| Action Date |
Action |
Description |
DEC Staff |
| 4/30/1987 |
Update or Other Action |
Facility ID 0-000788 500 gallon used oil Underground Storage Tank (UST) 14, Bldg 740, located at the intersection of D Street and First Street, was removed and replaced with a new UST in 1987. During excavation total petroleum hydrocarbon (TPH) contamination was encountered in the soil at up to 1,080 parts per million (ppm). |
Louis Howard |
| 12/30/1988 |
Update or Other Action |
UST Database shows a 1,000 gallon UST # 14 at Bldg. 740 DEH Maintenance to be leaking. It was installed in 1975 and is in use. |
Ron Klein |
| 4/5/1991 |
Enforcement Agreement or Order |
RCRA Federal Facility Compliance Agreement signed. On 6/8-9/89 inspection by EPA and ADEC of the Post to determine its compliance status with RCRA. Two 55 gallon containers, half full with spent solvent were noted. One container was adjacent to the dip tank and the other was just outside of the back door. An adequate hazardous waste determination has not been made on the contents of these two drums of solvent, in violation of 40 CFR 262.11 and paragraph 21.A. of the FFCA.
Neither container was labeled "hazardous waste" nor had the accumulation start date clearly marked on the container, in violation of paragraphs 21.C. and 21.D. of the FFCA. These recyclable materials were not being managed in accordance with 40 CFR 261.6(b), which requires that 40 CFR 262.34(a) be complied with for generators.
Required compliance action- Fort Richardson shall determine if its waste located at building 740 is a hazardous waste and comply with 40 CFR 262.11. Fort Richardson shall obtain a detailed chemical and physical analysis of a representative sample of waste or use knowledge of the waste to determine if wastes are hazardous wastes, as required by 40 DFR 262.11, 40 CFR 265.13(a)(1) and 40 CFR 268. |
Tim Law |
| 6/12/1991 |
Update or Other Action |
June 12, 1991 Resource Conservation & Recovery Act (RCRA) HW Management Compliance Evaluation Inspection Report documents Tim Law, Daniel Hartung, Vic Vickaryous, Geoffrey Kany, of ADEC's RCRA program inspection the Post for compliance with the provisions of the compliance agreement (FFCA) on April 29, April 30, 1991
Building 740 - DEH Mobile Equipment Repair/welding/Machine Sheet Metal Shops
Mr. Frank Faust and Mr. Gary Skaggs were present to show the inspection team around Building 740. Observed were two 55-gallon containers both approximately half full with spent solvent. One container was adjacent to the dip tank and the other was just outside of the back door. This solvent has a flash point of 110 degrees F as a product, according to the MSDS sheet that Mr. Faust showed Mr. Kany. An adequate hazardous waste determination has not been made on the contents of these two drums of solvent, in violation of 40 CFR 262.11 and Paragraph 21.A. of the FFCA.
This OEH operation normally brings their spent solvent over to the SPERS Shop in Building 974 for reclamation when the containers become filled with·spent solvent. Neither container was labeled "hazardous waste" nor had the accumulation start date clearly marked on the container, in violation of Paragraphs 21.C. and 21.0. of the FFCA. These recyclable materials were not being managed in accordance with 40 CFR 261.6(b), which requires that 40 CFR 262.34(a) be complied with for generators.
The fenced-in waste accumulation point out behind Building 740 had containers of "contaminated diesel", "contaminated fuel", and "contaminated antifreeze." Ms. Scott insisted that all of these materials would be reutilized without having to be first treated or filtered; such that they do not have to be accumulated as regulated hazardous waste. |
Tim Law |
| 9/21/1993 |
Update or Other Action |
A.G. letter (Breck Tostevin) to Tamela J. Tobia, OS Judge Advocate for the Army. Letter states that a separate petroleum site compliance agreement should be separate from the CERCLA federal facility agreement. The petroleum site restoration agreement would function as a "two-party agreement" under the FFA. It would track the basic provisions of the UST Agreement but be tailored to the State's contaminated site regulations and would interface with the FFA. All petroleum sites addressed under the Two Party agreement would be reviewed in the final operable unit of the FFA and actions taken would be memorialized in a Record of Decision (ROD) under the FFA. |
Louis Howard |
| 10/17/1993 |
Site Characterization Report Approved |
Release investigation showed diesel contaminated soils at site above matrix Level "C" criteria. The only contaminants of concern are diesel range organics (DRO) and TPH, at up to 7,400 ppm and 12,733 ppm, respectively. These contaminants, above the allowable contaminant levels specified in 18 AAC 78, were discovered down to 33.5 feet below ground surface (bgs). All other contaminants including gasoline, benzene, toluene, and tetrachloroethylene met acceptable risk based concentrations.
A leaching assessment shows that contaminants will not reach groundwater. Recommend close out site with institutional controls. |
Louis Howard |
| 11/12/1993 |
Enforcement Agreement or Order |
State-Fort Richardson Underground Storage Tank Compliance Agreement signed by the ADEC and the U.S. Army. Purpose of the agreement is to bring Fort Richardson into compliance with Underground Storage Tank (UST) regulations and avoid the expense of formal enforcement proceedings. The Army agrees to perform the necessary inventory, record keeping, registration, upgrading or closure, tightness testing, site assessment, release reporting, release investigation, and corrective action (remediation) associated with USTs at Fort Richardson (excluding Alaska Department of Military and Veterans Affairs and Army National Guard USTs). Listed in Attachment B as requiring a release investigation plan for UST 14. |
Louis Howard |
| 5/17/1994 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the April 1994 Draft Release Investigation report, Former UST 14 Building 740 Contract No. DACA85-93-D-0013, Fort Richardson, Alaska.
The Alaska Department of Environmental Conservation-Defense Facilities Oversight group (ADEC) has received, on May 6, 1994, a copy of the above referenced report for building 740. Below are our comments regarding the report.
2.2 Geology and Hydrogeology pages 5 and 6
The text states there is one well AP-2980 located within one-quarter mile of the site completed in 24 feet with groundwater at 23 feet. The exact location could not be determined by looking at the post map (fig. 1) or any other figure listed in the report. Please provide the information on its exact location in relation to the site.
5.2 Evaluation of Potential Remedial Alternatives page 36
While the numerical leaching model MMSOILS predicts that petroleum impacted soil will not
present a danger to the groundwater through leaching, ADEC will require additional measures beyond capping with asphalt material in order to ensure the groundwater is not impacted. Prior to ADEC accepting the no further remedial action alternative, the Army will be required to install a monitoring well located downgradient from the site. Downgradient will be assumed to mean in a westerly direction from the site based on information presented in section 2.2 of the report.
The well will be sampled for petroleum hydrocarbon contaminants-Leo diesel range organics,
gasoline range organics, BTEX, and total petroleum hydrocarbons. If groundwater sampling from the monitoring well shows no petroleum impacts and the site is capped with asphalt material, then ADEC will consider the site closed out. Closing out of this site does not limit nor preclude ADEC from requesting future remediation or site investigation at a later date.
If new information indicates that there is previously undiscovered contamination or exposures that may cause an increased risk to human health or the environment, then future investigation and/or remedial actions may be required by ADEC. It is recommended that the new monitoring well be added to the existing Fort Richardson groundwater monitoring network for regular sampling. |
Louis Howard |
| 5/31/1994 |
Update or Other Action |
Due to the high levels of diesel range organics (DRO) and total petroleum hydrocarbons (TPH) at the site, ADEC requested installation of a groundwater monitoring well, number AP-3532, to confirm contamination did not extend to groundwater. Neither DRO or TPH were discovered. However, groundwater samples contained chloroform and carbon tetrachloride above the maximum contaminant levels (MCL)/risk based concentrations (RBC) of 0.16 parts per billion (ppb) and 0.15 ppb, respectively. Soil samples taken during installation of the groundwater monitoring wells showed no evidence of carbon tetrachloride or chloroform contamination, indicating that UST 14 was not the source of these contaminants. |
Louis Howard |
| 2/5/1995 |
Update or Other Action |
Letter from Army to ADEC.
On January 13, 1995, you met with Mr. Samuel P. Swearingen, and Major Kevin Gardener of the Environmental Compliance Branch. At this time you requested an explanation for the lack of spill protection on a number of underground storage tanks(UST) located at Fort Richardson. Below you will find a listing of those regulated tanks that were in question and an explanation of how the spill control requirement is met:
Tank#14A- This is a used oil USTwith an ILS-350 interstitial monitor/overfill alarm system. The tank's spill control system consists of a catchement basin/floor drain system attached to an oil water separator. The tank is filled through manually pouring oil into either one of the floor drains or into an oil sink. The system is non-pressurized, and gravity fed. |
Louis Howard |
| 12/13/1995 |
Update or Other Action |
The Army sent ADEC a letter-SUBJECT: Closure UST Sites for UST Number 14(Bldg 740) and UST Number 27(Bldg 796)
As requested in your letters dated 17 May 1994, and 16 May 1994 groundwater wells were installed at Bldg 740 and 796, respectively. Once installed the wells were to be sampled to determine if the underground storage tanks (UST) number 14 and 27, at Bldg 740 and Bldg 796, respectively, had impacted the groundwater. These wells numbered AP-3532 (Bldg 740) and AP-
3533 (Bldg 796) were sampled and the results reported by the Alaska District Corps of Engineers in the "GROUNDWATER STUDY: FALL 1994 & SPRING 1995, FORT RICHARDSON, ALASKA" report. Based upon the samples analyzed chloroform and carbon tetrachloride were detected at Bldg 740 at 1.6
and 1.4 ug/L, respectively. At Bldg 796 these contaminants were detected at 0.2 and 1.6 ug/L, respectively.
While these analytes exceed their respective risk based concentration (RBC) levels, there is no evidence to suggest that these compounds were ever stored in either UST. Furthermore, neither chloroform nor carbon tetrachloride were detected in any of the soil boring samples taken during UST release investigations conducted at these sites. It appears, therefore, that the
groundwater is being impacted by a contaminant plume of unknown origin, that is not associated with either UST.
USARAK requests that contaminated soils associated with USTs 14 and 27, be granted closure under 18 AAC 78. Wells AP-3532 and AP-3533, along with other wells in the general area, will be resampled in the first quarter of 1996 to attempt to identify the upgradient source of the chloroform and carbon tetrachloride. Any corrective action taken to address groundwater contamination, if deemed necessary, would be conducted under the Fort Richardson-EPA-ADEC Federal Facility Agreement. |
Louis Howard |
| 5/8/1996 |
Institutional Control Record Established |
Based on the information submitted and the data from the monitoring wells installed at the sites (Buildings 740 UST 14 and Building 796 UST 27), it appears the detected contaminants (carbon tetra chloride/chloroform) were not from the two underground storage tank sites. ICs are required since level of soil contaminated with petroleum is above those levels which would allow for unrestricted use.
Dig permit required for any soil activity in area managed by Public Works Environmental staff. Area noted on Post Management plans and maps as an area requiring ICs and waste management and disposal at a permitted facility if soil were to be excavated at any time in the future.
Closure of the sites under the UST Management Plan Agreement is granted by ADEC. As a part of ADEC's conditions to granting closure, ICs restricting any access to the groundwater and contaminated soils at the site will be required. The closure does not preclude future remediation or site investigation if new information indicates there is previously undiscovered contamination from the USTs or exposures which cause unacceptable risk to human health or the environment.
Future investigation and/or remedial actions may be required if contamination exceeding these risks are detected or if the contamination at either site (740 and 796) is excavated by the Army (or its contractors, tenants, or lease holders) for any reason in the future. ADEC reserves all of its rights under Title 46 of the Alaska Statutes and 18 AAC 78 to request additional activities in the future if necessary to address these risks. ADEC requests the monitoring wells installed at the sites be added to the post-wide ground water monitoring network to be established under the CERCLA FFA.
ADEC concurs with the request to address the groundwater contamination as a part of Operable Unit D. Because this remedy will result in hazardous substances remaining on site above levels that allow for unlimited use and unrestricted exposure, a review will be conducted within five years after commencement of remedial action to ensure that the remedy continues to provide adequate protection of human health and the environment. |
Louis Howard |
| 5/8/1996 |
Conditional Closure Approved |
Release investigation showed diesel contaminated soils at site above matrix Level "C" criteria. Leaching assessment shows that contaminants will not reach groundwater. Site closed out with access restrictions to soil and groundwater. Closing out the site does not preclude ADEC from requesting future remediation or site investigation at a later date. If new information indicates that previously undiscovered contamination or exposures lead to groundwater contamination above the applicable water quality criteria (18 AAC 70) or pose a risk to human health, wildlife or the environment, then future investigation and or remedial actions will be required by ADEC.
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.
The off site disposal of all other soil subject to the site cleanup rules that does not meet the criteria above shall be reviewed by the ADEC project manager in order to determine if the off-site disposal action poses a current or future risk to human health or the environment. The final approval to dispose of soil off site that does not meet the criteria shall be made by the ADEC Section Manager.
Terms used in this document have the meaning given in 18 AAC 75.990 including: “environmentally sensitive area” means a geographic area that, in the department's determination, is especially sensitive to change or alteration, including:
(A) an area of unique, scarce, fragile, or vulnerable natural habitat;
(B) an area of high natural productivity or essential habitat for living organisms;
(C) an area of unique geologic or topographic significance that is susceptible to a discharge;
(D) an area needed to protect, maintain, or replenish land or resources, including floodplains, aquifer recharge areas, beaches, and offshore sand deposits;
(E) a state or federal critical habitat, refuge, park, wilderness area, or other designated park, refuge, or preserve; and
(F) an area that merits special attention as defined at 6 AAC 80.170 (Repealed see AS 46.40.210(1))
“area which merits special attention” means a delineated geographic area within the coastal area which is sensitive to change or alteration and which, because of plans or commitments or because a claim on the resources within the area delineated would preclude subsequent use of the resources to a conflicting or incompatible use, warrants special management attention, or which, because of its value to the general public, should be identified for current or future planning, protection, or acquisition; these areas, subject to council definition of criteria for their identification, include:
(A) areas of unique, scarce, fragile or vulnerable natural habitat, cultural value, historical significance, or scenic importance;
(B) areas of high natural productivity or essential habitat for living resources;
(C) areas of substantial recreational value or opportunity;
(D) areas where development of facilities is dependent upon the utilization of, or access to, coastal water;
(E) areas of unique geologic or topographic significance which are susceptible to industrial or commercial development;
(F) areas of significant hazard due to storms, slides, floods, erosion, or settlement; and
(G) areas needed to protect, maintain, or replenish coastal land or resources, including coastal flood plains, aquifer recharge areas, beaches, and offshore sand deposits. |
Louis Howard |
| 8/19/1997 |
Update or Other Action |
Memorandum from Army for Institutional Controls for soil and groundwater at Building 740. 1. Attached find a map delineating the area covered by institutional controls at Bldg 740, the Decision Document for Bldg 740, and the State of Alaska, Department of Environmental Conservation (ADEC) concurrence with using institutional controls to control contaminated soils and groundwater at Bldg 740.
2. Underground storage tank (UST) 14, Bldg 740 was incorporated in the Fort Richardson-ADEC UST Compliance Agreement in 1993, making investigation and corrective action at this site enforceable under 18 Alaska Administrative Code (AAC) 78 and 40 CFR 280. Any excavation, required for facility maintenance, within the area indicated on the above referenced map shall be coordinated with the Fort Richardson Environmental Coordinator. The Environmental Coordinator shall ensure proper worker personnel protective equipment selection. Further, the Environmental Coordinator shall ensure that any contaminated soils encountered are properly managed and, if necessary, disposed of in accordance with all relevant and appropriate regulations.
3. Both carbon tetrachloride and chloroform have been detected in groundwater monitoring wells in the vicinity of Bldg 740. Groundwater wells, other than for environmental monitoring purposes, shall not be drilled at this site. Failure to inform the Environmental Coordinator may result in violation of 18 AAC 78, the FRA-ADEC UST Compliance Agreement and 40 CFR 280, resulting in fines already stipulated in the Agreement. |
Louis Howard |
| 12/17/1997 |
Site Added to Database |
Petroleum contamination. |
Louis Howard |
| 4/21/1998 |
Site Ranked Using the AHRM |
Ranking action added now because it was not added when the site was originally ranked. |
Bill Petrik |
| 9/14/2001 |
Update or Other Action |
Update to Post-wide review of institutional controls received which includes this site. Soil contamination has been secured under an asphaltic cap, removing the potential for direct dermal exposure, and inhalation, or ingestion of contaminated dust or soils. There are no potable water wells within one mile radius of Building 740, with no current plans to have one installed. Any maintenance or construction activity involving excavation or drilling on Fort Richardson requires a site specific "work authorization permit". Each permit application is checked by the Environmental Resources Department against known ICs and contaminated sites. Enforcement of ICs and "Dig Permit" requirements will ensure that potential exposure of workers or other personnel at this site to residual soil contaminants is minimized through selection and use of personnel protective equipment (PPE) appropriate to the contaminants at the site.
Because this remedy will result in hazardous substances remaining on site above levels that allow for unlimited use and unrestricted exposure, a review will be conducted within five years after commencement of remedial action to ensure that the remedy continues to provide adequate protection of human health and the environment. |
Louis Howard |
| 12/12/2001 |
Update or Other Action |
1. All organizations conducting activities on United States Army Alaska (USARAK) controlled land are responsible for complying with established institutional controls (ICs). ICs are administrative, procedural, and regulatory measures to control human access to and usage of property. They are applicable to all known or suspected contaminated sites where contamination has been left in place.
2. These controls have been established to implement the selected remedial actions agreed upon by the U.S. Army (Army), the U.S. Environmental Protection Agency (USEPA), and the Alaska Department of Environmental Conservation (ADEC) in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) as amended by the Superfund Amendment Reauthorization Act (SARA). These controls also apply to remedial actions agreed upon under Two-Party Compliance Agreements. These agreements are concluded between USARAK and ADEC and apply to petroleum/oil/lubricants- (POL) contaminated sites.
3. ICs such as limitations on access, water use, excavations, and property transfers will supplement engineering controls as appropriate for short-term and long-term management to prevent or limit human and environmental exposure to hazardous substances, pollutants, or contaminants. Specific ICs include, among other things: limitations on the depth and location of excavations, prohibition of or restrictions on well drilling and use of ground water, requirements for worker use of personal protective equipment, site monitoring, and prohibition of certain land uses, types of vehicles, etc.
4. Organizational units, tenants, and support/contractor organizations must obtain an Excavation Clearance Request (ECR) for all soil disturbing activities impacting soils six inches or more below the ground surface. The review process for approval of an ECR begins with the identification of the current status (known or suspected hazardous waste site or “clean” site) of a work location. ECR’s for work in known or suspected hazardous waste sites:
a. will include specific limitations and controls on such work;
b. will include specific IC procedures, and notification, monitoring, reporting, and stop work requirements;
c. may include procedures for management, characterization, and disposal of any soil or groundwater encountered or removed;
d. will identify “project managers” for both the unit/contractor requesting the work and DPW Environment Resources.
5. The DPW project manager will conduct on-site inspections of each work site (at which ICs apply) to determine continued compliance with the terms and conditions of the approved ECR. DPW has the authority to revoke ECR approval if the specified terms and conditions are not being met. ECR forms are available at the Customer Service Desks at: a. Building 730 at Fort Richardson; b. Building 3015 at Fort Wainwright; c. Building 605 at Fort Greely.
6. USARAK has negotiated (with USEPA and/or ADEC) decision documents and/or Records of Decision (RODs) that mandate the implementation of ICs USARAK Directorate of Public Works, Environmental Resources Department (PWE), maintains copies of all decision documents and RODs requiring ICs in its real property files. PWE provides regularly updated post maps showing all areas affected by ICs. These maps can easily be accessed by using an approved intranet mapping interface application. Copies of these maps will be available to each directorate, activity, and tenant organization. To ensure the effectiveness of ICs, all organizational units and tenant activities will be informed on an annual basis of ICs on contaminated soils and groundwater in effect near their facilities.
7. ICs are enforceable by the U.S. Environmental Protection Agency (USEPA) and the Alaska Department of Environmental Conservation (ADEC). Failure to comply with an IC mandated in a decision document or ROD will violate the USARAK Federal Facility Agreement and may result in stipulated fines and penalties. This does not include the costs of corrective actions required due to violation of an established IC.
|
Louis Howard |
| 8/29/2007 |
GIS Position Updated |
61.259 N latitude -149.7074 longitude |
Louis Howard |
| 6/10/2013 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 72768 name: auto-generated pm edit Ft. Rich Bldg. 740 UST 14 DPW Maint |
Louis Howard |
| 7/31/2013 |
Update or Other Action |
Draft UFP-QAPP received for review and comment.
The overall objective for the site is to meet “unrestricted or residential site use” criteria and achieve a “cleanup complete without institutional controls (ICs)” determination. To meet this objective, soil and groundwater samples will be collected to characterize risk to human health and the environment within the framework of the ADEC site cleanup process (Title 18 Alaska Administrative Code Chapter 75 [18 AAC 75] Sections 325 to 390 and 18 AAC 78 Section 600)
(ADEC, 2012a; ADEC, 2012b). If ADEC Method Two cleanup criteria as established under
18 AAC 75 are exceeded, the Hydrocarbon Risk Calculator (HRC) approach under Method
Three will be used to assess whether site conditions meet ADEC risk criteria (in which case, a
“cleanup complete without ICs” determination will be requested) or whether the site poses
unacceptable risk (in which case, further remediation may be required).
If unacceptable risk is indicated by the HRC, or if vadose zone soils exceed maximum allowable
concentrations, then remedial options will be evaluated that address the contaminants of concern
and associated exposure routes that contribute enough risk to cause the cumulative risk estimate
to exceed the risk standard.
At TU064, four new soil borings will be drilled as shown on Figure 3 and discussed in the
following list:
Two borings will be drilled at former borings AP-3268 and AP-3271 to accomplish the
following: (1) resample the soil at the location and depth where previous sampling showed
the maximum exceedances of the migration to groundwater criteria for DRO and residualrange
organics (RRO); and (2) collect source area soil samples for analysis of GRO, polycyclic aromatic hydrocarbons (PAHs), volatile petroleum hydrocarbons (VPH), and extractable petroleum hydrocarbons (EPH).
Two borings will be drilled west and south of the former tank to assess the lateral extent of
contamination.
Up to approximately 24 primary soil samples will be collected and analyzed for DRO, RRO,
PAHs, and VOCs (BTEX plus naphthalene [BTEXN]). Three of the soil samples will also be analyzed for GRO, EPH and VPH. One of the soil samples will be analyzed for soil bulk density, grain size distribution, specific gravity, and soil moisture content. One of the soil samples will be collected from below the contaminated soil source and analyzed for fraction of organic carbon.
Groundwater will be collected from existing onsite monitoring well AP-3532 if it is viable and contains sufficient water for purging. The collected groundwater will be analyzed for GRO, DRO, RRO, ethylene dibromide, VOCs (BTEXN), and PAHs. |
Louis Howard |
| 8/30/2013 |
Document, Report, or Work plan Review - other |
Staff provided review comments on the draft work plan.
Executive Summary
Page ES-3
Site-Specific Proposed Work
It should be noted that sites with existing contaminated GW will require that migration to GW cleanup levels be used for soil & ICs will be required. Once GW is below Table C for a period of time (consistent with & per the latest approved “Basewide Monitoring Program Well Sampling Frequency Decision Guide (Attachment 1 Memo to the Site File for OUs 4, 5, & 6 September 2003)” two rounds annual GW monitoring), the maximum allowable concentrations in soil may become the cleanup levels as determined by ADEC on a case by case basis.
The text states: “Up to approximately 24 primary soil samples will be collected & analyzed for DRO, RRO, PAHs, & VOCs (BTEX plus naphthalene [BTEXN]).”
All VOCs will be required to be reported in addition to BTEXN due to PCE being found an order of magnitude above the cleanup level in the location of UST #14.
Tetrachloroethylene (PCE) was detected in sample 93FRU108SL above the migration to GW cleanup level of 0.024 mg/kg at 0.29 mg/kg (4.2.2 Volatile Aromatic Organic Compounds (Method 8010/8020) Page 21, EMCON Final RI Report Former UST No. 14 Bldg. 740 July 12, 1994).
This PCE soil result cannot be discounted & ignored as part of this site characterization.
Both ADEC required methanol preserved soil samples & EPA’s low-level analysis with SW8260 for VOCs shall be used at this site investigation associated with the former waste oil UST (UST 14). NOTE: EPA no longer accepts sodium bisulfate preserved samples for SW8260; instead use VOC/VOA vials with a water carrier.
GW analysis will need to include VOCs (specifically PCE & its daughter products since it was detected in the soil above migration to GW cleanup levels & UST 14 is the source of the contamination). ADEC requests clarification on whether or not sampling for ethylene dibromide (EDB) was conducted at the site during GW monitoring. EDB analysis is required for used oil sources per ADEC’s Draft Field Sampling Guidance (May 2010). This guidance document updates & expands the sampling procedures currently found in the Underground Storage Tank (UST) Procedures Manual, adopted by reference in the 18 AAC 78 regulations. EDB analysis with either method 8011 or 504.1 must be used to quantify EDB in GW. Method 8260 will quantify EDB in GW; however, the detection limits do not meet the Table C cleanup level of 0.00005 mg/L.
Historical Soil Boring Location & Results – Building 740
Please locate sample location, depth & result for sample 93FRU108SL on the figure (e.g. AP-3268 10’ bgs 0.29 mg/kg).
Conceptual Site Model
Land Use Considerations
The text states: “Concentrations of petroleum hydrocarbons in soil at TU064 exceed ADEC’s cleanup levels for unrestricted use.” This is partially true. A more correct statement would be: “Concentrations of petroleum hydrocarbons & PCE in soil at TU064 exceed ADEC’s cleanup levels for unrestricted use.”
Page 20
Data Gaps
3rd Bullet
VOCs beyond petroleum related VOC data for soils need to be reported (e.g. PCE & all potential daughter products). See comment #1 regard SW8260 methanol & low-level analysis sampling requirements for soil.
GW analysis will need to include VOCs (specifically PCE & its daughter products since it was detected in the soil above migration to GW cleanup levels & UST 14 is the source of the contamination).
Project Action Limits & Laboratory-Specific Detection/Quantitation Limits
Target Analyte List
VOCs beyond petroleum related VOC data for soils need to be analyzed for & reported (e.g. PCE & all potential daughter products). See comment #1 regard SW8260 methanol & low-level analysis sampling requirements for soil.
As a waste oil source, ADEC requests information on whether GW was ever sampled for EDB with an appropriate method with a detection limit below the Table C cleanup level of 0.00005 mg/L. EPA 8011 or EPA 504.1 should be used when evaluating ethylene dibromide (EDB).
EPA 8260 will quantify EDB in ground water; however, the detection limits do not meet the Table C cleanup level of 0.00005 mg/L (ADEC Draft Field Sampling Guidance Appendix F May 2010). If EDB is not detected in GW as part of this sampling for TU064, then it can be removed from consideration as a contaminant of concern.
Project Soil Screening Levels
VOCs
Add PCE & all potential daughter products to the table for VOCs.
Project GW Screening Levels
VOCs
Add PCE & all potential daughter products to the table for VOCs. Add EDB (ethylene dibromide or 1,2-Dibromomethane CAS Number 106-93-4).
|
Louis Howard |
| 1/12/2015 |
Update or Other Action |
Draft Site Characterization Report received for review and comment.
The following conclusions were made regarding TU064:
• Based on previous investigations and the 2013/2014 site characterization field investigation,
DRO, benzene, PCE, benzo(a)pyrene, and TCE were detected above screening levels at the site and are considered COPCs. Historical detections of GRO and RRO were not observed in the 2013 and 2014 results.
• There are three source areas of contamination at TU064: a large area of petroleum contaminated
surface soil mixed with various VOCs from surface spills associated with Building 740 operations; a smaller area of subsurface soil contaminated with petroleum hydrocarbons (DRO) mixed with various VOCs originating from the former leaking UST; and a very small area north of the surface petroleum contamination where only concentrations of TCE are present in soil above the screening levels, suggesting a possible separate surface spill. The surface and subsurface soil contaminated with petroleum hydrocarbons and VOCs overlap near the former UST, and as such is treated as one continuous area of contamination.
• The aerial extent of petroleum (DRO-) contaminated soil (the highest detected and most widespread COPC) is approximately 80 feet long and 80 feet wide centered around the former UST area, and extends from the ground surface to a total depth of approximately 30 feet bgs (approximately 190,000 cubic feet or 7,100 cubic yards). Contamination has been laterally and
vertically defined for all analytes.
• A groundwater sample collected from existing monitoring well AP-3532 was reported to contain a carbon tetrachloride concentration of 0.71 µg/L, which is above the project screening level of 0.50 µg/L, but was well below the ADEC Table C cleanup level of 5 µg/L. The groundwater contamination observed in monitoring well AP-3532 does not appear to be associated with soil contamination observed at TU064.
• Using the HRC for soil and groundwater within the petroleum contaminated area, the cumulative carcinogenic risk and noncarcinogenic HI estimates, based on both industrial and hypothetical residential exposure scenarios, are below the regulatory risk standards for soil direct contact/ingestion, outdoor air inhalation, and groundwater ingestion.
• Using the HRC for soil and groundwater within the petroleum contaminated area, potential risks posed by the GRO, DRO, and RRO aromatic and aliphatic fractions are below the regulatory risk standard of 1 for direct contact, outdoor inhalation, and groundwater ingestion pathways. Therefore, the site meets the ADEC risk criteria for bulk hydrocarbons.
Using the online Method Three and Cumulative Risk Calculator for soil within the TCE
contamination area, cumulative carcinogenic risk and noncarcinogenic HI estimates meet the
regulatory risk standards for all scenarios.
• TCE, PCE, and benzene were detected above 18 AAC 75.342(c) Table B1 Soil Cleanup Levels in soil within 100 feet of Building 740. Therefore, the vapor intrusion exposure pathway is currently complete. Risks from the vapor intrusion exposure pathway have not been quantitatively evaluated.
• No potential risks to ecological receptors were observed for TU064, and potentially complete
ecological exposure pathways at TU064 are considered insignificant. The site achieved the
“off-ramp” in Part 3, Habitat, of the Ecoscoping form (see Appendix D).
The following are recommended for TU064:
• No further investigation is necessary to characterize the nature and extent of COPCs present
in soil at TU064.
• No remedial action is necessary for the petroleum hydrocarbons present at TU064.
• Though Building 740 is currently unoccupied, if the occupational status of the building
changes, further evaluation will be necessary to assess possible vapor intrusion risk from TCE,
PCE, and benzene in soil. |
Louis Howard |
| 1/29/2015 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft SC report. The status shall remain unchanged at “Cleanup complete with institutional controls”.
Contaminants of Concern
Diesel range organics (DRO), benzene, trichloroethylene (TCE) & tetrachloroethene (PCE).
Cleanup Levels
The cleanup level for soils at TU064 containing DRO is 10,250 mg/kg in the Under 40-inch Zone based on the ingestion pathways within the 0 to 15’ interval below ground surface (bgs). The cleanup level for soil containing benzene is 0.025 mg/kg in the Under 40-inch Zone based on the migration to GW pathway. The cleanup level for soil containing TCE is 0.020 mg/kg in the Under 40-inch Zone based on the migration to GW pathway. The cleanup level for soil containing PCE is 0.024 mg/kg in the Under 40-inch Zone based on the migration to GW pathway.
In 2014, DRO was measured up to 3,790 mg/kg at TU064-SB07 (adjacent to AP-3268) near the former UST location, at a depth of 15 to 20 feet bgs. Benzene was detected above the migration to GW cleanup level of 0.025 mg/kg in the soil collected from the ground surface to 5 feet bgs in TU064-SB01 at 0.0272 mg/kg, & in the soil collected from 10 to 15 feet bgs in TU064-SB07 at 0.0314(J) mg/kg. TCE was observed above the migration to GW cleanup level (0.02 mg/kg) ranging from 0.028(J) mg/kg in TU064-SB07 at 5 to 10 feet bgs to 0.0611 mg/kg in TU064-SB01 at 10 to 15 feet bgs. The only detections of PCE in soil above the migration to GW cleanup level (0.024 mg/kg) were between 0 & 15 feet bgs in 2014 soil boring TU064-SB07 at concentrations ranging from 0.0325 mg/kg (at 0 to 5 feet bgs) to 0.299 mg/kg (at 5 to 10 feet bgs), & at 10 feet bgs in historical soil boring AP-3268 at a concentration of 0.29 mg/kg.
There were no exceedences of Table C cleanup levels for any contaminant of concern from the well sampled at TU064. GW was measured at approximately 110 feet bgs during the 2013 sampling event. The local GW is known to flow toward the northwest. The nearest drinking water well is 1.25 miles south-southwest of TU064.
TCE & PCE were detected above 18 AAC 75.342(c) Table B1 Soil Cleanup Levels in soil within 100 feet of Building 740 & within 100’ of the ground surface. Therefore, the vapor intrusion (VI) exposure pathway is potentially complete. Risks from the VI exposure pathway have not been quantitatively evaluated. The building is currently unoccupied & should the building become occupied or used on an intermittent, temporary or permanent basis, it will be necessary for the Air Force to assess possible vapor intrusion risk from TCE, PCE & benzene in the soil as soon as possible.
ADEC considers this issue a high priority, especially given the recent EPA 2012 TCE memorandum regarding cancer risk, chronic noncancer & short-term non-cancer effects from exposure to TCE indoor air contamination by women child bearing age for commercial/industrial buildings.
An ecoscoping form was completed for TU064 & no observed surface soil staining, no impacted vegetation, no surface water or sediment runoff from the site. The ecoscoping form indicates that a more in-depth risk evaluation is not needed & that the TU064 site conditions are protective of the environment.
Based on a review of the environmental records, ADEC has determined that TU064 has been adequately characterized, however, institutional controls (ICs) will remain in place. ADEC is issuing this written determination that cleanup is complete with ICs subject to a future department determination that the cleanup is not protective of human health, safety, welfare, or of the environment [18 AAC 75.380(d)].
Additionally, JBER shall establish an IC signifying the need to quantitatively assess vapor intrusion (VI) if the building occupancy changes, the building is used for any purpose by individuals (i.e. infrequent, short term, temporary or permanent basis) or new construction is planned because of the potential future exposure through the indoor air pathway from contaminated soil. A “cleanup complete with ICs” designation will remain in place for TU064 in the Contaminated Sites Database.
1. Any proposal to transport soil or GW off-site from TU064 requires ADEC approval in accordance with 18 AAC 75.325. A “site” [as defined by 18 AAC 75.990 (115)] means an area that is contaminated, including areas contaminated by the migration of hazardous substances from a source area, regardless of property ownership (see figure below).
2. Movement or use of contaminated material in a manner that results in a violation of 18 AAC 70 water quality standards is prohibited.
3. Notations of these requirements shall be made on the Environmental Restoration map/ Base General Plan which will show up during a dig permit review/work clearance request process.
|
Louis Howard |
| 11/30/2017 |
Update or Other Action |
Draft VI report received for review and comment. Benzene, PCE, and TCE were detected in indoor air during FSE1 and FSE2, and in outdoor air during FSE2. PCE and TCE were not detected in outdoor air during FSE1. Indoor air concentrations were higher than outdoor air concentrations during both sampling events. Benzene and PCE were the only COIs detected in soil gas during FSE1. There is no spatial bias apparent in the locations of the COI detections in ambient air or soil gas. The presence of benzene and PCE in soil gas and indoor air suggest the potential presence of a complete VI pathway. Based on the above lines of evidence, the VI pathway is considered potentially complete at Building 740.
See site file for additional information. |
Louis Howard |
| 4/12/2021 |
Document, Report, or Work plan Review - other |
DEC submitted comments on Draft JBER Basewide UFP-QAPP dated February 2021. |
William Schmaltz |
| 5/19/2021 |
Document, Report, or Work plan Review - other |
DEC Reviewed and approved of Basewide Uniform Federal Policy - Quality Assurance Project Plan. QAPP summarizes general activities for a 5 year period on JBER. |
William Schmaltz |
| 2/7/2023 |
Document, Report, or Work plan Review - other |
DEC reviewed the 2023 Letter Work Plan Remedial Action Operations and Long-Term Management, Draft, dated January 2023. The work plan describes the site inspections, maintenance activities, and groundwater, seep, and surface water monitoring, at multiple sites located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. The scope of work briefly summarizes the site locations, sampling/monitoring schedules, and activities such as free-product removal from monitoring wells and monitoring/maintenance activities at the Operable Unit 5 wetlands. The details regarding the procedures for the remedial action operations and long-term management activities will remain consistent with the 2021 Uniform Federal Policy Quality Assurance Project Plan (UFP-QAPP). |
Ginna Quesada |
| 4/25/2023 |
Document, Report, or Work plan Review - other |
DEC approved the 2023 Letter Work Plan Remedial Action Operations and Long-Term Management, Final, Dated April 2023. The work plan describes the site inspections, maintenance activities, and groundwater, seep, and surface water monitoring, at multiple sites located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. The scope of work briefly summarizes the site locations, sampling/monitoring schedules, and activities such as free-product removal from monitoring wells and monitoring/maintenance activities at the Operable Unit 5 wetlands. The details regarding the procedures for the remedial action operations and long-term management activities will remain consistent with the 2021 Uniform Federal Policy Quality Assurance Project Plan (UFP-QAPP). |
Ginna Quesada |
| 5/18/2024 |
Document, Report, or Work plan Review - other |
DEC submitted comments regarding the 2023 Annual Remedial Action-operations And Long-term Management Report for Select State-regulated Sites Draft, Dated April 2024. The report describes the site inspections, maintenance activities, and groundwater monitoring, at multiple sites located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. Site inspections were recommended to continue for all sites to ensure that conditions remain protective of human health and the environment. The report recommends updating land use controls (LUC) site boundaries at CG534, a ‘Cleanup Complete’ determination without institutional controls (ICs) for SS522, the removal of groundwater LUCs at SS041, and a ‘Cleanup Complete with ICs determination for TU101. |
Ginna Quesada |
| 6/25/2024 |
Document, Report, or Work plan Review - other |
DEC approved the 2023 Annual Remedial Action-operations And Long-term Management Report for Select State-regulated Sites Final, dated June 2024. The report describes the site inspections, maintenance activities, and groundwater monitoring, at multiple sites located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. Site inspections were recommended to continue for all sites to ensure that conditions remain protective of human health and the environment. The report recommends updating land use controls (LUC) boundaries at CG534, a ‘Cleanup Complete’ determination without institutional controls (ICs) for SS522, the removal of groundwater LUCs at SS041, and a Cleanup Complete with ICs determination for TU101. |
Ginna Quesada |
| 1/30/2025 |
Document, Report, or Work plan Review - other |
DEC approved the 2025 Remedial Action–Operations and Long-term Monitoring Work Plan Addendum Final, dated January 2024.The work plan describes the site inspections, maintenance activities, and groundwater, seep, and surface water monitoring, activities that will be conducted at multiple sites located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. The scope of work briefly summarizes the site locations, sampling/monitoring activities and schedules. This workplan will remain consistent with the procedures outlined in the 2023 Letter Work Plan Remedial Action-Operations and Long-Term Management. |
Ginna Quesada |
| 4/15/2025 |
Document, Report, or Work plan Review - other |
DEC provided comments for the 2024 Annual Remedial Action-Operations and Long-Term Management Report for Select State-Regulated Sites Draft, dated April 2025.The report describes the site inspections, maintenance activities, and groundwater monitoring, at multiple sites located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. Site inspections were recommended to continue for the majority of the sites to ensure that conditions remain protective of human health and the environment. DEC concurs with the recommendation to close SS522 site without ICs, discontinue groundwater sampling at TU107, and reducing the sampling frequency for some wells at TU103. |
Ginna Quesada |
