| Action Date |
Action |
Description |
DEC Staff |
| 7/10/1981 |
Update or Other Action |
Memorandum to the file: Paul Larson Env. Engineer-Env. Office Subject: Inspection of Battery Room Operations at Bldg. 796. On June 30, 1981, inspected the battery room at Building 796 in the company of Mr. Jones, general foreman of operations. Learned that the current method of battery acid disposal is direct dumping into a floor drain leading to a dry well east of the building. This practice is in violation of AR 200-1. Approximately 8 square feet of concrete floor surrounding the drain is severely corroded. A work request has been submitted for floor repair. This office (Environmental Office) is in the process of developing a hazardous waste management policy which will include instructions on battery acid disposal. |
Jennifer Roberts |
| 10/28/1983 |
Update or Other Action |
US Army Environmental Hygiene Agency GW Quality Survey No. 38-26-K986-91 Evaluation of Solid Waste Management Units Fort Richardson AK 24 June to 2 July 1991. This survey was performed to evaluate and update
the Solid Waste Management Unit (SWMU) information contained in Fort Richardson's RCRA Facility Assessment (RFA); to determine
which SWMU's require further sampling, investigation, or corrective action; and to identify and evaluate any SWMU's not previously documented.
SWMU's Not Previouslv Identified in the RFA. Former Neutralization Tank, Building 796. Building 796 is used for equipment and vehicle maintenance, and formerly contained a battery neutralization system. An underground tank
storing neutralized battery acid deteriorated over time, until its remains and surrounding soils were reportedly removed in the
late 1980's. The tank was most likely leaking for several years before its-removal, and therefore there is a potential for ground-water contamination. There could be continuing releases to ground water if soils were not sufficiently cleaned up during excavation (there was no documentation available for the RFA).
Fort Richardson should first attempt to locate any documentation of the tank removal and cleanup actions, to verify whether
appropriate'actions were taken. The installation should initiate an investigation of soil and ground water to determine whether a
release has occurred if such documentation is not available. In addition to the release of acids/caustics, heavy metals would be of concern in this study work. |
Jennifer Roberts |
| 1/31/1990 |
Update or Other Action |
Science Applications International Corporation (SAIC), January 1990. RCRA Facility Assessment,
PR/VSl Report. Contract No. 68-W9-0008. Work Assignment No. R10003. Project No. 6-788-03-807-00 received.
A waste accumulation area was reportedly lo-ted on the east side of Building 796; however, according to Mr. Spooner, the waste accumulation area was approximately 150 feet south of the building. A review of 1974 and 1983 aerial photographs confirms Mr. Spooner's location. In 1974, only a few drums (approximately 10) and two white aboveground storage tanks were present in the area. An approximate area of 50 feet by 30 feet around the drums was stained. In 1983, the waste accumulation area had grown to approximately 100 feet by 100 feet and contained several drums along with what looks like general refuse of unused equipment and materials from the building.
During the 1989 Visual Site Inspection (VSI) for the RCRA Facility Assessment, 13 drums and
5 boxes were observed in this waste accumulation area. The drums were stored on pallets,
and the area was roped off on one side with signs posted indicating the presence of hazardous
waste. Notes from the VSI indicated that the drums were in poor condition, and staining on the
ground surface was observed. |
Max Schwenne |
| 2/11/1991 |
Update or Other Action |
UST 27, Bldg. 796, located at the intersection of the Davis Highway and Fifth Street, was removed and replaced with UST 27A in July 1990. Soil samples taken during the removal were found to contain total petroleum hydrocarbons (TPH) at up to 17,700 mg/kg.
1,500 gallon used oil tank was removed in 1990 and an unidentified volume of soil was excavated and stockpiled. Soil samples collected from the excavation indicated that residual contamination remains. It is not clear what the lab did with regard to analytical methods. The report lacks detail on what was done at the site. No information on limits of excavation, sample collection procedures and locations, lack of information on metals, chlorinated compounds and PCBs. |
John Halverson |
| 4/5/1991 |
Enforcement Agreement or Order |
A Federal Facility Compliance agreement under RCRA docket Number 1090-05-29-6001 signed and was initiated by a notice of noncompliance (NON) dated June 19, 1990. Based on earlier inspections in 1985, 1986, 1987 EPA issued a NON on 7/28/87 for the following:
contingency plan did not name the emergency coordinator or describe an evacuation route;
a railcar shipment containing waste oil that exceeded 1,000 ppm halogen was sent to Fort Wainwright without proper labels or a manifest;
the Part A application did not reflect all wastes generated or stored at the site;
hazardous wastes (HW) containers were not dated or marked; and HW containers were not kept closed during storage.
A June 8/9, 1989 follow-up inspection found the Post failed to label drums containing HW and failed to mark containers with accumulation start date for Building 796.
Section V Required Compliance Actions (C) Fort Richardson shall label drums containing hazardous waste (HW) at the site and comply with 40 CFR 262.34(a)(3). (D) Fort Richardson shall mark containers of HW with the "accumulation start date" at the site and comply with 40 CFR 262.34(a)(2). |
Max Schwenne |
| 7/2/1991 |
Update or Other Action |
US ARMY Environmental Hygiene Agency: Groundwater Quality Survey No. 38-26-K986-91 Evaluation of Solid Waste Management Units, Ft. Richardson AK 24-June - 2 July-1991.
This survey was performed to evaluate and update the Solid Waste Management Unit (SWMU) information contained in Fort Richardson's RCRA Facility Assessment (RFA); to determine which SWMU's require further sampling, investigation, or corrective action; and to identify and evaluate any SWMU's not previously documented.
CONCLUSIONS. Four of the 120 previously-identified SWMU's require sampling and analysis to verify environmental release, and 14 sites are being investigated under separate programs.
Thirty-one SWMU's are Waste Accumulation Areas (WAA's), some of which require improvements to identify, prevent, or control environmental releases. Eighteen underground storage tanks
(UST's) require no actions other than continued documentation of efforts. The two SWMU's located at Camp Carroll should not be addressed under Fort Richardson's corrective action requirements. Based on a low potential for release and/or a lack of a susceptible migration pathway, 51 SWMU's require no further action. Six new SWMU's were identified, five of which have ongoing or planned investigations. The remaining new SWMU requires no further action.
SWMU 37, Former Neutralization Tank (Bldg. 796) Actions: Records and soil/groundwater sampling.
Former Neutralization Tank, Building 796. Building
796 is used for equipment and vehicle maintenance, and formerly contained a battery neutralization system. An underground tank storing neutralized battery acid deteriorated over time, until its remains and surrounding soils were reportedly removed in the late 1980's. The tank was most likely leaking for several years before its-removal, and therefore there is a potential for ground-water contamination. There could be continuing releases to ground water if soils were not sufficiently cleaned up during excavation (there was no documentation available for the RFA).
Fort Richardson should first attempt to locate any documentation of the tank removal and cleanup actions, to verify whether appropriate'actions were taken. The installation should initiate an investigation of soil and ground water to determine whether a release has occurred if such documentation is not available. In addition to the release of acids/caustics, heavy metals would be of concern in this study work. |
Louis Howard |
| 1/1/1992 |
Site Added to Database |
|
John Halverson |
| 3/12/1993 |
Document, Report, or Work plan Review - other |
Letter to Dave Fosbrook RE: Draft Release Investigation Plan/QAPjP Underground Storage Tank (UST) Sites Fort Richardson, HLA Project No. 21844, dated January 29, 1993 which was received on February 17, 1993. Introduction: Text states that if contamination is present above ADEC recommended cleanup levels, a risk- and leachability-based analysis of alternative cleanup levels will be developed, and a CAP will be prepared as appropriate. Clarification requested on whether the Army proposes ACLs on all sites where contamination is present. It is not clear what amount of detail will be included in the analysis to be done under this work plan. Project Description: Two former USTs identified: a gasoline tank and a diesel fuel tank at site F Building 796 (Vehicle and Weapons Repair Shop). A 1,500 gallon used oil tank (Tank #27) was also reportedly removed from the site and residual petroleum contamination was reported at the limits of the excavation. The release investigation should include investigating the area around Tank #27. UST #43 at Building 955, the used POL Holding Facility, is listed as a site to be investigated.
On November 3, 1992, the Department sent the Directorate of Public Works (DPW), Ms. Jane Smith, a letter noting that tank #43 was reportedly to have stored waste from the Sludge Pit Tank, which appears to be a hazardous waste tank. Therefore, Tank #43 and any associated contamination may have to be closed out as a RCRA hazardous waste tank and spill rather than the UST regulations. Our files do not indicate a response to the letter. This issue needs to be addressed prior to conducting field work. Soil Borings: The first paragraph states if groundwater is encountered at a depth of greater than 20 feet, but less than 50 feet, two soil borings will be terminated at approximately 20 feet and the third will be converted to a monitoring well.
This type of determination should be based on information obtained during field investigations. Terminating borings at 20 feet is not desirable if contamination extends to greater depths. If groundwater is, or may be, impacted, one monitoring well most likely will not provide sufficient information to determine the presence or extent of contamination and evaluation options for corrective action.
If there is not enough flexibility to make such a decision in the field, it may result in another phase of release investigation prior to developing a corrective action plan and would ultimately cost more money. Plate 5 for Site C, Building 755, identifies a pipeline valve near the former excavation. Please clarify what the pipeline is constructed of and what type of fluid it holds. Plate 10 for Site H, Building 47-438, shows proposed locations for four soil borings. If possible, a couple of borings should be located inside the former excavations as close as possible to the actual points of release. |
John Halverson |
| 7/30/1993 |
Update or Other Action |
EMCON, Alaska, Inc. conducted a Release Investigation for UST 27 in December 1993. The investigation consisted of drilling five soil borings to maximum depths of 33 feet bgs in the vicinity of the former UST and collecting soil samples. Soil samples were analyzed for VOCs, metals, GRO, DRO, PCBs, and biofeasibility parameters. |
Louis Howard |
| 9/2/1993 |
Update or Other Action |
Preliminary Release Investigation Report Underground Storage Tank Sites Fort Richardson, Alaska, dated July 6, 1993 received by ADEC for review and comment. The report covers the following sites:
Plate 3 Site A, Building 45590, Old Auto Hobby Shop
Plate 4 Site B, Building 750, Motor Pool
Plate 5 Site C, Building 755, Auto and Crafts Center
Plate 6 Site D, Building 756, Motor Pool
Plate 7 Site E, Building 974, Special Purpose Equipment Repair Shop
Plate 8 Site F, Building 796, Vehicle and Weapons Repair Shop
Plate 9 Site G, Building 47811, Veterinary Clinic
Plate 10 Site H, Building 47438, Bryant Anny Airfield Fuel Facility
Plate 11 Site I, Building 47641, Former Aero Club
Plate 12 Site J, Buildi ng 28004, Chlorination Facility
Plate 13 Site K, Building 955, Used POL Holding Facility |
John Halverson |
| 9/21/1993 |
Update or Other Action |
A.G. letter (Breck Tostevin) to Tamela J. Tobia OS Judge Advocate for the Army. Letter states that a separate petroleum site compliance agreement should be separate from the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) federal facility agreement. The petroleum site restoration agreement would function as a "two-party agreement" under the FFA. It would track the basic provisions of the UST Agreement but be tailored to the State's contaminated site regulations and would interface with the FFA. All petroleum sites addressed under the Two Party agreement would be reviewed in the final operable unit of the FFA and actions taken would be memorialized in a Record of Decision (ROD) under the FFA. |
Louis Howard |
| 11/4/1993 |
Update or Other Action |
Memorandum for the Record Subject: Additional Information Regarding Operable Unit D Sites.
A visit to Bldg 796 and discussions Mr. Dennis Hyder, chief of the DOL Vehicle & Weapons Repair Shop at that location provided the following information concering an underground neutralization tank, database ref.# R059, OU D:
a. Attached memo (enclosure 1) provided by Mr. Hyder discusses past battery acid disposal practices. Mr. Hyder verified these practices, describing the process of simply draining a number of batteries all at once into the floor drain of the battery shop located mid-way along the east side of bldg 796. To the best of Mr. Hyder’s knowledge, the acid flowed to a “dry well” just out side the bldg, however, he suspects that the dry well was created by the corrosion of the pipe going from the bldg to the main storm sewer line running parallel to 5th Street (along the front of the building).
b. Sometime following the July 1981 inspection by FRA environmental personnel in referenced memo, the sewer connection running from just outside the building to the main along 5th St. was excavated. The excavation supposedly was a single, narrow trench of unknown depth; however, part of the trench closer to the building was excavated deeper, to approximately 8’, according to Mr. Hyder. He could not recall the date of this excavation. A rough diagram of the area of concern is at enclosure 2.
c. Mr. Hyder is skeptical that there ever really was an underground neutralization tank at the location. The room housing the battery shop was originally designed and built for major automotive repair work and was converted to a battery shop at a later date. This information is consistent with the inconclusive findings of the June, 1989 RCRA Facility Assessment for this unit (enclosure 3). |
Louis Howard |
| 11/12/1993 |
Enforcement Agreement or Order |
State-Fort Richardson Underground Storage Tank Compliance Agreement signed by ADEC (Janice Adair Regional Administrator-Southcentral Office) and U.S. Army. The purpose of the agreement is to bring Fort Richardson into compliance with the Underground Storage Tank (UST) regulations and avoid the expense of formal enforcement proceedings.
The Army agrees to perform the necessary inventory, record keeping, registration, upgrading or closure, tightness testing, site assessment, release reporting, release investigation, and corrective action (remediation) associated with USTs at Fort Richardson (excluding Alaska Department of Military and Veterans Affairs and Army National Guard USTs). All petroleum sites addressed under the Two Party agreement would be reviewed in the final operable unit of the FFA and actions taken would be memorialized in a Record of Decision (ROD) under the FFA.
Site Assessment or Svstem Tightness Test
29. The Army shall conduct a site assessment* or a system tightness test, as required by AS 46.03.380(b) and 18 AAC 78.01S(i)(3), on all USTs located at Ft. Richardson, or permanently close the USTs in accordance with 40 CFR 280 and 18 AAC 78. If site assessments or system tests have been conducted, the Army shall submit proof of compliance by the deadlines set forth in the USTMP. Site Assessments or System Tightness Tests shall be conducted under the schedules in 18 AAC 78.015(i)(3) or, in order to come into compliance, as scheduled in the USTMP.
All tightness testing work will be conducted by a certified UST worker as required by 18 AAC 78.400. Site Assessment work will be conducted pursuant to 18 AAC 78 and an ADEC-approved Quality Assurance Program Plan (QAPP). With respect to UST recordkeeping requirements, the Army shall compile all required records by the date set forth in the USTMP and shall thereafter maintain and update those records as required by 18 AAC 78 and 40 CFR 280.
Release Investigation Reports
31. The Army shall submit to ADEC a Release Investigation* report for each UST site having a documented release* of petroleum products or hazardous substances. These reports will be submitted by the deadlines in the USTMP. The Release Investigation report shall contain all information required by 18 AAC 78.230(b), 18 AAC 78.240(c) and the following:
1) a detailed written or, if applicable, visual description of all work performed and summary of all pertinent data prepared by the Army and its consultants,
2) monitoring well construction data and
3) soil boring logs;
4) site maps detailing existing improvements and (if known)
5) the location of former fuel dispensing equipment,
6) water table elevation maps,
7) petroleum-product level and thickness (isoplot) maps,
8) organic-contaminant concentration maps,
9) aquifer interpretations,
10) other potential source areas within 1/4 mile,
11) data deliverables as outlined in 18 AAC 78,
12) interpretations of field observations and analytical data,
13) a completed Site Assessment/Release Investigation Summary Form, and
14) recommendations for any follow up work.
32. If upon review of a Release Investigation report the ADEC reasonably determines additional contamination assessment is required, ADEC shall notify the Army in writing. This writing will set forth the reason(s) the ADEC concluded that additional assessment is required.
111. "Site" shall mean a distinct area of contamination or potential contamination.
112. "Site assessment" shall mean the investigation of suspected contamination resulting from an unpermitted release of oil or hazardous substance as further defined in 18 AAC 78.090 (Site characterization and assessment).
110. "Release" shall have the meaning in AS 46.03.826 [(9) "release" means any spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping, or disposing into the environment, including the abandonment or discarding of barrels, containers, and other closed receptacles containing any hazardous substance.]
Site was originally listed as an Attachment B site requiring investigation under 18 AAC 78 for USTs 27 and 29. Listed in Attachment I as requiring complete treatment of existing stockpile at the Landfill for SP 3B. Listed in Attachment I as requiring complete treatment of existing stockpile at the Landfill for SP 15. |
Janice Adair |
| 2/9/1994 |
Enforcement Agreement or Order |
Compliance advisory signed by Janice Adair (Regional Administrator) sent to Army in reference to Fort Richardson UST compliance agreement for Tank 26 at Building 786. This advisory is being sent to notify the Army of its failure to comply, in a timely manner, with the Underground Storage Tank (UST) Compliance Agreement ("agreement") Upgrading of USTs (Para. 25) and Free Product Recovery and Soil Remediation (Para. 40). In an effort to keep the working relationship that the Army and the department have established, the department would like to move forward with the agreement's intent and goals, which is to come into compliance with the UST regulations.
A review of our records did not produce any information indicating the Army has complied with closure or upgrade requirements, outlined in Attachment D, for the following tanks and expected dates: UST 26, Bldg 786 Driver's Training 9/30/93, USTs 40 & 41, Bldg 979 POL Gas Station, 9/30/93, UST 57, Bldg 39600, Site Summit, 9/30/93, UST 92, Bldg 732 Resrv. Motor Pool 9/30/93.
Attachment I Petroleum Contaminated Soil Stockpiles- The Army has not submitted a final corrective action report for each site as required by 18 AAC 78.340. Soil Pile (SP) and expected date of completion was 10/30/1993: SP 1 Bldg 8102 Arctic Valley, SP 3B Bldg. 796 Vehicle Maintenance, SP 4 Bldg. 908S 1117th Sig. Batt., SP 5 Bldg. 908N 1117th Sig. Batt., SP 6 Bldg 702 Gas Pump Bldg., SP 7 Flying Club, SP 8 Bldg 733, SP 9 Bldg 798 Motor Pool, SP 10 Bldg 782 Gas Station, SP 11 Fuel Depot, SP 12 Bldg 47622 Bryant Airfield, SP 13, and SP 15 Bldg 55804 Ammo Area A. |
Janice Adair |
| 4/1/1994 |
Update or Other Action |
Harding Lawson 2.7.6
Site F: Building 796. Vehicle and Weapons Repair Shop
USTs 28 and 29 were removed from the north side of Building 796 (Plate 8). USTs 28 and 29 were 1,000-gallon tanks which previously contained gasoline and diesel, respectively. Both tanks were removed from a single excavation that measured approximately 47 feet by 27 feet at the surface and was 26 feet deep. The volume of soil excavated during tank removal is estimated to be 800 cubic yards. Replacement tanks with secondary containment and leak detection systems were installed in the excavation.
Soil sample analytical data indicated TRPH up to 5,800 mg/kg, DRPH up to 2,000 mg/kg, GRPH up to 450 mg/kg, benzene up to 16.1 mg/kg, and tota1 BTEX up to 24.4 mg/kg at the excavation limits. PCBs were not detected. |
Louis Howard |
| 5/6/1994 |
Update or Other Action |
Release Investigation report received for UST 27. Release investigation activities at this site are part of the UST compliance agreement entered into by the Army with ADEC concerning in service & out of service USTs at Fort Richardson, Alaska. The compliance order requires the Army to perform investigation & cleanup activities in accordance with the ADEC August 1991 UST regulations using a contractor with an ADEC approved Quality Assurance Program Plan (QAPP).
In the December sampling event, an effort was made to collect samples at 5-foot intervals in borings AP3277 (FRU-1) & AP3278 (FRU-2). Borings AP3279 (FRU-17), AP3280 (FRU-18) & AP3281 (FRU-19) were sampled at 10-foot intervals. Modifications to the sample plan were made at the discretion of the field geologist due to conditions encountered during drilling.
No significant sample collection problems were encountered during completion of the field investigation
Review of analytical data for the soil samples collected in December 1993 indicates the following results:
• Some analytes were not detected at levels above the MRLs or MDLs.
• Some analytes were detected at concentrations above the proposed soil cleanup levels.
• In some cases detected concentrations could be attributed to lab contamination.
DRO (143 mg/kg), GRO (2,550 mg/kg) and TPH (8,500 mg/kg), and contamination was found to extend to 33' bgs. A potential soil leachabililty study indicated that soil contamination present at the site will not impact GW. GW samples contained carbon tetracholoride (0.16 ppb) and chloroform (0.15 ppb) above MCLs or RBCs. Neither contaminant was used at the site and are considered part of CERCLA OUD Fort Richardson-EPA Federal Facility Agreement
Based on the results of the December 1993 investigation at this site in the vicinity of former UST 27, remaining site soils exceed ADEC cleanup criteria for petroleum. EMCON conducted an exposure assessment for the development of alternative cleanup levels (ACLs) using the EPA numerical leaching model multimedia contaminant fate, transport, & exposure model (MMSOILS). Results of the assessment indicate that the potential for human & ecological receptors to be exposed to the contaminated zone located at the site is very low. The results of the assessment also indicate that GW is not being influenced by DRO in the contaminated zone.
Based on the sensitivity analysis, TOC values of 0%, 50%, & infiltration rates which are twice the values used in the baseline run result in an increased rate of leachate movement in the vadose zone. Only in the TOC equal to 0% for SESOIL did model predict the contaminant would reach the GW surface. This case is based on unrealistic values & is not considered a likely scenario. Had the spill been a lighter more mobile hydrocarbon, such as benzene, GW contamination might be possible. However, volatilization would likely remove most of the benzene during a 50 yr time-frame & the zero value for Henry's constant would not be reasonable.
It is concluded that remedial actions are not warranted at this site. Prior to approval of the no further remedial action alternative, ADEC requested the installation of a monitoring well at this site to monitor potential leachate migration from the impacted soil to the GW. The MMSOILS Model for the site predicts the vertical migration of petroleum-hydrocarbon contaminants during a 50 yr time span to reach a depth of 51’ bgs. GW depth at this site is estimated to be approximately 120’ based on the available depth-to-GW information, as detailed in the report. Considering the results of the MMSOILS leaching model, the value of downgradient GW monitoring well at this site would be of limited value at this time for the following reasons:
• Contaminants would not be detected in the GW for over 50 years. If a well is installed at this location & contamination is detected in the GW sampled from this well, it would be difficult to accurately identify the contamination as the result of leachate from the site.
• Wells of this nature are expensive (approximately $78/ft [$245.00 per meter]). Installation of a monitoring well located in the vicinity of this site would cost over $10,000.
• Currently, Ft. Richardson is conducting an area-wide GW assessment based on a network of existing monitoring wells in the area. An evaluation of the findings of this study should be completed prior to determining the need for an additional well at the site.
Because of this analysis, EMCON believes the installation of a monitoring well at the site is unnecessary. |
Louis Howard |
| 5/16/1994 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the April 1994 Draft Release Investigation report, Former UST 27 Building 796 Contract No. DACAS5-93-D-0013, Fort Richardson, Alaska
The Alaska Department of Environmental Conservation-Defense Facilities Oversight group (ADEC) has received, on May 6, 1994, a copy of the above referenced report for building 796. Below are our comments regarding the report.
2.2 Geology and Hydrogeology page 5
The text states there is one well AP-2976 lucated within one-quarter mile of the site with depth to groundwater at SO-l00 feet below ground surface (bgs). The exact location could not be determined by looking at the post map (fig. 1) or any other figure listed in the report. Please provide the information on its exact location in relation to the site.
5.2 Evaluation of Potential Remedial Alternatives page 31
While the numerical leaching model MMSOILS predicts that petroleum impacted soil will not present a danger to the groundwater through leaching, ADEC will require additional measures in order to ensure the groundwater is not impacted. Prior to ADEC accepting the no further remedial action alternative, the Army will be required to install a monitoring well located downgradient from the site. Downgradient will be assumed to mean in a westerly direction from the site based on information presented in section 2.2 of the report.
The well will be sampled for petroleum hydrocarbon contaminants-i.e. diesel range organics,
gasoline range organics, BTEX, and total petroleum hydrocarbons. If groundwater sampling
from the monitoring well shows no petroleum impacts, then ADEC will consider the site
closed out. Closing out of this site does not limit nor preclude ADEC from requesting future
remediation or site investigation at a later date. If new information indicates that there is
previously undiscovered contamination or exposures that may cause an increased risk to
human health or the environment, then future investigation and/or remedial actions may be
required by ADEC. It is recommended that the new monitoring well be added to the
existing Fort Richardson groundwater monitoring network for regular sampling. |
Louis Howard |
| 7/21/1994 |
Site Characterization Report Approved |
Release Investigation-5 soil boring advanced 33' additional monitoring well installed at site. Soil was below action levels and closed out under UST agreement (November 1994). Groundwater impacts not linked to UST at site and was included in CERCLA investigation 5/8/96 OU D Building 796 |
Louis Howard |
| 11/3/1994 |
Meeting or Teleconference Held |
FFA Meeting notes for OUD.
Buildinq 35-752
Former Drum Storaqe Area
8 shallow borings have been completed with samples from 6 inches and 2 feet below ground
surface (bgs). Based on preliminary results 2-20 foot soil borings have been located.
Preliminary results had high levels of TPH and DRO from soil boring #5. Soil boring #8 had
hits of some SVOCs at 6 inches bgs not identified in the other samples. The 2-20 soil borings are scheduled to be advanced today.
Coolinq Ponds
Not sampled yet. [8 sediment samples. 1 angled soil boring from beneath pond sediment. 3 borings completed as monitoring wells. Sample 3 new and 2 existing monitoring wells.]
Concrete Floor
Not sampled yet. [27 wipe samples.]
Backfill Soils in Former USTs Location
4-20 foot soil borings advanced. Scheduled to be completed today. [2 monitoring wells yet to be sampled.]
Stormwater Outfall to Ship Creek
Not sampled yet.
Buildinq 7OO/718
8 shallow borings have been completed with samples from 6 inches and 2 feet below ground
surface (bgs). Preliminary analytical results have been received and will be evaluated today.
Based on the preliminary results 2-20 foot soil borings will be located. One soil boring had a strong petroleum odor throughout.
Buildinq 704
8 shallow borings have been completed with samples from .6 inches and 2 feet below ground
surface (bgs). Preliminary analytical results have been received and will be evaluated today.
Based on the preliminary results 2-20 foot soil borings will be located. One soil boring had some petroleum odor at 2 feet bgs.
Buildinq 796
2 soil borings located inside the building. One was advanced from 2.5 to 3 feet bgs and one
was advanced to about 4 feet bgs. These borings were planned to be 20 feet bgs but because
of height restraints inside the building had to be advanced with hand methods. The samples
were collected from below the anticipated level of former piping connections. Samples from 2-20 foot soil borings have been collected outside the building. Significant soil staining was encountered at approximately 14 to 16 feet bgs from the boring located at the former septic crib. Preliminary laboratory analysis is still pending. Based on the preliminary laboratory analysis, 1 monitoring well will be installed.
Buildinq 955
4-20 foot soil borings have been advanced at this location. One of the soil borings had definite
indication of petroleum contamination. Sampling activities are completed at this site.
Dust Palliative
Sampling at the dust palliative locations is completed. 3 composite samples have been collected form each of the 4 dust palliative locations.
Fire Trainins Area
10 shallow samples have collected from the Fire Training Area. Preliminary analytical results
have yet to be received. Based on the preliminary results 3-20 foot soil borings will be located. l-20 foot soil boring will be located outside the Fire Training Area.
The majority of the samples had a strong petroleum odor. Field PID readings were high; one
at 2,500 units. A second Fire Training Area has been identified.
Grease Pits
One of the two grease pits identified in the Work Plan has been located with a good degree of
reliability. The location of the second grease pit is confused because several pits have been
located in the area. All the pits in the area have since been identified as human waste (sewage disposal) pits. No sampling has occurred at this site.
Backsround Samplinq
1 shallow boring and l-20 foot soil boring has been sampled from each of the 4 background
locations. Sampling activities are completed at these sites.
|
Louis Howard |
| 11/30/1994 |
Document, Report, or Work plan Review - other |
Staff received the March 1994 Release Investigation Report, UST Sites, HLA Project No. 21844, Fort Richardson, Alaska on April 26, 1994. Section 5.7 Site F, Bldg. 796, Vehicle and Weapons Repair Shop USTs 28 and 29 Page 5-13. The text states a limited volume of volume of petroleum-impacted soil may remain in place due to endangering existing structures (Bldg. 974 and replacement USTs). ADEC concurs with the recommendation and will consider the site closed. Please note that closing out of this site does not limit nor preclude ADEC from requesting future remediation or site investigation at a later date. If construction activities or excavation activities cause contamination to become exposed, or new information indicates that there is a risk to human health or the environment, then future investigation and/or remedial actions may be required by ADEC. |
Louis Howard |
| 2/5/1995 |
Update or Other Action |
Letter from Army to ADEC. On January 13, 1995, you met with Mr. Samuel P. Swearingen, and Major Kevin Gardener of the Environmental Compliance Branch. At this time you requested an explanation for the lack of spill protection on a number of underground storage tanks(UST) located at Fort Richardson. Below you will find a listing of those regulated tanks that were in question and an explanation of how the spill control requirement is met:
Tank#27 A- This is a used oil UST with an ILS-350 interstitial monitor/overfill alarm system. The tank's spill control system consists of a catchement basin/floor drain system attached to an oil water separator. The tank is filled through manually pouring oil into either one of the floor drains or into a oil sink. The system is non-pressurized, and gravity fed. |
Louis Howard |
| 4/14/1995 |
Update or Other Action |
Draft PSE report received.
Soil
SS 1 32' to 40' bgs, Sample ID 94B79601SL 364 mg/kg DRO, Sample ID 94B79602SL 302 mg/kg, 730 mg/kg TPH
Chromium (Assume all Chrome+6 unless speciated): [Table B1 Method Two Migration to Groundwater cleanup level is 25 mg/kg]: 28 mg/kg - 37 mg/kg from 0' to 48' bgs.
MW AP 3513
80' - 81.7' bgs Sample ID 94B79627SL 12/13/1994:
Carbon Tetrachloride: 30J ug/kg (Table B1 Method Two MGW 0.023 mg/kg)
Chromium (25 mg/kg MGW): 34 mg/kg to 38 mg/kg
Nickel (86 mg/kg MGW): 28' - 29.8' bgs Sample ID 94B79622SL: 94 mg/kg
Groundwater
Lead (Table C 15 ug/L) MW AP 3513 sample 94B79628GW 12/21/1994 21 ug/L, 94B79629GW 17 ug/L.
Nickel (Table C 100 ug/L) 114 ug/L, 151 ug/L same well and samples as above.
The risks associated with noncarcinogenic compounds are below the estimated threshold for
adverse effects, the excess lifetime carcinogenic risk for drinking water ingestion exceeds the
lower benchmark of 1 x lo& listed in the NCP. The majority of the excess lifetime cancer risk
is associated with arsenic in groundwater. Arsenic is assumed to be completely in its carcinogenic form and above natural background levels. The remainder of the risk is associated with carbon tetrachloride and chloroform. However, if arsenic were eliminated as a compound of potential concern by comparison with background levels in groundwater, carcinogenic risks would also fall below the threshold for adverse effects.
The semi-quantitative risk assessment was performed using exposure assumptions that may
not be appropriate for the site (e.g., residential use). In addition, the extent of contamination and the dynamic state of soil and groundwater contamination plumes (expanding, degrading, or steady-state) have not been evaluated. The exposure assumptions, compounds of concern, future land use, and contaminant fate and transport may be reevaluated for inclusion in a baseline risk assessment, if required. In addition, ecological receptors, RBCs, risk quantitation methods, and measurement endpoints may be identified for inclusion in a baseline ecological risk assessment. |
Louis Howard |
| 5/1/1995 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the OUD draft Preliminary Source Evaluation doc# 9000-036-420 dated April 1995. ADEC concurs that further investigation for bldg. 796 under CERCLA is required. Please elaborate on what would be addressed under the additional investigation being recommended. Without any specifics, ADEC cannot determine the extent or scope of work being considered would address areas of concern. (This comment applies to all other sites currently being considered for additional investigation.) |
Louis Howard |
| 6/16/1995 |
Site Ranked Using the AHRM |
Initial ranking. Action code added because it wasn't when the site was originally ranked. |
Louis Howard |
| 12/13/1995 |
Update or Other Action |
The Army sent ADEC a letter-SUBJECT: Closure UST Sites for UST Number 14(Bldg 740) and UST Number 27(Bldg 796)
As requested in your letters dated 17 May 1994, and 16 May 1994 groundwater wells were installed at Bldg 740 and 796, respectively. Once installed the wells were to be sampled to determine if the underground storage tanks (UST) number 14 and 27, at Bldg 740 and Bldg 796, respectively, had impacted the groundwater. These wells numbered AP-3532 (Bldg 740) and AP-
3533 (Bldg 796) were sampled and the results reported by the Alaska District Corps of Engineers in the "GROUNDWATER STUDY: FALL 1994 & SPRING 1995, FORT RICHARDSON, ALASKA" report. Based upon the samples analyzed chloroform and carbon tetrachloride were detected at Bldg 740 at 1.6
and 1.4 ug/L, respectively. At Bldg 796 these contaminants were detected at 0.2 and 1.6 ug/L, respectively.
While these analytes exceed their respective risk based concentration (RBC) levels, there is no evidence to suggest that these compounds were ever stored in either UST. Furthermore, neither chloroform nor carbon tetrachloride were detected in any of the soil boring samples taken during UST release investigations conducted at these sites. It appears, therefore, that the
groundwater is being impacted by a contaminant plume of unknown origin, that is not associated with either UST.
USARAK requests that contaminated soils associated with USTs 14 and 27, be granted closure under 18 AAC 78. Wells AP-3532 and AP-3533, along with other wells in the general area, will be resampled in the first quarter of 1996 to attempt to identify the upgradient source of the chloroform and carbon tetrachloride. Any corrective action taken to address groundwater contamination, if deemed necessary, would be conducted under the Fort Richardson-EPA-ADEC Federal Facility Agreement. |
Louis Howard |
| 5/8/1996 |
Update or Other Action |
It should be noted that a 1994 HLA release investigation report showed that residual contamination was left in place at 8-12 feet below ground surface because of concerns of compromising foundation integrity and the two existing USTs. Plate 27 in Section 9.0 ‘Illustrations” clearly depicts an unleaded gasoline dispenser as well as a diesel fuel dispenser associated with bldg. 796.
Previous sampling efforts by contractors did not access the contaminated soils beneath the building, thus leaving question as to how much contamination is present. Further excavation is impossible without compromising the integrity of the building and the Army has conducted the most soil removal practicable from the site.
Groundwater is contaminated with non site-specific contaminants from an unknown source not related to Building 796. Staff reviewed a closure request for building 740 UST 14 and building 796 UST 27. Based on the information submitted and the data from the monitoring wells installed at the sites, it appears the detected groundwater contamination (carbon tetrachloride and chloroform) were not from the two USTs. The request for closure of the sites under the USTMP agreement is granted by ADEC. As part of ADEC's conditions to granting closure, institutional controls restricting any access to the groundwater and contaminated soils at the site will be required.
These closures do not preclude future remediation or site investigation if new information indicates there is previously undiscovered contamination from the USTs or exposures which cause an unacceptable risk to human health, welfare, safety, or the environment. Further investigation and/or remedial actions may be required if contamination exceeding these risks are detected or if the contamination at either site is excavated by the Army for any reason in the future.
ADEC reserves all its rights under Title 46 of Alaska Statutes and 18 AAC 78 to request additional activities in the future if necessary to address these risks. ADEC requests the monitoring wells installed at the sites be added to a Post-wide monitoring network. ADEC concurs with the request to address the groundwater contamination as a part of Operable Unit D. |
Louis Howard |
| 3/13/1997 |
Update or Other Action |
Based on Army Risk Data Report dated 11/8/96, pathways at the site are a deep aquifer; contaminants are leachable to groundwater. Receptors: potential exists for use of deep aquifer for industrial or residential purposes. |
Louis Howard |
| 8/18/1997 |
Update or Other Action |
OUD Remedial Investigation Report draft received.
Groundwater
During the Remedial Investigation, two wells were installed upgradient of the site to evaluate
the source and extent of the chloroform and carbon tetrachloride. Both wells were screened in
a confined aquifer as no unconfined water was encountered during drilling. In addition to
collecting groundwater samples from the two new wells, wells AP-3532 and AP-3533 (hydraulically downgradient) were also sampled. AP-3512, the well located on site, was unable to be sampled due to insufficient water present.
Analytes detected in groundwater samples from the new and existing wells are presented in
Table 4.4-2 and Figure 4.4-l. DRO, several VOCs, and metals were detected in the groundwater in the vicinity of the site. Carbon tetrachloride was detected in samples collected from the four monitoring wells. Concentrations ranged from 1.l ug/L in AP-3533 to a maximum concentration of 3.9 ug/l in AP-3778. The EPA Region 3 RBC [and 2012 18 AAC 75 Table C GW cleanup level] for carbon tetrachlonde is 0.16 ug/L and the MCL is 5 ug/L.
|
Louis Howard |
| 8/19/1997 |
Update or Other Action |
ARMY sent memorandum for distribution on Post, Subject: Institutional controls for soil and groundwater at building 796.
1) attached find a map delineating the area covered by institutional controls at Bldg. 796, the Decision Document for Bldg. 796, and the ADEC concurrence with using institutional controls to control contaminated soils and groundwater at Bldg. 796.
2) Underground storage tank (UST) 27, Bldg. 796 was incorporated in the Fort Richardson-ADEC UST Compliance Agreement in 1993, making investigation and corrective action at this site enforceable under 18 AAC 78 and 40 CFR 280.
Any excavation, required for facility maintenance, within the area indicated on the above referenced map shall be coordinated with the Fort Richardson Environmental Coordinator. The Environmental Coordinator shall ensure proper worker personnel protective equipment selection. Further, the Environmental Coordinator shall ensure that any contaminated soils encountered are properly managed and, if necessary, disposed of in accordance with all relevant and appropriate regulations.
3. Both carbon tetrachloride chloroform have been detected in groundwater monitoring wells in the vicinity of Bldg. 796. Groundwater wells, other than for environemental monitoring purposes, shall not be drilled at this site. Failure to inform the Environmental Coordinator may result in violation of: 18 AAC 78, the FRA-ADEC UST Compliance Agreement, and 40 CFR 280, resulting in fines already stipulated in the Agreement. |
Louis Howard |
| 9/18/1997 |
Update or Other Action |
Formerly known as the DOL maintenance area, the Battery Shop has carbon tetrachloride and chloroform in the groundwater. Source of contamination has not been identified with any known source at the site. Operable Unit A Record of Decision (ROD) signature was the start date long-term monitoring was to begin. Combined with OUD groundwater monitoring Main Post plume for monitoring. |
Louis Howard |
| 10/3/1997 |
Risk Assessment Report Approved |
Risk Assessment for Building 796 OU-D
Of the inorganic results evaluated at Building 796, nickel was statistically higher than background in groundwater. Chromium, mercury, and nickel were statistically higher than background in surface soil. None of the inorganic results were statistically higher than background in subsurface soil for this source area.
Document shows that there are no risks to receptors from soils at the site.
COCs in GW which drive risk for the hypothetical residential user is from: carbon tetrachloride, chloroform, 1,2-Dibromoethane, 1,1,2,2-tetrachloroethane, bis (2-ethylhexyl) phthalate for ingestion at 8.4E-04 total site risk. GW (resident) risk is mostly from 1,2-dibromoethane (EDB) at 98.8%. Worker. The cumulative site ELCR is estimated to be 2 x 10 -4.
EDB is used as an anti-knock additive in unleaded gasolines, but it is hypothesized that EDB is not from unleaded gas at this site because petroleum fuel constituents (alkylated monoaromatics) were not detected at elevated fuels in identical samples. LUSTs at sites which were removed contained waste oil not unleaded gasolines.
Maximum detected concentrations of metals (and arsenic) that were statistically determined to
be no greater than naturally occurring concentrations were eliminated from further consideration in the background evaluation. The exclusion of these chemicals from the BHHRA may have underestimated overall risks for a given site, but not from releases of siterelated chemicals.
Background values used in the statistical evaluation were either specific to Fort Richardson (E&E 1996a) or were obtained from large data sets for concentrations of metals in Alaskan soils and sediment (USGS 1988). Use of site-specific data for some analytes, supplemented with large data sets from Alaska soil and sediments for others, reduces the overall uncertainty.
Groundwater contamination by 1,2-dibromoethane (EDB) at Building 796 contributed over 90
percent of the total risk for the site. This analyte was detected in one out of seven samples
collected over a period of 3 years (1994 through 1996). The detection of EDB was an
estimated value from one sample collected during performance of the 1995 Groundwater
Study (USACE 1995b). EDB was not detected in samples collected in 1994 and 1996;
however, minimum detection limits exceeded RBCs in every case. Therefore, all nondetect
results (i-o., W the SQL, MRL, etc.) contribute significantly to the ELCR from exposure to
groundwater. EDB has been used historically as a fumigant for grain storage in agricultural
regions of the United States, and also used as an anti-knock additive in unleaded gasolines
(Merck 1996). However, it is unlikely that EDB originated from unleaded gasoline because
petroleum fuel constituents (i.e., alkylated monoaromatics) were not detected at elevated
levels in identical samples.
|
Louis Howard |
| 10/30/1997 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft Operable Unit D Risk Assessment dated September 23, 1997. The text states that EDB (1,2dibromoethane) detected at bldg. 796 is unlikely to have originated from unleaded gasoline since alkylated monoaromatics (toluene, ethytinzene, and xylenes) were not detected at elevated levels in identical samples. DEC agrees with the staterxlent, however, it should be noted that a 1994 HLA release investigation report showed that residual contamination was left in place at 8-12 feet below ground surface because of concerns of compromising foundation integrity and the two existing USTs.
Plate 27 in Section 9.0 ‘Illustrations” clearly depicts an unleaded gasoline dispenser as well as a diesel fuel dispenser associated with bldg. 796. Previous sampling efforts by contractors did not access the contaminated soils beneath the building, thus leaving question as to how much contamination is present. This may not have any bearing on the overall ‘risk” to receptors since it is at depth, but needs to be noted that the site has not been completely characterized. |
Louis Howard |
| 7/2/1998 |
Update or Other Action |
Updated USARAK institutional control policies and procedures received. The draft USARAK Command Policy Memorandum, ICs standard operating procedure and revised excavation clearance request have been finalized. To ensure the effectiveness of institutional controls, all organizational units and tenant activities will be informed on an annual basis of the institutional controls on contaminated soils and groundwater in effect on USARAK property. Where institutional controls are applicable to any organization, tenant, or activity, land use restrictions shall be incorporated into either a lease or Memorandum of Agreement, as appropriate. Costs for any and all remedial actions and fines and/or stipulated penalties levied as a result of a violation of an established institutional control shall be funded by the violating activity or organization. |
Louis Howard |
| 3/23/1999 |
CERCLA Proposed Plan |
OU D Proposed Plan signed and approved. OUD consists of 12 source areas: Building 35-752 – High Frequency Transmitter Site; Building 45-590 – Auto Hobby Shop; Building 726 – Laundry Facility; Building 796 – Battery Shop; Stormwater Outfall to Ship Creek; Dust Palliative Locations (four separate areas); Landfill Fire Training Area; Grease Pits; Circle Road Drum Site; Building 700/
718; Building 704; and Building 955. Of the four source areas evaluated in the RI, three (Buildings 35-752, 796, and 45-590) were determined to require cleanup action under CERCLA.
Building 796, a battery and vehicle and maintenance weapons repair shop, is at the southwest corner of Fifth Street and Davis Highway. Activities currently conducted at this facility include battery rework and other vehicle maintenance. Former activities at the battery shop included draining batteries into a floor drain that subsequently drained into a dry well on the east side of Building 796. Since the mid-1980s, batteries have not been drained, but have been disposed of through Fort Richardson’s Defense Reutilization and Marketing Office. Building 796 has an oil/water separator connected to the post’s sanitary sewer system. Building 796 was included in the RI/FS due to the past disposal practices for battery acid.
SUMMARY OF SOURCE AREA CONTAMINATION AT BUILDING 796
Soil-Low levels of contamination were detected in soil at Building 796; however, the levels do not pose an unacceptable risk to human health or the environment based on residential exposure scenarios. Therefore, soil at Building 796 does not require remedial action.
Groundwater-Groundwater associated with Building 796 has been impacted and requires remedial action based on the depth and amount of water and the presence of benzo(a)pyrene and 1,2-dibromoethane. Levels of contamination were evaluated for potential future residential and industrial use of the source area. 1,2-Dibromoethane was detected above the maximum contaminant level in 1 of 12 samples. Benzo(a)pyrene was detected above the maximum contaminant level (MCL) in 2 of 8 samples.
Currently, groundwater is not used as a source of drinking water at this source area. It is important to note that the RI was unable to prove that waste management practices at the Battery Shop and the contamination in groundwater are related. Therefore, the source of groundwater contamination is currently unknown.
Soil-Soil does not require cleanup at Building 796 because no contamination at this source area posed unacceptable risk to human health or the environment.
Groundwater-Groundwater cleanup at Building 796 will be performed for the overall protection of groundwater as a resource in accordance with the NCP.
The conclusion of the baseline Human Health Risk Assessment for Building 796 determined that there is currently no risk associated with groundwater because there is currently no exposure to groundwater.
In addition, institutional controls will prohibit access to the groundwater as a source of drinking water; and the land use at this source area and neighboring source areas will remain industrial for the foreseeable future. However, concentrations of benzo(a)pyrene and 1,2-dibromoethane were detected at concentrations above federal and state drinking water standards in groundwater at depths of approximately 100 feet below ground surface that may pose a risk to future residents if groundwater was used for domestic purposes.
The remedial action objectives for Bldg. 796 covered in this Proposed Plan are to:
Restore groundwater at Buildings 35-752, 45-590, and 796 to drinking water quality for protection of human health.
Preferred alternative for contaminated groundwater at buildings 35-752, 796 and 45-590 is monitored natural attenuation combined with natural attenuation. GW had 1 of 12 samples detect EDB above MCLs (0.13 ug/l detected v. 0.05 ug/l) and 2 of 8 samples of benzo (a) pyrene (1.0 ug/l detected v. 0.2 ug/l). As with any remedial action under CERCLA, as long as contamination remains on site, the effectiveness of the selected remedy is subject to periodic reviews, not to exceed 5 years. If the selected treatment technology is determined to be ineffective, the Army, EPA, and ADEC will propose another alternative.
|
Louis Howard |
| 3/29/1999 |
Update or Other Action |
COCs in GW include benzene, trichloroethene, iron, manganese, aluminum. |
Louis Howard |
| 3/8/2000 |
Meeting or Teleconference Held |
J. Roberts attended conference call between ADEC, EPA and Army staff. New information caused Buildings 45-590 and 35-752 to be withdrawn from ROD and become Operable Unit "E". Transformers were opened and oil disposed of in a pit dug in 1983 then lit on fire at corner of 35-752. Transformers were operated and used until 1980 at 35-750. Air photos from 1966 shows open pit with trenches and solid waste disposal along with historical information that tanks and armored vehicles were washed down with carbon tetrachloride. This carbon tetrachloride is more than likely the source for the contaminant in groundwater associated with 45-590. OU D ROD will consist of 796, the NFA sites and two party sites. New site-wide risk assessment to be done with OU E. Draft ROD for OU D will be delivered at end of March 2000 for agency review. Action entered by L. Howard. |
Jennifer Roberts |
| 9/2/2000 |
CERCLA ROD Approved |
Jennifer Roberts signed for Lynn Kent (ADEC CS Program Manager). This Record of Decision (ROD) presents the selected remedial actions for Operable Unit D (OUD) at Fort Richardson near Anchorage, Alaska. OUD is the fourth operable unit in the Federal Facilities Agreement Fort Richardson. OUD originally consisted of 12 sites: Building 35-752 -- High Frequency Transmitter Site; Building 45-590 - Auto Hobby Shop; Building 726 - Laundry Facility; Building 796 Battery Shop; Stormwater Outfall to Ship Creek; Dust Palliative Locations (four separate areas); Landfill Fire Training Area; Grease Pits; Circle Road Drum Site; Building 700/718; Building 704; and Building 955. Action related to Building 35-752 and Building 45-590 will be conducted as part of a new operable unit (E).
Two source areas, Building 796-Battery Shop and Building 955 (DDT contaminated soils) will undergo further monitoring. If levels of chemicals of concern at these sites are below MCLs or EPA risk numbers, then 796 and or 955 will be recommended as no-further action sites in OUE. To insure these sites do not pose a threat to human health or the environment, the monitoring data will be evaluated no later than the five-year review, currently scheduled for February 22, 2003, for the first OU at Fort Richardson.
Building 796-Battery Shop
Building 796, a battery and vehicle and maintenance weapons repair shop, is located at the southwest corner of Fifth Street and Davis Highway. Former activities at this source area included draining battery fluid into a floor drain that subsequently drained into a dry well located adjacent to the building. This activity took place from the 1950's until the late 1980's.
The remaining four sites were included in the Remedial Investigation (RI) for OUD. The purpose of the RI was to further characterize the nature and extent of contamination, and to provide enough information so that risk assessments and feasibility studies could be performed for each site. The four sites evaluated in the RI were: Building 35-752 - High Frequency Transmitter Site, Building 45-590 - Auto Hobby Shop, Building 726 - Laundry Facility, Building 796 - Battery Shop.
Prior to the 1970's, road oiling, using waste oils, was a common practice conducted on Fort Richardson to control dust on gravel roads and parking areas. Petroleum hydrocarbons, PCBs, and metals are potential contaminants of concern. No previous investigation of gravel roads or parking lots had been conducted at the Post. The objectives of this investigation were to qualitatively evaluate the impact of road oiling over a large area. During the 1995 PSE investigation three composite samples were collected from four locations known or suspected to have received road oiling in the past. The areas selected for sampling were chosen because they were representative of roads that were historically oiled for dust suppression. The areas included the road to Otter Lake, Roosevelt Road, Davis Highway, and the east side parking lot at Building 796.
Each sample was tested for TRPH, PCBs, pesticides, herbicides, semi-volatile organic compounds, and metals. A semi-quantitative risk assessment was not conducted at this site because all analytes were either 1) not detected, 2) below 1/10th of the Region 3 RBC for residential soil, or 3) not statistically different from background sample population, mainly metals.
CERCLA Section 117(b) requires an explanation of any significant changes from the preferred alternatives originally presented in the Proposed Plan. The proposed remedies for Building 35-752, 45-590 and 796 are being changed.
Significant Changes
The Army, EPA and State of Alaska have agreed to conduct another sampling event for COCs at Building 796. If those results show levels of COCs in the groundwater to be "non detect" (NO) then the Army, EPA and ADEC will recommend a no further action decision for Building 796 in the OUE ROD.
After evaluation of the chemical data for Building 796, it was determined that the risk were overestimated for the contaminants EDB and PAHs. Sampling was completed post-RI and no COCs were in any samples. To confirm these results, one additional sampling event for COCs will be conducted. If the COCs in the groundwater at this source area continues to be non detect, this site will be considered no further action under CERCLA and will be documented in the OUE ROD.
A revised Proposed Plan is not needed because the change for Building 796 is a logical outgrowth of the information available in the proposed plan and administrative record. Groundwater at Building 796 was to be monitored with the Two-Party Agreement sites. |
Lynn Kent |
| 9/28/2000 |
Update or Other Action |
Subsequent groundwater sampling events (15 events) failed to detect Benzo-a-pyrene (BAP) above the 0.2 ug/L cleanup level. EDB was never again detected in subsequent sampling events using a lab method, which can detect it at levels lower than the 0.05 ug/L cleanup criteria. After two more rounds of sampling for EDB and BAP which show them below cleanup levels, the source area will not require further action under CERCLA and the decision be documented in the OUE ROD. Contingency: monitored natural attenuation if monitoring shows that EDB is present above MCL and place the remediation plans in the OUE ROD. |
Louis Howard |
| 10/5/2000 |
Site Number Identifier Changed |
Workplan changed from X0 to X9 to reflect hazardous substances at site. |
Louis Howard |
| 10/19/2000 |
Meeting or Teleconference Held |
Staff met with EPA and Army project managers where preliminary results from the groundwater monitoring showed that EDB is not present in the groundwater. Polynuclear aromatics (PAH) sampling was not in contractor's scope due to COE error. Sampling for PAHs will be conducted in the groundwater prior to Army considering a no further action for the site. |
Louis Howard |
| 4/30/2001 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the draft release investigation for Buildings 796 and 955. Again staff reminded the Army of the required 30 day review time frame for documents. Also staff stated It appears the PAHs and EDB analyses for groundwater at Building 796 and the DDT soil sampling results at Building 955 were all below the Operable Unit (OU) D Record of Decision (ROD) action levels. ADEC requests the closure of these two source areas under CERCLA be documented in the OUE ROD. |
Louis Howard |
| 2/20/2003 |
CERCLA ROD Periodic Review |
Jennifer Roberts signed the five year review document for the Post. The objectives of the Five-Year Review are to answer the following questions: Are the remedies functioning as intended by the decision document? Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives (RAOs) used at the time of the remedy still valid? Has any other information come to light that could call into question the protectiveness of the remedy?
In 1993, a UST removal identified possible petroleum contamination. However, petroleum concentrations did not exceed State soil cleanup levels. During a PSE2 investigation in 1994, carbon tetrachloride and chloroform were detected in the groundwater. The presence of chloroform or carbon tetrachloride was not confirmed during additional groundwater pre-RI sampling events; however, 1,2-Dibromoethane (EDB) was detected during 1 out of 12 of the sampling events and benzo(a)pyrene (a PAH) was detected in 2 out of 8 sampling events. Even though the concentrations of chloroform and carbon tetrachloride were below risk based cleanup levels, the source area was added to the OU-D RI/FS because of the carcinogenic potency of the two chemicals.
The FS recommended a remedial action that was developed in the Proposed Plan and the Draft OUD ROD. During the ROD review, it was determined that the risk was overestimated for the contaminants detected in groundwater. Risks calculated during the RI were based on an estimated value for EDB concentration and PAH detected in samples that were unfiltered. Because the Risk Assessment and determination during the RI were based solely on contaminants that may or may not have been present in groundwater, after re-evaluating the Risk Assessment and the data, it was determined that there were no contaminants above risk levels. .
The Army, EPA, and State of Alaska agreed in the OUD ROD that an additional groundwater sampling event would be conducted. If no contaminants are detected the site will require no further action under CERCLA, and the decision will be documented in the OUE ROD.
Groundwater samples were collected from five on-site monitoring wells at Bldg. 796 during July 2000 and analyzed for VOCs, DRO, EDB, and metals. Samples were collected again during January 2001 for analysis of PAHs only. Threshold criteria for evaluating groundwater sample results are the federal MCLs or secondary MCLs. Results of the post-ROD sampling indicated that all analytes were non-detectable or well below the MCLs.
Recommendations and Follow-up Actions-Per the OUD ROD, the Building 796 site should be formally closed in the OUE ROD. |
Jennifer Roberts |
| 9/27/2004 |
Update or Other Action |
Proposed Plan for OU E In addition to summarizing the results of the investigation at OUE, this Proposed Plan: Provides a decision regarding cleanup at two sites, Building 955 and Building 796, that were deferred from the Operable Unit D Record of Decision (ROD).
The Plan mentions the two other OUD source areas, Building 955-Former Sludge Bin and Building 796-Battery Shop, required additional sampling before they could be recommended for no further action under CERCLA. Thus, a decision regarding cleanup at these two sites was deferred to OUE pending confirmation that contaminant levels were less than cleanup standards.
Both source areas were resampled in 2000 following completion of the OUD ROD. Results of the sampling at Building 796 indicated that 2-dibromoethane (EDB) contamination in groundwater did not exceed cleanup standards or risk levels. Additionally, soil sampling conducted at the Building 955 site indicated that concentrations of dichlorodiphenyldichloroethane (DDD), dichlorodiphenyldichloroethylene (DDE), and dichlorodiphenyltrichloroethane (DDT) did not exceed cleanup standards established at the time the OUD ROD was signed. Both sites are therefore eligible for no further action under CERCLA. This determination will be documented in the OUE ROD. |
Louis Howard |
| 10/11/2005 |
Update or Other Action |
2005 OUE Record of Decision signed concurring with the remedies chosen for Operable Unit E. The decision may be reviewed and modified in the future if new information becomes available that indicates the presence of previously undiscovered contamination or exposures that may cause an unacceptable risk to human health, welfare, safety, or the environment.
Two sites (Building 796-Battery Shop and Building 955-Former Sludge Bin) were identified in the OUD ROD to require further sampling before a formal decision could be made regarding the status of the sites. The OUD ROD required that the Army confirm whether concentrations of the pesticide dichlorodiphenyltrichloroethane (DDT) in soil at the Building 955 site exceeded the risk-based cleanup level of 17 parts per million (ppm). In addition, the OUD ROD required that the Army resample groundwater at the Building 796 site to determine if COPCs, specifically 2-dibromoethane (EDB) and benzo(a)pyrene (a polyaromatic hydrocarbon [PAH]), were present at levels exceeding cleanup standards.
Both source areas were resampled in 2000 following completion of the OUD ROD. Results of the sampling at Building 796 indicated that EDB and benzo(a)pyrene contamination in groundwater did not exceed cleanup standards. Additionally, soil sampling conducted at the Building 955 site indicated that concentrations of DDT in soils at the site did not exceed the risk-based cleanup level established in the OUD ROD. Both sites are therefore eligible for NFA under CERCLA.
Building 796, a battery, vehicle, and weapons maintenance repair shop, is located at the southwest corner of Fifth Street and Davis Highway. Former activities at this source area included draining battery fluid into a floor drain that subsequently drained into a dry well located adjacent to the building. This activity took place from the 1950s until the late 1980s.
Several investigations have been conducted at this site: a 1993 UST investigation, a second Preliminary Site Evaluation (PSE) in 1994, and the RI for OUD in 1996. During pre-RI investigations, chloroform was detected at 3.4 mg/L and carbon tetrachloride was detected at 30 mg/L (estimated value) in one well (NOTE: 18 AAC 75 Table C 2012 GW cleanup level is 0.005 mg/L). These values resulted in acceptable risk estimates. Even though the concentrations of chloroform and carbon tetrachloride were below risk numbers, the source area was recommended to be included in the RI because of the carcinogenic potency of the two chemicals.
Groundwater sampling events, conducted during the pre-RI, did not detect the presence of chloroform or carbon tetrachloride; however, EDB and benzo(a)pyrene (a PAH) were detected above MCLs. During the RI, EDB was detected in one of 12 sampling events at a concentration of 0.13 ug/L (NOTE 18 AAC 75 2012 Table C cleanup level in GW for EDB is 0.05 ug/L)and the PAH was detected in two of eight samples at concentrations of 0.5 and 1.0 ppb.
Based on this information a decision regarding the site was deferred (see the OUD ROD) until groundwater at the site could be re-sampled to determine if EDB and PAHs were present in groundwater at levels exceeding cleanup levels (State of Alaska 18 Alaska Administrative Code [AAC] 75, Table C, Groundwater Cleanup Levels; and federal Drinking Water MCLs).
The Army re-sampled groundwater at the site in 2000 and 2001. Groundwater samples were analyzed for the presence of PAHs, EDB, VOCs, metals, and diesel range organics (DRO). None of the samples contained chemical constituents that exceeded applicable cleanup standards. The only PAH compounds detected were phenanthrene (0.0818 µg/L) and naphthalene (0.0611 µg/L). The concentrations of naphthalene and phenanthrene detected at the site were less than the published cleanup values. EDB was not detected in any of the groundwater samples. Carbon tetrachloride (2.28 µg/L) and chloroform (3.21 µg/L) were detected at the site, but at levels less than the State and federal MCLs. Because contaminants were not detected at concentrations exceeding State and federal MCLs, the site is therefore recommended for NFA. |
Louis Howard |
| 8/24/2012 |
Update or Other Action |
UFP-QAPP for PA/SIs at Sites SA034, SA033, AT035, and AT032 Site Characterization/Cleanup at Sites TA008, TU948, TU110, TU111, TU112, TU949, and SS001 Dated August 23, 2012 received. SA034 – TBD #2, Powerline Drum Site
TU949 Building 770 UST Site (CC-FTRS-05)
SS001 - Building 796 (Battery Shop) (FTRS-01)
SA033 – TBD #3, Otter Lake Road Drum Site
TA008 –Biathlon Range Fuel Release (CC-FTRS-08)
TU948 –Building 57-428 UST Site (CC-FTRS-09)
TU110 –Building 47-431 Tanks E1 & E2 (CC-FTRS-10)
TU111 – CC-FTRS-11, Tank E5
TU112 – CC-FTRS-12, Tank E7
AT035 – TBD #4 MEB Complex, COF (FTR269)
AT032 – TBD #1, Airborne Training Facility (FTR255)
Soil sampling and analysis approach
– Soil samples will be collected every 5 feet between 5 and 25 feet bgs and at 10-foot intervals from 25 feet bgs to the water table (approximately 100 feet bgs) from two new soil borings.
– If, based on photoionization detector (PID) field screening and visual/olfactory evidence, the boring reaches the maximum vertical extent of the soil contamination, then two samples will be collected beyond the last evidence of contamination, and the boring will be terminated.
– Continuous logging of soil type and stratigraphy, moisture or groundwater, visual observations of staining or liquid-phase petroleum, PID readings, and other observations will be performed.
– Soil samples collected at former USTs 28 and 29 (up to 12, excluding quality control [QC]) will be analyzed for GRO, DRO, residual-range organics (RRO), and volatile organic compounds (VOCs) (excluding chlorinated compounds).
– Samples collected at the former UST 27 (waste oil) location (up to 12, excluding quality control [QC]) will be analyzed for GRO, DRO, RRO, the full suite of VOCs, polychlorinated biphenyls (PCBs), metals, and pesticides.
– A subset of soil samples (as described in Worksheet #17 of this appendix) will be collected for additional analyses to facilitate HRC calculations. These analyses include PAHs, volatile petroleum hydrocarbon (VPH), extractable petroleum hydrocarbon (EPH), fraction of organic carbon (foc), bulk density, grain size distribution, specific gravity, and moisture content.
Groundwater sampling and analysis approach
– Groundwater samples will be collected from existing wells (AP-3513 and AP-3533) and analyzed for GRO, DRO, RRO, VOCs, PAHs, VPH, EPH, PCBs, metals, pesticides, and total organic carbon (TOC).
Additional data to be collected for HRC analysis include the following:
? Soil source zone temperature (field measurement)
? Average precipitation/infiltration (estimate from available regional information)
? Aquifer hydraulic conductivity (estimate from literature values based on grain size distribution or from available aquifer testing data from the existing wells)
If unacceptable risk is indicated by the HRC and excavation is the selected remedial approach, then field screening and soil sampling will be performed in accordance with ADEC Field Sampling Guidance (ADEC, 2010).
The project objective is to collect soil and groundwater samples to characterize risk to human health and the environment within the framework of ADEC’s site cleanup process (18 AAC 75 Sections 325 to 390 and 18 AAC 78 Section 600). If Method 1 and Method 2 criteria are exceeded, the HRC approach under Method 3 will be used to assess whether site conditions meet ADEC risk criteria (in which case a “cleanup complete without ICs” determination will be requested) or whether the site poses unacceptable risk (in which case remediation, ICs, or both may be required).
If unacceptable risk is indicated by the HRC, then remedial options that address the compounds and exposure routes which contribute most significantly to the cumulative risk will be evaluated. |
Louis Howard |
| 9/21/2012 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft UFP-QAPP for priority sites including SS001.
WS #10
Land Use Considerations
The text states: “ICs include soil use restrictions based on agreements between the military services, EPA, and ADEC.”
The Army’s 2008 Standard Operating Procedures (SOPs) state “Institutional controls are established when contamination remains in soil or groundwater and a decision is made to restrict land use and access. Institutional controls include dig permits, signage, fences, and monitoring. IC areas are designated on the installation master plan and are regularly updated.”
JBER’s Land Use Controls (May 2011) states: “LUCs were established at JBER to prevent exposure to contaminated soil and water, based on agreements between the military services and the US Environmental Protection Agency (USEPA) and the Alaska Department of Environmental Conservation (ADEC). LUCs are used to reduce the potential for exposure to hazardous substances or to enhance the protectiveness of a soil and/or water cleanup remedy.”
Please state that ICs include both soil and groundwater use restrictions
Page 36
How Much Data Will be Required? Where, When and How Should They Be Collected and Generated?
Probabilistic risk assessment is data intensive, and it should not be done unless there is high quality data available to characterize the distribution of contaminants in exposure media and the behavior patterns of receptors at or near the site. Data would constitute, at a minimum, sufficient contaminant samples (minimum 30-50) in each media, appropriate to statistically characterize the distribution of contamination. It would also require a source of information about activity patterns near the site that was comparable in quality to studies in EPA’s Exposure Factors Handbook. Rarely will sufficient data be available for such risk assessments.
For data to be considered adequate for a risk assessment the following criteria must be met:
Analytical data sufficient for adequate site characterization should be available.
Data must have been collected consistent with DEC and EPA guidance. Sampling and analytical procedures must give accurate chemical specific concentrations.
Validated analytical laboratory data is required. Method detection limits and sample quantitation limits must be below screening criteria.
Qualified data must be appropriately used and explained in the uncertainty section (i.e. discussion on potential bias from qualified data and how it might result in the over or under estimation of risk).
Rejected data shall not be used for risk assessment purposes.
Table 11-1
Result 6B1
The text states the 95% UCLs of mean soil and groundwater concentration data will be compared to the respective SLs (cleanup levels). ADEC does not concur. Delete reference to use of the 95% UCL here and throughout the document and appendices.
Soil – A 95% UCL may be proposed for department review and approval in accordance with 18 AAC 75.380(c). If it is not approved, the maximum concentration will be used for site determination. It does not appear that sufficient data will be collected to calculate a valid 95% UCL.
Water – 95% UCL is not acceptable for GW. The maximum GW site concentrations shall be used.
Groundwater sample results are not averaged nor are a 95% UCL calculation appropriate for groundwater.
|
Louis Howard |
| 6/13/2013 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 72475 name: Bldg. 796 USTs |
Louis Howard |
| 8/30/2013 |
Document, Report, or Work plan Review - other |
ADEC has reviewed the figure, sample locations and analyses table sent on behalf of JBER for SS001 Building 796 (Battery Shop). ADEC will approve the resampling effort as detailed in the email and the attachments. This e-mail message will be considered an addendum to the “Priority Sites” UFP-QAPP for PA/SIs at Sites SA034, SA033, AT035, and AT032 Site Characterization/Cleanup at Sites TA008, TU948, TU110, TU111, TU112, TU949, and SS001. |
Louis Howard |
| 6/9/2014 |
Update or Other Action |
Draft SC report received for review and comment.
Conclusions
The following conclusions can be made regarding SS001:
UST 27 Area
Based on the 2012 and 2013 site characterization field investigation, DRO, 1,2,3-trichlorobenzene, benzo(a)pyrene, and Aroclor 1260 were detected in soil above project screening
levels. Several metals were detected above project screening levels; the concentrations are within JBER-R background, JBER-R OUD maximum, or within the range for Alaska surficial soils.
The source area at the former UST 27 area (defined as the three-dimensional soil volume with DRO concentrations greater than 250 mg/kg) begins at approximately 14 feet bgs and extends vertically to approximately 20 feet bgs, and extends laterally to cover a 34- by 13-foot area. The total volume of DRO in the area of UST 27 is estimated to be 100 cubic yards.
Risk was evaluated using the online Method Three calculator (ADEC, 2014) and the HRC, and cumulative carcinogenic risk and noncarcinogenic HI estimates are below the regulatory risk standards of 1E-05 and 1.
Groundwater sampled and submitted for laboratory analysis from the two existing monitoring wells in September 2013 had no reported contaminant concentrations above project screening levels.
UST 28/29 Area
Based on 1993, 2012, and 2013 site investigations, DRO, GRO, and VOCs were not detected or were below project screening levels.
All exposure pathways are incomplete or insignificant.
Recommendations
The following are recommended for SS001:
No further investigation and/or cleanup of soil and groundwater.
Designation from ADEC as Cleanup Complete because the site meets the criteria established for site closure. |
Louis Howard |
| 6/25/2014 |
Cleanup Complete Determination Issued |
Cleanup complete determination made.
Site Description and Background
SS001 consists of three former underground storage tanks (USTs) associated with Building 796 used to store used oil, diesel, and gasoline fuel (USTs 27, 28, and 29). Building 796 is currently used for weapons, vehicle, and equipment maintenance.
Contaminants of Concern
None. The exposure point concentrations detected no contaminants above applicable cleanup levels.
Cleanup Levels
The cleanup level for soils at SS001 containing DRO contamination is 10,250 mg/kg in the Under 40-inch Zone based on the ingestion pathway within the 0 to 15’ interval below ground surface (bgs). Modeling using the Hydrocarbon Risk Calculator, in accordance with Method 3 under 18 AAC 75.340, demonstrated that residual petroleum contaminants in soil do not pose a migration to groundwater risk/concern.
The estimated rounded cumulative cancer risk at SS001 for the current industrial and hypothetical residential exposure scenarios, across all exposure pathways, (3 x 10-6 and 1 x 10-5 respectively) is below the regulatory risk standard of 1 x 10-5 for petroleum hydrocarbons.
The estimated cumulative noncancer HI at SS001 for the current industrial and hypothetical residential exposure scenarios, across all exposure pathways, (0.03 and 0.01 respectively) is below the regulatory risk standard of 1. SS001 meets the ADEC risk criteria [18 AAC 75.325(g)] for petroleum hydrocarbons. The risk posed by the DRO aromatic and aliphatic surrogate fractions meets the risk standard for each exposure pathway, assuming a residential land use scenario.
An ecoscoping form was completed for SS001 and no observed surface soil staining, no impacted vegetation, no surface water or sediment runoff from the site. The ecoscoping form indicates that a more in-depth risk evaluation is not needed and that the SS001 site conditions are protective of the environment.
Based on a review of the environmental records, ADEC has determined that SS001 has been adequately characterized and has achieved the applicable requirements under the site cleanup rules. ADEC is issuing this written determination that cleanup is complete, subject to a future department determination that the cleanup is not protective of human health, safety, welfare, or of the environment [18 AAC 75.380(d)]. A “cleanup complete” designation will be entered for SS001 in the Contaminated Sites Database. |
Louis Howard |
| 6/26/2014 |
Institutional Control Record Removed |
Institutional Controls have been removed. |
Louis Howard |
