oxygen limited, but slow enough to allow sufficient contaminant residence times in the subsurface and minimize volatilization losses to areas outside the treatment zone. BV does not rely on volatilization, and therefore is appropriate for semivolatile compounds that are aerobically biodegradable, as it focuses on the treatment of soil contaminants and soil vapors within the unsaturated zone prior to their release to the atmosphere. A BV system consists of one or more extraction or injection wells screened in the unsaturated zone, blowers or vacuum pumps, and often also includes air injection or pressure venting wells.
See site file for additional information. |
Louis Howard |
| 9/13/2017 |
Document, Report, or Work plan Review - other |
Staff provided comments on the Remedial Implementation WP App. B VI Work Plan included in the draft final version of the work plan. Main comments were to give a heads up on the pending rescinding of the deep soil gas target level in ADEC guidance for vapor intrusion and to compare soil gas levels to the shallow soil gas levels. Other comments were made on the vapor assessment sampling procedures for soil gas with permanent probes.
See site file for additional information. |
Louis Howard |
| 10/11/2017 |
Update or Other Action |
WP for groundwater monitoring received. There are 3 phases to the work plan. three separate phases of work which are listed below.
Collection of groundwater data and analytical samples. High groundwater levels at the Site are defined when the groundwater level within monitoring well MW-30 is higher than 10 feet below mean sea level (which also corresponds to 30' below top of casing). Monitoring well MW-30 is a tidally influenced well, with substantial groundwater depth variation depending on temperature and precipitation. High groundwater levels occur in early- spring through summer (May through October) during maximum recharge from rain and snowmelt.
Decommission of vapor extraction wells VE-37, VE-41, VE-45, and VE-46 in accordance with the Alaska Department of Environmental Conservation (ADEC) Monitoring Well Guidance (ADEC 2013). This phase of work includes the decommissioning of the “Red Pipe” near Tank 813 and will be discussed in an Addendum to this Work Plan prepared under separate cover.
Replacement and repair of select monitoring wells. This phase of work will be discussed in an Addendum to this Work Plan prepared under separate cover.
See site file for additional information. |
Louis Howard |
| 10/19/2017 |
Update or Other Action |
Work plan addendum received for review and comment. The addendum addresses three tasks to be completed. Decommissioning of four vapor extraction wells and three groundwater monitoring wells in accordance with the Alaska Department of Environmental Conservation (ADEC) Monitoring
Well Guidance (ADEC. 2013). This phase of work includes the decommissioning of the “Red
Pipe” near Tank 813. Repair surface completions of six wells. Installation of three replacement groundwater monitoring wells.
See site file for additional information. |
Louis Howard |
| 3/15/2018 |
Document, Report, or Work plan Review - other |
Staff commented on the draft low groundwater sampling plan. Main comment was to ensure that for the polynuclear aromatic hydrocarbon analyses it analyzes and reports 1-methylnaphthalene and 2-methylnaphthalene.
See site file for additional information. |
Louis Howard |
| 6/1/2018 |
Document, Report, or Work plan Review - other |
Staff commented on the draft High GW monitoring plan. Main comments were on the use of Mann-Kendall for trend analysis and to use DRO results below 5 mg/L. See site file for additional information. |
Louis Howard |
| 6/4/2018 |
Offsite Soil or Groundwater Disposal Approved |
Staff approved transport of contaminated soil and GAC material to NRC Alaska. |
Louis Howard |
| 8/30/2018 |
Document, Report, or Work plan Review - other |
Staff commented on the draft LOW groundwater monitoring report. Main comments were regarding trend analysis for contaminants detected during the low and high groundwater level monitoring events in preparation for the 2021 five year review. Either Mann-Kendall or linear regression was suggested for performing this trend analysis.
See site file for additional information. |
Louis Howard |
| 3/5/2019 |
Document, Report, or Work plan Review - other |
Staff commented on the low water groundwater sampling plan. Main comments were to be sure to calculate total aromatic and total aqueous hydrocarbons for non-detects by using 1/2 of the practical quantitation limit not the method detection limit. |
Louis Howard |
| 5/13/2019 |
Document, Report, or Work plan Review - other |
Staff commented on the low water groundwater sampling report. Main comments were on repair or replace damaged well MW-87 and use of a peristaltic pump for volatile samples in groundwater will cause the results to be viewed as biased low. Lastly, staff requested the wells actively being monitored be resurveyed as part of the next groundwater monitoring contract (since this one is expiring soon) in accordance with ADEC well sampling guidance.
See site file for additional information. |
Louis Howard |
| 6/11/2019 |
Document, Report, or Work plan Review - other |
Staff reviewed responses to comments and found them satisfactory. Requested comments be incorporated into the final version of the report. |
Louis Howard |
| 8/20/2019 |
Document, Report, or Work plan Review - other |
Staff approved the Summer groundwater monitoring work plan. |
Louis Howard |
| 11/22/2019 |
Update or Other Action |
Staff received the draft remedial action implementation Report draft for review and comment. The remedial system uses bioventing to address petroleum contamination in soil. In-situ respiration rates are monitored at three well casings at three intervals: deep interval-2' above average low groundwater elevation, intermediate interval-center of the air injection zone for that area and the shallow interval-5' below ground surface. Due to the data being collected outside of true low groundwater elevations, it is not recommended to be used as baseline data. Collection of additional data prior to operation in 2020 is recommended. The vapor points were sampled on August 20, 2019 and the results will be presented under separate cover in November 2019 following data validation.
See site file for additional information. |
Louis Howard |
| 1/13/2020 |
Document, Report, or Work plan Review - other |
Staff reviewed and approved the draft Summer (High) Groundwater Monitoring Report.
See site file for additional information. |
Louis Howard |
| 1/13/2020 |
Document, Report, or Work plan Review - other |
Staff reviewed and approved the Low Groundwater Monitoring work plan dated December 2019. |
Louis Howard |
| 4/8/2020 |
Document, Report, or Work plan Review - other |
Staff reviewed the draft Low Groundwater Monitoring Report. Main comments were on to decommission the two wells MW-87 & MW-95 that are damaged and can't be sampled. Other comment was to request that all wells actively being sampled be resurveyed by a registered professional surveyor or registered professional engineer. Last comment was to request a Mann-Kendall statistical analysis be conducted for the "low" groundwater monitoring reports. |
Louis Howard |
| 9/29/2020 |
Update or Other Action |
DEC's Brunner approved gauging of MW-30 for the fall groundwater sampling event via email to the Defense Logistics Agency (DLA). DLA indicated it would submit a draft workplan for the groundwater sampling event itself in the near future. |
Melinda Brunner |
| 1/26/2021 |
Update or Other Action |
Staff reviewed the Low Groundwater Monitoring work plan dated January 2021. ADEC had three comments to the report. First comment was to add ADEC Contaminated Sites Database File ID 2114.38.011 and Hazard ID 1314 to the report, second to update the reference to reflect the current, March 2020, version of the 18 AAC 75 Oil and Other Hazardous Substances Pollution Control Statues and Regulations, and Third to add the "± 10% for turbidity" parameter is missing from the check list for the water quality stabilization requirements. Comment letter sent to Responsible Party on January 25, 2021. |
Daniela Fawcett |
| 1/27/2021 |
Update or Other Action |
On January, 27, 2021 ADEC reviewed and approved the Final 2021 Winter Low Groundwater Monitoring Work Plan, Defense Fuel Support Point – Whittier dated January 2021. |
Daniela Fawcett |
| 2/1/2021 |
Update or Other Action |
DEC reviewed and approved, by email, a request by the Alaska Volcano Observatory (AVO) to temporarily install monitors at the site, and confirmed compliance with the institutional controls. Email sent to the AVO, Defense Logistics Agency (responsible party) and U.S. Army (current landowner). |
Melinda Brunner |
| 3/4/2021 |
Update or Other Action |
Staff reviewed the High Groundwater Monitoring Report, dated February 2021. ADEC had two comments to the report. First comment was to correct the number of pressure transducers used to download well data. Second comment requested to add more historical information about the site. |
Daniela Fawcett |
| 4/15/2021 |
Update or Other Action |
On April 15, 2021 ADEC reviewed and approved the Final 2020 Winter High Groundwater Monitoring Report, Defense Fuel Support Point – Whittier dated February 2021. |
Daniela Fawcett |
| 5/13/2021 |
Update or Other Action |
DEC reviewed and provided comments to the U.S. Army on a draft quitclaim deed and Uniform Environmental Covenants Act covenant. The Defense Fuel Support Point Whittier site is made up of property owned by the U.S. Army and the Alaska Railroad Corporation. The U.S. Army is completing these documents in support of it's intent to transfer it's parcel to a new landowner. The covenant will run with the land, and document the institutional controls required (i.e. groundwater and soil restrictions). |
Melinda Brunner |
| 7/7/2021 |
Update or Other Action |
On July 7, 2021 ADEC reviewed and approved the Final 2021 High Groundwater Monitoring Work Plan for the Defense Fuel Support Point in Whittier, dated June 2021. |
Daniela Fawcett |
| 8/25/2021 |
Update or Other Action |
On August 25, 2021 ADEC approved the Final 2021 Winter Low Groundwater Monitoring Report, Defense Fuel Support Point – Whittier, dated July 2021. |
Daniela Fawcett |
| 2/11/2022 |
Document, Report, or Work plan Review - other |
On February 4, 2022 ADEC approved the Final first Five-Year Review Report, Defense Fuel Support Point – Whittier, dated January 2022. |
Daniela Fawcett |
| 3/8/2022 |
Update or Other Action |
On March 8, 2022 ADEC approved the Final 2022 Low Groundwater Monitoring Work Plan, dated January 2022. |
Daniela Fawcett |
| 8/1/2022 |
Document, Report, or Work plan Review - other |
ADEC reviewed and submitted comments regarding the 2022 High Groundwater Monitoring Work Plan, Defense Fuel Support Point – Whittier, dated July 2022. The objectives of the 2022 high groundwater monitoring and sampling effort are to assess current concentrations of contaminants of concern (COCs) in groundwater at the site, determine the current groundwater flow direction and gradient, and ensure ongoing monitoring well usability. Groundwater samples will be collected from 27 wells and analyzed for, diesel range organics (DRO), gasoline range organics (GRO), residual range organics (RRO), benzene, toluene, ethylbenzene, total xylenes (BTEX), polycyclic aromatic hydrocarbons (PAH), inorganic lead, and the following select volatile organic compiunds (VOCs): isopropylbenzene (cumene), naphthalene, styrene, n-butylbenzene, sec-butylbenzene, tert-butylbenzene, 1,2,4-trimethylbenzene and 1,3,5-trimethylbenzene. |
Ginna Quesada |
| 8/18/2022 |
Document, Report, or Work plan Review - other |
ADEC approved the Final 2022 High Groundwater Monitoring Work Plan, Defense Fuel Support Point – Whittier, dated August 2022. |
Ginna Quesada |
| 11/1/2022 |
Lien Recorded |
On 8/25/2022 A Quit Claim Deed (QCD) and Uniform Environmental Covenant (UECA) were executed and recorded for Anchorage-Whittier POL Pipeline (AKA: Defense Fuel Support Point-Whittier) Whittier, Alaska. The documents summarize petroleum or petroleum storage release or disposal, extend of remaining contamination, land use restrictions/Institutional Controls, ongoing long-term monitoring and access agreements. See attachments for more detail. |
Daniela Fawcett |
| 12/23/2022 |
Document, Report, or Work plan Review - other |
DEC reviewed and emailed comments to the Defense Logistics Agency – Energy for the Draft 2022 Low Groundwater Monitoring Report, Defense Fuel Support Point, Whittier Dated November 2022.
The report recommends to continue semi-annual groundwater monitoring for the site until contaminants reduce below their respective DEC groundwater cleanup levels, and to remove eight monitoring wells from the current sampling program, based on review of historical contaminant concentrations in groundwater samples collected from 38 wells during the high and/or low groundwater monitoring events between 2016 and 2022. |
Daniela Fawcett |
| 12/23/2022 |
Document, Report, or Work plan Review - other |
DEC reviewed the 2022 High Groundwater Monitoring Report, Defense Fuel Support Point, Whittier Dated July 2022. Comments were sent to DLA. |
Daniela Fawcett |
| 12/23/2022 |
Document, Report, or Work plan Review - other |
DEC reviewed the 2022 High Groundwater Monitoring Report, Defense Fuel Support Point, Whittier Dated July 2022. Comments were sent to DLA. |
Daniela Fawcett |
| 1/18/2023 |
Document, Report, or Work plan Review - other |
On 01/18/2023 DEC approved the 2021 High Groundwater Monitoring Report, Defense Fuel Support Point, Whittier Dated January 2023. |
Daniela Fawcett |
| 1/18/2023 |
Document, Report, or Work plan Review - other |
On 01/18/2023 DEC approved the 2021 High Groundwater Monitoring Report, Defense Fuel Support Point, Whittier Dated January 2023. |
Daniela Fawcett |
| 1/18/2023 |
Document, Report, or Work plan Review - other |
On 1/18/2023 DEC approved the Final 2022 DFSP-Low Groundwater Monitoring report, January 2023 |
Daniela Fawcett |
| 1/31/2023 |
Document, Report, or Work plan Review - other |
on 01/31//2023 DEC reviewed the Draft 2023 Low Groundwater Monitoring Work Plan, Defense Fuel Support Point – Whittier, dated January 2023. |
Daniela Fawcett |
| 2/1/2023 |
Document, Report, or Work plan Review - other |
On 02/01/2023 DEC approved the Final 2023 Low Groundwater Monitoring Work Plan, Defense Fuel Support Point – Whittier, dated February 2023.
The objectives of the 2023 low groundwater monitoring and sampling effort are to assess current concentrations of contaminants of concern (COCs) in groundwater at the site, determine the current groundwater flow direction and gradient, and ensure ongoing monitoring well usability. |
Daniela Fawcett |
| 2/1/2023 |
Document, Report, or Work plan Review - other |
On 02/01/2023 DEC approved the Final 2023 Low Groundwater Monitoring Work Plan, Defense Fuel Support Point – Whittier, dated February 2023.
The objectives of the 2023 low groundwater monitoring and sampling effort are to assess current concentrations of contaminants of concern (COCs) in groundwater at the site, determine the current groundwater flow direction and gradient, and ensure ongoing monitoring well usability. |
Daniela Fawcett |
| 6/19/2023 |
Document, Report, or Work plan Review - other |
DEC reviewed and provided comments regarding the Former Defense Fuel Support Point, Whittier, Alaska, 2022 High Groundwater Monitoring Report, Draft, dated January 2023. The report describes the groundwater monitoring activities and sampling results for twenty-seven monitoring wells at the Former Defense Fuel Support Point site located in Whittier, Alaska. The work was performed to evaluate contaminants of concern during the high groundwater event in October of 2022. Only one monitoring well (BS-06) had contaminant concentrations that exceeded 18 AAC 75.345 Table C values for gasoline range organics (GRO) and naphthalene.
|
Ginna Quesada |
| 7/3/2023 |
Document, Report, or Work plan Review - other |
DEC approved the Former Defense Fuel Support Point, Whittier, Alaska, 2022 High Groundwater Monitoring Report, Final, dated June 2023. |
Ginna Quesada |
| 7/17/2023 |
Document, Report, or Work plan Review - other |
DEC reviewed and provided comments for the Former Defense Fuel Support Point, Whittier, Alaska, 2023 Low Groundwater Monitoring Report, Draft, dated June 2023. The report describes the groundwater monitoring activities and sampling results for twenty-one monitoring wells at the Former Defense Fuel Support Point site located in Whittier, Alaska. The work was performed to evaluate contaminants of concern during the low groundwater event in March of 2023. Multiple wells continued to have contaminant concentrations that exceeded 18 AAC 75.345 Table C values for lead and petroleum compounds. |
Ginna Quesada |
| 7/21/2023 |
Document, Report, or Work plan Review - other |
DEC provided comments for the Defense Fuel Support Point, Whittier, Alaska, 2023 High Groundwater Monitoring Work Plan, Draft, dated July 2023. The work plan describes the planned groundwater monitoring and sampling activities at the Former Defense Fuel Support Point site located in Whittier, Alaska. The monitoring wells will be analyzed for gasoline range organics (GRO), diesel range organics (DRO), residual range organics (RRO), polyaromatic hydrocarbons (PAHs), volatile organic compounds (VOCs), and total lead. |
Ginna Quesada |
| 7/25/2023 |
Document, Report, or Work plan Review - other |
DEC approved the Former Defense Fuel Support Point, Whittier, Alaska, 2023 Low Groundwater Monitoring Report, Final, dated July 2023. |
Ginna Quesada |
| 8/16/2023 |
Document, Report, or Work plan Review - other |
DEC approved the Defense Fuel Support Point, Whittier, Alaska, 2023 High Groundwater Monitoring Work Plan, Final, dated August 2023. |
Ginna Quesada |
| 8/29/2023 |
Document, Report, or Work plan Review - other |
DEC approved the Turnagain Marine Construction Whittier Cruise Ship Terminal Gas Line Soil Management Work Plan Defense Fuel Support Plan Whittier, Alaska, dated July 17, 2023. The work plan describes the soil management and analytical sampling protocols for soil encountered during excavation activities for the installation of a buried natural gas line in Whittier, Alaska. Clean and potentially contaminated soil will be segregated during excavation activities. If contaminated soil is encountered, it will be analyzed for gasoline range organics (GRO), diesel range organics (DRO), residual range organics (RRO), polyaromatic hydrocarbons (PAHs), petroleum volatile organic compounds (VOCs), and total lead prior to transport or disposal. |
Ginna Quesada |
| 11/20/2023 |
Document, Report, or Work plan Review - other |
DEC provided review comments for the "Turnagain Marine Construction Whittier Cruise Ship Terminal Workplan Addendum Defense Fuel Support Site Whittier, ADEC File No. 2114.38.011, Hazard ID 1314" (Dated November 3, 2023) to the City of Whittier and their contractors. The work plan is an addendum under the Turnagain Marine Construction Whittier Cruise Ship Terminal Enstar Natural Gas Line Soil Management Workplan (dated July 17, 2023). The additional work is for additional road repairs and monitoring well decommissioning and re-installation of wells in the restoration program for the Whittier site. |
Erica Blake |
| 12/6/2023 |
Document, Report, or Work plan Review - other |
DEC has provided approval for the "Turnagain Marine Construction Whittier Cruise Ship Terminal Workplan Addendum Defense Fuel Support Site Whittier" (Dated November 28, 2023) to the City of Whittier and their contractors. The work plan is an addendum under the "Turnagain Marine Construction Whittier Cruise Ship Terminal Enstar Natural Gas Line Soil Management Workplan" (dated July 17, 2023). Work conducted under the original work plan is expected to continue December 2023, with work described in the work plan addendum planned to be conducted spring 2024. The work plan addendum describes activities associated with road repairs and monitoring well decommissioning and re-installation activities for the monitoring wells to be impacted from the construction work. |
Erica Blake |
| 2/2/2024 |
Document, Report, or Work plan Review - other |
Submitted comments on Former Defense Fuels Support Point Whittier, Alaska 2023 High Groundwater Monitoring Report Draft dated December 2023. The sampling report describes results from samples collected during a high groundwater monitoring event September 2023 at the Defense Fuel Supply Point site in Whittier, Alaska. Samples collected were analyzed for gasoline range organics (GRO), diesel range organics (DRO), residual range organics (RRO), benzene, toluene, ethylbenzene, and total xylenes (BTEX), volatile organic compounds (VOCs), and polynuclear aromatic hydrocarbons (PAHs). The following analytes exceeded cleanup levels: DRO, GRO, and naphthalene. Groundwater elevations were calculated to determine groundwater flow and gradient at the site during the 2023 fieldwork. |
Brian Watts |
| 2/23/2024 |
Document, Report, or Work plan Review - other |
Letter sent approving Former Defense Fuels Support Point Whittier, Alaska 2023 High Groundwater Monitoring Report Final dated February 2024. The sampling report describes results from samples collected during a high groundwater monitoring event September 2023 at the Defense Fuel Supply Point site in Whittier, Alaska. Samples collected were analyzed for gasoline range organics (GRO), diesel range organics (DRO), residual range organics (RRO), benzene, toluene, ethylbenzene, and total xylenes (BTEX), volatile organic compounds (VOCs), and polynuclear aromatic hydrocarbons (PAHs). The following analytes exceeded cleanup levels: DRO, GRO, and naphthalene. Groundwater elevations were calculated to determine groundwater flow and gradient at the site during the 2023 fieldwork. ADEC concurs with recommendations of further groundwater monitoring. |
Brian Watts |
| 2/28/2024 |
Document, Report, or Work plan Review - other |
DEC provided review comments for Defense Fuels Support Point – Whittier, Alaska 2024 Low Groundwater Monitoring Work Plan Draft dated January 2024. The work plan describes upcoming plans for groundwater monitoring and groundwater gradient assessment during a low groundwater event at the Defense Fuel Supply Point site in Whittier, Alaska. Samples will be collected from 24 monitoring wells and analyzed for the following analytes: benzene, gasoline range organics (GRO), diesel range organics (DRO), lead, residual range organics (RRO), polycyclic aromatic hydrocarbons (PAHs) and the following volatile organic compounds (VOC): toluene, ethylbenzene, total xylenes, isopropylbenzene, naphthalene, n-butylbenzene, sec-butylbenzene, tert-butylbenzene, styrene, 1,2,4-trimethylbenzene, and 1,3,5-trimethylbenzene. In addition to sample collection, the groundwater gradient elevation will be evaluated. |
Brian Watts |
| 3/13/2024 |
Document, Report, or Work plan Review - other |
DEC approved Defense Fuels Support Point-Whittier, Alaska 2024 Low Groundwater Monitoring Work Plan Final-dated March 2024. The work plan describes upcoming plans for groundwater monitoring and groundwater gradient assessment during a low groundwater event at the Defense Fuel Supply Point site in Whittier, Alaska. Samples will be collected from 24 monitoring wells and analyzed for the following analytes, benzene, gasoline range organics (GRO), diesel range organics (DRO), lead, residual range organics (RRO), polycyclic aromatic hydrocarbons (PAHs) and the following volatile organic compounds (VOC), toluene, ethylbenzene, total xylenes, isopropylbenzene, naphthalene, n-butylbenzene, sec-butylbenzene, tert-butylbenzene, styrene, 1,2,4-trimethylbenzene, and 1,3,5-trimethylbenzene. In addition to sample collection, the groundwater elevation will be measured to determine the gradient. |
Brian Watts |
| 6/28/2024 |
Document, Report, or Work plan Review - other |
DEC provided comments for the Contaminated Soil Work Plan Whittier Head of the Bay Electrical Project E2214130 (dated June 11, 2024) to the City of Whittier and their contractors regarding planned construction work at the Defense Fuel Support Point site. Several comments were made for clarification on the soil management plan. Construction work is expected to start as soon as work plan comments are resolved. |
Erica Blake |
| 7/5/2024 |
Document, Report, or Work plan Review - other |
DEC provided approval for the "Contaminated Soil Work Plan Whittier Head of the Bay Electrical Project E2214130 (dated July 2, 2024). All responses to comments were accepted, and the soil management work plan had appropriately revised and incorporated sections for clarification on the planned work. During this construction project, groundwater is not expected to be encountered but if it is, DEC has requested work be stopped until coordination with DEC's Division of Water on dewatering is completed. |
Erica Blake |
| 7/5/2024 |
Document, Report, or Work plan Review - other |
DEC provided comments for the Defense Fuels Support Point – Whittier, Alaska 2024 High Groundwater Monitoring Work Plan Draft Dated June 2024. Samples will be collected from 20 monitoring wells and analyzed. In addition, the groundwater gradient elevation will be evaluated and well repairs and maintenance will be conducted. One monitoring well will be decommissioned. Pre-event gauging at MW-30 will determine high groundwater elevation (approximately 20 feet above mean sea level) and then fieldwork will begin. |
Brian Watts |
| 8/9/2024 |
Long Term Monitoring Workplan or Report Review |
DEC provided approval for the "Defense Fuels Support Point – Whittier, Alaska 2024 High Groundwater Monitoring Work Plan, Final (dated July 2024)" to the Defense Logistics Agency. The work plan describes groundwater sampling activities planned to be conducted in Whittier, Alaska. This work plan was for groundwater sampling during a high groundwater event. High groundwater is defined as groundwater approximately 20 feet above mean sea level, which typically occurs between April and November each year. Work under this work plan is expected to occur late summer/fall 2024. |
Erica Blake |
| 12/17/2024 |
Long Term Monitoring Workplan or Report Review |
DEC reviewed and provided comments for the Former Defense Fuel Support Point, Whittier, Alaska, 2024 Low Groundwater Monitoring Report, Draft, dated August 2024. The report describes the groundwater monitoring activities and sampling results for twenty-one monitoring wells at the Former Defense Fuel Support Point site located in Whittier, Alaska. The work was performed to evaluate contaminants of concern during the low groundwater event in April of 2024. Multiple wells continued to have contaminant concentrations that exceeded 18 AAC 75.345 Table C values for lead and petroleum compounds. |
Juliana Smit |
| 1/27/2025 |
Long Term Monitoring Workplan or Report Review |
DEC reviewed and provided responses to the Defense Logistic Agency's responses to DEC comments for the Former Defense Fuel Support Point, Whittier, Alaska, 2024 Low Groundwater Monitoring Report, Draft, dated August 2024. |
Juliana Smit |
| 2/14/2025 |
Long Term Monitoring Workplan or Report Review |
DEC approved the Former Defense Fuel Support Point, Whittier, Alaska, 2024 Low Groundwater Monitoring Report, Final, dated February 2025. The report is for the low groundwater monitoring activities and sampling results for twenty-one monitoring wells at the Former Defense Fuel Support Point site located in Whittier, Alaska. The work was performed to evaluate contaminants of concern during the low groundwater event in April of 2024. Multiple wells continued to have contaminant concentrations that exceeded 18 AAC 75.345 Table C values for lead and petroleum compounds. |
Juliana Smit |
| 3/14/2025 |
Long Term Monitoring Workplan or Report Review |
ADEC reviewed and provided comment on the 2025 Low Groundwater Monitoring Work Plan Addendum for the Former Defense Fuel Support Point, in Whittier, Alaska. This addendum to the 2024 Low Groundwater Monitoring Work Plan provides updates and clarifications for the 2025 low groundwater monitoring event at the DFSP in Whittier, Alaska. Samples will be collected from 24 monitoring wells and analyzed for the following analytes: benzene, gasoline range organics (GRO), diesel range organics (DRO), lead, residual range organics (RRO), polycyclic aromatic hydrocarbons (PAHs). Significant changes from the 2024 Low Groundwater Monitoring Work Plan include two matrix spike duplicates being collected to achieve the required 5% sampling frequency and investigations into the status of monitoring wells MW-06 and MW-32. |
Juliana Smit |
| 3/18/2025 |
Exposure Tracking Model Ranking |
A new updated ranking with ETM has been completed for source area 72292 storage tanks. |
Juliana Smit |
| 3/19/2025 |
Document, Report, or Work plan Review - other |
ADEC approved the 2025 Low Groundwater Monitoring Work Plan Addendum for the Former Defense Fuel Support Point, in Whittier, Alaska. |
Juliana Smit |
