Skip to content Skip to content

Site Report: Cape Romanzof LRRS LF003 Landfill #2

Site Name: Cape Romanzof LRRS LF003 Landfill #2
Address: Cape Romanzof, Scammon Bay, AK 99662
File Number: 2526.38.001
Hazard ID: 1341
Status: Active
Staff: Axl LeVan, 9074512156 axl.levan@alaska.gov
Latitude: 61.791993
Longitude: -165.980029
Horizontal Datum:NAD83

We make every effort to ensure the data presented here is accurate based on the best available information currently on file with DEC. It is therefore subject to change as new information becomes available. We recommend contacting the assigned project staff prior to making decisions based on this information.

Problems/Comments

The site Landfill No. 2 (LF003) is located along the access road from the runway to the Lower Camp. The landfill is situated along the south side of the access road, approximately 1 mile west of the Composite Facility. The landfill covers approximately 43,800 square feet and contains various wastes including garbage, wood, metal, plastic, construction/demolition debris, shop waste, and incinerator ash, and was operated until the mid-1970s. The ground at LF003 is generally comprised of boulders with little fines. At the toe of the landfill, more fine material is present, and moving a few boulders facilitates access to some soil. Moving away from the landfill and south of the road, the boulders reach a depth greater than 3 feet. Formerly referred to as ROM-8 now LF003 Landfill #2. While not listed on the NPL, investigation at Cape Romanzof LRRS must follow CERCLA process per E.O. 12580 [e.g. CERCLA Sections 104(a), (b), and (c)(4), 113(k), 117(a), and (c), 119, and 121) with respect to releases or threatened releases where either the release is on or the sole source of the release is from any facility or vessel under the jurisdiction, custody, or control of their departments. These functions must be exercised consistent with CERCLA Section 120 Federal Facilities. State laws. -- State laws concerning removal and remedial action, including State laws regarding enforcement, shall apply to removal and remedial action at facilities owned or operated by a department, agency, or instrumentality of the United States when such facilities are not included on the National Priorities List. The preceding sentence shall not apply to the extent a State law would apply any standard or requirement to such facilities which is more stringent than the standards and requirements applicable to facilities which are not owned or operated by any such department, agency, or instrumentality.].

Action Information

Action Date Action Description DEC Staff
10/25/1977 Update or Other Action Records of the Alaska Department of Environmental Conservation (ADEC) indicate that the first solid waste disposal permits in Alaska were issued in late 1973. When the Resource Conservation and Recovery Act (RCRA) was enacted in 1976, a plan was developed to get all landfills in Alaska permitted and in compliance with RCRA technical standards. Until the mid 1970s, the landfill reportedly received garbage, rubbish, wood, metal, plastic, construction and demolition debris, shop wastes, and incinerator ash. The first permitting activity for the Cape Romanzof landfills that is evident from the USAF and ADEC files was in 1977. At that time (October 25, 1977) a permit for an incinerator and nearby landfill (ROM-8) was applied for, along with similar facilities at five other USAF sites. This permit was granted on July 11, 1978, and was issued as permit number SC-10-78. The permit at Cape Romanzof ROM-8 landfill was renewed on March 29, 1983 as permit number 8221-BA004. Louis Howard
8/29/1986 Update or Other Action Evaluation of natural resources planning requirements for selected AAC installations. Executive Summary AFR 126-1 currently requires development of land management plans for all Air Force installations. These plans must include detailed inventories of the manageable resources on each installation along with specific management goals. In order to assess the need for development of formal land management, forestry, grazing, and crop land plans for Alaskan Air Command installations, the Air Force Engineering Services Center (AFESC) Director of Environmental Planning (DEV) agreed that all installations with limited or questionable natural resource management potential should be evaluated by a qualified natural resource planner. These evaluations were conducted from 8 July-1 August 1986. Due to arctic and alpine conditions, short growing seasons, severe soils limitations permafrost, tundra soils, shallow depth to bedrock), and other natural factors, all of the evaluated Alaskan Air Command (AAC) installations were found to have significantly limited or specialized natural resource management potential. The body of this report contains summaries of available remote sensing data and/or on-site findings from each installation. Objective evaluation of the limitations, positive aspects, and potential of each site, resulted in the following recommendations: Cape Romanzof LRRS: Due to severe soil limitations and climatic conditions, forestry, grazing and cropland management plans are not required for this installation. Based on current grounds maintenance activities and extremely limited potential to enhance the grounds, it is recommended that the requirement for a formal Land Management Plan be waived. As with all remote sites, the native vegetation should be disturbed as little as possible. Often the best natural resource management strategy for these rugged, yet fragile, ecosystems is simply to leave them alone. Because establishment of vegetation in this area is slow and results are often less than satisfactory, wind erosion of the landfill area may best be addressed by using snow fences that are staked down-wind of the area to be protected. If this approach is used, the fence material should be securely anchored so that it does not dislodge and become a potential safety hazard. Jennifer Roberts
2/19/1988 Update or Other Action On February 19, 1988, pursuant to the anticipated permit expiration in April 1988, the USAF applied for a permit renewal for Cape Romanzof and several other USAF Alaskan facilities. This application indicated that for Cape Romanzof, a different land disposal site was to be used, namely at the location of ROM-1. This permit renewal application was denied on October 12, 1988, on the basis that: 1) "serious leachate problems" had been identified at the original site for which the permit was granted (ROM-8); and 2) the newly proposed landfill location at ROM-1 (at some distance from the then current landfill ROM-5) required a complete new application as a different landfill site. The "serious leachate problem" was based on findings in the USAF IRP Phase I Report. The current situation appears to be that permitting action has been suspended pending further results of the USAF 1RP RI/FS Program. This program is in the process of developing remedial action plans for the old landfill (ROM-8) as well as other sites at Cape Romanzof, including 'ROM-1. Interim landfill disposal continues, meanwhile, at ROM-5. Louis Howard
3/31/1989 Update or Other Action Stage 1 RI/FS work plan received. Landfill No. 2 (ROM-8) Description-The site, located about a half mile west of the Composite Facility on the south (downhill) side of the road, is described in the 1987 reconnaissance report. The main feature of this site is a field significant volume of effluent emanating from the landfill on its lower, south side; the effluent is reddish in color, has a multi-colored sheen, and has a foul odor in places. Vegetation around the effluent streams is dead. Setting- The landfillis situated below the road on the slope descending down to a lower plateau, which itself is still some distance away from and above Nilumat Creek. The natural subsurface conditions are mixed talus and alluvium, predominantly coarse-grained soils expected. Bedrock is expected to be encountered at relatively shallow depths (10 to 20 feet) above the road and at increasingly greater depths toward the creek. The long slope ascending to the north of the road is probably the source of the water entering the landfill, leaching through it and emerging on the south side in apparently contaminated condition. Permafrost is not expected at this site (if it were encountered, it would significantly affect the hydrogeologic conditions). For purposes of this investigation it is assumed that permafrost is absent and that shallow bedrock limits subsurface flow to shallow north of the road. Recommended Action - The purposes of the investigation outlined below are to: (1) define the quality and quantity of effluent emanating from the landfill, 2) appraise the effects of this effluent on Nilumat Creek, and 3) provide data to assist in developing remedial measures. The investigation has four components, a) through d) below: a) Effluent- The effluent emanating from the lower face of the landfill will be sampled about half of which will at six locations, be taken directly from effluent points and half will be taken at points of concentrated flow within small streams approximately 100 feet beyond the landfill face. Three sediment samples will also be taken in small streams. b) Inflow - Groundwater upgradient of the landfill will be sampled to ascertain the degree of contamination if any, or for background purposes. Water and sediment will be sampled on the north, uphill side of the road, in conjunction with the hydrogeologic investigation described in Item (d). Three water and two sediment samples will be taken from surface flows in small drainages and/or subsurface flows identified in excavated trenches. The two upgradient wells will also be sampled. c) Nilumat Creek - This main stream draining the entire valley will be sampled to evaluate the effect of the landfill effluent on the stream's water quality. Three water and sediment sample sets will be taken (1) upstream from the landfill vicinity, (2) just below all observable inflows from the landfill into the creek, and (3) in the fishing lagoons near the airport identified in the 1987 field reconnaissance report. For additional information see site file. Louis Howard
9/26/1990 Update or Other Action INTERIM GUIDANCE FOR SURFACE & GROUNDWATER CLEANUP LEVELS SEPTEMBER 26, 1990 Interim cleanup guidance for contaminated surface & groundwater remediation is necessary to ensure that consistent cleanup levels are being applied by district & 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 & 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 & 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 & final Federal MCLs are specified in 40 CFR 141 & 142. Proposed Federal MCLs are specified in the May 22, 1989, Federal Register Vol. 54, No. 97, pages 22155 - 22157 & the July 25, 1990, Federal Register Vol. 55, No. 143, pages 30408 - 30448. Appendix I provides a summary listing of State & Federal Final & Proposed MCLs for selected organic & inorganic contaminants. For organic & 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 & compounds which have toxic effects on aquatic organisms or toxic & carcinogenic effects on humans. If groundwater is being used as a drinking water source & 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 & odor, whereas MCLs are based on human health risks. For compounds such as xylenes, the SMCL maybe several hundred times lower than the MCL. Surface waters used for drinking water should also be cleaned up to levels not exceeding the final or proposed MCLs for organic & inorganic chemicals, as specified above. For additional information see site file. Louis Howard
3/1/1991 Report or Workplan Review - Other USFWS Letter to Lt. Col. William Lamb USAF 11 Tactical Control Wing/LG regarding discovered contaminants of concern (COCs) in selected fish and wildlife resources at the facility which lies in the Yukon Delta National Wildlife Refuge. The investigation was conducted in 1987 and 1988, and was specifically designed to determine if Site generated contaminants have entered the Refuge's resources. Analytical results indicate that elevated levels of some polycyclic aromatic hydrocarbons (PAHs), organochlorines and trace elements are accumulating in wildlife tissue. Most notable were PCBs and DDT-related compounds in vole, fox and fish samples. Pathways of uptake include contact, ingestion, or inhalation of contaminated soil, sediment, water, waste or prey. The U.S. Fish and Wildlife Service's Environmental Contaminant Specialists have determined that the elevated contaminant levels may pose a threat to the Refuge's wildlife resources. Furthermore, sediment samples collected by the Service and water and sediment samples collected by your contractor Woodward-Clyde Consultants indicate that an abandoned Landfill is a significant contributor of PAHs, PCBs, chlordane, lead and cadmium contamination. A copy of our "Report of Findings is enclosed for your reference. In conclusion, Service concerns appear to be adequately addressed under the U.S. Air Force's Installation Restoration Program. We believe Woodward-Clyde Consultants' remedial recommendations should be seriously considered. Therefore, we recommend, that: 1. the U.S. Air Force select remediation alternatives in consultation with the U.S. Environmental Protection Agency, Alaska Department of Environmental Conservation, and U.S. Fish and Wildlife Service; 2. the State of Alaska's Department of Environmental Conservation interim standard of i00 mg/kg (ppm) for Total Petroleum Hydrocarbons in soil be adopted by the U.S. Air Force as a cleanup level for the Cape Romanzof Long Range Radar Site; 3. the Environmental Protection Agency's "Polychlorinated Biphenyls Spill Cleanup Policy" (52 FR 10688. April 2, 1987) be used as a guide to remediate affected sites; and 4. the abandoned landfill's contents be excavated and disposed off-site to ensure permanent protection of the area's fish and wildlife resources. Louis Howard
3/11/1991 Update or Other Action 06/1990 stage 1 IRP RI/FS Report (WCC) received by ADEC for work conducted 7/89-9/89. In 1989, four monitoring wells were installed at the landfill area. Investigations conducted in 1989 and 1990 indicated that soil and surface water downgradient of the landfill were contaminated with petroleum and PCBs. At ROM-8 Landfill, the engineered drainage along the north side of the main access road contained a constantly flowing surface stream (during the July/August field work) except for the stream reach opposite and upgradient from the landfill and associated excavations. This reach had flowing surface water on July 29, 30, and 31, 1989, followed by a period of no surface flow on August 1, 2, 3, and 4, and then a resumption of surface flow on August 5, 6, and 7. This cyclic flow pattern suggests that some of the surface and subsurface flow north of the main access road was being diverted downgradient southwestward through or under the road embankment and through the landfill. This migration could have locally lowered the potentiometric surface to a level below stream bottom during periods of decreased precipitation/runoff, causing this stream reach to be temporarily dry at ground surface. The presence of several active seeps on the landfill surface to the southwest supports this suggestion. The data presented above indicate that groundwater occurs at shallow depths beneath the tundra surface in some areas; and depending on local conditions, this water can intermittently appear as surface flow. In 1989 and 1991, site investigations documented large amounts of exposed wood, metal and plastic debris in the areas around the landfill. Several areas of stained soil and several points of oily effluent were noted on top of and adjacent to the landfill, respectively. Two drainages adjacent to the landfill were receiving surface flow and effluent flow from the landfill. Several seeps were observed to emanate from the landfill surface, and appeared to flow for up to 100 feet before reentering the landfill. Shallow groundwater is also present in some of the granitoid block fields, as is documented west of ROM-8 Landfill. Here, near-surface flowing water was seen at some points between granitoid blocks about 2 to 3 feet below the surface, and subsurface flow was heard at many other points. Where these conditions occur, it is evident that subsurface flow can be converted to surface flow by excavations a few (less than 10) feet deep. Alaska's groundwater resources are reported to be highly variable. For additional information see site file. Vic Vickaryous
10/29/1991 Update or Other Action Letter from EPA to Patrick M. Coullahan (LTC), Commander, U.S. Air Force, 5099th CEOS, Elmendorf AFB, Alaska 99506-4420. Re: Request for Submission of Preliminary Assessments for the Enclosed List of Sites. The U.S. Environmental Protection Agency (EPA) is issuing this request for information concerning several sites (see enclosed list) under the authority of Section 104(e) of the Comprehensive Environmental Response, Compensation, & Liability Act (CERCLA), 42 U.S.C. S 9604(e). EPA is now requiring this information because your agency has not submitted complete preliminary assessments which EPA requires to complete the evaluation of the sites. The preliminary assessments also may indicate the need to complete a site inspection, which includes sampling. Your agency’s performance of the preliminary assessments, & perhaps a site inspections, is necessary in order for EPA to evaluate whether to include the facilities on the National Priorities List. This formal request for submittal of information is being made to assure that a preliminary assessment is conducted for each facility that was listed on the original Federal Facilities Hazardous Waste Compliance Docket, pursuant to the statutory requirement set forth in Sec. 120(d] of CERCLA, 42 U.S.C. 9620 (d). In a judicial Order dated January 15, 1991, in the case entitled Conservation Law Foundation of New England v. EPA, C.A. No. 89-2325-Y. D. Mass., EPA was ordered to conduct a preliminary assessment of certain facilities by July 15, 1992, & to complete evaluations of each facility for the National Priorities List by July 15, 1993. EPA has an obligation to use its utmost diligence to meet the Court order by assuring that a preliminary assessment is conducted for each facility on the docket. The cooperation of your agency & timely assessment of each site is essential if EPA is to meet these Court-ordered deadlines. You also should be aware that Sec. l16(a) of CERCLA, 42 U.S.C. S 9616(a), requires your agency to complete preliminary assessments & site investigations within specified times. The President delegated to the heads of Executive departments & agencies the authority to conduct such assessments with respect to facilities under the jurisdiction, custody or control of those departments & agencies, in Sec. 3(a) of Executive Order 12580 of January 23, 1987. Therefore, pursuant to the authority of Section 104(e) of CERCLA, 42 U.S.C. 9604(e), you are hereby requested to respond to the information request titled "Preliminary Assessment (PA)/Site Inspection (SI) Data Requirements for Federal Facility Docket Sites," set forth in Enclosure A to this letter. You only need to respond to the highlighted items for each site. Your responses to this request for information must be submitted (postmarked or hard delivered) to EPA within 60 calendar days of receipt of this letter. To comply with this request, you must provide a response to each question. If information relevant to a question already has been provided to EPA, your answer may precisely cite the previous submittal by title, date. page & paragraph number rather than resubmit the information. To assist in your efforts a copy of EPA's draft "Guidance for Performing Preliminary Assessment Under CERCLA" [Publication 9345.0-01A, September 1991] was provided at the October 8th meeting in Anchorage. For additional information see site file. Louis Howard
2/17/1992 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. For additional information see site file. Jennifer Roberts
2/25/1992 Report or Workplan Review - Other Staff reviewed the draft IRP RI/FS Stage 1 Tech Report Addendum March 1991 and 2nd draft report June 1990. The Department requests that in the future all workplans for investigation and cleanup of contaminated sites be submitted ninety (90) days in advance of any scheduled work. This schedule allows for a thirty (30) day review period by the Department, twenty (20) days for any necessary revisions by the Air Force, another thirty (30) days for the Department to review the revised document and grant approval, and an additional ten (10) days for any unforeseen delays. This request is based on a need to insure that field work is conducted in accordance with applicable state guidelines and regulatory requirements, thereby helping to insure that work does not have to redone. For ROM-8 Landfill the Department concurs with the recommendation that the site requires further remedial action. However, the recommendation that the. landfill be capped with hydraulic controls be implemented is not approved as a final remedial action for the site (page 6-13 sect. 6.4 Summary of Recommendations). Remedial alternatives need to address both the soil contamination with TPH as high as 100,000 ppm and the TPH/PCBs found in the surface water at the perimeter of the landfill. Please refer to the above NON-UST guidance documents listed under "General Comments." Other guidance that may prove useful for this site is listed in the Solid Waste Management regulations 18 AAC 60 Article 4 "Closure" shows steps on how a landfill may be closed out. Louis Howard
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 & 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, & JP-4, & a cancer potency factor for gasoline. The memo emphasizes that these are provisional numbers & that considerable uncertainty is involved in this quantitative assessment, because of data limitations, & because inhalation studies were used to calculate oral reference doses. Toxicity Reference Vaules for Fuel Mixtures EPA Region 10 4/9/1992 Non-cancer effects-Gasoline (unleaded) RfD (mg/kg-day) Oral: 2.0E-1, Uncertainty Factor-Oral:1000, Level of Confidence-Oral: Low. Toxicity Data Source-Oral RfD: Memo 3/92. Carcinogenicity-Cancer Potency/(mg/kg/day): Oral 1.7E-3, Unit Risk (/ug/m3) 4.8E-7, Cancer Weight Of Evidence-C, Toxicity Data Source-Oral SF & 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 Based on the available evidence, unleaded gasoline can be assigned to U.S. EPA (1986) weight-of-evidence Group C: possible human carcinogen. An earlier U.S. EPA document assigned unleaded gasoline to Group B2 as a probable human carcinogen (u.s. EPA, 1987a), but that document predates the U.S. EPA (1991d) conclusion that the male rat kidney tumors produced by gasoline are not predictive for humans, & therefore should not contribute to the weight-of-evidence or dose-response assessment of carcinogenicity. IARC concluded that marine diesel fuel is possibly carcinogenic to humans (Group 2B), but light diesel fuels & jet fuels are not classifiable as to their carcinogenicity in humans (Group 3). For additional information see site file. Jennifer Roberts
7/13/1992 CERCLA PA Letter from EPA Region 10 received by ADEC stating that the (June 30, 1992) Preliminary Site Assessment for the purposes of ranking under the Hazard Ranking System used to evaluate federal facilities for inclusion on the National Priorities List (NPL). A review of the documents indicate the site (facility) does not score high enough to be proposed for inclusion on the NPL. Therefore, a recommendation of no further remedial action planned (NFRAP) on the EPA's part will be included in the 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 will reevaluate the facility accordingly. The Facility is not relieved from complying with appropriate Alaska state regulations and SARA 1986(a) (4) requires federal facilities to comply with state cleanup requirements and standards when not listed on the NPL. NOTE To file: SEC. 120. FEDERAL FACILITIES. (a) APPLICATION OF ACT TO FEDERAL GOVERNMENT.— (1) IN GENERAL.—Each department, agency, & instrumentality of the U. S. (including the executive, legislative, & judicial branches of government) shall be subject to, & comply with, this Act in the same manner & to the same extent, both procedurally & substantively, as any nongovernmental entity, including liability under section 107 of this Act. Nothing in this section shall be construed to affect the liability of any person or entity under sections 106 & 107. (2) APPLICATION OF REQUIREMENTS TO FEDERAL FACILITIES.— All guidelines, rules, regulations, & criteria which are applicable to PAs carried out under this Act for facilities at which hazardous substances are located, applicable to evaluations of such facilities under the NCP, applicable to inclusion on the NPL, or applicable to remedial actions at such facilities shall also be applicable to facilities which are owned or operated by a department, agency, or instrumentality of the U.S. in the same manner & to the extent as such guidelines, rules, regulations, & criteria are applicable to other facilities. No department, agency, or instrumentality of the U. S. may adopt or utilize any such guidelines, rules, regulations, or criteria which are inconsistent with the guidelines, rules, regulations, & criteria established by the Administrator under this Act. (3) EXCEPTIONS.—This subsection shall not apply to the extent otherwise provided in this section with respect to applicable time periods. This subsection shall also not apply to any requirements relating to bonding, insurance, or financial responsibility. Nothing in this Act shall be construed to require a State to comply with section 104(c)(3) in the case of a facility which is owned or operated by any department, agency, or instrumentality of the U. S. (4) STATE LAWS.—State laws concerning removal & remedial action, including State laws regarding enforcement, shall apply to removal & remedial action at facilities owned or operated by a department, agency, or instrumentality of the U. S. or facilities that are the subject of a deferral under subsection (h)(3)(C) when such facilities are not included on the NPL. The preceding sentence shall not apply to the extent a State law would apply any standard or requirement to such facilities which is more stringent than the standards & requirements applicable to facilities which are not owned or operated by any such department, agency, or instrumentality. Jennifer Roberts
12/7/1992 Update or Other Action Vic Vickaryous received US Department of Interior (USDOI) Fish and Wildlife Service Refuge Manager Report of Findings at Cape Romanzof LRRS military cleanup dated Jan. 17, 1991). Study was conducted by Wayne Crayton (environmental contaminants specialist). Findings of fact: Cape Romanzof LRRS has contaminated area's environment, Fowler Creek's sediment is contaminated with petroleum hydrocarbons, fish and wildlife resources (dolly varden, voles, red fox) are contaminated with petroleum, oil and lubricants (POL) hydrocarbons (*Note: as of 2003 there are no cleanup levels for fuel range hydrocarbons-gasoline range organics-GRO, diesel range organics-DRO, residual range organics-RRO in sediments), PCBs and DDT-related compounds. Request Air Force conduct additional and more extensive monitoring on a regular schedule (every 2 or 3 years) to determine if contaminant problem associated with facility is continuing to impact Refuge resources. The frequency of sampling should be adjusted to reflect site activities. Vic Vickaryous
8/6/1993 Report or Workplan Review - Other John Halverson provided comments on work plan for site. Staff requested additional remediation of contamination and plan did not provide sufficient details on how this will be done. Hydraulic controls alone is not acceptable for landfill closure as reiterated in a 2/25/1992 letter commenting on the same subject. Areas of known soil/water contamination must be addressed (soils contain 100,000 mg/kg petroleum beneath a transformer, leachate from the landfill, and any other obviously impacted areas). The containment section of the plan must address these areas. No details are provided on diagrams or engineered drawings showing how the bedding, liner, cover material and diversion ditches will be constructed. Post closure monitoring does not contain sufficient detail to be approved and a minimum of five years of monitoring will be required for integrity of the final cover, slopes, drainage structures, liners, caps, groundwater monitoring devices as required by 18 AAC 60.410. John Halverson
5/2/1994 Update or Other Action Work plan for contaminated soil at facility states action items for FY93 and FY94 work. Finish FY93 Work: (a) Finish capping the landfill started in FY93 work season. The work plan was approved by ADEC for the FY93 work season and there are no changes anticipated for the FY94 work season. (b) Complete the two soil containment cells began in FY93. All that remains is the final grading. (c) Excavate three contaminated areas identified during the FY93 work season. 1 One area is located between the old POL Fill Stand (ROM-10 ST09) and the beaver pond near the beach area. 2 One area is located at the old POL Fill Stand ST-09 (ROM-10). 3 One area identified as Drum Storage Area SS-14 (ROM-14) near the beach area. FY94 Work: (a) Excavate Waste Accumulation Area No. 3 SS-08 (ROM 1) (380 cubic yards). (b) Excavate diesel contaminated soil stockpiled near SS-15 (900 cubic yards. This particular site will be first priority since soil has been stockpiled for over two years without an ADEC approved soil stockpiling plan. Obtain approval for the construction of Biopile remediation cells to be located near the removed lower camp facilities. The new cell will not be constructed on an existing RIP site. Exact location to be coordinated between 11 CEOS/CEV and 11 CEOS/CEOR during a site visit. a. This particular landfill is located adjacent to the main access road. During the 1989 and 1991 visits, the landfill that makes up this site was unsightly, with a large amount of exposed metal, wood, and plastic debris. There were several areas of stained soils, several points of effluent emanating from the downslope side of the landfill, and two drainages containing active surface flow just upslope and adjacent to the landfill. b. Woodward-Clyde mapped the landfill, located surface water courses, points of effluent, and the outline and the general topography of the landfill. c. The engineered drainage along the north side of the main access road contained a constantly flowing surface stream (during the Jul/Aug 1989 investigation) except for the stream reach opposite and upgradient from the landfill and associated excavations. This reach had flowing surface water on 29, 30, and 31 July, 1989, followed by a period of no surface flow on 1, 2, 3, and 4 August, 1989 and then a resumption of surface flow on 5, 6, and 7 August, 1989. This cyclic flow pattern suggests 'some of the surface and subsurface flow north of the main access road was being diverted downgradient southwestward through or under the road embankment and through the landfill. This migration could have locally lowered the potentiometric surface to a level below stream bottom during periods of decreased precipitation/runoff, causing this stream reach to be temporarily dry at ground surface. The presence of several active seeps on the landfill surface to the southwest supports this suggestion. For additional information see site file. Ray Burger
6/30/1994 Update or Other Action The 611th Air Support Group, Civil Engineer Squadron / Asset Management Flight Restoration Element (611th CES/CEAR) conducted site cleanup and capping at LF003 in 1993. Debris identified during the 1989 and 1990 RI/FS work was collected up to 200 feet around the periphery of the landfill and placed into the landfill. Approximately 500 cubic yards (CY) of fill was placed on the southern section of the landfill to cover collected debris. The active surface drainage which parallels the eastern edge of the landfill was diverted approximately 20 feet away from LF003. In 1994, monitoring wells MW-3 and MW-4 were abandoned (i.e., removed and sealed with bentonite). The landfill surface was compacted, and an additional 18 inches of fill was placed over the landfill and also compacted. Fifty foot-wide sheets of hypalon impermeable liner were laid with two foot overlaps in a north-south direction covering the landfill. The seams were then covered with 15-foot wide geotextile materials. An additional 18 inches of fill material was then placed over the liners, compacted and smoothed, and finally, a seed mixture was applied to the new surface. The area was monitored after rainfalls, and no new leachate areas were identified. Old leachate sites were observed to be drying up. In 1994, approximately 772 cubic yards of petroleum-impacted soils were removed from SS008 and placed into biocells constructed at Cape Romanzof LRRS. 1994 Confirmation Sampling: Post-excavation confirmation samples were analyzed for DRO, GRO, and BTEX. Five of the 21 confirmation samples showed DRO levels above the ADEC Method Two cleanup levelof 250 mg/kg (maximum detection of 911 mg/kg). The areas were resampled, and in one area the excavation was extended to remove more contaminated soil.The contamination was removed during the 1994 excavation activities, and there are no known areas of soil contamination above ADEC Method Two cleanup levels remaining at this site. The Proposed Plan erroneously showed one benzene detection (0.035 mg/kg) above the ADEC Method 2 cleanup level (0.02 mg/kg). Further review of the 1994 report suggests that the detections reported for benzene, ethylbenzene, toluene, m-xylene, and o,p-xylenes (0.035 mg/kg each) were incorrect and should have all been flagged “U” instead (to indicate under 0.035 mg/kg). This conclusion is also supported by a nondetect (at a reporting limit of 0.7 mg/kg) in the volatile petroleum hydrocarbon (VPH, a precursor to the current GRO analysis) analysis and a very low extractable petroleum hydrocarbon (EPH) result of 34.7 mg/kg. This change from the information presented in the Proposed Plan is considered insignificant, as the cumulative risk (Section 2.8.1.2) is below threshold levels both with and without the one reported benzene detection. Louis Howard
4/5/1995 Report or Workplan Review - Other ADEC staff sent letter to Steve Mattson 11 CES/CEOR re: Cape Romanzof LRRS Final Draft Report on the Investigation, Delineation, and Excavation of Contaminated Soil from SS15, SS08, SS14, and ST09; Construction of Cells for Contaminated Soil; Capping of Landfill-2 (LF03); and Geology/Water Resources of Nilumat Creek Valley received on March 6, 1995. This document reports on work conducted according to a work plan dated May 2, 1994. Executive Summary: Work was conducted according to a work plan dated May 2, 1994, however ADEC has final work plans dated August 12, 1994 and September 7, 1993. Please explain this inconsistency. Soil Sampling and Field Screening: After excavation of the stockpile, another 2-3 ft. of soil was excavated from below the liner "until the PID readings decreased to under 10 ppm." As this is not indicative of attainment of cleanup levels (for example, Field Sample #64 had a PID reading of 3 ppm and the lab DRO = 228 mg/kg), there can be NO CLOSURE until confirmation sampling is done. Also, of 88 PID readings taken, only 70 are presented in Table 10. Lab analysis and backfilling: It is stated a criteria of one confirmation sample per 250 square feet of surface area was used, which would result in about 100 samples collected for the 24,570 sq. ft. area excavated. Please explain why only 31 samples were collected. In order to close out this site, more confirmation sampling may be required. Deviations from the Work Plan: While it was stated that the trench around the base of the landfill was omitted, it is unclear whether the "roadside installation ditch [was] enlarged and compacted' as called for in the work plan. Recommendations: While ADEC agrees with the future work recommended, the long-term monitoring of the landfill (LF03) should be added to the list. Given the deviations from the work plan (i.e. omitting the trenching and geotextile layers) it is important to ensure that water does not leach through the landfill and the integrity of the hypalon barrier is upheld. Details of the monitoring program can be found in the "Landfill Work Plan" dated August 12, 1993. Chain of Custody Records: There is no indication of the temperature that samples were stored at during transport. This important information to document in order to evaluate data quality. Ray Burger
4/28/1995 Update or Other Action Field investigation report received for activities carried out during June 1994 through September 1994 for the Cape Romanzof Long Range Radar Site. Landfill 2, Work Plan, 12 Aug 93. The 94 work was a continuation of the tasks not completed in 93. The Landfill-2 (LF03) was prepared & capped with hypalon membrane. The top of the hypalon was covered with sand & pit run gravel, then seeded with grass. Landfill-2 (LF03) covers approximately 43,800 square feet. The debris composed of steel, wood, & paper was collected from a 200 foot width around the periphery of landfill & placed in the landfill. Approximately 500 cubic yards of fill was dumped on the south section of the landfill to cover the debris. The stream parallel to the eastern toe of the landfill was diverted 20 feet away from its original drainage. During Aug 94, the following measures were adopted to prepare the landfill surface for capping purposes. The surface of the landfill was compacted by running the tractor over its entire surface to flatten piles of material such as old empty rusted drums & metal etc. The surface of the landfill was thoroughly examined visually for any contaminants. Our field investigations located presence of several brown leachates seeping from the periphery of the landfill. The compacted surface of the landfill was then covered with a 12-inch thick bedding layer of, pit run material (a total of 250 truckloads of pit run material). The new surface was again compacted to give a smooth surface to the landfill. Well casings of two monitoring water wells (MW-3 & MW-4) were extracted & the wells were grouted, plugged, & abandoned. Details of water level measurements in wells MW-1, MW-2, MW-3, & MW-4. The compacted surface of the pit run material was then covered with a 6-inch thick layer of sand (1/2 minus material). A total of 125 truck-loads of sand was placed over the pit run surface This nominal thickness was considered necessary to compensate for loss of finer material through voids between the rocky surface material at the landfill & to completely cover the rough topography prior to covering it with an impervious liner to stop the downward flow of surface water through the contaminated material. The first sheet of impermeable liner hypalon (50-feet wide) was placed in a north-south direction, along the divide of the landfill. The successive sheets were placed parallel to the first one with a 2-foot overlap in both directions, to the east & west, away from the first sheet. This shingle type arrangement would cause water to run, away from the central part, in easterly, westerly, & southerly directions without penetrating downward into the contaminated landfill. For additional information see site file. Louis Howard
5/3/1995 Report or Workplan Review - Other Ray Burger reviewed the Final Report April 1995 Investigation, delineation, and excavation of contaminated soil from SS15 stockpile, waste accumulation area SS08, Drum storage area SS14, POL Fill stand ST09, Construction of Cells for contaminated soil, Capping of Landfill-2 (LF03) and Geology/Water Resources of Nilumat Creek Valley. LF03 was capped in Summer of 1994 (June through September 1994) with impermeable hypalon liner membranes. The cap was designed to prevent the infiltration of surface water that could potentially create contaminated effluent due to contact with buried debris. Two monitoring wells installed in 1989 (#3, #4) were abandoned during the construction of the landfill cap. Based on soil samples containing contamination above the cleanup level of 100 mg/kg TPH, and visual observations, estimate of the areas requiring remedial action was calculated to be 49,900 square feet and total volume of fill (soil mixed with debris) was calculated to be 11,530 cubic yards. August of 1994: surface of landfill was compacted to flatten piles of material such as old empty rusty drums and metals. Field investigators located several brown leachates seeping from the periphery of the landfill. Then landfill was covered with a 12 inch thick bedding layer of pit run material (250 truck loads total) and then compacted again. Another six inch layer of sand (1/2 inch minus) was added (125 truck loads total). Several sheets of impermeable liner hypalon was placed on the landfill. Seams of the liners were then covered by 15 feet wide geotextile fabric strips to hold the overlapping seams intact and provide a rough base for the overlying sand layer. Another six inch layer of sand overlain by 12 inch layer of thick pit run material was placed over the hypalon and geotextile (250 more truck loads total). This layer was compacted, revegetated with grass seed. Ray Burger
11/30/1995 Update or Other Action Draft Environmental Baseline Survey for Air Force Radar Stations contains information on Cape Romanzof. The Air Force began the IRP process at Cape Romanzof Radar Installation in 1985 prior to the terminology and procedural changes that took place in the IRP after the passage of the Superfund Amendments and Reauthorization Act (SARA) in 1986. As a result, the IRP was realigned to incorporate the terminology and requirements in the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). The IRP Administrative Record file contains both pre- and post-SARA terminology. The Remedial Investigation (RI) results presented are from investigation activities conducted at the Cape Romanzof Radar Installation. Additional information was gathered from previous investigations at these sites. Eight sites were investigated at the Cape Romanzof Radar Installation: Landfill N0. 2 (LF03), Landfill NO. 3 (LF04), Waste Accumulation Area No. 1 (SS07) Waste Accumulation Area No. 3 (SS08), Spill/Leak No. 3 (ST09), Seep Area No. 5 (SS13), Drum Storage Area (SS14) and Previous USTs (SS15). None of the six aboveground storage tanks (ASTs) at the facility shown evidence of a release. No underground storage tanks (USTs) were found at the facility. One oil/water separator is located at the Lower Camp for the Industrial Building (building 2294). PCBs were reportedly stored at SS01, LF02, LF04, OT06, and SS08. On inspection, all transformers were seen to be the dry type which do not contain PCBs. Restoration Activities Completed: Waste Accumulation Area #2 (SS01) NFRAP after 1993, Landfill #1 (LF02) NFRAP after 1993, Landfill#2 (LF03) Interim remedial action in 1994, Landfill #3 (LF04) Remedial investigation, feasibility study and draft proposed plan completed, Road Oiling (OT05) NFRAP after 1993, White Alice Site (OT06) NFRAP after 1993, Waste Accumulation Area #1, Spill/Leak#1 and #2 (SS07) Remedial investigation, feasibility study, and draft proposed plan completed, Waste Accumulation Area #3, Spill/Leak #6, 7, 8, and 9 (SS08) Interim remedial action in 1994, Spill/Leak #3 (ST09) Remedial Investigation completed in 1994, Spill/Leak #4 (SS10) NFRAP after 1993, Dump Area (DP11) NFRAP after 1993, Landfill (LF12) NFRAP after 1993, Seep Area, Spill/Leak#5 (SS13) Remedial investigation, feasibility study, and draft proposed plan completed, Drum Storage Area (SS14) Interim remedial action in 1994, Leaking USTs (SS15) Remedial investigation, feasibility study, and draft proposed plan completed Interim remedial action in 1994. Ray Burger
7/31/1996 Update or Other Action Cape Romanzof LRRS Landfill 2 Closure Monitoring Work Plan received. 611 CES will drill seven soil borings and complete them as monitoring wells at locations. An HLA geologist will be onsite for soil classification, sample collection and to direct monitoring well installation. Soil samples will be collected from the borings (field screening) at 5-foot intervals, beginning at the ground surface. One soil sample from each boring will be sent to the analytical laboratory for (confirmatory) chemical analysis. Four monitoring wells will be installed at the downgradient perimeter of the landfill to assess the potential leaching of contaminants from the landfill. Two monitoring wells will be installed further down gradient of the landfill to assess the extent of contaminant migration. One background monitoring well will be installed upgradient of the landfill in an area unaffected by past landfill practices. HLA will develop, purge, and sample 7 new GW monitoring wells to provide data for site characterization and for future sampling requirements. HLA will collect three surface water and three sediment samples from streams, seeps and drainage pathways where surface water drains offsite. Ray Burger
9/30/1996 Long Term Monitoring Established In 1996, Harding Lawson installed 7 monitoring wells around LF03 as part of landfill closure actions. Soil, sediment, groundwater and surface water samples were collected and analyzed during this effort. Results indicated that surface water and sediment downgradient of the landfill contained levels of PCB and diesel range organics (DRO) above the U.S. Environmental Protection Agency’s (EPA) risk-based concentration (RBC) screening criteria. Groundwater analytical results indicated the presence of diesel range organics (DRO), chloromethane, benzene, and several metals in both upgradient and downgradient monitoring wells. Ray Burger
2/10/1997 Site Added to Database Site added by Shannon and Wilson, Inc. S&W-Miner
2/11/1997 Interim Removal Action Approved IA action added by Shannon and Wilson, Inc. on 02/11/1997. Air Force Relative Risk Evaluation Worksheet dated 8/22/95 indicates this site is in the IRA (Interim Removal Action) phase. No other information is available. S&W-Miner
6/2/1997 Offsite Soil or Groundwater Disposal Approved ADEC (R. Burger) received and approved of disposal of investigative derived wastes (soil and water) generated as a part of the long term monitoring at Landfill Number 2 (LF03). Diesel range organics (DRO) was detected at 1.14 mg/L. Proposal is to dispose of it on the active biopile (Cell 3) at the Lower Camp prior to freeze up to avoid drum breakage. Ray Burger
9/30/1997 Update or Other Action Harding Lawson continued monitoring the site in 1997.Groundwater analytical results indicated the presence of DRO and several metals in both upgradient and downgradient monitoring wells. DRO and lead were detected exceeding regulatory levels in downgradient monitoring wells. Surface water analytical results indicated the presence of PCBs exceeding regulatory limits from all three surface water monitoring points, while DRO and several metals were detected from monitoring location SW-2. Sediment analysis indicated the presence of DRO, PCBs and several metals. DRO and PCBs again, exceeded regulatory limits from sediment monitoring location SD-2. DRO was detected in all sediment samples with concentrations ranging from 13.1 milligrams per kilogram (mg/Kg) to 371 mg/Kg. Trace amounts of pesticides were detected in one sediment sample. Ray Burger
11/20/1997 Report or Workplan Review - Other Gretchen Pikul commented on the draft closure monitoring report for LF03. Clarification was provided on petroleum hydrocarbons in surface water criteria. Requests were made to further characterize the PCB contamination found at sediment sample SD-2 which had a hit at 69.1 mg/kg. note: Review of report by Howard- Aroclor 1260 was detected in sample ID 97RMZ05SD at 437 mg/kg PQL was 22 mg/kg for SW846 8080 method on 6/1997 analyses by CT&E Environmental Services Inc laboratory. Sec. 5.0 Groundwater samples states PCB/Pesticide detection limits for samples 97RTMZ02WA, 98RMZ05WA and 97RMZ07WA were raised due to matrix interference. Surface water samples narrative states PCB/Pesticide surrogate recoveries for samples 98RMZ03SW and 97RMZ05SW were outside QC limits because of dilution. Sediment samples narrative states: The PCB QA and QC samples disagree with the project sample (RPD of 160% and 145% respectively). Sec. 6.3 Sediment Results states: PCB Aroclor 1260 was detected in three sediment samples: 97RMZ03SD (SD-2) AT 69.1 mg/kg, 97RMZ04SD (SD-2) at 630 MG/KG, and 97 RMZ05SD at 437 mg/kg. Narrative in Sec. 7.0 Conclusions and Recommendations states 630 mg/kg was a QA sample. Gretchen Pikul
1/9/1998 Update or Other Action Management Action Plan: Currently, the Cape Romanzof LRRS is neither listed, nor proposed for inclusion, on the National Priority Listing (NPL). In accordance with the National Contingency Plan [Title 40 Code of Federal Regulations(CFR) Part 300] Although Cape Romanzof LRRS is not included on the NPL, SARA § 211 and Executive Order 12580 requires that all sites be addressed in a manner consistent with CERCLA§120 which regulates NPL sites. Cape Romanzof LRRS is required to comply with the following restoration related environmental regulations and laws: CERCLA§ 120 (as amended by SARA), which establishes a framework for responding to releases of hazardous substances, pollutants, or contaminants all media at all installations; Executive Order 12580 and the statutory provisions of the Defense Environmental Restoration Program, of which the IRP is a sub-component, and All applicable federal and state statutes and regulation that govern environmental restoration activities and conditions. There are several ongoing or planned remedial actions (RAs), including: Groundwater monitoring is being performed around LF03 (Landfill No 2), which was previously capped. In addition surface soil, surface water, and sediment samples are also collected. Response Schedules: The schedule for the various sites at Cape Romanzof LRRS include the following activities: long-term monitoring (LTM) will be performed on a yearly basis for LF03 (Landfill No. 2). Designated as Zone 2 - This is the main support area known as the Lower Camp Several IRP Sites and POls are located in this zone: IRP Sites SS01,LF02, LF03, LF04, OT05, SS07, SS08, LF12, SS13, SS15;and POls 1,2, 3, 4, 7, 8, and 9. POI 1 Pesticide Handling where pesticides were mixed inside buildings-no exterior mixing. Operated from 1950s to present and building has since been demolished and site debris removed (NFA decision in 1985). POI 2 active during 1976 to 1977 NFA decision in 1985. POI 3 Landfill No. 5 had empty drums and other debris placed in it during 1976, 1977 and 1984 (NFA decision in 1985). POI 4 Hardfill No. 1 composed of concrete, wood, road maker drums, and demolition debris during 1950s to 1970s (NFA decision in 1985). POI 5 Hardfill No. 2 composed of debris from beach warehouse operated in the 1960s (NFA decision in 1985). POI 6 Hardfill No. 3 composed of heavy equipment dozers, clamshell buckets, etc. and operated during the 1950s to 1970s (NFA decision in 1985). POI 7 Incinerator had small quantities of waste and operated in 1950s to 1980s (NFA decision in 1985). POI 8 Sanitary Sewage System and POI 9 Surface Drainage System had insignificant quantities of hazardous waste disposed of and operated from 1950s to present (NFA decision in 1985). Gretchen Pikul
9/3/1998 Report or Workplan Review - Other G. Pikul provided comments on the draft work plan for closure monitoring. The applicable, relevant and appropriate requirements (ARARs) needs to be further discussed and brought out in further detail. PCB contamination characterization will need to go beyond the stated 1-2 foot depth described in the work plan. Clarification was requested on the number of actual lab samples collected vs. soil screening samples on PCB characterization of the soil. Gretchen Pikul
2/1/1999 Update or Other Action In 1998, samples were collected from the LTM monitoring locations, and across the area surrounding LF0O3, to define the nature and extent of PCB and petroleum contamination. Groundwater analytical results indicated the presence of DRO in several downgradient monitoring wells, and residual range organics (RRO) exceeding regulatory limits in CMW-4. Surface water analytical results indicated the presence of several metals and low levels of SVOCs. No constituents were detected above regulatory limits in surface waters in 1998. Sediment analytical results indicated the presence of DRO, PCBs, methylene chloride, and several metals. DRO and PCBs again, exceeded regulatory limits from sediment monitoring location SD-2. Approximately 50 soil samples were collected across the area around LFOO3, and results indicated widespread, low-level petroleum hydrocarbon contamination, and a "hot spot" of PCB contamination at SD-2. Louis Howard
5/3/1999 Report or Workplan Review - Other Staff provided comments on the site investigation and closure monitoring report of 2/99. Gasoline range organics (GRO) and residual range organics (RRO) may be deleted from the list of analytes since there have been no exceedances of either contaminant during sampling. Staff requested a hotspot removal of SD2 which had 180 mg/kg Arochlor 1260 (250 mg/kg J flagged value-estimated value). Narrative in SI/Closure monitoring document for LF03 stated: This one lone sediment sample (sample 57) proved to be exceptionally high in PCB (Arochlor 1260) at 180 ppm, approximately three orders of magnitude higher than surrounding samples. There is no adequate rationale developed for this. Appendix of Analytical data shows the following for PCBs: Sample 07B 48030988057 SD2 collected 9/27/1998 sediment PCB-1260 180 mg/kg (footnote D-Analyte was diluted to bring within instrument calibration range or to remove matrix interference). ARARS and TBCs Exceedance of ARARs does trigger a remedial action. The responsible party must, in a reasonable time frame, meet ARARs (i.e. promulgated federal and state regulatory levels). The NCP Subpart E. Hazardous Substances Response Sec. 300.430 Remedial Investigation/ feasibility study and selection of remedy requires protection of human health and the environment as threshold criteria. Overall protection of human health and the environment and compliance with ARARs (unless a specific ARAR is waived) are threshold requirements that each alternative must meet in order to be eligible for selection prior to implementation. Cleanup alternatives shall be assessed to determine whether they can adequately protect human health and the environment, in both the short- and long-term, from unacceptable risks posed by hazardous substances, pollutants, or contaminants present at the site by eliminating, reducing, or controlling exposures to levels established during development of remediation goals consistent with Sec. 300.430(e)(2)(i). Overall protection of human health and the environment draws on the assessments of other evaluation criteria, especially long-term effectiveness and permanence, short-term effectiveness, and compliance with ARARs. Compliance with ARARs. The alternatives shall be assessed to determine whether they attain applicable or relevant and appropriate requirements under federal environmental laws and state environmental or facility siting laws or provide grounds for invoking one of the waivers under paragraph (f)(1)(ii)(C) of this section. For additional information see site file. Louis Howard
9/15/1999 Site Ranked Using the AHRM site ranked based on updated information available in files. Louis Howard
10/12/1999 Report or Workplan Review - Other Staff reviewed and commented on the Draft Quality Program Plan for Landfill Cap Sampling and Analysis Plan dated September 1999. The text states that three sampling sites will be covered by this document: SS 13. SS 15, and LF03. Please note that SS 13 and SS 15 will require additional analyses for natural attenuation parameters not yet determined mid memorialized in the Record of Decision. A proposed plan has been finalized, however the public has not been able to comment on it in a public forum for SS13 and SSI5 The work proposed may proceed with the following modifications for sampling at SS13 and SS15, but be aware that additional sampling and monitoring requirements will be requested by DEC in the near future. Surface water samples analyses must also include analysis for total aromatic hydrocarbons and total aqueous hydrocarbons as specified in l 8 A.AC 70 Surface Water Quality standards. Total aqueous hydrocarbons (TAqH) m the water column may not exceed 15 ug/I and total aromatic hydrocarbons (TAH may not exceed 10 u_/1. Samples to determine TAH and TAqH must be collected in fresh waters below the surface and away from any observable sheen. DEC concurs with treating the IDW water through two granular activated carbon canisters arranged in series prior to discharge. Approval of this action is limited to this particular instance and all other approvals will be on a case-by-case basis. If the discharge for some reason is not disposed of at the facility's water treatment facility as proposed in the document, then it may not be discharged immediately upgradient of any drinking water well nor into any environmentally sensitive areas as defined in 18 AAC 75.990(35). Correct table to show that for SS13 and all other sites using DRO analysis of soil requires 2.0 mg/kg and 20 mg/kg for method detection limit (MDL) and practical quantitation limit (PQL) respectively. SS13 and all other sites using BTEX analysis of sod the PQL must be 0.05 mg/kg or less not 0.07 mg/kg. The text states that for ICP metals, see Section 5. However, section 5 consists of figures and does not provide any QA/QC parameters for metals analyses. Louis Howard
2/1/2000 Update or Other Action In 1999, groundwater analytical results received that indicated the presence of DRO and several metals, with lead being the only constituent exceeding regulatory limits. Surface water analytical results indicated the presence of minimal metals. Sediment analytical results indicated the presence of DRO and metals. Sediment monitoring locations SD-2 and SD-3 had DRO exceeding regulatory limits; however, PCBs were reported as non-detect. Louis Howard
4/17/2000 Update or Other Action Staff briefed management on alternative cleanup level established for biocells soil contaminated with 6,000 mg/kg diesel range organics and 18,000 mg/kg residual range organics. Soils originally came from SS08, SS15, SS14, and ST09. During 1994, the 611 CES/CEOS excavated and stockpiled approximately 1,300 cubic yards of petroleum contaminated soil in Containment cell 1 near the barge cargo beaching area and approximately 1,400 cubic yards of petroleum contaminated soil in Containment Cell 3 near Lower Camp. Containment cells 1 and 3 were retrofitted into biocells 1 and 3 during June and July 1996. 611th proposes soil to be used as cover material for active landfill. SESOIL leaching model run using site specific data and it showed that the groundwater would not be impacted with any petroleum constituents. Additional level of conservatism built in since soils will be mixed with clean fill, covered with at least 8 inches of clean soil and then revegated. Institutional controls will be in place and enforced by the closure plan submitted to the solid waste program to include restrictions for no residential land use or occupied buildings to ever be built on it. Louis Howard
4/17/2000 Report or Workplan Review - Other Draft Biocell Closure Report for Cape Romanzof Long Range Radar Site, AK February 9, 2000 reviewed by staff. The Department of Environmental Conservation (DEC) has received the above document on March 28, 2000. 4.0 Findings and Conclusions Pages 11-14: DEC concurs with the findings and conclusions presented in the report. Based on the SESOIL leaching assessment results it appears that the soils from the biocells will not cause a violation of groundwater standards. DEC requests clarification on whether the biocell soils will be used for the purposes of closure of the active landfill or in the normal day to day operations. It appears the USAF is operating a landfill which meets the definition of Class III municipal solid waste landfill (MSWLF). For the purposes of closure, the closure standards found in 18 AAC 60.390 Closure Standards for a Class III MSWLF and 18 AAC 60.396 Post-Closure Care Requirements for a Class III MSWLF apply at this landfill. Please contact Paul McLaruon in the Solid Waste Program at (907) 269-7642 for coordinating closure plan requirements and subsequent review. There will be a joint 611 CES & DEC meeting on the active landfill and reuse of the biocell soils as cover material on April 20 th 10 a.m. to 12 noon at DEC's 5th floor conference room. Your attendance is requested at this meetmg. Louis Howard
6/23/2000 Update or Other Action Biocell report received. The report documents biocell closure sampling activities and presents alternative cleanup levels (ACLs) to close the biocells and allow for beneficial use of the soil by the USAF as cover material at Landfill 2 (LF03), west of Lower Camp. During construction of the biocells, most of the material in the cells was screened to remove material greater than 2 inches in diameter, making it suitable for use as landfill cover material. Currently, the USAF does not have a readily available source of suitable cover material. Findings and Conclusions: Confirmation soil samples from Biocells 1 and 3 were collected and analyzed in accordance with the biocell closure plan. Two background soil samples for TOC analysis were collected from the area of the active landfill. These results were used in the leaching assessment evaluation and ACLs. Leaching assessment modeling performed as requested by ADEC in their biocell closure plan comments dated June 14, 1999 and discussed during a July 19, 1999 meeting (ADEC, USAF, USACE, HLA/Wilder) was conducted by using SESOIL. Multiple runs of the model with a range of input parameters indicate naphthalene (used as a conservative DRO Surrogate for the purpose of modeling) at a concentration equal to the maximum confirmation sample DRO concentration does not leach to a depth below the landfill after 25 years. Confirmation soil samples do not exceed the cleanup levels in evaluated in this report. Data presentation, calculations, and discussion in this report meet ADEC requirements for cleanup level approval and closure of Biocells 1 and 3. Closure of Biocells 1 and 3 will allow the USAF beneficial use of the soil in the biocells as cover material at Landfill 2 (LF03) does not have an available alternative source of suitable cover material. Louis Howard
8/30/2000 Report or Workplan Review - Other Staff reviewed and commented on draft long-term groundwater and surface water sampling plan for three sites at the facility (Landfill#2 LF03, SS13, SS15). 1.4 Scope of Work Page 2 The text states the surface water samples at SS13 and LF03 would be analyzed for the following petroleum constituents: diesel range organics (DRO), gasoline range organics (GRO), and residual range organics (RRO). Be aware that for surface water, the 611 CES must analyze for surface water quality criteria as required by 18 AAC 70.020 “Protected Water Use Classes and Subclasses; Water Quality Criteria; Water Quality Standards Table”. This is particularly applicable where Fowler Creek runs through a site that may be hydraulically connected, to the Lower Camp’s drinking water supply. Table 3.1 Soil/Sediment Sample Locations, Methods, MDL & PQL Page 2 The UST Procedures Manual states that for DRO analysis the method detection limit (MDL) must be at least 2 mg/kg and not 10 mg/kg as listed in Table 3.1. Benzene must have a practical quantitation limit (PQL ) of 0.02 mg/kg not 0.07 mg/kg as found in the table. Toluene, ethylbenzene, total xylenes must have a PQL of 0.05 mg/kg not 0.07 mg/kg as found in the table. For ICP contaminants of concern (metals) analyzed by SW6010B (and methods 7080A, 7130, 7420, 7520, and 7910) are for high contaminant level screening only. This method can be used for closure only if site specific MDL criteria are met. Analytical methods 6020, 7031A, 7060, 7061, 7081A. 7190, 7191, 7421, 7521, and 7911 are acceptable for closure. Table 3.2 Surface/Groundwater Sample Locations, Methods, MDL & PQL Page 2 DEC requests the 611 CES collect samples for determining TAH and TAqH below the surface of the water and away from any observable sheen. Concentrations of TAH will be determined through EPA Method 602 (plus xylenes) to quantify monoaromatic hydrocarbons. TAqH will be determined and summed using a combination of the previous method and EPA Method 610 to quantify polynuclear aromatic hydrocarbons. Use of any other alternative method requires prior DEC approval. Polychlorinated biphenyls in surface water and groundwater has a method detection limit of 1.0 ug/L for method 8082. Table C lists a lower cleanup value of 0.0005 mg/L (0.5 ug/L) for PCBs. DEC requests the 611 CES use an alternative method of analysis to achieve a method detection limit that is equal to or lower than the Table C values for PCBs. For additional information see site file. Louis Howard
9/30/2000 Update or Other Action Long term monitoring for LF03, SS13, SS15 conducted in September of 2000. All constituents at LF03 were non-detectable (except for metals) for all groundwater samples. High dissolved oxygen levels and acceptable pH indicate that conditions are present for intrinsic remediation processes. Nickel and Beryllium at CMW-3 slightly exceeded the MCLs. Lead and Cadmium exceeded the MCLs at CMW-4. CMW-3 and CMW-4 are located directly downgradient from the LF03 landfill. Elevated levels of metals at these wells may be associated with migration of contaminants from the landfill. Recommend continue long term monitoring of groundwater and surface water. Surface water samples were non-detect. Sediment samples from SD/SW-2 had PCB at 250 mg/kg (an increase over the 1997 and 1999 levels detected). Variability of PCB levels in this area may indicate a non-uniform distribution of PCB impacted sediment and soils from a previous spill event and/or migration of contaminants from the landfill. Recommend additional sediment samples in this area be taken to establish lateral extent of potential PCB impact and potential PCB migration from the landfill. Landfill cap inspection: The landfill cap cover shows exposed liner in several locations, tire tracks, and drainage channels on the slopes. Overall the cap is functional. Three seep areas with rust colored stained soils were identified. Recommend add fill and regrade the cap area to allow proper drainage. Collect representative samples from the seep areas to assess potential contaminant migration from the landfill. Louis Howard
10/16/2000 Meeting or Teleconference Held Staff met with communities of Chevak, Scammon Bay, Hooper Bay, Paimuit in Anchorage. Also present were the 611 CES-Environmental project manager, Community relations staff and the 611 CES Environmental Program Chief, U.S. Fish and Wildlife Service, Alaska Community Action on Toxics, Yukon-Kusko Health staff. Community members called for the meeting to be updated on what has happened at the facility, present and future work. Also they wished to be informed on any possible effects of contamination 15 miles upriver from their seasonal fish camps on the beach below the facility and the contamination present at the facility. Louis Howard
5/23/2001 Report or Workplan Review - Other Staff commented on the draft proposed plan for SS08 which affects LF03. Staff concurred with preferred alternative to transport treated soil from biocell to Landfill #2 LF03 and place it as additional cover material on a landfill. Soil samples collected from the bottom and sides of the excavation at the conclusion of soil removal confirm that soils containing DRO above the cleanup level were removed. The highest levels of DRO and GRO remaining in the completed excavation were 4.77 mg/Kg and 87.3 mg/Kg, respectively. The excavation was backfilled with clean fill. No contaminated soil remains at Waste Accumulation Area No. 3 (SS08). After removal of the soil, no further action is to be proposed since the remaining contaminants will be below action levels. Louis Howard
5/23/2001 Report or Workplan Review - Other Staff commented on the proposed plan for remedial action at Cape Romanzof LRRS dated April 2001. ADEC requests the Air Force identify the preferred alternatives on the introductory pages. Seven sites are being designated at no further remedial action & in fact have been approved as requiring no further action by ADEC in 1993. Three sites require some type of action & it should be stated briefly in the introduction what the preferred alternative is for each site. D11: Add text which states ADEC concurrence regarding the Air Force's request for no further action was granted by ADEC in a 1993 letter. This document (Proposed Plan) formalizes that no further action decision. LF02: Add text which states ADEC concurrence regarding the Air Force's request for no further action was granted by ADEC in a 1993 letter. This document (Proposed Plan) formalizes that no further action decision. LF12: Add text which states ADEC concurrence regarding the Air Force's request for no further action was granted by ADEC in a 1993 letter. This document (Proposed Plan) formalizes that no further action decision. OT06: Please clarify where the asbestos came from in the asbestos landfill that was observed, staked & placarded. Add text which states ADEC concurrence regarding the Air Force's request for no further action was granted by ADEC in a 1993 letter. This document (Proposed Plan) formalizes that no further action decision. SS01: Add text which states ADEC concurrence regarding the Air Force's request for no further action was granted by ADEC in a 1993 letter. This document (Proposed Plan) formalizes that no further action decision. SS10: Change text to state: The rationale for this alternative is that cleanup levels were not exceeded in the groundwater, which would allow for it to be used for drinking water. Add text which states ADEC concurrence regarding the Air Force's request for no further action was granted by ADEC in a 1993 letter. This document (Proposed Plan) formalizes that no further action decision. OT05:Add text which states ADEC concurrence regarding the Air Force's request for no further action was granted by ADEC in a 1993 letter. This document (Proposed Plan) formalizes that no further action decision. For additional information see site file. Louis Howard
9/18/2001 Report or Workplan Review - Other Clean Sweep Remedial Action Environmental Clean Up (Workplan) and A002 Sampling and Analysis Plan (Appendix C) Cape Romanzof Long Range Radar Site 2001 Contract #F41624-01-C-8072 reviewed and commented on by staff. The Alaska Department of Environmental Conservation (ADEC) has received the document on September 12, 2001 for review and comment. 4.3 Anticipated Corrective Actions and Assumptions Page 7 of 18 The text states that drums with product will probably contain POL products such as aviation gas, diesel fuel and lubricating oil. The assumption is incorrect since non-POL products may be present as well in one or more of the drams. The text also states that water without sheen will be immediately discharged on site. Having a sheen or not is one criteria that should be used, however there are other non-POL contaminants that do not exhibit a sheen and shall not be discharged directly to the lands or waters of the State without proper treatment. The 611 CES shall ensure that proper screening shall take place for all water present in containers prior to discharge. 4.5 Waste Management Plan Page 8 of 18 ADEC wishes to make the 611 CES aware that in order for the determination of whether or not a container is RCRA regulated, it must determine whether or not it is "hazardous debris." This determination is based on whether the container is intact and capable of containing 75% of its original volume. Per the definition of debris in 40 CFR 268.2, intact containers meeting these criteria are not debris. Therefore, intact containers can be rendered "RCRA empty" and thus non-regulated. On the other hand, if the container is not intact, draining the remaining residual waste does not render it "RCRA empty.” Rather, because it is considered debris instead of a container, it must be decontaminated in order to be excluded from regulation as hazardous waste. Ruptured containers which are not capable of containing 75% of their original volume do not qualify for the RCRA empty exclusion and are regulated unless decontaminated or covered by another exclusion (such as if being legitimately recycled as scrap metal). When managing corroded containers with residues of hazardous waste, do not automatically assume that it is excluded from regulation just because it contains less than an inch of residue. The RCRA empty exclusion applies only to intact containers. 4.5 Waste Management Plan: Drum Handling Pages 8 and 9 of 18 See comments regarding the disposal of water that does not exhibit any odor or sheen without further testing or field screening for hazardous waste characteristics. To determine whether a waste is in fact a hazardous waste, it is generally acceptable practice to apply user knowledge of the waste, although it may not be possible to accurately determine all the applicable waste codes without testing. However, it is generally not acceptable to categorize a waste as nonhazardous based solely on user knowledge of the waste. Louis Howard
11/6/2001 Update or Other Action Staff commented on & approved action at LF03 & SS13/SS15. The Proposed Plan finalizes earlier proposed plans for these 3 sites. Preparation of this Proposed Plan & the associated public comment period are required under Section 117(a) of the Comprehensive Environmental Response, Compensation & Liability Act (CERCLA, also known as the Superfund Program, as well as under 18 AAC 75 of the Alaska Administrative Code. The USAF’s cleanup program follows CERCLA guidance, although Cape Romanzof LRRS is not a Superfund site. The DoD is delegated authority & responsibility to carry out response actions, including clenaup, for hazardous substance releases on or from DoD facilities under Executive order 12580, Superfund Implementation. At sites under its control, the DoD has the lead agency authority to select remedial actions consistent with CERCLA Section 120. LF03 was the installation landfill & was used until the mid-1970s for disposal of garbage, rubbish, wood, metal, plastic, construction & demolition debris & incinerator ash. This landfill is located on the South side of the main access road from the runway to the Lower Camp facilities. The landfill covers approximately 1-1 ½ acres. Fowler Creek lies approximately 250 South of the landfill, with two small tributaries located between the landfill & the creek. One of these tributaries is adjacent to the landfill. PCBs volume estimated to be less than one-third of a cubic yard & cleanup level is 10 mg/kg (industrial land use presumed) from a high of 180 mg/kg for PCBs. In lieu of a Human Health & Ecological Risk Assessment a risk screening was accomplished at Cape Romanzof. Although chemicals are found in all media (soil, sediment, ground water & surface water) to varying degrees, there is limited exposure to humans at Cape Romanzof. Contaminated groundwater & surface water does not flow towards the drinking water source & exposure to contaminated soils & sediments is minimal. Overall, the risk screening process found that long-term risk to humans living & working at the site was at acceptable levels. Ecological Risk at Cape Romanzof is a more important consideration & is intimately tied to human health risk in the area. The area surrounding Cape Romanzof is a prime subsistence food gathering area for local communities. The possibility of contaminate migration is of extreme concern & importance to the health & well being of local residents. In order to address this concern, the 611 CES is funding a Contaminate Migration & Subsistence Foods Pathway study as a separate action to this Proposed Plan. However, some additional response action seems to be warranted to protect the health of the eco-system around Cape Romanzof. Landfill Closure/Hot Spot Removal is the recommended alternative for LF03. Contamination at the sites would continue to naturally degrade & monitoring would occur to verify that contaminate migration is not occurring. Monitoring (Landfill Cap inspection & repair) would also occur to verify that the integrity of the landfill cap is maintained. Louis Howard
11/28/2001 Meeting or Teleconference Held Staff traveled to Chevak to meet and participate in the public meeting held for the proposed plan on SS13, SS15, and LF03. Community members wanted to be more involved in the development of the draft document prior to the meeting held for the proposed plan. No objections to removal of the PCBs from LF03 out of state and no objections to monitored natural attenuation of groundwater at SS13 and SS15. Louis Howard
1/28/2002 Report or Workplan Review - Other Staff reviewed & commented on the Strategy for Developing a Scope of Work Ecological & Human Health Contaminant Evaluation Cape Romanzof Long-Range Radar Site April 2001. Determining whether or not gasoline (GRO) or diesel range organics (DRO) at the facility are directly related to any gasoline or diesel contamination present in tissue samples or ecological receptors & not other local sources is unreasonable. Instead, the Alaska Department of Environmental Conservation (ADEC) requests the ecological study limit GRO & DRO analyses to soil & water sampling efforts with contaminant specific analyses for everything else. For example, analyze for PCBs, polynuclear aromatic hydrocarbons (PAHs) & metals (e.g. lead, chromium, mercury, cadmium) if they were historically detected at the facility or are currently being monitored instead of fuel range constituents (DRO/GRO) for tissue samples & vegetation analyses. The ADEC requests the fish tissue sampling be done in accordance with US EPA document reference EPA 823-B-00-007 November 2000 “Guidance for Assessing Chemical Contaminant Data for Use in Fish Advisories” Volume 1 Fish Sampling & Analysis Third Edition. This particular document will be beneficial as a reference when conducting this particular phase of the ecological evaluation. There are recommended procedures for preparing whole fish composite homogenate samples, general procedures for removing edible tissues from shellfish, quality assurance & quality control guidance as well as much more important reference material in the EPA document. AK 103 analyses are not appropriate since residual range organics (RRO) not believed to be main contaminant of concern at the facility. The ADEC recommends that it be dropped from the study altogether & substitute some other more suitable analysis such as PAHs, semi-volatile organics or heavy metals that have historically or are presently being detected at Cape Romanzof LRRS facility. EPA has a recommended list of target analytes for tissue samples, which include: metals, organophosphate pesticides, chlorophenoxy herbicides, PAHs, PCBs, dioxin/furans, organochlorine pesticides. However, EPA states that to be most effective, one should recognize & carefully evaluate all existing data when assessing target analytes to monitor a particular site. Using a watershed approach gives the most flexibility to tailor a sampling & analysis program to obtain needed information as cost-effectively as possible by directing limited funding resources to obtaining information on contaminant levels most likely to be found in fish tissue at a given site. Dolly Varden is both a freshwater & a saltwater species depending on what age they are. For example, in their first & second year of growth they are resident fish staying in the streams until their third year. Most Dolly Varden migrate to sea in their third or fourth year, but some wait as long as their sixth year. After their first seaward migration, Dolly Varden usually spend the rest of their lives wintering in & migrating to & from fresh water. What this means for sampling tissue from Dolly Varden is that it is important to sample from only three year old Dolly Varden or less. Once they grow beyond the smolt stage (five inches or less in length), it is too late. For additional information see site file. Louis Howard
4/12/2002 Report or Workplan Review - Other Staff reviewed and commented on the Draft Work Plan and Possible Research Projects Cape Romanzof for Ecological and Human Health Contaminant Evaluation March 22, 2002. The ADEC requests further information on the laboratory methods being used, site-specific sampling methodology, holding times, sampling containers and preservation methods, detection limits, method detection limits, screening criteria and decontamination procedures that will be used on this project. The work plan does not have a quality assurance/quality control section, which would typically address most of these issues. The ADEC requests the Air Force provide additional information on storage and shipping of the samples to ensure holding times are met. Also, please provide an estimated schedule of the project with milestones for sampling events and draft reports. Also missing from the document are the applicable cleanup levels, sediment-screening criteria (e.g. NOAA), drinking water maximum contaminant levels (MCLs) that will used to compare the contaminant levels found during the investigation. The ADEC wishes to inform the Air Force that a background study of inorganics (metals) may have been done either by the Soil Conservation Service or US Geological Service. The information may already be present in one of their regional soil survey studies for CRLRR (Cape Romanzof Long Rage Radar) site or general vicinity. The ADEC has concerns that the sampling protocol presented may result in low confidence in the comparisons made. It appears the sample size for many species is not adequate to have confidence in the comparisons made. It is unclear why, in many cases, more samples are being taken at reference sites than at test sites. The ADEC requests that further information be provided regarding how reference sites were chosen and indicate if there are any other potential sources of contamination near the reference sites besides the CRLRR site. Throughout the document it references archiving of tissue samples for later analysis. The ADEC requests clarification on where and how the samples will be archived for further study. The ADEC requests clarification on whether or not metals are a contaminant of concern at CRLRR site. If the following metals were not identified as a COC at CRLRR site, then the ADEC questions the rationale behind analyzing for them in this study other than for establishing a background concentration: Antimony, Arsenic (carcinogen), Barium, Beryllium (carcinogen), Cadmium, Chromium (Total), Chromium +3, Chromium +6, Cyanide, Lead, Mercury, Nickel, Selenium, Silver, Vanadium, Zinc The mere presence of metals, PAHs, OC pesticides, or PCBs does not necessarily indicate that CRLRR site is the source of the contamination. Note to the Air Force: Normally projected costs such as collection, shipping of samples/sample containers are included in the overall budget of a project. For additional information see site file. Louis Howard
5/17/2002 Report or Workplan Review - Other Staff reviewed & commented on the draft Record of Decision for LF03, SS013, SS015. Main comments were to cut back on the use of tables where possible & only report those levels that are actually above established cleanup levels. The table shows PCB sample results above 50 ppm (mg/kg) concentration, which requires EPA involvement*. In 1997 PCB sample results show 69.1 mg/kg & in 2000 the level was 250 mg/kg (the associated numerical value is an estimated quantity). The Department strongly encourages the 611 CES to inform EPA about the removal of PCB contaminated soil from LF03. 40 CFR 761.61 regulates PCB remediation waste. In most cases, contaminated soil in Alaska is the result of spills or releases from transformers. Soil contaminated with PCBs from spills from such things as transformers may be considered PCB remediation waste & EPA involvement may be required. To determine this, the 611 CES needs to look at the definition of PCB remediation waste under The Toxic Substances Control Act (TSCA) of 1976 15 U.S.C. s/s 2601 et seq. (1976). If soil currently contains > 50 ppm, the source material must have also had a concentration > 50 ppm. So unless the 611 CES has knowledge that the source of contaminated soil was a spill between April 18, 1978 & July 2, 1979, where the source contained < 500 ppm, it appears that the soil is considered a PCB remediation waste regulated under TSCA. Please refer to the summary table below for information on cleanup level & disposal options for the “Self-Implementing Cleanup” option that the 611 CES has chosen to conduct for the PCB contaminated soils at LF03. Please note the soil would also be regulated under 18 AAC 75. The text states the USEPA guidance for documenting Record of Decisions (RODs) for Interim Remedial Action (IRA) under CERCLA does not establish chemical specific ARARs. Although federal facilities are encouraged to take early action at any facility where risk reduction can be accomplished promptly, the response action chosen must be one that will satisfy CERCLA & its implementing regulations. Early interaction with EPA, the state & the public will help ensure that removal actions are consistent with long-term actions & that cleanup levels will be based on risk assessment & Applicable or Relevant & Appropriate Requirements (ARARs) that will be sufficient to be the final action, whenever possible. For additional information see site file. Louis Howard
7/14/2002 CERCLA ROD Approved Jennifer Roberts, DoD section manager, signed an interim record of decision (ROD) for LF03, SS015, SS013. (This is not a CERCLA site; however the Air Force is following the CERCLA process and this is the most representative action available on the CS database.) The contaminants & media of concern for site LF003 are DRO & PCBs in sediment approximately 50 feet down gradient of the landfill cap. While not on National Priorities List under CERCLA, the DoD Component must comply with CERCLA, Executive Order 12580 & DERP. Executive Order 12580, signed in January 1987, addresses delegation of duties & powers assigned to the President in CERCLA. Remedial Action Objections for: LF003 Surface Water PCB 0.0005 mg/L (0.046 mg/L SD/SW-2000) Sediment PCB 10 mg/kg (250 mg/kg SD/SW-2 2000). ADEC has identified chemical-specific ARARs for these sites as including the Alaska Water Quality Criteria set forth in 18 AAC 70.020 (relevant & appropriate for Contaminants of Concern in surface water & groundwater that influences surface water) & the soil cleanup levels for contaminants of concern set forth under 18 AAC 75.341 Method 2 (relevant & appropriate for contaminants of concern in soil & sediments). The interim remedial action set forth in this decision document has the goal of attaining these chemical-specific ARARs but actual attainment of these chemical-specific ARARs may be deferred to the final remedial action to be adopted in the final record of decision for these sites. For LF03 a relevant & appropriate location-specific ARAR is the monitoring requirement for closed landfills as set forth under 18 AAC 60. Action-specific ARARs include those regulations applicable to the removal & disposal of PCB contaminated sediment. The selected action for LFOO3 will meet the following action-specific ARARs: • Toxic Substances Control Act, 15 USC 2601 et.seq. & 40 CFR 761 is applicable for the disposal of PCB remediation waste: • Alaska Air Quality Control Regulation 18 AAC 50.050(0 is relevant & appropriate for the selected remedy for dust suppression during excavation of PCB-impacted sediments: • Off Site Disposal Rule, 40 CFR 300.440 for the transportation & disposal of PCBcontaminated soil/sediments. DESCRIPTION OF THE SELECTED REMEDY The selected interim remedy includes the following components: Landfill Closure combined with PCB Hotspot Removal is the selected remedy for LF03. The main elements of the landfill closure portion of the alternative are capping & long-term monitoring of groundwater & any effluent generated by the landfill. Approximately.5 cubic yards of PCB contaminated sediment will be excavated & shipped to an approved PCB disposal facility. For additional information see site file. Jennifer Roberts
8/20/2002 Report or Workplan Review - Other Staff reviewed & commented on the eco-survey revised work plan for the facility. Same comments apply from April 2002 comment letter on work plan & scope of work. Meeting on August 22, 2002 to discuss comments is scheduled with community, 611CES, YKHC & perhaps USFWS staff. The Department requests clarification on the specific laboratory methods & protocols being used for water & sediment sampling. For example, polynuclear aromatic hydrocarbons (PAHs) using EPA Method 8270C or 8310 requires sample preservation will be 4 degrees C plus or minus 2 degrees preserved with Na3S2O3, dark / 7 days to extraction, 40 days to analysis of extract. It is not clear to the Department who is the “qualified person” for the project that will be on site twenty-four hours a day during all sampling collection activities at each sampling point. The organizational chart identifies Albert Simon as the sampling leader who will report weekly field progress to Tauni Rogers or Gretchen Brown. The Department requests clarification from the Air Force on what the qualifications of each person that will be the “qualified person” on site at each sampling location. The text states that the two objectives for the project are to determine if site-related chemicals are present that may pose unacceptable risk to humans consuming contaminated biota & if site-related contaminants pose an unacceptable risk to ecological receptors that frequent Cape Romanzof LRRS. The two objectives have not been adequately demonstrated that any chemicals or contaminants are “site-related” in the first place. Potential exposure pathways must meet specific criteria for an exposure to occur. Aside from reasonably anticipated future land & water use by humans & necessary habitat for ecological receptors, a complete exposure pathway must satisfy the following elements: Contaminant source (e.g., chemicals in soil, water), Mechanism for contaminant release & transport (e.g. surface-water runoff), Exposure point (e.g. water), Feasible route of exposure (e.g. ingestion), & a Receptor (e.g. people, plant, bird). For additional information see site file. Louis Howard
9/30/2002 Update or Other Action Clean Sweep Remedial Action Report received for work performed under contract#F41624-01-C-8072. Cape Romanzof drum recovery activities were conducted in September & October 2001. During this project 183 drums & containers were identified. This included 167 drums located within the Fowler Creek Drainage Area & 16 drums determined to be located outside the drainage area. Of the 167 drums within the drainage area, a total of 148 drums & containers were located & marked, screened, recovered & disposed of at the Cape Romnanzof landfill. A total of 16 drums & containers were located & marked but could not be removed by hand. Drums & containers that required machinery for removal were not part of this scope of work. Of the 148 drums & containers that were removable by hand, 140 were determined to be empty or only held vegetation, sediment or water, & were disposed of on-site. Eight drums contained a small amount of water with sheen. The contents of these eight drums were consolidated into one new recovery drum. The eight empty drums were disposed of on-site. The consolidated liquid in the recovery drum, approximately 30 gallons, was sampled & analyzed for Oil Burning Specifications. Two separate samples were collected & submitted to the laboratory for analysis & each time the laboratory could not conduct the analysis because the samples contained too much water. The recovery drum & contents were processed by Energy Recovery Services Inc. Representative soil samples were collected randomly from drum location areas to determine levels of various contaminants of concern. Sampling areas included locations visible container indentations, areas with no indentations, & areas adjacent to surface water. A total of 27 soil samples, including 3 duplicates, were submitted to CT&E Laboratory in Anchorage AK. DRO & RRO compounds were detected at all sample locations. DRO levels ranged from 40 to 2,500 mg/Kg. RRO compounds ranged from 144 to 9,320 mg/Kg. A total of 68 semi-volatile hydrocarbon compounds were analyzed for SVOCs per EPA method 8270. No SVOC compounds were detected in any of the samples. Total lead levels at two locations exceeded the HUD soil lead guidelines of 400 mg/Kg for residential & 1,000 mg/Kg for industrial. Sample #CR55 had a lead level of 418 mg/Kg; sample #CR1 18 had a lead level of 4,460 mg/Kg. Total lead concentrations for all other samples ranged from 2.7 to 151 mg/kg. No PCB compounds were detected in any of the samples. For additional information see site file. Louis Howard
3/10/2003 Report or Workplan Review - Other Staff reviewed the draft final version of the Cape Romanzof contaminant migration and subsistence receptor study quality assurance and project work plan. The Department approved the work plan as submitted. Just a reminder, while the 611 CES has obtained an approval from the Department, this approval does not mean there are not other regulations that may apply and other entities that need to be coordinated with on the work plan. For example: •EPA for TSCA and RCRA issues, •State Historic Preservation Office (SHPO) on historical sites, •National Park Service on National Historic Landmarks, •Alaska Department of Fish & Game for work involving anadromous streams, •Alaska Department of Natural Resources for work involving tidelands, •US Fish & Wildlife Service (FWS) on threatened and endangered species. The Department’s 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 we may comment on other state and federal laws and regulations, our concurrence on the plan does not relieve the 611 CES, its contractors, its subcontractors, or volunteer staff from the need to comply with other applicable laws and regulations. Louis Howard
6/4/2003 Update or Other Action Clean Sweep Work Plan and Field Sampling Plan received for LF-003. Work planned for FY 2003 includes inspecting the cap for integrity and serviceability. Soil field screening analysis (PetroFlag and Dexsil Chloride) for petroleum hydrocarbons and chlorinated compounds will be conducted in areas of suspected and potential contamination down gradient of the landfill. Soil and surface water samples from sampling site SD-2, have repeatedly contained levels of PCB’s that exceed ADEC clean up levels for soil or are above recommended background levels for water. Soil, groundwater, sediment and surface water samples adjacent to SD-2 contain minor to undetectable amounts of PCB contamination. The source and extent of the PCB contamination at SD-2 cannot be determined until removal of the contaminated soil is underway. It is possible that the elevated PCB levels at SD-2 are the result of point source contamination or that they are the result of contaminated leachate migrating from the landfill. If the latter is true, then removal of the overlying boulders up and down gradient from SD-2 will have to be accomplished in order to ascertain the extent of the contamination, its source and allow for the excavation of contaminated soil and source. Laboratory samples will be collected in areas of PCB/petroleum hydrocarbon contamination occurrences in order to assess current levels and distribution of contaminants of concern. Laboratory samples will be analyzed for DRO (AK102), PCBs/ pesticides (8082), and semi-volatile (8270) organic compounds. Soil with petroleum hydrocarbon contamination above ADEC clean up levels (18 AAC 75, table B2, Under 40” zone, migration to groundwater) and PCB concentrations above 1.0 ppm will be excavated until the remaining soil meets the aforementioned clean up criteria. The excavated soil will be stored either in 55 gallon drums or soil sacks for shipment to DRMO at Elmendorf AFB for disposal or stored on site in contaminated soil storage cells in the event that the amount of excavated soil is prohibitive to shipping. Louis Howard
6/20/2003 Update or Other Action Proposed Amendments and Modifications to the Cape Romanzof Workplan in FY2003 Modifications Section 8.3 Above Ground Storage Tank Berm Adjacent to Building #4100 Modification: No work is planned for this site in FY2003. Section 8.4 LF-003 (Landfill #2) Modification: Remediated soil from 2 on site bio-remediation soil cells will be spread and contoured over the top of the landfill. Approximately 5500 cubic yards will be used to form a 0-3 foot lift on the existing landfill cap. The fill will be added to this site only, based on the approval letter from ADEC dated April, 17, 2000. Amendments Section 8.5 Closure of Bio-Remediation Cells 1 and 3. Amendment: Biocells 1 and 3 (figure 5) will be emptied following confirmation sampling of the remediated soil. Each soil cell contains approximately 2750 cubic yards of soil and gravel. The connate water within the cells will be pumped through a cyclo-sorb activated carbon water filter and disposed of on site. Following dewatering, the soil will be excavated and used as cover material for LF03. The upper and lower membranes as well as any associated venting material, will be disposed of in the on site landfill. The gravel containment berms from the cells will be graded to fit the contours of the landscape. Louis Howard
9/24/2003 Report or Workplan Review - Other Staff reviewed and commented on the environmental sampling and analysis plan for LF03, SS13, SS15. The text states the PCB cleanup level in soil in 10 mg/kg. The Department does not concur. The cleanup level for total PCBs is 1 mg/kg irregardless of land use or precipitation zone. 18 AAC 75 contaminated sites regulations for PCB soil cleanup states: For unrestricted land use, PCBs in soil shall be cleaned up to one (1) mg/kg or less, unless the Department determines that a different cleanup level is necessary as provided in 18 AAC 75.340(i), as, for example, in a subsistence food gathering area. With the prior approval of the Department, PCBs in soil may be cleaned up to (A) between 1 and 10 mg/kg if the 611 CES (i) caps each area containing PCBs in soil at levels between 1 and 10 mg/kg; for purposes of this Note 9, “caps” means covering an area of PCB contaminated soil with an appropriate material to prevent exposure of humans and the environment to PCBs; to be approved, a cap must be designed and constructed of a material acceptable to the Department and of sufficient strength and durability to withstand the use of the surface that is exposed to the environment; within 72 hours after discovery of a breach to the integrity of a cap, the 611 CES or the landowner shall initiate repairs to that breach; and (ii) provides the Department within 60 days after completing the cleanup, documentation that the 611 CES has recorded a deed notation in the appropriate land records, or on another instrument that is normally examined during a title search, documenting that PCBs remain in the soil, that the contaminated soil has been capped, and that subsequent interest holders may have legal obligations with respect to the cap and the contaminated soil; or (B) an alternative PCB soil cleanup level developed through an approved site-specific risk assessment, conducted according to the Risk Assessment Procedures Manual, adopted by reference at 18 AAC 75.340. The alternatives listed above are the only options available to the 611 CES for which it may have PCB soil cleanup levels greater than one (1) mg/kg in soil at its facility. Just a reminder, while the 611 CES has obtained comments from the Department, these comments do not mean there are not other regulations that may apply and other entities that need to be coordinated with on the documents. For example: •The applicable EPA rule governing disposal and cleanup of PCB contaminated facilities under 40 C.F.R. Part 761.61 (PCB remediation waste) may apply to PCB cleanup at this facility. This would require coordination with EPA Region 10 TSCA program staff. The PCB cleanup levels listed in Table B1 are based on cleanup levels referred to in 40 C.F.R. 761.61 for high occupancy areas with no cap. •Coordination with EPA Region 10 RCRA staff for RCRA issues, •State Historic Preservation Office (SHPO) on historical sites, •National Park Service on National Historic Landmarks, •Alaska Department of Fish & Game for any work involving anadromous streams, •Alaska Department of Natural Resources for work involving tidelands, •US Fish & Wildlife Service (FWS) on threatened and endangered species which may be present or migrate through the area. For additional information see site file. Louis Howard
9/30/2003 Update or Other Action In 2003, groundwater analytical results indicated the presence of gasoline range organics (GRO), DRO, and toluene below regulatory limits from several monitoring wells. Surface water analytical results indicated the presence of DRO (SW-2 and SW-3) and toluene (SW-3) below regulatory limits. Sediment analytical results indicated the presence of GRO, DRO, and PCBs. DRO and PCBs exceeded regulatory limits at SD- I (PCBs) and SD-2 (DRO and PCBs). Louis Howard
1/5/2004 Update or Other Action Draft Final Clean Sweep report received. Work conducted in FY 2003 included inspecting the cap for integrity & servlceability. A sediment sample (53031038002) collected at SD-2 contained 60.2 mg/Kg of Aroclor 1260 (PCB) (Figure 5). The subsurface stream was traced under & through the boulder field by visual & auditory observations untd another sediment sample could be obtained. Sample 53031038003 was collected approximately 120 feet downstream of 53031038002 & contained an Aroclor 1260 concentratlon of 395 mg/Kg (Photograph #4). Further sampling could not be accomplished without the aid of an excavator. The extent of the PCB contamination initially documented at SD-2, cannot be determined until removal of the overlying boulder field has commenced. Sediment sample 53031038004 was collected from the roadside drainage upgradlent of 53031038002. Analytical results indicate no PCB contamination at this location. The landfill cap was in serviceable condition although there were several locations where the edges of the membrane were visible along the margins of the landfill. Recommendations Include: • Detailed mapping of the sub-surface stream course that is bearing PCB contaminated sediments. The mapping should include the streams outfall into Nilumat Creek. • Because there are numerous pockets of sediments in the boulder field interstices, only sediment samples that can be confidently identified as having been deposited by the sub-surface stream in question should be sampled. This sampling may involve moving boulders in order to gain access to the sediment samples. Invasive sampling of this type should be initiated at the downstream end of the drainage & proceed in a methodical upstream direction in order to prevent cross contamination. • Variations in the streams depth & width due to influxes of rainwater/seasonal meltwater dictate that sediment samples on either side of the streams present configuration be sampled as well. Again, only samples that can be confidently identified as having been deposited by the sub-surface stream in question should be sampled. • Following definition of the contaminated area, the contaminated sediment will have to be collected & shipped off site for disposal. For additional information see site file. Louis Howard
2/26/2004 Update or Other Action Biocell soil was placed on LF003 as cap material and covered with impermeable liner in 2004. The biopile soil shall NOT be placed in an "environmentally sensitive area" which is defined as a geographic area that, in the department's determination, is especially sensitive to change or alteration, including (A) an area of unique, scarce, fragile, or vulnerable natural habitat; (B) an area of high natural productivity or essential habitat for living organisms; (C) an area of unique geologic or topographic significance that is susceptible to a discharge; (D) an area needed to protect, maintain, or replenish land or resources, including floodplains, aquifer recharge areas, beaches, and offshore sand deposits; (E) a state or federal critical habitat, refuge, park, wilderness area, or other designated park, refuge, or preserve (F) area which merits special attention as defined by AS46.40.210(1)-- Sec. 46.40.210. Definitions. In this chapter, unless the context otherwise requires, (1) "area which merits special attention" means a delineated geographic area within the coastal area which is sensitive to change or alteration and which, because of plans or commitments or because a claim on the resources within the area delineated would preclude subsequent use of the resources to a conflicting or incompatible use, warrants special management attention, or which, because of its value to the general public, should be identified for current or future planning, protection, or acquisition; these areas, subject to council definition of criteria for their identification, include: (A) areas of unique, scarce, fragile or vulnerable natural habitat, cultural value, historical significance, or scenic importance; (B) areas of high natural productivity or essential habitat for living resources; (C) areas of substantial recreational value or opportunity; (D) areas where development of facilities is dependent upon the utilization of, or access to, coastal water; (E) areas of unique geologic or topographic significance which are susceptible to industrial or commercial development; (F) areas of significant hazard due to storms, slides, floods, erosion, or settlement; and (G) areas needed to protect, maintain, or replenish coastal land or resources, including coastal flood plains, aquifer recharge areas, beaches, and offshore sand deposits; Louis Howard
5/17/2004 CERCLA RI Plan Approved Work plan approved for remedial investigation/feasibility study work at LF03 Landfill No. 2, SS13 Diesel Seep Area, SS15 UST Spill Area, ST09 Former Truck Fueling Station, SS14 Former Drum Storage Area and DP11 Towek Mountain Debris Area. The Alaska Department of Environmental Conservation (the Department) has received the document for review and comment on May 10, 2004. The Department has reviewed the work plan for Landfill No. 2 LF03, Diesel Seep Area SS13, UST Spill Area SS15, Former Fueling Station ST09, Former Drum Storage Area SS14 and Towek Mountain Debris Area DP11. The Department will approve this specific draft version as a final version. The Department’s review and comment on this work plan is to ensure that the work is done in accordance with State of Alaska environmental conservation laws and regulations. While the Department may comment on other state and federal laws and regulations, our comments on the plan does not relieve the 611 CES employees, contractors, subcontractors, or volunteer staff from the need to comply with other applicable laws and regulations. For example: -The applicable Environmental Protection Agency (EPA) rule governing disposal and cleanup of polychlorinated biphenyls (PCBs) contaminated facilities under 40 C.F.R. Part 761.61 (PCB remediation waste) may apply to PCB cleanup at this facility. This would require coordination with EPA Region 10 Toxic Substances Control Act (TSCA) program staff. -Coordination with EPA Region 10 RCRA staff for Resource Conservation and Recovery Act (RCRA) issues, -State Historic Preservation Office (SHPO) on historical sites, -National Park Service on National Historic Landmarks, -Alaska Department of Natural Resources-Office of Habitat Management: Area III Office for any work involving anadromous streams, -Alaska Department of Natural Resources-Alaska Coastal Management for work involving tidelands/coastal zone (Northwest Region), -US Fish & Wildlife Service (FWS) on work that would possibly impact threatened and endangered species which may be present or migrate through the area. Louis Howard
11/16/2004 Update or Other Action File number issued 2526.38.001 Aggie Blandford
11/30/2004 Update or Other Action Final report for Landfill 2 (LF03) SS13, SS15 Long Term Monitoring (LTM) and soil sampling at SS13 and SS15. In 2003, groundwater analytical results indicated the presence of gasoline range organics (GRO), DRO, and toluene below regulatory limits from several monitoring wells. Surface water analytical results indicated the presence of DRO (SW-2 and SW-3) and toluene (SW-3) below regulatory limits. Sediment analytical results indicated the presence of GRO, DRO, and PCBs. DRO and PCBs exceeded regulatory limits at SD- I (PCBs) and SD-2 (DRO and PCBs). LF03 Recommendations: Continue Long Term Groundwater Monitoring at MW-1, CMW-1, CMW-3, CMW-4, CMW-5, CMW-6, CMW-7, and CMW-8. Repair well MW-1 by replacing damaged above ground PVC section and installing a cap. Fabricate and install a lid for stickup monument. Continue Long Term Surface Water Monitoring at SW-1, SW-2, and SW-3. Continued Long Term Sediment Monitoring at SD-1, SD-2, and SD-3 is strongly recommended. The collection of additional sediment samples down gradient of the landfill cap (in vicinity of SD-2) to establish lateral extent of PCB impact and potential PCB migration from the landfill is also recommended. Although the landfill cap was not inspected as part of this effort due to snow cover, continued inspection is warranted, especially in light of the increasing PCB concentrations observed in sediment down gradient (SD-2). The recommendation from the 2000 Long Term Monitoring Report to add fill and regrade the landfill cap area to allow proper drainage should be considered. The 2000 inspection also identified three seep areas with rust colored stained soils. Sampling of sediments and possibly water at these sites should be performed to assess potential contaminant migration from the landfill. Limit excavation may also be warranted in these areas to expose and inspect the integrity of the hypalon liner itself. Louis Howard
2/8/2005 Update or Other Action Former Landfill LF03 Surface Soil Investigation Report. Nine of the 18 samples had PCB concentrations above the ADEC cleanup level of 1.0 mg/kg. Araclor-1260 was the only PCB compound detected during the investigation. Concentrations of PCB-1260 are consistently above the cleanup level in samples taken along the seep flow path. PCB concentrations are generally higher closer to the landfill and decrease down gradient. The highest concentration of PCB was noted in sample SS-18, just downgradient from SD2, with a concentration of 195 mg/kg. SS-18 was collected west and down slope of SD2 in the approximate location of where PCBs at previously been detected at a concentration of 395 mg/Kg. No samples taken from the Fowler Creek area were above the cleanup level. Cleanup of PCB soil at this site could be logistically complicated. Because of the presence of large boulders onsite, cleanup strategies could involve excavators, hand operated suction devices, construction of sediment trapping devices, and extensive manual labor. Accurate estimates of the contamination extent will help keep costs lower and disturbance to the site to a minimum. We recommend that all future sampling be clearly marked with flagging and GPS sample coordinates to assist in future cleanup efforts. As evidenced by the three seep emerging from the landfill toe, water is still entering the landfill, despite the landfill cap. Future efforts to prevent water from entering the landfill is recommended, as these efforts may prevent further migration of PCBs downgradient towards Fowler Creek. Possible efforts to prevent infiltration of water could include: Divert drainage ditch upgradient of road, Build impermeable water device layers upgradient of landfill, Constuct a bottom liner for landfill. Louis Howard
3/28/2005 Update or Other Action Environmental Monitoring Report March 28, 2005 received. There were no analytes detected above preliminary remedial action objectives (RAOs) in 2004 Groundwater samples from LF03 monitoring wells MW-1, CMW-1, CMW-2, CMW-3, CMW-4, CMW-5, CMW-6, and CMW-7. The primary line of evidence for natural attenuation in groundwater, a stable to shrinking groundwater plume, can be inferred from the data collected at this site. An apparently declining DRO concentration trend has been observed at CMW-1, CMW-2, CMW-4, CMW-5, and CMW-7. The DRO concentrations at MW-1, CMW-3, and CMW-6 have been too low to discern any trend. The concentrations of all other analytes have been too low to discern a trend. Surface water contamination at LF003 has been limited to PCBs exceeding regulatory limits at all three monitoring locations in 1997, and at SW-2 in 1998 and 2004. Various petroleum hydrocarbon constituents, VOCs, SVOCs, and metals have been periodically detected in surface water below water quality standards. Sediment contamination at LF003 is comprised mainly of DRO at all three monitoring locations, and PCBs at SD-2 (ranging from 65.8 to 630 mg/kg). Methylene chloride has been detected occasionally in sediments at LF003 at levels exceeding regulatory limits. Similarly, arsenic and chromium have also been detected in excess of regulatory limits occasionally in sediments at LFOO3. Various SVOCs (phithalate compounds) were detected sporadically throughout LTM, and metals concentrations have varied through time at all three monitoring locations. Recommendations • Groundwater, soil, sediment, and surface water monitoring should continue. Additional data will allow continued evaluation of MNA processes at this site. • A statistical analysis of groundwater concentration trends should be made with the next data set collected at this site. These tests should be nonparametric (e.g., Mann-Kendall). • All wells should be surveyed, and an accurate water table map should be created using data from this site combined with any information from water elevations at nearby sites. • Petroleum hydrocarbon levels are so low that no recommendation can be made to monitor for additional electron acceptors. Such monitoring is unlikely to show any clear patterns between contamination and electron acceptor levels. Cap Inspection & Repair Recommendations: As part of LTM activities at LF03, the field crew visually inspected the entire extent of the landfill cap and documented its condition in field notes, site sketches, and photographs. As evidenced by the three seeps emerging from the toe of the landfill, water is still entering the landfill, despite the landfill cap. Future efforts to prevent water from entering the landfill is recommended, although they may not involve repair of the surface cap. It is recommended that all exposed areas of the landfill’s surface cap liner be covered with soil. This should be done with minimal disturbance of soil to avoid spreading PCB impacted soil around discovered in the lower areas of the landfill. For additional information see site file. Louis Howard
4/18/2005 Report or Workplan Review - Other Staff provided comments on the draft Environmental Monitoring Report. Staff concurred with recommendations for LF03. Staff also commented on the landfill capping proposal. At a minimum, the landfill’s surface cap liner must be covered by soil. The final cover must be at least 24 inches thick, or another thickness approved by the ADEC, must be graded to promote drainage without erosion, and must be revegetated to minimize erosion. Louis Howard
8/15/2005 Report or Workplan Review - Other Staff reviewed and commented on the Draft Contaminant Migration Study. General Comments-The evaluation should not have calculated consumption rate limits, but should have used available information about consumption rates to calculate current risk to the reasonable maximum exposure (RME) receptor. ADEC does not have the authority to set consumption rate limits, and the presentation of data in this document could be misinterpreted as an attempt to do so. Discussion of Department of Health policy should be reviewed by that specific department. Consultation with the Department of Health is highly recommended to discuss how to proceed with species showing a possible elevated risk. Below is the information for the Department of Health, Epidemiology’s Point of Contact Elizabeth “Beth” Funk, MD, MPH. Phone: (907) 269-8004 email: beth_funk@health.state.ak.us fax: (907) 562-7802. Information from the Alaska Native Health Board (ANHB) consumption study should be integrated as much as possible into this evaluation. In several instance values were compared to Environmental Protection Agency (EPA) data only, but the ANHB study has a greater chance of being an accurate portrayal of subsistence use. Since all of the data, database and calculations (Attachments D & E, respectively) have not be received for review, further comments may be pending from ADEC. Louis Howard
12/21/2005 Update or Other Action Final report received - Cape Romanzof Contaminant Migration & Subsistence Receptor Study. The primary objective of the project was to determine if chemicals are present in fish, mammals, shellfish, & other ecological receptors at CRLRRS at concentrations that may pose unacceptable risk to humans consuming contaminated biota during subsistence activities. Secondary objectives included an evaluation of potential migration of contaminants from CRLRRS into the surrounding environment & potential hazards to ecological receptors. There are approximately fifteen sites at CRLRRS that have been contaminated by past military site operation & maintenance activities. The list of contaminants of concern (COCs), agreed upon by all interested parties (i.e. local villagers & agencies), includes fuel components such as diesel range organics (DRO) & polynuclear aromatic hydrocarbons (PAHs), polychlorinated biphenyls (PCBs), & the heavy metals lead & cadmium. Sediment, water, animal tissue, & plant tissue samples were collected by local volunteers (trained villagers & a qualified person) & analyzed for COCs. The data were evaluated to test 4 specific hypotheses established to meet project objectives. Testing of these hypotheses included both quantitative & qualitative evaluation of the data. A primary focus of the study was comparison of the presence & concentration of chemicals potentially related to the CRLRRS at different geographic locations, including: 1) areas that are highly unlikely to have been impacted by chemicals from CRLRRS & are many miles away (Reference); 2) areas that are in the vicinity of CRLRRS but unlikely to be impacted (On-Site Reference); & 3) areas directly down gradient or in water bodies receiving drainage from CRLRRS (On Site). Hypothesis A: COCs originating from the CRLRR Site are not moving via the creeks. a) This hypothesis is true based on statistical tests comparing sediment & water data at On Site locations with Reference/On-Site Reference locations. b) With the exception of PCBs in water, for which minimal conclusions can be drawn, the data support the inference that there is little significant difference between the mean concentrations of COCs from On Site samples compared with Reference samples. Lack of a statistically significant difference infers that some of the biota contamination may be resulting from a non-point source such as regional atmospheric deposition. c) Statistics were not performed on PCBs in water samples due to the low number of detections; however, the detection limit was above the screening level used to protect human health. This means that PCBs in water could be present that may be deleterious to human health & overall site risk may be underestimated. For additional information see site file. Louis Howard
6/8/2006 Report or Workplan Review - Other FYI entry: John Halverson (ADEC) denies 611 CES/CEVR request for waiver of the requirement that an "Impartial Third Party" conduct sampling. We received your request for a waiver of the state requirement that a qualified, impartial third party conduct sampling, analysis, interpretation & reporting of characterization & cleanup data for work planned at Barter Island this summer. Specifically, the request was for the Civil Engineering Squadron, Environmental Operations Section (CES/CEVO) staff to be approved for collecting soil, sediment & concrete samples at Installation Restoration Program & Clean Sweep sites. However, ADEC has several concerns over past work conducted by the CES/CEVO, which lead to our denial on the request for a waiver. It has come to our attention that the CEVO work crew allegedly discovered releases of oil or other hazardous substances & failed to report the releases to DEC in a timely manner as required by 18 AAC 75.300; assessment/cleanup reports prepared by the CEVO lack detail & required information; the field crew has reportedly not followed approved work plans. A few examples of this include: - Point Lay where "gross petroleum contamination" was found during removal of bulk fuel tanks in 2005. We have found no record of a spill report being submitted, our contaminated sites staff working on the site was not informed, the draft report submitted this year failed to describe the release or extent of contamination clearly & instead described sampling in downgradient test pits & recommended natural attenuation for the area. - Point Lonely, where several large fuel tanks, a pumphouse & associated piping, & petroleum contaminated soil were removed in 2005. The draft report does not adequately describe fieldwork that was conducted during the characterization & removal of the contaminated soil & lacks required information (no data quality review, lack of laboratory data). DEC comments on the draft report have yet to be addressed & no final report has been submitted. A survey of our project managers indicates there has a consistent problem with the CEVO reporting information in a clear, understandable & complete manner. Based on these issues, we regrettably must deny your request for a waiver of the impartial third party sampler. As discussed with Mr. David Longtin of the 611 CES/CEVR, Air Force staff may conduct field screening & sampling to evaluate whether a release of oil or hazardous substances has occurred; however, a qualified impartial third party must conduct or oversee sampling, data collection & interpretation & reporting for contaminated site characterization & cleanup work on sites where releases have been confirmed. For additional information see site file. John Halverson
7/18/2006 Update or Other Action Work plan for 2006 Environmental Monitoring at LF03, SS13 and SS15 received. The purpose of this project is to comply with the 2002 Interim Record of Decision (ROD) and assess the effectiveness of actions prescribed therein for these sites. Environmental monitoring directed by the 2002 ROD includes long-term monitoring (LTM) of groundwater and effluent at the closed landfill LF03, monitored natural attenuation (MNA) of sediment and near surface soil at SS13, and MNA of groundwater at SS15. The purpose of the LTM is to assess the effectiveness of the landfill cap in providing adequate protection of human health and the environment. The purpose of the MNA study is to evaluate natural attenuation rates for identified contaminants of potential concern (COPCs) in impacted media. Field and sampling activities described in this work plan are intended to meet the data quality objectives (DQOs) identified for this project, which are largely based on the requirements identified in the 2002 ROD. Environmental sample analytical results obtained from the sampling effort will be compared to remedial action objectives (RAOs). Site-specific tasks that will be completed at LF03 are as follows: • Collect the following samples: Groundwater sample from 8 monitoring wells (MW-1, CMW1, CMW2,CMW3, CMW4, CMW5, CMW6, and CMW7). Surface water samples from 3 locations (SW-1, SW-2, SW-3). Sediment samples from 3 locations (SS-1, SS-2, SS-3). • Visually inspect and document soil cap conditions over the entire extent of the LF03 area. Field observations should be documented in the field notes, site sketches, and photographs. Louis Howard
7/21/2006 Report or Workplan Review - Other Draft Work Plan 2006 Environmental Monitoring Study LF03, SS13, SS15 Cape Romanzof LRRS reviewed by staff. Staff approved work plan as submitted. Louis Howard
2/23/2007 Exposure Tracking Model Ranking Louis Howard
8/1/2007 Meeting or Teleconference Held A TRIAD systemic project planning meeting was hosted by the USACE and attended by USAF, ADEC, and BLM. Several data gaps and uncertainties for four sites were identified during this meeting. IRP Site LF003, Landfill Number 2: Are any of the multiple discharges from LF003 impacting Fowler (Nilumat) Creek? What is the extent of PCB contaminatino surrounding the landfill? Is additional PCB sampling needed for the creeeks/drainages east of LF003? Are there PCB sources surrounding the former soil/sediment sample location SS18? What is the concentration distribution of PCBs in the seep bed between former sediment sample locations SS18 and SS07? Is there an upstream source impacting Fowler (Nilumat) Creek other than LF003? Louis Howard
9/18/2007 Update or Other Action Workplan (WP) approval requirements & quality assurance oversight on Performance Based Contracts (PBCs) letter from John Halverson (ADEC) to Scott Hansen (611 CES). ADEC is writing to remind you of contaminated site WP approval requirements in AK’s oil & hazardous substance pollution control regulations & UST regulations. Additionally, ADEC is concerned over quality assurance on PBCs. WP Approval-Several 611 CES environmental restoration projects were implemented this summer without obtaining prior WP approval from DEC. The site cleanup rules require ADEC approval on WPs before beginning interim removal actions (18 AAC 75.330), site characterization work (18 AAC 75.355), or cleanup operations (18 AAC 75.360). Similarly, the UST regulations specify ADEC may require a corrective action plan be submitted for approval prior to conducting corrective action at an UST release site (18 AAC 78.250). ADEC staff strives to complete plan reviews & respond to responsible parties within thirty (30) days after receipt of plans, although this is not always possible nor is it a requirement. At times expedited plan reviews are feasible based on project manager work load, adequate up-front planning, & contractors providing complete, well written plans. However, if significant WP revisions are required, additional review & comment resolution time will be needed. To facilitate successful project implementation, I recommend DoD project managers & contracting staff: • Coordinate schedules with DEC project managers in advance & throughout projects. • Include DEC project managers in project planning meetings (DQO meetings, UFP QAPP development meetings, Triad & other Technical Project Planning team meetings, etc.). • Plan & maintain project schedules that include a sixty (60) days for reviewing draft work plans, comment resolution, any necessary revisions & a final review & approval. • Review contractor planning documents prior to submission to DEC to ensure compliance with state & federal regulations consistency with agreements made during project planning meetings. Failure to obtain WP approval before implementing site work described above is considered a violation of AK regulations & may result in field work not being approved or additional work being required & may subject responsible parties &/or contractors to a Notice of Violation (NOV). Independent QA oversight on PBCs-As DoD transitions more ER projects to PBC concerns have risen regarding the level of Quality Assurance (QA) oversight. The site cleanup rules require that “collection, interpretation, & reporting of data, & the required sampling & analysis is conducted or supervised by a qualified, impartial third party”. Depending upon the specific terms in a PBC, a contractor may no longer be considered an impartial third party with respect to collecting, interpreting & reporting data. This should be taken into consideration when preparing scopes of work. DEC strongly recommends the Air Force provide an on-site Quality Assurance (QA) Representative or a third party QA oversight contractor to monitor fieldwork for consistency with approved plans & contract requirements. DEC is beginning to conduct more frequent independent QA site inspections to evaluate conformance to approved work plans & regulatory compliance. Because we lack staff resources to conduct independent QA on all of the anticipated PBC projects, we intend to include contracting support for field QA oversight in the DSMOA Joint Execution Plans & budget. John Halverson
2/8/2008 Update or Other Action Draft Work Plan for Remedial Investigation at four source areas (LF003, SS010, SS016 and SS017) received. In general, the 2008 field effort will utilize high density surface and subsurface soil sampling with field screening for multiple contaminants to define the nature and extent of contaminants, and lower density laboratory analytical sampling with rapid turnaround times to confirm sufficient delineation. The sampling strategy at each site was determined during the systematic planning meeting. LF003-1) Three arcs of soil/sediment sample locations will be established around the outside of the landfill. Arcs will be established at approximately 25 foot intervals from the edge of the landfill, originate from the access road in the northeast, and terminate at the seep associated with sediment sample location SD-2 to the west. Each arc will have a minimum of ten analytical sample locations. Additionally, established LTM sediment and surface water locations will be sampled for comparison to historic data. Analytical samples will be collected based on field screening results. 2) A ten foot by ten foot sampling grid will be established around former sample location SS18 to determine the extent of PCB contamination. A minimum of nine analytical samples will be collected around SS18. Analytical samples will be collected based on field screening results. The sampling grid may be expanded based on screening results. 3) A minimum of six analytical samples will be collected at 50 foot intervals along the west side of the seep between former sample locations SS07 and SS18 to identify the PCB concentration distribution along the seep. Sample locations and the need for additional step-out samples will be determined based on screening results. 4) Several analytical surface water and associated sediment samples will be collected from seep discharges along Fowler (Nilumat) Creek including up and down stream of drainages emanating from LF003. All Cape Romanzof LRRS sites will first be compared to Method Two cleanup levels. All three exposure pathways may exist at Cape Romanzof LRRS; therefore, the most stringent of the three pathway-specific cleanup levels will likely apply at each site. If a site does not meet Method Two cleanup levels, Method Three may be applied. A risk assessment will be performed at Cape Romanzof LRRS; however, Method Four will likely be considered at sites only if site-specific analytical data does not meet Method Two or Three cleanup levels. Because soil containing PCBs will be encountered during planned field activities, 40 CFR 761 is also considered an ARAR. This regulation provides standards for the storage, treatment, disposal, and management of wastes containing PCBs. All PCB data will be compared to applicable standards in 40 CFR 761. For additional information see site file. Louis Howard
2/26/2008 Update or Other Action Five Year Review received. This 5-year review is the first conducted at Cape Romanzof LRRS & covers the sites Landfill No. 2 (LF003), Diesel Seep Area (SS013), & UST Spill Area (SS015). This 5-year review has been prepared in accordance with existing US EPA 5 year review guidance. Landfill cap inspections have occurred during each of the LTM events. The LF003 monitoring wells have remained serviceable during each of the LTM events with the following exceptions. In 1994, during landfill cap installation, 2 monitoring wells (MW-3 & MW-4) were abandoned & 7 additional monitoring well installed. Over the years frost jacking has forced the MW-1 well casing out through the top of the monument & fractured the well casing. MW-2 well casing & monument have been struck by a grader & damaged extensively. Occasionally some of the monitoring wells (e.g., CMW-2) have been dry due to GW elevations being below the screened interval. Site Inspection: The only significant problem identified is that while the landfill liner appears to be intact, there are seeps at the toe of the landfill that indicate groundwater is still entering & exiting the landfill area. Furthermore, one of the seeps has been shown to be transporting PCBs downstream of the landfill towards Fowler Creek. Water is likely entering the landfill via subsurface routes either through periods of higher groundwater regimes &/or through subsurface flow of surface runoff (i.e., water from the drainage ditch located on the north side of the main access road on the north edge of the landfill). Technical Assessment: The primary COC at LF003 is PCBs. The landfill cap has proven to be ineffective in preventing the migration of PCBs from this landfill site. Additionally the volume of PCB contaminated media outside the landfill cap has proven to be larger than originally estimated & accurate estimates of its volume are still unknown. The absence of any LUCs (i.e., fencing) allows for direct exposure to the PCB contaminated soils & sediments. Current conditions do NOT appear to be protective of human health & the environment. Future investigations & alternative remedial actions need to be developed to correct this deficiency. The review of documents, ARARs, risk assumptions, & the results of the site inspections indicate that the remedy is NOT functioning as intended by the Interim ROD. The landfill cap has NOT prevented GW from passing through the landfill contents & leachate exiting the landfill is contaminated with PCBs that are migrating downstream of the landfill towards Fowler Creek. Removal of the PCB hotspot has not been performed as required by the ROD. Site investigation activities have shown that the PCB hotspot is larger than originally estimated & additional investigation activities are needed to define the full extent of the PCB contamination. One opportunity for system optimization observed during this review includes a reduction of the GW monitoring well network &/or monitoring frequency. With the exception of a couple of benzene & DRO results from 1996 & 1997, all the GW monitoring results have been below the ADEC GW cleanup levels. For additional information see site file. Louis Howard
2/27/2008 Exposure Tracking Model Ranking Initial ranking with ETM completed. Louis Howard
3/3/2008 Report or Workplan Review - Other Staff reviewed and commented on the Draft Work Plan Remedial Investigation for LF003, SS010, SS016 and SS017 at Cape Romanzof LRRS January 2008. If Method Three will be proposed, ADEC recommends the number, type, and location of samples to be taken for use in the Method Three calculation be discussed and agreed upon (ADEC approval) prior to field activities. ADEC requires submittal of the parameters proposed for modification, the site specific values for those parameters proposed for use and a description of the basis for each site specific value prior to calculating site-specific cleanup levels. This is especially important for samples where the fraction organic carbon (FOC) content is being determined for site specific conditions. The FOC is the organic carbon content of a soil expressed as a percentage. This parameter should be determined through laboratory analysis of uncontaminated soil samples using an analytical method such as EPA Method 415.1 or SW-846 Method 9060. ADEC will not accept results of a soil burn-off test that determines total organics. The default value is 0.1% for both surface and subsurface soil. This is a relatively low value. This parameter can vary from site to site and within one site. At least eight samples from uncontaminated areas will need to be taken. ADEC recommends a minimum of ten (10) samples for “background” determination, not seven (7) as proposed in the text. Trying to establish “background” diesel range organics/residual range organics (DRO/RRO) is not applicable, especially since SS010 is the only area where petroleum is a contaminant of concern (COC,) it is a characterization investigation to determine nature and extent and it should be in gravel/fill material. If the Air Force is concerned about biogenic interference with the samples for some reason, please refer to Tech Memorandum 06-001 “Biogenic Interference and Silica Gel Cleanup.” The Air Force can include this as part of the work plan, sampling and final report. As far as metals, ADEC does not recall where RCRA metals were discussed or agreed on as part of the initial Triad meeting in August 2007. If the Air Force agrees to eliminate the “background” approach, the text for the entire RI and FSP will need to be revised. LF003-From the meeting notes, it was agreed at the initial Triad meeting that further sampling and delineation of landfill points SS05, 06, 08 and 09. It was stated that it was not likely that active remediation would be conducted in areas with lower PCB concentrations. This may be addressed in the risk assessment, however, for consistency and documentation, ADEC recommends a brief discussion also be added in the RI work plan. For additional information see site file. Louis Howard
3/4/2008 Report or Workplan Review - Other Staff reviewed and commented on the Draft Five Year Review for LF003, SS013, SS015. Sites with surface water and groundwater contamination at any point in time will need to have all groundwater and surface water monitoring points sampled one year prior to the five year review or in the same year to be included in the five year review. For example, LF003 at well CMW-1 LF03 1996, benzene was detected above 5 ug/L in 1996 sampling event at 17 ug/L. However, it was not sampled in 2007 to be included in the five year review to show that contamination is still below cleanup levels (non-detect for 1997-2006). SS015 Well WW-04 1993 had detections above cleanup levels for either: benzene, total benzene, toluene, ethylbenzene, total xylenes (BTEX), gasoline range organics (GRO), and diesel range organics (DRO) in 1993 and 1997. It was never sampled again after that time and was not sampled in 2007, prior to the five year review, for any constituents which had exceedances of groundwater cleanup levels. The text states the review is limited to only the sites specified that are being remediated under CERCLA authority. ADEC will require periodic reviews to evaluate whether current site conditions and remedial measures are and will continue to be protective of human health and the environment for those sites not remediated under CERCLA authority, i.e. State authority. ADEC considers these periodic reviews required by 18 AAC 75.380. Final reporting requirements and site closure. “(J) other information requested by the department, as the department determines necessary to ensure protection of human health, safety, or welfare, or of the environment. The text states: “The land use still represents a relatively low level of occupancy and activity, but no land use controls have been established. Therefore the potential for completed exposure pathways still exist at the present time.” This is in direct conflict with statements at: 2.5 Installation Land Use Control and Remedy Implementation, 3.4.2 Remedy Implementation on Page 3-7 and 3.10 Protectiveness Statement on Page 3-15. If land use controls (LUCs) are not in place, then they will need to be established for the entire acreage covered by LF003 as well as the area where off-site migration of PCB contamination is present downgradient of the site. ADEC requests the text throughout the document be corrected to reflect current (if any) land use controls for LF003. The text states if the items discussed are not completed before 2013, five years from the date of this review, the next five-year review will be performed as required. ADEC disagrees. Typically, a statutory review is triggered by the initiation of the first remedial action that leaves hazardous substances, pollutants or contaminants on site at levels that do not allow for unlimited use and unrestricted exposure. In cases where there are multiple remedial actions, the earliest remedial action that leaves such substances on site (at any source area on Cape Romanzof LRRS not just LF003) should trigger the initial review, even if it is an interim remedial action. Louis Howard
6/12/2008 CERCLA ROD Periodic Review June 12, 2008 ADEC (J. Halverson) signed the five year review document concurring with the AF's findings contained in the review. TECHNICAL ASSESSMENT Question A: Is the remedy functioning as intended by the decision documents? The review of documents, ARARs, risk assumptions, & the results of the site inspections indicate the remedy is not functioning as intended by the Interim ROD. The landfill cap has not prevented GW from passing through the contents and leachate exiting LF003 is contaminated with PCBs that are migrating downstream towards Fowler Creek. Removal of the PCB hotspot has not been performed as required by the interim ROD. Site investigation activities have shown that the PCB hot spot is larger than originally estimated & additional investigation activities are needed to define the full extent of the PCB contamination. One opportunity for system optimization observed during this review includes a reduction of the GW MW network and/or monitoring frequency. With the exception of a couple of benzene & DRO results from 1996 and 1997, all the GW monitoring results have been below the ADEC GW cleanup levels (Table 3-1). Question B: Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives (RAOs) used at the time of the remedy selection still valid? No. The sediment/soil & surface water cleanup levels for PCBs & DRO have been revised from those provided in the Interim ROD (USAF, 2002). The ADEC cleanup level for PCBs in surface water has changed from 0.0005 mg/L to 0.000014 mg/L (ADEC, 2003). The ADEC cleanup level for PCBs in soil has changed from 10 mg/Kg to 1.0 mg/Kg (ADEC, 2006a). The ADEC does not provide cleanup level for sediment but ADEC guidance includes a PCB screening criteria of 0.0341 mg/Kg in sediments (NOAA, 1999). There have been no substantial changes to the land use factors that were used at the time of remedy selection. The land use still represents a relatively low level of occupancy & activity. LUCs are in place to prohibit the disturbance of LF003's cap and contents by any excavation activities. LUCs have also been established that prohibits digging, excavation, or trespassing on the PCB hot spot area downgradient of LF003 (USAF, 2006). Question C: Has any other information come to light that could call into question the protectiveness of the remedy? A surface soil investigation conducted in 2004 (USAF, 2005a) shows PCBs are present in a drainage exiting LF003 that flows into Fowler Creek & PCBs are also present in soils adjacent to Fowler Creek (Figure 4). These data suggest there is a potential for PCB impacts to Fowler Creek. Sediment & surface water sampling of Fowler Creek is recommended to assess the potential impacts to this water body. For additional information see site file. John Halverson
3/17/2009 Update or Other Action Draft Remedial Investigation Report using TRIAD approach received. Surface soil at Source Area LF003 is defined as soil from ground surface to 3 feet bgs The highest PCB result was 110 mg/kg (Aroclor 1260) in the surface soil sample from above the seep coming from the west side of the landfill (SS24), 100’ upstream from the historical location SS18. Most of the remaining PCB results above the screening criteria were from surface soil samples collected to determine the extent of PCB contamination around the historical SS-18 sample location. With the exception of surface soil samples SS14, which had a result of 1.0 mg/kg (Aroclor 1254), & SS10, which had a result of 1.4 mg/kg. Surface water & collocated sediment samples were collected along Fowler Cr. along the northwest seep & at 3 established LTM locations. At established LTM location SD2 (historically found to have elevated PCB levels), sample results were above screening criteria, with sediment results of 40 mg/kg & surface water results of 0.0066 mg/L. Five additional collocated surface water & sediment samples were collected southwest, or downstream, of LTM location SD2 & upstream of historical location SS07. All five sediment samples contained PCBs in excess of screening criteria ranging from 58 mg/kg to 230 mg/kg, & three of the surface water samples contained PCBs exceeding screening criteria ranging from 0.0039 mg/L to 0.014 mg/L. The highest 2 concentrations of PCBs in sediment (230 mg/kg & 190 mg/kg) were located between established LTM location SD2, & historical location SS18 at sample locations SD/SW-15 & SD/SW-16. The highest level of PCBs in surface water (0.014 mg/L) was located at sample location SD/SW-18, approximately 60 feet downstream from historical location SS18. The collocated sediment sample (SD/SW-18) had a PCB concentration of 110 mg/kg. Based on sample results, the entire length of the seep from the toe of the landfill to the southernmost collocated surface water & sediment sample (SD/SW-18) is impacted with relatively high PCBs levels compared to adjacent surface soils. The extent of surface water & sediment contamination may not have been fully defined during the 2008 field effort. At the southern most collocated sample point (SD/SW-18), the seep reaches a depth that is no longer accessible without removing a large quantity of boulders. Field crews attempted to reach the seep bed beneath sample locations SS-063, SS-064, SS-065, & SS-077, however, it could not be reached. Conclusions: Collocated surface water & sediment samples collected along Fowler Cr. both up & down stream of LF003 indicate minimal or no impact to Fowler Cr. from upstream. Sample results indicate PCB contamination is limited to 2 areas at sample locations SS-010 & SS-014 around the east & south of the landfill perimeter (1,000 & 775 sq. ft. respectively). Sample results indicate an area approximately 2,970 sq. ft., encompassing historical sample locations SS07 to the south & SS18 to the north, with surface soil results in excess of the regulatory screening criteria Sample results indicate that seep sediments are contaminated along the length of the seep emanating from the northwest corner of the landfill adjacent to historical sampling location SD2 through approximately the location of SS07 (approximately 1,755 sq. ft.). For additional information see site file. Louis Howard
4/17/2009 Report or Workplan Review - Other Staff reviewed & commented on the Draft Remedial Investigation (RI) for LF003, SS010, SS016 & SS017. ADEC requests the Air Force provide a new section 1.1 The Purpose of the U.S. Air Force Installation Restoration Program to discuss the IRP: 1.1 The Purpose of the U.S. Air Force Installation Restoration Program Page 1-1 The IRP is a federal program established to address past hazardous waste disposal & spill activities at Department of Defense (DoD) installations. DoD hazardous waste policy was specified in Defense Environmental Quality Program Policy Memorandum 81-5, dated December 11, 1981, & was implemented by the USAF in a letter dated January 21, 1982. DoD policy is to identify & fully evaluate suspected problems associated with past operations that may have caused hazardous waste contamination & to implement remedial actions that will minimize the hazards to human health & the environment resulting from such past operations. The IRP was established in accordance with the Comprehensive Environmental Response, Compensation, & Liability Act (CERCLA) or Superfund Program under Section 120, Executive Order 12316 & amended by the Superfund Amendments & Reauthorization Act (SARA) of 1986. Created by Congress in 1980, CERCLA mandates the investigation & remediation of hazardous substance releases from previous activities or spill incidents which threaten public health &/or the environment. The IRP focuses on cleanup of contamination associated with past DoD activities. SARA Section 211 & EO 12580 require that the IRP be conducted in a manner consistent with CERCLA Section 120. 2.2.1.6 Clean Sweep Program – 2003 Page 2-9 ADEC requests the Air Force provide information on whether or not a dye tracer study was ever conducted to determine where the seeps flow (“...A visual & auditory inspection of the seep thought to be depositing sediments at SD-2 indicated the seep switched from above ground....” If not, then perhaps such a dye tracer study should be conducted to assist in the feasibility study efforts. 6.2.1.3 Surface Water & Sediment Analytical Results Page 6-17 The last paragraph of the section states that the extent of surface water & sediment contamination from LF003 may not have been fully defined during the 2008 field effort. As stated in the text, ADEC believes it is premature for the Air Force to progress to risk assessment if it has not defined the extent of surface water & sediment contamination. ADEC requests the Air Force provide additional discussion in the risk assessment to this effect. For additional information see site file. Louis Howard
7/31/2009 CERCLA RI Report Approved Final RI received. The Cape Romanzof LRRS site includes several known source areas. Four IRP sites were investigated in August through October 2008, including: LF003 (Landfill No 2), SS010 (Spill/Leak No. 4 at the Weather Station Building), SS016 (Upper Tram Area) & SS017 (Lower Tram Area). The highest PCB result was 110 mg/kg (Aroclor 1260) in the surface soil sample from above the seep coming from the west side of the landfill (SS24), approximately 100 feet upstream from the historical location SS18. Most of the remaining PCB results above the screening criteria were from surface soil samples collected to determine the extent of PCB contamination around the historical SS-18 sample location. With the exception of surface soil samples SS514, which had a result of 1.0 mg/kg (Aroclor 1254), & SS 10, which had a result of 1.4 mg/kg, all other landfill perimeter analytical sample results were below screening criteria or had no Aroclor detections. Sample SS010 was located approximately 75 feet south & east of sample SS24, near the landfill cap. Sample SS14 was located on the east side of the landfill. The boundary of surface soil PCB contamination around LF003 was defined through laboratory analytical testing & field screening. Source Area LF003 is recommended for remedial action to eliminate PCB sources at the landfill which may continue to leach into surface water & sediments, Regulations from ADEC require removal of PCB impacted soils to a concentration of 1 mg/kg for unrestricted land use, or 10 mg/kg with ICs & the placement of a cap over remaining impacted soils. Regulations from USEPA under TSCA require institutional controls for PCBs up to 25 mg/kg, site control (fence) & ICs for PCBs between 25 mg/kg & 50 mg/kg, & capping & ICs for PCBs between 25 mg/kg & 100 mg/kg. Contaminated sediments along the seep emanating from the northwest toe of the landfill contain much higher PCBs ranging from 40 mg/kg to 230 mg/kg. Sediments should be removed to the extents practical from the toe of the landfill to the approximate location of historical sample SS07. Removal of these sediments will reduce impacts to soil & sediment downstream of this location, & be protective of Fowler Creek. Additional effort should be made to investigate the source of PCB contamination within the landfill itself As PCBs were generally only detected from the northwest seep, the source of these PCBs may be located within the landfill, along the northwest edge. For additional information see site file. Louis Howard
11/6/2009 Update or Other Action Note: If you are looking for information about this site prior to 2004, check file number 2526.38.000, marked Cape Romanzof General Information and Correspondence. This file contains documents that may pertain to all of the Cape Romanof sites before they were established as individual sites. Natalie Loescher
7/21/2010 Report or Workplan Review - Other Staff reviewed and commented on the Initial Screening of Alternatives for Cape Romanzof LRRS July 2010. Introduction Page 1-1: The text states: “The goal of the FS process is to determine the most appropriate methods or technologies for remediation of contaminated media at a site.” ADEC requests the Air Force change the text to read as follows: “The primary objective of the feasibility study (FS) is to ensure that appropriate remedial alternatives are developed and evaluated such that relevant information concerning the remedial action options can be presented to a decision-maker and an appropriate remedy selected.” [40 Code of Federal Regulations (CFR) § 300.430 (e)(1)]. 1.5.1 Remedial Action Objective Criteria Page 1-9 ADEC requests the Air Force insert this sentence as the first sentence for this section: “RAOs consist of medium-specific goals for protecting human health and the environment. The objectives should be as specific as possible but not so specific that the range of alternatives that can be developed is unduly limited” 1.5.1.1 Contaminants-of-Concern Page 1-9 The text states: “During the RI, chemical-specific ARARs were used to identify contaminants-of-potential concern (COPCs), evaluate risk and assess the need for further action at potentially contaminated sites at the Cape Romanzof LRRS.” ADEC requests the Air Force add the following text immediately after the first sentence in this section: “Chemical-specific ARARs usually are either health- or risk-based numerical values or methodologies that establish the acceptable amount or concentration of a chemical that may remain in or be discharged to the environment. Where more than one requirement addressing a contaminant is determined to be an ARAR, the requirement that should be used is the one that is the most stringent.” For additional information see site file. Louis Howard
6/15/2011 Update or Other Action Draft Feasibility Study received for four sites at the Cape Romanzof Long Range Radar Site. The four sites (source areas) are Installation Restoration Program (IRP) sites LF003 (Landfill No. 2, northwest of the Composite Facility along the access road), SS010 (Spill/Leak No. 4 at the Weather Station Building), SS016 (Upper Tram Terminal Area), and SS017 (Lower Tram Terminal Area). LF003 contains sediments with contaminant levels that exceed PRGs. The COC for sediment at Cape Romanzof LRRS is PCBs. Preliminary Remediation Goals for Surface Soil LF003 PCBs - maximum concentration: 110 mg/kg, PRG 1.0 mg/kg 18 AAC 75 Method Two Cleanup level. Completed exposure pathways: Dermal absorption, ingestion, inhalation of airborne suspended particles, ingestion of wild foods. LF003 Surface Soil Alternatives - LF03SS1 – No Action - LF03SS2 – Institutional Controls, Engineering Controls and Containment - LF03SS3 - PCB Soil (=10 mg/kg): Excavation and Off-Site Disposal; PCB Soil > or = 1 and < 10 mg/kg): Institutional Controls, Engineering Controls and Containment. - LF03SS4 - PCB Soil (> or = 1 mg/kg): Excavation, Ex-situ treatment and on-site disposal - LF03SS5 - PDB Soil (> or = 1 mg/kg): Excavation and Off-site Disposal - LF03SS6 - Excavation of Entire Landfill (debris and soil removal) and Off-Site Disposal LF003 Sediment Alternatives - LF03SD1 - No Action - LF03SD2 – Institutional Controls and Engineering Controls - LF03SD3 – Excavation and Off-site Disposal - LF03SD4 - Excavation, Ex-situ Treatment, and on-site disposal General Response Actions/Remedial Technologies not considered The containment general response actions, other than capping and installation of an eroded soil barrier, were not chosen because the permeable rocky/boulder substrate at the site effectiveness of these other barriers. Ex-situ treatment technologies other than high temperature thermal desorption were not considered because these technologies are more complex, take a longer period of time to set and implement, and generate large quantities of residual waste materials and liquids that would require disposal, which is difficult given the remoteness of this location. No in-situ treatment technologies were considered because the landfill is the suspected source of the PCBs and this treatment may be less effective than excavation and ex addition, in-situ treatments typically require complex equipment operated over a long time period. Due to the remote nature of the site, and the requirement for long these technologies were deemed impractical for the site. Physical and chemical in-situ treatment methods were not considered due to the time needed for treatment and the requirement for installing long nature of the site and the requirement for long deemed impractical for the site. Natural Attenuation was not considered because PCBs do not readily attenuate naturally. For additional information see site file. Louis Howard
6/30/2011 Report or Workplan Review - Other Staff reviewed & commented on the draft Feasibility Study. 1.3.1 It appears the incorrect value for exposure frequency values for “Arctic Zone” was used. Please use the correct value of 270 days in the Under 40 Inch Zone (90 days non-exposure time) per ADEC Cleanup Levels Guidance, Appendix A Soil & Groundwater Cleanup Standards Equations & Exposure Assessments, January 1, 2006. Notably absent from the document in this section is reference to the Method Two soil migration to groundwater cleanup levels. ADEC requests the Air Force reference any ADEC approved 350 determinations for sites mentioned in this document. ADEC requests the Air Force include migration to groundwater as an exposure pathway & reference the appropriate cleanup levels in the document. Under section 2.4.1.2 Contaminants of Concern Page 2-17, the text references being protective of human health & migration to groundwater: “The COCs for the surface soils were identified due to contaminant concentrations that exceeded screening criteria (ADEC Soil Cleanup Levels, Tables B1 & B2 Under 40-Inch Zone, 18 AAC 75.341; as amended through October 9, 2008), which are protective of human health & migration to groundwater.” Also see section 2.4.2.2 Contaminants of Concern Page 2-20 & section 2.4.3.2 Contaminants of Concern Page 2-22, 2.4 The 2008 RI Section 6.2.1.4 on Page 6-17 states: “Results of soil, surface water, & sediment analysis indicate the highest concentrations of PCBs are present in sediments along the seep, & PCBs are present in surface water. It appears that PCBs within the seep have impacted the soils surrounding the seep bed through time, likely based on seasonal precipitation & natural meandering of surface water throughout the boulder field.” These statements do not support the Draft FS which states the PCB contamination likely originated in the contaminated sediments from seeps along the toe of the landfill, as opposed to the water itself. The 2008 RI 9.3 Recommendations on Page 9-7 states: “Source Area LF003 is recommended for remedial action to eliminate PCB sources at the landfill which may continue to leach into surface water & sediments. Additional effort should be made to investigate the source of PCB contamination within the landfill itself. As PCBs were generally only detected from the northwest seep, the source of these PCBs may be located within the landfill, along the northwest edge.” The RI did not specifically state that remediation of surface water is not warranted. It can be stated that if the Air Force eliminates the PCB sources at (within) the landfill, then this should eliminate the cause of the surface water contamination. For additional information see site file. Louis Howard
9/29/2011 CERCLA FS Staff approved the final feasability study. Louis Howard
10/6/2011 Site Reopened reopen site Louis Howard
3/23/2012 Update or Other Action ADEC received the draft Proposed Plan presents the Preferred Remedial Alternatives for the following United States Air Force (USAF) Environmental Restoration Program (ERP2) sites within the Cape Romanzof Long-Range Radar Site (LRRS): • Landfill Number (No.) 2 (LF003) • Spill/Leak No. 4 at the Weather Station Building (SS010) • Upper Tram Terminal Area (SS016) • Lower Tram Terminal Area (SS017) The reasonably-anticipated future land use is the same as the current land use. There are no plans for residential use at ERP Sites LF003, SS010, SS016, or SS017. The baseline human health risk assessment concluded there is unacceptable human health risk from direct contact with PCBs in soil & sediment at LF003. There are potential hotspots of PCBs in soil & sediment at LF003. The screening level ERA concluded that there is potential unacceptable ecological risk for select sample locations with PCBs in soil & sediment at LF003 that exceed ecotoxicity screening levels based on food chain exposures. Tabulated water quality criteria (in 18 AAC 70.020) are appropriate for surface water at LF003. PCBs are present in surface soil (six areas) up to 110 mg/kg, in sediment up to 230 mg/kg at the seep at NW corner of landfill & in surface water near SS-18 at 0.014 mg/L. Excavation & Off-Site Disposal – Preferred Alternative In this alternative, surface soil where PCBs are present above 1 mg/kg (above cleanup levels protective of human health & the environment), would be excavated & disposed of off-site at a landfill permitted to accept PCB-contaminated soil. The soil would be excavated, loaded onto barges, & shipped to a commercially operated landfill for disposal. Confirmation sampling following the excavation & disposal would document the effectiveness of the remedy. Soil from a local borrow source would be used to backfill the excavation. This alternative is preferred because it eliminates unacceptable risk from PCBs present without the need for Institutional Controls when complete. Sediment: Excavation & Off-Site Disposal – Preferred Alternative Sediment within source area LF003, where PCBs are present above cleanup levels protective of human health & the environment, would be excavated & disposed off-site at a landfill permitted to accept PCB-contaminated wastes. The sediment would be excavated, properly containerized, loaded onto barges, & shipped to a commercially operated landfill for disposal. Confirmation sampling following the excavation & disposal would document the effectiveness of the remedy. Soil from a local borrow source would be used to backfill the excavation. In addition, eroded soil control barriers would be constructed on site to prevent the offsite migration of run-off water that may contain contaminated sediment in order to protect the surface water that flows around the landfill & further away (Fowler Creek). While the excavation would remove the sediment currently present, it may not remove the source of the PCBs, which is thought to potentially be the landfill itself. Therefore, it is possible that contaminated sediment could migrate from the landfill or other unknown source over time via the seep & into the surface water near the toe of the landfill. For additional information see site file. Louis Howard
5/15/2012 Report or Workplan Review - Other Current & Future Land Use ADEC requests the AF describe exactly what the “current land use” at Cape Romanzof LRRS & the surrounding land. ADEC requests the AF clarify that the workers do not reside at LF003, SS010, SS016, or SS017 since the reader may assume that the 4 year around workers (residents) may live at one or more of the ERP sites. GW Use ADEC requests the AF reference when a 350 determination was approved by ADEC (list year & month, if not, then at least the year). ADEC concurs that the remedial measures for PCBs in soil at these sites would effectively remediate lead contaminated soil, however, ADEC will require confirmation sampling for lead to ensure that cleanup levels have been achieved. LF003 Cleanup Actions to Date ADEC requests the AF clarify that GW is not of concern at LF003 since DRO has not been detected above cleanup levels since 1999 & no exceedances of any COCs have been detected in GW in 2003 & 2004 GW monitoring events. The text misleads the reader to assume the AF has stopped monitoring GW after 2004 despite stating here that DRO, RRO, VOCs, SVOCs & metals exceeded cleanup levels in GW. ERP Site Descriptions & History ADEC does not have any DRO or RRO cleanup levels in sediment. Request the AF remove any reference to DRO/RRO cleanup levels for sediment contamination in the document. Figure 3 IRP Site LF003 Western Soil & Seep Exceedances 2008 Remedial Investigation ADEC requests the AF verify the sample results for seep samples. Water sample results should be reported as mg/L not mg/kg. ADEC also requests the AF provide another figure showing the location of LF003 with respect to the landfill boundaries, road & Fowler Creek. The current figure of exceedances is hard for ADEC & the reader to get a perspective on where LF003 is in relation to the other site features. Alternatives for Surface Soil at LF003 LF03SS2: ICs, Engineering Controls, & Containment While ADEC would not object to restrictive covenants on AF property, this is the first time mention of restrictive covenants being conveyed that prevent certain kinds of activities at these locations in an AF PP. LF03SS55: PCB Soil (=1 mg/kg): Excavation & Off-Site Disposal – Preferred Alternative ADEC is uncertain that the AF can guarantee that there won’t be additional seepage from the landfill containing PCBs that will impact surface soils & require additional action such as ICs/testing/ongoing disposal costs. The 2009 RI states: “Source Area LF003 is recommended for remedial action to eliminate PCB sources at the landfill which may continue to leach into surface water & sediments. Additional effort should be made to investigate the source of PCB contamination within the landfill itself As PCBs were generally only detected from the northwest seep, the source of these PCBs may be located within the landfill, along the northwest edge.” At a minimum, the PP for LF003 should state that the soil near the northwest seep will be sampled after implementing the remedy to ensure that there are no PCB sources continuing to leach into surface water & sediments. A one-time excavation & off-site disposal may not be the final remedy for LF003. Also the off-site disposal of PCBs will comply with § 300.440 Procedures for planning & implementing off-site response actions (aka the “off-site rule”). For additional information see site file. Louis Howard
7/11/2012 CERCLA Proposed Plan While not listed on the NPL, Cape Romanzof LRRS must follow CERCLA process per E.O. 12580 [e.g. CERCLA Sections 104(a), (b), and (c)(4), 113(k), 117(a), and (c), 119, and 121) with respect to releases or threatened releases where either the release is on or the sole source of the release is from any facility or vessel under the jurisdiction, custody, or control of their departments. These functions must be exercised consistent with CERCLA Section 120 Federal Facilities. State laws. -- State laws concerning removal and remedial action, including State laws regarding enforcement, shall apply to removal and remedial action at facilities owned or operated by a department, agency, or instrumentality of the United States when such facilities are not included on the National Priorities List. The preceding sentence shall not apply to the extent a State law would apply any standard or requirement to such facilities which is more stringent than the standards and requirements applicable to facilities which are not owned or operated by any such department, agency, or instrumentality.]. The preferred alternatives for Sites LF003, SS010, SS016, and SS017 are listed below. LF003 PCB contaminated soil and sediment: • LF03SS5: PCB Soil (=1 mg/kg): Excavation and Off-Site Disposal. • LF03SD3: Excavation, Off-Site Disposal and Long-Term Monitoring. SS010 petroleum contaminated subsurface soil and groundwater potentially contaminated with petroleum: • SS10SB2: Institutional Controls and Engineering Controls. • SS10GW2 – Institutional Controls, Engineering Controls, Natural Attenuation and LTM. SS016 PCB contaminated soil: • SS16SS4: PCB Soil =1 mg/kg Excavation, to the extent feasible, and Off-Site Disposal. SS017 PCB contaminated surface and subsurface soil: • SS17SS4: Excavation and Off-Site Disposal. • SS17SB4: Excavation and Off-Site Disposal. USAF will implement, monitor, maintain, and enforce the ICs in accordance with ADEC’s contaminated site regulations. The purpose of the ICs is to help prevent inappropriate handling of groundwater contaminated above ADEC Table C groundwater cleanup levels at SS010 and help prevent the future handling of surface soil or sediment contaminated above ADEC Method Two cleanup levels at LF003 and SS016 in ways that are inconsistent with ADEC’s contaminated site regulations. For additional information see site file. Louis Howard
12/14/2012 Update or Other Action Draft Record of Decision received. LF003 – The COCs identified at LF003 are PCBs in surface soil and sediments, with approximately 227 cubic yards (cy) of contaminated surface soil and an estimated 20 cy of contaminated sediment. Remedial action is required under CERCLA as well as Alaska state law to address these COCs in order to protect human health and the environment at this area. The selected remedies for LF003 for PCB-contaminated surface soil and sediment are as follows: - Surface Soil – Alternative LF03SS5: PCB Soil (=1 mg/kg): Excavation and Off-Site Disposal, involves the following actions: - Surface soil at LF003 with concentrations of PCBs =1 milligram per kilogram (mg/kg) will be excavated, loaded onto barges, and shipped off-site to a commercially operated landfill permitted to accept PCB-contaminated waste for disposal. Confirmation sampling following the excavation and disposal will document the effectiveness of the remedy. Soil from a local borrow source will be used to backfill the excavation. - Sediment – Alternative LF03SD3: Excavation, Off-Site Disposal, and Long-Term Monitoring, involves the following actions: - Sediment within source area LF003 where PCBs are present above cleanup levels (1 mg/kg) will be excavated, loaded onto barges, and disposed of off-site at a commercially operated landfill permitted to accept PCB-contaminated waste. Confirmation sampling following the excavation and disposal will document the effectiveness of the remedy. Soil from a local borrow source will be used to backfill the excavation. - While the excavation would remove the sediment currently present, it may not remove the source of the PCBs, which is thought to be the landfill itself. Therefore, contaminated sediment may continue to migrate from the landfill via the seep and into the sediment near the toe of the landfill. Eroded soil control barriers will be constructed on-site to prevent the off-site migration of runoff water that may contain contaminated sediment in order to protect the surface water that flows around the landfill and further away (Fowler Creek). Periodic maintenance will be conducted to remove collected sediment, which will be analyzed to check PCB contamination levels and collected and disposed if it exceeds clean up levels. Over time, PCB concentrations in the sediment will decrease as the source concentrations decrease. Signs warning that PCB contaminated sediment may be present will be constructed and maintained at the site to alert personnel to the presence of contaminated sediments within the seasonal drainage channel and eroded soil control barriers until it is determined that sediments no longer pose an unacceptable risk to human health and the environment and allow for unlimited use and unrestricted exposure. - Locations of the eroded soil control barriers and signs will be surveyed and recorded in the appropriate Cape Romanzof LRRS land records, including the Base Master Plan and Alaska Department of Natural Resources (ADNR) land records. Louis Howard
2/1/2013 Update or Other Action General Permit No. SWGPLRRS-18 issued & expires on 1/31/2018. Cover letter signed by Douglas Buteyn Northern Solid Waste Program Coordinator and permit is signed by Robert Blankenburg Solid Waste and Pesticides Program Manager. For accounting purposes, the following project numbers have been assigned to these facilities. SWGPLRRS-18-01 Cape Lisburne SWGPLRRS-18-02 Cape Newenham SWGPLRRS-18-03 Cape Romanzof SWGPLRRS-18-04 Fort Yukon SWGPLRRS-18-05 Indian Mountain SWGPLRRS-18-06 Sparrevohn SWGPLRRS-18-07 Tatalina SWGPLRRS-18-08 Tin City The Alaska Department of Environmental Conservation (DEQ, under authority of AS 46.03 & 18 AAC 60, issues this general statewide solid waste disposal permit for the operation & maintenance of a landfill for incinerated domestic solid waste, inert waste, septage or sludge, & regulated asbestos-containing materials (RACM) at long-range radar sites owned by the U.S. Air Force. This permit replaces General Permit #SWGPLRRS-13. The following criteria must be met to conduct disposal under this permit: • Waste must be generated at a long-range radar site (LRRS) with no more than 50 year-round residents; • Waste must consist solely of incinerated domestic solid waste, inert waste, septage or sludge, & RACM; • Annual volume of waste may not exceed 50 cubic yards of ash from domestic waste, 1,000 cubic yards of inert waste, 5,000 gallons of septagc or sludge, & 100 cubic yards of RACM; • The LRRS must be located in a remote area with no year-round access to a major road system (a system of connected roads with a total length of 100 miles or more); & • The LRRS must be in a location where there is no reasonable access to an existing permitted landfill (all permitted landfills are more than 100 road miles away or have refused, in writing, to accept the waste). A person who wishes to dispose of waste under the conditions of this general permit must complete the appropriate application form & submit it to DEC. Waste may not be placed in the disposal site until the DEC has approved the application in writing. Waste Acceptance - Ensure that only the following materials generated at the LRRS facility are deposited in the landfill: i. Ash from burning of domestic solid waste, not to exceed 50 cubic yards annually. Domestic waste includes garbage, food scraps, packaging materials, & any trash associated with normal household-type operations; ii. Inert waste, not to exceed 1,000 cubic yards annually. Inert wastes include building debris, scrap metal, other waste from construction or demolition (C&D), & nonRACM; iii. Septage or sludge, not to exceed 5,000 gallons annually. Septage includes liquid & solid human waste removed from a septic tank, cesspool, or portable toilet Sludge includes solid & semi-solid residue from treatment of water in a water treatment plant; & iv. RACM, not to exceed 100 cubic yds annually. Prohibited Waste - Ensure that all other types of waste, including, but not limited to, liquids (other than septage), batteries, vehicle fluids, oily waste, refrigerants, hazardous waste, or putrescible or food waste that has not been treated by burning or incineration, are disposed of in accordance with all applicable laws & regulation. See site file for additional information. Louis Howard
3/28/2013 CERCLA ROD Approved John Halverson (ADEC Fed. Fac. Section Program Manager) approves the final Record of Decision for LF003, SS016, SS017. This signature sheet also documents the USAF approval of the remedy selected under Alaska state law in this decision document for Spill/Leak No. 4 at the Weather Station Building (SSO1O) at Cape Romanzof LRRS, Alaska. The State of Alaska agrees that, when properly implemented, the selected remedy complies with state law. The decision may be reviewed and modified in the future if new information becomes available that indicates the presence of contaminants or exposures that may cause unacceptable risk to human health or the environment. If additional contaminants are discovered, USAF and ADEC will determine compliance levels for soil and groundwater cleanup actions. The selected remedies for LF003 for PCB-contaminated surface soil and PCB-contaminated sediment are described as follows: · Surface Soil – Alternative LF03SS5: PCB Soil (=1 milligrams per kilogram [mg/kg]): Excavation and Off-Site Disposal: · Sediment – Alternative LF03SD3: Excavation, Off-Site Disposal, and Long-Term Monitoring (LTM) · Landfill – The remedy for buried solid and potentially hazardous materials in Landfill No. 2 is ICs/LUCs and LTM. Annually, inspections (with photos and field observations) of the landfill cap, signs, and control barriers, maintenance, and performance reports will be provided to ADEC, annually, for the first five years after remedial activities and will be followed by a Five-Year Review. At that time the frequency of inspections and reports may be reduced. John Halverson
4/19/2013 Update or Other Action 2nd Five-Year review received for review and comment. Because the first CERCLA Five-Year Review for LF003 (completed in 2008) found that the ROD-selected remedy, Cleanup with Institutional Controls, was not protective of human health and the environment, an initial screening of new alternatives for LF003 was conducted in 2010. A Final ROD for LF003 was completed and signed by the U.S. Air Force (USAF) and the Alaska Department of Environmental Conservation (ADEC) in March 2013. The protective metal casing at CMW-7 has exposed the wellhead and standing water surrounds the well. Recommendation: Repair CMW-7.Continue ongoing monitoring at LF003 and schedule the third Five-Year Review. Because the First Five-Year Review for LF003 (USAF 2008b) concluded that the RAOs from the 2002 ROD for Interim Remedial Action were not protective, the following revised RAOs were developed based on an Initial Screening of Alternatives conducted in 2010: • Prevent ingestion of, dermal contact with, inhalation of dust from, and uptake of biota of contaminants from surface soil containing fuel, PCB, and lead concentrations in excess of Preliminary Remediation Goals (PRG) and/or resulting in a cancer risk greater than 1 × 10-6 or a Hazard Index (HI) great than 1. • Prevent possible migration of fuels, PCBs, or lead (as identified in the 2010 Initial Screening of Alternatives [USAF 2010b]) in surface soil to surface water resulting in surface water concentrations that exceed the Alaska Water Quality Standards. On 20 August 2012, Jacobs conducted a Five-Year Review site inspection. Based on observations during the inspection, ICs to limit unauthorized excavation appeared to be effective. No excavations or disturbed soils were identified during the inspection. A Proposed Plan for LF003 was developed that recommended soil excavation and disposal at an off-site landfill permitted to accept PCB-contaminated soil. After excavation, the soil would be loaded onto barges and shipped to a commercially operated landfill for disposal. A new ROD for LF003 was approved and signed in March 2013. The effectiveness of the new RAOs, site remedy implementation, and ICs at LF003 will be evaluated in the next CERCLA Five-Year Review. This is the second Five-Year Review for LF003, the second Periodic Review for SS013, and SS015, and the first Periodic Review for ST009, SS014, and DP011. Since the first Five-Year Review (USAF 2008b) for LF003, a Final ROD has been completed and signed in March 2013. Since the first Periodic Review for SS013, and SS015, a Proposed Plan Final Remedial Actions for ERP Sites SS013 and SS015 (USAF 2010a) and a Record of Decision for Diesel Seep Area (SS013) and UST Spill Area (SS015) (USAF 2011) have been issued. The conditions reported in this review will serve as the baseline for the next review, which is scheduled to be finalized in 2018. Louis Howard
5/20/2013 Report or Workplan Review - Other Staff provided comments on the 2nd Five Yr. Review. It documents the U.S. Air Force acceptance of the Second Comprehensive Response, Compensation, and Liability Act (CERCLA) Five-Year Review of Site LF003, the Second Non-CERCLA Periodic Review of Sites SS013 and SS015, and the first non-CERCLA Periodic Review of Sites ST009, SS014, and DP011 at the Cape Romanzof Long-Range Radar Site, Cape Romanzof, Alaska. 10.1 Page 10-1 LF003 Landfill No. 2 Question A: Is the remedy functioning as intended by the Record of Decision? The question should either be answered: Yes or No. Any discussion on functioning of the remedy or its performance should be discussed under “Remedial Action Performance.” Please address this issue for each source area. Restate the text as follows: Answer: No Remedial Action Performance: The remedy is not functioning as intended by the 2002 ROD for Interim Remedial Action. The USAF identified that a new remedy was necessary in the First Five-Year Review (USAF 2008b), and a new ROD was approved and signed by the USAF and ADEC in March 2013. The NOAA Screening Quick Reference Tables (SQuiRTs) have been revised since 1999. Please update to latest version which is 2008. The screening criteria for PCBs in freshwater sediment at 0.0341 mg/kg is still relevant. Page 10-2 Question B: Are the exposure assumptions, toxicity data, cleanup levels, and RAOs used at the time of the remedy selection still valid? Changes in Standards to be Considered: The ADEC cleanup level for PCBs in surface water has changed from 0.0005 mg/L to 0.000014 mg/L (ADEC 2012b). The question should either be answered: Yes or No. Restate text as follows: Answer: Yes Changes in Standards and To Be Considered: The ADEC cleanup level for PCBs in surface water has changed from 0.0005 mg/L to 0.000014 mg/L (24 hr. average ADEC 2012b). Page 10-3 Question C: Has any other information come to light that could call into question the protectiveness of the remedy? Yes. The current remedy is not protective as implemented. The new ROD was approved and signed the USAF and ADEC in March 2013. The protectiveness of the new LF003 site remedy will be evaluated in the next Five-Year Review. Restate as follows: Answer: Yes The current remedy is not protective as implemented. The new ROD was approved and signed the USAF and ADEC in March 2013. The protectiveness of the new LF003 site remedy will be evaluated in the next Five-Year Review. Louis Howard
5/29/2013 Update or Other Action Responses to ADEC's comments were acceptable on the draft 2nd 5 Yr. Review. Finalize the document. Louis Howard
6/2/2014 Update or Other Action Draft Work Plan received for review and comment. IC inspections for sites LF003, ST009, and SS010. A landfill cap inspection will be completed for LF003. The results of these inspections will be documented in a field log book and accompanied by photographs. Louis Howard
6/24/2014 Report or Workplan Review - Other Staff provided comments on the draft WP. WS #1 & 2 Title and Approval Page Replace Jessica Morris, Program Specialist II with Louis Howard, Project Manager WS #3 & 5 Project Organization and QAPP Distribution Replace Jessica Morris (907) 269-3077 with Louis Howard (907) 269-7552. WS #6 Communication Pathways Communication from ADEC Replace Environmental Program Specialist II Jessica Morris (907) 269-3077 with Project Manager Louis Howard (907) 269-7552. WS #14 & 16 Groundwater Sampling The text states: “New tubing will be used for each well. The pump will be lowered into the well slowly and carefully to a depth corresponding with the approximate midpoint of the saturated screen interval.” Teflon® sampling equipment (e.g. tubing, bailers) is preferred. The use of HDPE equipment should be minimized to the extent practical. Studies have indicated that Teflon® shows the least absorption and leaching biases and should be the material of choice for detailed organic sampling purposes. Sampling equipment should be constructed of inert material, precluding alteration of analyte concentrations caused by sorption, desorption, degradation, or corrosion. Viton®, Tygon®, silicon and neoprene should not be components of sampling equipment that come into contact with the groundwater sample. These materials have been demonstrated to cause sorptive losses of contaminants, primarily VOCs. Table 15-1 Reference List and Evaluation Criteria for Soil Samples Note: the maximum allowable concentration (MAC), as defined by Table B2 of 18 AAC 75.341(d), for GRO, DRO, RRO is: 1,400 mg/kg, 12,500 mg/kg and 22,000 mg/kg, respectively. Please correct table for MAC. WS #19 & 30 Sample Containers, Preservation and Hold Times Table shows DRO, DRO/RRO water sample containers as VOA vials with Teflon-lined septum cap. ADEC’s Draft Field Sampling Guidance (May 2010) Appendix E states: container description for AK 102 DRO and AK 103 RRO: min. 100 ml - 1 L amber glass, TLC (Teflon-lined screw cap) and 14 days to extraction not 7 days as stated in the draft document. 3.0 References 18 AAC 75 has been updated since October 9, 2009. Please use the revised date as of April 8, 2012. 3.3 Groundwater Sampling General Rules The text states: “Filtered and unfiltered samples will be taken for inorganics (metals) analyses.” In accordance with 18 AAC 75.380(c)(2): groundwater cleanup levels are based on an analysis of unfiltered groundwater samples unless a responsible person demonstrates that a filtered sample provides a more representative measure of groundwater quality. See comment #4 above regarding use of tygon tubing. 3.6 Purging and Sampling with Bailers Bailers are not the preferred method for the collection of volatiles or other air sensitive parameters. Volatile organic analytical results may be biased low (due to aeration) and metals results may be biased high (due to turbidity). ADEC will not accept samples for VOCs collected with a bailer. Louis Howard
6/26/2014 Report or Workplan Review - Other The responses to ADEC's comments are satisfactory and the document may be finalized. Louis Howard
12/18/2014 Update or Other Action Draft 2014 Long Term Management Report for Sites LF003, ST009, SS015, and SS010 received for review and comment. Site LF003 was inspected on 31 July 2014, and notes were taken in a field logbook. The overall site is a capped landfill with top and edges vegetated in amounts ranging from 0 percent to 90 percent cover. The top of the cap is sparsely vegetated with grasses, ranging from 0 percent cover to 30 percent cover. The northern edge is without vegetation, and is a gravel pad bordered by the main road. The eastern edge has a percent cover estimated at 80-90 percent, with the vast majority of the vegetation consisting of grass and willow species; this densely vegetated section borders a small creek that is discussed in the 2013 ROD. The southern edge is densely vegetated with 80-90% cover with small 1-3 foot spots without vegetation. The western edges are sparsely vegetated and have surface erosion as discussed below. Cap surface erosion was observed along the western sidewall of the landfill is due to runoff from the adjacent road leading to Lower Camp. Erosion channels were observed that lead drainage from the road, over the cap, and into the boulder area adjacent to Site LF003 on the western flank. Debris that was found within the landfill boundary was primarily partially-buried and appeared to consist of large pieces of plastic, metal, and possibly liner. Unburied and partially-buried metal debris was observed primarily along the southwestern boundary of the site. Of note in the area was the presence of a rusted compressed gas cylinder. No marking or signs were observed at Site LF003. No environmental sampling was performed at Site LF003. Louis Howard
2/23/2015 Update or Other Action Draft Work Plan for Environmental Long Term Monitoring at Cape Romanzof LRRS Sites: LF003, ST009, SS010, and SS015 received for review and comment. Sampling activities at Sites ST009, SS010, and ST015 are being conducted in accordance with state guidance and regulations to meet the requirements of their respective Decision Documents. LTM is being performed at these sites for the purpose of evaluating the MNA remedial action for groundwater. During the 2014 effort at SS010, monitoring wells were installed at three locations to characterize current groundwater conditions. Groundwater samples were collected from the newly installed wells to determine the presence or absence of petroleum contamination in groundwater at the site. Detections of RRO and GRO were reported below the associated ADEC groundwater cleanup level or as not-detected, and there were no detections of DRO in any of the samples analyzed. While the presence of groundwater contamination was not seen in 2014, continued monitoring of groundwater conditions at SS010 will be performed to gather additional data for this site. Tasks for the 2015 field season: IC inspections for Sites LF003, ST009, and SS010. A landfill cap inspection will be completed for LF003. The results of these inspections will be documented in a field log book and accompanied by photographs. The landfill inspection form is included in Appendix B. ST009 -- Groundwater samples will be collected from three existing wells (MW-4, MW-7, and MW-9) and submitted for laboratory analysis of GRO, DRO, and BTEX. One surface water sample will be collected at ST009 and will be submitted for TAH and TAqH analysis. SS010 -- Groundwater samples from three existing monitoring wells (SS010-MW01, SS010-MW02, and SS010-MW03) will be submitted for GRO, DRO, and RRO analysis. Figure 11-2 indicates the approximate extent of previous petroleum contamination according to the 2013 ROD. • SS015 -- Groundwater samples will be collected from three wells (WW-01, WW-05, and WW-06) and submitted for analysis of DRO, GRO, BTEX, alkalinity, dissolved iron, sulfate, and nitrate/nitrite. Figure 11-3 shows former potential contamination sources within and near the site. The SS015 monitoring well WW-01 is heavily damaged, but was still successfully sampled according to the 2014 LTM Report. Louis Howard
2/26/2015 Report or Workplan Review - Other Draft Long-term monitoring work plan comments. ADEC has reviewed the document and has a few general comments. For summation of non-detects with TAH/TAqH data, the Air Force shall use one-half (1/2) the PQL (not the MDL ) for ND's in the calculation of TAH/TAqH. If the lab reports xylenes separately, they should be treated separately in the same manner. For contaminated sites evaluating TAH and TAqH under 18 AAC 75.345(f), unless there is a specific permit requirement to use the EPA 600 series methods (e.g. NPDES, etc), the following EPA SW-846 Methods are approved alternatives for TAH and TAqH determinations: TAH (BTEX): Methods 8021B or 8260B; TAqH (BTEX + PAH): Methods 8270C (including SIMS) or 8310 for the list of 16 PAHs listed by EPA Method 610. Please elaborate in the work plan why EPA Method 625 is being used instead of EPA 8270C (including SIMS) or EPA 8310. PQL: The lowest concentration that can be reliably measured within specified limits of precision and accuracy for a specific laboratory analytical method during routine laboratory operating conditions [50 FR 46906]. In practice, a PQL usually is set at 5 to 10 times an MDL based on reagent water. Thus, if the MDL is used to calculate both the PQL and ML, the PQL will be higher. MDL: The minimum concentration of a substance that can be measured and reported with 99% confidence that the analyte concentration is greater than zero. (40 CFR Section136 Appendix B). Louis Howard
3/18/2015 Update or Other Action One of several sites with Land Use Controls in effect (LUC Mgt Plan 2015 Pacific Air Forces Regional Support Center (PRSC) Installations, JBER, AK) March 13, 2015. In addition to ICs established as part of LUCs of the ERP for landfill sites with LUCs in effect, both ERP landfill & non-ERP landfill sites in AK under the management of PRSC must also comply with regulations set forth by the ADEC solid waste regulations in 18 AAC 60. Furthermore, landfill sites under the management of PRSC but not categorized as an ERP site must also comply with ADEC 18 AAC 60. Table 1-3 describes PRSC non-ERP landfill sites. Landfills are defined in 18 AAC 60 as “an area of land, or an excavation in which solid wastes are placed for permanent disposal, & that is not an application site, injection well, reserve pit, or waste pile.” This definition applies to most PRSC ERP & non-ERP sites in Alaska designated as landfills, dumps, or caches. Small PRSC ERP & non-ERP landfill sites at remote installations, such as the long-range radar stations, are regulated as Class III landfills as defined by ADEC. LUC_RESTRICTION The selected remedies for LF003 include: -- Surface Soil – Alternative LF03SS5: PCB Soil (=1 mg/kg): Excavation & Off-Site Disposal. No ICs or LUCs will be required for this portion of LF003. -- Sediment – Alternative LF03SD3: Excavation, Off-Site Disposal, & LTM. Because the source of the contamination will not be removed (the actual landfill), the sediment may continue to be impacted. ICs that prohibit the development & use of property for residential housing & prevent the use of contaminated soil for restricted uses, require a dig permit in the event of excavation, implement soils management plan, & maintain the landfill cap at LF003 in order to prevent direct exposure & water infiltration. ICs will be incorporated into the LUC Plan for LF003. -- Landfill – The remedy for buried solid & potentially hazardous materials in Landfill No. 2 is ICs/LUCs & LTM. ICs that prohibit the development & use of property for residential housing, prohibit excavation or disturbance of the landfill cap/cover, & require maintenance of the cap/cover will be established. ICs/LUCs will include site dig permit system & soils management plan to prevent direct exposure to buried wastes & contaminants. ICs will be incorporated into the LUC Plan for LF003. Louis Howard
9/16/2015 Exposure Tracking Model Ranking Initial ranking with ETM completed for source area id: 72319 name: dump Louis Howard
12/16/2015 Report or Workplan Review - Other Staff reviewed and commented on the draft long term monitoring report for LF003, ST009, SS015. Main comments were regarding qualifications of the two samplers who were not listed in the final approved UFP-QAPP work plan. Staff also requested the Air Force consider conducting statistical analysis of the groundwater results be performed or continued monitoring until three yearly results are below cleanup levels listed in Table C of 18 AAC 75. See site file for additional information. Louis Howard
1/29/2016 Update or Other Action Draft work plan received for LF003, SS016, SS017, OB942, and SR018. The objective of these RA-C activities is to perform remedial activities at LF003, SS016 and SS017 by removal and disposal of contaminated soil and sediments as documented in the ROD. To meet the objective of site restoration, specific field tasks are proposed as follows: ? LF003: Excavation, transportation, and disposal of approximately 375 tons of PCB and potentially lead contaminated surface and subsurface soil, and 38 tons of PCB contaminated sediment at an approved treatment/disposal facility. Removal and disposal of soil and sediment with PCB concentrations greater than or equal to 1 milligram per kilogram (mg/Kg) and lead concentrations greater than or equal to 400 mg/Kg per 18 AAC 75; Field screening and laboratory confirmation sampling to characterize PCB and lead contamination of remaining soils of the excavation floor and sidewalls following removal activities, and; Rehabilitation and surface restoration of the excavated sites by backfilling and leveling to local grade, and reseeding the disturbed areas using native vegetation as necessary. See site file for additional information. Louis Howard
2/3/2016 Report or Workplan Review - Other Staff reviewed and commented on the draft work plan for LF003, SS016, SS017, OB942 and SR018. Main comments were to include a conversion factor for cubic yards referenced in the ROD and tons of soil/sediment used in the work plan. Other comments were regarding the USACE/AFCEC limit of 1 foot for excavation depth when the RI showed contamination was present at two to three feet below ground surface. Also, that field screening for PCBs will not substitute for the required analytical soil samples required by regulation to demonstrate cleanup levels have been met and the site may be backfilled. Lastly, staff requested an explanation on why the migration to groundwater cleanup levels were not applicable at the site for GRO, DRO, BTEX. See site file for additional information. Louis Howard
4/20/2016 Cleanup Plan Approved The UFP-QAPP and Site-Specific Work Plans for LF003, S, 0 16, SS01 7 and OB942 at Cape Romanzof LRRS, Alaska dared January 2016 is approved for implementation at LF003, SS016, SS017, and OB942. ADEC is withholding its approval of SR018's site-specific work plan pending a signed Record of Decision. Louis Howard
9/15/2016 Update or Other Action WP Addendum received for review and comment. As a requirement of the 2016 Cape Romanzof LRRS Environmental Long Term Monitoring program implemented at Sites LF003, ST009, SS010, and SS015, the following work shall be performed: • IC inspections for Sites LF003, ST009, SS010 and SS015. • Landfill cap inspection for Site LF003. • ST009 – Groundwater samples will be collected from three existing wells (MW-4, MW-7, and MW-9) and submitted for laboratory analysis of GRO, DRO, and BTEX. No surface water monitoring is planned for this event. • SS010 – No groundwater monitoring is planned at this site for this event. • SS015 – Groundwater samples will be collected from three wells (WW-01, WW-05, and WW-06) and submitted for analysis of DRO, GRO, RRO and BTEX. • Land Use Control signage installation at LF003, SS010 and SS015, consisting of two concrete-reinforced signs designed according to USAF sign template. • Statistical evaluation of the groundwater wells and estimates to achieve cleanup at ST009 and SS015, by conducting a Mann- Kendall analysis at each site. See site file for additional information. Louis Howard
9/23/2016 Report or Workplan Review - Other Staff reviewed and approved the supplemental work plan for LF003, ST009, SS010, and SS015. See site file for additional information. Louis Howard
3/3/2017 Update or Other Action 2016 Technical Project Report Environmental Long Term Monitoring Activities Cape Romanzof Long Range Radar Station Sites LF003, ST009, SS010 and SS015 received for review and comment. Annual monitoring through IC and landfill inspection, LUC sign installation, and photograph documentation has been completed at LF003 for 2016. The inspections conducted at LF003 identified inert metal debris at the southwestern toe of the landfill (Figure 2). This debris should be removed and disposed of. Also, the three access ramps constructed during the 2016 remediation activities should be monitored for possible erosion. Evidence of heavy equipment operations was observed on the landfall cap; however, it did not appear that these activities negatively impacted the integrity of the cap or liner. As part of the required LTM for this site, IC and landfill inspection should continue at LF003 on an annual basis until deemed no longer necessary by the USAF and ADEC. See site file for additional information. Louis Howard
4/28/2017 Update or Other Action Draft report received for review and comment. Remedial activities conducted at LF003 resulted in the removal of approximately 727 tons of PCB and lead contaminated soil and sediment. The analytical results from the post excavation confirmation samples collected after each round of excavation show that cleanup goals for PCB and lead impacted soils have been achieved (Method Two Soil Cleanup Levels of 1 mg/Kg for PCBs and 400 mg/Kg for lead) for Areas 1, 2, and 4. While lead contamination remains in Area 3, further excavation along the eastern boundary was not continued due to the presence of buried debris along the edge of the capped landfill. It is anticipated that a recommendation to extend the land use control boundary along the southwest edge of LF003 cap (the eastern edge of Area 3) will be sought to include the area where subsurface debris was encountered in Cells #36 and #37 and lead contaminated soil remains. See site file for additional information. Louis Howard
5/11/2017 Report or Workplan Review - Other Staff reviewed and commented on the draft RA Construction Report for LF003, SS016 and SS017. Main comments were to state that all confirmation sampling was conducted by a qualified environmental professional or qualified sampler as defined by 18 AAC 75.333. A memo to the file was requested to be drafted with a revised land use control map explaining why buried debris could not be removed from cells #36 and #37 and the presence of a buried fiber optic cable which limits excavation. See site file for additional information. Louis Howard
8/24/2017 Report or Workplan Review - Other Staff commented on the draft RA-O LTM WP. Main comments were regarding analyzing for petroleum VOCs (N-Butylbenzene, sec-Butylbenzene, and tert-Butylbenzene, cyclohexane, N-Hexane, Propyl Benzene, 1,2,4-Trimethylbenzene and 1,2,5-Trimethylbenzene) in addition to BTEX. PCB analysis shall use the correct preparation method for soil and water matrices as specified in the current ADEC field sampling guidance. See site file for additional information. Louis Howard
2/28/2018 Update or Other Action 2017 Remedial Action-Operations/Long Term Management (draft) received for review & comment. The surface cap of the closed landfill was observed to be in good condition with no observed sinkholes, exposed debris, ponded water or erosion. In accordance with the 2013 ROD, periodic inspection of the cap should be completed annually to check the condition of the cap & signage. Maintenance shall be completed as necessary. New LUC signage was installed meeting the AFCEC requirements. IC & landfill inspections should continue on an annual basis until deemed no longer necessary by the USAF & ADEC. The results for all Total PCBs were below the ADEC soil cleanup level of 1,000 ug/kg. No further action for soil sampling in these areas is warranted. Reported surface water concentrations of PCBs for SW-01, SW-02 & SW-04 all exceeded the PAL for composite PCB concentrations of 0.5 ug/L. The remaining surface water location did not contain detectable PCBs. PCBs were detected at all four sediment locations with three locations (SED-01, SED-02 & SED-04) exceeding the 18 PAL of 1000 ug/kg. The surface water & sediment sampling results indicate that surface water & sediment sampling should continue annually, to monitor for contamination that may be migrating from the landfill via the seep & into the surface water or sediment near the toe of the landfill. Additionally, surface water & sediment sampling should be conducted down gradient of the samples collected during 2018 to verify off-site migration of PCB contaminants are not impacting surface water or sediments further down gradient from the capped landfill. See site file for additional information. Louis Howard
3/12/2018 Report or Workplan Review - Other Staff provided comments on the draft RA - O/LTM Report. Main comments regarded monitoring well repairs and/or decommissioning activities for damaged wells and to install protective barriers to prevent damage in the future. Staff requested institutional control inspections occur earlier in the fall (i.e. first half of September) to avoid having the sites not being inspected due to snow cover. Sediment samples from 3 locations at LF003 had PCBs above 50 mg/kg and require further remedial action. See site file for additional information. Louis Howard
8/28/2018 Report or Workplan Review - Other Staff commented on the 3rd Five-Year Review (draft) report. Main comments were regarding the applicability of Toxic Substance Control Act of 1976 for PCBs vs. Resource Conservation & Recovery Act (RCRA). PCBs are not listed wastes under RCRA. Additional comments were to include text for eroded soil control barriers used at LF003 and to acknowledge that there are additional actions needed for PCB contaminated sediments over 100 mg/kg total PCBs. See site file for additional information. Louis Howard
9/17/2018 Report or Workplan Review - Other A letter was sent regarding the 2018 ADEC tech memo which establishes drinking water action levels for six PFAS when detected in groundwater or surface water used for drinking at Cape Romanzof Long Range Radar Site. The tech memo establishes drinking water action levels for six PFAS when detected in groundwater or surface water used for drinking. These compounds, selected in accordance with the U.S. Environmental Protection Agency’s third Unregulated Contaminant Monitoring Rule (UCMR3) under the Safe Drinking Water Act, include: perfluorooctane sulfonate, also known as perfluorooctane sulfonic acid (PFOS), perfluorooctanoic acid, also known as perfluorooctanoate (PFOA), perfluorononanoic acid (PFNA), Perfluorohexanesulfonic acid (PFHxS), Perfluoroheptanoic acid (PFHpA), and perfluorobutane sulfonate (PFBS). Based on review of available information, DEC considers these six UCMR3 compounds to be hazardous substances under state law. See site file for additional information. Louis Howard
9/25/2018 Report or Workplan Review - Other Staff approved the Final Remedial Action – Operations/LTM Report. Louis Howard
11/16/2018 CERCLA ROD Periodic Review Staff approved the changes in the redline version of the Third CERCLA Five-Year Review and Third Non-CERCLA Periodic Review Report for sites-DP011, LF003, SS010, SS013, SS014, SS015, SS016, SS017 and ST009 At Cape Romanzof Long Range Radar Station (LRRS). Louis Howard
3/19/2019 Report or Workplan Review - Other Staff provided comments on the draft supplemental work plan. Main comments were to use the updated documents: 2017 Field Sampling Guidance, 2017 DoD Quality Systems Manual, 18 AAC 75 October 2018, and 18 AAC 70 (2018). See site file for additional information Louis Howard
6/11/2019 Report or Workplan Review - Other ADEC approves the Final Supplemental Work Plan for Cape Romanzof LRRS, Alaska. Dated May 2019 Contract Number: W911KB-14-D-0007-0008. Louis Howard
1/29/2020 CERCLA FS Preliminary Assessment for AFFF Areas at Cape Romanzof. AFFF use on site at Cape Romanzof LRRS was confirmed through the use related to the 1984 fuel leak, and from fire training activities that reportedly occurred on -site. Cape Romanzof LRRS should be considered for further investigation through sampling of environmental media to confirm the presence or absence of AFFF in the surface, subsurface, groundwater and/or surface water. Based on the information sources reviewed during this PA. Therefore, in accordance with the EPA and CERCLA PA and SI Guidance documents (Guidance for Performing Preliminary Assessments under CERCLA; EPA, 1991), Cape Romanzof LRRS is recommended for an SI based on the findings of this PA report. The SI is recommended in order to confirm or deny the presence of PFOS/PFOA contamination and to evaluate potential exposure pathways. See site file for additional information. Louis Howard
2/5/2020 Report or Workplan Review - Other Staff commented on the draft preliminary assessment for aqueous film forming foam. Staff noted that cleanup levels for PFOA and PFOS are promulgated in 18 AAC 75 for soil and groundwater. All other constituents of per- and polyfluoroalkyl substances (PFAS) are subject to regulation by 18 AAC 75.340(g) where ADEC will develop site-specific cleanup levels for a hazardous substance not listed in 18 AAC 75.341(c) using procedures in ADEC's Risk Assessment Procedure Manual. Staff noted that the distance PFAS may be found cold be thousands of feet or miles away from the original release/discharge location in the groundwater and not always located near or adjacent to the release/discharge location. See site file for additional information. Louis Howard
2/5/2020 Report or Workplan Review - Other Staff provided comments on the draft preliminary assessment report for AFFF. Main comments were regarding the regulatory authority of ADEC to develop site specific PFAS contaminant cleanup levels in soil and water that are not listed in Table B1 and Table C per 18 AAC 75.340(g). Additional comments were made on the ability of PFAS contamination to travel hundreds, thousands of feet from the point of release/discharge/spill at a source area. See site file for additional information. Louis Howard
6/19/2020 Report or Workplan Review - Other Approved Supplemental Work Plan, 2020 Remedial Action Operations, Land/Use/Institutional Control, Cape Romanzof LRRS, May 2020. Darren Mulkey
7/25/2020 CERCLA SI DEC approved the “Final Perfluorooctanoic Acid, Perfluoroctane Sulfonate, and Perfluorobutane Sulfonate Site Inspections, Uniform Federal Policy-Quality Assurance Project Plan Work Plan, Six Remote Radar Stations, Alaska” dated July 2020. This work plan was prepared by United States Air Force to guide investigation of the potential presence of perfluorooctanoic acid (PFOA), perfluorooctane sulfonate (PFOS), and perfluorobutane sulfonate (PFBS) at six remote radar sites in Alaska through the sampling of surface water, groundwater, soil and sediment. Sampling is planned for Cape Newenham, Cape Romanzof, Indian Mountain, Point Barrow, Sparrevohn and Tatalina, Melinda Brunner
7/28/2020 Report or Workplan Review - Other DEC reviewed the "Draft Supplemental Work Plan for 2020 Remedial Action Operations, Land Use/Institutional Controls, Cape Romanzof Long Range Radar Station (LRRS), AK" dated July 2020, and returned comments to the U.S. Air Force. The work plan describes planned work, to include sampling monitoring wells, collecting sediment samples, inspecting landfill caps, and repairing signage at LF003, ST009, SS010, SS015, SS016, SS017. Tim Sharp
8/18/2020 Update or Other Action DEC approved the "FInal Supplemental Work Plan for 2020 Remedial Action Operations, Land Use/Institutional Controls, Cape Romanzof Long Range Radar Station (LRRS), AK" dated August 2020. The work plan describes planned work, to include sampling monitoring wells, collecting sediment samples, inspecting landfill caps, and repairing signage at LF003, ST009, SS010, SS015, SS016, SS017. Tim Sharp
1/22/2021 Report or Workplan Review - Other DEC reviewed the "Draft 2020 Remedial Action Operations, Land Use/Institutional Control Technical Project Report, Cape Romanzof Long Range Radar Station (LRRS)" dated January 2021, and returned comments to the U.S. Air Force. Main comments were to ensure all results and recommendations in the report were included in the conclusions section. The technical project report describes performed environmental long-term management activities including groundwater monitoring well repair, decommissioning, installation and survey at sites LF003, ST009, SS010, SS013, SS014, SS015, SS016, SS017. Axl LeVan
1/26/2021 Report or Workplan Review - Other DEC reviewed and approved the "Final 2020 Remedial Action Operations, Land Use/Institutional Control Technical Project Report, Cape Romanzof Long Range Radar Station (LRRS)" dated January 2021, and returned comments to the U.S. Air Force. The technical project report describes performed environmental long-term management activities including groundwater monitoring well repair, decommissioning, installation and survey at sites LF003, ST009, SS010, SS013, SS014, SS015, SS016, SS017. Axl LeVan
5/21/2021 Report or Workplan Review - Other Staff provided comments on the Draft 2021 Remedial Action – Construction Work Plan, Multiple Sources, LF003, SS016, and SS017, Cape Romanzof Long Range Radar Station (LRRS), dated April 2021. The document was received 5/21/2021 outlines the intended plan for the demolition of the abandoned upper and lower tram buildings at Sites SS016/SS017. Additionally, it outlines the removal and characterization of polychlorinated biphenyl (PCB) contaminated soil and sites LF003, SS016, and SS017 at Cape Romanzof LRRS. Removal of 246 tons of PCB-contaminated soil from SS016 (Upper Tram area) is expected. Removal of 250 tons of PCB-contaminated soil from SS017 (Lower Tram area) is expected. Additionally, removal of 50 tons of PCB or lead-contaminated soil is expected from LF003 (Landfill No. 2) alongside repair of the landfill cap. Axl LeVan
5/26/2021 Report or Workplan Review - Other DEC approved the "Final 2020 Remedial Action Operations Land Use/Institutional Controls, Cape Romanzof Long Range Radar Station (LRRS), Alaska" dated May 2021. The report presented the results of the 2020 Environmental Remedial Action-Operation/Long Term Management (LTM) program. LTM activities included sampling of monitoring wells and IC/LUC inspections at Sites LF003, ST009, SS010, SS015, SS016, SS017. Additionally sediment and surface water sampling, and road maintenance occurred at Site LF003. LUC warning signs at Sites LF003, SS015, and SS010 were also installed/replaced. Axl LeVan
6/9/2021 Report or Workplan Review - Other DEC completed a review of the "Draft Final 2021 Uniform Federal Policy for Quality Assurance Project Plan for Long-Term Management and Remedial Action Operations Activities, Cape Romanzof Long Range Radar Station, Alaska, dated March 2021". DEC provided comments on June 10, 2021 and the document was received on May 11, 2021. The work plan documents the plan for sites LF003, ST009, SS010, SS015, SS016, and SS017. The work plan described the approach and procedures for site-specific long-term management and remedial action-operation activities at Cape Romanzof Long Range Radar Station. This work will include annual groundwater sampling at sites ST009 and SS015. Additionally, annual surface water and sediment sampling for PCBs will occur at LF003. The document covers work being performed over a 5-year period and outlines the information to be provided during annual reports. Axl LeVan

Contaminant Information

Name Level Description Media Comments

Control Type

Type Details

Requirements

Description Details
20130718 Proposed Plan
20130201 Record of Decision
2003 RI Report for LF003, SS010 SS016 & SS017
2011 Feasibility Study LF03 SS10 SS16 & SS17
2014 Long term mgt. report LF03 ST09 SS15 & SS10
2017 Remedial Action Construction report LF003 SS016 & SS)17
2018 Remedial Action Operations-Long Term Mgt. Report LF03, ST09, SS10, SS15, SS16 & SS17
1992 Preliminary Assessment
1997 Closure Monitoring Report Landfill 2 (LF03)
1999 Site Investigation & Closure Monitoring Landfill 2 (LF03)
2000 Long term monitoring LF Cap Inspection report
2001 Landfill 2 LF03 SS13 & SS15 Long Term Monitoring Report
2002 Record of Decision for Interim Remedial Action SS13 SS15 & LF03
2004 Long Term Monitoring Report Landfill 2 (LF03) SS13 & SS15
2005 Environmental Monitoring Report Landfill 2 (LF03) SS13 & SS15
2007 Environmental Monitoring Report Landfill 2 (LF03) SS13 & SS15
2009 Remedial Investigation Report
2016 Environmental Long Term Monitoring report
2000 Biocell Closure Report
2008 1st 5 Yr. Review LF003 SS013 SS015
2013 2nd 5 Yr. Review LF003 SS013 SS015 ST009 SS014 DP011
2018 3rd 5 Yr. Review DP011, LF003 SS010 SS013 SS014, SS015, SS016, SS017, ST009
1990 Remedial Investigation Stage 1
1991 IRP Remedial Investigation Tech Report Addendum
1995 SS15 SS08 SS14 ST09 Cell Construction Contaminated Soil - Capping LF03
1998 Closure Monitoring Report LF03
2001 Proposed Plan DP11 LF02 LF12 OT06 SS01 SS10 OT05 LF03 SS07 SS08
2005 LF03 Surface Soil Invest. Report
2017 Tech Proj Report LTM LF03 ST09 SS10 SS15
2003 Clean Sweep Report

No associated sites were found.

Missing Location Data

Because the GIS location data for this site has not been entered, we cannot direct you to its position on the map. Click "Continue" to proceed to the Contaminated Sites Web Map or "Close" to return to the site report.
Continue     Close