Action Date |
Action |
Description |
DEC Staff |
4/1/1969 |
Update or Other Action |
An explosion reportedly occurred in the Pumphouse while one of the booster pumps was being
repaired during the spring of 1969. An incinerating toilet reportedly ignited fumes from leaking
JP-4 fuel. The explosion did not result in a fire, and pipeline personnel do not recall that a release of fuel resulted from the blast. The pipeline should have been isolated during the repair work, and if the valves did not fail in the explosion, only a small volume of fuel would be expected to have been released.
The bypass line was installed on an emergency construction basis to allow continued operation of the pipeline while the Pumphouse and booster pump system were being repaired. DFSC contractor personnel familiar with the repair work did not recall how the fuel in the pipeline was handled before the bypass line was tied into the main pipeline. Given the emergency nature of the work, it is possible that fuel was released at this time. |
Ron Klein |
3/31/1989 |
Update or Other Action |
The Indian Booster Pump Station was constructed in 1967 in conjunction with a pipeline to transport fuel from Whittier to Anchorage for use by military bases and other government agencies in Alaska. The Army operated the pipeline until 1989, when operational responsibility was transferred to Defense Energy Support Center (DESC). |
Ron Klein |
4/6/1989 |
Update or Other Action |
ADEC William McGee for Larry Dietrick Director issued a general wastewater disposal permit #8840-DB001 for disposal of wastewater from excavations such as: culvert placement, gravel mining, pipeline installation, inspection or repair, bridge construction, building construction under provisions of Alaska Stature 46.03.
Each permittee whose estimated discharge is greater than 500,000 gallons should contact the Habitat Division of Alaska Department of Fish and Game at least two weeks prior to start of each discharge to surface waters. Permit is effective upon issuance and expires on April 1, 1994 or upon issuance of an amended general permit for excavation dewatering. Permit may be terminated, modified, or renewed in accordance with AS 46.03.120. |
William McGee |
4/14/1989 |
Update or Other Action |
A 5,000-gallon UST was located immediately west of the Pumphouse prior to 1989. Grates within the Pumphouse reportedly collected spilled fuel which drained into the UST. The types of fuel that reportedly drained to this UST included JP-5/JP-8, JP-4, and DF-2. The UST failed a tightness test in 1988 and the U.S. Army had the UST removed in 1989. It was noted during the removal that the UST was highly corroded with numerous holes. The quantity of fuel released from this UST is unknown, as is the mixture of fuel types that may have been released. |
Ron Klein |
9/1/1989 |
Update or Other Action |
The valve stations located north and south of the Pumphouse, where the bypass line was tied into
the main pipeline, have reportedly been the sites of past maintenance and repair work. DFSC indicated that fuel released from the pipeline during this maintenance work was contained and collected (Bestry, 1993). While specific instances of fuel spills have not been reported, free
product has been reported in the vicinity of the south valve in Well MW-22 and in Test Pits TP-18
and TP-19. |
Ron Klein |
5/14/1990 |
Enforcement Action |
ADEC sent Notice of Violation/Request for corrective action Spill# 90-2-1-1-122-4 letter to Defense Fuel Support center (DFSC). On May 1, 1990, Mr. Paul Bestry of TECON notified ADEC via AK State Troopers of a 60 plus gallon of JP-4 fuel spill from the Whittier to Anchorage pipeline at milepost 98.6 which is nine (9) miles north of Girdwood. This spill was due to a malfunctioning valve. On May 2, Lt. Colonel Robert Dryer of Elmendorf AFB also notified this office of the spill and stated you are the contact person. Upon further inspection, it was found that the valve had been leaking for some time and a substantial amount of staining was visible on the nearby soils. Also, a weep was found flowing into a nearby wetland.
Rich Sundet requested Mr. Bestry continue daily monitoring and cleanup. Since this area is a wetland, Mr. Bestry was directed to contact the Corps of Engineers (COE) for a wetland determination. On May 3, 1990, Mr. Randy Steen of the COE inspected the subject area, and a COE permit would be necessary for placement of fill. He also stated that soils were stained around the valve indicating that other spills had occurred and believed the spills were fairly extensive.
On May 9, 1990, Sundet informed Dreyer that a work plan would need to be submitted to this office (ADEC) for the remediation of the spill. Dreyer requested ADEC's approval for the operation of the pipeline prior to the work plan being submitted to the ADEC. Mr. Bestry later contacted Sundet that day and Sundet reiterated the discussion with Dreyer. Mr. Bestry stated that the faulty valve could not be replaced until the soil is excavated around the culvert which the valve is located within.
On May 9, 1990, Rich Sundet stated to Dreyer, that the Department has no objection for the pipeline to resume operation provided that the faulty valve is repaired and the pipeline is hydrostatically tested to ensure that there are no further leaks. Sundet stated to Mr. Bestry that the Department has no objection to him excavating the contaminated soil from around the valve so it can be repaired and stockpiling material on or off site provided that the material is stockpiled onto reinforced plastic sheeting and the soil is properly covered by this sheeting. Also that if the material is moved off-site, the property owner be notified of the potential liability.
The correct testing for the pipeline is a hydrostatically volumetrically test procedure in as short of segments of pipeline as possible. It is strongly recommended that the line, however, be pressurized to 1.5 times the normal operating pressure and then the line be visually inspected for this line.
According to AS 46.04.020 (c), if the Department determines that containment or clean-up activities are not adequate, it may direct the person engaged in the activities to cease and may undertake the activities itself through a contractor or its own resources or both. If the Department undertakes clean-up action, it must, under AS 46.04.010, seek reimbursement through civil action (AS 46.03.0760, AS 46.08.070) for the expense it incurs in cleaning up or containing a discharge of oil.
Please provide a written work plan to this office by June 1, 1990, out1ining the actions you intend to take. Please have your employees or contractors continue to monitor and place absorbent pads as necessary at the site, especially at the weep, until the area has been properly addressed/cleaned up. The Department specifically reserves the right to require additional assessment or cleanup activities as information is developed during the course of the site evaluation and cleanup. The Department specifically reserves the right to take further action as provided for in Title 46 of the Alaska Statutes. Additionally, the Department reserves all its rights to pursue any and all other responsible parties involved in this incident. |
Rich Sundet |
5/14/1990 |
Update or Other Action |
John Halverson took down a spill report from Lori Tussey-Lay Engineering (Ft. Richardson) regarding a underground storage tank (UST) closure of slop tank from floor drains in pump house at the Indian pump station. Spill report number= 90-21-1-134-3. Slop tank tightness tested 1 1/2 years ago (1988 est.), failed test, pumped out and left in ground. UST closure started 5/14/1990 contaminated soil found. Excavated approximately 50 cubic yards and stored with additional contamination present and left in ground. |
John Halverson |
7/25/1990 |
Site Characterization Workplan Approved |
Richard Sundet reviewed and approved, with comments, the work plan for spill# 90-1-1-1-122-4 submitted by Woodward Clyde Consultants dated June 26, 1990 to identify the extent of the contamination from the fuel leak at the site. Preliminary work showed that the pipeline valve has been leaking for some time. Twenty five (25) locations will be sampled to determine the extent of the surface and subsurface soil contamination. Also one (1) water sample will be collected from the pond/wetland downgradient of the pipeline leak. Additionally, one soil and one water background sample will be collected for comparison purposes. All samples will be analyzed for total petroleum hydrocarbons (TPH), benzene, toluene, ethylbenzene, and xylene using proper methodologies, and quality assurance/quality control procedures.
Two main comments were developed on the work plan.
1) All contaminated materials which are removed and properly stored at the Anchorage Fuel Terminal, be stored separately from contaminated materials collected at other sites. The material collected from the subject location is also to be marked so that these materials will not be mixed and later confused with the other materials collected. Please provide a sketch of where these materials will be stockpiled.
2) ADEC recommends the background sample be collected in an area which would less likely to have been affected by the spill(s) such as a nearby pond. However, the ADEC still advises to collect another sample in the location as designated in Figure 2.
The pollution spills constitute violations of AS 46.03.710 (Pollution of the Air, Land, Subsurface Land or Water of the State Prohibited), and AS 46.03.740 (Discharge of Petroleum or Petroleum Products without a Permit Prohibited) and associated regulations. According to AS 46.04.020 (a) (Removal of Oil Discharges), a person causing or permitting the discharge of oil shall immediately contain and cleanup the discharge. According to AS 46.04.020 (b), the containment and cleanup activities must be carried out in a manner approved by the Department. |
Rich Sundet |
7/26/1990 |
Document, Report, or Work plan Review - other |
John Halverson sent letter to Mr. Paul Bestry TECOM regarding the July 1990 work plan. Verbal approval was granted to the Defense Fuel Region Alaska. This letter serves as formal approval of the plan with the understanding that if soil borings are deemed necessary the minimum sampling effort will be one sample per each five (5) feet of boring and additional sampling will be conducted if needed based on visual screening, olfactory observations, and field screening with the TIP I. All soils removed from the ground must be completely contained on site until a treatment or disposal plan has been approved by the ADEC. Please be aware that a work permit from the Chugach State Park may be required prior to conducting field work. |
John Halverson |
9/17/1990 |
Document, Report, or Work plan Review - other |
Letter to Mr. Paul Bestry from J. Halverson (ADEC)-The Department has concerns with the content of the report and the work performed. Information provided to the Department May 14, 1990, indicates the original excavation was from 8 to 10 feet in depth. The samples collected during this investigation were from 7 to 8 feet below the surface. It appears these samples were not collected from the native materials deeper than the initial excavation. Soil samples collected by Fort Richardson personnel in May of 1990 were not sent to a lab for analysis. The decision not to analyze the samples were based on olfactory observations that the samples were not contaminated beyond acceptable levels. The Woodward Clyde work showed more than half of the samples collected contained olfactory evidence of petroleum contamination.
A lessor number of sub-samples from the stockpiled soils were collected than was in the site work plan. These samples were composited and mixed in a stainless steel bowl (volatile components would be lost during mixing). The sampling plan for stockpiled soils should be modified. There were at least seven (7) areas of concern regarding the quality assurance/quality control (accuracy, precision, completeness, corrective action, performance system audit, standard operating procedures, absence of a QA report attached to the final report as called for in the work plan.) Based on these outstanding issues, the Department cannot accept the September 7, 1990 site investigation report nor its recommendations included with it.
The Department is requesting that a plan for additional remediation and/or assessment work be submitted. |
John Halverson |
9/26/1990 |
Update or Other Action |
INTERIM GUIDANCE FOR SURFACE AND GROUNDWATER CLEANUP LEVELS SEPTEMBER 26, 1990
Interim cleanup guidance for contaminated surface and groundwater remediation is necessary to ensure that consistent cleanup levels are being applied by district and regional program staff. The following guidelines should be implemented under 18 AAC 75.140 which specifies that a "discharge must be cleaned up to the satisfaction of the Regional Supervisor or his designee.
Final cleanup levels shall be determined by the Regional Supervisor or his designee based on site-specific conditions. Staff should be aware that if a facility is regulated under RCRA, that RCRA corrective action and cleanup standards should enter into development of final site cleanup levels.
Groundwater should be cleaned up to levels not exceeding the more stringent of the final State or Federal Maximum Contaminant levels (MCLs) for Organic and Inorganic Chemicals. If final MCLs have not been adopted for a contaminant, then groundwater should be cleaned up to levels not exceeding proposed Federal MCLs. The group of compounds collectively identified as total petroleum hydrocarbons (TPH) should be cleaned, up to non-detectable levels as measured by EPA Method 418.1.
Final State MCLs are specified in 18 AAC 80.050 and final Federal MCLs are specified in 40 CFR 141 and 142. Proposed Federal MCLs are specified in the May 22, 1989, Federal Register Vol. 54, No. 97, pages 22155 - 22157 and the July 25, 1990, Federal Register Vol. 55, No. 143, pages 30408 - 30448. Appendix I provides a summary listing of State and Federal Final and Proposed MCLs for selected organic and inorganic contaminants.
For organic and in organic contaminants that have not been assigned a final or proposed MCL, cleanup levels should be based on criteria cited in EPA's Water Quality Criteria. 1986 using a health risk factor of 10-6. EPA's water quality criteria identify concentrations of elements and compounds which have toxic effects on aquatic organisms or toxic and carcinogenic effects on humans.
If groundwater is being used as a drinking water source and alternative water supplies or point of use water treatment cannot be provided, then final or proposed secondary maximum contaminant levels (SMCLs) may be used as cleanup target levels. SMCLs are based on aesthetic properties such as taste and odor, whereas MCLs are based on human health risks. For compounds such as xylenes, the SMCL maybe several hundred times lower than the MCL.
Surface waters used for drinking water should also be cleaned up to levels not exceeding the final or proposed MCLs for organic and inorganic chemicals, as specified above. Under the authority of 18 AAC 70.020, surface waters important to the growth and propagation of aquatic life should be cleaned up to the listed criteria which includes EPA's Water Quality Criteria. 1986. These criteria identify concentrations of specific elements or compounds which have toxic effects on aquatic organisms. The group of compounds collectively identified as total petroleum hydrocarbons (TPH) should be cleaned up to non-detectable levels as measured by EPA Method 418.1.
Alternative Cleanup Levels (ACLs) may be adopted for a site if a risk assessment approved by the department is performed and cleanup to levels identified above is technically infeasible. Risk assessments will not by themselves establish ACLs. Determination of cleanup levels is a risk management decision that the department must make based on results of a quantitative risk assessment and other pertinent information.
The responsible party (RP) may prepare at its own expense a risk assessment which shall include an assessment of both human health and environmental risks. Specific components of the risk assessment should include an exposure assessment, toxicity assessment, risk characterization, and justification of ACLs. A general description of these risk assessment components is provided in Appendix II.
General technical requirements for risk assessments should be based on EPA risk assessment guidance for superfund sites. A site specific risk assessment procedure must be prepared by the RP and submitted to the department for review and approval prior to conducting a risk assessment. The RP, at the department's discretion, must agree to reimburse the department for expenses incurred by the department if it chooses to contract for a risk assessment review. |
Louis Howard |
11/5/1990 |
Document, Report, or Work plan Review - other |
Letter from ADEC (Richard Sundet) to Bill Goodman spill#90-2-1-1-122-4. Review of the September 28, 1990 Woodward Clyde Assessment Report. Since the fuel spill encompasses wetlands & the area is with Fish & Game, Corps of Engineers, & Chugach State Park on October 31 & November 1, 1990. Fish & Game & Chugach State Park had no objection to the cleanup provided they are included in the development of the work plan. Corps stated that a Nationwide Permit may be issued to DoD by the Corps for the cleanup activities.
ADEC requests:
1) a work plan including a QA/QC document, be submitted for the cleanup of this spill in accordance to ADEC September Cleanup Guidelines (dated Sept. 1990).
a) To minimize impacts to the wetland from heavy equipment & human traffic, do not commence the cleanup until the ground is adequately frozen between the road & valve box.
b) Insulate as soon as possible the contaminated soils to keep the ground from further freezing until cleanup/excavation commences.
c) The spill has affected a narrow unvegetated band of soils between the valve & the pond, the pond, & along the east & southeast shores of the pond. These areas need to be addressed.
d) It is unclear the extent of the contamination to the east & southeast of the pond. Please address this concern.
e) To control erosion & the degradation of water quality during excavation & cleanup, please use fabric material, curtains, & other such techniques.
2) Please contact Corps, ADF&G, & ADP&R during the development of the workplan for their recommendations, requirements, & assistance in permitting the cleanup activity.
3) ADEC requests information on the status of the pipeline, i.e. is it registered as an underground storage tank (UST). If it is not registered as an UST & the excavated contaminated materials are over 1,000 kilograms, the materials will be required to be tested in accordance to the TCLP for benzene because of the amount of material generated. The TCLP is a characteristic used to determine if a material is a hazardous waste or not. If the excavated material fails TCLP, then it has to be treated as hazardous waste according to the Resource Conservation Recovery Act (RCRA). Currently, however, LUST are not subject to TCLP. Therefore, if applicable, it may be to your advantage to have the pipeline registered as an UST.
If the pipeline is classified as an UST, please contact John Halverson of this office as he addresses LUST sites for this area & all future correspondence concerning this spill should be directed to him. If the pipeline is classified as an UST, other options for the cleanup of the contaminated soils & waters may be allowed, i.e. in-situ remedation treatment.
4) As stated in the May 14, 1990 letter, ADEC has no objection to the pipeline resuming operations provided that the faulty valve was repaired & that the pipeline is hydrostatically tested. Please address the status of the valve which malfunctioned & the testing of the pipeline.
Please note that if further remedial action is not conducted at this time to meet contaminant levels recommended in the "ADEC September Cleanup Guidelines", further monitoring or a risk assessment may be requested by ADEC. Upon review of this data, further remedial action may also be requested.
The pollution spill constitute violations of AS 46.03.710 (Pollution of the Air, Land, Subsurface Land or Water of the State Prohibited), & AS 46.03.740 (Discharge of Petroleum or Petroleum Products without a Permit Prohibited) & associated regulations.
According to AS 46.04.020 (a) person causing or permitting the discharge of oil shall immediately contain & cleanup the discharge. According to AS 46.04.020 (b), the containment carried out in a manner approved by ADEC. All work plans must be approved by ADEC prior to any further sampling, clean-up or disposal activities except that previously approved & noted above. All work plans must be accompanied by a QA/QC plan.
According to AS 46.04.020 (c), if the Department determines that containment or clean-up activities are not adequate, it may direct the person engaged in the activities to cease & may undertake the activities itself through a contractor or its own resources or both. If the Department undertakes clean-up action, it must, under AS 46.04.010. seek reimbursement through civil action (AS 46.03.0760. AS 46.08.070) for the expense it incurs in cleaning up or containing a discharge of oil.
Please provide a written work plan this office by November 14, 1990, outlining the actions you intend to take. Please have your employees or contractors continue to monitor & place absorbent pads as necessary at the site. Especially at the weep until the area has been properly addressed/cleaned up. The ADEC has no objection to you insulating the contaminated soil immediately, provided that it is done in an environmentally sound manner. |
Rich Sundet |
4/9/1992 |
Update or Other Action |
EPA Memorandum April 9, 1992 Reply to the ATTN of ES-098. Subject Toxicity of Fuels. From Carol Sweeney Toxicologist Health and Environmental Assessment Section. To Wayne Pierre Federal Facilities Superfuend Branch (HW-124). A response has been provided to the frequently-asked question of whether a reference dose or other toxicity information can be provided for fuel mixtures so that these mixtures can be addressed quantitatively in Superfund risk assessments. The memo from ECAO Cincinnati is attached (last attachment). They have developed reference doses for gasoline, JP-5/kerosene, and JP-4, and a cancer potency factor for gasoline. The memo emphasizes that these are provisional numbers and that considerable uncertainty is involved in this quantitative assessment, because of data limitations, and because inhalation studies were used to calculate oral reference doses.
I typed up a summary table showing the numbers (first attachment) and calculated some risk-based concentrations (second attachment). On the risk-based concentration table, I also
included ordnance compounds, because I hadn't made a table of those before that I can remember. The risk-based concentrations were calculated the same way as table II-1 and II-2 of the Region
10 Supplemental guidance; for soil, the same limitations apply, that the numbers presented do not consider pathways other than soil ingestion.
Toxicity Reference 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 and Inhal. SF: Memo 3/1992.
Kerosene/JP-5 RfD2.0E-2, UF Oral: 10,000, LOC Oral: low, TDS Oral RfD: Memo 3/92
JP-4 RfD 8.0E-2, UF Oral: 10,000, LOC Oral: low, TDS Oral RfD: memo 3/92.
Screening Values for Water RBCs based on Ingestion, Residential
Gasoline-Risk = 10-6 (ug/L) 50, 10-4=5000 HI=1 (ug/L) 7000
JP-5 Kerosene Risk 10-6 10-4=NA HI = 1 (ug/L) 700
JP-4 Risk 10-6 10-4 = NA, HI = 1 (ug/L) = 3,000
Screening Values for Soils- RBCs Based on Soil Ingestion Residential
Gasoline-Risk = 10-6 (mg/kg) 400, 10-4 (mg/kg) 40,000, HQ = 1 (mg/kg) 50,000
JP-5 Kerosene Risk 10-6 10-4 NA, HQ =1 5,000
JP-4 Risk 10-6 10-4 NA, HQ = 20,000
IARC concluded that gasoline is possibly carcinogenic to humans (Group 2B). IARC concluded that marine diesel fuel is possibly carcinogenic to humans (Group 2B), but light diesel fuels and jet fuels are not classifiable as to their carcinogenicity in humans (Group 3). |
Louis Howard |
4/13/1992 |
Document, Report, or Work plan Review - other |
Bill Lamoreaux for Scott Bailey letter sent to Lt. Colonel Robert Dryer Defense Logistics Agency re: DOD JP4 Pipeline Whittier to Anchorage closure/no further action for Spill#s 90-2-1-1-122-04 File# CS75.02 and Department of Defense (DOD) Indian Pump Station-Groundwater Monitoring Program Spill# 90-2-1-1-134-03 File# L75.02. Based on current report(s) No Further Action is requested by the Department on CS75.01. DLA letter of October 8, 1991 on L75.02 outlines a two year groundwater monitoring well program in the vicinity of the Indian Pump Station. Please forward any test results received to the Anchorage District Office to Scott Bailey. The Department looks forward to working with DLA on the completion and close out of this project.
*Addendum to July 1990 work plan is to place all excavated soil from the underground storage tank excavation back into its original place and continue (groundwater) monitoring the area for the next two (2) years by taking water samples from the groundwater monitoring wells. |
Bill Lamoreaux |
8/3/1993 |
Update or Other Action |
Paul Bestry Superintendent reporting via Trooper Dispatch providing immediate notification to ADEC Bill Lamoreaux 3:53 p.m. that the high pressure pipeline had a blocked valve which had leaked spilling thousands of gallons into the roadway.
On August 3, 1993, a pressure valve at the Indian Booster Pump Station at Indian, Alaska, released a maximum of 35, 700 gallons of JP-5/ JP-8 to the environment, impacting soils and
groundwater at the site. Emergency response measures and construction of a groundwater treatment system prevented this released fuel from impacting the nearby creek or down-gradient residential wells. |
Bill Lamoreaux |
8/4/1993 |
Update or Other Action |
Situation report with spill# 93-21-1-215-1 for JP-8 released due to problems with transfer/pressure relief valve #7 after valves were newly installed in pipeline. Low estimate of release 500-4000 gallons. |
John Bauer |
8/26/1993 |
Site Added to Database |
Jet fuel. 20,000 gallons estimated released. |
Robert Weimer |
8/26/1993 |
Site Ranked Using the AHRM |
Initial ranking. |
Robert Weimer |
9/1/1993 |
Update or Other Action |
Mike Munger ADEC-Kenai District Office observed the pressure testing procedure and valve disassembly of the WKM eight (8) inch pipeline block valve that had been removed from the Whittier to Anchorage Pipeline. The procedures took place at Industrial Instrument Service Inc. in Kenai. Prior to the start of testing all custody seals and locks were checked for seal integrity. All markings and numbers matched the ones faxed by John Bauer. No evidence of tampering with locks or seals. 9/2/1993 report from Enterprise Engineering Inc submitted and signed with State of AK registered professional engineer seal Mr. Stephen S. Brooks P.E. Executive Vice President AKRE No. ME-8473.
Two separate deficiencies were found and in combination were the direct cause of the valve discharge upon initial operation of the pipeline. 1) The first deficiency found was that the WKM valve stem protector was not long enough to allow full opening of the valve. The WKM valve, in partial open condition, allows operating line pressure and flow to be exerted on the Circle Seal body cavity relief valve.
2) The second deficiency found was the Circle Seal relief valve installed on the WKM valve cavity was rated for 1060 psig. The relief valve should have been rated at 1550 psig for this pipeline service.
Thus, it is concluded that the WKM valve, not being fully open, allowed operating pressure of 1190 psig to be exerted on the Circle Seal relief valve, which opened due to its nominal rated set point being 1060 psig. |
Mike Munger |
9/7/1993 |
Update or Other Action |
Bill L. sent letter to DFSC Major Robert Wholey DFR-Alaska requesting information.
1) Specifications for the valve at this station, specifications on the valve that was replaced, and specifications for the valve that failed.
2) All documentation concerning the reason the original valve was replaced.
3) All records of maintenance activities related to the valve.
4) All records of testing performed on the valve prior to failure.
5) Names of all contractors and workers associated with the selection, replacement, and testing of the valve.
To evaluate the circumstances surrounding this spill and the potential risk this pipeline has to future spills, and to understand what capabilities exist for leak detection, ADEC request additional information.
1) All inspection reports involving the pipeline that DFC or other agencies have performed or commissioned since the Turboscope evaluation following the 1990 oil spill.
2) All standard operating procedures (SOPs) for the pipeline's maintenance and repair.
3) An explanation as to why current gauging and metering devices were unable to detect a leak of this magnitude.
4) Information as to whether the new leak detection system would/should have been able to detect this leak.
5) Dispatcher logs for all transfers since the line was put back into service after being turboscoped.
6) All maintenance logs since the line was turboscoped.
7) Anchorage and Whittier pipeline transfer records since 1990.
8) The Whittier and Anchorage operator/supervisor logs (shift logs).
9) Names of each company and persons within that company that are or were responsible for any aspect of pipeline operation and that company's specific task.
At least as early as May 1990, the Department had expressed concern about the safe operation of this fuel pipeline. Specifically, the Department has expressed concern over DFC's ability to monitor the integrity of the pipeline and to quickly detect leaks from the pipeline. The August 3, 1993 spill verifies the validity of these concerns and raises further questions about the system's structural integrity and leak detection ability. It is the Department's understanding that the leak was discovered not by the system itself, but by a nearby worker's inadvertent observation. This inadvertent discovery of the leak suggests that the leak could have been even larger than what occurred on August 3, 1993. For this reason, it is DEC's opinion that continued use of the pipeline should be suspended until the Department can fully evaluate the pipeline's integrity and leak detection systems, and can reach an agreement with DFC as to the system's ability to transport fuel safely. (9/16/1993 news release by DFC revises estimate of release to be 35,700 gallons of JP-8 fuel released). |
Bill Lamoreaux |
9/23/1993 |
Update or Other Action |
Letter from Bill Lamoreaux to US ARMY, Colonel Robert J. Wrentmore Director of Public Works APVR-PW-DPW RE: Indian Valley Spill Defense Fuel Region Alaska Pipeline. The Department is conducting an investigation into the circumstances surrounding this fuel spill incident on August 3, 1993 at the Whittier to Anchorage pipeline at Indian Valley. In addition, the Department has concerns regarding the overall condition and operation of the pipeline.
It is the Department's understanding that the U.S. Army is the owner of the pipeline right-of-way. As the owner of this right-of-way, the Department formally requests that the Army provide or make available, copies of all inspections, surveys, maintenance, spill incident or other similar documentation the Army's possession regarding this pipeline. This information is requested under the auspices of " Statement of Cooperation between Alaska Department of Defense Agencies and the Alaska Department of Environmental Conservation" of which the U.S. Army is signatory. |
Bill Lamoreaux |
9/29/1993 |
Update or Other Action |
Bill L. received fax from Matt Carr Southcentral Regional office regarding memorandum between US Army and DFSC. August 4, 1993 inspection of pipeline by DPW staff, Installation Safety Office with Directorate of Logistics from Mile 34 to Mile 55. Numerous and possibly serious failures of integrity of pipeline were observed.
A) The right of way has not been cleared or maintained.
B) Damaged and inoperable cathodic protection devices were observed in the vicinity of Mile 34 and Mile 39 and the saddle block anchor at Mile 38 appears to have failed. The saddle block anchor is not under tension and it appears there is nothing supporting the weight of the pipe between the summit and the bottom of the hill above the Indian Pump Station.
C) Finally, serious erosion of the overburden covering the pipe is occurring at this location.
The Public Works staff also evaluated the Coffman Engineers report dated January 5, 1993. Based on this report and the information observed during the August 4, 1993 inspection, it appears there are serious operational and maintenance flaws with the pipeline. The U.S. Army is the land manager for the pipeline easement. Unless the Army is confident that the pipeline is being maintained in accordance with sound engineering practices, and in accordance with our lease agreements, we must in good faith, and as responsible stewards of the environment, prevent operation of this pipeline. |
Bill Lamoreaux |
10/8/1993 |
Update or Other Action |
Janice Adair letter to DFSC, Major Robert Wholey re: wastewater disposal permit for Indian Creek spill cleanup ADEC permit # 9240-DB003-2D. The Department has completed its review of the subject Notice of Disposal which was received on September 29, 1993. Authorization is hereby granted to conduct wastewater disposal activities as described in the Notice of Disposal. This approval is subject to the terms and conditions of General Permit Number 9240-DB003 and the facility specific conditions listed in this letter and is valid for the time period from the date of this letter through January 1, 1997.
For wastewaters discharged under Option 1 of this authorization a target value of less than 1 mg/L for the parameter Total Petroleum Hydrocarbons will be the goal of the treatment system. If bioremediation of the hydrocarbon contaminated groundwater is proposed at a future date, that operation will require authorization under a separate general permit (9240-DB004). |
Janice Adair |
10/13/1993 |
Update or Other Action |
Letter to Dames and Moore: October 12, 1993 inspection identified problems at the site which require corrective action.
1) Portions of the top cover were laid back, exposing the contaminated soils to rainfall.
2) The berm at the southeast corner of the storage pile no longer exists and contaminated water originating in the contaminated soil pile is flowing off-site.
3) The truck wash station is overflowing and contaminated water is flowing off-site.
4) The new liner for handling the contaminated soils installed for sorting the contaminated soils and trucking off-site has numerous holes and rips.
5) There is no protective berm on the east side of the new liner material and the surface discharge. Contaminants are flowing off-site.
6) Petroleum contaminated water is leaving the staging area and is further contaminating Chugach State Park lands. |
John Bauer |
10/15/1993 |
Update or Other Action |
DLA DFSC Captain, SC, USN Edward Pinion Director Facilities Management response to State Cost Recovery letter sent on 10/7/1993 by John Bauer. As you know, Federal Government expenditures must be authorized under Federal as well as state law. Once we have received a detailed accounting of the reimbursements you seek, we will be pleased to review them to insure compliance with all applicable statutes and regulations. Requests for reimbursement should be forwarded to Defense Fuel Office Alaska, Elmendorf AFB, AK 99506-5000 Attn: Major Bob Wholey USAF. |
John Bauer |
10/19/1993 |
Update or Other Action |
Keven Kleweno sent letter to Dames and Moore re: nondomestic wastewater plan review. Information was submitted on Sept. 30, Oct. 1, Oct. 5, Oct. 8. During an October 8, 1993 meeting, verbal approval was granted to use the pilot treatment plant. Approval is conditional on the requirement that the following items be submitted within fourteen (14) days.
1) As-built drawings of the pilot treatment plant be submitted to this office under the stamp of a Professional Engineer (P.E.).
2) Operation and Maintenance (O&M) manual for the pilot treatment plant will be submitted to this office.
3) Manufacturer's specifications and performance information of each component of the pilot treatment plant be submitted to this office (Anchorage District Office).
The following items need to be addressed before construction approval can be issued before the interceptor and recharge trenches can be issued.
1) A written report covering how the two trenches will be installed. The report will need to address such items as which trench will be excavated first, how each trench will be dewatered and what will occur if contamination is encountered.
2) Will the interceptor trench be lined with an impermeable membrane as discussed during the October 8, 1993 meeting?
A stormwater pollution prevention plan will need to be submitted to this office for review and approval. This plan will need to be submitted to this office as soon as possible in order to ensure that the site will not adversely affect the water quality at Indian Creek next spring. |
Kevin Kleweno |
10/26/1993 |
Update or Other Action |
October 24, 1993 submittal reviewed and it appears all items found in Section XII, paragraph B of permit# 8840-DB001-2G have been addressed. Based on results of Thursday's inspection by ADEC and discussion with Dames and Moore staff, it appears that the control of stormwater runoff issue of ADEC's October 21, 1993 letter is being addressed. As a result, the Notice of Violation to Dames and Moore on October 21, 1993 has been resolved.
To clarify the reporting requirements for surface discharge of wastewater, under Section XII, paragraph A of the general permit (8840-DB001-2G), the permit holder is required to report the noncompliance to the Department within 24 hours, or as soon as possible, of becoming aware of such conditions. Although discussing the incident at the project's weekly agency meeting on October 19, 1993, was the departmental notification, as required, it appears that the written report that is also required and was requested in the notice of violation was not discussed at the meeting. As the written report was not received and the staff from the Departments of Fish and Game and Environmental Conservation had stressed that there was to be NO discharge of silt laden water to any surface water, the Notice of Violation was issued.
|
Kevin Kleweno |
11/22/1993 |
Update or Other Action |
Draft Site Characterization Report (D&M Job Number 09607-049-005 Prepared for IMPACT TECHNOLOGIES CORPORATION) received for review and comment.
The following activities are recommended to complete the site characterization & provide additional information for remediation design.
• Forensic chemical analyses: Additional analyses should be performed to better identify the types & distribution of free & dissolved phase hydrocarbon in the subsurface. Recommended sampling points for the additional analyses are the pumphouse well (PW), MW5, MW-21, Trench 4, & Trench 7.
• GW quality monitoring: Monitoring of GW for potential hydrocarbon migration past the trench system & in the deeper aquifer, both beneath & down-gradient of the site should be carried out throughout the remediation & containment period. All of the deep monitoring wells & selected shallow monitoring wells down-gradient of the site should be monitored to assess the effectiveness of remediation. The shallow aquifer perimeter wells & the deep aquifer wells should be sampled on a quarterly basis to monitor the integrity of the containment system. The complete monitoring well network should be monitored on an annual basis.
GW level monitoring: Extensive GW level gauging is recommended in the start-up phase of the GW pump-&-treat & recirculation system to evaluate the effects of pumping & injection on GW levels & flow patterns. The objectives of the gauging program will be to evaluate containment of the free & dissolved phase plumes by the treatment system, to tune the pumping & injection systems to optimum flow rates, & to obtain data from which the hydraulic characteristics of the reworked glacial soil & consolidated soils can be further characterized.
Quantitative Risk Assessment: A risk assessment should be performed to establish cleanup levels for site soil & GW for both the JP-8 & older spill contamination.
Residual hydrocarbon remediation treatability study: Studies are recommended to evaluate alternative methods for treating the residual free-phase hydrocarbon that will remain in the subsurface after recovery of the mobile hydrocarbon is completed. Potential in-situ remediation methods include soil washing & bioremediation. The treatability studies should evaluate parameters affecting implementation of these alternatives.
See Site File for Additional Information. |
Louis Howard |
12/8/1993 |
Update or Other Action |
Al Meiners signed Park Use Permit 93-058 effective from October 20, 1993 through October 20, 1996. Control, remediation and restoration of JP8 Fuel Spill which occurred on or about August 3, 1993 |
John Bauer |
12/13/1993 |
Offsite Soil or Groundwater Disposal Approved |
John Bauer approved 12/7/1993 request concerning measurement and disposal of recovered fuels from the DFSC Indian Spill. He approved the fuel measurement methodology as identified in the letter and DLA is free to properly dispose the fluids in the rail cars. |
John Bauer |
1/12/1994 |
Update or Other Action |
ADEC letter to Bio-Tech. RE: Plan is not approved to burn hydrocarbon contaminated sorbent material and protective clothing DFSC letter dated on January 6, 1995, and other information provided by Bio-Tech. Proposed work plan is not approved. There were no post-treatment sampling, inappropriate disposal of ash and other contaminated debris, the treatment concept not being suitable for all of the waste stream, and for the lack of complete information on procedures and handling.
The department requests that an alternative work plan for the retrieval, treatment and disposal of the Indian Spill related contaminated materials presently stored at the Bio-Tech facility be submitted on January 26, 1995. |
Robert Weimer |
3/3/1994 |
Potentially Responsible Party/State Interest Letter |
Janice Adair sent letter to Major Bob Wholey USAF DFO-Alaska re: Reimbursement of Costs. The Department is required by state law to recover expenses incurred providing regulatory oversight for all hazardous substances spills. Alaska Statute AS 46.08.070 requires recovery be sought for costs incurred by the State in response actions. The DFSC has accepted responsibility for the spill response and cleanup, therefore we have concluded you are liable for the State's oversight costs. We must seek expense reimbursement for State agency staff time, travel, equipment, supplies and contracting costs. The State incurred $65,518.77 in response costs to date, according to our project records. The detailed costs for the Department or Environmental Conservation, Department of Law, Department of Fish and Game, Department of Natural Resources-Chugach State Park and Department of Natural Resources-Division of Water are enclosed for your review. The full amount of $65.518.77 is due by April 3, 1994.
We must notify you that failure to pay will result in the assessment of interest on the full amount owed at 10.5 percent, annual percentage rate (AS 45.45.010). Failure to pay could also result in legal action which, in addition to other requirements and/or sanctions, may result in he assessment of court costs and attorney's fees and the placement of liens on your property (AS 46.08.075). |
Janice Adair |
4/1/1994 |
Update or Other Action |
DFSC-F letter sent to ADEC Commissioner John Sandor re: to formalize the proposal the Defense Fuel Supply Center proposal presented at the March 17, 1994 meeting regarding future remediation at the Indian Site.
1) DFSC proposes to open up the trench system to permit natural ground water flow to resume. DFSC therefore requests ADEC concurrence in DFSC's proposal to modify the water treatment system and proceed immediately with this plan. DFSC views the modification of the water treatment system as a matter of considerable urgency and request ADEC to respond accordingly. As the Spring runoff causes the volume of water entering the water treatment plant to increase, manpower requirements will expand.
DFSC contends that there is now sufficient information available to enable us to conclude that the water treatment system is no longer performing a useful function. Accordingly, DFSC requests that ADEC modify existing permit conditions to reflect current knowledge base and conditions at the site.
As a result of the decreasing low concentrations of hydrocarbons in the influent samples and because there is no identified threat to the environment or public health, DFSC believes that the ground water collected by the existing trench system can be appropriately discharged without treatment through a controlled discharge point. The existing trench system will continue to operate, capture and remove residual free floating product. Intercepted ground water will be directed through the trench system either by subsurface flow or pumping towards Trench 4, the lowest point in the trench intercept system. In the event the discharge monitoring detects elevated concentrations of hydrocarbon constituents above the target levels, the discharge of ground water will be redirected through the treatment system.
DFSC requests an alteration in the discharge limitations specified in ADEC permit# 9240-DB003-2D issued October 8, 1993 to permit Option 2 (offsite surface) and Option 3 (offsite subsurface) discharges not to exceed 3 mg/L under the test methods specified. Water samples will be collected at the discharge sump to be constructed at Trench 4. In the event the average daily contaminant level exceeds 3 mg/L for two (2) consecutive days, DFSC will resume water treatment and consult with ADEC prior to resuming the untreated discharge at Trench 4. |
John Bauer |
4/8/1994 |
Update or Other Action |
Letter J. Adair from DFSC-FQ re: reimbursement costs. The backup documentation forwarded with the letter has been reviewed and supports the claim of reimbursement of $65, 518.77. Prior to approving your payment request, DFSC is required to review all relevant agreements between the State and Dept. of Defense to ensure that the reimbursement conforms to any applicable provisions. Copies of the agreements have been requested and we expect to receive them shortly. Barring any restrictions in the agreements, we anticipate completing our review and recommending approval of ADEC's request for payment by the end of April 1994. |
Janice Adair |
4/25/1994 |
Update or Other Action |
Letter to Major Robert Wholey US Defense Fuels re: DFSC Indian Spill risk assessment study. During an April 19, 1994 meeting, ADEC advised DFSC against pursuing the risk assessment at this time due to a lack of a full year of data, free phase fuel flowing into the trenches, impacts upon Chugach State Park lands, proximity to nearby residential wells, and recent data indicating Indian Creek, an anadromous stream, is sometimes a gaining stream at the spill site. NOTE to File: “free product” means a concentration of a hazardous substance that is present as a nonaqueous phase liquid; for purposes of this paragraph, a “nonaqueous phase liquid” is a liquid that is not dissolved in water.
During a phone conversation on April 22, DFSC indicated it will go forward with the risk assessment study. There must be a mutual understanding of the risk assessment objectives, parameters, and exposure scenarios to ensure that the information developed in the risk assessment is useful. Neither ADEC nor DFSC have the resources to retroactively fix a flawed work product that should have been done right the first time. If DFSC submits a risk assessment to ADEC for consideration which is not based upon an approved work plan, the assessment has a high probability for being rejected or not considered. |
John Bauer |
6/24/1994 |
Offsite Soil or Groundwater Disposal Approved |
Bill Lamoreaux District Office manager approved disposal of 1,800 cubic yards of rock currently stockpiled at CleanSoils Anchorage Facility, by processing the rock for asphalt production at the Eastwind Inc. crusher plant. The department understands that the rock stockpile was derived from the screening of fuel soaked soils generated from Indian Booster Station Fuel spill. Please provide written notification by fax or mail to this office within two business days of completion of the steps outlined in the proposal. |
Bill Lamoreaux |
7/15/1994 |
Offsite Soil or Groundwater Disposal Approved |
Robert Weimer approved disposal of 2,700 tons of treated soil currently stockpiled at CleanSoil's facility and which has been approved by ADEC for disposal. This soil was generated from the thermal remediation of fuel soaked soils generated from the Indian Booster Fuel Spill. Plan is to dispose of the soil as subfloor fill for the Alaska Paper company warehouse building under construction at 2209 Spar Avenue. |
Robert Weimer |
9/30/1994 |
Update or Other Action |
(Old R:Base Action Code = RAPR - Remedial Action Plan Review (CS)). Plan for bioremediating sorbents is not approved at the time of the letter. |
Robert Weimer |
12/22/1994 |
Update or Other Action |
(Old R:Base Action Code = RPL3 - RP Determined and Action Request). Request retrieval of materials from Bio-Tech facility. Action performed by Krieber. |
Mike Krieber |
12/23/1994 |
Update or Other Action |
DFSC takes exception to the NOV and believes it to be inappropriate nor is it accurate. Soil piles were in fact covered and has been since our on-site meeting on November 10, 1994. The only times the soil piles are not covered are when they are being worked. |
Robert Weimer |
2/22/1995 |
Update or Other Action |
(Old R:Base Action Code = RECN - Site Reconnaissance (CS)). Site reconnaissance. |
Robert Weimer |
2/28/1995 |
Update or Other Action |
(Old R:Base Action Code = RAPR - Remedial Action Plan Review (CS)). Reviewed a corrective action plan. |
Robert Weimer |
8/25/1995 |
Cleanup Plan Approved |
Letter sent to Mike Foster Dames & Moore re: conditional approval of work plan for remediation of contaminated soils spill# 92-2-1-1-215-1. The Department has reviewed the response dated June 29, 1995 for the March 14, 1995 work plan for remediation of contaminated soils currently stockpiled at the site. Based on a review of the information submitted, the Department is granting conditional approval to treat the excavated soil as per the work plan.
1) The confirmation BTEX sampling is to be done on sample sets 1, 4, 8, and 12. Additional sampling for BTEX may be required based on results of the initial sampling sets.
2) All soils to be remediated to Level A cleanup levels. If the proposed treatment fails to achieve those levels then additional treatment/remediation will be required in accordance with a plan reviewed and approved by the Department.
3) The goal is that only soils remediated to non-detect(ND) levels are to be placed back in the excavation within high groundwater level. In the event that there is not sufficient enough non-detect remediated soils to fill the excavation above the high groundwater level then every effort should be made that only the lowest level of remediated soils be placed within the high groundwater level and with the understanding that additional in-situ treatment (active/passive) of those soils will occur. |
Robert Weimer |
9/14/1995 |
Update or Other Action |
The pipeline no longer is used to transfer fuel. It was retrofitted for natural gas transport in 1995 and leased by the Department of Defense to the Alaska Pipeline Company in September 1995 for a term of 33 years. ENSTAR Natural Gas Company currently uses the pipeline to transport natural gas (see text below).
No. DACA85-1-95-81 Whittier-Anchorage P.O.L. Pipeline lease agreement filed with Commission on October 13, 1995 was executed on September 14, 1995, and is for lease of a pipeline system "consisting of an eight (8) inch diameter pipeline for use, transportation, maintenance, repair and delivery of natural gas to rural areas South of, and from Anchorage to Whittier Alaska." The term of the lease agreement is thirty-three (33) years commencing September 15, 1995 and ending September 14, 2028, however, it is revocable at will by the Secretary of the Army.
In consideration for the lease, Alaska Pipeline Company (APLC) is required to pay, in advance, $76,000 per annum. Sanctions are imposed for late payment. According to Ms. Patty Moore, Reality Specialist for the U.S. Army Corp of Engineers (COE), the lease was competively advertised in local newspapers on several occasions during the month of August 1995. There were two respondents to the advertisements, namely APLC/ENSTAR and AIGC. The proposals were opened on September 5, 1995, and evaluated them. The COE and Army reviewed the proposals, and jointly determined that APLC/ENSTAR was the most responsive proposer. The pipeline was consequently leased to the applicants. The Army will be preparing an environmental assessment report which will document the amount of environmental damage which has occurred as a result of the Army's operation of the pipeline. It is stated in the agreement that the Army has retained its responsibility for environmental cleanup of damages resulting from its past use of the pipeline. |
Louis Howard |
3/13/1996 |
Update or Other Action |
Letter sent to DFSC requesting comprehensive site characterization, including the pipeline valve release and old LUST spill (90210013403). Requested meeting and development of Compliance Order.
Lynn Kent on behalf of Kurt Fredriksson Director, sent a letter to Edward W. Pinion Director Facilities mgt. DLA DFSC. The Department understands that the DFSC would like to perform a risk assessment to develop alternative cleanup levels based on risk. The Department requests DFSC fully characterize the site by investigating all past spills including the 1990 leaking underground storage tank spill (# 90210013403). Site data generated from the prior spill site investigations should be then incorporated into the 1993 valve release investigation (#93210121501) dataset to develop a comprehensive assessment of the site soil, groundwater, contamination and site hydrogeology. This data can then be utilized to develop ecological and human health exposure pathways. The risk assessment must be based upon a Department approved work plan.
Due to the complex widespread contamination, hydrogeology, high level of public interest in the site, and to prevent future misunderstandings, the Department would like to enter into a compliance order with the DFSC so all affected parties have clear guidance on how this project will proceed through closure. |
Scott Rose |
3/19/1996 |
Site Ranked Using the AHRM |
Site reranked. New score = 68. |
Scott Rose |
3/20/1996 |
Site Number Identifier Changed |
Combined 2 sites into this Reckey. Changed workplan from X1 to 01. |
Scott Rose |
5/1/1996 |
Site Ranked Using the AHRM |
Reranked by Shannon and Wilson. |
S&W |
6/4/1996 |
Update or Other Action |
Sent letter to DFSC indicating need to remove stored contaminated soil from Bio-Tech facility. ADEC was in recent contact with Mr. Randy Banez of Defense Fuels, discussing the actions necessary to resolve the outstanding matter of the approximately 180,000 pounds of used cleanup materials (sorbents, protective gear, booms, etc.) presently stored at the referenced facility. ADEC infomed Mr. Banez, the facility has not been actively treating contaminated soil, for in excess of a year. Although the facility has ADEC approval to treat soil, BioTech has never received approval of any method to treat the Indian Spill cleanup treatments.
The last ADEC correspondence was to Major Robert Whooley US Defense Fuels on January 12, 1995. In the letter, ADEC did not approve the proposed treatment and disposal method. BioTech has failed to respond to the issues raised in that letter. The Shannon & Wilson's plan prepared in April 1995, with some minor modifications would be a plan acceptable to ADEC. If Defense Fuels desires to use that plan, please have Shannon & Wilson contact ADEC (Krieber) to discuss the needed modifications.
Also, there is the outstanding issue of suspected secondary contamination of the soil where the contaminated materials were being stored. Specifically, S&W performed sampling in BioTech's Quonset Hut in early 1995. Please have the results of that field investigation submitted to this office (Mat-Su Public Service Office) for the Department's review and approval. |
Mike Krieber |
7/2/1996 |
Update or Other Action |
ADEC Letter (M. Krieber) sent to Defense Fuels (R. Banez) confirming a telephone conversation that contaminated material will soon be removed from the BioTech facility. ADEC is looking forward to Defense Fuels formal response to ADEC's June 3, 1996 letter. In our conversation, Defense Fuels inquired about the status of other parties' contaminated material which was stored at BioTech and was requested by ADEC to be removed.
1) Anchorage Refuse's 804 tons contaminated soil was placed in an outdoor cell and removed in early 1995, and taken to an approved treatment and disposal facility. Secondary contamination was discovered under and around the cell. Soil cleanup and post-cleanup confirmation sampling was performed in March/April 1995. No further action is needed.
2) ADOT 10,000 gal. of oily wastewater stored and awaiting treatment. Spill from the vessel occurred in 1995. The spill was cleaned up and after sampling of wastewater showed it to be non-hazardous, it was properly treated at an approved facility.
3) Over 600 drums of oil, lubricants and miscellaneous materials stored outside was removed in 1994 and 1995. BioTech had cleaned up the April 1994 release from the drums.
4) VRCA has approximately 100 overpack drums of spent granulated activated carbon (water treatment), used PPE, and contaminated soil. They have been repeatedly requested to remove the overpacks, for proper disposal. ADEC is currently continuing to work with them on removing the drums.
5) There is a contaminated soil pile, reportedly to be BioTech's (10 cy). ADEC recently received some information that would tie another responsible party to the pile.
To the best of ADEC's knowledge, these are the projects which we have requested the original responsible party to remove from the BioTech property, and to be properly treated/disposed. A great portion of the material has been removed and secondary contamination has been cleaned up. ADEC looks forward to continuing to work together to resolve the Defense Fuels outstanding issues at the BioTech Facility. |
Mike Krieber |
7/17/1996 |
Site Characterization Workplan Approved |
Letter to DFSC re: approval of work plan for remediation of contaminated soil and rock Indian fuel spill. Completed review of revised workplan for remediation of contaminated soil and rock at the Indian Booster Station Fuel Spill received on July 16, 1996. ADEC approves the work plan execution of remediation actions may proceed as provided in the plan. After thermal remediation contractor is selected and prior to any removal of any contaminated soil, DFSC must submit a letter ADEC requesting ADEC approval to transport and treat the contaminated soil.
The approval request must identify the name and address of the thermal remediation contractor, must specify that only contaminated soil and rock currently residing at the Indian fuel spill site will be transported to the treatment facility for remediation. At least ten (10) days prior to transportation of the contaminated soil and rock, please provide Robert Weimer and Scott Pexton with:
1) map that identifies the source of clean fill material to backfill Manhole #1.
2) contact person name/phone# to call if questions or concerns arise during the project.
3) a revised project schedule that includes estimated start/finish dates of the liner removal. |
Scott Pexton |
7/19/1996 |
Document, Report, or Work plan Review - other |
M. Krieber, reviewed and approved a sampling and analysis plan for cleanup of materials stored at the BioTech Services Treatment Facility. Materials were associated with Spill# 93-2-1-1-215-1. The materials are to be transported to, stored and treated at two (2) incinerating facilities located in Anchorage, at Entech, Inc, and at Sure-Way Incineration Company. Entech, Inc: Air Quality Control Permit to Operate No. 9521-AA008 with 29 conditions to the permit which expires on December 30, 2000. Sure-Way Incineration Co. permit to operate with 20 conditions was granted by Muni. Of Anchorage DHHS (AQS 941115) which expires on January 15, 1997.
There is an outstanding issue of suspected secondary contamination of the soil where the contaminated materials were being stored. The Department has not received a copy of your firm's field investigation report. Please have the results of that field investigation submitted to this office (Mat-Su Public Service Office) for review and approval.
For your information, ADEC is assisting Defense Fuels in obtaining access to the property so the material can be removed and treated per your plans. |
Mike Krieber |
8/12/1996 |
Document, Report, or Work plan Review - other |
Limited Site Characterization Report received by Mike Krieber (ADEC) Wasilla Office task order ACO-0001 of contract no. SP0600-95-C-5500. After initial site work was completed, additional analyses were authorized by DFSC's March 3, 1995 facsimile as modification 01 to Task Order ACO-0001. The BioTech facility has been used as a waste storage site from at least 1993-1994. Wastes including used protective clothing, spent sorbent booms and pads, etc. derived from the Booster Station Fuel Spill and subsequent remediation project at Indian Alaska were reportedly stored in plastic bags in the quonset hut. These solid wastes contained residual JP-8 fuel oil, and during an incident at the facility, the bags were reportedly set on fire by vandals.
Wastes from other sources were also stored in quonset hut, therefore, the ADEC (Mr. Mike Krieber) has indicated that DFSC's responsibility was/is limited to characterization and cleanup of two areas of the building each impacted by DFSC wastes. The 2 areas are designated Area Alpha and Area Bravo defined by Mr. Krieber and Mr. Randy Banez (representing DFSC) during a February 21, 1995 site visit. Area Alpha: 12 mg/kg to 4,600 mg/kg diesel range organics (DRO) were detected as well as total petroleum hydrocarbons (TPH) at 5,500 mg/kg. Area Bravo: 69 mg/kg to 3,100 mg/kg DRO and TPH was detected at 3,000 mg/kg.
Based on the results of the quantitative analytical work, DRO exceeds level A cleanup criteria in Samples SA1, SB1, SB2 and SB4 (a duplicate of SB1). Based on qualitative work, DRO "hits" for all samples except Sample SB3 are reasonably well represented as JP-8. Sample SB3 does not appear to contain JP-8, which suggests that some unknown background contamination exists which predates the DFSC wastes at the BioTech facility. A release investigation and/or corrective action is required as stipulated in 18 AAC 75. Standard remediation techniques:bioremedtion, low temperature thermal desorption, etc. should be appropriate to treat the contamination. |
Mike Krieber |
8/20/1996 |
Update or Other Action |
S&W Inc letter addendum Oily Waste sampling and analysis biotech services inc. facility Wasilla, Alaska. The analytical results from teh bulk material samples are consistent with the JP-8 fuel release at Indian, Alaska. On the basis of the testing performed, we find the oily waste materials to be non-hazardous and recommend the Alaska Department of Environmental Conservation (ADEC) approve the incineration of the wastes as detailed in the S&W July 1996 work plan " Sampling And Analysis Plan, Biotech Services, Inc., Waste Storage Facility, Parks Highway, Wasilla, Alaska."
ADEC advised William Burgess from Shannon & Wilson Inc on August 20, 1996, that ADEC had already issues plan approval contingent upon a non-hazardous waste determination. Therefore, the Defense Fuels could proceed with removal without any more approvals from ADEC. |
Mike Krieber |
10/14/1996 |
Update or Other Action |
Report received for "Disposal of Petroleum Hydrocarbon Impacted Soils, BioTech Services, Inc. Facility Wasilla, Alaska" Dated October 14, 1996 to DFSC Virginia Ms. Amy Loar, F.P. from Shannon & Wilson Inc. This summary report documents the results of environmental services by S&W Inc. and their subcontractors under modification 4 (dated August 29, 1996) to task order ACO-0002 of contract SP0600-95-C-5500. All work was conducted by experienced personnel in accordance with "ADEC July 1991 "Interim Guidelines for Non-UST Contaminated Sites" and S&W Inc's August 22, 1996 work plan for excavating and remediating the secondary contamination.
S&W Inc. subcontracted with B.C. Excavating (BC) of Anchorage Alaska for removal and transportation of the soil and Alaska Soil Recycling (ASR) of Anchorage Alaska for thermal treatment of the soil.
After the oil wastes were removed from the Quonset Hut, the ADEC requested DFSC characterize the secondary soil contamination. Upon review of the results (DRO up to 4,600 mg/kg Area Alpha and up to 3,100 mg/kg Area Bravo), ADEC requested corrective action to remediate the secondary soil contamination. The scope of work, which was described in S&W's ADEC approved August 22, 1996 work plan, included recovering oil stained soil within the two impacted areas and hauling off soil off site for thermal remediation.
Provided the excvation depth did not exceed about one foot, the ADEC did not require backfill or confirmatory samples. Mr. Krieber indicated that the removal and documented disposal of the soil would be sufficient to CLOSE this matter from the viewpoint of the ADEC.
On September 4, 1996, Ms. Ruth Adams, S&W field representative, Mr. Delmar Klem & Mr. Ken Schumaker of BC mobilized to the project site. Lt. Col John Esada, Randy Banez of Defense Fuel Office-Alaska (DFO-A), & Mr. Mike Krieber, ADEC Wasilla inspected the site before and after the stained soil was removed. The site work was completed in one day during which the weather was sunny and clear.
Based on observations and discussions at the site between Lt. Col. Esada, Mr. Banez, Mr. Krieber, and Ms. Adams, the scope of work was expanded to include removing surface soil between and beyond Area Alpha & Bravo. The excavated soil was deposited into a lined long-dump truck and a cover was placed over the top of the load to prevent any loss of soil during transportation to ASR. Mr. Krieber met the Shannon & Wilson Field Representative at the site to inspect the area after the work was completed. A total of 19.6 tons of soil were delivered to ASR in a single load. On September 11, 1996 the BioTech secondary soil stockpile was treated by low-temperature thermal desorption process in ASR's rotary kiln. Post treatment samples showed levels significantly below the most stringent cleanup level "A" for DRO. |
Mike Krieber |
2/25/1997 |
Update or Other Action |
Updated Site Characterization Report received. D&M Job # 09607-059-160.
Soil: Four deep borings were installed & sampled. A surface soil sample was collected from each boring as well as a representative sample from the vadose zone & another from the capillary fringe. Due to the nature of the soils at SS-12, a surface soil sample was not collected at this location. DRO was reported in all of the surface soil samples, ranging from 21. 7 to 106 mg/kg.
The maximum DRO level in surface soils was from SS-10. Subsurface soil samples reported detections of DRO ranging from non-detect to 106 mg/kg. The maximum reported detection for a vadose zone sample (106 mg/kg) is from SS-10 at a depth of 5 feet. The maximum reported detection for a capillary fringe sample (79.6 mg/kg) is associated with SS-12 at a depth of 10 feet.
BTEX: Benzene was not detected in surface or subsurface soil samples. Low levels (less than 0.5 mg/kg) of ethylbenzene, xylenes, & toluene were detected in the surface & subsurface soil samples, except Boring SS-10 at the 12.5-foot depth.
PAHs: PAHs detected in surface soils were limited to naphthalene & substituted naphthalenes, fluoranthene, phenanthrene, & pyrene. Surface soil results from Boring SS-6 reported the highest levels of detections for the above analytes. PAHs detected in subsurface soils were limited to naphthalene & substituted naphthalenes: 1-methylnaphthalene, 2,6-dimethylnaphthalene, 2-methylnaphthalene, & C-2 & C-3 naphthalenes. Five of the eight subsurface soil samples reported negligible results for these analytes. Total naphthalenes were reported at 13 mg/kg from Boring SS-10 at a depth of 5 feet.
GW: Background water samples were collected from monitoring wells MW-39 & MW-400 to characterize the shallow & deep GW occurrences, respectively. DRO was detected in MW-39 at 0.0749 mg/L, & was not detected in MW-400 where the detection limit was 0.1 mg/L. GRO, BTEX, PAHs was not detected in either background water samples. Arsenic, barium, cadmium, chromium, & lead were detected in MW-39. None of the seven metals analyzed were detected in MW-400.
Shallow GW: Twenty-seven monitoring wells were sampled to characterize the shallow GW occurrence. DRO was detected in all of the shallow GW samples, ranging from 0.0514 to 99.5 mg/L. The maximum detected level was reported for the sample from MW-38. Seven of the reported detections were less than 0.10 mg/L.
GRO: Monitoring Well MW-PH was analyzed for GRO. GRO was detected at a level of 0.391 mg/L.
BTEX was detected in four of 27 samples. The reported concentrations were as follows: 0.00118 to 0.00315 mg/L benzene, 0.00188 to 0.0922 mg/L ethylbenzene, 0.00119 to 0.042 mg/L xylenes, & 0.00125 to 0.0092 mg/L toluene.
PAHs detected in shallow GW monitoring wells were acenaphthene, anthracene, benzo(g,h,i)perylene, fluorene, naphthalene, phenanthrene, & pyrene. MW-38 accounted for the maximum detected levels of naphthalene at 390 µg/L, phenanthrene at 2.62 µg/L, fluorine at 7.04 µg/L, & anthracene at 0.216 µg/L. The maximum detected level of acenaphthene was 0.242 µg/L at MW-30. Benzo(g,h,i)perylene & pyrene were detected once & 0.0824 µg/L, respectively at MW-15 at 0.067. Naphthalene was the most commonly reported PAH, being detected in ten of the 27 samples analyzed.
Metals: Monitoring well MW-PH was analyzed for metals. Four (arsenic, barium, cadmium, & chromium) of the seven metals analyzed for were reported at levels similar to background levels.
Deep GW: Eight monitoring wells were sampled to characterize the deep GW occurrence. DRO was detected in all eight deep monitoring wells & in the method blank associated with three of these results. The presence of DRO in these three samples has been discounted. Detected concentrations ranged from 0.18 mg/Lat MW-340 to 2. 75 mg/Lat MW-22D.
BTEX: Xylenes were detected in a single sample from MW-20 at 0.00149 mg/L. No other BTEX analytes were detected.
PAHs detected in deep GW samples were benzo(g,h,i)perylene, fluorene, naphthalene, & pyrene. Maximum reported levels were 0.0762 µg/L fluorene at MW-20 & 0.69 µg/L naphthalene at MW-33DR. Benzo(g,h,i)perylene & pyrene were detected at MW-270 at 0.0752 & 0.761 µg/L, respectively.
A sample of fuel product from the pipeline was collected in October 1996 & analyzed for volatile aromatic hydrocarbons using gas chromatography/mass spectrometry (GC/MS). The results of the analysis demonstrated that the concentration level & distribution of BTEX compounds were similar to that found in kerosene type products, such as commercial or military jet fuels. The n-alkane, isoprenoid, alkylcyclohexane, C4-alkylbenzenes, & PAH distributions were similar to those of a reference JP-5 jet fuel mass chromatogram. The analysis indicated that the product tested was JP-5, which had been exposed to the environment for only a short time.
See site file for additional information. |
Louis Howard |
6/19/1997 |
Meeting or Teleconference Held |
Stakeholder meeting held at Potter Section House. Included representatives from ADNR, Indian Citizen Task Force, MOA, Defense Fuels Office, and Dames and Moore. |
Scott Pexton |
6/30/1997 |
Update or Other Action |
Excavation and Site Assessment Report - Former Pumphouse UST received.
RRO & HVO were not detected in any of the submitted samples. Soil samples collected from 10 feet bgs in the excavated pit (S-1, S-2, & S-2 Duplicate) indicated low concentrations of GRO & BTEX, & slightly elevated concentrations of DRO. DRO concentrations exceeded the ADEC Category A soil cleanup concentrations for DRO of 100 milligrams per kilogram (mg/kg). The soil sample from the excavated pit near the drainpipe (S-3) indicated low levels of DRO, GRO, toluene, & xylenes. Samples collected from the excavated trench beneath the gravity feed drain pipeline, S-4 & S-5, reported low concentrations of GRO, DRO, benzene, toluene & xylene. None of the samples collected from the excavated trench exceeded the ADEC Category A values.
HVO & benzene were not detected in the stockpile samples. The DRO value in FS-2-TSS was slightly elevated at 570 mg/kg. Low concentrations of GRO, toluene, ethylbenzene, xylene, & PeBs were detected at levels within ASR permitted treatment ranges for the disposal of petroleum contaminated soil. Detected metals included maximum concentrations of 4.26 mg/kg arsenic, 0.11 mg/kg cadmium, 30.2 mg/kg chromium, & 9.07 mg/kg lead.
The former UST is not present near the Pumphouse. Evidence of the former UST included: the gravity feed drain cleanout pipe attached to the Pumphouse walls, broken pieces of pipe observed in the excavation trench between the Pumphouse & the former UST location, & the concrete slab or deadman at the bottom of the excavated pit.
Previous sample results from WCC's 1990 investigation & Dames & Moore's 1996 site characterization indicated DRO concentrations in soils exceeding applicable UST Matrix Scoresheet Category A levels. Soil beneath the fonner UST location showed evidence of petroleum fuels which contain low GRO & BTEX compounds & slightly elevated ORO.
Soil sampled below the fonner gravity feed drainpipe indicated concentrations of petroleum compounds which are less than the Category A cleanup concentrations. Approximately 40 cubic yards of soil were removed from the former UST excavation pipeline in April 1997. These soils will be treated & their disposition will be documented in an addendum to this report.
Since the location of the former UST & the known & down-gradient extent of contamination lie within the investigation area of the 1993 fuel spill, the most effective future action is to include the former UST location in the overall site characterization, evaluation, & risk assessment of the Indian Booster Pump Station site & consider the existing UST data in selecting final corrective action alternatives for the site. Existing down-gradient wells at the site will be used to monitor groundwater near the former UST location.
See site file for additional information. |
Scott Pexton |
7/7/1997 |
Meeting or Teleconference Held |
Meeting held to discuss interpretation of laboratory data. |
Scott Pexton |
8/17/1997 |
Update or Other Action |
Risk Assessment workplan approved with understanding that the clarifications of 1a, 1b, 1c, 7f, 8, 9a, 9b, 9c, 9d, 9h, 10a, 10b, 10d, 12, 13a, 13b, 14d, 15, 19a, 20b, 22, 23, 25, 27, 28, 33a, 33b, 35, 38a, 38c, 38d and 39a will be made and reported in draft risk assessment report. Submittal of the human health and ecological risk assessment is anticipated on October 30, 1997. |
Scott Pexton |
8/18/1997 |
Document, Report, or Work plan Review - other |
ADEC sent comments on the risk assessment work plan to DFSC Randy Banez. The department and your consultant do not appear to be in agreement on several issues. The following comments are intended to clarify ADEC's position on several of your consultant's responses to the ADEC comments.
1. In addition to land uses such as hiking, camping, and hunting, ADEC considers sport fishing
in Indian Creek to be another land use in the site vicinity. The risk assessment report must
evaluate potential risks to humans that may ingest fish from Indian Creek.
2. Additional information was presented at the August 6 meeting indicating that precipitation
at the site may be less than 40 inches per year. This information will be presented in the
draft-risk assessment report.
3. Known and suspected hot spots, such as areas nearMW-17, MW-22, MW-24, MW-26, MW-33, and the former Manhole #1 excavation area will be further evaluated in the risk assessment report. Cleanup objectives will include consideration of methods to minimize risks associated with future potential exposures to soil or groundwater that exceeds appropriate site-specific risk-based cleanup levels.
4. For the purpose of risk assessment, ADEC does not consider reported concentrations of DRO
(or other compounds) that are within an order of magnitude in concentration to be equivalent.
5. For calculations of the 95% UCLs, the risk assessment report should evaluate what effect a
lognormal distribution assumption would have on the calculations.
6. The risk assessment report should include a table that lists all analytes evaluated for each
media, the laboratory analysis employed, each compound specific practical quantitation limit
(PQL) obtained, and the screening values for each compound. This table should include PQLs actually achieved by the laboratory, not the PQL levels predicted in the site characterization work plan.
7. Data results associated with the UST investigation and the PCB Characterization will be
summarized and further evaluated in the risk assessment report.
8. The risk assessment report will include an evaluation of ingestion and dermal contact with
groundwater by workers and recreationists. However, the evaluation will use the more
conservative groundwater ingestion and dermal contact parameters used for a residential scenario. In other words, the same risk-based levels calculated for ingestion or dermal contact with groundwater in a residential scenario will be applied to evaluate risk to receptors in a worker Qr recreationist scenario.
9. An evaluation of the probability that a hot spot exists will be included in the draft-risk
assessment report.
10. While future site drinking water wells may be located up gradient of the source areas,
currently no restrictions exist to discourage a land manager from locating a future drinking
water well close to known or suspected source areas. This is clearly indicated as a primary
pathway in the approved human-health conceptual site model. The risk assessment must
evaluate risk to future on-site receptors if a drinking water well is located near impacted
areas, such as known areas with past free-phase product detections.
11. ADEC agrees that the 1996 data collection effort was designed to augment the existing data
set, not reproduce it. However, ignoring prior existing soil data sets introduces a low bias
into the resulting risk calCulations for the site.
12. During the risk management decision process, the department will further evaluate soil data
available from the Manhole #1 excavation and other data from hot spot areas (particularly
near areas with past free-phase product) to clean the site to appropriate site-specific cleanup
levels.
13. ADEC contends that there is enough sediment in Indian Creek to gather samples to further
evaluate this pathway, if necessary. Therefore lack of sediment in the creek is not an adequate reason to eliminate the pathway from consideration in the risk assessment. The approved Human Health Conceptual Site Model (CSM) and the Ecological CSM both identify fresh water sediment as completed pathways to aquatic and human receptors.
14. Several of the petroleum compounds detected at the site are known to bioaccumulate.
Polycyclic Aromatic Hydrocarbons (PAHs) can be accumulated in aquatic organisms from water, sediments, and food (see August 1995 ATSDR Toxicological Profile for PARs).
Bioconcentration factors for several species of aquatic ·organisms are listed in Table 5-2 of
the ATSDR Toxicological Profile. This information must be further evaluated to detennine
if additional ecological compounds of concern exist and to estimate risk to aquatic receptors
from exposure to site-related compounds that bioaccumulate in water or sediment.
15. ADEC contends that a monitoring well which has been exposed to free product can still be
monitored to reliably reflect the water quality of the aquifer. |
Scott Pexton |
9/18/1997 |
Meeting or Teleconference Held |
Stakeholder meeting held at Potter Section House. |
Scott Pexton |
9/23/1997 |
Update or Other Action |
PCB Characterization Report received.
The analytical results for soil samples show detectable concentrations of specific analytes in six of nine samples. DRO was detected in 5 of 9 samples ranging from 4.4 to 26. 8 mg/kg. GRO & xylenes were detected in 2 of 9 samples ranging from 0.909 to 2.07 mg/kg for GRO & 0.0287 to 0.017 mg/kg for xylenes. The PCB Aroclor 1254 was detected in a single sample at 0.142 mg/kg. The sample containing the PCB detection also reported the maximum GRO, DRO, & xylene detections. Benzene & ethylbenzene were not detected, & toluene was reported in a single sample. The soil concentration results for fuel components are generally lower than the results from soil samples obtained from within the excavated pit in April 1997. All maximum detected analytes in soil from this investigation are at lower levels than those detected in the approximately 40 cubic yards of soil excavated from the former UST location in April 1997.
The analytical results for the groundwater sample from MW-PH indicate the presence of detectable levels of ORO (4.46 mg/l), GRO (0.30 mg/l), benzene (0.00171 mg/I), ethylbenzene (0.00206 mg/l), & xylenes (0.00502 mg/l total).
Arochlor 1254 is virtually insoluble & immobile. Transport of this compound is not expected under current & anticipated future site conditions. All soil analyte detections from this investigation appear to be lower than the human health risk-based screening levels. The results of this investigation will be incorporated into the risk assessment for further evaluation.
The soil analytical results did not indicate regulated concentrations of detected compounds therefore, the borehole soil cuttings were spread on the ground surface at the investigation area.
Approximately 10 gallons (total) of purge water & decontamination water generated from this investigation has been stored in the on-site groundwater treatment plant for treatment at a later date.
See site file for additional information. |
Scott Pexton |
11/20/1997 |
Meeting or Teleconference Held |
Stakeholder meeting held at Potter Section House. |
Scott Pexton |
12/26/1997 |
Document, Report, or Work plan Review - other |
ADEC Review letter sent to John Esada (DFSC) re: Department review of October 30, 1997 Risk Assessment Report Indian Booster Station Fuel Spill. A meeting with stakeholders was held November 20 at the Chugach State Park Potter Section House to discuss the report and to clarify some of the information presented. ADEC has completed review of the risk assessment report and provides specific comments on the report below. Comments from the ADEC's term contractor, Ecology and Environment, are identified with bold highlighting.
Stakeholder comments from the Indian Citizens Task Force and the Alaska Department of Natural Resources (ADNR) were received by ADEC and are included below. ADEC requests the Defense Fuels Supply Center (DFSC) or their contractor provide written responses to all of the comments. Please provide written responses to the comments on or before February 15, 1997. A meeting with stakeholders to clarify any questions on the comments will be arranged and likely will occur during the last week of January 1998. After review and resolution of DFSC's responses to the submitted comments, please incorporate the comments and corresponding responses into the Risk Assessment Report as an addendum to the report.
After comments are resolved, ADEC will issue a decision document regarding proposed site-specific alternative Cleanup levels for contaminated soil and groundwater at the IrIdian Booster Station Pumphouse site. After the alternative cleanup levels are established, the DFSC must submit for department review a site cleanup work plan to implement the cleanup levels for the site.
Page ES-2 Executive Summary
The last sentence of the second paragraph states that no adverse impact would be expected from use of water from wells not previously impacted by free product. What about on-site wells with dissolved product that exceed the proposed 1.46 mg/L alternative cleanup level for DRO in groundwater? ADEC considers any well that exceeds the site-specific cleanup standard to be adversely impacted.
Page ES-2 Executive Summary
The last sentence of the fourth Pagraph says that it is expected that the contaminant flux will decrease over time and the extent and degree of groundwater contamination will decrease as well. Is the DFSC proposing that natural attenuation will be the cleanup strategy for the contaminated soil and groundwater? If so, what is the natural attenuation rate? How many years are estimated until all of the contaminated groundwater (including monitoring wells MW-17, MW-22, MW-22D, MW-26, and MW-38) meets the proposed groundwater cleanup standard of 1.46 mg/L?
Page ES-3 Executive Summary
The proposal for alternative points of compliance and for institutional controls will be further discussed as one risk management strategy in the overall final cleanup plan. However, ADEC requires that a cleanup action work plan be submitted for department approval. Alternative points of compliance should be within the existing groundwater contamination plume and should not exceed the property boundary, unless the responsible party proves to the department's satisfaction that attainment is technically impractical and the responsible party provides an alternative source of water for the affected persons.
Page 4-1 Potentially Complete Pathways
ADEC agrees that the ingestion, inhalation, and dermal contact pathways for surface soils did not exceed screening levels and therefore need not be carried forward in the risk assessment. However, hot spots of subsurface soil contain DRO contamination that do exceed screening levels the inhalation pathway and the ingestion pathway. The release mechanism for these areas is excavation/redistribution. Each hot spot should be further evaluated to determine whether future park activities (such as installation of water lines, septic systems, utility trenches, buildings, or other park related facilities) could occur at or near the hot spots.
Page 4-4 Exposure Point Concentrations
a) Exposures to groundwater should generally be evaluated on a well-by-well basis. Averaging results across several wells implies that a resident (or worker) has several wells and selects each one for use with equal frequency; this in unlikely. Rather, a person is likely to use only one well for all uses at a household.
b) Use of the geometric mean for calculation of exposure point concentrations is generally inappropriate; in fact, Calculating the Concentration Term (EPA 1992) specifically states not to use the geometric mean, because it can underestimate exposure.
c) What are the exposure point concentrations at each of the following monitoring wells: MW-2, MW-4, MW-5, MW-17, MW-21, MW-22, MW-24, MW-26, MW-28, MW-30, MW-38, MW-2D, MW-5D, MW-22D, MW-33DR, Mw-34DR, and MW-35D?
For additional information see site file.
|
Scott Pexton |
7/31/1998 |
Update or Other Action |
Risk Assessment Report received. An evaluation of the CSMs was completed to assess the viability of each of the potential contaminant transport pathways. The evaluation results indicated human exposure to residual soil & GW contamination by ingestion, direct contact, & inhalation are viable pathways. Surface soil contamination is the only viable exposure pathway to relevant ecological receptors: terrestrial birds (spruce grouse), terrestrial mammals (snowshoe hare), & terrestrial plants.
Maximum levels of the contaminants of potential concern from the site characterization were compared against human health & ecological risk-based screening criteria to which chemical compounds or mixtures must be evaluated in the risk characterization. The HH screening levels were calculated for the ingestion & inhalation pathways assuming a 1x10-5 cancer risk & a HQ of 1.0, with the exception of carcinogenic PAHs, which assume a cancer risk of lx10-6. DRO in GW was the only contaminant that exceeded the human health screening level. Benzene, GRO, & DRO exceeded the ADEC screening level for drinking water protection. Ecological screening levels were based on conservative indicator species toxicological benchmark values. DRO in surface soil exceeded the spruce grouse & snowshoe hare screening levels.
The HHRA contains an exposure & toxicity assessment for DRO in GW. The potentially exposed populations were adult & child residents (off-site & onsite), on-site workers, & recreational visitors to the site. EPCs were developed from the calculation of the 95% UCL of the GW characterization data set. A binodal distribution of DRO in shallow GW data indicates reasonable maximum exposures are greatly reduced by using data from monitoring wells not previously impacted by free product. The HH risk characterization shows there are no potential hazards to carcinogenic effects posed by residual site contamination. The results of noncarcinogenic effect risk quantification show the hypothetical future on-site resident (adult & child) is threatened by GW ingestion if taken from a location nearby the monitoring wells fouled by free product in the past. No adverse impact to human health would be expected from use of water if taken from areas where GW is consistently below the proposed cleanup level of 1.5 milligrams per liter (mg/L).
The ecological risk assessment includes a detailed evaluation of the effects of DRO in surface soil on the spruce grouse & the snowshoe hare. Since no studies have been conducted on the effects on these indicator species, studies of surrogate contaminants & species were referenced, such as the effects of weathered Exxon Valdez crude oil on mallards & ferrets.
No-Observed-Adverse-Effect-Levels were calculated based on site-specific conditions. Based on HQ calculations for the indicator species, no adverse risk is indicated due to residual petroleum on-site. A contaminant transport analysis showed that the contaminant flux causing the current DRO plume in GW is approximately 2.3 kilograms per day over the area of the site previously impacted by petroleum releases. In a worst case scenario, future DRO in GW would remain at current levels & the plume would be maintained at the same size if there is no flux reduction. It is expected that the contaminant flux will decrease over time, & the extent & degree of GW contamination will decrease as well.
See site file for additional information. |
Louis Howard |
11/16/1998 |
Risk Assessment Report Approved |
CS Program Scott Pexton sent letter to Lt. Colonel John Esada DEO-Alaska re ADEC Approval of 1998 Final Risk Assessment Report spill# 93-21-01-215-01. A review was conducted and ADEC concurs with much of the characterization of risk provided in the document. The report presents data to demonstrate that contaminated groundwater at the site if ingested, poses an unacceptable risk to human health and therefore requires cleanup actions to mitigate the risk. Section 6 of the report deals with site specific alternative cleanup levels and risk management issues. The Department does NOT approve this section of the report. The Department will continue to evaluate risk management strategies after submittal of a draft site cleanup work plan.
Text in this section recommends ADEC waive application of the soil cleanup standards designed to be protective of the migration to groundwater pathway. ADEC does NOT concur with this recommendation. Based on the information provided in the report, the Department concludes that soil cleanup standards, protective of the soil to groundwater migration pathway, are warranted and will be applied at the site.
Leaching of contaminants from subsurface soils to groundwater is a viable and likely release mechanism. A potential exists through ingestion of contaminated groundwater caused by the movement of contaminants through soil to groundwater. Therefore, the migration to groundwater pathway is applicable for the establishment of soil cleanup standards at the site.
The Department will require confirmation sample collection during the cleanup operation to verify attainment of applicable soil standards at different areas of the site. DRO (AK 102) analysis will be done for many of the confirmation samples at the site and BTEX/PAH will be required for some confirmation samples.
The Department does not currently endorse any analytical methods for analysis for either the aromatic fraction or aliphatic fraction of the DRO hydrocarbon range. Groundwater cleanup standard at the site will be 1.5 mg/L DRO using AK102 lab analysis method. Table C of the proposed 18 AAC 75 regulations will apply to groundwater.
Also groundwater that is closely hydraulically connected to nearby surface water must meet the Water Quality Standards in 18 AAC 70. TAH and TAqH (10 ug/L and 15 ug/L respectively) will be the cleanup standards utilizing EPA 602 and EPA 610 analytical methods. By December 31, 1998 please submit a draft site cleanup work plan to Scott Pexton at the Anchorage Office for review and comment.
ADEC approval excludes Section 6 of the report which requested a waiver of application of the migration to groundwater pathway in the development of alternative soil cleanup levels.
A risk assessment report was prepared to characterize the risks posed by fuel contamination to human health and the environment. DRO exceeded risk-based screening levels and was retained for inclusion in the human health and ecological risk characterizations. The risk assessment indicated that the site does not exceed the cumulative carcinogenic risk threshold (1 x 10-5). However, at several monitoring wells, the estimated hazard index exceeded the cumulative noncarcinogenic threshold for the groundwater ingestion pathway. (Hazard Index > 1.0)
Ecological Risk Assessment Summary: In the ecological risk assessment, terrestrial and aquatic habitats with associated receptors were evaluated for potential impact due to remaining contamination. The potential exposure of the spruce grouse, snowshoe hare, American dipper, coho (silver) salmon, and dolly varden to site contaminants was evaluated. Based on the site conditions, potential of exposure to contaminants by ecological receptors was considered to be relatively small. The majority of the impacted soil at the site is at depth, and contaminated groundwater would be significantly diluted prior to mixing with surface water.
Human Health Risk Assessment Summary: The human health risk assessment showed that the groundwater contamination in the shallow and deep groundwater zones exceeded DEC cleanup levels for DRO, chiefly by the ingestion exposure pathway. For humans, complete pathways occur for the ingestion, inhalation, or dermal contact pathways if future park activities disturb the smear zone such that contaminated soil is redistributed to the surface. The smear zone is located within subsurface soil, approximately 10 to 20 feet beneath the ground surface, between high and low groundwater levels where contamination tends to stick or smear to soil. |
Scott Pexton |
11/25/1998 |
Update or Other Action |
Ron Klein sent a Clarification letter re: final risk assessment report approval spill#93-21-01-215-01. The Department approves sections 1.0 through 5.4 of the 1998 Final Risk Assessment Report for the Indian Booster site. Please note that Section 6 of the report is NOT approved as it deals with site-specific alternative cleanup levels and risk management issues. The Department will work with DFSC on a collaborative basis to develop a final action plan for the site. |
Ron Klein |
1/28/1999 |
Update or Other Action |
Keven Kleweno DEH DW & WW Program sent letter to Eric Goller Dames and Moore re: Class B Public Water System. Based on the final risk assessment report, it appears contamination above 50 mg/L diesel range organics (DRO) could be found within one-hundred twenty (120) feet of the existing Class B Public Water System Source Well. The State Drinking Water Regulations require a minimum of two-hundred (200) feet between a Class B Public Water System Source Well and other potential sources of contamination.
A review of the information provided to the Department by Dames & Moore has determined that the lesser separation distance is reasonable due to the following conditions:
1) The contamination has been found only in the upper aquifer.
2) The well yield test results indicate the lower aquifer that the existing source well is finished in, does not appear to contact the upper aquifer where the contamination is found.
3) There will be long term monitoring of the site, including the source well, to ensure that water being provided to the public is not contaminated.
Therefore, in accordance with the provisions of 18 AAC 80.030, the following separation distance is granted: Between existing Class B Public Water System Source Well and the 50 mg/L DRO contour of the contamination plume, from 200 feet to 120 feet.
This waiver will remain valid AS LONG AS THE FOLLOWING REQUIREMENTS ARE MET:
1) If the existing Class B Source Well becomes contaminated, the U.S. Defense Energy Support Center (Responsible Party) will provide another source acceptable to both the Department of Natural Resources and this Department (of Environmental Conservation).
2) Water quality will be monitored from the existing Class B Source Well by the U.S. DOD, Defense Energy Support Center Anchorage, as follows
a) Quarterly monitoring for two consecutive years (til 2001 estimated) followed by a Department review to determine future sampling frequency and laboratory analysis requirements.
b) One (1) round of sampling and analysis will be performed prior to operation startup.
c) A flexible schedule will be established, once final use of the source well is determined, that ensures one week prior notification to ADEC (Contaminated Sites & Drinking Water staff) and ADNR (Chugach State Park). Rapid turn around analysis time frames for the first one (1) or two (2) sampling rounds (whenever system is in actual use) will be required.
d) Immediate notification to ADEC and ADNR via telephone, fax, email and/or in person of any sheen or free product detected during water sampling.
e) Upon receipt of analytical results, immediate notification to ADEC and ADNR via telephone, fax, email, and/or in person of any detectable levels of compounds from the laboratory analytical methods listed: VOCs EPA method 502.2 or 524.2, PCBs EPA Method 608, GRO AK Method 101, DRO AK Method 102, PAHs EPA Method 610 or 8270C.
f) Upon written request by the Chugach State Park Superintendent, collect and analyze water samples for: Flavor-Method 2160B (S.M. for the Examination of Water & Wastewater) and Odor Method 2150B (S.M. for the Examination of Water & Wastewater).
The public water system identification (PWSID) assigned to this public water system is 218593. Under State Drinking Water Regulations, DFSC is required to sample this public water system for total coliform bacteria once each quarter and nitrates (as nitrogen) once a year. |
Kevin Kleweno |
2/26/1999 |
Document, Report, or Work plan Review - other |
ADNR Div. of Parks & Outdoor Recreation Chugach State Park Al Meiners Park Superintendant Subject: Comments on the Draft Indian Site Mgt. Plan
Overall. I am comfortable with the Draft Site Management Plan prepared for the Indian Spill Site and believe that it is ready for public review. Our meeting on February lSt'h identified a numper of items that will make the plan better. My specific comment follow:
Soil Cleanup Level: On th~ matter of the appropriate soil cleanup level. I defer to you and Mary Mauer to determine what the appropriate level should be.
Institutional Controls. Our agency is tentatively prepared to accept the proposed institutional controls use of the site. for the purposes of the draft plan and its review by the public. These controls would include a prohibition on developing water wells or digging below lO feet underground within the boundaries of the groundwater development control area.
The replacement domestic water well and the terms of its testing are also acceptable to us. I recently spoke with Leroy Latta at the AG's Office. He is drafting an MOU between DEC and Parks which can be included in the site management plan to be reviewed by the public.
Natural Attenuation: As you know. the geology and hydrology of this site are complex. Further the rate of attenuation of the remaining contaminants is uncertain. As the manager of a public park. we are willing to wait the 20 to 30 years to obtain the desired level of clean up as long as the contamination does not spread.
I believe that the proposed monitoring well system provides an adequate means of detecting the potential migration of contaminants. The 5 year review of the attenuation rate is a good idea and should be repeated at 5 year intervals until the desired clean up level is obtained .
Residential well monitoring.
We support the plan expressed at our meeting to stop residential well monitoring and replace it with a new monitoring well up gradient of the residents. We are prepared to authorize the
installation of this new well on park land.
Unused Monitoring Wells.
While I understand the desire of some persons to retain these wells for future moni toring needs. I share DESC' s concern about them becoming a conduit for groundwater contaznination by vandals. Our agency is unwilling to take responsibility for any contamination that may occur in this manner.
Graphics. I believe that the plan would benefit from an additional drawing that illustrate the projected attenuation rates. As drawing of this types As drawing of this types is found in the risk assessment as figure 12. |
Scott Pexton |
3/8/1999 |
Document, Report, or Work plan Review - other |
ADEC reviewed & commented on the draft Site Management Plan - Stakeholder Review Draft.
The Alaska Department of Environmental Conservation (ADEC), Contaminated Sites Remediation Program has completed a review of a draft Site Management Plan, dated February 1, 1999 that proposes soil & groundwater cleanup levels, alternative points of compliance, a monitored natural attenuation remediation strategy to attain cleanup levels. ADEC provides the following comments on the plan. ADEC plans to meet with you & your consultants, as needed, to revise the draft plan to address all stakeholder-review comments.
Pages 1-2 Introduction
- First Paragraph. Revise the sentence in the first paragraph. ADEC has agreed to consider (NOT implement) a natural attenuation remedy combined with restrictions to groundwater use & soil excavation for portions of the site. ADEC has requested that the DESC evaluate & present other viable alternative remedies for consideration.
- Second Paragraph. This plan is not presented in a manner that is analogous to a "Proposed Plan" as used at CERCLA/SARA sites. A typical proposed plan briefly summarizes the cleanup remedies considered for a particular site & then provides supporting rationale for the selection of one preferred alternative. Public input is solicited on the preferred alternative & a decision is made after consideration of public comments. This draft plan does not present or evaluate alternative remedies for this site.
- Update the DESC agency personnel responsible for implementation of a cleanup remedy at the site.
- Please refer to the 18 AAC 75 regulations as amended through January 22, 1999, rather than referring to them as filed on December 22, 1998.
- The proposed alternative soil cleanup level of 8,000 mg/kg is NOT acceptable to ADEC because it is NOT in accordance with 18 AAC 75.
Page 4 Site Description
For clarity, please revise the last sentence in this section regarding continued active remedial actions on a continuous basis. The diminished product recovery & completion of the Manhole -1 excavation supported a decision -to turn off the groundwater pump & treat system.
Page 8 Risk Assessment
Based on the estimated transport analysis modeled leaching of 2.3 kilograms per day, please provide an estimated rate of petroleum loss from the smear zone to the aquifer, in gallons per year. Delete the rate calculation (in parentheses) of 10 milligrams per square foot per day.
Page 8 Groundwater Cleanup Levels
Add text to state that the DESC will ensure compliance with all monitoring requirements of Public Water System Identification number 218593 (particularly the waiver requirements identified in the January 28, 1999 letter addressed to Eric Goller of Dames & Moore from the ADEC Division of Environmental Health).
All new wells added to the interior network will be sampled & the groundwater analyzed at least once for BTEX & PAHs. ADEC will determine if further monitoring will be required for these compounds on a well by well basis.
Page 9 Groundwater Alternative Points of Compliance
ADEC requests two more new wells be installed within the interior network. A new deep well will be located near the southern boundary of the groundwater control area near Trench 4. A new shallow well will be installed between the decommissioned treatment plant building & the former south valve of the pipeline.
Also, add existing wells MW-21 & MW-28D to the interior network & MW-24 & MW-33 to the free product network. As we find no record of free product reported at monitoring well MW -PH, this well will be removed from the free product network & added to the interior network. The new well currently proposed near MW-PH will be moved further down-slope in between MW-PH & MW-22.
There are three general categories of wells to be monitored in the future: free-product wells, alternative points of compliance wells, & sentry wells.
Free-product wells
Free-product wells are wells located within the groundwater development control boundaries & have had accumulations of free product (LNAPL) in the past. They will be monitored to determine if free-product is present in the well, by use of the indicator paste method. These wells will not be regularly monitored for dissolved petroleum compounds in groundwater.
The following wells will be monitored for free product:
MW-17
MW-22
MW-24
MW-26
MW-28
MW-33
Alternative points of compliance wells
Alternative points of compliance wells are wells where groundwater cleanup levels must be attained in accordance with 18 AAC 345 (e). These wells will consist of three networks, an interior, a perimeter, & a creek protection network. The interior network includes wells located within the groundwater use restriction area. Perimeter network wells are located outside of the restricted groundwater use area.
For additional information see site file.
|
Scott Pexton |
5/14/1999 |
Update or Other Action |
Analytical results from April 1999 Quarterly Monitoring effort received.
Samples were collected from the Perimeter Monitoring Network (PMN) between April 13-15, 1999.
Also included are groundwater samples collected from six additional monitoring wells (MW-2, -2D, -22D, -25, -27, and -27D), as directed by ADEC.
All samples were tested for Diesel Range Organics (ORO) by AK102 Method. The Method Detection
Limit (MDL) for these analyses, performed by CT&E Environmental Services (CT&E), was 0.033
mg/L as determined by CT &E's MDL study dated January 7, 1999. The attached figure (Figure 1)
shows the recent results in a plan view of the site, and Table 1 provides the recent results in summary format. Table 2 contains the results of the Perimeter Monitoring Network samples collected between November 1995 and the most recent sampling event. The results from MW-17 (119 mg/L), MW-19 (1.11 mg/L) , MW-22D (1.16 mg/L), MW-26 (510 mg/L), MW-27D (1.09 mg/L), and MW-28 (8.51 mg/L) exceeded the Practical Quantitation Limit (1.0 mg/L) for the DRO analyses. The results of samples from the remaining wells were all non-detections.
All of the samples conformed to the quality assurance and quality control requirements of the ADEC certified laboratory with the exception of MW-26, which failed the control requirements (high surrogate recovery) based on matrix interference. Also note, that the duplicate sample from MW-27D was "non-detect." The result from MW-19 caused the well to be re-sampled in accordance with the Site Monitoring Plan. A sample and duplicate were collected from MW-19 on April 29, 1999 for a "rush" groundwater DRO analysis. The MW-19 resample DRO result was "non-detect" for both the sample and the duplicate.
DRO Results
MW-28 8.51 mg/L Up from Jan. 1999 4.62 mg/L
MW-26 510 mg/L Up from Jan. 1999 277 mg/L
MW-17 119 mg/L Up from Jan. 1999 69.1 mg/L
|
Louis Howard |
6/1/1999 |
CERCLA Proposed Plan |
Proposed Plan Approved this date.
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 DFSC's cleanup program follows CERCLA guidance, although Indian Booster Pump Station is not a Superfund site. The DoD is delegated authority & responsibility to carry out response actions, including cleanup, 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.
Based on the information generated from the site characterization, risk assessment, comparative analysis of alternatives, and the interim cleanup actions completed to date, the preferred alternative, as the cleanup remedy for the Site is Alternative 2.
The Proposed Cleanup Remedy includes monitored natural attenuation, the excavation of approximately 1,000 cubic yards of soil near monitoring well MW-26 and recontouring and revegetation of the excavated area. It also includes placement of two additional monitoring wells, one between monitoring well MW-22 and the pumphouse, and one between monitoring well MW-22 and the former south pipeline valve.
The proposed cleanup remedy includes limited institutional controls on the Site property to formally restrict access to groundwater and limit the Park’s ability to excavate soil in certain areas. Additional wells will be installed and long-term groundwater monitoring will be conducted to ensure that contaminants do not migrate beyond the points of compliance, and to determine when cleanup levels are reached. The proposed cleanup levels for soil and groundwater contained in Table 2 are consistent with the expected future use of the site by the Chugach State Park.
As the manager of the land on which the spill occurred in Chugach State Park, the Alaska Department of Natural Resources (ADNR) is participating in the public review of this plan. ADNR may enter into an agreement with ADEC to restrict ADNR’s use of land near the spill area. ADNR plans to issue a Special Park Use Permit to the Department of Defense for future activities at the site after a decision is made regarding the proposed plan. ADNR intends to gather public input for both the draft agreement and the park use permit during the public review process of this proposed plan. ADEC and ADNR have been involved throughout the site investigation, and support the proposed cleanup alternative.
The comment period runs from June 7, 1999 to July 6, 1999. Written comments must be postmarked by close of business on July 6, 1999. If you wish to comment or have questions, please contact Scott Pexton at (907) 269-7550. |
Scott Pexton |
6/16/1999 |
Meeting or Teleconference Held |
Public informational meeting regarding proposed plan held at Z.J. Loussac Library in Anchorage. Two informational meetings are scheduled to discuss this Proposed Plan and to answer questions. ADEC, ADNR, and DESC representatives will be present at the Loussac Library in Anchorage at 7:00 p.m. on June 16, 1999 and at the Valley Bible Chapel in Indian at 7:30 p.m. on June 17, 1999. The informational meetings also will provide an opportunity for interested parties to submit written or verbal comments on the Proposed Plan. |
Scott Pexton |
6/17/1999 |
Meeting or Teleconference Held |
Public informational meeting regarding proposed plan held at the Valley Bible Chalet in Indian. Two informational meetings are scheduled to discuss this Proposed Plan and to answer questions. ADEC, ADNR, and DESC representatives will be present at the Loussac Library in Anchorage at 7:00 p.m. on June 16, 1999 and at the Valley Bible Chapel in Indian at 7:30 p.m. on June 17, 1999. The informational meetings also will provide an opportunity for interested parties to submit written or verbal comments on the Proposed Plan. |
Scott Pexton |
7/15/1999 |
Update or Other Action |
In response to 7/27/1995 $2,000,000 (two-million dollar) natural resources damage claim from AK DNR to DFSC a settlement was reached. Stipulation for Compromise Settlement and Release of Claim of the State of Alaska, Department of Natural Resources filed by Alan H. Meiners, Superintendent, Chugach State Park, arising from damages to real property as a result of pipeline discharge of JP-8 fuel on August 2, and August 3, 1993, within Chugach State Park, at the Indian Valley Pump Station on the Whittier to Anchorage, Alaska pipeline.
The United States of America agrees to prepare an instrument transferring all right, title, and interest in the real property improvements and personal property described in Exhibits A and B to this agreement, to claimant, the State of Alaska, Dept. of Natural Resources (hereinafter referred to as the "claimant").
Structures to be transferred1) Pumphouse (decommissioned) 3,069 square feet.
2) Shed 100 square feet.
3) Groundwater Treatment Plant 4,800 square feet. (decommissioned)
Onsite utilities and infrastructures to be transferred
1) Class B Public Water Supply Well (water well) 500 KG (thousand gallons per day capacity)
2) Onsite wastewater disposal system (GTP septic tank and leachfield) 500 KG
3) metered electricity to the pumphouse and GTP
4) onsite roads and parking area
5) swing gate-chain link fencing and swing gate 2,500 lineal feet
6) GTP and pumphouse chainlink fence
Equipment and materials to be transferred
1) numerous storage tanks
liquid storage tank 5,000 gallons two water storage tanks 500 KG each, overhead electric line 200 lineal feet, fire alarm system 200 lineal feet
2) pumps, valves, hoses, fencing and miscellaneous equipment and materials stored in the pumphouse
Offsite improvements
1) Indian Creek trailhead parking lot improvement Road-unsurfaced 32, 835 square yards parking lot unsurfaced 800 square yards.
2) trail improvement
3) 1998 Oceanview Road washout repair and materials
1999 Off-site road repair
1) Road repair in 1999 to correct degradation caused by heavy vehicle traffic meeting onsite operation requirements.
|
Ron Klein |
7/26/1999 |
Update or Other Action |
Monitoring Wells-1999 Work Plan received. In accordance with Section 3.0 "Groundwater Monitoring" and Section 5.2 "Decommission Unneeded Monitoring Wells" of the "Site Management Plan", dated June 3, 1999, this Work Plan has been prepared to address the following tasks.
• Groundwater analysis.
• Decommission of selected monitoring wells.
• Installation of new monitoring wells.
• Sample compliance monitoring wells.
• Completion report.
Upon completion of this Work Plan, and subsequent site work, a long-term groundwater monitoring
plan will be incorporated in the Site Operations Plan, which will be submitted to the Alaska
Department of Environmental Conservation (AOEC) in mid-September.
Groundwater from all 40 existing on-site monitoring wells (MW-l, 2, 20,3,4,5,50,6,7,8,9, 10,
11,13,16,17, 19,20,21,22,220,23,24,25,26,27,270,28,280,30,31, 32, 33, 33DR, 34, 34DR, 350, 37, 38, and 39) and 3 Indian Creek gauge stations (CG-3, 4, and 5) shown on Figure 1, will be sampled and analyzed for diesel range organics (ORO). Samples will be collected and analyzed in general accordance with ADEC's "Guidance for Treatment of Petroleum-Contaminated Soil and Water and Standard Sampling Procedures", dated March 1, 1999.
In addition to the ORO analysis, all new monitoring wells added to the interior network (MW-43,
44,45,46,47, and 480) and sentry well (MW-49D) will be sampled at least for Benzene, Toluene,
Ethylbenzene, and Xylene (BTEX), and for Polycyclic Aromatic Hydrocarbons (PAHs). ADEC will
determine if further monitoring will be required for these compounds on a well-by-well basis.
Prior to sampling the monitoring wells, the groundwater depth will be measured to the nearest 0.01 foot using a water level indicator to calculate the water volume in each well.
A total of eight new monitoring wells (MW-42, 43, 44, 45, 46, 47, 48D, and 49D) will be installed to support the groundwater compliance monitoring program. The locations of the new wells (except MW-49D) are shown on Figure 2. The new sentry well, MW-49D, will be located near the Chugach State Park - Heritage Land Bank (HLB) property boundary near Oceanview Road (Figure 3). The exact placement of the wells will be reviewed with ADEC during an initial site visit.
During drilling, soil samples will be collected within 2 feet of ground surface and every 5 feet
thereafter until the groundwater interface is encountered, where the last soil sample will be collected. The soil samples will be collected using a split-spoon sampler. The sampler will be driven 18-inches (or until refusal) with a 30-inch drop of a 340-pound hammer. Hammer blow counts will be recorded every 6-inches over the I8-inch interval. A soil sample will be collected and placed in the appropriate teflon-capped jars in accordance with ADEC sample collection requirements.
The samples will be labeled, placed in a cooler containing blue ice, and transported to an ADEC approved laboratory under standard chain-of-custody procedures. The soil samples will be analyzed for DRO and for Residual Range Organics (RRO). In addition, the soil samples collected at the groundwater interface from the new interior shallow monitoring wells (MW-43, 44, 45, 46, and 47) will also be analyzed for BTEX and PAHs. One duplicate sample per each 10 soil samples collected in a day (a minimum of one field duplicate soil sample per day) will be submitted for laboratory analyses. Table 2 indicates each chemical compound to be analyzed (including ORO, RRO, BTEX, and PAHs), laboratory method, PQL, and MDL.
Because of the type of drill rig, and the process used (air rotary), the deep monitoring wells will be installed without collecting environmental soil samples. |
Louis Howard |
7/27/1999 |
Update or Other Action |
Received Restoration Work Plan (dated July 27, 1999) prepared by Dames and Moore for DESC "Restoration Work Plan Indian Booster Station Fuel Spill D&M Job No. 09607-059-160". Plan describes plans to remove salvageable items and backfilling manholes and vaults associated with emergency response trenches, recontouring of topsoil, and revegetation of disturbed areas with local vegetation. |
Scott Pexton |
8/30/1999 |
Cleanup Level(s) Approved |
See Record of Decision. |
Scott Pexton |
8/30/1999 |
CERCLA ROD Approved |
Remedy selection includes limited excavation, additional characterization, and natural attenuation with groundwater monitoring. In soil, diesel range organic (DRO) hydrocarbons were identified as the primary contaminants of concern (COC) in subsurface soil. Due to limited sample collection and the uncertainty of actual chemical concentrations in the subsurface soil within the smear zone, benzene, toluene, ethylbenzene, xylenes, and polynuclear aromatic hydrocarbons (PAHs) are considered potential COC in subsurface soil.
In groundwater, DRO is the primary COC. Benzene is another COC that was reported in several monitoring wells sampled in 1993. Due to the uncertainty of dissolved chemical concentrations in the groundwater near wells previously impacted by free product, toluene, ethylbenzene, xylenes, and PAHs are considered potential COC in groundwater. NOTE to file: “free product” means a concentration of a hazardous substance that is present as a nonaqueous phase liquid; for purposes of this paragraph, a “nonaqueous phase liquid” is a liquid that is not dissolved in water.
The site characterization results indicated that DRO concentrations in the soil and groundwater exceed Method two Table B2 cleanup levels (18 AAC 75.341). The majority of fuel contamination is in subsurface soil within a “smear zone” located 10 to 20 feet below ground surface. The extent of the smear zone is bounded on the north and east sides by the pipeline and to the west and south by Collection Trenches 2, 5, 6, and 8 (Figure 2).
Leaching of the DRO in the smear zone impacts groundwater quality in the shallow and deep groundwater zones. The extent of contaminated shallow groundwater is graphically depicted on Figure 3. DRO was reported in a deep groundwater well onsite, which confirms a hydraulic connection between the shallow groundwater zone and the deep groundwater zone.
The soil and groundwater cleanup levels for the site are based on values listed in Table B1 and Table B2 of 18 AAC 75.341 (Summer 1999). Table 1 lists the following as COC (soil mg/kg/gw mg/L cleanup level respectively): DRO 250/1.5, benzene 0.02/0.005, ethylbenzene 5.5/0.7, toluene 5.4/1.0, xylenes(total) 78/10.0, acenaphthene 210/2.2, anthracene 4,300/11.0, benzo(a)anthracene 4,300/11.0, benzo(b)fluoranthene 20/0.001, benzo(k)fluoranthene 200/0.01, benzo(a)pyrene 3/0.0002, chrysene 620/0.1, dibenzo(a,h)anthracene 6/0.0001, fluorene 270/1.46, ideno(1,2,3-c,d)pyrene 54/0.001, naphthalene 43/1.46, pyrene 1,500/1.1.
Three types of alternative points of compliance (APOC) will be monitored for compliance with the groundwater cleanup levels. The APOC wells are listed in Table 2 below, and depicted in Figure 2. Type-1 monitoring wells are located on the down-gradient edge of the plume. NOTE to file: “plume” means a visible or measurable discharge or release of a hazardous substance from a given point of origin. Type-2 monitoring wells are located within the plume area. Type-3 monitoring wells are located between Indian Creek and the plume.
Type-1 POC are located at the perimeter of the site, down-gradient of the existing DRO contamination, on hydrologic flow paths between the source area of contamination and human receptors. Type-1 wells are expected to continue to meet cleanup levels, but will be monitored to verify that contaminant migration does not occur beyond the boundaries of the perimeter monitoring well network.
Type-2 POC are wells located within different parts of the existing groundwater contaminant plume. These wells will be monitored to evaluate the progress of natural attenuation processes, to confirm that the plume concentrations are stable or decreasing and to determine when cleanup levels are reached.
Type-3 POC are wells located down-gradient of the site between the source areas of contamination and Indian Creek. These wells will be monitored to confirm that groundwater will not cause a violation of the 18 AAC 70 surface water quality standards for Indian Creek. |
Scott Pexton |
9/3/1999 |
Institutional Control Record Established |
Memorandum of Agreement between the State of Alaska, Department of Natural Resources, Division of Parks and Outdoor Recreation (hereinafter, "Parks") and the State of Alaska Department of Environmental Conservation, Division of Spill Prevention and Response (hereinafter "DEC") to restrict access to groundwater within eleven (11) acres and limit access to subsurface soil below ten (10) feet below ground surface within 5.5 acres.
General provisions
1) This MOA shall automatically be terminated and be without further force or effect upon execution by DEC and Parks of a "Release of Memorandum of Agreement."
2) Nothing herein shall be deemed to create in any third party the right to enforce this MOA.
3) Nothing herein shall be deemed to limit the State's authority to bring an action against a third party under either State or federal law. Furthermore, this MOA does not limit in anyway the State's authority to require further cleanup actions by Defense Energy Support Center (DESC, formerly the DFSC) or any other responsible party should contamination be encountered.
Parks agrees:
1) The conditions and restrictions set forth herein remain in force until such time as DEC and Parks execute a Release of Memorandum of Agreement.
2) To notify DEC immediately of any observed environmental problems, such as sheen on surface water, odors, stressed vegetation, or stains, believed to be associated with the jet fuel discharge.
3) To not drill any groundwater well within the bounds of the Property unless specifically authorized in writing by DEC.
4) To not disturb the groundwater monitoring system unless specifically authorized in writing by DEC.
5) To not excavate or otherwise disturb the soil to a depth of greater than 4 feet below the ground surface without first notifying DEC's contaminated sites remediation program by telephone, fax, email or memorandum seven days before commencing the activity (Parks will notify DEC within 24 hrs. should Parks, its contractors, agents, employees, and authorized representatives, encounter any petroleum contaminated soil at any depth during excavation or other soil disturbance. In the case of an emergency requiring an immediate response, Parks, may immediately begin to employ necessary action provided Parks notifies DEC in writing within 24 hrs. of commencing work and that Parks takes necessary steps to reestablish the DEC-approved groundwater monitoring system should it be damaged.
6) To bear responsibility for any costs associated with removal or treatment of soil contamination if encountered at a depth greater than 10 feet below the ground surface during any excavation or soil disturbance activity caused or overseen by Parks, its contractors, agents, employees and authorized representatives.
7) To provide DEC, its contractors, agents, employees, and authorized representatives, with full and unhindered access to the Property.
8) To notify holders of any existing or future utility easements, permits, or rights of way across the Property of the restrictions placed on soil excavation or disturbance activities and on the use of groundwater as well as the need to protect the groundwater monitoring system.
9) To maintain posted copies of this MOA at the two buildings located on the Property (the former pump house and the former groundwater treatment plant).
10) To maintain any signs posted by the DESC (formerly DFSC) around the boundaries of the Groundwater Development Restriction Area or the Excavation Restriction Area.
11) To request in writing that the Department of Natural Resources, Land Records Information Section depict this MOA on the land, mineral, and water estates of all State land status plats that include section 32, Township 11 North, Range 1 West, Seward Meridian, Alaska. Signed Lynn Kent ADEC Manager Contaminated Sites Remediation Program August 30, 1999 and Jim Stratton Director September 3, 1999. |
Scott Pexton |
9/15/1999 |
Update or Other Action |
Work Plan for limited excavation near MW-26 received: "1999 Excavation Work Plan Indian Booster Station Fuel Spill D&M Job No. 09607-059-160".
As discussed in the Site Management Plan and the Proposed Planfor Cleanup (Alternative #2), we have prepared this Work Plan to perform a limited excavation in the vicinity of monitoring well (MW) number 26, located northwest of the north valve. The work is to be completed this fall (September), with recontouring and revegetation to occur in 1999 or the spring of 2000. The intent of the excavation is to remove contaminated soil in the area of MW-26.
The work will be similar to the work performed in 1994 between the north valve and manhole (MH) number 1. It is anticipated that approximately 1,000 cubic yards of material will be excavated and removed off-site for thennal remediation. The dimensions of the excavation and the actual amount of soil removed for treatment will depend on field screening results and the site conditions during the excavation activities. and removed off-site for thermal remediation.
Prior to beginning the excavation, MW -26 will be removed utilizing the excavator or the loader. In addition, ENST AR will be contacted and the excavation coordinated with their office. The actual excavation will begin by removing a two-foot lift utilizing either the dozer and loader, or the excavator. The soil will be placed in the dump truck and transported to an area located in front of the Pump House.
This area will be designated "clean fill". Prior to transport, all soil will be screened utilizing a photo ionization detector (PID). The (PID) will be calibrated on-site in accordance with the manufacturer's operating manual. Selected samples will be collected from the excavation and placed in jars for headspace screening. In addition, in-situ soils will be screened using the PID. It is anticipated that an ADEC representative will be on-site to help determine field screening sample locations and frequency and to assist with interpretation of results.
Once contaminated soil is encountered, the soil will be excavated to no more than two feet below the top of the groundwater surface. Obviously stained or contaminated soil will be placed into dump trucks for transport to an approved thermal treatment facility. Also during the excavation, a PID will be utilized to field screen the soil. PID readings, as well as locations, will be recorded for future reference. Some potentially contaminated soil may be stockpiled on a 1O-mil or greater thickness liner until laboratory results are available.
The lined area will be bermed to contain leachate. Contaminated soil will be loaded into dump trucks with pups for transport to an approved facility in Anchorage. Each truck will be visually inspected to look for soil, which may have fallen outside of the dump area. Any such soil will be cleaned off of the truck and either placed in the dump area or returned to the excavation for removal on the next dump truck.
The area in the vicinity of the dump trucks will be routinely scraped using the loader. Collected soil will then be loaded into one of the dump trucks. Each truck will be covered prior to transport, and will remain cover until unloading at the approved facility. Clean soil will be backhauled and stored on-site for future backfilling.
The excavated area will be field screened to determine which soil samples are submitted for laboratory analysis. Based on the highest field screening results, soil samples will be collected from the sidewalls, and the floor of the excavation and submitted for laboratory analysis. At least four samples will be collected from the walls and three samples collected from the bottom of the excavated area and analyzed for BTEX by Alaska Method AKIOI and ORO by Alaska Method AKI 02. Based on the highest field screening results, at least one excavation wall and one excavation bottom sample will be analyzed for P AH components using Method 8270C or 8310. |
Louis Howard |
9/20/1999 |
Cleanup Plan Approved |
Letter sent with approval of September 15, 1999 Excavation Work Plan regarding soil removal and thermal treatment of approximately 1,000 cubic yards of petroleum contaminated soil near monitoring well MW-26.
The 1999 Excavation Work Plan is approved with the following conditions:
1) the contractor will manage contaminated soil to minimize leachate spillage outside of excavated areas.
2) based on field screening results, the contractor will collect at least one (1) soil sample for DRO and BTEX analysis for each two-hundred fifty (250) square feet of excavation area. |
Scott Pexton |
10/8/1999 |
Update or Other Action |
CT&E Environmental Services laboratory results received. Non-detect PCB results however the PQL for all samples are above the Table C Cleanup level of 0.5 ug/L total PCBs. 1.04 ug/L, 0.990 ug/L, 1.10 ug/L, 1.05 ug/L, 1.00 ug/L, |
Louis Howard |
10/12/1999 |
Update or Other Action |
Dames & Moore sent letter to ADEC (Scott Pexton) on behalf of DESC. RE: Addendum 1999 Excavation Work Plan Indian Booster Station Fuel Spill D&M Job No. 09607-059-160.
Based on our recent discussions, and on behalf of the Defense Energy Support Center (DESC), we have prepared an Addendum to the "1999 Excavation Work Plan", dated September 15, 1999. This Addendum includes adding the area around monitoring well (MW) 22 to the Work Plan. The work in general will follow the same process as that used in 'conjunction with the excavation of the area around MW-26.
Because of the constraints of the Groundwater Treatment Plant, Enstar's pipeline, and Chugach Electric's substation, it is anticipated that only approximately 500 cubic yards of material can be excavated and removed off-site for thermal remediation. Pending approval of this Addendum, we are prepared to begin site work this week (removal offence and other obstructions), with the excavation beginning on Monday (October 25th). |
Louis Howard |
10/12/1999 |
Site Ranked Using the AHRM |
Site reranked based on September 1999 groundwater monitoring results and data from the updated site characterization report. |
Scott Pexton |
10/19/1999 |
Offsite Soil or Groundwater Disposal Approved |
ADEC Letter sent to Jack Appolloni of DESC with approval of addendum to work plan Indian Booster Pump Station, ADEC Database Record Key 93-2101-215-01.
The Alaska Department of Environmental Conservation (ADEC) Contaminated Sites Remediation Program has completed a review of the October 12 Addendum to the 1999 Excavation Work Plan. The addendum proposes the excavation and offsite thermal treatment of approximately 500 cubic yards of petroleum contaminated soil near monitoring well MW -22. The plan is to follow the same excavation and sampling procedure recently performed at monitoring well MW-26. On behalf of the ADEC Contaminated Sites Remediation Program, I approve the addendum to the Excavation Work Plan, subject to the following conditions:
- trucks or any associated heavy equipment will stop operation or movement along Ocean View Road at any time that a school bus is present.
- head-space field screening will be conducted to segregate potentially contaminated soil from
uncontaminated soil and the contractor will manage contaminated soil in a manner that minimizes leachate spillage outside of excavated areas;
- potentially contaminated soil will be stockpiled on a liner in accordance with 18 AAC 75 or
loaded directly into trucks for transport as a covered load to the Anchorage Soil Recycling
Facility. |
Scott Pexton |
10/21/1999 |
Update or Other Action |
CTE Environmental Services, Alaska Division, Laboratory Data Report, Project: 09607-059-160 Indian Booster, Client: Dames & Moore-Anch, CTE Work Order: 995461 received. PCB EPA SW846 8082 PQL for Aroclors was 1.00 ug/L, 1.05 ug/L, 1.10 ug/L, 0.990 ug/L, 1.04 ug/L, . TABLE C Groundwater cleanup level for total PCBs is 0.0005 mg/L or 0.5 ug/L. |
Louis Howard |
11/2/1999 |
Update or Other Action |
Monitoring Well 22 (MW-22) laboratory results received. CTE Environmental Services
Alaska Division, Laboratory Data Report, Project: 09607-059-160, Client: Dames & Moore-Anch
CTE Work Order: 995290. DRO, PCBs, PAHs, BTEX requested. Practical quantitation limit for benzo(a)pyrene was 0.500 (U) ug/L (EPA SW846-8310) Cleanup level (TABLE C) for benzo(a)pyrene is 0.0002 mg/L or 0.2 ug/L. Dibenzo(a,h)anthracene PQL (EPA SW846-8310) is 1.00 ug/L Cleanup level (Table C) for dibenzo(a,h)anthracene is 0.00012 mg/L or 0.12 ug/L.
DM-DESC-002-MW22 Results
Diesel range organics (GRO) 305 mg/L (PQL was 16.8 mg/L) exceeds the DRO Table C cleanup level is 1.5 mg/L. PCBs (Aroclor-1260) 3.44 ug/L (EPA SW846-8082) exceeds the Total PCBs Table C cleanup level is 0.0005 mg/L or 0.5 ug/L. |
Louis Howard |
11/25/1999 |
Update or Other Action |
MW-22 Excavation laboratory results received (DM-DESC-002).
NOTE: Benzene migration to groundwater cleanup level is 0.025 mg/kg PQL in most cases was above the cleanup level "U" flagged-compound was analyzed for but not detected.
DM-DESC-002-10N~E(20 BOG)
DRO 508 mg/kg 0.0333 mg/kg benzene (U)
DM-OBSC-002-10N-OOE(l3 BOG)
DRO 600 mg/kg benzene (U) 0.321 mg/kg
DM-DESC-002-00N-10E(20 BOG)
DRO 333 mg/kg benzene 0.258 mg/kg (U)
DM-DESC-002-OON-10B{l3 BOG)
DRO 674 mg/kg benzne 0.0331 mg/kg (U)
DM-DESC-002-OON-38E(1l.9 BOG)
DRO 2,160 mg/kg benzene 0.0698 mg/kg (U)
DM-DESC-002~00N-38E(l6 BOG)
DRO 266 mg/kg benzene 0.0272 mg/kg (U)
DM-DBSC-002-OON-64E(14.8 BOG)
benzene 0.0826 mg/kg detected above cleanup level of 0.025 mg/kg PQL was 0.0562 mg/kg
DM-DESC-002-00N-64E(l0.7 BOG)
DRO 2,010 mg/kg benzene 0.0592 mg/kg (U)
DM-DESC-002-21N-64S(l0.8 BOG)
3,920 mg/kg DRO, 0.00980 mg/kg benzene (U)
DM-DESC-002-32N-64E(lO BOG)
1,120 mg/kg DRO benzene 0.0106 mg/kg (U)
DM-DESC-002-53N-60E(11 BOG)
1,460 mg/kg DRO 0.641 mg/kg benzene (U)
DM-DESC-002-53N-6OB(l6 BOG)
1,160 mg/kg DRO 0.0262 mg/kg benzene (U)
DM-DESC-OO2-48N-35E (lO BOG)
865 mg/kgk DRO 0.0415 mg/kg benzene (U)
DM-DESC-002-48N-3SE(17 BOG)
1,950 mg/kg DRO 0.0734 mg/kg benzene (U)
DM-DESC-002-45N-1OE(l1.6 BOG)
4,960 mg/kg DRO 0.0700 mg/kg benzene (U)
DM-DESC-002-28N-5E(11 BOG)
1,320 mg/kg DRO 0.0334 mg/kg benzene (U)
DM-DESC-002-28N-5E(lS BOG)
1,920 mg/kg benzene 0.0172 mg/kg (U) |
Louis Howard |
1/14/2000 |
Update or Other Action |
Completion Report 1999 - Monitoring Wells Indian Booster Pump Station. Indian, Alaska.
This report documents the completion of tasks described in the "Monitoring Wells - 1999 Work Plan" (Work Plan), dated July 1999. The following tasks, as described in the Work Plan, have been completed.
• Groundwater analysis from 40 previously existing on-site monitoring wells.
• Decommissioning of selected monitoring wells.
• Installation of new (1999) monitoring wells.
• Groundwater analysis.
• Free Product Monitoring
Prior to sampling each existing monitoring well, the groundwater depth was measured to the nearest 0.01 foot using a water level indicator, and the water volume in each well was calculated. Following the groundwater depth measurements, free-product thickness measurements were made using a petroleum indicator and water finding paste. In addition, a second measurement for free-product was made using an oil/water interface probe. Free product was detected in MW-22, -25 , and -26. A second measurement in MW -25 showed no detectable free product. Based on the result of the confirmation measurement, and historical data for this well, the original measurement of free product in MW -25 is believed to be anomalous.
In accordance with Section 3.0 of the Work Plan, and ADEC correspondence (e-mail) dated July 27,
1999, 10 monitoring wells (MW-1, -2, -3, -5, -9, -10, -20, -31, -32, and -34DR) were decommissioned. In addition, three monitoring wells (MW -22, -26, and -44) were decommissioned during soil excavation activities. Monitoring well MW-26 was replaced with MW-45, and two monitoring wells (MW-22 and -44) were replaced with MW-49.
During the initial sampling of the 1999 monitoring wells, polynuclear aromatic hydrocarbons (PAH) and benzene, toluene, ethylbenzene, and xylenes (BTEX) analyses were inadvertently overlooked in samples from monitoring wells MW-43, -44, -46, -47, and -48D. Monitoring wells MW-43, -46, -47, -48D, and --49 (replaces MW-44) will be sampled and analyzed for BTEX and PAH during the first quarter 2000 as part of the network sampling.
July 1999 Analyis above cleanup levels for Diesel Range Organics (DRO) 1.5 mg/L
MW-4 1.75 mg/L
MW-17 45.9 mg/L
MW-17(DUP) 80.8 mg/L
MW-22 390 mg/L
MW-22D 2.11 mg/L
MW-26 3,810 mg/L
MW-28 4.88 mg/L
MW-30 3.36 mg/L
MW-30 (DUP) 0.985 mg/L
MW-33 124 mg/L
MW-37 2.17 mg/L
MW-38 33.8 mg/L
MW-PH 12.2 mg/L
FREE PRODUCT (in Feet)
MW-22 0.14
MW-26 0.03
Soil sample results from well installation (mg/kg) Gasoline Range Organics (GRO) was not analyzed for as required for JP-8 fuel releases.
Cleanup for DRO 250 mg/kg Benzene 0.025 mg/kg
MW-43/10' 252 mg/kg DRO MW-43/10'(DUP) 515 mg/kg
MW-45/10' 10,500 mg/kg DRO
MW-47/10' 850 mg/kg DRO benzene 0.0478 mg/kg MW-47/10' (DUP-2) 505 mg/kg DRO benzene 0.0504 mg/kg
MW-49/20' 264 mg/kg DRO
Groundwater
EPA 602 typical PQL of 7.0 ug/L is ABOVE the cleanup level of 5 ug/L for BENZENE. However the MDL is below at 0.7 ug/L.
DRO cleanup level in GW is 1.5 mg/L *GRO was not analyzed as required for JP-8 fuel releases.
MW-43 2.25 mg/L MW-43 (Dup.) 2.05 mg/L
MW-45 21.5 mg/L
MW-46 3.54 mg/L
MW-47 10.1 mg/L
MW-48D 1.89 mg/L
MW-49 1.55 mg/L
|
Louis Howard |
4/4/2000 |
Update or Other Action |
Received Quarter 1-2000 Sampling Report of groundwater monitoring results, prepared by Michael L. Foster and Associates.
Two monitoring wells listed in the LTMP, MW-19 and MW-22D, could not be sampled due to blockages within the well. Under the advisement of Scott Pexton of ADEC, three wells not included in the original LTMP (MW-4, -27, and –39) were then added.
As a result of a detection of free-product (0.25 inches) in MW-47 on February 29, 2000, MW-17, -24, -25, -33, and -47 were tested on March 8, 2000 for the presence of free-product. Free-product was tested utilizing petroleum indicator and water finding pastes. No free-product of measurable thickness could be identified in any of the groundwater monitoring wells tested on March 8, 2000.
Of the 30 wells sampled, the only wells that had concentration levels exceeding groundwater clean-up levels as defined in the Record of Decision for Clean-up were 9 Type 2 APOC wells, which are located within the contaminant plume. Of the contaminant levels exceeding the clean-up level of 1.5 mg/L DRO, values ranged from 1.80 mg/L at MW-48 to 55.3 mg/L at MW-47.
NOTE TO FILE: DRO concentrations in water in equilibrium with diesel #1 and jet A fuels may be expected to have DRO concentrations of about 2 to 5 mg/L. DRO concentrations exceeding this range likely indicate the presence of NAPL (Non-Aqueous Phase Liquids). Five Type 2 APOC wells had concentration levels below 1.5 mg/L. Table 7 lists each groundwater monitoring well that exceeded clean-up levels.
Sentry well, MW-49D, tested for benzene below clean-up levels of 0.005 mg/L with a value of 0.000905 mg/L. Due to this positive test for benzene, MW-49D has been scheduled for retesting on May 11, 2000.
NOTE TO FILE:
Benzene was detected above the 5 ug/L cleanup level in APOC Type 2 wells: MW-30 at 5.35 ug/L and MW-47 at 14 ug/L. |
Scott Pexton |
4/6/2000 |
Update or Other Action |
Al Meiners Park Superintendent DNR Div. Parks & Outdoor Recreation-Chugach sent letter to Chugach Electric and Enstar Natural Gas companies RE: 1993 Indian Valley Fuel Spill: Memorandum of Agreement between DEC and State Park to establish institutional controls on land use activities.
The management of the spill has moved into the long term monitoring and, hopefully, natural remediation of the contaminated groundwater and soil. It could be twenty (20) years (2020) or more before DEC would be able to determine that the site is no longer contaminated. As the fee title owner/manager of the affected lands, DNR has signed the enclosed memorandum of agreement with DEC to limit our land use activities in the area. In this agreement DNR has agreed to not drill water wells in one area and to limit ground disturbing activities to a depth of four (4) feet. If DNR needs to dig deeper, DNR may do so with DEC's approval. If DNR encounters contaminated soils below a depth of ten (10) feet, DNR is responsible for the cost of treating the contaminated soil.
As part of the agreement with DEC, DNR also agreed to notify all holders of easements or rights-of-way of the existence of the agreement. This letter is that notice. DNR asks that before a well is drilled or activities conducted at a depth of greater than four (4) feet in the easement or right-of-way within the areas depicted on the enclosed map, that DEC be contacted. This summer, Dames & Moore will be installing metal sign markers in this area to delineate in the field the areas where these land use controls exist. |
Scott Pexton |
5/18/2000 |
Update or Other Action |
Site Restoration and MW-22/MW-26 Excavation Summary received May 18, 2000. Pursuant to the Record of Decision for Cleanup, Indian Booster Pump Station, U.S. Defense Energy Support Center, ADEC Database Record Key 93-2101-215-01, dated August 30, 1999, approximately 1,000 cubic yards of soil in the area of monitoring well MW-26 was excavated, removed, and thermally treated off-site. In addition, after further consideration, and based on the continued presence of free-product in monitoring well MW-22, it was decided that the area around monitoring well MW-22 should also be excavated, removed, and thermally treated off-site. Based on this, approximately 800 cubic yards of soil was excavated in the area of monitoring well MW-22. In conjunction with the excavation efforts, final site restoration activities were also completed. This report has been prepared to document the activities associated with the following three tasks.
• Monitoring well MW-26 excavation.
• Monitoring well MW-22 excavation.
• Final site restoration
Monitoring well MW-26 Excavation: It was estimated that 1,000 cubic yards of material would be excavated. Based on the soil type, glacial till, and its density, it was estimated that the unit weight of the material was approximately 100 pounds per cubic foot. Therefore the 1,511.63 tons of material sent to ASR equated to 1,100 cubic yards of contaminated material excavated. As part of the excavation, monitoring well MW-26 was also removed. Thermal treatment at ASR's facility will be completed during the spring of 2000. Upon completion, a final deposition notification will be transmitted to the ADEC.
Monitoring Well MW-22 Excavation: 830 cubic yards of contaminated material was excavated. As part of the excavation MW-22 and MW-44 were also removed. MW-49 was installed on November 13, 1999 to replace MW-22 and MW-49. Upon completion of treatment by ASR a final deposition notification will be transmitted to ADEC.
Based on the results of the soil analyses, there appears to be contamination along portions of the walls with DRO values ranging from non-detect to 4,960 mg/kg in the northwest corner. Since the contamination and the material in the area of the gray zone appeared to be relatively consistent, it was estimated that contamination based on DRO analysis was in the range of 2,000 to 4,000 mg/kg. Assuming an average concentration of 3,000 mg/kg (DRO), then approximately 500 gallons of fuel was recovered as a result of the excavation effort.
Due to the onset of winter, revegetation in the area of the monitoring well MW-26 excavation was not completed. Final revegetation is planned for the summer of 2000. In addition, several of the areas associated with the removal of the below ground infrastructure will also be revegetated at the same time.
|
Scott Pexton |
5/31/2000 |
Update or Other Action |
May 2000 report documenting the 1999 Monitoring Wells work plan dated July 16, 1999 received. Tasks: Groundwater analysis from 41 previously existing on-site monitoring wells, and 3 Indian Creek gauge stations, Decommissioning of 13 monitoring wells, Installation of 9 new (1999) monitoring wells, and Groundwater analyses of the new 1999 monitoring wells.
In accordance with Section 3.0 of the Work Plan, and ADEC correspondence (e-mail) dated July 27, 1999, 10 monitoring wells (MW-1, -2, -3, -5, -9, -10, -20, -31, -32, and -34DR) were decommissioned. Prior to decommissioning, each of the listed wells was sampled and analyzed for DRO as part of the groundwater analysis task described in Section 2.0. As described in the Work Plan, a maximum DRO threshold concentration of 0.8 milligrams per liter (mg/L) was used to determine whether each well should be decommissioned. All of the listed wells showed DRO concentrations less than the 0.8 mg/L threshold concentration. In addition, three monitoring wells (MW-22, -26, and -44) were also decommissioned during soil excavation activities. Monitoring well MW-26 was replaced with MW-45, and two monitoring wells (MW-22 and 44) were replaced with MW-49.
In accordance with Section 4.0 of the Work Plan, and as modified by ADEC during the GTP excavation, a total of nine new monitoring wells (MW-42, -43, -44, -45, -46, -47, -48D, -49, and -49D) were installed between August 11 and November 30, 1999, to support the groundwater quality compliance monitoring program. One of these wells (MW-44) was decommissioned shortly after installation as described in Section 3.0. The locations of the nine new wells are shown on Figures 3 and 4.
All of the 1999 monitoring wells (MW-42, -43, -44, -45, -46, -47, -48D, -49, and -49D) were sampled. Monitoring wells MW-42, -43, -44, -46, -47, -48D, and -49D were sampled between September 8 and 10, 1999; and monitoring wells MW-45 and –49 were sampled on December 3, 1999. The sampling and quality control methods used for this task were the same as those described in Section 2.0. In addition, the Class B Public Water Supply Well (Public Water System 218593) was sampled and analyzed in accordance with the Certificate to Operate, dated January 28, 1999. A summary of the groundwater analytical program for the 1999 monitoring wells and the public water supply well is presented in Table 6. During the initial sampling of the 1999 monitoring wells, BTEX and PAH analyses were inadvertently overlooked in samples from monitoring wells MW-42, -43, -44, -46, -47, -48D, and -49D (PAH only). Monitoring wells MW-42, -43, -46, -47, -48D, -49 (replaces MW-44), and -49D will be sampled and analyzed for BTEX and PAH during the first quarter 2000 sampling effort.
Results of the July 1999 Site-wide GW DRO Analysis: MW-17 7/13/99 45.9 mg/L (DUP 80.8 mg/L), MW-22 7/13/99 390 mg/L, MW-24 7/13/99 41.3 mg/L, MW-26 7/13/99 3,810 mg/L, MW-28 7/13/99 4.88 mg/L, MW-30 7/16/99 3.36 mg/L, MW-33 7/13/99 124 mg/L, MW-38 7/13/99 33.8 mg/L and MW-PH 7/16/1999 12.2 mg/L. NOTE TO FILE: DRO concentrations in water in equilibrium with diesel #1 and jet A fuels may be expected to have DRO concentrations of about 2 to 5 mg/L. DRO concentrations exceeding this range likely indicate the presence of NAPL (Non-Aqueous Phase Liquids).
Product thickness
MW-22 0.14 ft, MW-26 0.03
Soil Sample Analytical Results
MW43 10' bgs 515 mg/kg DRO, MW45 10' bgs 10,300 mg/kg DRO, MW47 10' bgs 850 mg/kg benzene 0.0478 mg/kg.
DRO
MW-43 2.25 mg/L, MW44 21.5 mg/L, MW45 3.54 mg/L, MW46 18.4 mg/L, MW47 10.1 mg/L, MW48D 1.89 mg/L |
Louis Howard |
6/8/2000 |
Meeting or Teleconference Held |
Meeting at ADNR Division of Parks conference room at 550 West 7th Avenue, Anchorage. Discussed site status, reports, planned actions, and revisions to draft long-term groundwater monitoring plan. |
Scott Pexton |
8/4/2000 |
Long Term Monitoring Established |
Part I of II Letter sent to DESC with approval of July 2000 Long-term Monitoring Plan. Please note that it is your responsibility to obtain any permits or authorizations from landowners or land managers to access equipment and wells during monitoring activities. *Revised comment field-Groundwater monitoring at site is scheduled to be quarterly sampling frequency for the 3 general categories: 1) Alternative points of compliance (APOC)-a) perimeter monitoring wells, b) interior monitoring wells, c) creek protection monitoring wells, 2) Sentry wells, and Class B public water supply wells.
Type 1 APOC wells include MW-4, 5D, 6, 7, 13, 23, and 27 located at the perimeter of the site. These wells are expected to continue to meet cleanup levels but will be monitored to verify that contaminant migration does not occur beyond the boundaries of the perimeter monitoring network.
Type 2 APOC wells include MW-PH, 21, 27D, 28D, 30, 37, 38, 43, 45, 46, 47, 48D and 49 within parts of existing plume. These will be monitored to evaluate the progress of natural attenuation processes to confirm that plume concentrations are stable or decreasing and to determine when cleanup levels are reached. Type 3 APOC wells include: MW-8, 11 and 16 located downgradient of the site between the source areas of the contamination and Indian Creek. These wells are to be monitored to confirm that groundwater will not cause a violation of the 18 AAC 70 surface water quality standards for Indian Creek. Surface water samples will be for TAH, TAqH and DRO (*note to file-DRO is not a surface water quality analyte but groundwater analyte).
Sentry wells include deep monitoring wells: MW-2D, 35D and 49D will be monitored to confirm and ensure that contamination does not migrate towards downgradient landowners. Wells will be sampled quarterly for DRO and BTEX to confirm and ensure that petroleum impacted groundwater does not migrate towards downgradient landowners.
Drinking water wells will not be sampled except on a contingency basis. If DRO or BTEX compound is detected in ANY sentry well at concentrations above the practical quantitation limit specified in Table 4 (includes DRO, GRO, BTEX, PAHs, TAH, TAqH, PCBs, VOCs) additional sampling will be undertaken to determine groundwater concentration trends and to identify potential contributing source areas. Scope of LTM program to be evaluated annually to determine if changes to locations and frequencies are appropriate. Type 1 and 2 APOC to be monitored for DRO on quarterly basis for two (2) years. After 2 years, ADEC will determine if changes are warranted in frequency or locations. Type 3 APOC wells to be monitored for DRO, TAH, TAqH on quarterly basis for one year, after which ADEC will evaluate monitoring frequency.
Sentry wells to be monitored for DRO and BTEX on quarterly basis for two years. After two years, ADEC will determine if changes to the monitoring frequency are warranted. If DRO or BTEX are reported in ANY of the sentry wells (MW-2D, MW-35D and MW-49D), sampling frequency will increase to attempt to determine contaminant level trends and to identify contributing source areas that may require cleanup action.
Downgradient residents will be notified and sampling of residential wells may be initiated with landowner consent. Class B Public drinking water supply well to be monitored for DRO, GRO, VOCs, PAHs, PCBs and total coliform bacteria on quarterly basis and nitrates on annual basis for two years. After two years, ADEC will determine if changes to the monitoring frequency are warranted. Contingency Plan: If groundwater cleanup levels, except for groundwater sampled at Type-2 APOC wells are exceeded during routine monitoring, ADEC will be notified IMMEDIATELY, and new samples will be collected and analyzed under a fast lab turn-around time for DRO and BTEX (TAH and TAqH for type 3 APOC wells) using analytical methods specified in Table 4. In addition to ADEC, the Chugach State Park Superintendent, the President of the Turnagain Arm Community Council and the Indian Fuel Spill Citizen Task Force Chair will be notified. |
Scott Pexton |
8/11/2000 |
Update or Other Action |
Received Quarter 2 - 2000 Sampling Report with groundwater monitoring results, prepared by Michael L. Foster and Associates.
Type 2 APOC wells were tested using a petroleum indicator paste for free-product before bailing. Free-product was detected in monitoring wells MW-38 and MW-47 on June 30, 2000 at 1/16 inch and 1/2 inch, respectively. Free-product was again detected in monitoring wells MW-38 and MW-47 on July 5, 2000 at 1/16 inch and 3/8 inch, respectively.
Monitoring wells were analyzed for GRO, DRO, TAH, and TAqH. The Pubic Water System was analyzed for GRO, DRO, VOCs, PAHs, PCBs, and total coliform bacteria. Sample duplicates were collected at a rate of ten percent with a duplicate sample collected for each parameter each day. BTEX, GRO, VOCs, and PAHs, were non-detect (ND) for all samples analyzed. DRO ranged from ND to 35.5 milligrams per liter (mg/L); (NOTE TO FILE: DRO concentrations in water in equilibrium with diesel #1 and jet A fuels may be expected to have DRO concentrations of about 2 to 5 mg/L. DRO concentrations exceeding this range likely indicate the presence of NAPL (Non-Aqueous Phase Liquids).)total coliform ranged from 1 colony per 100 milliliter (col/100 ml) other bacteria (OB) to 35 col/100 ml OB with coliform bacteria. Calculated levels of TAH and TAqH were ND. |
Scott Pexton |
11/1/2000 |
Update or Other Action |
Received Quarter 3 - Sampling Report with groundwater monitoring results, prepared by Michael L. Foster and Associates. |
Scott Pexton |
1/12/2001 |
Update or Other Action |
Received Quarter 4 - 2000 Sampling Report with groundwater monitoring results, prepared by Michael L. Foster and Associates. |
Scott Pexton |
3/6/2001 |
Update or Other Action |
Received letter from Michael Foster that summarized completed tasks at the site regarding restoration activities and placement of institutional control boundary markers. |
Scott Pexton |
3/19/2001 |
Meeting or Teleconference Held |
Meeting held at the Chugach State Park Potter Section House to discuss groundwater sampling results and restoration efforts. Participants included Scott Pexton, Jack Appolloni, Michael Foster, Traci Bradford, Mary Maurer, Gordon Scott and Jerry Lewanski. |
Scott Pexton |
3/29/2001 |
Update or Other Action |
Received Quarter 1 - 2001 Sampling Report. |
Scott Pexton |
6/21/2001 |
Update or Other Action |
Received Quarter 2 - 2001 Sampling Report with groundwater monitoring results, prepared by Michael L. Foster and Associates. |
Scott Pexton |
10/9/2001 |
Update or Other Action |
Received Quarter 3 - 2001 Sampling Report with groundwater monitoring results, prepared by Michael L. Foster and Associates. Of 28 monitoring wells sampled, seven had DRO concentrations reported exceeding the cleanup level of 1.5 mg/L. DRO concentrations ranged from 1.66 mg/L to 46.9 mg/L in monitoring wells MW-PH, MW-38, MW-43,
MW-45, MW-46. MW-47 and MW-49. |
Scott Pexton |
10/25/2001 |
Meeting or Teleconference Held |
Met with Lieutenant Colonel Redmon and Jack Appolloni of DESC and Mike Foster of Michael L. Foster and Associates to discuss groundwater monitoring results, funding issues under DSMOA, and future actions at the site. |
Scott Pexton |
3/13/2002 |
Update or Other Action |
Received 2001-Annual Sampling Report prepared by Michael L. Foster & Associates for the Defense Energy Support Center.
The Type 1 APOC wells (perimeter network) had DRO levels that were below the site cleanup criteria of 1.5 mg/L. Only one well (MW-6) had a detectable level (0.693 mg/L) of DRO (Q3 only). The chromatographic pattern was compatible to a weathered middle distillate, such as Diesel Fuel #2. Eight of the nine Type 1 APOC wells (MW-4, MW-5D, MW-7, MW-13, MW-23, MW-27, MW-34, and MW-42) had no detectable levels of DRO during any quarterly sampling event.
Seven of the thirteen Type 2 APOC wells (MW-PH, MW-38, MW-43, MW-45, MW-46, MW-47, and MW-49) exhibited DRO concentrations in excess of the site cleanup criteria of 1.5 mg/L. These wells are located primarily within the existing contaminant plume. Of the contaminant levels exceeding the cleanup criteria for DRO, MW-38 displayed the highest contaminant levels with values ranging from 10.8 mg/L to 46.9 mg/L. NOTE TO FILE: DRO concentrations in water in equilibrium with diesel #1 and jet A fuels may be expected to have DRO concentrations of about 2 to 5 mg/L. DRO concentrations exceeding this range likely indicate the presence of NAPL (Non-Aqueous Phase Liquids).
The Type 3 APOC wells (creek protection network) had no detectable levels of DRO, TAH, or TAqH concentrations for any of the quarterly sampling events.
The sentry wells have also had no detectable levels of DRO or BTEX concentrations during any sampling event.
The Class B PWS had no results above cleanup criteria for GRO, DRO, VOCs, PAHs, or PCBs. No coliform bacteria was detected during any quarterly sampling event. However, 23 OB were reported during the Q3 sampling event.
Based on the results of the quarterly sampling events for the year 2001, contaminant levels in excess of cleanup criteria are limited to the Type 2 APOC wells contained within the contaminant plume. Neither Indian Creek nor nearby residences have been impacted by the on-site contamination.
Report recommends that the following Type 1 APOC wells be decommissioned. We recommend MW-19, since it is damaged and not a part of the LTMP. It also recommends that MW-27 and MW-42 be decommissioned since neither has shown any detection over the past two years.
Type 2 APOC wells which have shown no detectable levels of contamination during 2001 include MW-21, MW-28D, MW-37, and MW-48D. Based on this, the report is recommending them for decommissioning.
The Sentry well, MW-35D (the artesian well) is also recommended for decommission. This well is commonly frozen and cannot be sampled. This well has also not exhibited any detectable levels of any analytes tested during the past two years. |
Scott Pexton |
3/20/2002 |
Update or Other Action |
Received Free-Product Testing Report prepared by Michael L. Foster & Associates for the Defense Energy Support Center. Fifteen groundwater monitoring wells proposed for decommissioning were tested for the presence of free product on March 11, 2002. No free product was detected in 14 of the wells and the other well was frozen. |
Scott Pexton |
6/7/2002 |
Meeting or Teleconference Held |
Meeting held at ADEC offices in Anchorage. ADEC agreed with recommendations to decommission thirteen monitoring wells and to revise the long-term monitoring plan to reflect semi-annual sampling instead of quarterly sampling. |
Scott Pexton |
7/30/2002 |
Update or Other Action |
Received Updated Long-Term Monitoring Plan prepared by Michael L. Foster & Associates for the Defense Energy Support Center. In general, thirteen groundwater monitoring wells will be decommissioned. These wells include three Type-1 Alternative-Points-of-Compliance (APOC) wells, three Type-2 APOC wells, one Sentry well, and six unused wells.
Prior to decommissioning a groundwater monitoring well, the well will be tested for free-product by applying both a fuel locating paste and a water locating paste to a water level indicator and inserting the water level indicator into the well. If free-product is detected, the well will not be decommissioned and ADEC will be notified.
After testing for free-product, an excavator will be used to remove the well casing from the ground. After the casing has been removed, the annulus will be sealed with bentonite chips to within six inches of the surface where it will be topped off with soil and blended into the surrounding area. Decommissioning debris will be transported off-site for disposal. Upon completion of the decommissioning of the thirteen groundwater monitoring wells, a summary letter report will be submitted to ADEC with an updated site map. Purge water will be collected twice per year in June and December for both the Type-1 APOC and Type-2 APOC wells. Purge water will be stored in 55-gallon drums near the Pumphouse building pending results of sample analyses.
As approved by ADEC in their letter dated June 7, 2002, and as agreed upon by the Chugach State Park Superintendent during the 2002 Annual Stakeholder’s Meeting, collected water with analytical results below ADEC cleanup levels listed in Table 1 can be disposed of via surface spillage in an area near the Pumphouse building as shown on Figure 3. Collected water with analytical results higher than the cleanup levels found in Table 1 will be disposed of off-site at an ADEC-approved facility.
7.0 LABORATORY ANALYSES-Laboratory analyses will be performed utilizing an ADEC-approved laboratory. The chemical compound to be analyzed, laboratory method, and typical PQLs, and method detection limit (MDLs) for each analyte are presented in Table 6.
8.0 REPORTING FORMAT-Semiannual reports will be submitted to ADEC within 30 days after receipt of the analytical results. The semiannual reports will have at a minimum the following data.
• A summary of the sample collection effort.
• A summary of the laboratory analysis results (table format).
o Monitoring well location
o Date sampled
o Elevation of groundwater (ref. local datum)
o Analytical results
• Laboratory analysis data sheets.
The Winter Semiannual Report will also contain any proposed alternatives or changes to monitoring well locations, frequency, and/or analytical testing if appropriate. In addition, the Winter Semiannual Report may also include requests for decommissioning additional groundwater monitoring wells.
Type-1 and Type-2 APOC wells will be monitored for DRO on a semiannual basis. Type-3 APOC wells will be monitored for DRO, TAH, and TAqH on a semiannual basis. Sentry wells will be monitored for DRO and BTEX on a semiannual basis. If DRO or BTEX is reported in any of the sentry wells then sampling frequency will increase in an attempt to determine contaminant level trends and to identify contributing source areas that may require cleanup action. Down-gradient residents will be notified and sampling of residential wells may be initiated with landowner consent.
The Class B Public drinking water supply well will be monitored for DRO, GRO, VOCs, PAHs, PCBs, and Total Coliform Bacteria semiannually. In addition, a nitrate sample will be collected annually during the summer sampling event. |
Scott Pexton |
7/31/2002 |
Document, Report, or Work plan Review - other |
Letter sent to Major Kephart of Defense Energy Support Center with ADEC approval of Updated Long-Term Monitoring Plan. The plan describes how groundwater quality will be monitored in the vicinity of the former DESC booster pump and pipeline facilities located within Chugach State Park near the community of Indian, Alaska. The main objective of the groundwater monitoring is to verify that contaminated groundwater does not migrate to threaten drinking water or Indian Creek.
The updated plan reflects previously agreed upon changes to sampling frequency and specifies thirteen monitoring wells for decommissioning during 2002. The plan was determined to be consistent with both the general requirements of Site Cleanup Rules under 18 AAC 75 and the specific long-term groundwater monitoring regulations at 18 AAC 75.345 and 18 AAC 75.360. DESC was also notified of a change in ADEC project manager from Scott Pexton to Jim Frechione.
Wells approved for decommissioning since July 2000 LTM Plan was approved: Type 1 APOC wells MW-19, MW-27, MW-42, Type 2 APOC wells MW-21, MW-28D, MW-48D, Sentry Well MW-35D, Non-LTMP Wells: MW-17, MW-24, MW-25, MW-28, MW-33, and MW-33R.
Type 1 APOC wells (MW-4, 5D, 6, 7, 13, 23, and 34) will be monitored semi-annually (twice yearly) for DRO during winter and summer sampling events.
Type 2 APOC wells (MW-PH, 27D, 30, 37, 38, 43, 45, 46, 47 and 49) will be monitored semi-annually for DRO during the summer and winter sampling events.
Type 3 APOC wells (MW-8, 11 and 6) will be monitored semiannually (twice yearly) for DRO, TAH, TAqH during summer and winter sampling events.
Sentry wells (MW-2D and 49D) will be sampled semiannually for DRO and BTEX.
Class B Public Water Supply Well will be sampled for DRO, GRO, PCB, VOC, PAH, Nitrate, and total coliform on a semiannual basis. |
Scott Pexton |
8/13/2002 |
Update or Other Action |
Summer 2002 Water Sampling report Dated August 13, 2002. Of the 22 groundwater monitoring wells sampled, the only wells that had concentration levels exceeding groundwater cleanup levels as defined in the Record of Decision for Cleanup for DRO were five Type 2 APOC wells, which are located within the contaminant plume (MW-PH, MW-38, MW-45, MW-47, and MW-49).
Of the contaminant levels exceeding the cleanup level of 1.5 mg/L DRO, values ranged from 1.57 mg/L to 28.2 mg/L.
NOTE TO FILE: DRO concentrations in water in equilibrium with diesel #1 and jet A fuels may be expected to have DRO concentrations of about 2 to 5 mg/L. DRO concentrations exceeding this range likely indicate the presence of NAPL (Non-Aqueous Phase Liquids). |
Louis Howard |
11/19/2002 |
Conditional Closure Approved |
ADEC Letter sent to Major Steven Kephart, Commander of DESC-Anchorage. The groundwater monitoring data has indicated that groundwater cleanup levels have been achieved at the points of compliance established for this site. While there are elevated levels of soil and groundwater contamination remaining on site, monitoring data indicates that the groundwater plume is decreasing in both size and concentration and does not pose a risk to human health and the environment. Long-term groundwater monitoring will continue in accordance with the Updated Long-Term Monitoring Plan dated July 29,2002. The institutional control remains in effect as described in the September 3, 1999 Memorandum of Agreement between ADNR and ADEC. In addition, an alternative water source has been installed to provide safe drinking water source for the owners and operators of the site.
In summary, based on information provided to date, ADEC has determined that the groundwater at the site has met applicable cleanup levels at the established compliance points and that in conjunction with the site's established institutional controls; the site does not pose a risk to human health and the environment. However, long-term groundwater monitoring will continue in accordance with the Updated Long-term Monitoring Plan dated July 29, 2002 because specific areas (of soil and groundwater) at the site remain above applicable cleanup levels. Also, please note that if contamination is identified at the site in the future that may pose a risk to human health or the environment, additional site characterization or cleanup action may be necessary.
Once it is demonstrated that soil and groundwater consistently meet the applicable cleanup level throughout the site, ADEC will close this site and require no further work including groundwater monitoring, that will also be the appropriate time to remove any restrictions identified in the September 1999 Memorandum of Agreement.
The following policy applies for soil regulated under 18 AAC 75 and 18 AAC 78 that is proposed for disposal off site from where it was generated. If the following criteria is met, ADEC approval and/or an institutional control(s) are not required:
1. The soil meets the most stringent Method Two, Migration to Groundwater, Table B2 cleanup level, and the most stringent standards for those chemicals under Table B1;
2. The soil may only be disposed of at any non-environmentally sensitive location in the Under 40" or Over 40" annual precipitation zone;
3. The soil is not placed within 100 feet of water wells, surface waters, and drainage ditches; and
4.The written approval from the landowner of the off-site location is required.
For additional information see site file. |
Jim Frechione |
12/6/2002 |
Update or Other Action |
Letter sent to Jim Frechione (ADEC) regarding fourteen groundwater monitoring wells were decommissioned on November 12 and 13, 2002 at the Indian Booster Pump Station, a former U.S. Defense Energy Support Center (DESC) facility, located within Chugach State Park approximately 25 miles southeast of Anchorage on the Seward Highway, one mile north of the community of Indian, at the end of Oceanview Road.
In accordance with the Updated Long-Term Monitoring Plan (LTMP), dated July 29, 2002, thirteen monitoring wells were decommissioned. An additional damaged well, MW-46, was approved for decommissioning on October 10, 2002 by the Alaska Department of Environmental Conservation (ADEC).
The monitoring wells decommissioned included three Type-1 Alternative-Points-of-Compliance (APOC) wells, four Type-2 APOC wells, one Sentry well, and six unused wells. Prior to the decommissioning of the monitoring wells, each well was tested for free-product, as specified in the LTMP. No free-product was detected in any of the 14 monitoring wells that were tested. |
Jim Frechione |
1/10/2003 |
Update or Other Action |
Winter 2002 Sampling Report recieved. Field activities for the Winter 2002 sampling event, which included the sampling of 21 groundwater monitoring wells and the Class B Public Water Supply Well, were completed during the month of December. The wells sampled included Type 1, 2, and 3 alternative points of compliance (APOC) wells, sentry wells, and a Class B Public Water Supply well, as defined in the Updated Long-Term Monitoring Plan (LTMP). Type 1 APOC wells (7) are located at the perimeter of the site, down-gradient of the existing fuel concentrations, on hydrologic flow paths between the source area of contamination and human receptors.
Type 2 APOC wells (9) are located within different parts of the existing groundwater contaminant plume. Type 3 APOC wells (3) are located down-gradient of the site between the source areas of contamination and Indian Creek. Sentry wells (2 deep monitoring wells) are located down-gradient of the site and are monitored to ensure that contamination does not migrate toward down-gradient landowners. A Class B Public Water Supply Well is located up-gradient of the site, and is intended to be utilized as an alternative water source for the landowner.
Monitoring wells were analyzed for BTEX, DRO, TAH, and TAqH. The Pubic Water System was analyzed for GRO, DRO, PAHs, PCBs, and total coliform bacteria. Sample duplicates were collected at a rate of ten percent with a duplicate sample collected for each parameter each day. BTEX, GRO, VOCs, PAHs, Total Coliform Bacteria, and PCBs were non-detect (ND) for all samples analyzed. However, 1 other bacteria (OB) was detected in the Public Water System. DRO ranged from ND to 196 milligrams per liter (mg/L). Calculated levels of TAH and TAqH were ND.
Of the 21 groundwater monitoring wells sampled, the only wells that had concentration levels exceeding groundwater cleanup levels as defined in the Record of Decision for Cleanup for DRO were three Type 2 APOC wells, which are located within the contaminant plume (MW-38, MW-43, and MW-47). Of the contaminant levels exceeding the cleanup level of 1.5 mg/L DRO, values ranged from 9.19 mg/L to 196 mg/L.
NOTE TO FILE: DRO concentrations in water in equilibrium with diesel #1 and jet A fuels may be expected to have DRO concentrations of about 2 to 5 mg/L. DRO concentrations exceeding this range likely indicate the presence of NAPL (Non-Aqueous Phase Liquids). |
Louis Howard |
7/21/2003 |
Update or Other Action |
2003 Summer Water Sampling Report received. Of the 21 groundwater monitoring wells sampled, the only wells that had concentration levels exceeding groundwater cleanup levels as defined in the Record of Decision for Cleanup for DRO were two Type 2 APOC wells, which are located within the contaminant plume (MW-38 and MW-47). Of the contaminant levels exceeding the cleanup level of 1.5 mg/L DRO, values ranged from 1.78 mg/L to 2.29 mg/L. |
Louis Howard |
3/5/2004 |
Update or Other Action |
File number assigned: 2102.38.046. |
Sarah Cunningham |
3/17/2004 |
Update or Other Action |
Site history and file review updates conducted. |
Louis Howard |
3/18/2004 |
Document, Report, or Work plan Review - other |
Review and comment conducted of the 2003 Winter Sampling report received for the site. In the future please include a line graph for each well with all the sampling results for since 1999 to the most current sampling event presented in the report. This would include: well number, date sampled, sample result, date of sampling event and cleanup standard for each contaminant of concern (see example attached with letter). Alternatively, a map could be provided with text box that has: date the well was sampled, sample result bolded if above cleanup level (expressed in mg/L or ug/L as appropriate) paired with cleanup standard, contaminant of concern for each well. Compliance with this request may require a bigger fold out map than which has been provided to the Department in the past, but will vastly improve reviews in the future to ascertain whether or not a trend exists at the monitoring wells for the site.
The text recommends the Class B PWS well be removed from the LTMP. The Department does not concur and will require sampling continue for the Class B PWS well (public water system identification 218593). The text also recommends MW-5D, MW-06, MW-23, MW-PH, MW-27D and MW-37 be removed from the LTMP.
The Department does not concur with the removal of MW-5D, MW-06, and MW-23, which are Type 1 Alternate Points of Compliance (APOC). These wells were expected to meet cleanup levels, but are to be monitored to verify that contaminant migration does not occur beyond the perimeter monitoring network.
The Department does not concur with removal of MW-PH, MW-27D, MW-37, which are Type 2 APOC wells. These wells are to be monitored for evaluation of the progress of natural attenuation processes to confirm that plume concentrations are stable or decreasing and to determine that cleanup levels have been met. Of particular concern to the Department is MW-PH which has come close to exceeding the diesel range organics (DRO) Table C cleanup level of 1.5 mg/L in the last two sampling events (1.35 mg/L and 1.3 mg/L respectively) in 2003. The June 2002 sampling event did exceed the DRO cleanup level with a 1.68 mg/L sampling result.
With additional groundwater monitoring data gathered from the site, there may be opportunity in the future to reduce sampling frequency or the number of APOC wells consistent with the long-term monitoring plan for the site. |
Louis Howard |
9/29/2004 |
Update or Other Action |
The Alaska Department of Environmental Conservation (the Department) has received DESC's requests for various actions at monitoring wells located at the stie on September 28, 2004 for review and comment. Below are the Department’s comments.
Recommendations-Class B PWS Well
The text recommends the Class B PWS well be removed from the LTMP. The Department concurs and will not require further sampling for the Class B PWS well (public water system identification 218593).
MW-5D, MW-06, MW-23
The text recommends wells: MW-5D, MW-06, MW-23, be removed from the LTMP. The Department concurs with the recommendation for wells MW-5D and MW-23 and not for well MW-06. This Type 1 Alternate Point of Compliance (APOC) well was expected to meet cleanup levels, but is to be monitored to verify that contaminant migration does not occur beyond the perimeter monitoring network.
MW-PH, MW-27D, MW-37
The text recommends wells: MW-PH, MW-27D and MW-37, be removed from the LTMP. The Department concurs with the recommendations for wells MW-27D and MW-37, but not for well MW-PH which is a Type 2 APOC well. This well is to be monitored for evaluation of the progress of natural attenuation processes to confirm that plume concentrations are stable or decreasing and to determine that cleanup levels have been met. Of particular concern to the Department is MW-PH which has come close to exceeding the diesel range organics (DRO) Table C cleanup level of 1.5 mg/L in the last two sampling events (1.35 mg/L and 1.3 mg/L respectively) in 2003.
With additional groundwater monitoring data gathered from the site, there may be opportunity in the future to further reduce sampling frequency or the number of APOC wells consistent with the long term monitoring plan for the site. |
Louis Howard |
2/2/2005 |
Update or Other Action |
2004 Winter Sampling Report received. Seventeen wells sampled no free product was found in any well. Wells which reported light sheen were MW-38 and MW-45. Well MW-47 had medium sheen present. There were a few interior network wells that had results above cleanup levels. Well MW-38 had 5.2 mg/L and a duplicate sample at 4.4 mg/L for diesel range organics (DRO). MW-45 detected 14 mg/L DRO. No other wells had results above cleanup levels established for the site. Three of the four PAH samples were damaged at the laboratory resulting in complete sample loss. DRO sample extracts were used to obtain PAH results for MW-08, MW-08 Dup, and MW-11. |
Louis Howard |
4/20/2005 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the updated long term groundwater monitoring plan at the site. Class B PWS Well: As stated in a September 29, 2004 letter to DESC-A, ADEC concurs with the recommendation for the removal of the Class B PWS well from the sampling plan. ADEC will not require further sampling for the Class B PWS well (public water system identification 218593).
MW-5D, MW-27D, MW-37 and MW-23: The Department concurs with the recommendation for decommissioning of wells: MW-5D, MW-27D, MW37 and MW-23.
IDW Disposal of Purge Water from Type 1 APOC, Type -3 APOC, and Sentry Wells: The text recommends only surface spilling of purge water for Type 1 Alternative Point of Compliance (APOC) wells. This section contradicts the statements in sections 4.0 2nd sentence 3rd paragraph and 5.0 2nd sentence 1st paragraph where it is stated that purge water for the Type -1 APOC, Type-3 APOC and Sentry monitoring wells will be surface spilled upon sample collection. ADEC requests correcting either the introduction or the subsequent text in these sections which conflicts with the introductory text.
Upon receipt of groundwater sample results above cleanup levels for diesel range organics or BTEX/TAH, or TAqH, ADEC will be immediately notified by phone, facsimile within three working days within receipt of the results. As a result of any result that is above established cleanup criteria, ADEC’s approval of on-site disposal of IDW purge water from monitoring wells from: Type 1 APOC, Type 3 APOC or Sentry wells will be revoked.
ADEC will not require DESC-A to apply for discharge of purge water from the wells listed above and these small scale discharges are considered to be insignificant.
ADEC is basing its approvals on the data provided to-date from DESC-A and its contractors.
ADEC will require a DESC-A to perform additional containment or cleanup if subsequent information indicates that the plume is expanding and not stable or that long-term monitoring of the groundwater is no longer adequate for protection of human health, safety, or welfare or of the environment. |
Louis Howard |
8/15/2005 |
Document, Report, or Work plan Review - other |
Comment letter to DESC-A RE: 2005 Annual Sampling Report Indian Booster Station Fuel Spill
AK MLFA Job No. DESC-DESC-006-0003. The Alaska Department of Environmental Conservation (ADEC) received the above document for review and comment on July 26, 2005. ADEC has the following comments on it.
General Comments-ADEC requests future submittals by DESC-Alaska for all of its reports include: chain of custody form, transfer log and/or release form for all samples sent off to the laboratory for analyses. ADEC will approve the report with the incorporation of the requested information as an appendix to the document. |
Louis Howard |
8/10/2006 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Long-Term Monitoring Report Indian Booster Pump Station Fuel Spill MLFA Job No. DESC-DESC-006-0005 July 28, 2006. Staff approved the document as submitted. Staff requested DESC include text or tables in future report submittals which compares the current sampling results to the previous sampling events at the site. This comparison will be used to identify any general trends in concentrations of contaminants in groundwater (if any can be inferred). |
Louis Howard |
11/16/2006 |
Update or Other Action |
Letter sent to Steve Cooper re: No Further Action Regarding Secondary Contamination at the Former Biotech Services Treatment Facility; File. # 2265.38.015. The Alaska Department of Environmental Conservation (Department) has recently reviewed your letter dated October 12, 2006.
Within your letter, you responded to the Department's questions regarding the status of the property located at Mile 37.5 Parks Highway. Thank you for providing this information. Please be aware that the Department has also recently contacted Mike Krieber and Bob Fultz. Mr. Fultz and Mr. Krieber were both working for the Department when the Biotech Services Treatment Facility was being dismantled and secondary contamination was being cleanup up. Both Mr. Fultz and Mr. Krieber confirmed that all secondary contamination at the former Biotech Services Treatment Facility had been cleaned up according to the Department's satisfaction in the mid 1990's.
At this time, the Biotech Services Facility will no longer be considered a contaminated site and
therefore, will be reclassified as non qualifying in the Department's database |
Todd Blessing |
10/9/2008 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the 2008 Annual Sampling Report Defense Fuel Support Point-Indian, AK. The Alaska Department of Environmental Conservation (ADEC) has received the above document on September 18, 2008 for review and comment. ADEC will approve the report
as submitted.
|
Louis Howard |
8/12/2009 |
Document, Report, or Work plan Review - other |
Staff reviewed and provided comments on the 2009 Annual Sampling Report Defense Fuel Support Point-Indian, AK.
General Comments
ADEC wishes to reiterate to DESC-A that an electronic copy (i.e. CD-ROM with ADOBE Acrobat PDF/MS WORD files) be provided with all of the draft/final versions of reports, work plans, documents sent to ADEC. ADEC requests the DESC-A require the contractor to provide as an appendix to all future soil sampling/groundwater monitoring activity reports, a copy of the contractor’s staff field notes describing dates, times, field observations, monitoring well condition, etc.
5.0 Recommendations Page 12
The text recommends the removal of MW-PH, MW-49, MW-34, and MW-08 from the long-term monitoring plan. ADEC disagrees. MW-8 shall remain in the long-term monitoring plan. MW-8 is a Type 3 well. Type-3 points of compliance are wells located down-gradient of the site between the source areas of contamination and Indian Creek. These wells will be monitored to confirm that groundwater will not cause a violation of the 18 AAC 70 surface water quality standards for Indian Creek (1999 Record of Decision).
MW-34 shall remain in the long-term monitoring plan. MW-34 is a Type 1 well. Type-1 points of compliance [wells] are located at the perimeter of the site, down-gradient of the existing DRO contamination, on hydrologic flow paths between the source area of contamination and human receptors. Type-l wells are expected to continue to meet cleanup levels, but will be monitored to verify that contaminant migration does not occur beyond the boundaries of the perimeter monitoring well network (1999 Record of Decision).
MW-PH ( a Type 2 point of compliance well) shall remain in the long-term monitoring plan and ADEC will request DESC-A to analyze for DRO, BTEX, PAHs since the text in Table 2 noted that there was a fuel odor and light sheen present. It was also noted in the Case Narrative on Page 2 of 41 (Appendix A) that client sample ID DESC-06-0010-MW-PH AK102 [had] “Unknown hydrocarbon with several peaks is present.”
Prior to considering any action on MW-49 (or any well), ADEC requests DESC-A to provide the last four years of monitoring data in tabular and graphical form for all the monitoring wells at the site. It has been five years since such comprehensive data was provided to ADEC which also showed the groundwater flow direction (June 29, 2004 Groundwater Trend Data MLFA Job No. DESC-DESC-001-029).
Finally, ADEC will require DESC-A to analyze for DRO, BTEX, and PAHs in MW-30 and MW-47 as well since they had “Unknown hydrocarbon with several peaks is present” noted in the case narrative (Appendix A). Table 2 indicated that MW-47 had fuel odor and a light sheen. |
Louis Howard |
8/27/2010 |
Document, Report, or Work plan Review - other |
2010 Annual Sampling Report Defense Fuel Support Point-Indian, AK received and commented on by staff.
Table 4 – 2009 Annual Water Sampling Activities Page 8
The table lists monitoring wells MW-45 and MW-47 as having 1.79 mg/L and 1.85 mg/L (respectively) diesel range organics (DRO). This is above the 1999 Record of Decision (ROD) groundwater cleanup level for DRO at 1.5 mg/L (See Table 1 Page 4 of the ROD) and both results should be bolded and shaded. Correct Figure 2 to show that MW-45 is at 1.79 mg/L from the 2010 sampling event not 8.10 mg/L 2009 sampling event. Similarly, MW-38 has incorrect data from the 2010 sampling event using 2009 data, please correct the figure.
5.0 Recommendations Page 10
The text recommends the removal of MW-PH, MW-49, MW-34, and MW-08 from the long-term monitoring plan. With the exception of MW-PH, ADEC disagrees with the recommendations. A review of the 2006-2009 monitoring well sampling data, ADEC will approve the removal of the Type 2 APOC Well: MW-PH from the monitoring program. plume concentrations are stable or decreasing at this well. This monitoring well change will need to be reflected in a memorandum to the site file should it be granted by ADEC.
MW-8 shall remain in the long-term monitoring plan. MW-8 is a Type 3 well. Type-3 points of compliance are wells located down-gradient of the site between the source areas of contamination and Indian Creek. These wells will be monitored to confirm that groundwater will not cause a violation of the 18 AAC 70 surface water quality standards for Indian Creek (1999 Record of Decision).
MW-34 shall remain in the long-term monitoring plan. MW-34 is a Type 1 well. Type-1 points of compliance [wells] are located at the perimeter of the site, down-gradient of the existing DRO contamination, on hydrologic flow paths between the source area of contamination and human receptors. Type-l wells are expected to continue to meet cleanup levels, but will be monitored to verify that contaminant migration does not occur beyond the boundaries of the perimeter monitoring well network (1999 Record of Decision). |
Louis Howard |
4/8/2011 |
Update or Other Action |
Revised long term monitoring plan received. Pursuant to the Record of Decision for Cleanup, Indian Booster Station, u.s. Defense Energy Support Center, ADEC Database Record Key 93-2101-215-01, dated August 30, 1999, and in accordance with the Site Management Plan, Indian Booster Station Fuel Spill, Indian, Alaska, dated June 3, 1999, a Long-Tenn Monitoring Plan (LTMP), dated July 27, 2000, was prepared for the Indian Booster Pump Station, a Department of
Defense facility, located within Chugach State Park approximately 25 miles southeast of
Anchorage on the Seward Highway, and one mile north of the community of Indian, at the end of Oceanview Road, as shown on Figure 1.
The original LTMP, dated July 27,2000, was updated in 2002,2005, and again in 2007. The 2007 L TMP is being updated based upon recommendations presented by Michael L. Foster and Associates, Inc. (MLFA) , and subsequently approved by the Alaska Department of Environmental Conservation (ADEC) in a cOlTespondence dated August 27, 2010. These recommendations include the decommissioning of five groundwater monitoring wells (MW-6, MW-13, MW-16, MW-2D, and MW-43).
Type-l APOC wells (MW-4, MW-7, and MW-34) are located at the perimeter of the site, down-gradient of the existing DRO contamination, on hydrologic flow paths between the source area of contamination and human receptors. Type-l APOC wells are expected to continue to meet cleanup levels, but will be monitored to verify that contaminant migration does not occur beyond the boundaries of the perimeter monitoring well network. Type-l APOC wells will be monitored annually (during the summer) for DRO.
Type-2 APOC wells (MW-30, MW-38, MW-45 , MW-47, and MW-49) are located within different parts of the existing groundwater contaminant plume. These wells will be monitored to evaluate the progress of natural attenuation processes, to confinn that the plume concentrations are stable or decreasing, and to determine when cleanup levels are reached. Type-2 APOC wells will be monitored annually (during the summer) for DRO.
Type-3 APOC wells (MW-8 and MW-ll) are located down-gradient of the site between the source areas of contamination and Indian Creek. These wells will be monitored to confinn that groundwater will not cause a violation of the 18 AAC 70 surface water quality standards for Indian Creek. The Type-3 APOC wells will be monitored annually (during the summer) for DRO, TAH, and TAqH.
If a TAH and/or TAqH concentration in a Type-3 APOC well exceeds the levels found in Table 2, then surface water samples from Indian Creek will be collected at the closest accessible sampling point down-gradient of the monitoring well. Surface water samples will be analyzed for DRO, TAH, and TAqH. A response plan will be developed if water quality in Indian Creek exceeds the levels found in Table 2.
One deep monitoring well (MW-49D) will be monitored to confinn and ensure that contamination does not migrate towards down-gradient landowners (MW-49D is shown on Figure 1). The sentry well will be sampled annually (during the summer) for DRO and BTEX. Residential drinking water wells will not be sampled, except on a contingency basis. If DRO or any BTEX compound is detected in any sentry well at concentrations above the Practical Quantitation Limit (PQL), additional sampling will be undertaken to determine groundwater concentration trends and to identify potential contributing source areas. Response actions will be evaluated as needed. Down-gradient residents will be notified and residential well sampling (with prior landowner permission) may be undertaken.
In general, DRO is the major contaminant of concern (COC) for the Type-l APOC, Type-2 APOC, Type-3 APOC, and Sentry monitoring wells. However, as a precaution to down-gradient landowners, BTEX is considered a potential COC for the sentry wells, and due to the proximity of Indian Creek, TAH and TAqH are considered potential COCs for Type-3 APOC wells. |
Louis Howard |
8/24/2011 |
Update or Other Action |
2011 Annual Sampling Report received. BTEX and PAH results were non-detect (ND) for all samples
analyzed. DRO ranged from 0.250(J) to 26.9 milligrams per liter (mg/L). Calculated levels of TAH and TAqH were ND for MW-08, MW101 (MW-08 Dup), and MW-11. Two of the twelve wells sampled (MW-38, MW-38 Dup, and MW-45) exceeded DRO cleanup levels defined in the Record of Decision for Cleanup. MW-38 and MW-45 are Type 2 APOC wells located within the contaminant plume. DRO values of these wells ranged from 10.5 to 26.9 mg/L. The data is accepted as representative of the site at the time of sampling with the flagged exceptions noted. |
Louis Howard |
8/24/2011 |
Update or Other Action |
2011 Annual Sampling Report received. BTEX and PAH results were non-detect (ND) for all samples
analyzed. DRO ranged from 0.250(J) to 26.9 milligrams per liter (mg/L). Calculated levels of TAH and TAqH were ND for MW-08, MW101 (MW-08 Dup), and MW-11. Two of the twelve wells sampled (MW-38, MW-38 Dup, and MW-45) exceeded DRO cleanup levels defined in the Record of Decision for Cleanup. MW-38 and MW-45 are Type 2 APOC wells located within the contaminant plume. DRO values of these wells ranged from 10.5 to 26.9 mg/L. The data is accepted as representative of the site at the time of sampling with the flagged exceptions noted. |
Louis Howard |
9/16/2011 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the 2011 Annual Sampling Report Indian Booster Station Fuel Spill-Indian, AK MLFA Job No. DESC-DESC-010-0003.
The Alaska Department of Environmental Conservation (ADEC) has received the above document on August 24, 2010 and has the following comments for the Indian Booster Station Fuel Spill site (CS DB Hazard ID 1775). ADEC agrees with the recommendations in the report.
ADEC requests that a periodic review of the selected remedy identified in the 1999 Record of Decision be conducted at this site as soon as possible. The review is similar to the EPA’s Five Year Review. This review is appropriate since there are hazardous substances on the site at levels that do not allow for unlimited use and unrestricted exposure. Unlimited use and unrestricted exposure (UU/UE) means that there are no restrictions placed on the potential use of land or other natural resources. In general, if the selected remedy relies on restrictions of land, ground water, or surface water use by humans or if any physical or engineered barrier is part of the remedy, then the use has been limited and a periodic review, no less than every five years, should be conducted.
EO 12580 paragraphs 2(d) and (e)(1) delegates the authority in CERCLA §104 and §121 to the Federal agencies or departments for selecting and conducting remedial actions addressing releases or threatened releases at sites that are not on the NPL. Consistent with CERCLA §121 and this guidance, Federal agencies or departments should conduct five-year reviews for all CERCLA non-NPL remedial actions that require a review.
The purpose of the periodic review is to determine whether the remedy at a site is, or upon completion will be, protective of human health and the environment by answering the following questions:
Question A: Is the remedy functioning as intended?
When answering Question A, the reviewer focuses on the technical performance of the remedy, whether that remedy is related to a single Operable Unit (OU) or the entire site. Data on monitoring, system performance and operation and maintenance of the remedy plays an important role in the determinations. In addition, the reviewer confirms that access and institutional controls are in place and successfully prevent exposure.
Question B: Are the exposure assumptions, toxicity data, cleanup levels, and Remedial Action Objectives still valid?
In answering Question B, the lead agency should review all the risk parameters on which the original remedy decision was based. This assessment should test the validity of all assumptions that underlie the original risk calculation. To reach its conclusions, the lead agency will generally consider changes in:
• Target populations,
• Exposure routes,
• Site characteristics and land use,
• Reference doses and slope factors,
• Applicable or Relevant and Appropriate Requirements (ARARs) and To Be Considereds (TBCs), and
• Remedial Action Objectives (RAOs).
ADEC generally will not reopen remedy selection decisions contained in RODs unless a new or modified requirement calls into question the protectiveness of the selected remedy.
Question C: Has any other information come to light that could call into question the protectiveness of the remedy?
The reviewer considers any other information that comes to light that could call into question the protectiveness of the remedy.
How does the lead agency formulate its conclusions?
The conclusions of the review should include:
• Identification of issues,
• Recommendations and follow-up actions, and
• A determination of whether the remedy is, or is expected to be, protective of human health and the environment.
The reviewer arrives at these conclusions through a technical assessment of the information collected during the document review, data collection, interviews, site inspection, and other activities. The reviewer identifies all issues that currently prevent or may prevent the response action from being protective.
Consistent with CERCLA §120(a)(4), at non-NPL Federal facilities sites, States generally have remedial oversight responsibilities and should be provided with adequate opportunity to participate in the five-year review process and to review the draft Five-Year Review document before it is finalized.
Once the review report has been finalized, signed by the lead agency and placed in the local site repository, the lead agency should notify community members that the review is complete and the report is available. |
Louis Howard |
3/1/2012 |
CERCLA ROD Periodic Review |
Draft ROD Periodic Review report received.
The review remedy is explained in Record of Decision (ROD), dated August 1999. This review evaluates the status of implementation of the selected remedy, identifies significant variances from the ROD, if any, & makes recommendations for reconciling variances &/or improving performance of remedial actions, if applicable.
The triggering action for this review is a request made by ADEC Project Manager, Mr. Louis Howard. This review is required due to the fact that hazardous substances, pollutants, or contaminants remain at the site above levels that allow for unlimited use & unrestricted exposure (UU/UE). UU/UE means that there are no restrictions placed on the potential use of land or other natural resources. In general, if the selected remedy relies on restrictions of land, GW, or SW use by humans or if any physical or engineered barrier is part of the remedy, then the use has been limited & a periodic review, no less than every five years, should be conducted. This review is being prepared pursuant to CERCLA §104 & §121.
Interviews were conducted with various parties connected to the site. The following individuals or entities were contacted & advised of the ROD review.
• The Indian Fuel Spill Citizen’s Task Force – The task force is no longer active.
• Jack Appolloni, DESC Facilities Manager – Mr. Appolloni was contacted on January 5, 2012 & had no concerns regarding the site.
• Heritage Land Bank – Ms. Alison Smith was contacted on January 17, 2012 & had no concerns regarding the site.
• ADNR, Division of Mine, Land, & Water – Mr. Roy Ireland was contacted on January 13, 2012 & had no concerns regarding the site.
• Tom Harrison, Chugach State Park Superintendent, landowner representative – As landowner representative, Mr. Harrison was presented with the following list of questions. His responses are included below each question.
1. Has the State Parks observed any environmental problems, such as sheen on surface water, odors, stressed vegetation, or stains, believed to be associated with the jet fuel discharge at the Property?
Although State Park employees have not been on the lookout for any problems, they are unaware of any such problems.
2. Has the State Parks drilled any GW well within the bounds of the Property unless it was specifically authorized in writing by ADEC?
No wells have been drilled by State Parks.
3. Has the State Parks disturbed the groundwater monitoring system at the Property unless it was specifically authorized in writing by ADEC?
Mr. Harrison is unfamiliar with the “groundwater monitoring system.”
4. Has the State Parks excavated or otherwise disturbed soil at the Property to a depth of greater than 4' bgs without first notifying ADEC’s CS Program by telephone, fax, e-mail or memorandum 7 days before commencing the activity.?
Mr. Harrison is unaware of what actually constitutes “the Property.” State Parks employees have not excavated greater than four feet in & around the Indian facilities over the five years Mr. Harrison has been associated with Chugach State Park.
5. Has the State Parks removed or treated soil contamination at the Property if encountered at a depth greater than 10 feet below the ground surface during any excavation or soil disturbance activity caused or overseen by Parks, its contractors, agents, employees, & authorized representatives?
To Mr. Harrison’s knowledge, no contaminated soil has been treated or removed from the site.
6. Has the State Parks notified (on a regular basis e.g. annually or biannually) holders of any existing or future utility easements, permits, or rights-of-way across the Property of the restrictions placed on soil excavation or disturbance activities & on the use of GW as well as the need to protect the groundwater monitoring system? Written documentation is requested that this has been done.
As Mr. Harrison became Chugach State Park Superintendent approximately 5 years ago, he is unaware of what restrictions have been placed on soil excavation or disturbance activities nor anything about a GW monitoring system, this has not been completed.
7. Has the State Parks maintained any signs posted at the Property by the DESC around the boundaries of the GW Development Restriction Area or the Excavation Restriction Area? Photo documentation requested of the signs at the site.
Mr. Harrison is unaware of any signs posted at the Property.
8. Has the State Parks requested in writing that the ADNR, Land Records Information Section Depict the MOA on the land, mineral, & water estates of all State land status plats that include Section 32, Township 11 North, Range 1 West, Seward Meridian, Alaska? Provide written documentation that this task has been completed & is in fact in the ADNR Land Records.
To Mr. Harrison’s knowledge, this request has not been completed.
For additional information see site file. |
Louis Howard |
6/7/2013 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 72753 name: auto-generated pm edit Defense Energy Booster Pump Station |
Louis Howard |
9/9/2014 |
Update or Other Action |
2014 Annual Sampling report received.
Three of the eleven wells sampled (MW-38, MW-45, and MW-47) exceeded DRO cleanup levels defined in the Record of Decision for Cleanup. MW-38, MW-45, and MW-47 are Type 2 APOC wells located within the contaminant plume. DRO values of these wells ranged from 1.25 to 7.35 mg/L. The data is accepted as representative of the site at the time of sampling.
In accordance with the 2011 Updated Long Term Monitoring Plan, recommendations may be made biannually for the removal of groundwater monitoring wells from the continued long term monitoring program based upon historical analytical results.
In the 2013 annual sampling event, MLFA recommended the removal and decommissioning of MW-4 and MW-11 from the long term monitoring plan for the site. Both of these wells are routinely ND for all analytes tested, and MLFA believes that MW-08 adequately provides coverage for these two monitoring well areas. Data from the 2014 annual sampling event continue to support that recommendation. |
Louis Howard |
9/16/2014 |
Document, Report, or Work plan Review - other |
Staff provided review comments on the GW report.
2.1 Groundwater Sampling
The text states: “Each well was then purged by removing at least three well volumes, or by complete evacuation, using a disposable bailer.”
ADEC will require DLA to cease collection of water samples with disposable bailers for volatile organics (i.e. BTEX, GRO, VOCs). From this point forward, low flow sampling devices will be used instead of bailers for those wells where volatiles are being sampled for (i.e. BTEX).
ADEC May 2010 Draft Field Sampling Guidance states:
“Peristaltic pumps (section D2 of Groundwater Sample Equipment) and bailers (section D1) are not the preferred method for the collection of volatiles or other air sensitive parameters. Rather the use of bladder pumps (section D3), positive pressure submersible pumps (section D4), gear pumps (section D5), passive diffusion bag samplers (section D6), or samplers like HydraSleeve (section D8) or Snap Samplers (section D9) are preferred to reduce the loss of volatiles during sampling.”
Disadvantages of bailers:
• Ball check valve function susceptible to wear, dimension distortion and silt buildup resulting in leakage in reusable bailers. This leakage may aerate succeeding sample and may gather unwanted material by rinsing unwanted material from well casing.
• Cannot provide reliable or reproducible data for air sensitive parameters, e.g., dissolved oxygen, pH, carbon dioxide or iron and its associated forms.
• Volatile organic analytical results may be biased low (due to aeration) and metals results may be biased high (due to turbidity).
These comments regarding bailer use especially apply to monitoring wells MW-8, MW-11, MW-49. ADE requests DLA sample the Interior Network Type 2 and Perimeter Network Type 1 wells again for BTEX with low-flow sampling equipment from this point forward.
5.0 Recommendations
ADEC does not concur with the recommendations to remove MW-4 MW-11 from the monitoring network at this time. ADEC will require that DLA sample MW-4 and MW-11 for, DRO, PAHs, and BTEX using low-flow sampling equipment instead of disposable bailers. If the monitoring results for two consecutive groundwater sampling events are below cleanup levels, then ADEC will reconsider DLA’s request regarding their disposition. The data from previous sampling events are suspected to be biased low based on use of disposable bailers and sampling of volatile organics.
|
Louis Howard |
11/19/2015 |
Update or Other Action |
2015 Annual Groundwater Monitoring report received for review and comment.
All eleven wells sampled had concentrations below cleanup levels defined in the Record of Decision for Cleanup. MW-30, MW-38 and MW-45, all Type 2 APOC wells, had reported DRO concentrations below the cleanup level. Well MW-8 had small estimated concentrations of fluoranthene and naphthalene, which summed together were below the TAqH cleanup level.
In the 2013 and 2015 annual sampling events, MLFA recommended the removal and decommissioning of MW-4 and MW-11 from the long term monitoring plan for the site. Both of these wells are routinely ND for all analytes tested. ADEC commented in the September 16, 2014 data review, that decommissioning will be considered if, after two consecutive groundwater sampling events using low flow sampling and bladder pumps, concentrations continue to be below cleanup levels.
This is the first sampling event performed using low flow sampling and bladder pumps. All concentrations were below cleanup levels for the first time since sampling began.
Staff approved report as submitted without changes. |
Louis Howard |
12/14/2015 |
Document, Report, or Work plan Review - other |
2015 Annual Report Defense Fuels Supply Point – Indian Dated August 21, 2015 received. Staff approved report as submitted. |
Louis Howard |
6/29/2016 |
Update or Other Action |
Draft LTM GW monitoring plan received for review and comment. Monitoring is being performed annually to evaluate the effectiveness of natural attenuation and confirm that contaminant migration does not cause unacceptable risk to human health or the environment |
Louis Howard |
7/5/2016 |
Update or Other Action |
Staff provided comments on the draft LTM GW WP.
For volatile and semi-volatile compounds (e.g. BTEX, DRO, PAHs) the purge rate shall be much slower. ADEC’s Field Sampling Guidance (May 2016) states:
“Reduce the flow rate, by adjusting the throttle control, to 100-150 milliliter (mL)/minute or less while sampling volatile and semi-volatile organics."
Please identify the laboratory under contract, any network laboratories being considered or backup laboratory that will used if the primary laboratory cannot analyze the samples. Also include all copies of the DoD ELAP current certification with expiration date for the laboratory methods being used in this work plan. Also, please supply a copy of the current ADEC approval letter. This letter will detail the methods, matrices, and dates for which the lab has approval. Labs must renew their approval and pass performance evaluation samples annually.
Provide in an appendix to the work plan:
- Laboratory specific SOPs
- Project Screening Levels and Laboratory-Specific/Quantitation Limits (similar to UFP QAPP WS #15)
- measurement performance criteria for each analytical method with data quality indicators, QC Sample or Measurement Performance Activity and Measurement Performance Criteria (similar to UFP QAPP WS # 12 Measurement Performance Criteria).
See site file for additional information.
|
Louis Howard |
1/12/2017 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft final GW Monitoring report. Monitoring wells MW-30 and MW-47 had detections above the November 6, 2016 18 AAC 75 Table C cleanup level of 1.7 ug/L (4.05 and 1.89 ug/L, respectively). These laboratory results should be bolded in Table 8. None of the BTEX contaminants exceed the revised cleanup levels. The revised cleanup levels referenced in the table shall include a footnote identifying 18 AAC 75 Table C (November 6, 2016) as the source of the cleanup levels. A cumulative risk analysis for BTEX and PAHs should be conducted (using 1/10th of Table C cleanup levels) and the results presented in the Five Year Review to demonstrate the protectiveness of the cleanup decision selected in the 1999 Record of Decision.
See site file for additional information. |
Louis Howard |
2/27/2017 |
Update or Other Action |
2nd Five-Year Review report received for review and comment.
Issues
1. One recommendation from the first FYR suggests that, “An appropriate exit strategy for the site would be to continue the LTM Plan on an annual basis. When the DRO levels are non-detects for two consecutive sampling events, the site should be considered “cleanup complete with institutional controls (ICs) on GW use & soil.”
Recommendations
1. The purpose of established cleanup levels is to provide an achievable goal that provides protection for potential receptors, without needing to attain the perhaps unachievable goal of reaching concentrations below lab detection limits. An appropriate exit strategy for the site is; When COC concentrations are below cleanup levels for two consecutive sampling events, the site should be considered “cleanup complete with ICs on GW use & soil.”
2. Reduce the sampling frequency to a five-year schedule, with the first five-year event occurring in the summer of 2021. FYR events should be performed in support of & in conjunction with FYRs, with the next FYR Report due February 2022. Sampling events should include sampling & analysis of DRO, BTEX, & PAHs for all 11 wells in the monitoring network, in general accordance with the 2016 sampling plan.
3. A DLA Project Manager should inspect the site annually & provide a letter report to the State as to the site conditions.
Other Findings
In addition, the following are recommendations that were identified during the FYR. The recommendations may improve performance of the remedy, but do not necessarily affect current &/or future protectiveness:
• In keeping with the MOA, ensure that the ADNR provides copies of the MOA, to be maintained at the two remaining buildings on site.
• Ensure that the ADNR communicates the existence of ICs to interested parties on an annual basis; specifically Chugach Electric Association, Inc., Chugach State Park employees, & the SCA.
• Ensure that signage is posted at the perimeter of the site to inform visitors of the ICs.
The remedy at the site is protective of human health & the environment. |
Louis Howard |
3/15/2017 |
Document, Report, or Work plan Review - other |
Draft-Final GW Monitoring Report Dated December 2016 received for review and comment. Monitoring wells MW-30 and MW-47 had detections above the November 6, 2016 18 AAC 75 Table C cleanup level of 1.7 ug/L for naphthalene (4.05 and 1.89 ug/L, respectively). These laboratory results should be bolded in Table 8.
In the text of the document in this section and in the ADEC Data Review Checklists, it should be noted that the coolers did not have chain of custody seals, but were within one’s physical possession and in one’s view from the time of sample collection until the time the coolers were delivered to the laboratory the same day of sample collection. In the future, all coolers shall have chain of custody tape (seals) applied regardless of whether samples were collected the same day or days later prior to receipt by the laboratory and regardless if shipped by commercial carrier or hand-delivered by sampling team the same day.
See site file for additional information. |
Louis Howard |
4/6/2017 |
Update or Other Action |
Staff provided comments on the draft 5 Year Review.
Status of Implementation
Add text that the site was assigned no further remedial action planned (NFRAP) status, which is equivalent to cleanup complete with institutional controls, as found in the November 11, 2002 [Letter from J. Frechione (ADEC) to W. Barnum (DESC)].
Recommendations
Based on the information provided and environmental records to date, ADEC concurs with the recommendations 2 and 3 in this section. The recommendations and other findings (Section 6.3) should have a table that shows who is responsible for implementing the recommendation and the milestone date by which the recommendation/finding will be accomplished.
ADEC does not concur with recommendation 1 and proposes alternate text be used which was originally submitted in the ADEC 2002 NFRAP letter to DESC :
“1. Once it is demonstrated that soil and groundwater consistently meet the applicable cleanup levels throughout the site, ADEC will close this site (i.e. “Cleanup Complete”) and require no further work, including groundwater monitoring. That will also be the appropriate time to remove any restrictions identified in the September 1999 Memorandum of Agreement.”
See site file for additional information. |
Louis Howard |
7/28/2021 |
Document, Report, or Work plan Review - other |
On 7/28/2021 ADEC approved the Long-Term Groundwater Monitoring Work Plan for the Former Indian Creek Booster Pump Station. |
Daniela Fawcett |
1/20/2022 |
Institutional Control Periodic Reporting |
On 1/20/2022 ADEC approved the Final Former Indian Creek Booster Pump Station, Indian, AK, 2021 Long-Term Groundwater Monitoring Report, Indian, Alaska, December 2021. The primary focus of this report is to summarize activities and results associated with the 2021 groundwater monitoring event. Groundwater monitoring is being performed to evaluate the effectiveness of natural attenuation and to confirm that contaminant migration is not a cause of unacceptable risk to human health or the environment. |
Daniela Fawcett |
10/11/2022 |
Long Term Monitoring Workplan or Report Review |
on 10/11/22 ADEC reviewed the 2022 Draft Third Five-Year Review, Former Indian Creek Booster Pump Station Indian, Alaska, Dated August 2022.
The purpose of a Five-Year Review (FYR) is to evaluate the implementation and performance of a remedy to determine its protectiveness of human health and the environment. In addition, FYR identifies issues found during the review, if any, and document recommendations to address them. |
Daniela Fawcett |
10/11/2022 |
Long Term Monitoring Workplan or Report Review |
on 10/11/22 ADEC reviewed the 2022 Draft Third Five-Year Review, Former Indian Creek Booster Pump Station Indian, Alaska, Dated August 2022.
The purpose of a Five-Year Review (FYR) is to evaluate the implementation and performance of a remedy to determine its protectiveness of human health and the environment. In addition, FYR identifies issues found during the review, if any, and document recommendations to address them. |
Daniela Fawcett |
10/20/2022 |
Long Term Monitoring Workplan or Report Review |
On 10/19/22 ADEC approved the 2022 Final Third Five-Year Review, Former Indian Creek Booster Pump Station Indian, Alaska, Dated October 2022.
The recommendations in this Third FYR are:
Once it is demonstrated that soil and groundwater consistently meet the ADEC Cleanup Levels (CULs) throughout the site, the site should be considered for evaluation for possible closure without institutional controls (ICs). An additional round of groundwater and soil sampling shall be conducted within one year, or at the earliest convenience of the Defense Logistics Agency, to confirm all contaminants remain below the ADEC CULs to support site closure without ICs. If the results do not meet the ADEC CUL criteria or if the recommended sampling cannot be performed before 2026, sampling of groundwater in the 11 monitoring well network should continue on a five-year schedule as agreed on in the decision document, with the next five-year event occurring in the summer of 2026. The site should be inspected annually, and inspection report submitted to ADEC until the site is approved for closure.
|
Daniela Fawcett |
1/10/2023 |
Site Characterization Workplan Approved |
DEC approved the 2023 Final Groundwater and Soil Sampling Work Plan, Former Indian Creek Booster Pump Station Indian, Alaska, Dated January 2023.
This soil and groundwater monitoring event will be conducted during summer 2023. The purpose of the sampling is to evaluate the residual concentration of the identified contaminants of concern (COC) at the site. Soil will be analyzed for gasoline range organics (GRO), diesel range organics (DRO), residual range organics (RRO), benzene, toluene, ethylbenzene, total xylenes (BTEX). Groundwater will be analyzed for BTEX, PAHs, GRO, DRO, RRO, total aromatic hydrocarbons (TAH) and total aqueous hydrocarbons (TAqH).
|
Daniela Fawcett |
12/15/2023 |
Long Term Monitoring Workplan or Report Review |
DEC provided comments for the Former Indian Creek Booster Pump Station Soil and Groundwater Sampling Evaluation Report Indian, Alaska (dated October 2023) to the Defense Logistics Agency. The report details the execution of soil and groundwater sampling activities conducted at the Former Indian Creek Booster Pump Station in April and May 2023. |
Brian Watts |
1/22/2024 |
Offsite Soil or Groundwater Disposal Approved |
DEC has approved transport and disposal of 55 gallon drum containing soil cuttings and investigative derived waste. The drum will be moved from Former Indian Booster Pump Station to Soil Treatment Technologies, Nikiski, Alaska. Signed approval letter has been sent to Defense Logistics Agency-Energy. |
Brian Watts |
1/23/2024 |
Long Term Monitoring Workplan or Report Review |
DEC provided responses to comments for the Draft Final Report Former Indian Creek Booster Pump Station Soil & Groundwater Sampling Evaluation Report to the Defense Logistics Agency. The report described additional soil and groundwater results and recommended removal of institutional controls for a Cleanup Complete, No IC's determination. |
Brian Watts |
1/26/2024 |
Document, Report, or Work plan Review - other |
DEC approved the Final Report Former Indian Creek Booster Pump Station Soil and Groundwater Sampling Evaluation Report Indian, Alaska (dated January 2024). The sampling report describes seasonal field sampling and analysis of groundwater and soil samples at the Former Indian Creek Booster Pump Station, a former Defense Energy Support Center (DESC) site near Indian, Alaska. Sampling activities were completed during April and May 2023. The soil samples resulted in 11 exceedances above DEC migration to groundwater soil cleanup levels. There were no exceedances in the 11 groundwater samples. Removal of institutional controls (ICs) has been recommended by the Defense Logistics Agency. |
Brian Watts |
5/13/2024 |
Exposure Tracking Model Ranking |
A new updated ranking with ETM has been completed for source area 72753 auto-generated pm edit Defense Energy Booster Pump Station. |
Brian Watts |
3/10/2025 |
Exposure Tracking Model Ranking |
A new updated ranking with ETM has been completed for source area 72753 Defense Energy Booster Pump Station. |
Juliana Smit |
4/14/2025 |
Workplan Requested |
DEC requested a work plan for the decommissioning of the monitoring wells associated with the long-term monitoring activities at Indian Booster Pump Station in preparation for closing the site without institutional controls. |
Juliana Smit |