| Action Date |
Action |
Description |
DEC Staff |
| 9/1/1983 |
Update or Other Action |
Installation Restoration Program:Phase I-Records Search prepared by USAF AFESC/DEV Tyndall AFB, FL, and Alaskan Air Command EAFB September 1, 1983 (ES Engineering-Science). FT-1 Fire Training Area FT-1 (FT23) was assessed using a Hazard
Assessment Rating Methodology (HARM) which takes into account factors such as site characteristics, waste characteristics, potential for contaminant migration and waste management practices. FT-1 operated from 1940-1983 has an initial priority ranking of 60 which is determined to have a moderate potential for environmental contamination.
Recommended Monitoring Program for Phase II: Conduct geophysical survey, using EMC and ER. If plume is present install wells and sample. The survey should be used to locate placement
of wells, if necessary.
In the past, the site consisted of a drum storage area and a bermed burning area. The drum storage area was used to store as many as 100 55-gallon drums of contaminated waste oils, paint thinners, waste fuel, and waste solvents from aircraft maintenance and the other shop operations on base. Until 1974, fire training activities occurred approximately once per month. During each exercise, 250 to 3,000 gallons of contaminated waste materials were spread on the water-saturated and bermed burn area and ignited. Protein foams or Chlorobromomethane were then used to extinquish the fire. From 1974-1978 only clean JP-4 jet fuel was used during exercises conducted twice per year.
From 1978-1980 quarterly exercises were initiated and continue at present. The site is located on a level, gravel moraine area which soaks up water and residual materials rapidly. According to personnel interviews, the burn area remained saturated with unconsumed waste fuel following each fire training exercise. The berm does not totally enclose the site. Subsequently, runoff has been known to occur outside the bermed area during fire training exercises. However, the runoff normally does not travel too far horizontally due to the rapid infiltration rates at the site. Visual examination of the area during the site visit indicated very small amounts of residual fuels in the burn area.
However, due to the permeable soils and gravel till deposits at the site a potential for contaminant migration exists since much of the fuel and waste residues may have seeped into the ground. In addition to the fire training activities conducted at Site FT-1, a small area a few hundred feet east of the bermed burn area was used in the past for burial of empty drums and spent fuel filters. The site is presently covered with local gravel till. This disposal pit will be considered part of Site FT-1.
It is recommended that land use restrictions at the identified
disposal and spill sites at Elmendorf AFB be considered. The purpose of such land use restrictions would be: (1) to provide the continued protection of human health, welfare, and the environment; (2) to insure that the migration of potential contaminants is not promoted through improper land uses; (3) to facilitate the compatible development of future USAF facilities; and (4) to allow for identification of property which may be proposed for excess or outlease. Land use restrictions at sites recommended for Phase II monitoring should be reevaluated upon the completion of Phase II monitoring program and changes made where appropriate.
|
Jennifer Roberts |
| 3/17/1986 |
Update or Other Action |
IRP Phase II Confirmation/Quantification Stage 1 report (Dames & Moore) USAF CONTRACT NO. F33615-83-D-4002, DELIVERY ORDER NO. 0019. Site FT-1: Fire Training Area Site (one of 11 sites included in report) has been used from the 1940s until the present. During each exercise, 250 to 3,000 gallons of contaminated waste oils, paint thinners, waste fuel, wash solvents, and/or clean JP-4 fuel are spread on a water-saturated and bermed burn area and ignited. Protein foam or chlorobromomethane is then used to extinguish the fire. Generally, the burn area remains saturated with unconsumed waste fuel following the exercise. Slightly elevated oil and grease, specific conductance, and pH indicate W-15 is probably located on the periphery of a contaminant plume from the fire training area. The oil and grease found in a soil sample at 45 feet indicates contamination is relatively deep at this site.
No active base wells are directly downgradient from Site FT-1; therefore, the threat to the water supply is limited. There is, however, an inactive well (base well No. 34 at gun site No. 10) that, if poorly completed, could act as a conduit for contaminants in the surface aquifer to enter the lower aquifer. |
Louis Howard |
| 3/20/1987 |
Update or Other Action |
DAF USAF Occupational and Environmental Health Laboratory, Brooks Air Force Base Memorandum - Subject Preservation of Installation Restoration Program (IRP) Monitoring Wells. To all MAJCOM/DEEV.
1. This letter is in response to a HQ USAF/LEEV letter dated 10 Jul 87, same subject, and a subsequent letter from ATC/DEEV to USAFOEHL requesting that we comply as their service center for IRP work. Since this guidance affects all of our command customers, we are addressing this issue with all commands.
2. The HQ USAF/LEEV guidance letter on IRP monitoring well installation and abandonment is very practical and judicious. The USAFOEHL technical approach for IRP is consistent with this guidance. As a matter of fact, we have followed this approach since the inception of the IRP. 3. We have successfully negotiated with many states and US EPA regional offices on the use of PVC as well material for IRP Confirmation and Quantification studies in lieu of Teflon (PTFE) or stainless steel. Since most of the wells will be destroyed or abandoned during the IRP Phase IV clean-up effort or after the initial IRP studies are complete and they are not suitable for long-term monitoring (LTM) purpose, the PVC well system is the most cost effective. We believe the National Sanitation Foundation-grade PVC suits our purpose for ground water sampling.
However, we do recommend stainless steel for LTM or RCRA Part B Permit wells deeper than 200 feet or Teflon for wells less than 150 feet.
4. The decision for above-ground completion of monitoring wells rests with the installation commander. Our Statement of Work (SOW) allows either aboveground or flush-with-ground completion. We recommend that wells be located on the side of road hedge facing away from thoroughfares or be painted a color that blends with the base surroundings. The color should be determined by the installation point of contact (POC). All wells, either above-ground or flush-with-ground, are installed in a manner to prevent surface runoff from entering into the well. As a rule, the rise pipe is located above a 25-year flood stage, preferably a 100-year flood stage. A steel protective casing and lock are standard prescription for all wells, and the master key will be delivered to the base POC. Guard posts will be installed where the base POC thinks necessary to prevent the damage caused by moving equipment.
5. After well completion, USAFOEHL always requests the Air Force contractor to survey its coordinates and elevation using a certified land surveyor. This survey result is transmitted to the base. If the base requests, the surveyor can locate the wells immediately on the Base Comprehensive Plan.
6. Proper abandonment of monitoring wells is crucial in ground water pollution prevention. Even if we know that the wells will be destroyed during IRP Phase IV excavation, they should be properly abandoned beforehand. Identifying well abandonment procedures according to state regulations is a standard clause in our SOW. Physical abandonment must be initiated in later contract efforts or be carried out by the base. 7. We always weigh both the cost and the technical soundness before establishing a monitoring and/or sampling well system. USAFOEHL strives to serve the Air Force by following the HQ USAF guidance on Preservation of IRP Monitoring Wells. |
Jennifer Roberts |
| 3/1/1988 |
Update or Other Action |
INSTALLATION RESTORATION PROGRAM PHASE II - CONFIRMATION/QUANTIFICATION STAGE 2 FINAL REPORT
FOR ELMENDORF AIR FORCE BASE ALASKA ALASKAN AIR COMMAND ELMENDORF, ALASKA 99506 MARCH 1, 1988
PREPARED BY DAMES & MOORE. During Stage 1, monitor well W-15 at the fire training area had an oil and grease concentration, specific conductance, and pH levels above the inferred background levels. The Stage 2 analyses revealed no
concentrations of purgeable aromatics or petroleum hydrocarbons above the detection limit in either W-15 or GW-5A. The pH in both wells (W-15 at 6.0 and GW-5A at 6.1) exceed the SDWS. The specific conductivity in GW-5A is elevated at 614 umhos/cm. Site FT-1 has a calculated gradient of 8 feet per mile to the
south-southwest.
Extent of Contamination at Site FT-1 I-The Stage 2 analytical results from the two downgradient wells at the fire training area indicate little impact on ground water quality. Petroleum hydrocarbons and purgeable aromatics were not detected. The pH in both wells exceed the SDWS and the specific conductivity in GW-5A is
elevated at 614 umhos/cm. No active wells are located directly
downgradient of this site and impact on the base water supply is believed to be insignificant.
It is recommended, that resampling of FT-1 monitor wells to obtain TDS (USEPA 160.1) pH, temperature, specific conductivity, and petroleum hydrocarbons be carried out to ensure that ground water standards are being met. |
Jennifer Roberts |
| 4/18/1988 |
Update or Other Action |
AF (AAC) FY 1989 Military Construction Project Data Fire Training Area
Soil Borings 1
Monitor Well Sampling 3
Contaminated Soil Removal/Disposal
Description of Proposed Remedial Action:
lhe scope of restoration work includes the following major elements: install monitoring wells, define contaminant plume, and remove/dispose of contaminated soil. Proposed work is scheduled for IRP Site FT-l.
Requirement
Project: Delineate contaminant plume at base Fire Training Area. Remove and dispose of contaminated soils and/or groundwater.
REQUIREMENT: Soil borings sunk in late 1985 by Corps of Engineers revealed POL contamination as deep as 45 ft below grade. Prior to the proposed upgrade of this area under a FY91 MCP, plume boundaries and contaminant removal operations need to be completed. CERCLA applies.
CURRENT SITUATION: Site FT-1 has been the location of Elmendorf AFB Fire Training Area since the 1940's. The site is located on a level, gravel moraine area which rapidly soaks up water and residual training materials. In the past drums of waste products such as oils, thinners,
fuels and solvents were used to fuel training operations.
Until 1971 fire training activities occured approximately monthly with 250 to 3,000 gallons of contaminated waste materials used per exercise. From 1974 to 1978 fire training exercises were conducted semiannually with only clean JP4. From 1978 to present quarterly exercises have been initiated. During each exercise JP4 fuel is spread over the water-saturated and bermed area and ignited. Protein foams and/or chlorobromomethane (CBM) are then used to extinguish the fire. Following each fire training exercise the berm area remains saturated with unconsumed fuels and/or foams.
Since the berm does not totally enclose the site, runofff has been known to occur. Due to the high soil permeabilities the runoff does not travel horizontally very far before the fuel/foam/water mixture infiltrates into area soils.
IMPACT IF NOT PROVIDED: Fire training exercises will continue at the existing base Fire Training Area. Based on existing soil permeabilities significant quantities of fuels will be lost into area soils and could subsequently adversly impact area groundwaters. The proposed FY91 MCP will provide for the construction of an impermeable Fire Training Pit to
prevent soil/groundwater contamination.
ADDITIONAL: This is an RA IRP (old Phase IVB, Priority IB) project. Proposed action remediates IRP site FT-1.
Signed Terese D. LeFrancois, GS-12, DAF
AAC DERA Program Manager. |
Jennifer Roberts |
| 8/1/1988 |
Update or Other Action |
RCRA Facility Assessment Report: Preliminary Review and Visual Site Inspection conducted by ADEC during July 19 and 20, 1988. Site FT-1 Fire Training Area No. 1: This site is located just west of the north end of the north-south airstrip near Building 43-585.
This site has been used as the fire training area from the 1940's to the present, where large quantities of contaminated waste oils and fuels, paint thinners, waste solvents and clean fuels have been spread on the ground surface and ignited to provide fire extinguishment training. Until 1974, training activities occurred approximately on a monthly basis; from 1974 to 1978 on a semi-annual basis; and since 1978 on a quarterly basis. During each exercise, 250 to 3000 gallons of the above materials were used and extinguished with protein foams or chlorobromomethane.
Rubble fill and other unclassified materials have been placed in the pit beginning sometime after 1983. Mr. Drewett stated that after 1974, EAFB has used only JP-4 fuel to ignite the materials at FT-1. In addition to the fire training activities conducted at this site, a
small area a few hundred feet east of the bermed burn area was used in the past for burial of empty drums and spent fuel filters, it is presently covered with local gravel till.
The site is located on a level, gravel moraine area which soaks up water and residual materials rapidly, i.e. contaminant migration
from fuel and waste residue seepages. Water was encountered at 42 feet on 6/12/84. According to personnel interviews, the burn area remained saturated with unconsumed waste fuel following each fire training exercise. The berm does not totally enclose the site, therefore runoff has occurred outside the bermed area
during fire training exercises. EAFB reported that Monitor well W-15 had an oil and grease concentration, specific conductance and pH levels above the inferred background levels.
Purgeable aromatics nor petroleum hydrocarbons were detected in either W-15 and GW-5A. PH in both wells (W-15 at 6.0 and GW-5A at 6.1) exceeded the SDWS. The specific conductance in GW-5A is elevated at 614 umhos/cm. During a stage 2 sampling, petroleum hydrocarbons and purgeable aromatics were not detected in two downgradient wells, and the impact to base water quality was believed to be insignificant. However it was noted that there is an inactive well/base well 34 that could act as a conduit for contaminants in the surface aquifer to enter the
lower aquifer. |
Max Schwenne |
| 8/10/1989 |
Update or Other Action |
USEPA AK Ops Office letter ot ADEC Dennis Kelso Commissioner RE: Federal Facility National Priority List Sites. On July 14, 1989, the Environmental Protection Agency (EPA) proposed listing
the following Alaska Federal Facilities on the Superfund National Priorities List (NPL): Eielson Air Force Base, Elmendorf Air Force Base, Fort Wainwright, and Standard Steel Metals and Salvage Yard.
The next step in the NPL process is to develope three party Inter-Agency Agreements (IAG's) including each facility the State of Alaska Department of Environmental Conservation (ADEC) and EPA. The Alaska Operations Office is committed to effecting signed agreements according to the following schedule 1st Quarter FY 90: Eielson Air Force Base, Elmendorf Air Force Base,
Fort Wainwright, and Standard Steel
In order to initiate the IAG process, we request ADEC identify a policy negotiating team consisting of an attorney and staff members of the Central Office Oil and Hazardous Substance Spill Response Branch and Hazardous and Solid Waste Management Branch. In addition, a senior management person who has the authority to speak for the State and participate in the negotiations
and dispute resolution needs to be identified. We would appreciate receiving this list by August 20, 1989.
As you know, EPA and ADEC staff members have begun informal discussions pertaining to ADEC's oversight and document review for the proposed NPL sites. These oversight and review tasks are to be provided through an EPA grant to ADEC. Furthermore, as a part of the negotiations with each Federal Facility, these tasks and funds are to be incorporated into a follow up grant from each facility to ADEC.
Signed Alvin L. Ewing, Assistant Regional Administrator. |
Louis Howard |
| 4/16/1990 |
Update or Other Action |
USEPA Memorandum Subject: Elmendorf AFB Deliverables and Operable Units (OU) from D. Johnson Environmental Scientist, AOO/A to George Hofer Chief Federal Facility Branch HW-074.
The following is a synopsis of two meetings that were held with staff members of ADEC and EPA. The first meeting was held on April 6, 1990 and the second was held on April 12, 1990. Attendees for the meetings from ADEC were Ron Klein, Max Schwenne, Colleen Burgh, Jennifer Roberts with Mary Siroki and Geoff Kany attending the first meeting.
The following reflects the input from ADEC regarding the document deliverables, determination of operable units, and schedules for inclusion to the Elmendorf AFB Interagency Agreement. This information was discussed with Bob Loiselle during your absence.
Document Deliverables: It was determined by mutual agreement that the same document deliverables now proposed for the Eielson IAG be incorporated into the Elmendorf IAG without change. ADEC agrees that for consistency and simplicity reasons the document deliverables for all Alaska IAG's remain the same.
Operable Units: Operable unit determination was based upon a hierarchy which was derived by either geographic or site characteristic similarities. The listed order was determined by severity of contamination (worst first) based upon common knowledge of the meeting participants.
Operable Unit #1 (Million Gallon Hill Area)-Sites SP-5/5A, OT-1, D-15, D-16, D-17, NS-2.
Operable Unit #2 (Air Force High Priority Sites-Sites S-5, D-4, D-10, FT-1
Operable Unit #3 (Landfills)-Sites D-5, D-6, D-7, D-8, D-9, D-11, D-12, D-13, NS-2
Operable Unit #4 (Hangar Floor Drains)-Sites IS-1, IS-2, IS-3, IS-4, IS-5, IS-6, IS-7, IS-8
Operable Unit #5 (Fuel Spill Sites)-Sites SP-1 thru SP-16, NS-3
Operable Unit #6 (UST/LUST Sites)-Approx. 35 known UST/LUST sites scattered around facility.
Operable Unit #7 (Misc. Sites)-Sites D-1, D-2, D-3, RD-1, S-l, S-3, S-4, S-6, S-7
Please note that of these operable units, the first three are probable definites for inclusion to the IAG. The last four have been included at this stage for discussion purposes and for understanding the perceived universe of sites at Elmendorf AFB.
Further refinement of this list and determination of schedules to be discussed on May 2, 1990 with ADEC. I will continue to discuss this subject with Bob as it develops, and would welcome any input you might have. |
Jennifer Roberts |
| 7/2/1990 |
Update or Other Action |
AFOEHL REPORT 90-124EQ00687GHH Hazardous Waste Technical Assistance Survey EAFB (July 1990).
21 Transportation Squadron (21 TRANS) Shop: Refueling Maint Bldg: 31-338: Refueling maintenance personnel maintain & repair aircraft refueling vehicles. Waste JP-4 (2000 gallons/year), diesel (60 gallons/year), & MoGas (60 gallons/year) are drained to an UST. The waste fuel is pumped from the tank by POL personnel. Since the fuel usually gets contaminated during draining procedures (from dirt & snow on the vehicle), it cannot be recycled.
**The waste is usually used at the Fire Training Pit (FTP) for training purposes or disposed as nonhazardous waste through DRMO. Waste oil (400 gallons/year) & transmission fluid (50 gallons/year) are drummed & stored at the shop's accumulation site.
Bldg. 21-900 Vehicle Maintenance: Shop personnel perform oil changes, lubrication, & routine
maintenance on all military vehicles assigned to Elmendorf AFB. Waste motor oil (200 gallons/month) is drained into a 10,000-gallon UST; when full, the waste is pumped from the tank by Refueling Maintenance personnel into a tanker truck. Hydraulic fluid (30 gallons/month), transmission fluid (15 gallons/month), & brake fluid (2 gallon/month) are drummed & stored at the shop's accumulation site. Waste MoGas (10 gallons/month) & diesel (20 gallons/month) are drummed & stored at the shop's accumulation site.
**The waste fuel is either used for training purposes at the Fire Training Pit or disposed through DRMO.
Bldg. 21-900 Shop: Vehicle Maintenance: Shop personnel perform oil changes, lubrication, & routine maintenance on all military vehicles assigned to Elmendorf AFB. Waste motor oil (200 gallons/month) is drained into a 10,000-gallon UST; when full, the waste is pumped from the tank by Refueling Maintenance personnel into a tanker truck. Hydraulic fluid (30 gallons/month), transmission fluid (15 gallons/month), & brake fluid (2 gallon/month) are drummed & stored at the shop's accumulation site. Waste MoGas (10 gallons/month) & diesel (20 gallons/month) are drummed & stored at the shop's accumulation site.
**The waste fuel is either used for training purposes at the Fire Training Pit or disposed through DRMO. Batteries are taken to the 21 CRS Battery Shop for neutralization. Waste antifreeze (55 gallons/month) is drummed, stored at the shop's accumulation site & disposed through DRMO as nonhazardous waste. |
Louis Howard |
| 11/12/1991 |
Enforcement Agreement or Order |
Federal Facility Agreement under Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) signed for docket # 1089-07-19-120. The agreement ensures that the environmental impacts associated with past and present activities at the Base are thoroughly investigated and appropriate removal and/or remedial action(s) taken as necessary to protect human health and the environment. Elmendorf Federal Facility Agreement signed.
The general purposes of this Agreement are to: (a) Ensure that the environmental impact associated with past and present activities at the Site are thoroughly investigated and appropriate removal and/or remedial action(s) taken as necessary to protect the public health, welfare, and the environment.(b) Establish a procedural framework and schedule for developing, implementing, and monitoring appropriate response actions at the Site in accordance with CERCLA, the NCP, Superfund guidance and policy, RCRA, RCRA guidance and policy, and applicable state law.
The FFA divided the CERCLA study source areas at Elmendorf AFB into the following seven operable unites (OUs), on the basis of geographic proximity and similar source characteristics or contaminants:
- OU1 Landfills (LF05, LF07, LF13, LF59, OT56)
- OU2 Tank Spill Sites (ST20, ST41, including the ST41 Sludge Disposal Area)
- OU3 Central Containment Area (SD16, SD31, SD52, SS21)
- OU4 Northern Containment Area (SD24, SD25, SD28, SD29, FT23, SSl0)
- OU5 Southern Containment Area (ST37)
- OU6 Surface Disposal Sites (LF02, LF03, LF04, SD15, SD73, WP14)
- OU7 Limited Field Investigation (SS19)
Proposed listing on NPL was 07/14/1989 and Final listing on NPL was on 08/30/1990.
See site file for additional information. |
Jennifer Roberts |
| 11/12/1991 |
Update or Other Action |
Jennifer Roberts Federal Facility Coordinator sent letter to Joe Williamson and Rich Howard pursuant to Section 9.1 of the Elmendorf Air Force Base Federal Facility Agreement (FFA). ADEC designates Jennifer Roberts as the Project Manager and Ron Klein as the Alternate Project Manager for all activities covered under the FFA. |
Jennifer Roberts |
| 11/26/1991 |
Document, Report, or Work plan Review - other |
Jennifer Roberts sent letter to Mr. Lewis R. Ivers P.E. Manager Western Division EA Remediation Technologies Inc. Concord CA. The federal facilities staff of the Southcentral Regional Office of Alaska Department of Environmental Conservation has reviewed the Quality Assurance Manual submitted for EA Laboratories. The document appears to meet our guidelines for laboratory quality assurance manuals. |
Jennifer Roberts |
| 12/30/1991 |
Update or Other Action |
EPA sent letter to Air Force (AF) Rich Howard and Joe Williamson. The notification will serve as an addendum to the previous letter of November 4, 1991 which designates the USEPA project managers pursuant to Section 9.1 of the Elmendorf Air Force Base (EAFB) Federal Facilities Agreement (FFA). Marcia Combes will serve a lead remedial project manager (RPM) for Base-wide activities, as well as Operable Units (OUs) 2, 3, 5, 6, 7. Michele Poirier-McNeill will serve as lead RPM for OUs 1 and 4. In addition both RPMs will serve as an alternative RPM on OUs for which they are not the lead. For communication and correspondence purposes, the lead RPM should be the point of contact, and the alternate should be copied. |
Jennifer Roberts |
| 4/9/1992 |
Update or Other Action |
EPA Memorandum April 9, 1992 Reply to the ATTN of ES-098. Subject Toxicity of Fuels. From Carol Sweeney, Toxicologist Health and Environmental Assessment Section. To Wayne Pierre Federal Facilities 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
USEPA Office of Research and Development, Environmental Criteria and Assessment Office Cincinnati, OH Subj: Oral Reference Doses and Oral Slope Factors for JP-4, JP-5; similar to Kerosene (CAS no. 8008-20-6), Diesel Fuel (CAS No. 68334-30-5), and Gasoline (CAS No. 8006-61-9) (AVGAS) [McChord AFB (Wash Rack/Treatment)/Tacoma, WA]. From Joan S. Dollarhide Associate Director, Superfund Health Risk Techncial Support Center, Chemical Mixtures Assessment Branch TO Carol Sweeney USEPA Region X.
This memorandum is in response to your request for oral systemic and carcinogenic toxicity values for JP-4, JP-5, diesel fuel, and gasoline (AVGAS) found to contaminate soil and
groundwater at McChord AFB (Wash Rack/Treatment), Tacoma, WA. We have attempted to derive RfDs and slope factors for the above fuel mixtures. We have derived provisional RfDs for
gasoline, JP-4, JP-5 and diesel fuel; provisional cancer weight-of-evidence classifications of C for gasoline and D for JP-4, JP- 5 and diesel fuel; and a provisional slope factor (adapted from an interim Agency value) for gasoline
Based on the available evidence, unleaded gasoline can be assigned to U.S. EPA (1986) weight-of-evidence Group C: possible human carcinogen. An earlier U.S. EPA document assigned unleaded
gasoline to Group B2 as a probable human carcinogen (u.s. EPA, 1987a), but that document predates the U.S. EPA (1991d) conclusion that the male rat kidney tumors produced by gasoline
are not predictive for humans, and therefore should not contribute to the weight-of-evidence or dose-response assessment of carcinogenicity. IARC concluded that marine diesel fuel is possibly carcinogenic to humans (Group 2B), but light diesel fuels and jet fuels are not classifiable as to their carcinogenicity in humans (Group 3). |
Jennifer Roberts |
| 6/3/1992 |
Update or Other Action |
USAF sent the meeting minutes from the May 21, 1992 meeting on Ground Penetrating radar results. Also discussed at the meeting was determining the extent of the limited field investigation (LFI) as described in the LFI work plan. If contamination is encountered at the first sample point, further excavation and sampling is not required. However, if no contamination is found through field screening techniques at the first sample point, further excavation will proceed and a vadose zone sample will be obtained. If contamination is encountered, an evaluation of risk associated with contaminant levels will be performed to determine if further action is warranted.
NOTE TO FILE: "Limited Field Investigation or "LFI" shall mean screening investigations of potential source areas with, inadequate data to determine whether these areas pose an
unacceptable risk to human health or the environment. Limited Field Investigations (LFIs) will be conducted at the old spill/disposal sites to identify whether or not these sites pose an unacceptable risk to public health from soil ingestion, dust inhalation, future agricultural use and crop uptale or direct contact. The potential for these areas to represent a
significant source to groundwater contamination will also be evaluated. Prior to performing LFI's a workplan will be developed identifying the Data Quality Objectives established based on the conceptual site model development.
As the objectives of the LFI are to ascertain the potential risk to human health from shallow soil contamination and/or the risk to human health from groundwater contamination resulting from the leaching of contaminants from these areas, the scope of the study is significantly less than that of an RI/FS. A sampling analysis plan "SAP" consisting of a field sampling plan (FSP) and QAPP will also be submitted as part of the workplan. At completion of the LFI investigation, a LFI report which contains the findings of the investigation shall be submitted to the agencies for review and comment.
A determination shall be made between the Project Managers to the disposition of each of the
sources. Based on report results a decision will be reached between the Project Managers on
what specific source areas in the operable unit (OU) require follow up action. The decision will be reflected in the administrative record." |
Jennifer Roberts |
| 9/15/1992 |
Update or Other Action |
USAF letter to Jennifer Roberts regarding "Revisions to Elmendorf AFB Federal Facility Agreement (FFA) Scope of Work for Operable Units (OU) 4 and 7."
1. As a result of this summer's field investigation, we request attachment 1 of the FFA be revised as follows:
a. Move FT23 from OU7 to OU4. Based on the results of the Limited Field Investigation (LFI) it appears FT23 may be a source of contamination observed in past investigations at SD24, SD25,
SD26, and SD27.
b. Move SD31 from OU4 to OU3. Geographically, SD31 is more closely aligned with the sources in OU3.
c. Move SS63 (Classic Owl) from OU4 to OU7. Currently at Classic Owl a building is under construction by the Corps of Engineers. If SS63 remains in OU4, then there could be major
conflicts which several contractors working in the area. Also by moving SS63 into OU7, we would be able to address all of the sources located north of the Elmendorf Moraine in one remedial
investigation.
d. Delete the requirement of an interim remedial action (IRA) at OU4. Based on the LFI, the remedial project managers identified the dry wells at SD24, SD28, and SD31 as potential
IRAs. However, further review of the results of the LFI, indicate only the sludge at the bottom of the dry well at these sources were sampled and no soil samples were obtained. At this
time there is no evidence of soil contamination in the immediate vicinity of the dry wells. Without additional investigation of these wells, it does not appear an IRA is warranted. Instead of an IRA, we will pursue funding to remove the sludge in each dry well.
e. Delete the requirement of an IRA at OU7. In 1988, light non-aqueous phase liquid (LNAPL) contamination was found and an IRA was put into the FFA to remove the LNAPL from this source
area. Based on two rounds of water level measurements that showed no LNAPL and soil samples collected this summer attachment 1), it appears there is no reason to address the LNAPL
and we do not have enough information to address the soil contamination. Without additional investigation of this source, it does not appear an interim action is warranted.
2. Please express your concurrence or non-concurrence to the above request and return this letter within seven days of receipt. |
Jennifer Roberts |
| 10/6/1992 |
Document, Report, or Work plan Review - other |
Jennifer Roberts commented on the Draft OU4 Limited Field Investigation (LFI) dated September 1992. Jennifer Roberts sent the USAF a comment letter on the draft OU4 LFI report dated September 1992. Groundwater flow direction section 1.4.3.2 adequately addresses the groundwater flow south of the moraine, but neglects groundwater flow in the area of Source Area SS63 (Classic Owl Construction site). SS63 is north of the Elmendorf terminal moraine and will exhibit groundwater characteristics and flow patterns. The Corps of Engineers has some preliminary groundwater information that could be utilized in this report.
Section 2.3.2.2 Field Change Requests-ADEC recommends that a sentence be added to this section stating that copies of the field changes area in the information repository. The alternative to this is to include the field changes in an appendix and the appendix referenced in the section.
Recommend expanding exposure pathways section 2.5.2 to include groundwater and exposure pathways specific to SS63. During the Classic Owl construction phase, a clay pipe containing high levels of lead contamination was discovered. CH2MHILL took additional samples under a field memorandum to determine if the lead contamination had impacted SS63 and should be included in OU4. |
Jennifer Roberts |
| 12/4/1992 |
Document, Report, or Work plan Review - other |
Letter sent to USAF regarding the Draft Operable Unit (OU) 4 ARARs. Citations to the National Contingency Plan (NCP) need to be included for all legal assertions in this section and throughout the document. For example, in section 2.2 the draft makes a statement without reference to the Code of Federal Regulations: " The NCP states that cleanup level of zero is not appropriate for Superfund-type cleanups because:
(1) CERCLA does not require the complete elimination of risk; and
(2) it is impossible to detect whether 'true' zero has actually been attained." The State of Alaska Water Quality Standards contained in 18 AAC 70 apply to groundwater as well as surface water. See 18 AAC 70.110.(46): "'water' means lakes, bays, sounds, ponds, impounding reservoirs, springs, wells, rivers, streams, creeks, estuaries, marshes, inlets, straits, passages, canals, the Pacific Ocean, Gulf of AK, Bering Sea, and Arctic Ocean, in the state's territorial limits AND all other bodies of surface or underground water that are wholly or partially under state jurisdiction." See also AS 46.09.900(35).
The state's water quality standards are therefore applicable to groundwater. As promulgated regulations, Alaska's water quality criteria are ARARs. See United States v. Akzo Coatings of America, 946 F.2d 1409 (6th Cir. 1991). To the extent, state water quality regulations adopt USEPA's water quality criteria are also ARARs and not "potentially TBC standard." See e.g. 18 AAC 70.020(b) (Toxics and other Deleterious organic and inorganic substances). To correct this confusion between state and federal requirements in this area, a new section entitled "Alaska State Water Quality Standards" is suggested. |
Jennifer Roberts |
| 12/8/1992 |
Conceptual Site Model Submitted |
Jennifer Roberts provided comments to the USAF on the draft Conceptual Site Model for OU4. Section 3.1.3 last paragraph states that contamination from FT23 may have reached the groundwater table, that is, unless there are unknown upgradient sources, a certainty. The sentence should state that measurable floating product has been found on the groundwater table and may have migrated downgradient.
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. ADEC has noticed that samples taken in May June and July tend to have strong masking tendencies and contaminant concentrations become very low or in some cases go non-detectable. ADEC recommends the sampling dates also be reviewed to determine if seasonal masking has skewed chemical contaminant concentrations.
The statement in section 4.1.4 which states that it is not possible to assess the extent of the population that participates in recreational activities and is subjected to the potentially contaminated water at Ship Creek is not entirely correct. The Alaska Department of Fish and Game conducts periodic creel censuses and fishermen interviews at Ship Creek throughout the fishing season as well as sending out an end of the year questionnaire to fishing license holders asking them where and how long they fished during the past season. Finally, appendix A states that the JP-4 and diesel fuels listed here are probably for fuels in the continental U.S. Both fuels have a different mix in Alaska and tend to have a higher than "normal" levels of volatile compounds including benzene. |
Jennifer Roberts |
| 3/18/1993 |
Document, Report, or Work plan Review - other |
ADEC sent a letter regarding the Management plan to the USAF. Chain of custody will need to incorporate that the sample was in an individual's physical possession and locked up or otherwise sealed so that tampering will be evident. Sample will need to be kept in a secure area restricted to authorized personnel only. Pumping test does not appear to be needed since target objectives can be achieved without conducting a pumping test using the data from other operable units. If overall base-wide RI results show that a groundwater extraction system is appropriate, then a pumping test near the site can be done to fine tune the system design. |
Jennifer Roberts |
| 3/26/1993 |
Update or Other Action |
DOD and ADEC joint Technical Memorandum of understanding signed concerning the Base-wide Groundwater (GW) signed by: ADEC Jennifer Roberts RPM and USAF Joseph Williamson Chief Environmental Programs and Restoration. Due to the base-wide GW study and the FY92 field work that occurred at Operable Units (OUs) 1, 2, and 5 it appears a large portion of the GW flows into OU5 (attach. 1-contour map). Based on this fact, Elmendorf (EAFB) will move all upgradient GW into the OU5 Feasibility Study, Proposed Plan and Record of Decision (ROD).
This means addressing all GW from upgradient sources (CERCLA (ST20, OUs 3 and 4) and OUs 1 and portions of OU2) and SERA) at OU5 instead of at each individual source area (see attach. 2-Area Map). Sites with free phased product would be looked at to see if there is an available technology to clean them up in a cost effective way. Soil contamination would be addressed at the source areas. NOTE: addressed at the source areas is interpreted by ADEC as removal through excavation or active treatment systems (e.g. high vacuum extraction, bioventing, etc...). |
Jennifer Roberts |
| 4/26/1993 |
Site Characterization Workplan Approved |
ADEC reviewed and approved the April 1993 OU4 management plan. |
Jennifer Roberts |
| 5/7/1993 |
Update or Other Action |
Source Area SS18 (Building 22-021 now Bldg. 5327 or AFID 21/STMP-ID 343) is included in Operable Unit (OU) 4 for purposes of remedial investigation at Elmendorf AFB under CERCLA. This site is located approximately 850 feet south of Second Street along the east side of Maple Avenue. Building 22-021, constructed in 1944, rests on a concrete floor. The building has housed the pest management operations of the Base since 1960 and is currently used to store and maintain pesticide equipment and vehicles. No releases or spills have been documented at the source area.
A Limited Field Investigation (LFI) was conducted at Source Area SS18 in 1992 to identify and evaluate the drain outfalls at Building 22-021 and to assess the possible environmental impacts that may have resulted from past operations and disposal practices. The results of the LFI were used to (1) determine the final disposition of the outfalls and (2) recommend either no further action (NFA) or that a remedial investigation/feasibility study (RI/FS) be conducted.
A geophysical survey was conducted using ground-penetrating radar technology to locate the drain outfalls and identify any geophysical anomalies for sampling. As a result of this geophysical survey and soil-sampling, the recommended action for the outfall structure source areas investigated at SS18 was NFA. None of the soil samples collected during the LFI at SS18 contained analytes in excess of risk-based criteria.
The concentrations of pesticides detected during SS18 sampling are not expected to be mobile and act as an contaminant source. Groundwater was not evaluated during the LFI. Any groundwater contamination present will be evaluated as part of the ongoing remedial investigation at OU5. The criteria for NFA were met at each of the source sampling locations; therefore, NFA is justified for the building floor drains and outfalls at Source SS18. |
Jennifer Roberts |
| 8/16/1993 |
Update or Other Action |
Letter from Joseph Williamson (3 SG/CEVR) to Jennifer Roberts (ADEC) RE: Identification of State Proposed ARARs.
1. The Installation Restoration Program (IRP) at EAFB is now reaching the point where decisions will have to be made at source areas, so it is necessary to identify all related State remedial requirements.
a. Section 121(d) of the Comprehensive Environmental Response, Compensation & Liability Act (CERCLA), as amended by SARA, requires selected remedial actions to attain a degree of cleanup of hazardous substances, pollutants, & contaminants released into the environment & of control of further release at a minimum which assures protection of human health & the environment. Such remedial actions shall be relevant & appropriate under the circumstances presented by the release or threatened release of such substance, pollutant, or contaminant. Section 121(d) further requires attainment of Federal ARARs & of State ARARs in State environmental or facility siting laws when the State requirements are promulgated, more stringent than Federal laws, & identified by the State in a timely manner.
b. According to EPA Publication 9347-3-15, Compendium of CERCLA ARARs Fact Sheets & directives, as the support agency, the State is responsible for:
(1) Receiving & reviewing information about proposed Federal ARARs & to-be-considered's, as early as site characterization;
(2) Coordinating State input on ARARs from all State agencies;
(3) Identifying State ARARs during the remedial investigation/feasibility (RI/FS) study;
(4) Justifying proposed State ARARs; &
(5) Reviewing ARARs identified in the proposed plan & record of decision.
States are always responsible for identifying State ARARs & communicating them to the Federal-lead agency in a timely manner.
c. A critical point for identifying ARARs is during the scoping of the RI/FS. We have reached this point on the majority of operable units (OUs). To avoid an issue of "timeliness" & prevent a delay in the scoping process, we request the State identify its ARARs with justification for OUs 1 through 6. As lead agency, the Air Force is not legally required to consider potential State ARARs that are not identified in a "timely" manner.
d. To demonstrate that the State requirement is an ARAR, you are required by the NCP to provide citations to the statute or regulation number. In addition, you should provide the requirement's effective date & description of scope, where appropriate. Furthermore, you should provide evidence that the requirement is more stringent than the Federal requirement. Finally, you should also describe in writing the relationship between the State requirement & the site or action, to show that the State requirement is applicable or relevant & appropriate to that particular site or action.
2. Please provide the requested ARARs data so the information can be used to complete the required evaluations of the source areas in the previously-mentioned OUs. |
Jennifer Roberts |
| 2/15/1994 |
Update or Other Action |
SERA Phases 1A & 1B Site Assessment report includes site ST47 JP-4 Fuel Line Leak (IRPIMS Site 55). Site ST47 (formerly known as site SP-12) is the location of suspected contaminated soil
reportedly caused by a 1,000-gallon JP-4 fuel line leak in 1971 (CH2M Hill 1991). The leak and
suspected contaminated soil are located north of Fire Station No. 1 (Building 10-875), which is
located south of the east-west runway. A soil sample collected from 55WL01 at a depth of 6.0 feet bgs had a DRO concentration of 4,300 mg/kg and xylenes at 35 mg/kg.
No soil contamination above the cleanup levels was found in the area designated as ST47. Elevated levels of DRO in soil from the upgradient well location may indicate a different source. Low-level groundwater contamination does not appear to be consistent with water-soluble components of fuels.
No further action should be required for groundwater and soil associated with ST47; however, further investigation to identify the source of DRO in soil from well 55WL01 could be initiated. Leak testing of the hydrant system in this area should be performed to evaluate this system as a potential source. The source of the dissolved hydrocarbons in the groundwater is most likely located upgradient from well 55WL01 and is most likely the fire training area (FT023 fka FT-1) under investigation in Operable Unit 4. |
Louis Howard |
| 3/17/1994 |
Site Ranked Using the AHRM |
Initial ranking. |
Louis Howard |
| 3/25/1994 |
Document, Report, or Work plan Review - other |
Staff provided comments on the February 1994 Draft Remedial investigation report. Use of significance criteria is questioned since it does not compare to any known standard (i.e. RBCs, MCLs). PCE detected in the groundwater was stated to be at a maximum concentration of 130 ug/L for the fire training area. In table 4-42 it states the maximum concentration detected was 201 ug/L. Same can be said for 1,1-dichloroethane (1,1-DCA) at 12 ug/l but on page 4-150 it is stated to be 20 ug/l. The use of the Alaska Cleanup Matrix cleanup levels for establishing cleanup levels is generally not appropriate for sites where groundwater is contaminated with petroleum constituents. Clarify how the scores were derived. |
Jennifer Roberts |
| 5/3/1994 |
Site Added to Database |
Chlorinated solvents, gasoline, diesel and waste oil used in fire training exercises. |
Louis Howard |
| 7/6/1994 |
Document, Report, or Work plan Review - other |
Staff commented on the draft Remedial Investigation/Feasibility Study (RI/FS) Report dated June 1994. Clarify what significance criteria means with regards to risk-based chemical concentrations of concern or federal and state action levels. Text states maximum concentration detected PCE (tetrachloroethane) up to 40.5 ug/L, however PCE was listed in table 4-45 at a maximum detected concentration of 77.8 ug/L. Development and analysis of alternatives: The text states Intrinsic Remediation as a viable applicable technology.
ADEC wishes to state, while it is listed as being cost effective by the USAF, intrinsic remediation has not been proven as being adequately protective of human health and the environment, meeting ARARs, or being able to provide long or short term effectiveness and permanence. ADEC suggests a pilot study to show its applicability or desirability for further consideration as a remedial alternative.
Pending resolution of the comments, report will be approved. |
Jennifer Roberts |
| 9/15/1994 |
Risk Assessment Report Approved |
Risk assessment combined with RI/FS final version received and approved. 12 constituents were identified as major contributors to groundwater risk. 8 were identified as contributors to carcinogenic groundwater risk: benzene, chloromethane, dieldrin, 1,1-dichloroethene, 1,2-dichloroethane, chloroform, trichloroethene, and carbon tetrachloride. 4 constituents were principal contributors to non-carcinogenic groundwater risk, including toluene, ethylbenzene, cis-1,2-dichloroethene, and trichloroethene. Results of the risk evaluation for soils indicated six constituents as primary contributors to the carcinogenic risk in soil, including benzo(a) pyrene, benzo(b)fluoranthene, dibenzo(a,h)anthracene, benzo(a)anthracene, PCB-1260, and benzo(k)fluoranthene. Non-carcinogenic risk in soil did not exceed an HQ of 1.0.
The results of the risk assessment indicate that each of the six soil and five of the six groundwater areas of interest have a carcinogenic risk in excess of 1.0 x 10-6 using the most conservative residential estimates. At the Asphalt Drum Storage Area, no groundwater risks were identified.
Ecological risk assessment: Ecological quotients for moose did not exceed 1.0 for moose. EQs of 1.0 were exceeded for copper and lead for meadow voles at OU4. None of these exceedances appear to be highly significant for the following reasons: the overall nature of the methodology used was conservative. In several cases the calculated doses, reference criteria, or measurement endpoints were inappropriate for this site because even normal background concentrations caused exceedances. Finally, the relatively uniform distributions of concentrations of manganese, selenium and thallium across all the sites is not typical of highly contaminated areas. |
John Halverson |
| 9/15/1994 |
Site Characterization Report Approved |
Final version of Remedial Investigation/Feasibility Study (RI/FS) received and approved. |
John Halverson |
| 10/5/1994 |
Document, Report, or Work plan Review - other |
ADEC provided comments on the Proposed Plan for OU4 to the USAF. Request clarification on what constitutes shallow soils as described in the preferred alternative. Text needs to include how the AF will prepare a response to significant comments, criticisms, and new data submitted on the document and ensure that this response document accompanies the Record of Decision. |
Jennifer Roberts |
| 11/27/1994 |
Document, Report, or Work plan Review - other |
ADEC provided comments on the draft final Proposed Plan for OU4 to the USAF. Clarification requested on the time for cleanup using air sparging in the document for groundwater at 8 years and the RI stating that MCLs will be reached in 5 years. Also the RI states that the alternative GW-3 In-situ Air sparging as being generally implementable and reliability of technology is considered high an effects of cold climate on it are not a problem.
This is in direct conflict with the Proposed Plan which stated that the alternative will require more substantial maintenance and operations of the life of the systems and is a less well proven technology with both soil and climate posing potential obstacles to the success of the technology. ADEC requested clarification on the discrepancies. |
Jennifer Roberts |
| 3/20/1995 |
Document, Report, or Work plan Review - other |
ADEC provided comments on the draft proposed plan for OU4. Comparative analysis of cleanup alternatives page 13 states both yes and no for shallow and deep soils. Please clarify in the document how the alternative would be applied to both shallow and deep soils. |
Jennifer Roberts |
| 4/11/1995 |
CERCLA Proposed Plan |
Proposed Plan received and approved. Source areas include Fire Training Area (FT23) (GW & Soil), Hangar 8 (GW), Hangar 10 (GW & Soil), Hangar 11 (GW & Soil), Hangar 14 (GW), Hangar 15 (GW & Soil), and Asphalt Drum Storage Area (Soil).
Because low levels of fuels were relatively widespread in the deep soils at the FTA at depths of up to 40 feet (about 10 feet above the top of the groundwater), some action may be required to remove the fuels at this location for protection of the groundwater. One plume of fuel-related and solvent contamination was detected moving to the southwest (in the direction of groundwater flow) from the FTA. The findings of both the modeling work and the biological
study conducted on the groundwater at OU 4 indicate that contaminants should not migrate beyond
the flightline area of Elmendorf AFB, and that through the natural processes already occurring in the groundwater, contamination will be below acceptable levels in a reasonable amount of time (15 years). These findings are supported by the fact that even though the sources of these plumes may have formerlybeen active for several years (especially at the FTA), the plumes have still not migrated very far from their sources.
The Proposed Plan lists asphalt type contaminants found at all OU4 source areas at low levels. In the Deep soils fuel contamination was found at 40' deep (10' from GW surface). 2,200 mg/kg as kerosene in shallow and 3,710 mg/kg as gasoline contamination. Cleanup is 2,000 and 1,000 mg/kg respectively, for kerosene and GRO. COCs in GW is 1,1,1-trichloroethane, 1,1-dichloroethene, 1,2-dichloroethane, tetrachloroethene, TCE, 1,2-dichoroethene, benzene at levels exceeding the MCLs.
Preferred alternative for shallow soils and GW in all areas is IC/IR (institutional controls/intrinsic remediation) and for the deep soils Bioventing is the preferred alternative. This was chosen because it could act a future source of GW contamination.
|
Louis Howard |
| 5/10/1995 |
Meeting or Teleconference Held |
Public meeting held to discuss and take comments on the Proposed Plan for Final Remedial Action at Operable Unit 4. |
Louis Howard |
| 10/4/1995 |
Cleanup Plan Approved |
ADEC commented on the Base Bioventing Treatability Study OU4 dated September 1995. ADEC concurs with the treatability design report as presented and the rationale supporting bioventing at the deep soils at the Fire Training Area ( FT23) , Hangar 11, and the Asphalt Drum Storage Area (ASDA). The selected remedy using bioventing to treat the deep soils satisfies the preference for treatment as a principal element where soils may act as a continuing source for groundwater contamination. Because of the substantial additional cost of actively treating groundwater, the potential for intrinsic remediation within 13 years, and the fact that there are no current receptors of groundwater, institutional controls and monitoring are a better way of addressing groundwater contamination than active treatment. Intrinsic remediation and institutional controls are used in areas where active treatment is impracticable.
NOTE To File: “practicable” means capable of being designed, constructed, and implemented in a reliable and cost-effective manner, taking into consideration existing technol¬ogy, site location, and logistics in light of overall project purposes; “practicable” does not include an alternative if the incremental cost of the alternative is substantial and disproportionate to the incremental degree of protection provided by the alternative as compared to another lower cost alternative. |
Louis Howard |
| 10/10/1995 |
Cleanup Level(s) Approved |
Chemical-Specific Applicable Relevant & Appropriate Requirements (ARARs) identified the following contaminants of concern with their maximum concentrations above the MCL : 1,1,1 trichloroethane (TCA)** 242 ug/L, 1,1-dichloroethene (1,1-DCE) 13.7 ug/L, 1,2-dichloroethane (1,2-DCA) 12.1 ug/L, tetrachloroethene (PCE) 77.8 ug/L, trichloroethene (TCE) 74.7 ug/L, 1,2-dichloroethene (1,2-DCE) 741 ug/L & benzene 398 ug/L.
For petroleum contaminated soil that will be remediated, soil cleanup level "D" from the AK Cleanup Matrix, 18 Alaska Administrative Code (AAC) 78.315, is applicable. 1,000 mg/kg gasoline range organics, 2,000 mg/kg diesel range organics, 2,000 mg/kg residual range organics, 0.5 mg/kg benzene & total BTEX of 100 mg/kg. Action-Specific ARARS: Clean Air Act 42 USC Section 7401 NPSAAQS 40 CFR Part 50 Establishes standards for ambient air quality to protect public health & welfare. Remedial actions must not result in exceedance of ambient air quality standards. There could be air emissions from bioventing.
NOTE TO FILE: NOTE TO FILE: TCA was first prepared in 1840, but was not used in significant commercial quantities for over 100 years. It was first introduced commercially in the US by Dow Chemical in the mid-1950s. TCA's early uses were in cold cleaning applications & as an aerosol propellant. As a propellant, TCA was used in a variety of products including hair sprays. Despite its effectiveness as a cleaning solvent & its significantly reduced toxicity relative to TCE, TCA took many years to gain acceptance in the vapor degreasing market because it was relatively unstable, particularly in the presence of aluminum & when subjected to high temperatures.
TCA was not widely used until improved stabilizer formulations were developed & implemented in the late 50s & early 60s. These stabilizer formulations used several chemicals, chief among them being 1,4-dioxane, to overcome TCA's corrosion problems. As a result of improved TCA stabilizers & the regulation of TCE as an air pollutant, the production of TCA surpassed TCE in 1973. TCA, along with CFCs & other chemicals, were identified as ozone-depleting substances in the mid-to-late 1970s. Aerosol propellants were banned in the US in 1978. The 1990 Clean Air Act Amendments imposed a December 1995 deadline for ending emissive uses, & included other interim deadlines & schedules that significantly decreased TCA use. Dow Chemical ceased TCA production in February 1994.
|
Jennifer Roberts |
| 10/10/1995 |
Institutional Control Record Established |
ICs established by signing of ROD and subsequently been enforced by land planning department at the Base and environmental restoration staff oversight. These institutional controls on land use and water use restrictions are to restrict access to contaminated groundwater throughout OU4 until cleanup levels have been achieved, ICs on land use will continue to restrict access to the contaminated shallow soils (< 5' deep) in OU4 until cleanup levels have been achieved. Deep soils (> 5' deep) at specified locations and depths at the FTA, the ADSA, and hangar 11 will be treated with bioventing to accelerate degradation of contaminants in those locations. |
Louis Howard |
| 10/10/1995 |
CERCLA ROD Approved |
This Record of Decision (ROD) presents the selected remedial action for OU 4 at Elmendorf AFB. In keeping with the premise that the contamination associated with OU 4 was not specifically related to individual hangars, the OU was divided into two "study areas", OU 4 West & OU 4 East. The selected remedy includes the following: 1) active bioventing for deep soils (greater than 5’ below the ground surface) at the Fire Training Area (FTA), Hangar 11, & the Asphalt Drum Storage Area (ADSA), & 2) ICs with intrinsic remediation for any remaining deep soil contamination, all shallow soils (ground surface to 5’ below ground surface), & all GW (GW) within the upper aquifer.
ROD states hangars 10, 11, 14 (SD 24, 25 & 26) GW contamination will be intrinsically remediated & have institutional controls (ICs) on land use & water use restrictions to restrict access to the contaminated GW until cleanup levels have been met.
GW- ICs on land use & water use restrictions will restrict access to the contaminated GW throughout OU 4 until cleanup levels have been achieved. GW will be monitored & evaluated semi-annually to assess contaminant migration & timely reduction of contaminant levels by intrinsic remediation. This will include five-year reviews to assess the protectiveness of the remedial action, as long as contamination remains above cleanup levels. A monitoring plan will be prepared to address the details involved in sampling. All GW is expected to be cleaned up within thirteen years.
Soil - ICs on land use will restrict access to the contaminated shallow soils throughout OU 4 until cleanup levels have been achieved. Deep soils at specified locations & depths at the FTA, the ADSA, & Hangar 11 will be treated with bioventing to accelerate degradation of contaminants in those locations. Deep soils at other source areas will be allowed to degrade through intrinsic remediation. Both shallow & deep soils will be monitored & evaluated bi-annually to assess contaminant migration & timely reduction of contaminant concentrations by intrinsic remediation. This will include five-year reviews to assess the protectiveness of the remedial action, as long as contamination remains above cleanup levels. When concentrations in the bioventing areas are below cleanup levels, bioventing will be discontinued. A monitoring plan will be prepared to address the details involved in sampling. All soils are expected to be cleaned up within 11 years.
The remedy will be implemented after the Remedial Design has been completed. A treatability study for bioventing design is currently in progress. Bioventing will be implemented until cleanup levels have been achieved. The actual timeframe for intrinsic remediation at the other source areas is not known, but GW & soil modeling predict cleanup levels will be achieved in 10 to 15 years.
GW & soil will both be monitored to evaluate the progress of intrinsic remediation processes. Further response actions, coordinated with the regulatory agencies, may be considered if monitoring finds unacceptable contaminant migration occurring, or unacceptable reduction in contaminant concentrations through intrinsic remediation.
See site file for additional information.
|
Kurt Fredriksson |
| 10/31/1995 |
Offsite Soil or Groundwater Disposal Approved |
ADEC received a proposal for IDW disposal for OU4 dated October 30, 1995. Based on the data presented it appears the derived wastes from the FY95 field activities may be disposed of appropriately by the Air Force (AF). Loads will be covered when transporting to a treatment facility and please submit the post treatment results and tare receipts for ADEC files. |
Louis Howard |
| 11/6/1995 |
Update or Other Action |
Staff approved the remedial design/remedial action for OU4 scope of work as submitted. |
Louis Howard |
| 11/8/1995 |
Meeting or Teleconference Held |
Restoration advisory board meeting held and announced beforehand in the Anchorage Daily News 10/29/95 and the Sourdough Sentinel 11/3/95. |
Louis Howard |
| 11/15/1995 |
Update or Other Action |
Basewide Support & GW Monitoring Program, Analytical Results for OUs 3/4 - Round 2 received. The objective of GW monitoring at OUs 3 & 4 is to compare concentrations of contaminants of concern (COCs) to historic concentrations & available background concentrations, at each respective well. Analytical methods utilized for each OU are based jointly on the results of the RI/FS programs conducted at OU 3, OU 4, & OU 5, during which COCs were initially identified.
OU4-MW-11 and FP-56 are associated with FT023 at OU4. OU4-MW-11 has the following exceedances (based on 2018 18 AAC 75 Table C cleanup levels in groundwater): benzene 35.0 ug/L (5 ug/L), ethylbenzene 285 ug/L (15 ug/L), gasoline range organics (GRO) 6.9 mg/L (2.2 mg/L), xylenes 959 ug/L (190 ug/L), diesel range organics 2.88 mg/L "Z" [Hydrocarbons eluting within the jet fuel and kerosene retention time window, but do not match the jet fuel or kerosene pattern.] (1.5 mg/L), cis-1,2-dichloroethene 241 ug/L (36 ug/L), tetrachloroethene 43.8 ug/L (41 ug/L) and trichloroethene 65.2 ug/L (2.8 ug/L).
FP-56: benzene 174 ug/L (5 ug/L), ethylbenzene 167 ug/L (15 ug/L), GRO 5.39 mg/L (2.2 mg/L), xylenes 288 ug/L (190 ug/L), DRO 1.93 mg/L (1.5 mg/L), 1,1-dichloroethane 42.5 ug/L (28 ug/L), 1,2-dichloroethane 6.09 ug/L (1.7 ug/L), ethylbenzene 113 ug/L (15 ug/L), TCE 31.4 ug/L (2.8 ug/L) and lead 17.3 ug/L (15 ug/L).
See site file for additional information. |
Louis Howard |
| 11/30/1995 |
Long Term Monitoring Established |
Remedial action started which includes long term monitoring of the groundwater at Operable Unit 4 source areas. |
Louis Howard |
| 3/7/1996 |
Meeting or Teleconference Held |
Minutes from 7 March 1996 Conference Call. OU3 The project schedule will be completed today and distributed to the agencies Monday, March 11. Steve will be working to coordinate the delivery of the schedule to Tim Brincefield at EPA in Seattle.
OU4-The bioventing systems are installed and operating. We performed some soil gas testing and are putting together a memo to present that information. We just performed the second round of soil gas measurements, this was actually the first round after the bioventing systems were turned on. We found the background checks had total volatile hydrocarbon concentrations in the percent LEL range, and the high PPM range.
During our recent round of checks we noticed a significant decrease in those concentrations. Eight of the wells were down at non-detect for the total volatile hydrocarbons, all but three were in the PPM range. One well located in the Fire Training Area, is in the LEL range and does appear to have a "hotspot". We will be performing another set of background tests in April. Kim noted AFCEE did receive the Final Technical Memorandum. |
John Halverson |
| 4/8/1996 |
Document, Report, or Work plan Review - other |
ADEC provided the AF comments on the Bioventing/Soil Intrinsic Remediation Monitoring Report dated June 1996. ADEC concurs with the recommendations presented in the document. Bioventing to continue for another year and after such time, an additional evaluation of the system can be done and potential modifications may be considered. |
Louis Howard |
| 10/17/1996 |
Update or Other Action |
Air Force memo: Restricted Use of the Shallow Aquifer on EAFB signed by William R. Hanson P.E. GM-14 Chief Environmental Flight dated October 17, 1996 Memorandum for 3 SPTG/CEC/CEO from 3 SPTG/CEV
1) Due to the contamination and commitments to EPA/DEC the use of the shallow aquifer for any purpose on is not allowed. Attached Facilities Board minutes-03/29/1994 0930 Item 9 has Mr. William Hanson, briefing the Board on the policy to not use the shallow aquifer due to contamination. The Board approved this policy. Minutes approved by Thomas R. Case Brigadier General USAF Commander. The IRP has RODs for OUs 3 and 6 which require, the aquifer remain unused. 2) Personnel in the review process within CES must be aware of these policies and review them on a recurring basis. It is imperative this restriction be recognized and observed during engineer reviews and operations. |
Louis Howard |
| 12/31/1996 |
Update or Other Action |
Staff provided comments on the technical memorandum "SOP for Closing Bioventing Systems on the Glacial Outwash Plain at EAFB" dated November 14, 1996. Project managers from ADEC, the EPA, and EAFB agreed that attempting to develop a correlation between monitoring data and closure sampling would be beneficial. If a good correlation is shown to exist, then developing a closure procedure based on monitoring data should be possible. Since there has been extensive site investigation and monitoring work done on EAFB, this appears to be a reasonable alternative. It would reduce sampling costs associated with having to do subsurface soil confirmation sampling at every bioventing site in the outwash plain.
To decide whether this will be a feasible alternative, it will be necessary to identify the number of sites with various types of petroleum contamination; conduct bioventing system monitoring and respiration testing along with confirmation soil sampling at a representative number of the sites; and show a good correlation between the monitoring data and the soil sample results. To do this, ADEC requests a list be prepared showing the number of bioventing sites currently operating or proposed. The site list should be broken down into categories for gasoline range organics (GRO), diesel range organics (DRO), and residual range organics (RRO). ADEC requests 25% of the sites under each category, with a minimum of 10 from each be included in the confirmation soil sampling sites to decide if a good correlation can be developed. If less than 10 sites exist under any category (i.e. RRO) confirmation sampling should be done at each site in that category rather than pursuing an alternative closure process for them.
At Page 3, under "problem definition", it refers to relatively small volumes of contaminated soil commonly treated at the Base through bioventing. It states that once the obviously contaminated soil around an underground storage tank has been removed, the remaining contaminated soil is often in a relatively shallow and even layer. The basis for these statements is not clear. In many cases, when USTs were removed, contaminated soil was placed back into the ground. Since most outwash plain consists of coarse grained soil with a low organic carbon content, most of the releases have resulted in contaminate migration down to the groundwater.
Table #3 Footnote #1 refers to respiration testing between June 15 and September 30. It is likely that some frost may remain in the ground during June. Also, if sufficient biological activity is generated, the soil temperatures would remain elevated later into the year. Therefore, ADEC recommends respiration testing be conducted later in the year (i.e. between July 15 and November 15).
Figure 2 does not include fields for helium injection and monitoring during respiration tests. These should be included to evaluate whether short circuiting may be occurring. Average air flow rates at each venting well should also be reported. This may help indicate whether soil moisture may be a limiting factor due to drying of the soil during bioventing. The depth and screen length of soil implants should be provided on the form to simplify the review process. |
John Halverson |
| 1/17/1997 |
Update or Other Action |
This letter is written to officially notify the Air Force of our change in Project Managers for
Elmendorf Air Force Base. Louis Howard is replacing me as our lead project manager. He will now
be handling all operable units as well as basewide activities under the FFA. Please direct future project correspondence to Louis. He can be reached at the same mailing address, phone # 269-7552, or via facsimile at 269-7649. |
Louis Howard |
| 3/13/1997 |
Update or Other Action |
UPD action on 3/13/97, based on Relative Risk Evaluation Worksheet dated 8/17/95. Pathway: Contaminants dumped on soil in fire pit just below clean surface soils placed there when pit was closed. Soil is mostly gravel with some sand. |
Louis Howard |
| 6/16/1997 |
Update or Other Action |
USAF Memorandum to ADEC regarding Clarifications to OU2 ROD. The letter is a follow-up to the discussions regarding institutional controls at OU2. The USAF hopes by this correspondence, to clarify appropriate land use controls at OU2 and setup a land use restriction method consistent with the most recent Elmendorf RODs. The OU2 ROD states that groundwater at ST41 needs remedial action and a part of the selected remedy was to restrict land use by implementing zoning controls. The Summary of the ROD on page 9-2 states that the selected remedy includes "Zoning the affected area for industrial use only, excluding the development of commercial aquaculture."
However, the Declaration of the ROD states "Zoning the affected area for undeveloped outdoor/recreational use only." In light of this contradiction and the use of "restricted use areas" under the RODs for OU3 and OU6 the USAF is providing clarification of the permissible land uses within the area affected by ST41 groundwater. The affected area should include those areas that exceed the groundwater cleanup levels established in the OU2 ROD. A map of the area currently and potentially impacted by the contaminated groundwater from ST41 is at attachment 1. This map may be revised based upon review of the contamination remaining in place, which will be conducted at least every 5 years. While the affected area remains above cleanup levels, it will be designated as a "restricted use area" in the base Planning Office.
This designation provides for recreational use of the parcel (such as cross country skiing, bicycling, etc.) and the construction of unmanned facilities (such as parking lots, storage buildings, etc. ) but prohibits the construction of any manned facilities (such as office buildings or a residence). Construction activities within the affected area of OU2 will be restricted to construction of unmanned facilities. Furthermore no construction will be allowed which comes within five feet of the groundwater.
Existing industrial uses within OU2 are allowed as they are unmanned. This description conforms to the current base land use planning terminology and is consistent with the recently signed RODs for Operable Units 3 and 6. Land use restrictions will be enforced by the following method. When there is a construction project on Base, the project is to be approved by the Base Planning Office. The planner will route all projects through the Environmental Management Office. The project will be disapproved if it conflicts with the above construction restrictions. The USAF believes this will be a reliable and effective means of enforcing the zoning land use restrictions imposed by the various RODs. Signed by Randy E. Honnet Colonel USAF Vice Commander. |
Louis Howard |
| 7/24/1998 |
Update or Other Action |
June 1998 Remedial Action Report signed. Bioventing and monitoring is continuing at all OU4 locations in accordance with the bioventing and performance monitoring plan, pending confirmation of the achievement of cleanup goals. Efforts are also underway to evaluate the discrepancy between biodegradation rate estimates based on respiration testing as compared to soil analytical results, as are efforts to develop basewide protocols for shut down of bioventing systems.
For shallow soils, sufficient intrinsic remediation has occurred such that cleanup goals have been reached at both soil intrinsic remediation sites. No further monitoring of shallow soils is being done at these sites. Based on the Basewide Groundwater Monitoring Report, groundwater in the shallow aquifer still exceeds cleanup goals. However, due to current land use and institutional controls, there is no human exposure to the groundwater (or contaminated soils).
The site, bioventing systems, and monitoring wells are in good condition. One monitoring well
may need to be reconfigured to a flush mount to accommodate flight operations. Some soils at
certain source areas and groundwater in the shallow aquifer exceed cleanup goals. Response
actions at OU4 are ongoing and are expected to continue for another 11-12 years, based on
current estimates of the time to remediation documented in the 1997 annual report.
The 1997 annual report documented the results to date, which included the conclusion that based
on analytical samples taken in April 1997, bioventing is degrading contaminants at rates in excess of the original predictions, and that one of the three bioventing sites (Hangar 11) is ready for closure at this time. Also, intrinsic soil remediation has achieved cleanup goals at one of the two sites. LTO and maintenance of the remedy must continue until soil cleanup goals are achieved, which is expected to occur within the time frame originally estimated in the ROD.
The OU4 source areas and applicable groundwater and soil use restrictions are documented in the
Base GP and the Environmental Restoration Program MAP, which are consulted prior to approval of changes in land use, siting, work orders, and/or drilling permits. Water use restrictions, in the form of a Basewide prohibition on use of the shallow groundwater aquifer due to contamination, were established on March 29, 1994 by order of the Base Commander.
Institutional controls on land use already in place at the time of the ROD are being relied upon to protect against unacceptable human contact with contaminated shallow soils: apecifically, since these areas are in the vicinity of the runway, routine access to and/or residential development of the areas is prohibited. The bioventing sites are visited at least weekly as part of O&M, so any unplanned changes in land use or other disturbances (i.e., unforeseen releases from other sources) of the area should be noticed in a timely manner. Soil and groundwater institutional controls \-vill be maintained until cleanup goals are met.
The areas in OU4 which remain above cleanup goals will be subject to CERCLA five-year
reviews until such time as cleanup goals are achieved. The OU4 five-year review(s) will be done
as part of a Basewide review. Since the cleanup goals assumed residential use, once the cleanup
goals are met, no further institutional controls or five-year reviews will be required for OU4.
|
Louis Howard |
| 8/10/1998 |
Update or Other Action |
Technical Document to support no further action (NFA) declaration. DESCRIPTION OF THE SELECTED REMEDY- To administratively close Site ST64 from the SERA Phase I program and move it under the SERA Phase IV program as Site ST421.
DECLARATION-Site investigations have been conducted under SERA and as part of the CERCLA OU4 RI/FS. A SERA Phase I site investigation was conducted in 1993. The assessment identified contamination, and concluded an additional investigation was required to define extent of contamination and evaluate groundwater movement. The 1994 OU4 RI/FS assessment detected soil and groundwater contamination at, up gradient, and down gradient from the four USTs (425A, B, C and D). It was concluded the USTs were contributing to and within, a larger plume of contamination originating up gradient and investigated as part of OU4.
The four USTs were removed on 6 Jun 95. Contamination above Level A was detected in all samples collected beneath the USTs. Soil contamination is being addressed under the SERA Phase IV program as Site ST421. Monitoring wells 52WL03 (on site-cross gradient); OU4W-8 (on site-up gradient) and 52WL04 (on site-down gradient) have been sampled twice a year since 5 Jun 95. POL contamination is below ADEC maximum contaminant levels. Monitoring wells 52WL04 and OU4W-8 are included in the OU4 groundwater contaminants of concern effort.
Therefore, groundwater contamination will continue to be monitored under the Basewide Groundwater Monitoring Program until the water meets standards. Due to these conditions, it has been determined the selected remedy of administratively closing ST64 under the ERP is protective of human health and the environment because the necessary cleanup is being done under other programs (Compliance's SERA Phase IV project and Basewide Groundwater Monitoring Program under Operable Unit - OU4).
Proposed Monitoring Plan: OU4W8-On site and upgradient, sampled every six months, GRO, BTEX, DRO. 52WL02-On site and downgradient, sampled every six months, GRO, BTEX, DRO and 52WL04 downgradient, every six months for GRO, BTEX and DRO. |
Louis Howard |
| 8/12/1998 |
Document, Report, or Work plan Review - other |
Letter to AF regarding Response to Comments on draft work plan SERA Phase II Sites ST36/66, ST74, and ST61 Investigation dated July 1998. ADEC disagrees with contractor's response to comments concerning analytical methods discussed in Items 1(i) and 1(m). UST and CS regulations require cleanup levels for GRO/DRO be based on analyticals using AK methods not 8015M/8100M.
The only exception to the analytical methods are found in 18 AAC 78.090: "If site assessment sampling began before November 3, 1995, and if test results satisfy the water quality criteria and cleanup levels referred to in (i) of this section, the owner or operator may continue to use the analytical methods used before that date to complete the site assessment. If a site assessment is begun on or after November 3, 1995, the owner or operator shall use the analytical methods set out in Table G of 18 AAC 78.800(b)."
ADEC requests the AF cease use of alternative lab methods (8015M/8100M) for DRO and GRO analyses by the end of the calendar year for soil and groundwater analysis or long term monitoring which do not include AK 101 or 102. The alternative methods will no longer be acceptable when the new 18 AAC 78 and 18 AAC 75 regulations become final. It is anticipated that the UST and CS regulations will become finalized by the end of this calendar year. Please make changes to any future contracting or scopes of work to ensure that by March 1, 1999 all analyses for gasoline range organics and diesel range organics utilize AK methods for both soil and groundwater. |
Louis Howard |
| 10/20/1998 |
CERCLA ROD Periodic Review |
Five-Year Remedy Review conducted by U.S. EPA, USAF, and ADEC staff to ensure that the remedial actions selected in the Record of Decision for the operable unit remains protective of public health, the environment and are functioning as designed. Elmendorf Federal Facility Agreement 1991
The start of construction of the OU2 Interim Remedial Action (IRA) on August 5, 1993 triggered this review requirement. Response actions at the OU are ongoing, all remedial actions are operational and functional as documented in the OU's remedial action report. All required institutional controls have been established and incorporated into the Base General Plan and the management action plan. Site conditions and land use are consistent with the OU's ROD requirements and remain protective, based on evaluation of current monitoring data and trends, and the most recent joint inspection conducted by the USAF, EPA, and ADEC project managers on April 9, 1998.
Future Five Year reviews are necessary because contamination remains above levels that allow for unrestricted use and/or unlimited exposure at the operable units. The next five year review will be completed by August 2003. |
Louis Howard |
| 1/29/1999 |
Update or Other Action |
Basewide Bioventing Annual Report received. The respiration test data indicate biodegradation rates of zero (0) to 521 mg/Kg/yr. Five of the soil implants at FTA-1 (2A lower, 2C upper, 3A upper, 4B upper, and 4B lower) and one at FTA-2 (1A) have biodegradation rates greater than or equal to 100 mg/Kg/yr. The other implants have consistently had calculated biodegradation rates of less than 100 mg/Kg/yr. Biodegradation rates of less than 100 mg/Kg/yr may not be indicative of hydrocarbon degradation. A review of previous soil boring data suggests that these soil
implants may be located outside the zone of soil contamination, or that the soil 3
contamination is minimal and very slow to biodegrade.
Bristol recommends discontinuing bioventing operations and attempting closure for the fire
training area sites FTA-1 and FTA-2. This recommendation is based on the low biodegradation rates and soil analytical data collected by Radian (Radian, 1997). The soil analytical data collected in 1997 by Radian for FTA-1 area indicates 1,014 mg/Kg DRO, 678 mg/Kg GRO, less than 0.046 mg/Kg benzene, and 4.3 mg/Kg total BTEX are present. These maximum concentrations were observed in the immediate vicinity of bioventing well BV-2. Soil concentrations are all below the ACM level D cleanup standards of 2,000 mg/Kg DRO and 1,000 mg/Kg GRO.
The soil analytical data from FTA-2 collected by Radian in 1997 indicates 380 mg/Kg DRO, 0.8 mg/Kg GRO, 0.013 mg/Kg benzene, and 0.092 mg/Kg total BTEX. These maximum concentrations were found in the immediate vicinity of the bioventing well BV-1, and are below the ACM level D cleanup standards of 2,000 mg/Kg for DRO and 1,000 mg/Kg for GRO. |
Louis Howard |
| 7/12/1999 |
Update or Other Action |
Staff provided AF comments on the Long-term Operations and Maintenance of the Base-wide Bioventing systems at SD25 and FT23 dated May 1999. ADEC does not approve of data gathered from composite samples (except for metals and PCBs) or homogenizing of soil samples. ADEC requests UST Procedure manual be followed for field screening procedures and calibration of field screening instruments. |
Louis Howard |
| 10/25/1999 |
Offsite Soil or Groundwater Disposal Approved |
Staff reviewed AF proposal to thermally treat four 55 gallon drums of POL contaminated soils from the FT23 closure sampling investigation. AF proposed to send the soil to Alaska Soil Recycling for thermal treatment and disposal. ADEC concurred with the proposal on 10/25/99. |
Louis Howard |
| 11/8/1999 |
Update or Other Action |
The location of a former 500-gallon UST (tank 31-338) that was primarily used to store JP-4 jet fuel waste from fuel truck maintenance activities. The UST was removed in August 92, and replaced with a 1,200-gallon UST (31-338A) in an adjacent location.
The depth to groundwater in well 49WL01 located approximately 150 feet south-southwest of the site, was measured at 13.59 feet below ground surface (bgs). The depth to groundwater in the bioventing vent well was measured at 11.53 feet bgs. Shallow groundwater is not currently used as a drinking water source and is unlikely to be used as one in the future. Contaminant of concerns (COCs) with initial contamination levels are as follows:
Initial Contamination Levels for Soil Water
Diesel Range Organics (DRO) 860 mg/kg 9,700 ug/l
Gasoline Range Organics (GRO) 3,600 mg/kg 9,700 ug/l 9 Benzene .033 mg/kg 740 ug/l
Toluene 1.3 mg/kg 35 ug/l
Ethylbenzene 4.9 mg/kg 95 ug/l
Total xylenes 80 mg/kg 1,300 ug/l
STATEMENT OF BASIS-This decision is based on the following attached references:
a. Site ST71 from SERA Phase I Corrective Action Plan (CAP), Final, Apr 95
b. Alaska Department of Environmental Conservation's (ADEC) 27 Feb 97 Ltr
c. Table 4-17, Basewide Annual Groundwater Report, Final, Mar 98 (49WL01)
d. Site Closure Report for Site ST71, Nov 96 (refer to your copy)
e. Table 5-8, Basewide Annual Groundwater Report, Final, Jun 99 (49WL01)
f. Table 2-4, Basewide Monitoring OU4-Round 1, Aug 99 (49WL01)
DESCRIPTION OF THE SELECTED REMEDY-No further remedial action remedy is based on the field sampling conducted on 28 May 96 pursuant to closure of site ST71 on base. All of the laboratory analytical results for vadose zone soil were below ADEC (1995) Category A soil cleanup levels for all analytical methods. These results indicate that petroleum hydrocarbons in the vadose zone soil at the site have been remediated to the applicable matrix cleanup levels during the operation of the bioventing system.
Monitoring well 49WL01 has been added to the OPERABLE UNIT (OU)4 monitoring program. With the exception of benzene concentrations in groundwater at down gradient well 49WL01 (14.9 ug/l), GRO (930 mg/kg at 49BH07-12 and 500 mg/kg at 49BH08-13), and DRO (1,600 mg/kg at 49BH07-12) concentrations in saturated soil samples, this site meets all applicable state cleanup goals. Contaminated soil below the watertable is not effectively remediated through bioventing.
The vadose zone soil was below ADEC (1995) Category A soil cleanup levels for all analytical methods. This has allowed the bioventing system at this site to be turned off in 1997 and will be removed in the future. The groundwater contamination is under the cleanup levels in Table C using the criteria outlined by 18 AAC 75.345 (b)(2)(A)&(B). In addition, the wetland remediation system constructed on the Ship Creek flood plain prevents ST71 contamination from leaving the base property boundary. Therefore, there is no further requirement for tracking conditions at ST71. Monitoring well 49WL01 has been added to the OPERABLE UNIT (OU)4 (Basewide) monitoring program.
If any information is presented in the future that indicates contamination from this project area is present (above established cleanup levels) and/or poses a risk to the public's health or the environment, then additional assessment and corrective action may be necessary. The location of this monitoring well is useful to track trends of trichloroethene (TCE), dichloroethene (DCE), and chloride concentrations in the outwash plain. The remedy of no further remedial action under the ERP is selected because the contaminant levels at the site present no significant threat to human health or the environment; thus, no treatment is necessary. |
Louis Howard |
| 11/9/1999 |
Update or Other Action |
OU4 round 2 monitoring results received. Monitoring wells FP-56 results for benzene decreased slightly from 8.7 to 8.4 ug/l and TCE remains detected in the associated blank as well as the sample at TCE 7.7 in round 1 and 6.1 ug/l in round 2. OU4W-11 benzene levels decreased from 11 ug/l to 6.1 and TCE decreased from 68 to 48 ug/l in round 1 sampling to round 2 sampling events respectively. |
Louis Howard |
| 12/10/1999 |
Document, Report, or Work plan Review - other |
Staff reviewed site closure report for SD 25/FT 23. Recommend bioventing be expanded beyond current areal extent and operation be continued until cleanup levels are achieved in soil. |
Louis Howard |
| 1/10/2000 |
Update or Other Action |
10/99-12/99 quarterly progress report received. Received round 2 analytical results-13 wells sampled and 4 wells exceed the MCL for benzene and 5 wells exceeded the MCL for TCE. Closure sampling for SD25 and FT23 indicated sites did not meet the cleanup levels established in the ROD. Continue operation of bioventing system at SS10, SD25 and FT23 and collection of data associated with system operation. Target date to meet cleanup levels in groundwater is October 2008 and in soil September 2003. |
Louis Howard |
| 4/10/2000 |
Update or Other Action |
1 January- 31 March 2000 quarterly report received. Results of closure sampling for FT23 and SD25 indicated that these sites did not meet the cleanup levels established in the OU4 ROD. Sites will continue bioventing for FY00. |
Louis Howard |
| 6/1/2000 |
Update or Other Action |
Environmental Monitoring Plan received. The purpose of the Basewide Environmental Monitoring Program (EMP) is to provide information on surface water and groundwater quality, groundwater flow characteristics, and monitoring well integrity at specified locations throughout Elmendorf AFB. The data assessment portion of the program includes data collection via groundwater and surface water sampling, and groundwater level measurements.
Groundwater samples will be collected biannually from 14 wells as part of the OU 4 Groundwater
Sampling Program. The groundwater samples at OU 4 will be analyzed for anions (chloride, sulfate, and nitrate), volatile organics, total iron, and diesel and gasoline range hydrocarbons. Like OU 2, the methods prescribed for this OU are based jointly on the results of the RI/FS programs conducted at OU 4 and at OU 5 and on assumptions made in the OU 4 ROD, during which constituents were identified as COCs. The proposed analytical methods for OU 4 include, but are not limited to, these COCs. A comparison of the data to 1998 Groundwater Model predictions for the Outwash Plain will be included as part of the conclusions for OU 4, as well as a discussion of observable trends of contaminant concentrations over time.
MTBE will be added to the list of compounds analyzed in the Method SW8260B volatile organics
analysis. This change is made as a result of a request by ADEC to monitor for this compound at all wells in the Basewide Sampling Program for one year. |
Louis Howard |
| 8/23/2000 |
Update or Other Action |
2000 Groundwater monitoring well results received. In 2000 methyl tert-butyl ether (MTBE) was added to the list of analytes and not detected in any of the wells. Benzene was above the MCL in three wells and TCE was above the MCL in five wells. OU4W-04 was substantially higher than the concentration detected during Round 2 in 1999. |
Louis Howard |
| 10/2/2000 |
Update or Other Action |
Quarterly progress report received for the 3rd quarter 1, July 2000-30 September 2000. Round 2 groundwater samples collected in August 2000. Three wells exceeded the MCL for benzene and five wells exceeded the MCL for TCE. Continued operation of the bioventing system at SS10, SD25, and FT23 and collection of the data associated with the system operation. |
Louis Howard |
| 1/12/2001 |
Update or Other Action |
Quarterly progress report received for the 4th quarter October 2000 to December 2000. Round 2 groundwater analytical results received. 4 wells exceeded maximum contaminant level (MCL) for benzene and 5 wells exceeded MCL for TCE. Continued operation of the bioventing system at SS10, SD25, and FT23. |
Louis Howard |
| 3/21/2001 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft 2000 Bioventing Annual Report dated February 28, 2001 received on March 5, 2001. ADEC concurs with the recommendations for this site. However, it should be noted the 1995 Record of Decision (ROD) for Operable Unit (OU) 6 states: "Deep soils at specified locations and depths at the FTA (FT 23) the ASDA, and Hangar 11 will be treated with bioventing to accelerate degradation of contaminants in those locations. Deep soils at other locations will be allowed to degrade through intrinsic remediation. Both shallow and deep soils will be monitored and evaluated bi-annually to assess contaminant migration and timely reduction of contaminant concentrations by intrinsic remediation.
Bioventing will be implemented until cleanup levels are achieved. The actual timeframe for intrinsic remediation at the other source areas is not known, but groundwater and soil modeling predict cleanup levels will be achieved in 10 to 15 years."
The ROD does not specify the frequency period while monitoring of soils and groundwater for intrinsic remediation, but it does state that "Groundwater and soil will both be monitored to evaluate the progress of intrinsic remediation processes." There is specific language regarding the evaluation of other remedial technologies or alternatives in the ROD: "Further response actions, coordinated with the regulatory agencies, may be considered if monitoring finds unacceptable contaminant migration occurring, or unacceptable reduction in contaminant concentrations through intrinsic remediation." |
Louis Howard |
| 4/17/2001 |
Update or Other Action |
Overall, ADEC concurs with Elmendorf’s approach to reduce its groundwater monitoring costs while still providing protection to human health, safety, or welfare and the environment. With regards to decreasing the monitoring frequency in Operable Unit (OU) 1 to an annual basis, ADEC concurs. With regards to OU 6, ADEC recommends not discontinuing groundwater monitoring at well 703-WL-02 and to continue to monitor for methyl tert-butyl ether (MTBE). |
Louis Howard |
| 1/2/2002 |
Update or Other Action |
Staff received the seventh Annual Report of Groundwater Sampling Activities developed for the
Elmendorf Air Force Base (AFB) Basewide Environmental Monitoring Program, hereafter referred to
as the Basewide Program. The Basewide Program encompasses two field programs, the Basewide
Groundwater Sampling Program and the Basewide Water Level Monitoring and Well Optimization
Program. This Annual Report of Groundwater Sampling Activities contains a summary of 2001 water
quality data and interpretations from the Basewide Groundwater Sampling Program. The Annual
Technical Memorandum (United States Air Force [USAF], 2002a) developed and distributed as a
separate deliverable report, addresses activities associated with the Basewide Water Level Monitoring and Well Optimization Program.
The Basewide Program was established through the Elmendorf AFB Installation Restoration
Program (IRP) to address the needs of multiple programs on the base. These programs include the
Federal Facilities Agreement (FFA), and the State-Elmendorf Environmental Restoration Agreement
(SERA). Over the following two program years, 2002 and 2003, the focus of the Elmendorf AFB
Basewide Program will be modified to reflect the requirements outlined in appropriate Records of
Decision (RODs), decision documents, corrective action documents, and/or any other binding
agreements. In an effort to optimize the program, several changes may occur in sampling frequency, in the wells sampled, and in groundwater seep sampling.
The following are conclusions derived from intuitive and statistical analysis of 2001 groundwater data for OU 4:
* As a result of the 2001 Decision Guide analysis of the OU 4 program area, it is recommended that one well, 48-WL-01, be removed for the 2002 program year. The well is currently one of four
wells within the same TCE plume. In place of this well, a new well should be installed
downgradient of the plume and well 48-WL-03 (OU 5) to delineate the plume boundary and more
effectively monitor natural attenuation.
* For wells in the OU 4 program area, a measurable free product layer was not detected in 2001.
However, a fuel odor and /or hydrocarbon sheen was noted at four well locations (OU4W-08,
FP-56, OU4W-11, and 49-WL-01).
* OU 4 groundwater COCs exceeding primary MCLs during the 2001 sampling events includes benzene, PCE, and TCE. Benzene exceeded the MCL at three well locations (FP-56, OU4W-04, and OU4W-08); PCE exceeded the MCL at two well locations (OU3-MW-11 and OU4W-11); and TCE exceeded the MCL at five well locations (48-WL-01, 49-WL-01, FP-56, OU3MW-1 1, and OU4W-11). Benzene, previously found above the MCL in OU4W-11, was found below the MCL in the well in 2001.
* Five wells at OU 4 contained statistically valid trends using current available data for benzene. Only wells FP-56, OU4W-04, and OU4W-08 exceeded the benzene MCL of 5 ug/L in 2001. Only one of the five wells showing decreasing trends exceeded the MCL, well FP-56. The two remaining wells exceeding the MCL, OU4W-04 and OU4W-08, had no statistical trend.
* Eight wells at OU 4 contained statistically valid trends using current available data for TCE. The TCE MCL was exceeded at wells 48-WL-01, 49-WL-01, FP-56, OU3MW-11, and OU4W-1 1. Of the wells exceeding the MCL, three showed statistically significant decreasing concentrations
(48-WL-01, 49-WL-01, and FP-56) and one (OU3MW-11) established no statistical trend.
* Data imply that natural attenuation is removing organic contaminants within OU 4. |
Louis Howard |
| 2/21/2002 |
Document, Report, or Work plan Review - other |
Staff commented on the base-wide groundwater annual report.
Regulatory Levels
ADEC requests removing the word “Potential” from the heading “Potential Regulatory Level” in the tables throughout the document. Listing the word “Potential” gives the reader the impression that compliance with the levels listed is optional or not required (e.g. Tables 4-7, 4-11, 4-15, 4-20, 4-25, 4-29, 4-32, and 6-2).
Free Product
Please note 18 AAC 75.325(f) states: A responsible person shall to the maximum extent practicable,
(A) use permanent remedies;
(B) recover free product in a manner that minimizes the spread of contamination into an uncontaminated area by using containment, recovery, and disposal techniques appropriate to site conditions.
ADEC recognizes that in some cases it may not be technically practicable to implement an active or passive recovery system for free product. The Elmendorf Remedial Action Report for Operable Unit (OU) 2 (September 1998) set a precedent for defining what is meant by “technically practicable” for free product recovery. Section 2.4.1 Product Recovery Endpoints at the 1st bullet on page 10 states: “As designed and constructed, the ST41 ground water treatment system cannot recover floating product when there is less than a measurable thickness of 0.1 feet of product. Therefore, as an endpoint for product recovery, if less than 0.1 feet is sustained for one year, recovery at that source can be discontinued. Floating product will be measured monthly. When product thickness falls below 0.1 feet for one year, the recovery of product at that source will not be considered “technically practicable”.
Therefore, where free product is greater than 0.10 feet, ADEC expects corrective action (active or passive) to be implemented for free product recovery. Currently, free product was found to exceed 0.10 feet or more in SERA Phase I well 43-WL-11. This well had the highest level of free product measured at 0.86 feet. The presence of measurable free product is generally not considered conducive for intrinsic (natural) attenuation. ADEC requests the identity of the free product be described in the text at each source area that it is found (e.g. gasoline, diesel, or chlorinated solvents).
3.3.4 Target Analytes Pages 3-10 and 3-11
Benzene and TCE are identified as target analytes to evaluate contaminant of concern (COC) trends in detail and be consistent with the Base-wide Groundwater model. ADEC concurs, however, focusing on these two analytes does not accurately reflect whether diesel range organics (DRO) and gasoline range organics (GRO) plumes are migrating, expanding, steady state, or receding (especially for wells noted to have either free product or fuel odor and/or sheen being observed during sampling). Benzene can be at low levels or even non-detectable while concentrations of DRO and GRO remain above cleanup levels (1.5 mg/L and 1.3 mg/L respectively). Please see the following examples below of where benzene was below the 5 ug/L cleanup level, but DRO and GRO are above cleanup levels.
OU 4
Round 1 sampling at well 49-WL-01 detected benzene at 0.11 ug/L and DRO at 2,400 ug/L and well OU4W-11 detected benzene at 4.3 ug/L while GRO was detected at 3,000 ug/L and DRO was detected at 6,100 ug/L.
OU6
Round 1 sampling at well OU6MW67 detected benzene at 2.8 ug/L, GRO at 2,500 ug/L and DRO at 1,700 ug/L during round 1 sampling. During round 2 sampling, well OU6MW-91 detected GRO at 25,000 ug/L and DRO at 9,500 ug/L [NOTE TO FILE: LNAPL is considered present where analytical data shows DRO concentrations above the theoretical solubility limit for diesel of 3.9 mg/L] while benzene was found to be non-detectable.
See site file for additional information. |
Louis Howard |
| 3/7/2002 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Base-wide Bioventing report for 2001.
General Comments -Decommissioning Bioventing Systems
Where the Air Force is recommending bioventing systems be decommissioned, the Department requests additional clarification if the Air Force has looked at other alternatives to treat the "smear zone" (Smear Zone: the vertical area over which groundwater fluctuates (thereby the contaminated water will smear floating and dissolved contamination into the soils in the zone)) contamination and found it was not practicable to implement them.
The basis for not being practicable can be due to reasons such as: reliability of the alternative, alternative is not cost effective, site location, logistics in light of overall project purposes. If an analysis of alternatives was conducted, then it should be stated it is not practicable due to the incremental cost of implementing an alternative is substantial and disproportionate to the incremental degree of protection provided by the alternative as compared to another lower cost alternative.
Well Log Submittal
The Department also wishes to inform the Air Force of the well log recording requirement by the Alaska Department of Natural Resources (ADNR), Division of Mining, Land and Water. The requirement is referenced in the Underground Storage Tank (UST) Procedure Manual, Section 4.7.1 Installing groundwater monitoring wells. Alaska statutes: 38.05.020, 38.05.035, 41.08.020, 46.15.020 and regulations 11 AAC 93.140 require a log of the well be submitted to the ADNR within 45 days after installing a well.
The Department concurs with the expansion of the current bioventing system to address contamination present at SB62. Additionally, the Department concurs that contamination present at SB64 is likely the result of smearing of hydrocarbon-impacted groundwater and will not be effectively treated with a bioventing system. |
Louis Howard |
| 3/22/2002 |
Update or Other Action |
AF requested review and approval on a emailed request for FT23 expansion of a biovent system. ADEC approved it and noted that ADEC review and concurrence on this request is to ensure that
the work is done in accordance with State of Alaska environmental
conservation laws and regulations. While ADEC may comment on other state and
federal laws and regulations, our concurrence on the request does not
relieve the U.S. Air Force from the need to comply with other applicable
laws and regulations. |
Louis Howard |
| 6/3/2002 |
Update or Other Action |
Final Environmental Mgt. Plan received.
Additionns/removal of analytical methods.
OU4: Methane, ethene, ethane, & total Organic Carbo were added to more effectively monitor natural attenuation of chlorinated solvents & fuels.
ARARs were developed in the OU 4 ROD (USAF, 1995b) by considering regulatory standards (ARARs). 1,l1,-trichloroethane; 1,1-dichloroethene; 1,2-dichloroethane, chloroform, ethylbenzene, & toluene were dropped from the list due to analytical results.
GW samples at OU 4 will be analyzed for anions (chloride, sulfate, & nitrate), volatile organics, gasoline range organics (GROs), diesel range organics (DROs), total iron, total organic carbon, & dissolved gases. Like OU 2, the purpose for monitoring at OU 4 is to assess contaminant migration & the timely reduction of contaminant concentrations by natural attenuation. COCs include several chlorinated solvents & benzene, ethylbenzene, & toluene. In this program area, natural attenuation monitoring will include the target analytes (which are all VOCs), electron acceptors, electron donors, daughter products, & byproducts. Analysis of data will be performed on a plume-by-plume basis & will focus on the natural attenuation pathway responsible for the breakdown of each type of contaminant found.
One well, 48-WL-01, will be removed from OU 4 in 2002 due to an abundance of in-source well locations at the associated plume. The effort will shift to provide a broader investigation downgradient of the plume associated with this well. Two wells, OU4-E3 & IS6-01, will be added to OU 4 in 2002 to monitor a chlorinated solvent plume in OU 4 East. The OU 4 ROD (USAF, 1995b) specifies the expected cleanup date of 2002. The wells will be sampled twice in 2002 to determine if the ROD cleanup date has been met for this plume.
Target analytes will be used to evaluate ARAR trends in detail over time through statistical, graphical, & spatial analyses (see Section 3.3). Identification of target analytes were consistent with the Basewide GW Model (USAF, 1994b). Hence, benzene & TCE were selected as target analytes for all sites, except OU 1 & SERA sites. For OU 1, target analytes are manganese & TCE. For SERA sites the only target analyte is benzene.
Of the constituents detected in GW, aromatic & halogenated compounds were found over the widest area of the base. Benzene was selected from the aromatic compounds detected because of its potential health impacts. TCE was selected from the detected halogenated compounds for the same reason. Aromatic & halogenated compounds have different migration & breakdown characteristics.
Aromatics tend to be soluble compared to chlorinated compounds & will "float," staying near the water table if they are not dissolved in water. Aromatics typically degrade rapidly under aerobic (oxygen-rich) conditions.
Chlorinated compounds (e.g., TCE), typically less soluble than aromatics, will sink if not dissolved in water, & degrade more slowly under aerobic or anaerobic conditions. By selecting benzene & TCE, the established trends reflect organic compounds that behave differently.
Because the target analytes selected for this program are consistent with those used in the GW modeling effort, new target analytes will not be selected if benzene or TCE are eliminated as a COC for a given program area. For example, if benzene is eliminated as a COC from OU 4, only TCE will be evaluated in the future as a target analyte for that program area.
The same methodology used in the 1999 Annual Report was used in the 2000 & 2001 Annual Report & will be carried over to the 2002 Annual Report. Sen's Nonparametric Estimator of Slope will be used to determine an overall trend of historical & "current" data on a well-by-well basis for wells having ten (10) or more valid data points.
This analysis will also confirm or deny conclusions established from the intuitive time series plots (see Section 3.3.1) & will provide statistically sound evidence of any new potential contaminant releases. Mann-Kendall statistical analysis will be used to allow determination of trend for "current" conditions (1999-2002). To focus analysis on current conditions statistical analysis will use only the last five years of data. |
Louis Howard |
| 8/28/2002 |
Meeting or Teleconference Held |
STATUS MEETING MINUTE ELMENDORF BASEWIDE MONITORING PROGRAM AUGUST 28, 2002 Attendees: Joe Williamson (USAF), Cindy Hood (AFCEE), Terry Beach (AFCEE), Kevin Oates (EPA), Louis Howard (ADEC), Cory Hinds (URS), Russ Beck(URS)
Agenda: Review of soil gas surveys and new well locations, Recommendation for treatment of TCE at OU5 Seeps 9, 10, and 11 in the existing Wetland Remediation System, Well sampling frequencies for 2003
2003 Monitoring Well Sampling Frequencies
URS presented the new proposed Basewide decision guide for determining sampling frequencies for monitoring wells. Proposed monitoring frequencies are based on position of plumes relative to environmental receptors. Plumes immediately upgradient of a receptor were proposed for annual sampling. Plume not immediately upgradient of a receptor were proposed for sampling every 2 to 5 years.
EPA pointed out that this guide is only appropriate for stable plumes and suggested that we add a box to include a decision for unstable plumes. Unstable plumes should be sampled semi-annually if upgradient of a receptor or within the early warning line in OU 5.
URS presented the new sampling frequency table, which is based on plumes rather than program areas. EPA and ADEC agree that it makes sense to organize on a plume-by-plume basis instead of by program area. The Air Force mentioned that there will be additional wells required for the early warning system at OU5, and that some of the early warning sampling will be conducted using passive diffusion bags. Use of the passive bags may mean that it is feasible to sample in the winter. EPA, ADEC, and URS agreed on modification of sampling frequencies. In general, sampling frequencies were increased when the plumes were close to a receptor (i.e., Ship Creek) or the concentrations of contaminants were increasing. A list of the agreed sampling frequencies is attached.
Additional items discussed:
• WP14: Air Force mentions reducing number of wells. ADEC mentions an early warning system. These will be discussed later.
• Air Force will investigate the floating product at OU4 West. |
Louis Howard |
| 1/14/2003 |
Meeting or Teleconference Held |
Meeting minutes from January 14, 2003 meeting with Joe Williamson (USAF), Gary Fink (USAF), James Klasen (USAF), Kevin Oates (EPA), Louis Howard (ADEC), Cory Hinds (URS), Paul Dworian (URS), Kristin Paul (URS)
Discuss ADEC’s request to add the analyses of Diesel Range Organics (DRO) and Gasoline Range Organics (GRO) to several Operable Units at Elmendorf.
1. URS summarized recent (year 2000) ADEC risk assessment guidance that shows that DRO and GRO themselves can cause noncarcinogenic human health risks. This information was not known during preparation of the risk assessments and RODs for Elmendorf Operable Units. Therefore, addition of DRO/GRO to the sampling scheme for Elmendorf was recommended.
2. The Air Force agreed to add DRO/GRO, but cannot add funding to cover the additional analysis until 2004.
3. The following was decided on implementation:
A. This decision will be documented in the 5-Year Review. The addition of DRO/GRO to the program should be introduced in the 5-Year Review under mention of new issues affecting protectiveness.
B. The Air Force will NOT add DRO/GRO as a CERCLA ARAR, but will compare DRO/GRO results to ADEC cleanup levels in the annual reports and will discuss in subsequent 5-Year Reviews. The benefit of this is that if CERCLA COCs meet ARARs, the Air Force can achieve a partial delisting.
C. The Air Force will add DRO and GRO to the suite of analyses at monitoring wells associated with fuel plumes starting in 2004.
D. The Air Force will not pursue a decision document with ADEC on DRO/GRO until more data is gathered on the extent of the problem.
E. Until a decision document is signed with ADEC, GRO and DRO concentrations will be compared to ADEC regulations in 18 AAC 75 (Table C, Groundwater Cleanup Levels; 1,500 µg/L for DRO, 1,300 µg/L GRO).
F. Sampling frequency for DRO/GRO will follow the latest Decision Guide for Sampling Frequency (see 2002 Basewide Annual Report). “Immediately upgradient” means within a 2-year warning line, similar to that generated for OU5.
G. ADEC GRO/DRO criteria apply to groundwater, not to seeps which daylight as surface water. Criteria in 18 AAC 70 (TAH, TaqH) apply to surface water. |
Louis Howard |
| 1/31/2003 |
Update or Other Action |
2002 Annual Report Basewide Environmental Monitoring Program Draft January 2003 received. Note to file under:
ARARs
This data-reporting category addresses groundwater constituents for each individual program area
specifically identified as COCs. The original list of cleanup levels for each program area is listed in Table 2-1. These chemical-specific cleanup levels were identified either in decision documents prepared for these sites (FFA program areas) or as contaminants which were found to significantly exceed cleanup levels where groundwater COCs were not specifically identified in previous investigations (SERA and Taxiway “N” program areas). Source documents that listed cleanup levels are referenced in Section 4.
Within the context of the Basewide Program, the list of COCs for each program area can change
as data are continuously evaluated and the quality of data improves with new methods. For instance, as natural attenuation occurs, select constituents will reach cleanup levels and additional monitoring for that constituent will not be required unless mandated by a regulatory agreement. Specifically, if a COC is below cleanup levels for two consecutive sampling rounds, sampling for that COC can be discontinued.
Similarly, if cleanup levels for all COCs in a given analytical method are met across an entire program area, analysis using that method in that program area will no longer be required. An exception to the above guideline is made for OU 5. Because OU 5 serves as the downgradient receptor for most of the other program areas, COCs will not be eliminated from OU 5 unless the COC in question has been similarly eliminated first from all upgradient program areas. |
Louis Howard |
| 2/14/2003 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft SD15 HVE System Annual Technical report. Staff concurs with the recommendations in Table 5-3 to address the two known areas of shallow soil contamination, minimize vacuum to the deep soils and to increase vacuum pressure at wells W-1301, 1302 and 1303. |
Louis Howard |
| 2/25/2003 |
CERCLA ROD Periodic Review |
Staff reviewed the draft bioventing five year review document. The five-year review of remedial actions taken at all operable units is to ensure they remain protective of human health and the environment. Under CERCLA such reviews are required at least every five years after a record of decision is signed if contaminants remain in place.
Please clarify in the document whether or not groundwater sampling has been conducted at FT23 and whether or not the thirteen year prediction for all groundwater being cleaned up will be met. The closure samples taken at FT23 did not state what contaminants of concern (COCs) were above remediation goals in the two of the twenty one samples taken. The Department requests further clarification in the document on what these COCs were and whether or not soils will be expected to be cleaned up within eleven years (modeling predicted remediation within ten-fifteen years for soils/groundwater) as stated in the record of decision.
The text does not mention whether or not groundwater at FT23 is above cleanup levels in wells at the site or in nearby wells which would contribute to the “smearing” of soils at the saturated interval. The Department requests each contaminant of concern for each source area, not just SD25, be listed in a table identifying: the chemical, media of concern (groundwater, shallow or deep soils where applicable), remediation goal, and the basis for remediation goal.
Annual system Operations and Maintenance (O & M) costs which were present in the OU 6 SD15 five year review document submitted to the Department are notably absent in this document. The Department requests O & M Costs for the bioventing systems be provided which cover, at least, the time period since the last five year review was conducted. Also, the Department requests the Air Force address whether large variances in O & M costs have occurred which could indicate a potential remedy problem or remedy issue.
The Department wishes to state the State-Elmendorf Environmental Restoration Agreement (SERA) is no longer applicable since it has been dissolved by the State and Air Force effective October 21, 2002. Since the SERA has been dissolved, releases to the land and waters of the State which have not been properly characterized and formally closed out will need to be addressed following the applicable current contaminated sites and underground storage tank regulations (18 AAC 75 and 18 AAC 78, respectively). |
Louis Howard |
| 6/11/2003 |
Meeting or Teleconference Held |
MEMORANDUM FOR FILE FROM: 3 CES/CEVR SUBJECT: Minutes, Remedial Project Manager Meeting, 11 June 2003
A quarterly meeting of the remedial project managers (RPMs) convened at 1430 on 11 Jun 03 in the Environmental Flight (CEVR) conference room, Building 5312. Mr. Louis Howard (Alaska Department of Environmental Conservation (ADEC), Mr. Kevin Oates (Environmental Protection Agency (EPA) - Anchorage), Mr. Gary Fink (CEVR), Mr. Joe Williamson (CEVR), Ms. Donna Baumler (CEVR), and Ms. Doris Thomas (Public Affairs (3WG/PA) attended. Mr. Claude Mayer (CEVR) joined the meeting via teleconference. Mr. Jim Klasen (Legal (11AF/JACE) was attending a training course and was unable to attend.
DP98, Land Use Control Issues (Ms. Baumler). Ms. Baumler stated that the Land Use Control (LUC} Management Action Plan (MAP) was completed in January. It has been updated to include information for DP98. A signature page for the Environmental Protection Committee (EPC) Chairman also has been added. In the future, we plan to have a wing instruction to assist in the enforcement of the MAP. Ms Baumler provided copies of the DP98 inserts which incorporate Mr. Howard's review comments regarding continuous implementation of institutional controls. The MAP will go to the EPC Chairman for signature and should be ready for distribution by the end of the month.
DP98, 2 Jul Meeting for Proposed Plan (Mr Mayer). Mr Mayer stated that the proposed 2 Jul date
would coincide with the date comments were due from agencies and would provide an opportunity to
meet with the contractor to resolve any issues.
Mr. Oates commented that the date would work with his schedule and reminded us that he would be gone in 31 days. He agreed that the meeting would be beneficial. Mr. Oates made a few remarks about the Proposed Plan. He said some new issues have arisen in the last few years, such as groundwater analysis of 1,4-Dioxane. This chemical was sometimes used as a stabilizer for different types of ethenes. Mr. Howard stated that detection requires a different method of analysis from the type we currently use.
Mr. Williamson said that we would add the new analysis to the Basewide Groundwater Monitoring Program next year. |
Louis Howard |
| 7/17/2003 |
CERCLA ROD Periodic Review |
Staff reviewed and commented on the second draft five-year review for Elmendorf's Operable Unit (OU) OUs 1, 2, 4, 5, 6. Section 121 of CERCLA, as amended by the Superfund Amendments and Reauthorization Act of 1986 (SARA), requires that remedial actions which result in any hazardous substances, pollutants, or contaminants remaining at the site be subject to a five-year review. The National Oil and Hazardous Substances Pollution Contingency Plan (NCP) further provides that remedial actions which result in any hazardous substances, pollutants, or contaminants remaining at the site above levels that allow for unlimited use and unrestricted exposure be reviewed every five years to ensure protection of human health and the environment. The requirement applies to all remedial actions selected under CERCLA §121. Therefore, sites with CERCLA remedial actions may be subject to a five-year review. Consistent with Executive Order (EO) 12580, other Federal agencies are responsible for ensuring that the reviews are conducted at sites where five-year reviews are required or appropriate.
"1991 Elmendorf Federal Facility Agreement: XIX Five Year Review 19.1: If a remedial action is selected that results in any hazardous substances, pollutants, or contaminants remaining at the Site, the Parties shall review such remedial action no less often than each five (5) years after the initiation of such remedial action to assure that human health and the environment are being protected by the remedial action being implemented. The U.S. EPA Project Manager and the ADEC Project Manager shall advise the USAF Project Manager of their findings in this regard."
The text makes several recommendations and follow-up actions for various operable units. The Department suggests the Air Force formalize these recommendations or follow-up actions in either a separate technical memorandum or separate formal document, as appropriate, to EPA and ADEC for concurrence or non-concurrence to be placed in the administrative record.
General comment: OU (matrix and units) listings are not consistent with the rest of the document. Operable unit 4 is listed as OU 4 instead of “OU4” as is Operable Unit 5 and 6 which are listed as OU 5 and OU 6 instead of OU5 and OU6. Please correct this to be more consistent within the document. The Department requests clarification on the origin of the OU 4 soils cleanup level for 4, 4-DDT at 34 mg/kg. In 18 AAC 75.341 Table B-1 states that DDT has a cleanup level for ingestion in the Under 40-inch zone of 24 mg/kg. Additionally, for OU 5, Di-n-butyl phthalate and Diethyl phthalate have 2,700 ug/L and 23,000 ug/L listed as groundwater cleanup levels in the table.
In 18 AAC 75.345 Table C, the groundwater cleanup levels listed for Di-n-butyl phthalate is 3.65 mg/L or 3,650 ug/L and for Diethyl phthalate it is listed as 29.0 mg/L or 29,000 ug/L. Please correct Table B-1 to reflect the correct cleanup levels or provide justification as to leaving the cleanup levels unchanged.
General comments: The Department requests changing the column heading for Current Applicable Standard (Table B.1.) to include Table C or drop Table B.1 reference and leave it as Current Applicable Standard. Otherwise, the reader will infer that Table B.1 (Soil Cleanup Levels) applies to groundwater cleanup levels, which is incorrect. Also, see comment above regarding OU labeling within Table B-2 to match rest of the document (e.g. OU1 vs. OU 1). See comments above regarding cleanup levels for: 4, 4-DDT, Di-n-butyl phthalate, Diethyl phthalate.
General comment: Also see comment regarding Operable Unit labeling within the table to match rest of the document (e.g. OU1 vs. OU 1). The Department requests that the origin of the cleanup levels for the three OU 4 contaminants of concern be clarified. The Table B1 soil cleanup inhalation values for: 1,1,2-Tricholorethane is 460 mg/kg not 457 mg/kg, benzene is 9 mg/kg not 8.64 mg/kg, and for methylene chloride it is 180 mg/kg not 457 mg/kg. Please correct text in Table B-3. |
Louis Howard |
| 1/27/2004 |
Update or Other Action |
The second five year review was signed by ADEC. The purpose of this five-year review is to evaluate the implementation and performance of the remedial actions that were selected in the Record of Decision (ROD) for each Operable Unit (OU). TCE concentrations in the East Plume; TCE, tetrachloroethane, and 1,2-dichlororethene in the Fire Training Area Plume (FT23); and benzene in wells OU4W-04 and OU4W-06 may not reach groundwater cleanup levels by the target date of 2008. In addition, the bioventing system at FT23 was expanded in 2003 to address additional soil contamination discovered at this site. Therefore, soil cleanup levels in the new area may not be met by 2008.
For groundwater, conduct a thorough review of modeling results and evaluate the potential for natural attenuation to achieve cleanup levels in the timeframes specified in the ROD. Revise and/or recalibrate the models, if needed. Continue groundwater monitoring according to the guidelines of the Base wide Groundwater Monitoring Program until cleanup levels are met. For OU4, continue bioventing at the new site until soil cleanup levels are met.
Recommendations and Follow-up actions: Review and revise the frequency of sampling for some wells in OU4, OU5, and OU6 in accordance with the decision guide. Several wells in OU4 have been shown to meet COC cleanup levels and warrant less frequent monitoring. Progress since the last Five Year Review-No areas of non-compliance were identified during the first five-year review in 1998. At that time, all remedies were protective of human health and the environment and LUCs adequately prevented potential exposure to contaminants present in soil and shallow aquifer. No recommendations for follow-up actions were made during the 1998 review.
The remedial systems were operating and functioning as designed and no modifications were required. Since 1998, contamination at OUs 1, 2, 4, 5, and 6 has decreased and the remedies continue to protect human health and the environment-as long as LUC are in place Contamination remains above levels that allow for unlimited use and unrestricted exposure at OUs 1, 2, 4, 5, and 6. Site inspections at OU4 reveal that bioventing systems and monitoring wells are in good condition.
Data from FT23 (FTA-1 location) indicated that only low levels of hydrocarbon contamination remain in the subsurface. The original bioventing treatability study areas met cleanup levels at both FTA-1 and FTA-2. Later, in 2002, the system at FTA-1 was expanded to address contamination at SB-62, a soil boring location not previously included in the original bioventing treatability study. Therefore the system has successfully remediated contaminants as intended by the decision documents and the system has been expanded and continues to operate to address newly found contamination. Bioventing system O&M procedures and LUCs continue to ensure protectiveness of the system.
There is a newly promulgated groundwater standard for 1,1-dichloroethane. The maximum detected level of 14 ug/L in 2002 is below the new standard of 3,650 ug/L; therefore, the new standard is being met at the site and the remedy is protective for this COPC. The new standard is risk based and, if concentrations were present at the level of the standard, hazards would not exceed the target hazard quotient goal of 1 (1,1-dichloroethane is a non-carcinogen). |
Louis Howard |
| 7/16/2004 |
Update or Other Action |
2003 Annual Tech report Environmental Monitoring and System Optimization of Base wide Bioventing Systems. Cleanup standards FT23: DRO 2000 mg/kg, GRO 1000 mg/kg.
Historical: In 2002, the bioventing system at FT23 was expanded to address contamination
surrounding SB62. Two injection wells were installed near SB62, and drilled to depths of 23 and 40 feet bgs. Four additional soil borings were advanced to install soil vapor implants in order to monitor vapors from the system. The upper soil implants were screened at approximately 11-12 feet bgs and the lower implants were installed at approximately 32-33 feet bgs.
Only blower FTA-1 is operating at FT23. Blower FTA-2 was shut down in 2000 because remediation at the injection well and soil vapor implant locations associated with this blower was complete. Blower FTA-1 was connected to three injection wells until the 2002
expansion. One of the bioventing injection ports (BV 5) at the Fire Training Area (FT 23) was modified and fitted with a pitot tube in 2003 as described in Section 2.9. Currently the blower is connected to five injection wells.
Recommendations: It is recommended that the bioventing system be left in operation, with
continued biweekly monitoring and maintenance activities. During 2003 respiration tests, the BV-5C upper implant had an oxygen concentration of 5.6% prior to system shutdown. It is recommended that the oxygen concentrations be monitored at all BV-5 upper locations to ensure adequate O2 is available for biodegradation to occur. If O2 concentrations drop below 5%, the
blower pressure should be increased. Once in-situ respiration test data indicate that bioventing is not contributing to remediation at the site, closure soil sampling should be performed. |
Louis Howard |
| 2/3/2005 |
Meeting or Teleconference Held |
Memorandum for File from 3 CES/CEVR. A quarterly meeting of the remedial project managers (RPMs) convened at 0830 on 3 Feb 05 in the Environmental Flight (3 CES/CEV) conference room, Building 5312. Mr. Louis Howard (Alaska Department of Environmental Conservation (ADEC)), Mr. Joe Williamson (Environmental Restoration (CEVR)), Mr. Gary Fink (CEVR), Mr. Claude Mayer (CEVR), Ms. Ellen Godden (CEVR), and Ms. Donna Baumler (CEVR) attended. Mr. Kevin Oates
(Environmental Protection Agency (USEPA) - Anchorage) joined via teleconference.
No action items remained from the previous RPM Meeting held on 19 Jul 04; however, the 3
Feb 05 meeting was previously scheduled for 20 Jan 04, and two topics were discussed briefly
on that date. Mr. Mayer had follow-up information regarding one of these topics, the Fire
Training Pit (FT23). He has received an updated design, and it appears that one comer of one
building falls within the boundary ofFT23. When the site boundary was drawn during the
remedial investigation and feasibility study (RIIFS), there did not appear to be much
contamination in the area, but the boundary was extended to ensure protectiveness. Mr. Mayer
asked if it would be possible to allow for excavation in this area as long as the contractor took samples and took measures to protect trench workers. Mr. Howard and Mr. Oates concurred that a minor site letter would allow excavation under these circumstances. Mr. Fink asked for
clarification regarding the boundary, specifically if there was a "no excavation" zone.
Mr. Oates replied that there is not a "no excavation" zone; however, if we excavate in areas of known contamination, as opposed to "gray" areas, we must modify the record of decision (ROD).
Additionally, if contamination is found in the "gray" area, we must stop work and modify the
ROD before work can proceed. Mr. Fink asked if there is a field-screening test for
trichloroethene (TCE). Mr. Oates replied that he did not know of one, specifically, but suggested that an on-site laboratory with a portable gas chromatograph might be an option.
Update on Zone implementation (Mr. Williamson). We began the break out into zones (1, 2, and 3)
last May. By 1 Oct 06, the change will be fully implemented. Currently, the RPMs are preparing FY06 programming documents for their respective zones and have been reviewing documents for their zones since last summer. The change should improve the whole process of document review and site management. Groundwater will be broken into zones, but Mr. Fink will retain a basewide report.
Quarterly Progress Reports (QPRs) (Mr. Williamson). Mr. Oates and Mr. Howard confirmed that the information they receive in the report, in its current format, is quite useful to them when they are briefing their higher headquarters. Both agreed that we could reduce submittals to semi-annual reports, which will be submitted in December and May. Mr. Howard requested that we continue to break sites out by Operable Unit since that is the way their database has been designed to track. |
Louis Howard |
| 3/1/2005 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the base wide annual technical report for bioventing systems. The Department concurs with the recommendations for the site to leave the bioventing systems operating. |
Louis Howard |
| 3/21/2005 |
Update or Other Action |
2004 Phase I RPO Annual Report Groundwater Performance Optimization Monitoring Program received. The long-term monitoring plan for the FTA Plume is to continue monitoring PCE, TCE, and benzene concentrations. Monitoring activities should be performed to verify that decreasing trends continue. To optimize performance monitoring at this plume, it is recommended that the following evaluations be performed on the FTA Plume:
COC monitoring: COC monitoring for this plume is currently performed at two in-source wells to capture information from a POL and chlorinated solvent plume. Monitoring network optimization and sampling frequencies should continue to be determined by using the decision guides in Appendix H.
MNA monitoring: It is recommended that MNA samples no longer be collected from the FTA Plume. An MNA evaluation is not possible when only two in-source wells are sampled for these parameters.
Cleanup date predictions: The OU 4 ROD allows remedial activities to proceed at this plume until the early cleanup date of 2008. It is possible that PCE and TCE levels will not be below OU 4 ROD-specified levels by 2008. SourceDK Tier 1 is the appropriate program for estimating a new cleanup date for the FTA Plume.
Bioventing treatment system: Bioventing has been ongoing for several years to reduce smear zone contaminants at the FTA Plume. With the installation of two new injection wells in 2002 to address an area of newly discovered contamination, a total of five injection wells are now employed at this plume. Because of the recently discovered area of contamination, it is recommended that this bioventing system remain in operation.
Contaminant mass calculations: Contaminant mass calculations cannot be determined at this plume with any high degree of accuracy because the FTA Plume is a two-well plume. It is recommended that contaminant mass calculations not be performed at the FTA Plume.
Remedy protectiveness summary – groundwater: MNA is the selected remedy for groundwater at the FTA Plume. This remedy should be considered protective of human health and the environment. COC concentrations are decreasing, plume expansion is not occurring, and potential downgradient receptors are not being exposed to groundwater contaminants. Land use controls are also in place, which prevent the use of groundwater from the shallow aquifer.
Remedy protectiveness summary – soil: Bioventing is the selected remedy for subsurface soil at the FTA Plume. This remedy should be considered protective of human health and the environment because it is reducing soil contaminant levels that could potentially contribute to groundwater contamination. The bioventing system at the FTA Plume has been expanded to treat a recently discovered pocket of contamination. Additionally, one of the blowers (FTA 2) associated with this site has already been shut down in 2000 because remediation goals were achieved at the related injection well and soil vapor implants (USAF, 2003).
It is recommended that the COC monitoring network be reevaluated with existing decision guides during the summer of 2005. In addition, a revised cleanup date for this plume should be developed. These exercises should be performed and the findings should be submitted as a stand-alone report before the 2005 Annual Report is prepared. The results of the reevaluation would not be generated in time to guide field activities during 2005, but would be available to influence recommendations in the 2005 Annual Report. |
Louis Howard |
| 4/1/2005 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (ADEC) received the 2004 Phase I RPO Annual Report (DRAFT FINAL) Groundwater Performance Optimization Monitoring Program on March 21, 2005. Below are ADEC’s comments on the document.
General Comments-Typically, delineating a plume of contaminated groundwater takes more than one well in the source area. ADEC requests the Air Force redraw boundaries for “plumes” in the following figures where one well is defining a “plume” of contaminated groundwater with a bold line and replace it with a dashed line to show it as being “inferred” or “interpreted” rather than a distinct boundary.
Zone 1 - Figures 3.2-1 and 3.3-1 for wells: OU6MW-46 and OU6MW-63, Figure 3.3-3 for well OU6MW-46, Figures 3.5-1 and 3.6-1 for well ST41-10R, Figure 3.9-1 for wells: OU6MW-46 and OU6MW-63, Figure 3.10-1 for well OU6MW-46
Zone 2 - Figure 4.1-1 for well 59WL-31, Figure 4.3-1 for well SP7/10-04, Figures 4.3-1 and 4.5-1 for well OU4MW-04, Figure 4.6-1 for well OU4MW-08R, Figure 4.7-1 for IS6-01, Figures 4.9-1 and 4.10-1 for wells: SP7/10-04 and W-4
Zone 3 - Figure 5.3-1 for well OU3MW-25, Figure 5.5-1 for wells: 60WL-04 and 64WL-01, Figure 5.6-1 for wells: 64WL-01 and 62WL-05, Figure 5.10-11 for well LF59MW-03
3.2.4 Phase I RPO Conclusions and Recommendations- Verifying that plume expansion is occurring with one monitoring well is nearly impossible to do without additional monitoring wells. The text states that the OU6 ROD mandated 5-year reviews be performed to evaluate the performance of the selected remedy (MNA). However, the recommendation in this section for MNA monitoring states MNA assessments cannot be accurately performed at one-well plumes. Also the text states plume expansion is not occurring and potential downgradient receptors are not being exposed to groundwater contaminants. ADEC requests clarification on how it can be demonstrated with one monitoring well that downgradient receptors are not being exposed to groundwater contaminants and whether or not it can be shown a plume is expanding or shrinking when sampling data is limited to one well.
The comments above apply to: PL81 South Plume (Section 3.3.5), ST41 North Plume (Section 3.5.4), 59WL-31 (Section 4.1.5), Hangar 10 Plume (Section 4.5.4), Hangar 11 Plume (Section 4.6.4), OU4 East Plume (Section 4.7.5), SS43 Plum (Section 4.9.4), W4 Plume (Section 4.10.4), OU3MW-25 Plume (Section 5.3.4), and SP01-2 Plume (Section 5.8.4).
7.0 Phase I RPO Recommendations Summary Page 7-1 - ADEC concurs with updating the conceptual site models for inclusion in the 2005 Program Baseline Calculations Report.
7.1 Plume-Specific Recommendations - ADEC concurs with the plume-specific recommendations listed in this section which are not provided in Table 7.1-1. |
Louis Howard |
| 3/6/2006 |
Document, Report, or Work plan Review - other |
Staff reviewed the draft 2005 Phase I RPO Annual report. The text states if significant downgradient migration were to occur, the contaminants found at FT23 would be detected at downgradient sites. ADEC requests the Air Force specify which sites are downgradient of FT23 that are monitoring these same contaminants of concern (COCs). The OU 4 Record of Decision (ROD) identified benzene, 1,1,1-trichloroethane, 1,1-DCE, 1,2-dichloroethane (DCA), PCE, TCE and 1,2-DCE as COCs. Currently, the remaining COCs associated with FT23 are benzene, TCE and PCE.
NOTE: Wells used to monitor FT23 are FP-56 and OU4W-11. |
Louis Howard |
| 5/15/2006 |
Update or Other Action |
2005 Soil Sampling Report: single soil boring drilled and two field samples collected and one field duplicate from the boring. Diesel range organics (DRO) still exceeds the cleanup standards for this site at 15 ft. bgs. DRO levels were reported as high as 2,630 mg/kg which exceeds the 2,000 mg/kg cleanup standard identified in the OU4 Record of Decision. Concentrations of GRO and BTEX were not detected above the cleanup standards in any sample. |
Louis Howard |
| 6/21/2006 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft Zone 2 Remedial Actions/Operations Workplan, Elmendorf AFB, June 2006.
1.1 Project Purpose and Scope Page 1-1 The text refers to an RPO being prepared for all operating systems and plumes in Zone 3 which will include an evaluation of cleanup dates or establishing cleanup dates in Zone 3. This document is for Zone 2. Please correct text as needed where it refers to Zone 3.
2.6.1 Operable Unit 1 Page 2-9 and 2.6.3 Operable Unit 6 Page 2-11 The text in both sections refer to site LF02 as being in both operable units. Please correct text to reflect placement of LF02 in the correct operable unit.
ADEC’s review and concurrence on this specific work plan is to ensure the proposed work is in accordance with State of Alaska environmental conservation laws and regulations. While ADEC may comment on other state and federal laws and regulations, our concurrence does not relieve the United States Air Force (USAF) or its consultants, contractors, subcontractors, agents acting on its behalf or AF civilian personnel from complying with other applicable laws and regulations.
NOTE: Zone 2 consists of seven sites and eight groundwater plumes: FT23 (TCE & Tetrachloroethene (PCE), SD15 (benzene and TCE), SD24 benzene, SD25 (toluene and benzene), SD28, SD29 (TCE and PCE), SS43 (benzene, GRO, DRO), and ST32 (benzene, GRO, DRO).
|
Louis Howard |
| 2/23/2007 |
Exposure Tracking Model Ranking |
|
Louis Howard |
| 3/6/2007 |
Update or Other Action |
NOTE: this is a duplicate of JBER-Elmendorf Fire Training Pit AFID 435 Hazard ID 23569 file number 2101.26.047 (old identifier RecKey 199421X028001 Spill date 10/12/1998). FTA Pit AFID 435 was administratively closed out March 6, 2007 for further action under Operable Unit 6 source area FT023 is the actual site.
PFAS soil contamination from AFFF usage will still need to be addressed and GW wells installed to characterize PFOA/PFOS contamination not detected in cross-gradient well (FP56) sampled at FT023 in 2016 (SI Report for AFFF Areas on JBER May 2018).
|
Louis Howard |
| 3/17/2007 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft Annual Monitoring Field Report Zone 2 Remedial Actions/Operations, Elmendorf AFB, February 2007.
5.3.3 FT23 Page 5-2
The recommendation for FT23 is to continue with bioventing until sample results confirm the vadose zone soil cleanup standard has been met at this site. ADEC concurs with the recommendation.
|
Louis Howard |
| 6/19/2007 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the draft Technical Report Surface/Sub-surface Soil and Groundwater Sampling at C-17 Maintenance Complex Phase ELM242. Staff requested clarification on the use of EPA's region 6 Soil Screening Levels for contaminated soil and water sampling results. |
Louis Howard |
| 7/31/2007 |
Update or Other Action |
In 2007, Elmendorf AFB initiated construction of two new hangars at Site FT23. Four VOCs (benzene, TCE, PCE, and cis-1,2-DCE) have been historically detected in the monitoring wells closest to these buildings. Based on this information, an evaluation of the vapor intrusion to indoor airway pathway at the new buildings was initiated by the USAF. The United States Environmental Protection Agency (USEPA) published guidance regarding vapor intrusion that begins with a simple and generally conservative screening approach that gradually progresses toward a more complex assessment to evaluate whether the vapor intrusion pathway is complete and significant (USEPA, 2002). ADEC also published guidance on evaluation of vapor intrusion pathways based on the USEPA document (ADEC, 2004). The tiered approach discussed in the USEPA and ADEC guidance documents was used to determine if a complete vapor intrusion pathway exists at Site FT23.
Tier 1 of this approach consisted of a preliminary screening evaluation to determine whether site specific conditions indicate the potential for a complete subsurface vapor intrusion pathway. The Tier 1 evaluation accounts for contaminant volatility and toxicity, depth and distance of the contamination from the structure, and the presence of current or future inhabited structures. At Site FT23, VOCs have been detected in groundwater that are
1) toxic,
2) have historically been detected in groundwater at depths less than 100 feet bgs, and
3) are beneath or within 100 feet laterally or vertically of inhabited buildings.
Based on this information, a complete vapor intrusion exposure pathway was deemed possible and a Tier 2 evaluation was merited. The Tier 2 evaluation compared contaminant concentrations detected in groundwater at Site FT23 to generic numerical criteria that reflect a reasonable worst-case scenario based on an incremental lifetime cancer risk of 10-6 or a non-cancer hazard index of 1.0 under a residential exposure scenario (USEPA, 2002). |
Louis Howard |
| 3/7/2008 |
Update or Other Action |
ZONE 2 2007 PHASE I REMEDIAL PROCESS OPTIMIZATION REPORT received. Site FT23, consists of two small plumes. Two source areas are responsible for the GW contamination: a drum storage area & a bermed burning area. The drum storage area contained as many as 100 55-gallon drums of contaminated waste oils, paint thinners, waste fuel, & waste solvents from aircraft maintenance & other shop operations. Fire training activities were conducted in the bermed areas from the 1940s to 1983. From the 1940s to 1960s, combustible wastes such as oils, fuels, & solvents were used as fuel for the exercise. The OU4 ROD was signed for in 1995.
DRO & GRO were identified as COCs for soil. COCs & cleanup levels in GW at FT23 include 1,1,1-trichloroethane (TCA) (200 micrograms per liter [µg/L]), 1,1-dichloroethane (DCA) (7 µg/L), 1,2-DCA (6 µg/L), tetrachloroethene (PCE) (5 µg/L), TCE (5 µg/L), cis-1,2-dichloroethene (DCE) (70 µg/L), & benzene (5 µg/L).
Estimated cleanup time for GW in the OU 4 ROD was 13 years (or 2008). Chlorinated compounds (TCE & PCE) are the only contaminants currently exceeding the GW cleanup criteria at this site.
Terminating bioventing operations at some locations has led to decreasing concentration trends for both PCE & TCE. The only bioventing system currently operating is near the FP-56 Plume. It is being operated to address remaining soil contamination above the cleanup criteria in deep soils near BV-5 (at 15' below grade surface [bgs]). Until confirmation soil sampling can be completed, the biovent system air flow should be directed toward the shallow injection wells, which are screened from approximately 7.5' - 22.5' bgs. This will accomplish two objectives: 1) focus treatment on soils remaining above treatment standards & 2) decrease the impact of the biovent system on the geochemical conditions near the water table. Confirmation sampling at SB62 is scheduled to be completed in the summer of 2009 to verify that soil contamination meets criteria.
The recommendations for the FTA plumes are as follows:
Short-Term (FY08-FY09) - Continue monitoring. Sample soil at SB62. Complete confirmation sampling to closeout the soils remedy. Until confirmation sampling can be completed, stop air flow to deep biovent injection wells at BV-2, BV-3, BV-4, & BV-5. Balance air flow in the upper biovent injection wells to focus treatment where soil contamination may remain above cleanup criteria while allowing residual organics closer to the water table to aid in TCE & PCE degradation. Install a new well or sample existing wells W-15 or GW-5A near new construction to assess water quality in this area. Following successful confirmation of soil cleanup, remove bioventing system.
Long-Term (FY10 or Longer): Continue monitoring. Perform RPO evaluation. Perform long-term monitoring optimization study & implement with approval from regulatory agencies. Monitor according to optimized monitoring schedule.
See site file for additional information. |
Louis Howard |
| 4/22/2008 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft 2008 Zone 2 Work Plan. There are eight active sites within the Zone 2 Management Area: FT23, SD15, SD24, SD25, SD28, SD29, SS43, and ST32. The objective of the project for FT23 is: Evaluate the potential vapor intrusion pathway at FT23 to new buildings constructed near the site.
Table 1.1 Site Descriptions Page 1-5: The table refers to various locations with the number of wells in the monitoring program and a listed contaminant of concern (COC) in Record of Decisions (ROD) or Decision Documents. ADEC concurs with this approach generally, however, ADEC requests the Air Force have a separate table for contaminants which are presently exceeding established groundwater cleanup levels found in 18 AAC 75 Table C or Region 6 Human Health Medium Specific Screening Levels when no maximum contaminant level (MCL) exists.
While not a listed specific COC in the RODs, these contaminants are of interest to the State for groundwater monitoring as long as they continue to exceed cleanup levels established in 18 AAC 75.
For example a review of previous groundwater reports found these exceedances: 2005 Laboratory Analyses Appendix F Attachment F-1 Fire Training Area (FTA): OU4W-11 Page 13 of 24 - Cis-1,2-Dichloroethylene CAS Number: 156-59-2 210 µg/L 18 AAC 75: 70 µg/L.
Appendix C Section 3 Site Investigation Analytical Procedures
3.1.1 Zone 2 Page 3-1: The text states the following constituents associated with releases impacting the sites have been designated as site COCs: VOCs, specifically benzene, TCE and tetrachloroethene (PCE) and fuel constituents, specifically gasoline range organics (GRO) and diesel range organics (DRO). ADEC requests the Air Force expand the list to include other contaminants which currently exceed Table C Groundwater Cleanup Levels in 18 AAC 75.345.
|
Louis Howard |
| 7/31/2008 |
Update or Other Action |
The concentration of TCE detected in groundwater samples collected in 2008 from monitoring wells GW-5A (31 µg/L) and OU4W-11 (12 µg/L) exceeded the USEPA (2002) generic screening level of 5.3 µg/L. The results of this Tier 2 assessment using 2008 groundwater data suggested a potentially complete and significant vapor intrusion pathway for TCE at Site FT23. Based on this information, further evaluation of the potential vapor intrusion pathway was recommended for the 2009 field season. |
Louis Howard |
| 10/15/2008 |
Update or Other Action |
5 YR Review
OU4 Remedy Implementation Status
Deep soils at specified locations and depths at the Fire Training Area (FT23), the asphalt drum storage area (SS10), and Hangar 11 (SD25) will be treated with bioventing to accelerate degradation of contaminants in those locations. Deep soils at other source areas will be allowed to degrade through intrinsic remediation.
Bioventing is ongoing at FT23. SS10 and SD25 have reached cleanup levels and bioventing systems were shut down in 2006 and 2003, respectively.
Both shallow and deep soils will be monitored and evaluated to assess contaminant migration and timely reduction of contaminant concentrations by intrinsic remediation (i.e., natural attenuation). This will include five year reviews to assess the protectiveness of the remedial action, as long as contamination remains above cleanup levels.
Soils meet cleanup levels at all sites except for one sampling location at FT23. Sampling locations and frequency are updated periodically. Five-year reviews were conducted in 1998, 2003 and 2008.
The remedy at OU4 is expected to be protective of human health and the environment upon attainment of soil cleanup levels through bioventing at two remaining sites (FT23 and SS10) and attainment of groundwater cleanup levels through natural attenuation. In the interim, exposure pathways that could result in unacceptable risks are being controlled.
During the period 2003 through 2007, there were several notable detections of contaminants at OU4 in addition to COCs:
• Bromomethane was detected in well FP-56 at 0.11 µg/L in 2005, but has never been detected prior to or after 2005. Bromomethane was not identified as a COPC for FT23.
There is no MCL or ADEC cleanup level for bromomethane.
Recommendations for changes to the OU4 monitoring program include:
• Perform confirmation sampling to close out the soils remedy at FT23 in 2010 or sooner.
Site Inspection
The bioventing system was inspected and found to be operational. Mr. Marty Hannah, the system operator, reported O&M problems including failure of an electrical controller and blockage of one vent during the winter, probably due to ice. Land use changes included construction of new hangars on a portion of FT23. Vapor barriers have been incorporated into the design of the hangars to control migration of VOCs into indoor air. All active monitoring wells were located, and one well needs a replacement cap. There was no evidence of unauthorized wells or any other site disturbance.
Changes to land use were evident at sites FT23 and LF04, but site conditions are understood and precautions to prevent exposure are being incorporated into the design of the new facilities. Difficult environmental conditions as evidenced by frost heaving of wells are routinely addressed through maintenance.
Issues
Inconsistent Cleanup Levels: The cleanup levels for 1,2-dichloroethane, PCE, and TCE for FT23 groundwater, and DRO and GRO for SD24 and SD25 soil, as presented in OU4 ROD, are inconsistent with their referenced standards. The cleanup levels for 1,2-dichloroethane, PCE and TCE at FT23 are listed as 6 µg/L instead of the MCL standard of 5 µg/L.
The cleanup levels identified for DRO and GRO at SD24 and SD25 are 1,000 and 2,000 mg/kg respectively, which is the reverse of their referenced Alaska Cleanup Matrix Level D standard. These inconsistencies appear to be typographical errors because there is no discussion in the ROD about deviation from the referenced standards.
Recommendations/Follow-up Actions
Update the ROD-specified cleanup levels for 1,2-dichloroethane, PCE, and TCE for FT23 groundwater, and DRO and GRO for SD24 and SD25 groundwater, so that they are consistent with their referenced standards. Document the updated cleanup levels in a memorandum to the site file.
Conduct soil sampling in 2010 or earlier. If soil meets cleanup levels, prepare Site Closure report, shut down the bioventing system and remove bioventing components.
|
Louis Howard |
| 2/23/2009 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft Zone 2 Management Area Annual Report, January 2009. There are eight active sites within the Zone 2 Management Area: FT23, SD15, SD24, SD25, SD28, SD29, SS43, and ST32.
General Comments
ADEC requests the Air Force submit completed ADEC Laboratory Data Review checklist(s) (currently version 2.5) with this report for review as required by ADEC Technical Memorandum 06-002 (October, 9, 2006). ADEC has determined that the quality assurance submittals described in the memorandum are necessary to meet requirements of 18 AAC 75.335 (b) (2) (B) & (G), 75.335 (c) (3) & (4), 75.355 (a), 75.360 (2) and 18 AAC 78.007. However, if an independent third party conducted the data quality assessment for data validation (other than OASIS or PARSONS) which meets the requirements of the checklist, then the review presented in the document would be sufficient. Please provide the name of the company/agency that conducted the review. Otherwise, please complete the checklist(s). This matter was raised in a previous letter to the Air Force (April 2007 ADEC letter on Draft Annual Monitoring Field Report Zone 3).
Specific Comments
2.4.1 Groundwater Elevation Measurements Page 2-3
The text states in developing the groundwater contours for Figure 2.1, the groundwater elevations at some wells were not considered due to uncertainty with the accuracy of the data, including the groundwater elevation at well FP-56, which has a fully submerged screen. ADEC requests clarification on whether this is an issue which needs to be addressed by installation of a monitoring well to replace FP-56 or whether there are enough other comparable wells which do not have their screens submerged to develop groundwater contours.
2.4.2 Groundwater Analytical Results Page 2-3
The text states laboratory analysis did not detect any other contaminants of concern (COCs) at concentrations above applicable cleanup levels. This is partially true for COCs specified in the 1995 Operable Unit 4 (OU4) Record of Decision (ROD). However, in Appendix C Table C-1, well OU4W-11 shows a result of 160 ug/L for cis 1-2 dichloroethylene which is above the 1995 ROD cleanup level listed in Table 5-2 on page 5-6 of 70 ug/L. Please correct text to state that this COC is also above cleanup levels. |
Louis Howard |
| 3/17/2009 |
CERCLA ROD Periodic Review |
Cover letter to the EPA's Five-Year Review signature sheet sent to Richard J. Walberg, Colonel, US Air Force Vice-Commander from EPA Region 10 Office of Environmental Cleanup Daniel D. Opalski, Director. The Environmental Protection Agency (EPA) has completed their review of the third Five-Year Review report for the United States Air Force (USAF) Elmendorf Superfund site, in Anchorage Alaska.
EPA reviewed this report for technical adequacy, accuracy, and consistency with EPA guidance. In general, EPA agrees with the protectiveness determinations in this report. However, I understand that all parties to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Section 120 Federal Facility Agreement (FFA) are aware of a potential new source that has not been fully characterized, namely SS-022. It is also my understanding that while the Five-Year Review identifies this potential new source, the USAF has not adequately discussed the interim measures it has already taken to ensure protectiveness as site characterization proceeds, such as Institutional Controls (ICs) at SS-022 and the ongoing Remedial Investigation.
Therefore, we recommend that within ninety (90) days (by June 15, 2009), USAF supplement the Site File and Administrative Record with a Memorandum to document the ICs (e.g., installation of a fence, signage, and notation on the Environmental Restoration Program Atlas) that have been implemented for the protection of human health and the environment at SS-022. The Memorandum should also mention the Installation-wide ICs (including restriction of ground water use) already in place.
In addition, EPA agrees with USAF's recommendation for further action at the OU-l landfill area for the trichloroethylene (TCE) groundwater contamination, and requests that the Program Managers meet to discuss the timeline for completion of the groundwater contamination characterization and establish deadlines and, as appropriate, target dates for subtasks, as required under the FFA.
|
Louis Howard |
| 7/31/2009 |
Update or Other Action |
In 2009, six shallow vapor monitoring points, identified as FT23VMP-01 through FT23VMP-06, were installed along the perimeter of Buildings 17508 and 17534. The vapor monitoring points were installed on 06 August 2009 using direct push methods, with soil vapor implant screens set at approximately 3 feet bgs. Soil vapor samples were collected using 6-liter summa canisters on 14 August and 18 August 2009 and were submitted to a fixed-base laboratory for analysis of VOCs.
Soil vapor VOC analysis results for the COCs at FT23 (1,1,1-TCA, 1,1-DCA, 1,2-DCA, PCE, TCE, cis-1,2- DCE, and benzene) were compared to the most conservative cleanup levels in the USEPA (2002) vapor intrusion guidance. None of the COCs exceeded their respective screening levels.
Chemical (screening level ppbv), maximum ppbv, (screening level ug/m3) maximum ug/m3
1,1,1-TCA (200,000) 380 (1,100,000) 2,100
1,1-DCA (62,000) 0.43 U (250,000) 1.7 U
1,2-DCA (12) 0.43 U (47) 1.7 U
PCE (60) 20 (410) 140
TCE (2.1) 0.75 F (11.0) 4.0 F
cis-1,2-DCE (4,400) 0.65 U (18,000) 2.5 U
Benzene (49) 1.1 (160) 3.6
Screening level based on Table 3c-SG of USEPA, 2002 and a vapor attenuation factor of 2 x 10-3; ppbv = parts per billion by volume; ug/m3 = micrograms per cubic meter. |
Louis Howard |
| 11/11/2009 |
Update or Other Action |
Draft MEMORANDUM TO THE SITE FILE Elmendorf Air Force Base Operable Units (OUs) 1,2,4, and 5 received. The minor revisions to the OU 1,2,4 and 5 RODs clarify how LUCs will be implemented and managed for activities within these operable units. In addition, this minor revision will correct inconsistencies to chemical specific ARAR in the Operable Unit 4 ROD. In 2003, the USAF published guidance for active installations entitled Air Force Policy on Performance-Based Records of Decision (RODs) for Land Use Control (LUC) Implementation (SAF/IE Memo, 7 Oct 03) requiring documentation of LUCs in administrative documents such as the ROD. LUCs are part of the selected remedies in the RODs for OUs 1,2,4, 5, and 6 and Site DP98.
This Memorandum to the Site File uses the 2003 guidance to clarify how the USAF intends to implement the LUCs at OUs 1,2,4 and 5.
Some of the cleanup levels presented in the OU4 ROD Table 5-2 (Chemical specific ARARs for Groundwater and Soils) are inconsistent with their referenced standards. These are likely typographical errors. Specifically, the clean up levels for 1,2- dichloroethane, tetrachloroethene, and TCE at the FT23 are presented as 6 ug/L, but the source ofthe cleanup level is the drinking water maximum contaminant level (MCL), which was, and is, 5 JLg/L for all of these chemicals (and also listed as 5 ug/L in Table 4-1 of the ROD). Also, the SD25 soil cleanup level values for GRO and DRO appear to be reversed. This Memorandum to the Site File establishes corrections to these inconsistencies.
Land Use Control Objective: Restrict access to the contaminated groundwater throughout OU 4
until cleanup levels have been achieved. Restrict access to the contaminated shallow soils throughout OU 4 until cleanup levels have been achieved. Designate OU4 for "Airfield Use Area" for aircraft operations and maintenance, to include active and inactive runways, taxiways, and
parking aprons for aircraft.
Proposed Minor change-Groundwater: Institutional controls on land use and water use restrictions will restrict access to the contaminated groundwater throughout OU 4 until cleanup levels have been achieved. OU4 is designated "Airfield Use Area" for aircraft operations
and maintenance, to include active and inactive runways, taxiways, and parking aprons for aircraft. Land Use Controls will be managed and implemented in accordance with section
4.1 of this memorandum to site file.
Soil: Institutional controls on land use (also called LUCs) will continue to restrict access to the contaminated shallow soils throughout OU 4 until cleanup levels have been achieved. |
Louis Howard |
| 12/1/2009 |
Update or Other Action |
Semi-annual progress report received. SUMMARY OF WORK PERFORMED DURING LAST SIX MONTHS-Received final Five-Year Review Findings Report (Apr 09), Distributed Final Five-Year Review Results Fact Sheet (Apr 09), and Removed biovent system at FT23 (Oct 09)
PLANNED ACTIVITIES FOR NEXT SIX MONTHS-Receive Final 2009 Zone 2 Management Area Annual Report (Jun 10), Conduct groundwater sampling (Jun 10), and Finalize minor site letter for clarification of land use controls (LUCs) at OUs 1, 2, 4, and 5 (Jan 10). |
Louis Howard |
| 2/22/2010 |
CERCLA ROD Periodic Review |
Final Memorandum to.the Site File for OUs 1,2,4, and 5 received. The purpose of this Memorandum to the Site File is to present non-significant or minor changes to the Record of Decision (ROD) signed for OUs 1,2,4, and 5. The minor changes to the OUs involve clarifying how the US Air Force (USAF) intends to implement the Land Use Control (LUC) at sites LF59 (in OUI), ST41 (in OU2), FT23, SD24, SD25, SD26, SD27, SD28, SD29 (in OU4) and ST37 (in OU5). LUCs are referred to as institutional controls in the RODs. Also, some of the cleanup levels presented in the OU4 ROD Table 5-2 (Chemical-Specific Applicable and Relevant and Appropriate Requirements [ARARs] for Groundwater and Soils) are inconsistent with the referenced standard, and are likely typographical errors. This Memorandum to the Site File corrects the inconsistencies. Other components to the OUs 1,2,4, and 5 selected remedy will not be affected by this minor change.
Summary Comparison of Original and Proposed Minor Changes: These changes to the RODs do not significantly change or fundamentally affect the remedy selected in the RODs; therefore, no public comment is required.
OU4 is located in the central portion of Elmendorf AFB, near the main runways, and is divided into OU4 East and OU4 West areas. OU4 consisted of a total of 10 sites. These included:
• Fire Training Area (FT23),
• Building 5327 (old building number 22-021) [SDI8],
• Building 6211 (old building number 21-900) [SD30],
• Building 16710 (old building number 43-410) [SD28],
• Hangar 8 [SD27],
• Hanger 10 [SD24],
• Hanger 11 [SD25],
• Hanger 14 [SD26],
• Hanger 15 [SD29]), and the
• Asphalt Drum Storage Area (SS1O).
Due to minimal soil contamination, sites SSI8, SD26, SD27, and SD30 were designated as NFA (no further action) for soil in decision documents signed May 1993.
Land Use Control Performance Objective: Restrict access to the contaminated groundwater throughout OU 4 until cleanup levels have been achieved.
Restrict access to the contaminated shallow soils throughout OU 4 until cleanup levels have been achieved.
Designate OU4 for "Airfield Use Area" for aircraft operations and maintenance, to include active and inactive runways, taxiways, and parking aprons for aircraft.·
Corrections to Chemical-Specific ARARS for Groundwater and Soils, Operable
Unit 4: Some of the cleanup levels presented in OU4 ROD Table 5-2 (Chemical specific ARARs
for Groundwater and Soils) are inconsistent with their referenced standard. These
inconsistencies are likely typographical errors. This Memorandum to the Site File
corrects the inconsistencies. FT23 (old ROD level), new corrected cleanup level: 1,2-Dichloroethane (6 ug/L) 5 ug/L, tetrachloroethene (6 ug/L) 5 ug/L, trichloroethene (6 ug/L) 5 ug/L from Maximu Contamination Level; 40 CFR Part 131, and 18 AAC Chapter 70.010a and d, 70.015 through 70.0110, 18 AAC 80.070. Soils-SD25: DRO (1,000 mg/kg) 2,000 mg/kg, GRO (2,000 mg/kg) 1,000 mg/kg from Alaska Cleanup Matrix Level D, 18 AAC 75.315.
OU4 Groundwater: Institutional controls on land use and water use restrictions will restrict access to the contaminated groundwater throughout OU 4 until cleanup levels have
been achieved. OU4 is designated "Airfield Use Area" for aircraft operations and maintenance, to include active and inactive runways, taxiways, and parking aprons for aircraft. LUCs will be managed and implemented in accordance with Section 4.1 of this memorandum to site file. The LUC
boundaries are depicted in Figures 4.3 and 4.4 of this memorandum to site file.
Rationale for Change: Air Force Policy (SAFflE Memo, 7 Oct 03) requires RODs to contain
details on implementation of LUCs. Section 4.1 of this document describes how LUCs will be managed, including the duration of the LUCs.
ROD Component: All groundwater is expected to be cleaned up within thirteen years (2008). Proposed Minor Change: Deleted. Rationale for change: The concentrations of chemical of concern
are decreasing at all sites and it is anticipated that all sites (with the exception of SD25) should meet cleanup levels by 2009. LUCs at OU 4 will be maintained until the concentrations of
hazardous substances in the groundwater are at such levels to allow for unrestricted use and exposure (see Section 4.1.6 of this document). Therefore this component of the ROD is not needed.
Soil: Institutional controls on land use (also called LUCs) will continue to restrict
access to the contaminated shallow soils throughout OU 4 until cleanup levels have been achieved. Details for implementing LUCs are provided in Section 4.1. Rationale for change: Air Force Policy (SAF/IE Memo, 7 Oct 03) requires RODs to contain details on implementation of LUCs. |
Louis Howard |
| 4/14/2010 |
Update or Other Action |
This annual report includes a qualitative evaluation of the 2009 groundwater analytical data to
determine if the current conditions at the Zone 2 potentially warrant changing the 2007 RPO
category for each site. The next detailed RPO evaluation is scheduled for 2012.
Field activities performed during 2009 at Zone 2 included water level measurements; groundwater sampling; operation, maintenance, and monitoring (OM&M) of the bioventing system at Sites FT23 and ST32; decommissioning of the FT23 bioventing system; soil, groundwater, and vapor intrusion investigations at FT23; a groundwater investigation at SS43; soil and groundwater investigations at ST32; monitoring well inspections and surveys at ST32; well abandonment; well maintenance; well flagging; land use control (LUC) inspections; and waste management.
The 2007 RPO evaluation (USAF, 2008) identified Site FT23 as a Green priority site because the groundwater remedy was on track to reach specific cleanup levels within two years of the 2008 completion date specified in the ROD (USAF, 1995a). The results for the sample from well FP-56 indicate that the northern Fire Training Area Plume has been remediated below groundwater cleanup levels for all COCs. COC concentrations in the southern Fire Training Area Plume remain above applicable standards, however. Based on the analytical data for wells FP56, OU4W-11, and GW-5A, VOC concentrations in groundwater in 2009 were generally lower than the 2008 concentrations except for TCE and PCE concentrations in OU4MW-11, which were slightly higher than the 2008 concentrations.
The observed increase in TCE and PCE concentrations in OU4W-11, and the small decrease in TCE concentrations in GW-5A between 2008 and 2009 indicate that there is significant uncertainty with respect to the cleanup dates for the southern FT23 Plume. Because contaminants in the southern FT23 Plume have now exceeded the original cleanup target date of 2005 by 4 years, and the VOC cleanup end date exhibits considerable uncertainty, a change in the priority
designation for Site FT23 from Green to Yellow is recommended.
Laboratory analysis of soil vapor samples collected at Site FT23 in 2009 did not detect COC concentrations in excess of the most conservative screening levels for the soil gas to indoor air exposure pathway (USEPA, 2002). These data demonstrate that a significant vapor exposure pathway does not exist for the buildings currently present at this site.
Based on soil samples collected in 2009 that confirmed that DRO concentrations at the former location of SB6205 are below cleanup levels, the soil remedy is considered complete at Site FT23. As a result, no further action with regard to soil is required at this site. The bioventing system that was used to accelerate soil remediation at Site FT23 was therefore shut down and decommissioned in 2009. The extent of damage to W-15 should be assessed to determine if this well can be repaired or requires abandonment. |
Louis Howard |
| 4/28/2010 |
Update or Other Action |
Memorandum for ADEC. SUBJECT: Response to ADEC Comment on Draft 2009 Zone 1 Field Activities Report (Ref: ADEC Memo, 12.Mar 10)
1. This memorandum is in response to ADEC's concern as to why diesel-range organics (DRO) and gasoline-range organics (GRO) at select groundwater plumes were not sampled in 2009 as previously agreed in a January 14, 2003 meeting. Specifically, ADEC's comment (Attachment 1) is in reference to Section 3.7.1 Implications of Contaminant and Geochemical Monitoring, Page 3-17 of the draft 2009 Zone 1 Field Activities Report, which stated: "The text states: When these parameters were monitored from 1999 to 2007, GRO concentrations in this monitoring well exceeded cleanup levels while DRO concentrations hovered near the cleanup level. ADEC requests the Air Force provide an explanation or a memorandum to the site file as an appendix to the document on why DRO and GRO were eliminated from the monitoring program as previously agreed to in a January 14, 2003 meeting with ADEC, USAF and EPA."
2. The analytes in question were not included in the Zone 1 groundwater monitoring program for FY09 due to an administrative oversight. The agreement to monitor for DRO and GRO was captured in meeting minutes (Attachment 2), not in a more formal mechanism such as a decision document or memorandum to the site file. In preparation for programming of project requirements, we reviewed the governing documents for the Zone 1 sites. None of the governing documents for Zone 1 sites identified GRO/DRO as a contaminant of concern (COC); therefore, GRO/DRO sampling was not programmed or conducted in 2009.
3. The U.S Air Force agrees with ADEC's request to continue sampling for diesel-range organics (DRO) and gasoline-range organics (GRO) for CERCLA sites with fuel-related plumes. Minutes of a 14 Jan 03 meeting with EPA, ADEC and DRS, provided with the above referenced ADEC memo, documents that the Air Force agreed to add DRO/GRO into the sampling program under the following conditions:
a. The decision will be documented in the 5-Year Review. The addition of DRO/GRO to the program should be introduced in the 5-Year Review under• mention of new issues affecting protectiveness.
b. The Air Force will NOT add DRO/GRO as a CERCLA ARAR, but will compare DRO/GRO results to ADEC cleanup levels in the annual reports and will discuss in subsequent 5-Year Reviews. The benefit of this is that if CERCLA COCs meet ARARs, the Air Force can achieve a partial delisting.
c. The Air Force will add DRO and GRO to the suite of analyses at monitoring wells associated with fuel plumes starting in 2004.
d. The Air Force will not pursue a decision document with ADEC on DRO/GRO until more data is gathered on the extent of the problem.
e. Until a decision document is signed with ADEC, GRO and DRO concentrations will be compared to ADEC regulations in 18 AAC 75 (Table C, Groundwater Cleanup Levels; 1,500 ug/L for DRO, 1,300 ug/L GRO).
f. Sampling frequency for DRO/GRO will follow the latest Decision Guide for Sampling Frequency (see 2002 Basewide Annual Report). "Immediately up gradient" means within a 2-year warning line, similar to that generated for OU5.
g. ADEC GRO/DRO criteria apply to groundwater, not to seeps which daylight as surface water. Criteria in 18 AAC 70 (TAR, TAqH) apply to surface water.
4. The fact that these analytes were not included in the Zone 1 groundwater monitoring program for FY09 is attributed to an oversight. The USAF will add DRO/GRO into the suite of analyses at monitoring wells associated with fuel-related plumes for Zone 1 (LF04 South and WP14) and will prepare a memo to the site file to prevent this type of oversight from occurring in the future.
The USAF strategy will be to compare DRO/GRO and total aromatic hydrocarbon (TAH)/total aqueous hydrocarbon (TAqH) sample results as contaminants of interest with current ADEC regulations in 18 AAC 75 - Table C - Groundwater Cleanup Levels and 18 AAC 70 for surface water. Should you have any questions, please feel free to contact me at (907) 552-2875.
Signed Gary Fink YF-02 Chief, Environmental Restoration.
|
Louis Howard |
| 10/15/2010 |
Update or Other Action |
5 YR Review
OU4 Remedy Implementation Status
Deep soils at specified locations and depths at the Fire Training Area (FT23), the asphalt drum storage area (SS10), and Hangar 11 (SD25) will be treated with bioventing to accelerate degradation of contaminants in those locations. Deep soils at other source areas will be allowed to degrade through intrinsic remediation.
Bioventing is ongoing at FT23. SS10 and SD25 have reached cleanup levels and bioventing systems were shut down in 2006 and 2003, respectively.
Both shallow and deep soils will be monitored and evaluated to assess contaminant migration and timely reduction of contaminant concentrations by intrinsic remediation (i.e., natural attenuation). This will include five year reviews to assess the protectiveness of the remedial action, as long as contamination remains above cleanup levels.
Soils meet cleanup levels at all sites except for one sampling location at FT23. Sampling locations and frequency are updated periodically. Five-year reviews were conducted in 1998, 2003 and 2008.
The remedy at OU4 is expected to be protective of human health and the environment upon attainment of soil cleanup levels through bioventing at two remaining sites (FT23 and SS10) and attainment of groundwater cleanup levels through natural attenuation. In the interim, exposure pathways that could result in unacceptable risks are being controlled.
During the period 2003 through 2007, there were several notable detections of contaminants at OU4 in addition to COCs:
• Bromomethane was detected in well FP-56 at 0.11 µg/L in 2005, but has never been detected prior to or after 2005. Bromomethane was not identified as a COPC for FT23.
There is no MCL or ADEC cleanup level for bromomethane.
Recommendations for changes to the OU4 monitoring program include:
• Perform confirmation sampling to close out the soils remedy at FT23 in 2010 or sooner.
Site Inspection
The bioventing system was inspected and found to be operational. Mr. Marty Hannah, the system operator, reported O&M problems including failure of an electrical controller and blockage of one vent during the winter, probably due to ice. Land use changes included construction of new hangars on a portion of FT23. Vapor barriers have been incorporated into the design of the hangars to control migration of VOCs into indoor air. All active monitoring wells were located, and one well needs a replacement cap. There was no evidence of unauthorized wells or any other site disturbance.
Changes to land use were evident at sites FT23 and LF04, but site conditions are understood and precautions to prevent exposure are being incorporated into the design of the new facilities. Difficult environmental conditions as evidenced by frost heaving of wells are routinely addressed through maintenance.
Issues
Inconsistent Cleanup Levels: The cleanup levels for 1,2-dichloroethane, PCE, and TCE for FT23 groundwater, and DRO and GRO for SD24 and SD25 soil, as presented in OU4 ROD, are inconsistent with their referenced standards. The cleanup levels for 1,2-dichloroethane, PCE and TCE at FT23 are listed as 6 µg/L instead of the MCL standard of 5 µg/L.
The cleanup levels identified for DRO and GRO at SD24 and SD25 are 1,000 and 2,000 mg/kg respectively, which is the reverse of their referenced Alaska Cleanup Matrix Level D standard. These inconsistencies appear to be typographical errors because there is no discussion in the ROD about deviation from the referenced standards.
Recommendations/Follow-up Actions
Update the ROD-specified cleanup levels for 1,2-dichloroethane, PCE, and TCE for FT23 groundwater, and DRO and GRO for SD24 and SD25 groundwater, so that they are consistent with their referenced standards. Document the updated cleanup levels in a memorandum to the site file.
Conduct soil sampling in 2010 or earlier. If soil meets cleanup levels, prepare Site Closure report, shut down the bioventing system and remove bioventing components. |
Louis Howard |
| 11/17/2010 |
Meeting or Teleconference Held |
A meeting of the remedial project managers (RPMs) convened at 0900 on 17 November 10 at
the Joint Base Elmendorf-Richardson (JBER)-Richardson Conference Room in Building 658.
Attendees included: Mr. Bill Adams - Environmental Protection Agency (EPA); Mr. Louis
Howard - Alaska Department of Environmental Conservation (ADEC); Mr. Robert Shirley - Air
Force Center for Engineering and Environment (AFCEE) Western Region Environmental Office;
Mr. Nick Muszynski - AFCEE Restoration - Program Management Office (R-PMO); Mr. Rafael
Vazquez - AFCEE R-PMO; Mr. Jim Klasen - lith Air Force Environmental Attorney;
Ms. Renee Wright - Environmental Restoration Community Relations Coordinator; and CEANR
personnel - Mr. Gary Fink, Mr. Mark Prieksat, Ms. Donna Bawnler, Mr. Don Aide, Mr. Tim
Plucinski, Mr. Dick Nenahlo, and Ms. Cynthia Tomlinson.
Zone 2 - Mr. Don Aide explained that field activities for Summer 2010 were complete and included the following: at FT23 - all contaminants of concern (COCs) in the northern portion of the site are below cleanup levels and the bioventing system at this site will be removed in Winter 2010. |
Louis Howard |
| 1/24/2011 |
Update or Other Action |
Staff received the 2010 Zone 2 Mgt. Area Annual Report. This annual report presents a description of the activities performed in 2010 at the Zone 2 Management Area at Joint Base Elmendorf-Richardson (JBER), Alaska. This document describes field activities and pertinent observations, presents analytical data, and provides recommendations for the Zone 2 Management Area, which now includes Sites ST48 and ST68. Beginning in 2010, Sites ST48 and ST68 have been included in reports related to the Zone 2 Management Area (rather than the Zone 3 Management Area) because the boundary between the Zone 2 and Zone 3 Management Areas was revised during the 2009 field season.
This annual report includes a qualitative evaluation of the 2010 groundwater analytical data to determine if the current conditions at Zone 2 potentially warrant changing the 2007 RPO category for any of the sites. The next detailed RPO evaluation is scheduled for 2012.
Although the LUC inspection conducted on 10 August 2010 identified several changes to site conditions within the Site FT23 LUC area, none of the observed changes created a LUC concern. A copy of the 2010 LUC inspection form for Site FT23 is provided in Appendix C. The most notable change was construction of a parking lot over a significant portion of the site. As part of construction, well FP-56 was inadvertently paved over by asphalt. As described below, well FP-56 was salvaged by removing asphalt from around the protective casing of the well.
During 2010, one well required abandonment and one well required maintenance at Site FT23. Well W-15 was assessed and found to be damaged beyond repair because the well casing was broken several feet below the ground surface. Well W-15 was therefore abandoned as described in Section 2.3.4. As described above, paving activities during parking lot construction at Site FT23 resulted in the inadvertent covering of well FP-56 with asphalt. The asphalt was cleared from this well as part of maintenance activities, and the well casing and protective cover appear to be intact.
The 2007 RPO evaluation (USAF, 2008a) identified Site FT23 as a Green priority site because the groundwater remedy was on track to reach specific cleanup levels within two years of the 2008 completion date specified in the ROD (USAF, 1995a). The results for the samples collected from well FP-56 in 2009 and 2010 indicate that the northern Fire Training Area Plume has been remediated below groundwater cleanup levels for all COCs.
In 2011, COC concentrations in a sample from well FP-56 should be measured to determine if they remain below groundwater cleanup levels for the third consecutive year. Three successive years of measuring COC concentrations below cleanup levels are required as the final step in demonstrating that remediation of the northern Fire Training Area Plume is complete.
Based on historical data, COC concentrations in the southern Fire Training Area Plume were assumed to remain above applicable standards in 2010. Because contaminant concentrations measured in the southern Fire Training Area Plume in 2009 exceeded cleanup levels four years beyond the original cleanup target date of 2005, and because the VOC cleanup end date is considered uncertain, the priority designation for Site FT23 was changed from Green to Yellow in the recommendations of the 2009 Zone 2 Management Area Annual Report (USAF, 2010b). The Yellow priority designation remains appropriate because new in-source data were not scheduled forcollection in 2010. The priority designation will be reevaluated following the next round of sampling at well OU4MW-11, which is the in-source well for the southern FT23 Plume that will be sampled in 2014.
|
Louis Howard |
| 1/28/2011 |
Update or Other Action |
Staff received the 2010 Annual Land Use Control (LUC) Monitoring Letter for DP98 and Operable
Units (OUs) 1,2,4,5, and 6. References: (a) DP98 Record of Decision, Section 12.2.3.4, dated May 2004, (b) OU6 Explanation of Significant Differences, Section 4.3.1.3, dated Mar 2007, and
(c) Memorandum to the Site File for OUs 1,2,4, and 5, Section 4, dated Jan 2010.
This letter serves as the annual monitoring report on the status of LUCs in place at DP98 and
at OUs 1,2,4,5 and 6.
Groundwater - Restrict access to the contaminated groundwater throughout OU 4 until cleanup levels have been achieved. OU4 is designated "Airfield Use Area" for aircraft operations and maintenance, to include active and inactive runways, taxiways, and parking aprons for aircraft.
Soil- mstitutional controls on land use (also called LUCs) will continue to restrict access
to the contaminated shallow soils throughout OU 4 until cleanup levels have been achieved.
Evaluation - A land use control inspection was performed and land use controls are in place and continue to be effective at FT23. Due to construction of a parking lot, a large portion of the site was paved over in 2010. Well W-15 was abandoned because of damage sustained in 2009.
The Air Force ensures compliance with LUCs by conducting periodic monitoring and completing site inspections. Separate controls are in place and enforced by the Air Force to prevent inappropriate soil and groundwater exposure at these sites. The Air Force currently requires all proj ects resulting in soil disturbance of greater than four inches below ground surface
to follow 3r Wing Instruction 32-1007, Safeguarding Utilities from Damage, dated 17 Aug 07
and 3rd Wing Instruction 32-7003, Land Use control Management, dated 16 Feb 07. Both instructions require the proponent to obtain an approved Base Civil Engineer Work Clearance
Request (3 WG Form 3) prior to conducting work on the Base. |
Louis Howard |
| 7/15/2011 |
Update or Other Action |
Draft Work Plan Environmental Remedial Action-Operations & LTM & Maintenance received.
The purpose of this project is to perform RA-O & LTM activities for several JBER Programs. These programs include sites distributed across both JBER-Elmendorf & JBER-Richardson. This Work Plan addresses remedial activities in JBER-Elmendorf Zone 1, Zone 2, & Zone 3 Management Areas, JBER-Elmendorf Compliance Restoration Program (CRP) sites, the JBER Elmendorf Operable Unit (OU) 1 Landfill, JBER-Richardson Multiple Installation Restoration Program (IRP) Sites, & JBER-Richardson Poleline Road & OUE Armored Vehicle Maintenance Area (AVMA).
Currently there are ten active sites within the Zone 2 Management Area: FT23, SD15, SD24, SD25, SD28, SD29, SS43, ST32, ST48, & ST68. The OU4 ROD (USAF, 1995a) specifies the selected remedy for Sites FT23, SD24, SD25, SD28, & SD29. Currently, LUCs are used at all OU4 sites until cleanup levels are met, & GW monitoring is performed at Sites FT23 & SD25. At Site SD15, 149 an ESD; to the OU 6 ROD (USAF, 1997) transitioned the remedy for this site to monitored natural attenuation (MNA). The remedial approach for Site SS43 is described in the State-Elmendorf Environmental Restoration Agreement (SERA) Phase I Corrective Action Plan, & currently consists of natural attenuation with free product removal. The selected remedy for soils with contamination in excess of cleanup levels at Site ST32 is limited hot spot removal with off-site low-temperature thermal desorption.
A final remedy for GW at Sites ST32 & ST48 has not been established. The remedy for ST68 includes MNA & LUCs specified in a DD that was finalized in 2007. Impacted media at the Zone 2 Management Area sites includes soil & GW. COCs identified for Zone 2 sites include trichloroethene (TCE); tetrachloroethene (PCE); 1,1,1-trichloroethane (1,1,1-TCA); 1,1,2-TCA; 1,2-dichloroethane (1,2-DCA); 1,1-dichloroethene (1,1-DCE); 1,2-DCE; 1,1,2,2-tetrachloroethane (1,1,2,2-PCA); benzene, toluene, ethylbenzene, & total xylenes (BTEX); DRO; & gasoline-range organics (GRO).
The overall objectives of RA-O activities within the Zone 2 Management Area are to monitor the rate of natural attenuation within GW plumes, determine the effectiveness & protectiveness of the site remedies (currently MNA for all sites), & manage all waste according to state & federal regulations.
Site FT23 consists of two small plumes west of the North/South Runway between Airlifter Drive & 33rd Street. The Site FT23 plumes are also referred to as the Fire Training Area Plumes. GW contamination at this site has been attributed to two source areas, a drum storage area & a bermed burning area. The drum storage area contained as many as 100 55-gallon drums of waste oils, paint thinners, waste fuel, & waste solvents from aircraft maintenance & other shop operations. Fire training activities were conducted in the bermed area from the 1940’s to 1983. From the 1940’s to the 1960’s, combustible wastes, including oils, fuels, & solvents, were used as fuel for the training exercises. Site FT23 was included in the OU4 investigation cleanup.
The Zone 2 Management Area sites are located throughout the central portion of JBER-Elmendorf. The southern boundary of Zone 2 is parallel to the southern edge of the east/west instrument runway. The WP presents the site locations, associated sources, & plumes. Ten sites & 12 GW plumes are located within this management area, as follows (analytes shown exceeded cleanup levels during the most recent monitoring event):
• Site FT23 (2 plumes) - TCE & PCE
• Site SD15 - benzene & TCE
• Site SD24 - benzene
• Site SD25 - toluene & benzene
• Site SD28 - TCE & PCE
• Site SD 29 - TCE & PCE
• Site SS43 - benzene, gasoline range organics (GRO), DRO
• Site ST32 (2 plumes) - benzene, GRO, & DRO
• Site ST48 - GRO
• Site ST68 (2 plumes) - benzene & GRO |
Louis Howard |
| 8/3/2011 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft Work Plan Environmental Remedial Action – Operations and Long-Term Monitoring and Maintenance July 2011.
8.2.2: Water quality parameters are considered stable when three successive readings, collected 3-5 minutes apart, are within:
• ± 3% for temperature (minimum of ± 0.2 oC),
• ± 0.1 for pH,
• ± 3% for conductivity,
• ± 10 mv for redox potential,
• ± 10% for dissolved oxygen (DO), and
• ± 10% for turbidity.
A minimum of three (minimum of four if using temperature as an indicator) of these parameters should be monitored and recorded (ADEC May 2010 Draft Field Sampling Guidance A. General Guidelines Page 29).
ADEC will require that a fourth field parameter be used in addition to the three proposed in the document (pH, specific conductivity and temperature) to determine when a well is considered stable or stabilized. This comment is applicable for sampling activities of any monitoring well on JBER. The variance allowed for considering temperature and conductivity “stable” is a three percent (3%) variance not ten percent (10%) as stated in the document.
The text states: “Trip blanks will be kept with samples and analyzed whenever volatile organic samples are required.” ADEC will require one trip blank per analysis and cooler for all water samples being analyzed for GRO, BTEX or VOCs. The allowable tolerance for trip blanks will be less than the practical quantitation limit (ADEC May 2010 Draft Field Sampling Guidance Table 3).
2-8 2.1.5: The following applies to existing monitoring wells on JBER: At sites with long-term detection monitoring, survey the location of each well, the elevation of the land surface, and the top of each well casing. A registered professional surveyor or registered civil engineer engaged in the practice of surveying must conduct this work.
Sites undergoing contaminant assessment monitoring with a large number of monitoring wells should have the wells surveyed as described above. Re-survey monitoring wells every five years, or more frequently, if freeze-thaw processes compromise the well (Pages 7 and 8 from ADEC’s Monitoring Well Design and Construction for Investigation of Contaminated Sites, February 2009)
2-9 2.2.1: See comment #10 regarding the number of water quality parameters and their use for determining whether a well is stabilized or not.
2-10 2.2.2: The text states: “In the event that floating product is detected in the well, a disposable polyethylene bailer will be used to first remove the product from the top of the water column. The bailer will be lowered to just above static water level and purging cycles performed until no visible product remains at the groundwater interface. After the field crew has determined that no product remains in the casing, actual sampling procedures will commence.”
The statements in this section are in conflict with the statements from Section 2.2.1 Well Purging on Page 2-9: “Samples will not be collected from wells with measurable product because the samples would contain light nonaqueous phase liquids (LNAPL) that is not representative of dissolved phase concentrations.” Please clarify whether or not wells containing measurable free product will be sampled.
2-15 Table 2-1: EPA 8011 or EPA 504.1 should be used when evaluating ethylene dibromide (EDB). EDB soil samples should be field preserved in hexane. 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.
|
Louis Howard |
| 2/2/2012 |
Update or Other Action |
Memorandum for 2010 Annual Land Use Control (LUC) Monitoring Letter for DP98 and OUs 1, 2, 4, 5, and 6.
References:
(a) DP98 Record of Decision, Section 12.2.3.4, dated May 2004
(b) OU6 Explanation of Significant Differences, Section 4.3.1.3, dated Mar 2007
(c) Memorandum to the Site File for OUs 1,2,4, and 5, Section 4, dated Jan 2010
1. This letter serves as the annual monitoring report on the status of LUCs in place at DP98 and
at OUs 1,2,4,5 and 6. The specific LUCs in place at each site are provided below. An
evaluation of the implementation of these requirements is provided in bold following each
specific LUC.
OU4:
Site FT23
Groundwater - Restrict access to the contaminated groundwater throughout OU 4 until cleanup levels have been achieved. OU4 is designated "Airfield Use Area" for aircraft operations and maintenance, to include active and inactive runways, taxiways, and parking aprons for aircraft.
Soil- Institutional controls on land use (also called LUCs) will continue to restrict access
to the contaminated shallow soils throughout OU 4 until cleanup levels have been achieved.
Evaluation - LUCs are in place and continue to be effective at FT23. A land use control inspection was accomplished in Oct 2011. The inspection forms will be presented in Appendix B of the 2011 Zones 1, 2, and 3 Mgt. Area Annual Report.
2. The Air Force ensures compliance with LUCs by conducting periodic monitoring and completing site inspections. Separate controls are in place and enforced by the Air Force to prevent inappropriate soil and groundwater exposure at these sites. The Air Force currently requires all projects resulting in soil disturbance of greater than four inches below ground surface to follow 3 Wing Instruction 32-1007, Safeguarding Utilities from Damage, dated 20 Aug 10 and 673d Wing Instruction 32-7003, Land Use control Management, dated 19 May 2011. Both instructions require the proponent to obtain an approved Base Civil Engineer Work Clearance Request (3 WG Form 3) prior to conducting work on the Base. |
Louis Howard |
| 3/16/2012 |
Update or Other Action |
Co-Occurrence of 1,4-Dioxane with Trichloroethylene in Chlorinated Solvent GW Plumes at US Air Force Installations: Fact or Fiction (Richard H Anderson,*Janet K Anderson, & Paul A Bower)
Air Force Center for Engineering & the Environment, Technical Support Division (AFCEE/TDV), 2261 Hughes, Site 155, Lackland AFB, Texas 78236, USA. Contractor, AFCEE Environmental Restoration Branch (AFCEE/ERD), Lackland AFB, Texas, USA (Submitted 22 November 2011; Returned for Revision 23 January 2012; Accepted 16 March 2012)
ABSTRACT: Increasing regulatory attention to 1,4-dioxane has prompted the United States Air Force (USAF) to evaluate potential environmental liabilities, primarily associated with legacy contamination, at an enterprise scale. Although accurately quantifying environmental liability is operationally difficult given limited historic environmental monitoring data, 1,4-dioxane is a known constituent (i.e., stabilizer) of chlorinated solvents, in particular 1,1,1-trichloroethane (TCA). Evidence regarding the co-occurrence of 1,4-dioxane & trichloroethylene (TCE), however, has been heavily debated.
In fact, the prevailing opinion is that 1,4-dioxane was not a constituent of past TCE formulations &, therefore, these 2 contaminants would not likely co-occur in the same GW plume. Because historic handling, storage, & disposal practices of chlorinated solvents have resulted in widespread GW contamination at USAF installations, significant potential exists for unidentified 1,4-dioxane contamination.
Therefore, the objective of this investigation is to determine the extent to which 1,4-dioxane co-occurs with TCE compared to TCA, & if these chemicals are co-contaminants, whether or not there is significant correlation using available monitoring data. To accomplish these objectives, the USAF Environmental Restoration Program Information Management System (ERPIMS) was queried for all relevant records for GW monitoring wells (GMWs) with 1,4-dioxane, TCA, & TCE, on which both categorical & quantitative analyses were carried out.
Overall, ERPIMS contained 5788 GMWs from 49 installations with records for 1,4-dioxane, TCE, & TCA analytes. 1,4-Dioxane was observed in 17.4% of the GMWs with detections for TCE &/or TCA, which accounted for 93.7% of all 1,4-dioxane detections, verifying that 1,4-dioxane is seldom found independent of chlorinated solvent contamination. Surprisingly, 64.4% of all 1,4-dioxane detections were associated with TCE independently. Given the extensive data set, these results conclusively demonstrate for the first time that 1,4-dioxane is a relatively common GW co-contaminant with TCE. Trend analysis demonstrated a positive log-linear relationship where median 1,4-dioxane levels increased between approximately 6% & approximately 20% of the increase in TCE levels.
In conclusion, this data mining exercise suggests that 1,4-dioxane has a probability of co-occurrence of approximately 17% with either TCE &/or TCA. Given the challenges imposed by remediation of 1,4-dioxane & the pending promulgation of a federal regulatory standard, environmental project managers should use the information presented in this article for prioritization of future characterization efforts to respond to the emerging issue. Importantly, site investigations should consider 1,4-dioxane a potential co-contaminant of TCE in GW plumes. Integr Environ Assess Manag 2012;8:731–737 |
Louis Howard |
| 4/10/2012 |
Update or Other Action |
Draft 2011 Zones 1, 2, and 3 Annual Report received.
The Site FT23 bioventing system was shut down in June 2009 to accommodate soil vapor sampling. During the shutdown, a soil sample was collected at the location of SB6205 from the depth interval between 14 and 15 ft bgs. The results of soil sampling demonstrated that DRO concentrations were below cleanup standards, leading to the determination that the soil remedy was complete at Site FT23. As a result, most of the bioventing system components were decommissioned in October 2009. Final decommissioning of the remaining components was completed in December 2010.
Currently, PCE, TCE and cis-1,2-DCE concentrations remain above their respective cleanup levels in the southern Fire Training area plume. The Northern Fire Training Area Plume has had three successive years of measuring COC concentrations below cleanup levels.
Concentrations of benzene, TCE, PCE, and cis-1,2-DCE in samples from wells FP-56 and 407MW-01 were below their respective cleanup levels.
The LUC inspection was conducted on 13 October 2011. Nothing significant was discovered during the inspection. The 2010 inspection identified several changes to site conditions within the Site FT23 LUC area, none of the observed changes created a LUC concern, however. The most notable change found in 2010 was construction of a parking lot over a significant portion of the site. As part of construction, well FP-56 was inadvertently paved over by asphalt. The well was salvaged by removing asphalt from around the protective casing of the well.
Summary & Recommendations
Northern Fire Training Area Plume - The 2007 RPO Evaluation Report (USAF, 008g) identified Site FT23 as a Green priority site because the groundwater remedy was on track to reach specific cleanup levels within two years of the 2008 completion date specified in the ROD (USAF, 1995c). The results for the samples collected from well FP-56 in 2009, 2010, and 2011 indicate that the northern Fire Training Area Plume has been remediated below groundwater cleanup levels for all COCs (Figure 3.2). Three successive years of measuring COC concentrations below cleanup levels were required as the final step in demonstrating that remediation of the northern Fire Training Area Plume is complete. Well FP-56 is recommended to be removed from annual sampling.
Southern Fire Training Area Plume - Based on historical data, COC concentrations in the Southern Fire Training Area Plume were assumed to remain above applicable standards in 2011. Because contaminant concentrations measured in the southern Fire Training Area Plume in 2009 exceeded cleanup levels four years beyond the original cleanup target date of 2005, and because the VOC cleanup end date is considered uncertain, the priority designation for Site FT23 was changed from Green to Yellow in the recommendations of the 2009 Zone 2 Management Area Annual Report (USAF, 2010b). The Yellow priority designation remains appropriate because new in source data were not scheduled for collection in 2011. The priority designation will be reevaluated following the next round of sampling at well OU4MW-11, which is the in source well for the southern FT23 Plume that is currently scheduled to be sampled in 2014. |
Louis Howard |
| 6/6/2012 |
Update or Other Action |
Draft Project Management Plan received.
Project Objective
Site Closure
Performance Objectives
· Prepare an approved Explanation of Significant Difference (ESD) Report by January 2013
· Conduct 2012 RA-O Monitoring Event under Addendum to Current LTM Plan with approved Annual RA-O Monitoring Event Memo by November 2012
· Prepare an approved Characterization and Treatability Study Workplan by February 2013
· Conduct Site Characterization and treatability Study concurrently with 2013 RA-O Monitoring Event
· Prepare an approved Characterization and Treatability Study Report
· Prepare an approved Remedial Action Workplan
· Conduct Remedial Action concurrently with 2014 RA-O Monitoring Event
· Prepare an approved Remedial Action Construction Report and Remedial Action Completion Report
· Continue RA-O Monitoring to meet ROD and ADEC requirements
· Prepare an approved Site Closure Report and conduct final site closure requirements and well abandonment to achieve SC.
Potential Risk
Multiple ISCO treatments required to successfully remediate southern plume, multiple vadose zone sources identified.
Risk Mitigation
Additional rounds of ISCO application will take place based on LTM results to ensure SC is
achieved, information regarding newly identified vadose zone sources will be evaluated for the appropriate remedy to eliminate these sources, and the remedy will be implemented.
Date of achieving performance objective
4th quarter 2019
Planned approach
Prepare an Explanation of Significant Difference to transition remedy from LTM to active treatment for southern groundwater plume. Conduct bench-scale test and prepare an approved Remedial Action Workplan.
Implement Remedial Action by installing and sampling five soil borings and two groundwater monitoring wells, inject potassium permanganate perpendicular to the plume, conduct monthly monitoring to assess ISCO effectiveness, two additional injections occurring in the following two years, and monitor impacts of treatment for six years.
Prepare an approved Remedial Action Report documenting effectiveness of ISCO treatment, document the Annual LTM requirements, and document that the site meets ROD and 18 AAC 75 requirements for Cleanup Complete without ICs.
Prepare an approved Site Closure Report documenting site meets OU4 ROD requirements for closure
and meets 18 AAC 75 requirements for Cleanup Complete without ICs.
Receive EPA and ADEC concurrence with SC without restrictions and provide documentation to AFCEE. |
Louis Howard |
| 6/22/2012 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the draft Project Mgt. Plan.
Table 2-1
FT023 Page 2-11
Please note this site is a CERCLA site covered by the FFA under Operable Unit (OU) 4. Please include text in site name to reflect that it is also a part of OU4. As such, any work plans, scoping documents, studies, closure reports developed for this site will need to follow EPA CERCLA guidance and coordination of reviews with EPA and ADEC as required by the Elmendorf FFA.
Page 2-31
The text states: “The WPs will be submitted in the initial phases of the project for Air Force and regulatory review and concurrence according to the schedule outlined in the IMS. If regulatory agencies elect not to review/approve documents, approval will be sought through the Secretary of the Air Force/Installations and Environment (SAF/IE) to proceed with execution of the plan activities. The WESTON Team understands that a procedure has been established for this situation, and that the Air Force controls this process.”
Failure to obtain work plan approval before implementing site work described above is considered a violation of Alaska regulations and may result in field work not being approved or additional work being required and may subject responsible parties and/or contractors to a Notice of Violation (NOV).
In addition, proceeding with unapproved work plans and finalizing documents which are not approved by EPA or ADEC will likely cause the regulatory agencies to invoke dispute resolution as allowed for under the respective Federal Facility Agreements (XXI Dispute Resolution).
Table 6-3 JBER-Elmendorf
General comments
Risk mitigation: In general, vadose zone soils shall not exceed maximum allowable levels for petroleum contamination for soil from 0 – 15’ bgs (i.e. direct contact for BTEX, PAHs and ingestion for DRO, GRO, RRO) regardless of HRC calculated levels. Treatment or excavations deeper than 15’ bgs may be warranted on a site-specific basis to prevent the soil from acting as a continuing source of groundwater contamination.
In addition, sites with existing groundwater contamination above Table C cleanup levels will require that migration to groundwater cleanup levels be used for soil and ICs will be required. Once groundwater is below Table C for for a period of time (per the latest approved “Basewide Monitoring Program Well Sampling Frequency Decision Guide”), the maximum allowable levels may become the cleanup levels as determined by ADEC on a case by case basis.
7.1.2
Independent QA Oversight on Performance Based Contracts
The site cleanup rules require that “collection, interpretation, and reporting of data, and the required sampling and analysis is conducted or supervised by a qualified, impartial third party”. Depending upon the specific terms in a performance based contract, a contractor may no longer be considered an impartial third party with respect to collecting, interpreting and reporting data.
This should be taken into consideration when preparing scopes of work. ADEC strongly recommends the Air Force provide an on-site Quality Assurance Representative or a third party QA oversight contractor to monitor fieldwork for consistency with approved plans and contract requirements.
|
Louis Howard |
| 1/11/2013 |
Update or Other Action |
Draft UFP-QAPP for FT23 received.
The overall objectives for the site are to meet “unrestricted or residential site use” criteria and achieve a “cleanup complete without institutional controls (ICs)” determination. To meet these objectives 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 of the Alaska Administrative Code [AAC] Chapter 75, Sections 325 to 390 and 18 AAC 78, Section
600).
A series of soil borings will be installed to determine the concentration of the COCs in the smear zone to set up the bench scale test. The borings will start at the potential source and step out perpendicular to groundwater flow. The first step out will be approximately 20 ft to one cross gradient side, with the screening results of that boring determining the next step out length, in 20 ft increments. This process will continue until you find clean samples, once the one cross gradient side is delineated, that same length will be applied to the other cross gradient side. Once the lateral extent of the smear zone contamination is delineated this process will be used to delineate the down gradient extent contamination. The samples from the smear zone in the soil boring cores will be collected and screened utilizing a photoionization detector (PID). Based upon results of the PID field screening, two samples from each boring with the two highest PID readings will be collected and submitted for laboratory analysis of the COCs.
Soil samples from within the LNAPL contaminated smear zone will be collected to conduct a
bench scale test to determine the most effective ISCO treatment option. Vadose zone soil
samples from three representative boring locations will be submitted for grain size analysis to
assist in ISCO design. The bench scale test will be performed to determine the type and quantity
of product to be used in the ISCO treatment. ISCO treatment will likely consist of injection of
either potassium permanganate or Regenox depending on bench scale test results. For the ISCO
application, the active ingredient will be diluted to the appropriate concentration using clean tap water.
The chemical will be injected in the subsurface through drill rod that is advanced using a direct push drill rig. Injection locations will be placed in the extent of the delineated smear zone soils thought to be southeast of monitoring well OU4W-11. Injection of the chemical will occur in two lines spanning approximately 300 ft perpendicular to the plume. Approximately 40 injection points will be spaced approximately 15 ft apart and injection lines will be offset to maximize coverage. Injection locations may be modified in the field to ensure an even distribution of the chemical. Two additional rounds of ISCO treatment may occur until
groundwater cleanup criteria are reached. |
Louis Howard |
| 1/25/2013 |
Document, Report, or Work plan Review - other |
EPA provided a cursory review of the draft UFP-QAPPs for SD025 and FT023 and requested additional information be provided for the UFP-QAPPs for the revised draft UFP-QAPPs.
EPA requires revision of the draft Site Characterization Workplan/ QAPP for SD025 and FT023, JBER, AK, January 2013.
EPA Region 10 conducted a cursory review of the both of the Draft Site Characterization Workplans/ QAPPs for SD025 and FT023, JBER, AK, January 2013. As stated in EPA General comment #5 on the draft Uniform Basewide Quality Assurance Performance Plan, all site-specifics workplans must complete the following worksheets and cannot reference the draft Uniform Basewide QAPP :
Worksheets #1 & 2 – Title and Approval Page
Worksheets #3 & #5 – Project Organization and QAPP Distribution
Worksheet # 6 – Communication Pathways, roles and responsibilities
Worksheet # 9 – Project Planning Session Summary
Worksheet # 10 – Conceptual Site Model
Worksheet # 12 – Measurement Performance Criteria
Worksheet #14/16 – Project Schedule
Worksheet # 15 – Project Action Limits and Lab Specific Detection/Quantitation Limits
Worksheet # 17 – Sampling Design and Rationale
Worksheet #18 – Sampling Locations and Methods
Worksheet #19 & 20 – Sample Containers, Preservation and Holding Times
Worksheet #20- Field QC Summary
Worksheet #23 – Analytical SOPs (if lab change)
Worksheet # 28 – Analytical Quality Control and Corrective Action (if lab change)
EPA requires a revised draft version of both workplans/QAPPs for review. Please ensure revisions are based on the changes agreed to at the JBER Basewide UFP-QAPP Comment Resolution meeting on December 20, 2012. The comments below are only based on a very cursory review and are not meant to be all-inclusive.
These workplans combine site characterization with a large scale treatability study and should state this directly. The worksheets incorrectly refer to the ISCO treatment as a remedial action, however ISCO is not a remedy identified in the OU4 rods for either of these sites. Approval by both EPA and ADEC will be required prior to initiation of the site characterization or treatability activities. EPA has been incorrectly designated as NA for approval signature for both workplans.
Worksheet #10 CSM should identify all possible routes of exposure, including vapor intrusion
The timing of the ISCO treatability study should be reflected in the project timelines and activities in worksheet #14/#16.
It is critical to understand if the current breakdown of TCE at FT023 is due to oxidizing or reducing conditions prior to conducting the ISCO treatability study. Addition of vinyl chloride to the target analyte list will provide valuable information on the stage of degradation.
For FT023, please describe how the presence of a building will impact the step in/step out characterization sampling for the smear zone.
As discussed during the JBER Basewide UFP-QAPP Comment Resolution meeting on December 20, 2012 (meeting minute # 3) EPA will not accept data for VOC soil samples preserved in methanol. Please clarify the methods used and sample numbers on worksheets #19/30 and #20.
For SD025, ADEC requested EDB to be added to the analyte list, however it is omitted in worksheets #15, #17, #18 and #20.
Both workplans provide incorrect references to well locations or figures. Worksheet #18 references Fig 2, possibly a mistake for Figure 1-2, however the locations of proposed monitoring wells is absent or difficult to distinguish from soil boring symbols. |
Louis Howard |
| 2/6/2013 |
Meeting or Teleconference Held |
EPA, JBER, CH2MHILL/WESTON PBR contractor, ADEC staff met to discuss basewide and site specific UFP-QAPPs (re: FT023 and SD025). It was agreed that the FT023 and SD025 plans would be resubmitted after incorporating comments received and revising the documents to only discuss characterization. The PMP (still draft form) refers to characterization plans, treatability plans and closure (via ESD, Memo to file or ROD amendment) documentation being submitted separately and they should not be anything else but site characterization work plans at this point in time for agency review. |
Louis Howard |
| 3/1/2013 |
Update or Other Action |
2012 Annual LUC IC Monitoring memorandum received.
This letter serves as the annual monitoring report on the status of LUCs in place on JBER Elmendorf at DP98 and OUs 1, 2, 4, 5 and 6. The specific LUCs in place at each site are
provided below. An evaluation of the implementation of these requirements is provided in bold
following each specific LUC.
Groundwater - Restrict access to the contaminated groundwater throughout OU 4 until cleanup levels have been achieved. OU4 is designated ··Airfield Use Area" for aircraft operations and maintenance, to include active and inactive runways, taxiways, and parking aprons for aircraft.
Soil - Institutional controls on land use (also called LUCs) will continue to restrict access
to the contaminated shallow soils throughout OU 4 until cleanup levels have been achieved.
Evaluation -Inspection conducted on 30 Aug 11 and LUCs are in place and continue to be effective at FT13. |
Louis Howard |
| 3/12/2013 |
Update or Other Action |
Revised UFP-QAPP for FT023 received.
The overall objectives for the site are to meet “unrestricted or residential site use” criteria and achieve a “cleanup complete without institutional controls (ICs)” determination. To meet these objectives soil and groundwater samples will be collected to characterize risk to human health and the environment within the framework of the Alaska Department of Environmental
Conservation (ADEC) site cleanup process (18 Alaska Administrative Code [AAC] 75 Sections
325 to 390 and 18 AAC 78 Section 600).
Based upon results of the PID field screening, two samples from each boring with the
two highest PID readings will be collected and submitted for laboratory analysis of the COCs.
The borings will start at OU4MW-11 and step downgradient until the edge of the contaminated
smear zone soils have been reached. A boring will be placed immediately downgradient of GW-
5A to investigate the smear zone soils at that location. Once this lower extent has been reached
the boring will become the downgradient monitoring well.
The objectives of these borings are to delineate the extents of light non-aqueous phase liquid (LNAPL) hydrocarbon impact at the smear zone. The LNAPL smear zone contamination is the likely source contributing to downgradient impact in the groundwater. The area of the smear zone with LNAPL present will be the treatability study area where in-situ chemical oxidation (ISCO) injections will be focused.
Smear zone delineation borings will start in the source area and will be stepped out, moving
downgradient, until contamination is no longer present, based on field screening results.
Samples for laboratory analytical analysis will be collected from the area of smear zone
contamination. Approximately three samples will be collected from the clean soils outside of the
smear zone contaminated zone to confirm field screening results are accurate.
If evidence of contamination is observed in the field during the installation of delineation
borings, additional boring locations may be installed in order to vertically and horizontally
delineate the evidence of contamination encountered. The location and depths of these borings,
if necessary, will be determined in the field, based on the evidence of impacts observed to the
soil.
Treatability Study:
Soil samples from within the LNAPL contaminated smear zone will be collected to conduct a
bench scale test to determine the most effective ISCO treatment option. Vadose zone soil
samples from three representative boring locations will be submitted for grain size analysis to
assist in ISCO design.
Reporting:
Following the 2013 field activities a report will be generated summarizing the results of the site characterization and treatability study bench scale test. A work plan will following the report outlining the next step of the treatability study to be implemented in 2014. Based on the results of the bench scale test the next step will likely consist of an ISCO application consisting of the injection of either potassium permanganate or Regenox. |
Louis Howard |
| 4/4/2013 |
Document, Report, or Work plan Review - other |
EPA (Sandra Halstead) comments on the UFP-QAPP for FT023.
A very good review paper is available on the use of ISCO as a treatment remedy. Many of the background parameters that are necessary for evaluating ISCO are not proposed in the data collection efforts of these site characterization workplans. It is strongly recommended to collect the necessary biogeochemical parameters to understand the conditions prior to ISCO/ISCR treatments to provide a baseline, and during and after ISCO/ISCR injections to evaluate treatment effectiveness.
http://www.epa.gov/ada/gw/pdfs/insituchemicaloxidation_engineering_issue.pdf
No information is provided on the approach for the bench studies. Will a separate workplan be provided to detail out how these will be conducted?
No information is provided regarding site characterization of the buried drum source location as shown on Figure 1-2. Please describe how this source area has been addressed in the past or will be addressed as a part of this site characterization workplan.
In numerous places throughout the document, ISCO ‘treatment’ is referenced. As this site is under an existing ROD which does not include ISCO, please clarify that additional remedies may be evaluated after the the site characterization data is reviewed by the regulators and AF.
p. ES-2 The narrative describes a change in the remedy “the selected remedy now includes the following”. Please describe if the modified remedy is based on a ROD Amendment, ESD, or memo to the site file. If so, please reference the type and date of the remedy modification. If COCs have been deleted, please state this explicitly.
p. ES-3 The last sentence of the first paragraph should include the exceedance for TCE at well GW-5A in addition to OU4W-11.
Table 1-1 p. ES-3
Please clarify the contaminants as listed in this table. Why are they identified with soils, and why are they termed as COPCs? These are 3 of the seven COCs identified in groundwater in the OU4 ROD for FT023 (called FTA in the ROD). If these are soil cleanup criteria, why are the units expressed in ug/L and not mg/kg? The values presented as the cleanup level appear to be the current EPA MCL values for these three COCs and do not match the ADEC Table B1 soil migration to groundwater criteria or ADEC Table C groundwater cleanup values.
ES p. ES-4 The first paragraph on page ES-4 appears to belong to activities associated with GW-5A but it does not specifically mention this well. Please clarify if this paragraph applies to both OU4W-11 and GW-5A locations or only one of these areas.
Treatability Studies section. Soil samples will be used to conduct the bench scale test to determine the most ISCO chemical and application method for the site. EPA recommends that additional factors, including groundwater geochemical conditions, be considered when designing the bench scale test for future treatment options.
Figure 1-2
p. ES-7 Two new borings are shown on Figure 1-2, one each downgradient of OU4W-11 and GW-5A, however the narrative in Worksheet #17 proposes 5 soil borings. New possible groundwater wells are proposed in the narrative of Worksheet #17, and no new well locations are approximated on Fig 1-2. No former borings are presented on the figure as mentioned in W#17. Please revise Figure 1-2 to more accurately represent the proposed sampling activities in the workplan.
No former treatment locations are identified on Figure 1-2 as suggested at the scoping meeting in November 2012.
A former location of buried drums is shown on Figure 1-2. No monitoring wells appear to exist downgradient of this former source area. Please clarify the fate (treatment and/or monitoring) of the buried drums source location in the Previous Investigation narrative.
If this source area has not undergone a removal action, please address how treatment and montoring of this source area will be conducted under this site characterization workplan.
There are seven VOCs identified in the OU4 FTA ROD for groundwater contaminants. For completeness, please provide data for all GW contaminants over time at the monitoring wells. This data is not necessary if a formal change to the ROD COCs has been completed to eliminate a subset of COCs. Please refer to Specific Comment #2.
Please include a descriptor for building numeric id’s in the legend. No reference to what these numbers signify was provided on the figure.
|
Louis Howard |
| 4/8/2013 |
Document, Report, or Work plan Review - other |
ADEC Review comments for the FT023 UFP-QAPP provided to the Air Force.
Pg ES-1
While currently not a part of the JBER Performance Base Remediation (PBR) contract scope of work, ADEC is requesting that Air Force address Perfluorinated compounds (PFCs) at FT023 under non-PBR contracts as soon as possible. In 1970, the Air Force (nationwide) began using Aqueous Film Forming Foam (AFFF) fire fighting agents containing PFCs to extinguish petroleum fires. AFFF can contain & degrade into perfluorooctane sulfonate (PFOS), & may further degrade into perfluorooctoanoic acid (PFOA). During fire training, equipment maintenance, & use, AFFF was released directly to the environment.
Even if all other contaminants were below applicable cleanup levels in soil & GW at FT023, without analysis of PFOS & PFOA, ADEC will not grant a cleanup complete, unrestricted use/unlimited exposure or a cleanup complete with ICs decision & FT023 will remain “active” or open in the Contaminated Sites database.
In accordance with 18 AAC 75.340(g) , ADEC has calculated cleanup levels for PFOS & PFOA. Using the numerical factors presented in EPA’s Office of Water which established a provisional health advisory for PFOS & PFOA to protect against the potential risk from exposure of these chemical through drinking water provisional health advisory, a subchronic RfDs was extrapolated by ADEC & subsequently used in the current EPA Regional Screening Levels equations for Alaska site-specific risk based cleanup levels in soil & GW. Values maybe updated by ADEC as more current & relevant toxicity information are presented & reviewed
WS #10 Nature & Extent of Contamination
Previous Investigations
1999/2005 Sampling
Please note that soil samples collected in 1999/2005 were analyzed for: BTEX, GRO, DRO, RRO. PAHs & VOCs were not analyzed for during this effort. Also, the 1994 RI detected PAHs surface & sub-surface soils & trichloroethylene in the subsurface, all which were above cleanup levels.
Page 16
ADEC requests JBER provide information (e.g. location & well construction) on the nearest (within ½ mile of FT023) drinking water [Base] well or standby drinking water well that may be used on a temporary, intermittent or permanent basis.
See site file for additional information. |
Louis Howard |
| 5/30/2013 |
Update or Other Action |
Draft Annual Field Activities report received for review & comment.
This report summarizes the 2012 annual long-term management activities, including remedial action-operation (RA-O) & Record of Decision (ROD) requirements conducted at Joint Base Elmendorf-Richardson (JBER) Comprehensive Environmental Response, Compensation, & Liability Act (CERCLA) sites. The United States Air Force (USAF) has mandated a reduction of long-term environmental liabilities & life-cycle costs through accelerated cleanup of contaminated sites.
As such, the Performance Based Remediation (PBR) initiative has been developed to protect human health & the environment in a cost effective manner while at the same time reducing life-cycle costs. In April 2012, Weston Solutions, Inc. (WESTON) was awarded a PBR contract from the Air Force Civil Engineer Center (AFCEC) (Contract Number FA8903-09-D-8589, Task Order No. 0016) that includes remediation & related activities at several JBER contaminated sites. The contract includes performing RA-O & ROD requirements at those sites. The WESTON Team performing the activities summarized in this report consists of WESTON & CH2M Hill Constructors, Inc. (CH2M HILL). WESTON executed project work on sites located within JBER-Elmendorf (JBER-E) while CH2M HILL executed project work on sites located within JBER-Richardson (JBER-R).
During 2012, in-source groundwater monitoring well OU4MW-11 & downgradient well 407MW-11 were sampled & analyzed for all groundwater COCs. Analytical results exceeded the OU4 ROD cleanup criterion in groundwater well OU4MW-11 for 1,1-DCA (9.1 micrograms per liter [µg/L]), PCE (7.7 µg/L), TCE (6.7 µg/L) & cis-1,2-DCE (81 µg/L). All other laboratory sample results were below cleanup criteria. Table 3-1 presents a summary of the 2012 results. Historic results are presented on Figure 3-1. A LUC inspection performed at FT023 on 30 August 2012 did not identify any issues.
Site Summary
Well FP-56, in the northern plume, was removed from annual sampling after three successive years (2009, 2010, & 2011) of measuring COC concentrations below cleanup levels, indicating that the groundwater cleanup for the northern Fire Training Area Plume is complete. In 2012, in-source data was collected from OU4MW-11 in the southern plume, & showed several COCs above cleanup levels. Contaminant concentrations measured in the southern Fire Training Area Plume have exceeded cleanup levels seven years beyond the original cleanup target date of 2005. The downgradient well, 407MW-01 results were below cleanup levels from 2009—2012.
Additional investigation to characterize soil & groundwater contamination is being proposed for FT023 under the new PBR contract. No changes to the annual monitoring are being proposed for this site.
|
Louis Howard |
| 6/10/2013 |
Update or Other Action |
Draft Annual Report for CERCLA sites received for review and comment.
During 2012, in-source groundwater monitoring well OU4MW-11 and downgradient well 407MW-11 were sampled and analyzed for all groundwater COCs. Analytical results exceeded the OU4 ROD cleanup criterion in groundwater well OU4MW-11 for 1,1-DCA (9.1 micrograms per liter [µg/L]), PCE (7.7 µg/L), TCE (6.7 µg/L) and cis-1,2-DCE (81 µg/L). All other laboratory sample results were below cleanup criteria.
A LUC inspection performed at FT023 on 30 August 2012 did not identify any issues.
Well FP-56, in the northern plume, was removed from annual sampling after three successive
years (2009, 2010, and 2011) of measuring COC concentrations below cleanup levels, indicating
that the groundwater cleanup for the northern Fire Training Area Plume is complete.
In 2012, in-source data was collected from OU4MW-11 in the southern plume, and showed several COCs above cleanup levels. Contaminant concentrations measured in the southern Fire Training Area Plume have exceeded cleanup levels seven years beyond the original cleanup target date of 2005. The downgradient well, 407MW-01 results were below cleanup levels from 2009—2012.
Additional investigation to characterize soil and groundwater contamination is being proposed
for FT023 under the new PBR contract. No changes to the annual monitoring are being proposed for this site. |
Louis Howard |
| 6/28/2013 |
Document, Report, or Work plan Review - other |
Staff provided review comments on the CERCLA Annual field activies report.
Comment #1
ADEC is requesting that 1,4-dioxane be sampled for in GW where trichloroethylene (TCE) or 1,1,1- trichloroethane (TCA) contamination exists or was previously above cleanup levels at any site (CERCLA or State restoration or compliance). Please incorporate these comments into any basewide sampling plans (current/future).
AFCEE research has found 1,4-dioxane at Air Force sites contaminated with TCE. The study, titled "Co-Occurrence of 1,4-Dioxane with Trichloroethylene in Chlorinated Solvent GW Plumes at US Air Force Installations: Fact or Fiction," found detections of 1,4-dioxane at sites with TCE, independent of TCA.
The study authors recommend site investigations consider 1,4-dioxane as a potential co-contaminant of TCE at GW plume sites. The study, which was published in the Integrated Environmental Assessment & Management journal last year, explicitly warns that new discoveries of 1,4-dioxane contamination could delay cleanup completions & require more costly revisions to existing remedies, noting that there is strong evidence suggesting that 1,4-dioxane "will migrate much further than chlorinated solvents."
ADEC has promulgated enforceable cleanup levels (not advisories) for 1,4-Dioxane in soil & GW (latest version 18 AAC 75 April 2012 Table B1 & Table C) effective since 2008 which has remained unchanged in 2012 revised regulations.
This comment regarding monitoring requirements for 1,4-Dioxane applies to JBER-Elmendorf & JBER-Richardson sites with current or past TCE or TCA contamination. The monitoring requirement is also applicable to the “Early Warning & Sentry Wells” which were established to provide early detection of contaminant plumes that may impact Ship Creek or other downgradient environmental receptors.
1,4-Dioxane readily leaches to GW, is not expected to adsorb significantly to soil particles, & is difficult to biodegrade. Due to these properties, a 1,4-Dioxane plume typically proceeds ahead of the chlorinated solvent plume, & will tend to impact an aquifer system to a much larger extent.
See site file for additional information.
|
Louis Howard |
| 11/4/2013 |
Update or Other Action |
Fourth Five-Year Review (draft) received for review & comment.
Groundwater (GW) monitoring results have been evaluated annually since the previous Five-Year Review Report (2008). Evaluations included trend analysis of COCs & an assessment of natural attenuation parameters. COC concentrations in GW are below cleanup levels at the FT23 North Plume, SD24, & SD28; & are decreasing at SD29. Natural attenuation processes appear to be working at these sites. However, natural attenuation processes do not appear to be occurring effectively at SD25 & the FT23 South Plume, where concentrations of COCs are either stable or increasing; for this reason, a cleanup date cannot be predicted for these sites.
The 2003 Five-Year Review indicated that it was unclear whether natural attenuation of chlorinated solvents would be limited by the amount of organic carbon available at the FT23 South Plume. The 2008 Five-Year Review (USAF, 2008a) concluded that BTEX concentrations were sufficiently high to support reductive dechlorination, & that chlorinated solvents were expected to meet cleanup levels by 2010; however, erratic contaminant concentrations & a lack of data over the past several years does not provide a great deal of confidence in this estimate (USAF, 2012b). Current trend analysis shows that COC concentrations are decreasing except for TCE at the source well at the FT23 South Plume, where a cleanup date cannot be predicted at this time.
The remedy at OU4 is expected to be protective of human health & the environment upon attainment of deep soil cleanup levels through bioventing at one remaining site (FT23) & attainment of GW cleanup levels through natural attenuation at sites FT23, SD24, SD25, & SD29. In the interim, exposure pathways that could result in unacceptable risks are being controlled. The remedy at site SD28 is protective of human health & the environment. GW samples from the time of the ROD show that no contamination above background levels/regulatory cleanup levels remains & the site is acceptable for UU/UE.
According to monitoring results at SD25, an increasing trend has been identified for ethylbenzene. Additionally, trend analysis results indicate that concentrations of benzene & toluene are stable & no decreasing trend for these contaminants was evident. According to the OU4 ROD, all groundwater contamination was expected to be below established cleanup levels by 2008; no cleanup date can be predicted for groundwater at SD25.
The assessment of potential vapor intrusion risk to indoor air has evolved significantly during the review period. Several manned facilities are located in proximity to the VOC groundwater plumes associated with OU4. Historic vapor intrusion assessments have occurred at OU4; however, additional lines of evidence are needed to support short- & long-term protectiveness.
GW COPCs were compared to current federal & state standards. New GW cleanup levels &/or MCLs (not addressed in the ROD or previous five-year reviews) for 2-methylnaphthalene, 4-methylphenol, acetone, chloroethane, chloromethane, cis-1,3-dichloropropene, dieldrin, methyl ethyl ketone, phenol, & trichlorofluoromethane were identified. Concentrations of the aforementioned contaminants were below the newly established cleanup levels at the time ROD. Therefore, the newly promulgated cleanup levels do not call into question the protectiveness of the remedy.
The OU4 ROD established 2008 as the groundwater cleanup date; however, concentrations of COCs at SD25 remain at least an order of magnitude above cleanup levels. No decreasing trends for two of the COCs (toluene and benzene) could be established and an increasing trend was identified for ethylbenzene. Therefore, a cleanup date cannot be predicted at this time.
Protectiveness: Protectiveness determination of the remedy at OU4 is deferred until the potential impacts associated with the vapor intrusion pathway at the site are evaluated. The vapor intrusion assessment is expected to be performed in 2014.
Recommendations & Follow-up: Evaluate alternative remedial strategies to accelerate attainment of cleanup levels in groundwater at SD25. Vapor intrusion evaluations that provide multiple lines of evidence should be conducted for each occupied facility that is in proximity to the VOC groundwater plumes.
Manned facilities are present in the vicinity of the contaminant plumes associated with the active sites at OU4, indicating a potential for vapor intrusion to occur at those facilities.
Future Five-Year Reviews for OUs 1, 2, 4, 5 & 6 & Site DP98 are necessary because contamination remains above levels that allow for UU/UE in these areas. The next Five-Year Review is due on or before January 27, 2019. |
Louis Howard |
| 12/20/2013 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft 4th 5 Year Review report.
S-3 Issues & Recommendations Identified in the Five-Year Review: Page S-3 OU4 Remedy Performance Recommendation - ADEC requests the Air Force be more specific. A modification to the feasibility study (FS) to determine whether a revised remedy would be more effective.
Monitoring
ADEC requests the Air Force move the “Milestone Date” up to 2015 instead of 2016. All sites with complete exposure pathways & potential unacceptable risk are a high priority & the vapor intrusion assessments should be moved up.
4-20 4.3.1 OU 4 Remedy Implementation & Status - The text states: “Current trend analysis shows that COC concentrations are decreasing except for TCE at the source well at the FT23 South Plume, where a cleanup date cannot be predicted at this time.”
ADEC requests text be added clarifying whether TCE concentrations at FT23 South Plume are either increasing, stable, or there is no identifiable trend.
OU 4 Page 6-10
ADEC requests the text states: “A trend analysis performed for monitoring well GW-5A determined that there is no identifiable trend was available for TCE, …”
Page 6-11
ADEC requests the text state: “A trend analysis evaluation determined that there is no identifiable trend for toluene & benzene;…”
7-12, 7-13 & 7-14 7.3 OU 4
Question B: Are the exposure assumption, toxicity data, cleanup levels & RAOs used at the time of the remedy selection still valid?
Answer: Yes
Changes in Standards & TBCs
This is partially correct for sources with trichloroethylene (TCE) GW contamination. See comment #6 above regarding 1,4-Dioxane cleanup levels & sampling requirements. TCE was identified as a contaminant present in water most likely present due to past disposal practices at OU4.
While currently not a part of the JBER Performance Base Remediation (PBR) contract scope of work or as part of the JBER Basewide monitoring program under CERCLA, ADEC is requesting that Air Force address Perfluorinated compounds (PFCs) at FT023 under non-PBR contracts or PBR basewide program as soon as possible.
In 1970, the Air Force (nationwide) began using Aqueous Film Forming Foam (AFFF) fire fighting agents containing PFCs to extinguish petroleum fires. AFFF can contain & degrade into perfluorooctane sulfonate (PFOS), & may further degrade into perfluorooctoanoic acid (PFOA). During fire training, equipment maintenance, & use, AFFF was released directly to the environment. FT023 is one of these sites where AFFF was used.
In accordance with 18 AAC 75.340(g), ADEC has calculated cleanup levels for PFOS & PFOA. Using the numerical factors presented in EPA’s Office of Water which established a provisional health advisory for PFOS & PFOA to protect against the potential risk from exposure of these chemical through drinking water provisional health advisory, a chronic RfDs was extrapolated by ADEC using equations in the “Cleanup Level Guidance” (adopted by reference-18 AAC 75). Below are the Under 40-inch Zone risk based cleanup levels in soil & GW. Values may be updated by ADEC as more current & relevant toxicity information are presented & reviewed or when the Alaska Cleanup Rules are updated & promulgate cleanup levels in soil & GW for these chemicals of concern.
Soil Cleanup Levels
Under 40 Inch Zone:
Direct Contact
PFOS 0.634 mg/kg & PFOA 1.58 mg/kg
Migration to GW
PFOS 0.277 mg/kg & PFOA 0.258 mg/kg
Table C GW Cleanup Levels:
PFOS 0.000292 mg/L & PFOA 0.000730 mg/L.
The request for monitoring PFOS & PFOA applies to FT023 on JBER-Elmendorf as well as any other JBER sites where fire training areas/pits were historically used (e.g. Ft. Richardson Landfill/Fire Training Area aka FTP-1 & Ruff Road aka FTP-2). Also, ADEC requests that all locations were AFFF was also stored for firefighting purposes or demonstration purposes such as near runways in tanker trunks, aboveground tanks, underground storage tanks &/or fire stations be included in this monitoring.
The text states: “Although historic vapor intrusion assessments of OU4, OU5, & DP98 found no threat to human health, additional lines of evidence may be needed to support short- & long-term protectiveness.”
ADEC concurs. However, the OU5 1994 RI did calculate a maximum soil gas concentration from GW for TCE: 5.05 mg/m3 (Table 6-29 Comparison of Estimated Maximum Soil Vapor Concentrations From GW to Acute & Chronic Exposure Effect Levels by Inhalation in Mammals). At OU5, an independent gaseous standard was not analyzed to calibrate soil gas samples. Therefore, the soil gas sample concentrations cannot be quantitated because the standard headspace concentration was unknown & the soil gas results are all designated as “unitless”.
|
Louis Howard |
| 1/3/2014 |
Document, Report, or Work plan Review - other |
EPA comments on the draft 4th 5 Year-Review report.
Summary Form pages S-2 to S-5 And Section 7
Comment: The protectiveness determinations, issues, and recommendations in the Summary Form and Sections 8 and 9 should reflect the issues identified in Section 7, Technical Review, Questions A, B, and C for each OU.
As drafted, Section 7 answers “yes” to all OUs for Question A,” Is the remedy functioning as intended in the decision documents?”. However, OU4, OU5, and DP98 groundwater will not meet RAOs in a reasonable time frame and recommendations are made for these OUs to “evaluate alternative remedial strategies” or “improve remedial performance”. If the remedy is functioning as intended, how are “optimization of performance” or “evaluation of alternative remedial strategies” justified?
As drafted, Section 7 answers “no” to all OUs for Question B, “ Are the exposure assumptions, toxicity data, cleanup levels, and RAOs used at the time of the remedy selection still valid?” . However, OU4, OU5, and DP98 defer protectiveness until the vapor intrusion risk can be assessed, which reflects a change in exposure pathway assumptions.
As drafted, Section 7 answers “no” to all OUs for Question C, “Has any other information come to light that could call into question the protectiveness of the remedy”. However OU1 and OU5 discuss possible unidentified upgradient and uncontrolled sources for groundwater plumes.
Please amend the responses to Section 7, Questions A, B, and C as needed to reflect the issues and recommendations identified in Sections 8, 9, 10, and the corresponding sections of the Summary Form and Protectiveness Statements.
Summary Form OU4, OU5, DP98 Monitoring VI pathway Pages S-3, S-4, S-5
Comment: EPA agrees with both the issue of potential vapor intrusion and evaluation of the VI risk in these OUs, however the recommendation should spell out what is intended in the “vapor intrusion evaluations that provide multiple lines of evidence” as outlined in OU4 and DP98. OU5 recommends a “comprehensive vapor intrusion study, especially in terms of residential occupancy exposure”.
Page 8 of Assessing Protectiveness at Sites for VI - 5YR Supplemental Guidance (OSWER Directive 9200.2-84) provides additional direction for the data collection efforts.
The magnitude and extent of the VI investigation is not defined (how VI will be characterized, estimate how many buildings will be assessed)
Additionally, the current monitoring well networks at many sites do not appear adequate to define the extent of groundwater plumes or determine whether plumes remain stable. This affects not only the MNA effectiveness determination but may also hinder the vapor intrusion assessments attributed to VOC plumes.
It is suggested to prioritize the vapor intrusion evaluations at these OUs. Select interim milestones for conducting the vapor assessments by the end of calendar year 2014 and identify 2016 as the date the protectiveness determination can be made
1) Prioritize evaluation of residential indoor air VOC concentrations, followed by office spaces
2) The plume source and boundaries for the OU5 plumes are not well defined, and any VI evaluation at this OU should concentrate on residential housing and office space in and around the OU5 plumes as a priority.
Summary Form Protectiveness Statements Pages S-6 and S-7 OU4, OU5, DP98: Please add a date when the protectiveness determination can be made. (Addendum Due Date).
The Summary form protectiveness statement suggests the evaluation will be conducted in 2016. The Protectiveness Statements in Section 10.0 state the “vapor intrusion assessment is expected to be performed in 2014”.
It is suggested the assessment of vapor intrusion risk will include all residential areas and office space by the end of the calendar year 2014, and a protectiveness determination completed by the end of calendar year 2016. |
Louis Howard |
| 3/17/2014 |
Document, Report, or Work plan Review - other |
EPA Letter to Air Force regarding the 4th Five Year Review for JBER-Elmendorf.
The U. S. Environmental Protection Agency Region 10 has reviewed the Fourth CERCLA Five-Year Review report for Superfund sites, specifically for Operable Units (OU) 1, 2, 4, 5, 6 and DP98 associated with Elmendorf Air Force Base on Joint Base Elmendorf-Richardson, Alaska. The conclusions in this letter are based on the draft report from November 2013 and revised Response to Comments, Summary Form, and Sections 8 and 9 which were received by the EPA on March 12, 2014.
The EPA reviewed the report for technical adequacy, accuracy, and consistency with the National Contingency Plan and EPA guidance. The document provides a summary of the status and protectiveness for OUs for which Records of Decisions (RODs) have been completed and are not determined as No Further Action. It also identifies actions to be taken that ensure protectiveness of the selected remedies and on-going remedial actions and documents a schedule for completion of the recommended actions.
The following are the EPA’s protectiveness determinations for these OUs and the overall Site protectiveness that will be reported to Congress in the EPA’s annual report. Also included are additional recommendations and follow-up actions necessary to address issues raised in the Five-Year Review that affect or could affect protectiveness. In general, the EPA concurs with the protectiveness determinations in this Air Force report. Each OU is discussed individually below.
OU 4
The EPA concurs with the deferred protectiveness determination for OU 4 pending additional sampling to address the potential for vapor intrusion at occupied buildings in proximity to the contaminated chlorinated groundwater plumes. The vapor intrusion evaluation will prioritize buildings with the most vulnerable populations (child care centers, schools, homes or offices occupied by women of childbearing age) and is expected to be completed for all occupied facilities by 2015.
In addition, benzene contaminated groundwater at Site SD25 remains at least one order of magnitude above cleanup levels and exceeded the predicted cleanup date of 2008. Land Use Controls for OU4 prohibit access to contaminated groundwater as a source of drinking water. EPA agrees with the recommendation to evaluate alternative remedies using the process established in the FFA to accelerate attainment of cleanup levels in groundwater at SD25.
An addendum to determine the protectiveness of OU 4 will be prepared by December 31, 2016.
|
Louis Howard |
| 3/20/2014 |
CERCLA ROD Periodic Review |
ADEC appreciates the opportunity to review the fourth Five Year Review report for the Elmendorf Air Force Base (now JBER-E) Superfund site, in Anchorage Alaska. ADEC reviewed this report for technical adequacy, accuracy, and consistency with EPA guidance and the Elmendorf Air Force Base Federal Facility Agreement. Also included are additional recommendations and follow-up actions necessary to address issues raised in the Five Year Review that affect or could affect protectiveness. ADEC has reviewed the report which includes: Operable Units (OU) 1, 2, 4, 5, 6 and DP98, associated with Elmendorf Air Force Base on Joint Base Elmendorf-Richardson, Alaska. In general, ADEC agrees with the protectiveness determinations in this report.
General Comments
ADEC has commented on the matter of sampling for Perfluorinated compounds (PFCs) in this Five-Year Review at various fire-training areas/pits where Aqueous Film Forming Foam (AFFF) fire-fighting agents containing PFCs were used to extinguish fires. The Air Force’s response to ADEC’s comments was the following: “USAF guidance (Interim Guidance on Perfluorinated Compounds, 17 Sep 2012) will be followed to address potential release of perfluorinated compounds (PFCs). A centrally-funded project to conduct initial sampling has been authorized and programmed.” ADEC expects JBER to sample all of its former fire training areas/pits for PFCs [e.g. perfluorooctane sulfonate (PFOS), and perfluorooctoanoic acid (PFOA)] prior to the Fifth Five-Year Review to determine whether or not these compounds are contaminants of concern and require remedial action to protect human health, welfare, safety or the environment.
ADEC concurs with the deferred protectiveness determination for OU4 pending an evaluation in 2015 of the vapor intrusion pathway at manned buildings above and in the vicinity of the chlorinated solvent plumes in OU4. Priority for sampling and reporting of results will be given to those buildings with the most vulnerable populations (e,g, child care centers, schools, homes/residences or offices occupied by women of childbearing age). An addendum to the Five-Year Review report should be prepared by December 31, 2016 which incorporates the results of the vapor intrusion assessment and any change on protectiveness for OU4.
Benzene contaminated groundwater at SD025 remains at least one order of magnitude above cleanup levels. Land Use Controls for OU4 prohibit access to contaminated groundwater as a source of drinking water. Groundwater contaminants at site SD025 (Hanger 8/11) did not meet cleanup goals within the 13 year timeframe (by 2008) as specified in the ROD for OU4. ADEC agrees with the recommendation to evaluate further response actions (e.g. alternative remedies) through the process established in the Elmendorf Air Force Base Federal Facility Agreement to accelerate attainment of cleanup levels in groundwater at SD025. |
John Halverson |
| 5/28/2014 |
Update or Other Action |
Draft 2013 Annual Field Activities Report received.
This report summarizes the 2013 annual long-term management activities, including remedial
action-operation (RA-O) and Record of Decision (ROD) requirements, conducted at Joint Base
Elmendorf-Richardson (JBER) Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA) sites. The United States Air Force (USAF) has mandated a reduction
of long-term environmental liabilities and life-cycle costs through accelerated cleanup of
contaminated sites. As such, the Performance-Based Remediation (PBR) initiative has been
developed to protect human health and the environment in a cost-effective manner, while at the
same time reducing life-cycle costs.
In April 2012, Weston Solutions, Inc. (WESTON) was awarded a PBR contract from the Air Force Civil Engineer Center (AFCEC) (Contract Number FA8903-09-D-8589, Task Order No. 0016). The contract includes performing RA-O and ROD requirements at several JBER sites. The WESTON team performing the activities summarized in this report consists of WESTON and CH2M HILL Constructors, Inc. (CH2M HILL). WESTON executed project work on sites located within JBER-Elmendorf, while CH2M HILL executed project work on sites located within JBER-Richardson.
Well FP-56, in the northern plume, was removed from annual sampling after three successive years (2009, 2010, and 2011) of measuring COC concentrations below the OU4 ROD cleanup criteria, indicating that the groundwater cleanup for the northern Fire Training Area Plume is complete.
A groundwater sample collected in 2013 from an in-source monitoring well, OU4MW-11, in the
southern plume, had PCE, TCE, and cis-1.2-DCE above the OU4 ROD cleanup level. Contaminant concentrations measured in the southern Fire Training Area Plume have exceeded cleanup levels eight years beyond the original cleanup target date of 2005.
Mann-Kendall trend tests show that there is a statistically significant decreasing trend at the 95% level of significance for PCE, TCE, and cis-1.2-DCE in well OU4MW-11. Mann-Kendall trend test analysis records are provided in Attachment 1. Results from the downgradient well, 407MW-01, were below cleanup levels annually since it was first sampled in 2009.
According to the Basewide Monitoring Program Well Sampling Decision Guide (USAF, 2006), if a plume is stable, in-source wells should be sampled once every five years and downgradient wells should be sampled once every two years. The in-source well OU4MW-11 should continue to be sampled once every five years. The downgradient well, 407MW-01 is recommended to be sampled once every two years in accordance with the Well Sampling Decision Guide. |
Louis Howard |
| 6/4/2014 |
Document, Report, or Work plan Review - other |
ADEC provided comments on the draft CERCLA GW monitoring report.
FT023 Site Summary
The text states: “According to the Basewide Monitoring Program Well Sampling Decision Guide (USAF, 2006), if a plume is stable, in-source wells should be sampled once every five years and downgradient wells should be sampled once every two years. The in-source well OU4MW-11 should continue to be sampled once every five years. The downgradient well, 407MW-01 is recommended to be sampled once every two years in accordance with the Well Sampling Decision Guide.”
ADEC concurs with the recommendations regarding sampling frequency with regards to TCE, PCE, cis-1,2,-DCE. However, little is known about the extent of 1,4-Dioxane and and perfluorinated compounds PFCs at FT023 (OU 4 Fire Training Area) and the sampling guide does not apply to these contaminants since there is not any baseline data.
While currently not a part of the JBER Performance Base Remediation (PBR) contract scope of work or as part of the basewide monitoring program, ADEC is again requesting that Air Force address PFCs at FT023 under non-PBR contracts as soon as possible. In 1970, the Air Force (nationwide) began using Aqueous Film Forming Foam (AFFF) fire fighting agents containing PFCs to extinguish petroleum fires. AFFF can contain and degrade into perfluorooctane sulfonate (PFOS), and may further degrade into perfluorooctoanoic acid (PFOA). During fire training, equipment maintenance, and use, AFFF was released directly to the environment.
In accordance with 18 AAC 75.340(g) , ADEC has calculated cleanup levels for PFOS and PFOA. Using the numerical factors presented in EPA’s Office of Water which established a provisional health advisory for PFOS and PFOA to protect against the potential risk from exposure of these chemical through drinking water provisional health advisory, a subchronic RfD was extrapolated by ADEC and subsequently used in the current EPA Regional Screening Levels equations for Alaska site-specific risk based cleanup levels in soil and groundwater. Values may be updated by ADEC as more current and relevant toxicity information are presented and reviewed.
Under 40 Inch Zone: PFOS 6.3 mg/kg and PFOA 16 mg/kg (based on cumulative risk from soil (ingestion, dermal and inhalation).
Risk-based Groundwater Cleanup Levels: PFOS 0.0013 mg/L and PFOA 0.0031 mg/L.
See site file for additional information. |
Louis Howard |
| 11/5/2014 |
Document, Report, or Work plan Review - other |
EPA provided comments on the Draft Annual CERCLA report.
Comment: Please provide an explanation on the fate of the drums (where they removed)?
Why aren’t there any gw wells regularly monitored immediately downgradient of the drum area?
Comment: The statement that OU4MW-11 is sampled every 5 years is not factual. Sample frequency has been variable over the past few years including multiple results for a given sample date. Sampled in both 2012 & 2013. Please revise the narrative to reflect the variable sampling intervals.
Comment: The statement about the absence of organic carbon at well 407MW-01 is not substantiated by TOC data unless a clear link can be made to the TOC content and similar biogeochemical conditions at Northern Plume well FP-56. Also under oxidizing conditions, you would not expect degradation however this well doesn't have any detectable COCs. Please clarify the interpretation of conditions at this well that lead to low COC concentrations.
Comment: Three successive annual sample results under cleanup levels is not statistically valid for closure. It may be premature to claim ‘groundwater cleanup complete’
Comment: Mann Kendall trend test records were not found in Attachment 1.
Comment: This is a 2013 CERCLA activity report, however the Elmendorf 5YR was completed in February 2014 prior to the first draft of this report, and recommends adding in GW-05 to understand plume dynamics. There needs to be some way to follow through on future activities at each site, and would be most efficiently captured in a Recommendations section for each section.
Comment: This figure is an improvement by providing groundwater elevations on the map, however it is doubtful that a groundwater directional gradient could be established with only two groundwater elevation measurements. It is basic hydrology that a minimum of three elevation points are needed to determine the gradient.
Suggested changes to future Annual CERCLA reports
The CERCLA sites Annual Field Activities Report clearly reports on long term monitoring activities at these JBER sites. It would be great to include a section in the annual report which lists the titles of approved/final site specific documents associated with sites in this report as a mechanism to track the ‘new’ work occurring under the PBR (ie...CG039 OUB PRDA Treatability workplan, SS044 GW Monitoring report and decommissioning workplan ).
For additional information, see site file. |
Louis Howard |
| 4/1/2015 |
CERCLA PA |
Preliminary Assessment received for multiple U.S. Air Force (Air Force or USAF) and Air National Guard (ANG) Fire Training Areas (FTAs) to determine probable environmental release of perfluorinated compounds (PFCs). Specifically, HGL is completing PA activities consistent with the U.S. Environmental Protection Agency (USEPA) Guidance for Preparing Preliminary Assessments under the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) (USEPA, 1991) to determine potential releases of PFCs at 82 Air Force and ANG installations from FTAs and other known and suspected PFCs or aqueous film-forming foam (AFFF) usage or storage areas.
General practices related to the fire training at this location are unknown. However, according to the Assistant Fire Chief (involved with JBER fire safety since 2003), AFFF was not used to
extinguish the fires during training events now or in the past (Bakker, 2014b, personal
communication; Appendix C). Because the operational history and release of AFFF during the
years prior to the current Assistant Fire Chief is unclear, it is assumed that the potential for PFCs released to the environment is present.
Recommendation is to initiate a site inspection. A SI is defined as an investigation to collect and analyze waste and environmental samples to support an evaluation (USEPA, 1992). |
Louis Howard |
| 4/8/2015 |
Update or Other Action |
Draft Limited Site Investigation Report received for review & comment. Work Plan deviations: The field work was conducted per the project SOPs in the FT023 Fire Training Area (IRP) UFP-QAPP, & the scope of work described in the site-specific work plan was accomplished. There were deviations from the work plan. Step-out distances determined in the FT023 UFP-QAPP were deemed inadequate from field screening results & soil observations so they were subsequently lengthened.
More than eight borings were installed, as lab samples & field screening determined the solvent plume to be more extensive than assumed in the FT023 Fire Training Area (IRP) UFP-QAPP. A glycol line providing floor heating in Bldg 17508 was damaged while attempting a downgradient boring into the slab foundation.
This boring was not pursued to avoid any further damage to the glycol lines & to prevent glycol contamination of the underlying soil. Additional wells were not installed because the extent of the chlorinated solvent contamination had not been determined.
The GW samples were not analyzed by TestAmerica Labs as specified in the FT023 UFP-QAPP, but instead were analyzed by SGS Labs, which had been approved in the updated 2014 Basewide QAPP. The GW samples were also analyzed for the full VOC suite, instead of the reduced list specified in the FT023 UFP-QAPP. Only the GW contaminants listed in the ROD are summarized in Table 4-3. There were no detections above Table C cleanup levels for the additional GW VOC parameters.
The data set for FT023 supports the following conclusions:
• Field screening suggests contamination by petroleum hydrocarbons in the smear zone soils is present within the chlorinated solvent plume.
• Contamination by petroleum occurs in a lens approximately 250’ x 240’ x 5’ thick within the smear zone. This was inferred from PID readings in the 100s of ppm range obtained from smear & saturated zone soil borings around OU4W-11.
Recommendations - Complete additional soil borings to delineate the source(s) & extent of chlorinated solvent contamination to the N-NE & in the vicinity of the decommissioned 50,000-gallon UST. Install a downgradient GW well to delineate the extent of the dissolved phase chlorinated solvent contamination. Analyze soil & GW samples for GRO, DRO, RRO, & the solvent related SW8260 parameter list, in order to characterize petroleum hydrocarbons, chlorinated solvents, & associated solvent decay compounds.
See site file for additional information. |
Louis Howard |
| 4/10/2015 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation has received the draft LSI document on April 8, 2015. ADEC has reviewed the document and has no significant comments on it and it may go final pending any EPA comments on the document. One minor comment on the analysis of VOCs via SW8260 which ADEC requests the full VOC suite be analyzed for, not just the ROD VOC list , and report the results for non-ROD VOCs in an appendix to the reporting document. |
Louis Howard |
| 4/28/2015 |
CERCLA PA |
Final Preliminary Assessment received. Under authority of CERCLA and the Superfund Amendments and Reauthorization Act of 1986, CH2M HILL conducted a PA visit at Joint Base Elmendorf-Richardson (JBER) during the week of December 15, 2014, with a follow-up visit on January 12 and 13, 2015, to secure additional information.
Based on background research and visits to JBER, a total of four FTAs, seven fire stations, seven
hangars, five crash locations, four areas where AFFF spray testing has occurred, and three
additional “miscellaneous” locations have been identified as being active during the timeframe
when AFFF has been used by the USAF for fire suppression.
JBER has one current operating FTA (on JBER-E), which was constructed with a double liner, a
pump system, and a retention pond to recirculate water used in training. The current FTA uses
only propane as a fuel source; however, anecdotal accounts indicate that the servicing of mobile
AFFF units stationed at Hangar 6 (Building 9311) may have occurred at the current FTA (Green
2015, personal communication; Appendix C). Although the FTA is lined, on occasion excess water
was disposed from the nearby retention pond by pumping the water to the adjacent ground surface.
As a result, a small amount of AFFF may have been released to the environment.
Recommendation: initiate a site inspection as an investigation to collect and analyze waste and environmental samples to support an evaluation. |
Louis Howard |
| 5/5/2015 |
Document, Report, or Work plan Review - other |
EPA provided comments on the draft LSI report. Main comments on the need for sampling of "emerging contaminants" in future investigations (i.e. 1,4-dioxane and PFCs) and the need to report all the volatile organic compounds analyzed for by low-level 8260 not just TCE, PCE and 1,2-DCE. |
Louis Howard |
| 7/23/2015 |
Update or Other Action |
Draft Annual Field Activities Report received for review and comment.
SITE SUMMARY AND RECOMMENDATIONS
A groundwater sample collected in 2014 from an in-source monitoring well, OU4MW-11, in the
southern plume, had PCE, TCE, and cis-1.2-DCE above the OU4 ROD cleanup level.
Five-Year Review
Areas in OU 4 that remain above cleanup goals are required to have CERCLA five-year reviews
conducted until such time as the cleanup goals are achieved. The purpose of the five-year review
is to evaluate the implementation and performance of the remedial actions. There were no
recommendations for FT023 documented during the first and second five-year review period. The third five-year review report recommended updating 1,2-dichloroethane, PCE, and TCE groundwater cleanup levels to be consistent with the referenced standards.
The fourth five-year review report recommended that a sampling event be conducted to identify if concentrations of 1,4-dioxane exist and determine whether or not there is an unacceptable risk at the site. Sampling of GW-5A was also recommended, as well as conducting a vapor intrusion evaluation in accordance with EPA guidelines for each occupied facility that is in proximity to the volatile organic compound (VOC) Plume.
NOTE to file: Future five-year reviews for OUs 1, 2, 4, 5 and 6 and DP098 are necessary because contamination remains above levels that allow for UU/UE in these areas. The next five-year review is due on or before March 17, 2019.
Recommendations
FT023 is identified as a Yellow priority since the plume continues to have concentrations of PCE, TCE, and cis-1.2-DCE above the OU4 ROD cleanup level. The milestone date for the vapor intrusion evaluation is 2016. The LSI recommended additional work be conducted to better delineate the extent of the chlorinated solvent contamination by installing a downgradient groundwater monitoring well and collecting soil and groundwater samples for GRO, DRO, residual-range organics (RRO), and the entire SW8260 parameter list. The following text summarizes observations and recommendations for Site FT023:
• According to the Basewide Monitoring Program Well Sampling Decision Guide, if a plume is stable, insource wells should be sampled once every five years and downgradient wells should be sampled once every two years. The downgradient well GW-5A should be added to the LTM program and sampled once every two years in accordance with the Well Sampling Guide. The well will be sampled again in 2016. |
Louis Howard |
| 8/10/2015 |
Document, Report, or Work plan Review - other |
Staff provided comments on the Annual CERCLA Report. Main comments were to ask for clarification on whether 1,4-Dioxane sampling was conducted as recommended by the Five-Year Review by the PBR contractor or if it will ever get sampled for at FT023.
Little is known about the extent of this contaminant and perfluorinated compounds associated with fire-training areas such as FT023.
See site file for additional information. |
Louis Howard |
| 4/11/2016 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft PFC Site Inspections work plan for JBER-E and JBER-R.
Main comments were regarding obtaining prior approval from ADEC and EPA project managers before making changes to the approved QAPP and that the EPA RSSLs are less stringent than the human health soil cleanup levels and migration to ground cleanup levels ADEC will be promulgating this winter (2016). It was noted that WS# 10 is especially vague: "Based on the above, the best available screening criteria for PFOA and PFOS releases are the EPA PHAs for groundwater and RSSLs for soil. Because ADEC has proposed lower concentration limits that are in the public
comment process, the ADEC levels should also be considered."
It states that ADEC levels should also be considered, however in WS # 11, it states the concentrations of PFOA and PFOS in soil and groundwater will be compared to project screening levels based on the most conservative risk based EPA or ADEC values.
For determining presence or absence of PFOS and PFOA using solely risk based screening levels is not acceptable to ADEC. If the migration to groundwater cleanup level is adopted by ADEC and it exceeds for PFOS or PFOA, a release is confirmed and it is deemed to be contaminated by ADEC. 18 AAC 75.990 Definitions.
(23} "contaminated soil" means soil containing a concentration of a hazardous substance that exceeds the applicable cleanup level determined under the site cleanup rules. If AFCEC chooses to proceed with risk based values (as it is apparent upon review of Table 10-2 Steps 2, 4, & 5), then ADEC reserves the right to require further investigation/cleanup under 18 AAC 75 for all areas of concern/source areas where AFC EC determined no addition action was necessary at an area of concern/ source area, but the PFC levels detected exceed migration to groundwater cleanup levels for PFCs.
See site file for additional information. |
Louis Howard |
| 1/13/2017 |
Update or Other Action |
ADEC received a groundwater monitoring report for several JBER sites. The report summarizes the 2015 annual long-term management (LTM) activities, including remedial action-operation (RA-O) and Record of Decision (ROD) requirements conducted at Joint Base Elmendorf-Richardson (JBER) Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) sites.
Site FT023 is identified as a Yellow priority since the plume continues to have concentrations of
PCE, TCE, and cis-1.2-DCE above the cleanup goals. The milestone date for the VI evaluation is
2016. The 2014 LSI recommended conducting additional work in order to better delineate the
extent of the chlorinated solvent contamination by collecting soil samples, and installing a
downgradient monitoring well. It is recommended to analyze soil and groundwater samples for
GRO, DRO, residual-range organics (RRO), VOCs, (including 1,4-dioxane) and perfluorinated
compounds.
See site file for additional information. |
Louis Howard |
| 6/1/2017 |
Update or Other Action |
Draft site inspection (SI) at aqueous film forming foam (AFFF) areas on JBER-E and JBER-R was received for review and comment. The purpose of the SI was to determine the presence or absence of perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS) in the environment. These compounds are a class of synthetic fluorinated chemicals used in industrial and consumer products, including defense-related applications. This class of compounds is also referred to as per- and polyfluorinated alkyl substances (PFAS).
No soil borings were completed at FT023, so lithology could not be confirmed.
One existing monitoring well was sampled. The groundwater flow direction could not be confirmed from this single well, but groundwater flow is thought to be to the south-southwest based on existing potentiometric surface maps. One groundwater sample was collected from 40 to 50 feet bgs in existing monitoring well FP-56. PFBS and PFOS were not detected in groundwater at FT023. PFOA was detected at concentrations below the EPA HA and ADEC cleanup level.
See site file for additional information. |
Louis Howard |
| 6/13/2017 |
Document, Report, or Work plan Review - other |
Staff commented on the draft SI for JBER-E and JBER-R sites which included this site. It appears there are documented releases of PFOS and/or PFOA at these areas which require additional investigation through a remedial investigation/feasibility study under CERCLA or as required by 18 AAC 75.335 Site Characterization.
The 1991 Elmendorf Federal Facility Agreement Part II Definitions. Paragraph 2.1 states: “(y) "Site” shall mean the areal extent of contamination and shall include sources of contamination subject to this Agreement at the Elmendorf (Elmendorf AFB), which occupies approximately thirteen thousand one hundred and thirty (13,130) acres, bordered by the Municipality of Anchorage,- Alaska, to the south. The Site includes ANY OFF-BASE area(s) contaminated by the MIGRATION of hazardous substances, pollutants, or contaminants FROM Elmendorf AFB;”
See site file for additional information. |
Louis Howard |
| 7/17/2017 |
Document, Report, or Work plan Review - other |
EPA received the Draft Site Inspection Report for Aqueous Film Forming Foam Areas, Joint Base Elmendorf-Richardson, Alaska, May 2017 for review the week of June 2, however Appendix B2 (App B2) laboratory data was not included. EPA received App B2 for review the week of June 20. EPA preliminary comments were sent to the Air Force on July 17, 2017.
EPA Office of Research and Development staff, as well as EPA Region 5 Laboratory chemists, reviewed App B2. EPA has asked the Air Force for clarification regarding what level of report and data review was done by the government prior to submittal of the report to EPA and have not received a clear response. EPA’s initial review has identified a number of data quality issues and that the government data review should be completed and submitted to EPA before we are asked to finalize our comments. The comments submitted in this table reflect only those requiring clarification on the narrative or figures and do not concern data quality or final conclusions on the source areas based on the data.
The last bullet point of Section 5.0 states that no further action is required for AFFF Area #17 – FT023, but no soil samples were collected from this area during the SI. Soil at AFFF Area #17 – FT023 should be sampled to confirm the absence of PFAS prior to recommending no further action. Please revise the SI Report to recommend sampling soil at AFFF Area #17 – FT023 to confirm the absence of PFAS in soil prior to recommending no further action.
See site file for additional information. |
Louis Howard |
| 11/7/2017 |
Update or Other Action |
Letter report received for CY2016 [January 1, 2016 - December 31, 2016] Annual Land Use Control (LUC) and Institutional Control (IC) Monitoring at Joint Base Elmendorf-Richardson (JBER). This letter serves as the annual monitoring report on the status of LUCs/ICs in place on JBER-Elmendorf (JBER-E) and JBER-Richardson (JBER-R). The Air Force ensures compliance with LUCs by conducting periodic monitoring and site inspections. Formal LUC/IC inspections occur annually on JBER during late spring through early fall and are typically conducted by contract. A total of 55 sites were formally inspected. Random site inspections are also conducted throughout the year by JBER Restoration staff.
Discrepancies: bolt was added to well FS-52 and the well was secured. All other wel1s were in good condition except for well 407MW-0 1, which requires replacement of the outer metal casing.
The well is covered but can,not be secured with bolts, however it is protected.
See site file for additional information. |
Louis Howard |
| 11/21/2017 |
Update or Other Action |
Per AFCEC email: A memo from the USACE summarizing issues found in their review should be in hand on the 4th of December. |
Louis Howard |
| 11/30/2017 |
Update or Other Action |
Draft VI report received for review and comment. Building 17534 is located entirely within the boundary of a VOC groundwater contamination plume with the depth to groundwater approximately 45 feet bgs. The building is relatively airtight during normal operations. Floor drains and a sump were noted within the building. No non-VI ambient air COI contaminant sources were identified. Sub-slab air pressure gradients do not apply to Building 17534, as all soil gas samples were collected from near-slab locations due to the presence of an in-slab heating system at the building.
1,1,1-TCA, benzene, PCE, and TCE were detected in soil gas and indoor air during FSE1 and
FSE2. Benzene was the only COI detected in outdoor air during FSE1, and the maximum concentration was higher than the maximum indoor air result. Outdoor air maximum concentrations were less than indoor air for the same COIs during FSE2. There is no spatial bias apparent in the locations of these COI detections in ambient air or soil gas.
Based on the above lines of evidence, the VI pathway is considered potentially complete at
Building 17534. The consistent detections of 1,1,1-TCA, benzene, PCE, and TCE in soil gas
and indoor air suggest VI as a potential source for these contaminants.
See site file for additional information. |
Louis Howard |
| 1/8/2018 |
Document, Report, or Work plan Review - other |
Draft Vapor Intrusion study received for review and comment.
Main comments were to state that the purpose of sampling was to help address the Operable Unit 4 protectiveness deferred statements in the Fourth Five-Year review. Other comments were on requesting clarification on why four outdoor air samples collocated with the near slab soil gas samples as opposed to the near slab soil gas samples being collocated with indoor air samples.
See site file for additional information. |
Louis Howard |
| 2/13/2018 |
Document, Report, or Work plan Review - other |
Staff commented on the draft RA-O & M Report for select CERCLA Sites. Main comment was on various contaminants of potential concern in soil and groundwater which were identified as part of the remedial investigation for OU4 which exceed November 7, 2017 cleanup levels in 18 AAC 75. Please address any cumulative risk from these more stringent cleanup levels and impacts to the protectiveness of the selected remedy during the next Five-Year Review. Staff also concurred with recommendations to analyze soil and groundwater for GRO, DRO, RRO, VOCs (including 1,4-dioxane) and PFCs.
See site file for additional information. |
Louis Howard |
| 5/1/2018 |
CERCLA SI |
Site Inspection Report May 2018: No soil borings were completed at FT023, so lithology could not be confirmed. One existing monitoring well was sampled (depth to GW 41.46'). The groundwater flow direction could not be confirmed from this single well, but groundwater flow is thought to be to the south-southwest based on existing potentiometric surface maps.
One groundwater sample was collected from 40 to 50 feet bgs in existing monitoring well FP-56.
PFBS and PFOS (cleanup level 0.40 ug/L) were not detected in groundwater at FT023. PFOA was detected at concentrations below the EPA HA and ADEC cleanup level (0.40 ug/L). |
Louis Howard |
| 1/15/2019 |
Update or Other Action |
Draft 5 Year Review received for comment which include Operable Unit 4 Source Area FT023. Cancer risks exceed 1 x 10-4 or have an HQ greater than 1 for the following non-COC chemicals: [in groundwater (GW)] 1,1,2-TCA, ethylbenzene, naphthalene, and total xylenes; and (in soil) 2-methylnapthalene, cis-1,2-DCE, cyanide, naphthalene, TCE, and total xylenes. Recommendation: Investigate by conducting a GW sampling event the following chemicals for potential inclusion as remedy COC chemicals: (in GW) 1,1,2-TCA, ethylbenzene, naphthalene, and total xylenes; and (in soil) 2-methylnapthalene, cis-1,2-DCE, cyanide, naphthalene, TCE, and total xylenes for potential inclusion as remedy COCs. Document any changes to COCs in a decision document.
Limited natural attenuation of COCs in GW is occurring at the site, and RAOs were not achieved within the projected timeline. Recommendation: Conduct additional studies to optimize the approach to achieve remediation goals. Other studies may include, but are not limited to: site characterization, ecological assessment, focused feasibilities studies, GW modeling, treatability studies, and/or sampling
See site file for additional information. |
Louis Howard |
| 2/14/2019 |
Document, Report, or Work plan Review - other |
Comments made on the draft five year review.
The redline version of the Site Inspection (SI) Report for AFFF Areas on JBER was accepted by ADEC for finalization on February 8, 2018. EPA provided an approval letter to finalize the SI May 21, 2018. The SI was finalized soon after the EPA approval letter in May 2018 which should have been immediately passed on to Stantec Consulting Inc. by AFCEC prior to the July 2018 “deadline” for data acquisition into the Fifth Five-Year Review. It was not.
Now that the draft Fifth Five-Year Review has been received by ADEC in January 2019, it is too late to capture this SI data set and will have to be addressed by follow-up investigations in the year 2020 and beyond. The subsequent data collection effort for PFAS contamination will need to be fully addressed in the Sixth Five-Year Review in 2024. I wish you luck in your endeavors on that matter since I will be retired from the State of Alaska employment by that time (my last day at ADEC will be 04/30/2020).
PFAS investigation is needed to delineate the nature and extent of contamination at this source area (CS DB Hazard ID 1798) in Operable Unit 4. In 2016, no soil borings were completed at FT023, so this is a data gap for PFAS.
[Additionally, groundwater was characterized with one existing cross-gradient well - FP-56 during the SI 2016 activities due to budgetary constraints. More wells are needed installed to sample for PFAS GW contamination at FT023.] Non-contaminants of concern: PFAS-no soil borings were installed as part of the 2016 Site Inspection investigation. PFAS should be assessed by conducting a sampling event (e.g. in.2020 or more realistically, 2021) of soil as soon as an EPA approved method is finalized for PFAS.
See site file for additional information. |
Louis Howard |
| 9/11/2019 |
Document, Report, or Work plan Review - other |
Staff reviewed the annual monitoring report for select CERCLA sites. Main comment was on the recommendations made in the previous 2016 RA-O and Monitoring report for CERCLA sites: “2014 LSI recommended conducting additional investigation to better delineate the chlorinated solvent sources by collecting soil samples to the north-northeast (upgradient) and the vicinity of the decommissioned 50,000 gallon UST, and installing a downgradient monitoring well. Soil and groundwater samples should be analyzed for GRO, DRO, residual-range organics (RRO), full suite VOCs, (including 1,4-dioxane), semivolatile organic compounds (SVOCs) and perfluorinated compounds (USAF, 2015b) and existing COCs.”
See site file for additional information.
|
Louis Howard |
| 3/31/2021 |
Document, Report, or Work plan Review - other |
DEC reviewed the "Draft JBE054 N/S Runway Extension Site Investigation UFP-QAPP" dated March 2021 and provided comments to the U.S. Air Force via email. The intent of the investigation is to characterize the nature and extent of soil contamination within the footprint of a proposed runway extension. |
Melinda Brunner |
| 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 |
| 5/28/2021 |
Document, Report, or Work plan Review - other |
DEC Approved of Final LTM and LUC Inspection Work Plan for select CERCLA sites dated May 2021. |
William Schmaltz |
| 7/7/2021 |
Offsite Soil or Groundwater Disposal Approved |
Approved of the transport and disposal of 9 gallons of IDW water generated during decontamination of soil boring equipment. PFOS, DRO, and RRO exceeded PSLs in the IDW water. Approval for disposal at NRC Alaska, LLC in Anchorage, Alaska. |
William Schmaltz |
| 7/29/2021 |
Document, Report, or Work plan Review - other |
DEC reviewed Draft Chemical Data Report JBE054 N/S Runway Extension Site Investigation Joint Base Elmendorf-Richardson, Alaska, June 2021. Report described soil investigation activities to determine the nature and extent of soil contamination in an area that could be impacted by a proposed runway extension project. PFAS, DRO, RRO, VOCs, and PAHs exceeding DEC cleanup levels in numerous soil borings. DEC comments included recommendations for additional soil borings to determine extent of soil contamination. |
William Schmaltz |
| 8/9/2021 |
Document, Report, or Work plan Review - other |
DEC staff reviewed and provided comments on Draft 2020 Land Use Control report for Select CERCLA sites dated June 2021. Report summarized LUC inspections performed in December 2020. Most sites were covered in snow and a full inspection could not be performed until spring 2021. DEC requested that the spring 2021 inspections are included in the 2020 report or as a separate cover because they are a continuation of the 2020 inspections and separate of the 2021 inspections. |
William Schmaltz |
| 10/4/2021 |
Document, Report, or Work plan Review - other |
DEC Approved QAPP summarizing additional step out boring locations for JBE054 N-S Runway extension project. |
William Schmaltz |
| 10/14/2021 |
Document, Report, or Work plan Review - other |
DEC provided comments on field extension summary report. Report sumamrized boring locations and results for investigations of in-situ soil to be removed during the N-S Runways extension project. |
William Schmaltz |
| 2/16/2023 |
Document, Report, or Work plan Review - other |
DEC reviewed and provided comments regarding 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 |
| 4/20/2023 |
Document, Report, or Work plan Review - other |
DEC reviewed and provided comments for the 2021 Annual Remedial Action-Operations and Long-Term Management Report for Select CERCLA Sites, Draft, dated December 2023. 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 and sampling were recommended to continue for all applicable sites to ensure that conditions remain protective of human health and the environment. |
Ginna Quesada |
| 5/8/2023 |
Update or Other Action |
DEC reviewed QAPP for contaminated soils that will be removed during the N/S Runways Extension project during the 2023 construction season. PFAS soils will be stockpiled on site in accordance with 18 AAC 75.370 until appropriate disposal is approved. All other soils will be stockpiled in accordance with 18 AAC 75.370 and disposed of off-site at the appropriate and approved facility. |
William Schmaltz |
| 1/29/2024 |
Document, Report, or Work plan Review - other |
DEC reviewed the 2022 Annual Remedial Action-Operations and Long-Term Management Report for Select CERCLA Sites, Draft, dated October 2023. 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 and sampling were recommended to continue for all applicable sites to ensure that conditions remain protective of human health and the environment. |
Ginna Quesada |
| 6/27/2024 |
Document, Report, or Work plan Review - other |
DEC approved the Final Leachability Model Work Plan for the JBER Runway Extension Project Environmental Services to Model the Leachability of PFAS Impacted Soil at JBER, Alaska, dated June 2024. The work plan describes the modeling procedures that will be used for the proposed soil leachability study to obtain alternative site-specific soil screening levels for ex-situ soil contaminated with per and polyfluoroalkyl substances (PFAS). The ex-situ PFAS contaminated soil was excavated from the Runway 16/34 expansion project and placed on a liner adjacent to FT023 (located in Operable Unit 4) on Elmendorf at the Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. |
Ginna Quesada |
| 7/2/2024 |
Document, Report, or Work plan Review - other |
DEC approved the 2022 Annual Remedial Action-Operations and Long-Term Management Report for Select CERCLA 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 and sampling were recommended to continue for all applicable sites to ensure that conditions remain protective of human health and the environment. |
Ginna Quesada |
| 7/9/2024 |
Document, Report, or Work plan Review - other |
DEC provided comments for the FT023 – Fire Training Area Supplemental Remedial Investigation Management Plan Draft, dated June 2024. The work plan describes the investigation procedures to identify the source area and characterize the extent of contamination at the Fire Training Area FT023 located at the Joint Base Elmendorf- Richardson (JBER), in Anchorage, Alaska. The plan proposes the collection of soil gas, soil, and groundwater samples. Soil samples will be analyzed for the analysis of gasoline range organics (GRO), diesel range organics (DRO), residual range organics (RRO), volatile organic compounds (VOCs), and polycyclic aromatic hydrocarbons (PAHs). Groundwater samples will be analyzed for GRO, RRO, DRO, VOCs, alkalinity, anions, nitrate/nitrite, and dissolved gases. The screening levels for the investigation will be EPA Regional Screening Levels (RSLs) for residential soil and tapwater (target risk = 1×10-6, HQ = 0). In cases without an EPA RSL, one-tenth of the ADEC Method Two Table B1 Under 40-Inch Zone soil cleanup levels for human health or one-tenth the Table C groundwater cleanup level will be used. |
Ginna Quesada |
| 8/9/2024 |
Document, Report, or Work plan Review - other |
DEC provided responses to comments for the FT023 – Fire Training Area Supplemental Remedial Investigation Management Plan Draft Final, dated August 2024. |
Ginna Quesada |
| 9/6/2024 |
Document, Report, or Work plan Review - other |
DEC approved the FT023 – Fire Training Area Supplemental Remedial Investigation Management Plan Final, dated September 2024. The work plan describes the investigation procedures to identify the source area and characterize the extent of contamination at the Fire Training Area FT023 located at the Joint Base Elmendorf- Richardson (JBER), in Anchorage, Alaska. The plan proposes the collection of soil gas, soil, and groundwater samples. Soil samples will be analyzed for the analysis of gasoline range organics (GRO), diesel range organics (DRO), residual range organics (RRO), volatile organic compounds (VOCs), and polycyclic aromatic hydrocarbons (PAHs). Groundwater samples will be analyzed for GRO, RRO, DRO, VOCs, alkalinity, anions, nitrate/nitrite, and dissolved gases. The screening levels for the investigation will be EPA Regional Screening Levels (RSLs) for residential soil and tapwater (target risk = 1×10-6, HQ = 0). In cases without an EPA RSL, one-tenth of the ADEC Method Two Table B1 Under 40-Inch Zone soil cleanup levels for human health or one-tenth the Table C groundwater cleanup level will be used. |
Ginna Quesada |
| 11/12/2024 |
Document, Report, or Work plan Review - other |
DEC approved the 2023 Annual Remedial Action-Operations and Long-Term Management Report for Select CERCLA Sites, Final, dated October 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 and sampling were recommended to continue for all applicable sites to ensure that conditions remain protective of human health and the environment. |
Ginna Quesada |
| 3/17/2025 |
Exposure Tracking Model Ranking |
A new updated ranking with ETM has been completed for source area 72776 Surface release. |
Ginna Quesada |
