| Action Date |
Action |
Description |
DEC Staff |
| 1/25/1988 |
Update or Other Action |
USEPA Assistant Administrator J. Winston Porter (OSWER) Memorandum for the record to Regional Administrators I-X Subj: Enforcement Actions under RCRA and CERCLA at Federal Facilities. Statutory language makes it clear that Federal facilities must comply both procedurally and substantively with RCRA and CERCLA in the same manner as any non-Federal entity. The purpose of this memo is to lay out the statutory authorities under RCRA and CERCLA that EPA may use at Federal facilities to achieve compliance and expeditious cleanup.
EPA (The Agency) is viewing the Section 120 Interagency agreement as a comprehensive document to address hazardous substance response activities at a Federal facility from the remedial investigation/ feasibility study (RI/FS) through the implementation of the remedial action. All such interagency agreements must comply with the public participation requirements of Section 117. The timetables and deadlines associated with the RI/FS and all terms and conditions associated with the remedial actions (including operable units or interim actions) are enforceable by citizens and the States through the citizen suit provisions of Section 310 of CERCLA. In addition, Section 122(1) of CERCLA authorizes the imposition of civil penalties against Federal agencies for failure to comply with interagency agreements under Section 120. Procedures for imposing these penalties are provided for in Section 109 of CERCLA.
Executive Order 12580 clarifies that EPA is authorized to issue Section 104 and Section 106 administrative orders to other Federal agencies, with the concurrence of the Department of Justice. Section 4(e) of the Executive Order provides that: Notwithstanding any other provision of this Order, the authority under Section 104(e)(5)(A) and Section 106(a) of the Act to seek information, entry, inspection, samples or response action from Executive Departments and agencies may be exercised only with the concurrence of the Attorney General.
States also have a variety of enforcement authorities under CERCLA, so the exercise of EPA's enforcement authorities should be closely coordinated with the States.
First, Section 121(e) (2) of CERCLA authorizes States to enforce ANY Federal or state standard, requirement, criteria or limitation to which the remedial action must conform under CERCLA.
Second, Section 310 authorizes citizen suits to require Federal agencies to comply with the standards, regulations, conditions, requirements, or orders which have become effective pursuant to CERCLA including IAGs under Section 120 of the Act.
Third, Section 120(a)(4) clarifies that State laws concerning removal and remedial action, including State laws regarding enforcement, are applicable at Federal facilities not included on the NP. In addition, Section 120(i) states that nothing in CERCLA Section 120 shall affect or impair the obligation of the Federal agency to comply with the requirements of RCRA, including corrective action requirements (see section IV.C., "Importance of the States as a Party to the IAG"). EPA enforcement actions against Federal agencies should therefore be carefully coordinated with States to avoid potentially duplicative or conflicting exercises of authority.
All RCRA Subtitle C permits issued after November 8, 1984, will contain provisions for implementing the corrective action requirements of 40 CFR Part 264 Subpart F (or authorized state requirements), and Section 3004(u) and (v) of RCRA. For facilities that have or are seeking a RCRA permit, the requirements for a "CERCLA" remedial investigation and cleanup could be met by implementing these requirements through RCRA corrective action. It is important to keep in mind, however, that the extent of coverage of the RCRA permit is generally limited to hazardous wastes/constituents (e.g., some CERCLA hazardous substances such as radionuclides are not RCRA hazardous constituents and, therefore, the permit may not be able to address all of the releases at a facility).
The corrective action authority under Section 3008(h) of RCRA can be used at RCRA interim status facilities to address releases from RCRA regulated units and other solid waste management units. At a Federal facility that has interim status, a RCRA corrective action order could address the investigation and clean-up of releases in. lieu of a "CERCLA" response action or as an interim measure. Again, the extent of coverage in the RCRA corrective action order is limited to RCRA hazardous wastes/constituents.)
CERCLA Section 106 can be used to address releases from RCRA units or CERCLA sites when an "imminent and substantial endangerment" is shown. A Section 120 IAG could be drafted to incorporate all RCRA corrective action requirements and CERCLA statutory requirements. Where some or all of a Federal installation has been listed on the NPL, the CERCLA Section 120 IAG is required for remedial action by statute. |
Louis Howard |
| 4/18/1988 |
Update or Other Action |
AF (AAC) FY 1988 Military Construction Project Data
Knik Bluff Landfill
Field Survey limits of Exposed Landfill
Remove Exposed Fill Material
Install Seawall
Place Clean Fill (4' depth)
Description of Proposed Remedial Action
The scope of the restoration work includes the following major elements: field survey the limits of the exposed landfill cell face, install approximately 3,000 LF of concrete retaining wall, dragline 65° exposed slope face to new 350-45°, transport removed materials to active base
sanitary landfill, place 4 ft depth of new clean fill materials, and seed disturbed areas with grass/willow mixture.
Requirement
Project:Cover a WW II era landfill with clean fill material after removal of uncovered debris and exposed slope stabilization. Disturbed area to be revegetated to prevent future erosion problems.
REQUIREMENT: To close a 40 year old landfill cell site before further erosion uncovers additional fill material. Exposed landfill debris is currently sliding down the bluff slopes and into the water of the Knik Arm.
CURRENT SITUATION: The landfill cell operated during 1940-45 as an open dump down the steep slope of the Knik Arm Bluff just west of the 05 runway. The landfill cell was either not covered or improperly covered when closed as substantial erosion has occured since 1945. Much of the 65° slope seaward face of the fill is exposed to view from the City of Anchorage, revealing large quantities of wood and metal scraps, glass, car bodies, engine blocks, wallboard materials, and other trash items.
Landfill debris is scattered throughout the Knik Arm Bluff and along the adjoining beach for approximately one mile. The exposed landfill is giving up its material to the beach area which is causing tidal action to take the material into the Knik Arm.
IMPACT IF NOT PROVIDED: Erosion will further expose landfill material, and subsequent materials exposed will slide down into the Knik Arm. As the area is within public view it is probable that increase state involvement at this area is forthcoming. Although no known contamination
has been identified at this site, adverse publicity based on visual appearances is likely.
ADDITIONAL: This is an RA IRP (old Phase IVB project, Priority IC). The proposed actions will close all known requirements for completion of IRP site D-4.
Signed Terese D. LeFrancois, GS-12 DAF AAC DERA Program Manager. |
Louis Howard |
| 8/1/1988 |
Update or Other Action |
RCRA Facility Assessment Report: Preliminary Review and Visual Site Inspection ID # AK8570028649 by ADEC August 1988. The VSI, conducted on July 19 - 20, 1988, consisted of
collecting additional facility information and obtaining visual evidence/information of releases. Interviews were conducted with various EAFB representatives to obtain site-wide SWMU
information. EAFB's Environmental Coordinator is Mr. Mike Drewett.
Site D-4, Bluff Landfill
a. Location: This site is located east of Knik Arm on the west side of the base on the bluff, approximately two acres in size.
b. Operation: This site was operated from 1945 to 1957, it was used for disposal of old cars, construction rubble and small quantities of general refuse. The materials were dumped over the hill toward Knik Arm, and in 1983, some debris was still evident. An investigation conducted by EAFB revealed concrete debris mixed with metallic debris and old 55-gallon drums. Exposed landfill debris including large quantities of wood and metal scraps, glass, car bodies, engine blocks, wallboard materials and other trash items, is currently drifting down the slopes of the bluff and onto the beach. Tidal action is causing this material to move out into the Knik Arm. Depth of disposal area unknown.
c. Contamination Potential: Unknown, further study is warranted due to the presence of the unknown drums at this site.
d. Recommended Action: Types of materials present, if any, in the 55-gallon drums must be determined, this will be addressed in the RFI Workplan. If hazardous constituents are present, these drums should be removed, to prevent further harm. If no hazardous wastes are present, this area should be addressed under the solid waste disposal authority.
Summary
Each site has been evaluated for recommended action; the sites which require further investigation are described in the categories below.
GROUP 1
Those sites which are high priority and will be addressed initially in the RFI Workplan, also to include those sites which will be involved in the investigation of Ship Creek; they are as
follows: D-3, D-4, SP-7, SP-10, IS-2 through -8, NS-1, NS-3, OT-1, and FT-1
Ship Creek investigation sites:
SP-2, SP-4, SP-ll, SP-12, and SP-14. |
Max Schwenne |
| 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 |
| 12/30/1991 |
Update or Other Action |
EPA sent letter to 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 |
| 10/4/1993 |
Update or Other Action |
Conceptual site model received. LF04 was used as a surface dump from 1945 to 1957. Data gaps identified are spelled out. Contamination encountered during the Phase II RI field investigation indicating the presence of petroleum contamination (boring K303) in the vicinity of the ocean dock fuel lines was not sampled or investigated. Physical or chemical (clean) boundaries of the landfill have not been established. Horizontal and vertical extent of contamination along the beach has not been identified. Source of PCBs detected in the groundwater remains unknown. Soil and groundwater have not been sampled adequately for risk characterization purposes. |
Jennifer Roberts |
| 4/1/1994 |
Site Added to Database |
Surface dump. |
Louis Howard |
| 6/16/1995 |
Site Ranked Using the AHRM |
Initial ranking. Action code added because it wasn't when the site was originally ranked. |
Louis Howard |
| 11/8/1995 |
Meeting or Teleconference Held |
Restoration advisory board meeting held to discuss: Elmendorf Air Force Base’s Community Relations Plan and Management Action Plan, discussion of Elmendorf Air Force Base’s Natural Resource Management Program. |
Ray Burger |
| 12/22/1995 |
Meeting or Teleconference Held |
The purpose of this confirmation notice is to convey the significant decisions reached and pertinent issues discussed during the above referenced meeting. The meeting was held to address final questions regarding the selection of the preferred alternatives for OU 6.
LFO4
The USAF is conducting annual testing of the base POL lines. This will be included in the OU 6 ROD, but will not be part of the alternatives as they are defined in the RI/FS.
Other Solid Waste Issues-It was noted that it is a strong Air Force desire to identify any solid waste issues at OU 6 now, and address them under CERCLA, rather than having them surface later as compliance issues. The objective is to include language or the required actions in the OU 6 Record of Decision which will ensure that the three landfills at OU 6 are compliant with State solid waste regulations. It was agreed that solid waste issues are best addressed under CERCLA, where the money is currently available to take any required actions.
ADEC noted that in order to comply, the Air Force must prove the landfills are not leaching. The issue of a future cover for LF02 or LF04 was addressed, and it was agreed that the existing vegetative cover at these two landfills (as well as the existing soil cover at LF03) may be adequate to comply with State regulations, provided the surface debris at the landfill is removed, and it is confirmed that the landfill leachate is not impacting groundwater.
ADEC noted that what remained to achieve closure was the performance of groundwater quality sampling for the parameters listed in the solid waste regulations (a list of parameters was circulated from 18 AAC 60.310). Four rounds of sampling for these parameters are required by the State (in each of the four seasons), to show that a landfill is not leaching. After reviewing the list of parameters, it was noted that most (but not all) of the parameters had already been tested for in the previous rounds of analytical sampling of OU 6 wells.
It was agreed that the first two rounds of groundwater sampling at LF02, LF03, and LF04 would be sufficient to serve as the first two of four required rounds of State water quality sampling. These two rounds, conducted in mid-1994, would address the summer and fall sampling requirements. It was also agreed that the next two rounds would need to include the full suite of analytical parameters as listed in the regulations. These two rounds would need to be collected in winter and spring. It was agreed that the sampling should be conducted as soon as possible (January and March of 1996) to verify compliance with State solid waste regulations before the OU 6 Public Meeting was held or the ROD prepared.
It was agreed that if landfill leachate is not impacting groundwater, if the debris was addressed, and if the cover was proven to be adequate, then the landfills would be in compliance, and no changes to address further State landfill issues would be required in the ROD (or other future documents). ADEC noted that in the Draft Final RI/FS, indicator parameter data was missing from some of the LF02 wells. Radian will address this issue. Radian will prepare a list of wells and analytical methods, including maps, which will be sampled in early 1996 to address the remaining State requirements. There is no specified criteria for spacing between wells downgradient of the landfills. |
Ray Burger |
| 1/2/1996 |
Risk Assessment Report Approved |
Risk assessment is incorporated as part of the Remedial Investigation/Feasibility Study report final version received and approved. Soils at both the beach and the bluff exceeded the 1.0 x 10-6 carcinogenic risk and the 1.0 noncarcinogenic HI for the future residential RME exposure scenario. Species contributing a risk greater than 1.0 x 10-6 include: arsenic, and three dioxin/furans for the beach, and arsenic, DDT and HpCDD for the bluff. The noncarcinogenic threshold exceedance at both the beach and bluff (2.9 and 3.9 respectively) are primarily due to manganese (with HIs of 2.5 and 3.4 respectively). The residential RME exposure scenario is not only highly conservative, but also highly unlikely at Source LF04 because of the rugged topography and slope instability on the LF04 bluff. For the more realistic visitor scenario, the carcinogenic risk due to exposure to soil equals 1.1 x 10-6 and 1.8 x 10-6 for the beach and bluff, respectively, and is largely due to arsenic (bluff beach) and HxCdd (beach only).
For the residential RME scenario, groundwater in the LF04 bluff aquifer has a carcinogenic risk of 2.6 x 10-6, almost entirely due to benzene (2.5 x 10-6). The noncarcinogenic HI for groundwater equals 4.1, with the highest contributions coming from 1,2-dichloroethane (2.0) and toluene (1.1). The residential RME scenario is considered to be very unrealistic for source LF04 due to the site layout and physiography. The more realistic visitor scenario was evaluated for the groundwater seeps at LF04 bluff. The total risk associated with exposure to contaminated seep water under this scenario equals 1.5 x 10-7. For the residential RME scenario, groundwater in aquifer 3 has a carcinogenic risk of 1.7 x 10-5, mainly due to 1,1,2,2-tetrachloroethane, benzene and dieldrin. The noncarcinogenic HI is less than 1.0. The carcinogenic risk in aquifer 2 equals 1.5 x 10-3 with the vast majority being contributed by benzene (1.4 x 10-3) and the rest being associated with pesticides and chlorinated VOCs. The noncarcinogenic HI equals 2.5 with the majority (1.2) being contributed by 1,2-dichloroethane. Again, the residential scenario for Source LF04 is very unrealistic.
Ecological risk: EQs exceeded 1.0 for lead, copper, zinc, for the spotted sandpiper (beach only), meadow vole, masked shrew, and black-capped chickadee (beach and bluff). Several pesticides and SVOCs had ecological quotients greater than 1.0 for the spotted sandpiper (beach only), masked shrew and black-capped chickadee (beach and bluff). Overall the most affected indicator species was the spotted sandpiper. The highest EQ at LF04 was associated with lead for the black-capped chickadee, and equaled 24,000 for the LF04 beach.
*NOTE soil contamination detected in the bluff above Alaska cleanup matrix (ACM) levels is either associated with "smear zone" (The smear zone is defined as the range of depths within which the groundwater will fluctuate under normal seasonal conditions, and therefore, in which free product would move and “smear” the soil in response to these seasonal changes in the water level elevation. The smear zone soils may therefore be saturated or unsaturated with groundwater at any given time.) contamination or will be addressed under the Elmendorf AFB underground storage tank program. |
Jennifer Roberts |
| 1/2/1996 |
CERCLA RI Report Approved |
Remedial investigation/feasibility study final version received & approved. Three rather distinct perched aquifers were identified underlying LF04: Aquifer 1 (shallow aquifer), Aquifer 2 (deeper aquifer), & a third aquifer, Aquifer 3, is present at near sea level at the base of the LF04 bluff.
State of Alaaka Cleanup Level for Non-UST soil. ElmendorfOU 6 site. have been ranked as: LF02, LFO3, LF04, WP14, & SD73- Level B; & SDI5 - Level C.
NOTE TO FILE:
Contaminants of Concern
The list of contaminants of concern (COCs) differs from the list of contaminants of potential concern (COPCs) and contaminants of potential ecological concern (COPECs). The COPCs and COPECs are the chemicals which were detected at the site and included in the calculations of the human-health and ecological risk assessments. As documented in the risk assessment, the COPCs and COPECs represent differing levels of health and ecological risks within each media at OU 6.
Many of these chemicals do not pose an appreciable risk and/or do not exceed any PRG, e.g., maximum contaminant levels (MCLs). These chemicals do not warrant remediation and hence are not designated as COCs.
RBCs
Unacceptable human-health risks are defined as those chemicals posing a carcinogenic risk greater than 1E-06 for an exposure scenario exceeding 1E-04; or, those chemicals posing a HI > 1.0. So as not to exclude any possible risk-drivers, these determinations will be initially based on a residential, reasonable maximum exposure (RME) scenario, i.e., hypothetical future residential land use scenario.
Ecological risks are qualitatively evaluated. Chemicals having calculated significant risks do not necessarily require study for remediation. The additional considerations discussed in this section may indicate that study for remediation is unwarranted. Comparisons of observed concentrations to risk-based preliminary remediation goals (PRGs) are also made as part of this evaluation.
ARAR-based Considerations
To evaluate ARAR-based considerations, comparisons were made to maximum contaminant levels (MCLs) & the State of Alaska guidance on non-UST cleanup matrix. This Alaskan guidance is to-be-considered (TBC) information.
Other Considerations
Thus far, risk-based & regulatory considerations have been evaluated. However, before making final determinations of what chemicals require remediation to protect human health & the environment, it is important that other factors be considered such as land use, sufficiency of data to make remedial decisions, & the ubiquitous nature of some chemicals.
Slight Exceedances of MCLs.
In some cases, a single sample slightly exceeded a MCL. One example is the single detection of benzene in aquifer 3 at LF04. The detected amount was 5.8 ug/L, just 0.8 ug/L greater than the MCL. Exceedances of this magnitude are not considered reproducible, given the natural variances
in sample collection & analysis. Developing remedial strategies for contamination that cannot
be consistently detected is not considered justified.
Remediation of metals in groundwater based on turbid samples.
In general, there were very few metals which exceeded any MCLs. Most exceedances were slight, making the appropriateness of developing remediation strategies questionable (see above). Another reason for not remediating metals in groundwater (in addition to the fact that exceedances were generally marginal), is that the data compared to MCLs were from unfiltered turbid samples. Turbid samples can yield inflated concentrations of naturally occurring analytes, such as metals. Therefore, these slight exceedances are believed to be more the result of the well construction & geologic formations, than an indication of groundwater contaminated by human activities.
Background Levels of Arsenic & Manganese.
As discussed in Sections 3 through 8, detections of arsenic & manganese in soils are thought to be comparable to background levels. Background levels of metals at Elmendorf have historically been high, as well as spatially variable. As indicated for site SD73 (section 7.6.4), arsenic results were above background UTLs for analytical results associated with the Environmental Baseline Assessment (EBA), but were virtually indistinguishable from background UTLs in the 1994 data set. Because of this variability & history of metals background data at Elmendorf AFB, arsenic & manganese levels are believed to be comparable to background.
Smear Zone Soils.
Smear zone soils are the soils associated with a fluctuating ground water table. COCs in smear zone soils will be addressed as a groundwater remediation issue, & hence will be categorized as groundwater COCs. |
Jennifer Roberts |
| 1/2/1996 |
Update or Other Action |
Remedial investigation for LF04 soil samples confirmed the presence of hydrocarbon contamination in the area surrounding the pumphouse in the southern portion. Soil samples were not collected from locations of SG-22 and SG-35 soil gas sampling points. Organic contamination at LF04 consists of fuels, semi-volatile organic compounds (SVOCs), pesticides, dioxins, and furans. Fuels were detected primarily in the southern portion with free phase hydrocarbons may be present at 10-30 feet below ground surface when MW-63 was installed. 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.
However, a sample taken at the water table 40.5 to 41 feet below ground surface suggest no free phase contamination is present (at least not down to the water table). The highest SVOC concentrations were found in SS-046 on the beach and SS-013 on the bluff. Surface soils from these two locations also contain elevated levels of dioxins, furans, and metals. Soils from SS-013 also contained PCBs. 4,4-DDT is the primary pesticide at LF04 and the primary breakdown products 4, 4-DDE and 4,4-DDD are also widespread at the source area but at lower levels than the parent compound. The pesticide dieldrin was detected in 19 of 53 beach and bluff surface soil samples. Dieldrin's maximum level was 143 ug/kg in sample SS-001 where the highest 4,4-DDT was also detected.
PCBs were also detected in two surface soil sampling locations. SS-013 at the base of the bluff contained 3.120 mg/kg PCB-1254 and PCB-1260 at SS040 at a level of 0.318 mg/kg. PCBs were not detected in subsurface soils, however, no subsurface soils were sampled in the northern portion of LF04 including SS-013. Soil from SS-013 also contained the highest dioxin and furan species detected at LF04. The most abundant congener in the surface soil from SS-013 is octachlorodibenzo-dioxin (OCDD) at 79.9 ug/kg. Location SS-021 is the only other bluff slope location where dioxins were detected (1.68 ug/kg OCDD). It is suspected that the dioxins and furans were derived from the incomplete combustion of pesticides, chlorinated oils, plastics, or other materials combusted in the presence of chlorine.
The highest concentration of BTEX in groundwater was within a broad plume in the southern end of LF04 (SB62) at 17,690 ug/L with 990 ug/L benzene. In general, the wells with the highest chlorinated solvents are the bluff wells at which the highest BTEX levels were detected. Five pesticides (aldrin, alpha-BHC, beta-BHC, dieldrin, heptachlor and heptachlor epoxide) were detected in the groundwater above toxicity screening RBCs. Highest pesticide concentration detected at LF04 was 0.088 ug/L beta-BHC during round 1 (aquifer 1-2 mixing zone) well MW-78.
See site file for additional information. |
Jennifer Roberts |
| 4/2/1996 |
CERCLA Proposed Plan |
Final Proposed plan received. LF04 was divided into the landfill area called LF04 South, & the north part of the landfill & the entire beach area called LF04 North Beach. GW contaminant levels for fuel constituents, metals, solvents were above MCLs. Contaminants of concern: benzene 3,400 ug/L, (5 ug/L), 1,2-dichloroethane 32.6 ug/L (5 ug/L), ethylbenzene 722 ug/L (700 ug/L), methylene chloride 6.53 ug/L (5 ug/L), toluene 3,020 ug/L (1,000 ug/L), bis(2-ethylhexyl)phthalate 24.2 ug/L (6 ug/L), cadmium 62.8 ug/L (5 ug/L) & selenium 91.1 ug/L (50 ug/L).
Soil was also contaminated above action levels found in the Alaska cleanup matrix. DRO shallow soil: 2,910 mg/kg (200 mg/kg), deep soil: 0.694 mg/kg (0.5 mg/kg), BTEX 100 mg/kg (15 mg/kg), & GRO 5,980 mg/kg (100 mg/kg).
As indicated above, the Air Force has concluded that the groundwater &/or soil at some of the OU6 source areas do not require cleanup. This conclusion was reached only if one of the following two criteria were met:
1) the level of contaminants was within the state cleanup levels or federal drinking water standards,or
2) the risk associated with coming into contact with the soil or groundwater was within established health guidelines.
Source Area LF04 South/WP14
Groundwater
Long-term Monitoring with ICs & Oily Contaminant Removal is the preferred alternative for the groundwater at LF04 South! WP14 ICs will prohibit the use of the contaminated aquifer as a water supply, & annual monitoring will be conducted to track the progress of contaminant degradation & dispersion, as well as to provide an early indication of unforeseen environmental or human health risk. This monitoring will be protective of Knik Arm because it will monitor the quality of the groundwater being discharged into it from these areas.
Five-year reviews of contaminant levels will provide an additional safety net for human health & the environment. With this alternative, any detected amounts of oily contaminants on the groundwater will be regularly removed. This alternative is the only practical alternative in terms of implementability, due to the size & instability of the bluff, & it meets all of the other requirements. Furthermore, because the current & likely future use of groundwater at this site is not for drinking, & because contaminants in the groundwater are expected to decrease below regulatory levels within the next 30 years without active treatment, the cost-effective alternative is LTM & ICs to ensure that the groundwater is not used for drinking water.
Soil
To support the implementation of LTM with ICs & oily contaminant removal at LF04 SouthlWP14, active treatment of the contaminated soils at WP14 will be conducted to prevent the possible movement of any of the soil contaminants into the groundwater in the future. Soil Alternative 4, Excavation, Low Thermal Treatment, Backfilling, & Bioventing, is preferred.
Shallow soils containing unwanted fuel-type contaminants will be excavated & treated. At WP14, a soil action is necessary to prevent direct contact with contaminants, & to remove the contaminants before they can reach the groundwater. This will help restore the affected groundwater in a reasonable time frame. This process is the most rapid & cost-effective technology available, & as an active treatment, will prevent the movement of the shallow soil contaminants into the groundwater. Deep soils, also containing fuel & fuel by-product contaminants will be cleaned by bioventing. This combined alternative for soils is the most protective to humans & animals, among the most easily implemented. & a permanent means of removing the contaminants from this source area.
Removal of Surface Debris was recommended as the preferred alternative for the LF04 North Beach soils (Soil Alternative 6). At LF04 North Beach, a variety of other alternatives were considered to address the exposed landfill material on the beach, such all capping or stabilization. However, due to the instability of the bluff slope, the overall size of the landfill area, & the fact that tidal action will continually cause slope erosion, slope capping & stabilization were considered impracticable.
Annual removal of the landfill debris was considered reasonable, since it would prevent the accumulation of excessive debris on the beach & would reduce the chances of contact between the debris & humans or animals. This limited action is considered acceptable since the risks at the beach were low & the contaminants found were at low levels. Any hazardous contaminants from the landfill which might be encountered on the beach will be handled appropriately. |
Louis Howard |
| 8/27/1996 |
Document, Report, or Work plan Review - other |
ADEC letter to USAF RE: OU 6 Draft ROD July 1996. GENERAL COMMENTS - In all of the discussions of Contaminants of Concern (COCs) the statement is made that some contaminants were not included as contaminants of concern (COCs) because: "(1) their presence was determined to be anomalous, or in the case of groundwater, solely related to smear zone contamination". The second half of this is confusing. It appears to refer to soil contamination found in the smear zone that is to be treated as part of the groundwater remediation. Please clarify.
The cleanup goals stated in the Record of Decision for soil contaminants are different from the cleanup goals stated in the Proposed Plan. Changes in cleanup goals need to be justified and agreed upon by all three parties. Changes between the proposed plan and the ROD need to be adequately described in the ROD.
In the tables summarizing soil analytical results for each section, the "ACM" for toluene, ethylbenzene and xylene are all individually listed as 50 mg/kg. These should be footnoted to indicate that this is a total BTEX level.
Section 3.3.3. Contaminants of Concern: In the last paragraph's discussion of the separation of the LF04 South bluff area, there should be an acknowledgment of the fact that accessible debris on the bluff face will be treated the same as the LF04 North/Beach area.
Section 3.4.5. Summary of Comparative Analysis of Soil Alternatives: Following the statement that the capping and excavation of the landfill are impracticable, the reasons should be explained as in the Proposed Plan.
Section 3.5. Selected Remedy for LF04: In the soil remedy the statement is made that, "No further action will be required as a means of closing the LF04 landfill." It should be stated here that this evaluation is based on current conditions and if there is a significant change (such as massive land slides or discovery of previously unknown contamination) the remedy may be reevaluated. Also, land use restrictions consistent with other landfills on Elmendorf AFB should be implemented here. Alaska Solid Waste Management Regulations (18 AAC 60) should be mentioned as an actionspecific ARAR. This comment applies to LF02 and LF03 also.
To avoid confusion over land use restrictions, like what arose over LF01 in OU 1, the ROD should clearly describe land use restrictions that will be applied consistent with the real estate section's land use categories.
Section 5.3.1. Soil Contamination at LF02: The text states a maximum lead concentration of 6010 mg/kg in surface soils, while Table 5.3-2 shows a maximum of 6080 mg/kg. Also, in the last
paragraph the discussion of subsurface soils should point out the elevated lead levels. |
Ray Burger |
| 12/11/1996 |
Long Term Monitoring Established |
Remedial action started which includes long-term monitoring of the groundwater at Operable Unit 6 source areas. |
Louis Howard |
| 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 |
| 1/27/1997 |
Cleanup Level(s) Approved |
Groundwater contamination from WP14 represents an upgradient source for the groundwater contamination at LF04. The combined plume from WPl4 and LF04 is estimated to contain 45.5 million gallons of fuel contaminated groundwater. Contaminants of Concern (COCs): benzene 5 ug/L (Maximum contamination 3,400 ug/L), ethylbenzene 700 ug/L (722 ug/L), toluene 1000 ug/L (3020 ug/L), 1,2-Dichloroethane 5 ug/L (32.6 ug/L) and methylene chloride 5 ug/L (6.53 ug/L). Soil: no exposed landfill waste (see NOTES below regarding soil cleanup levels exceeded bu not captured in ROD).
Note Table 3.3-2 Summary of GW Analytical Results for Beach Area at LF04 lists other contaminants not captured in the ROD but exceed 2012 18 AAC 75 CS regulatory levels. GRO-9,700 ug/L (2,200 ug/L). Seeps: GRO-9,480 ug/L, DRO-3,860 ug/L (1,500 ug/L).
During the final round of monitoring, samples will be collected and analyzed for ALL constituents that exceeded MCLs during the 1994 investigation including VOCs, SVOCs, and metals. These results will be evaluated before a final determination is made that groundwater meets all cleanup requirements.
NOTE TO FILE: MCL Exceedances from the RI Table 10 Appendix S
Benzene 3,400 ug/L (5 ug/L)
bis(ethylhexyl)phthalate 24.2 (6 ug/L)
GRO 9.15 mg/L (2.2 mg/L) DRO 3.86 mg/L (1.5 mg/L)
*Most stringent soil cleanup level applies in soil since groundwater is contaminated.
Surface Soil exceedances: gamma-Hexachlorocyclohexane (Lindane) 31.3 ug/kg (P) (9.5 ug/kg), 4,4-DDD 8,410 ug/kg (7200 ug/kg), DDT 47,300 ug/kg (7,300 ug/kg), Heptachlor epoxide: 23 ug/kg (14 ug/kg), PCB 3120 ug/kg (1000 ug/kg), TCDD (dioxin) totals: 1.1 ug/kg (0.047 ug/kg), cadmium 6.96 mg/kg (5 mg/kg), chromium 71.3 mg/kg (25 mg/kg), Selenium 11 mg/kg (3.4 mg/kg), thallium 8.75 mg/kg (1.9 mg/kg), arsenic 56.5 mg/kg (3.9 mg/kg), and lead 1,160 mg/kg (400 mg/kg residential 800 mg/kg commercial/industrial).
Subsurface Soil exceedances: Ethylbenzene-32,800 ug/kg (6,900 ug/kg), GRO 5,880,000 ug/kg (300,000 ug/kg), toluene 14,000 ug/kg (6,500 ug/kg), xylenes 65,900 ug/kg (63,000 ug/kg These levels are based on soil saturation level (Csat) using the equations set out in
Cleanup Levels Guidance, adopted by reference in 18 AAC 75.340. Refer to the Cumulative
Risk Guidance, adopted by reference in 18 AAC 75.325(g), for inhalation risk screening levels.) |
Jennifer Roberts |
| 1/27/1997 |
Record of Decision |
ROD states for GW at LF04 "North beach" NFA required, LF04 "South beach" ICs and designated as a "restricted use area" in the Base Comprehensive Plan (BCP). This designation provides for recreational use of the parcel (cross country skiing, etc.). The duration of the soil remedy is indefinite. The cost estimate includes 30 years of annual beach sweeps, per CERCLA guidance.
Access to the soil at LF04 North Beach will be institutionally controlled.
NOTE TO FILE: § 300.430 Remedial investigation/feasibility study and selection of remedy.(a) General—(1) Introduction. The purpose of the remedy selection process is to implement remedies that eliminate, reduce, or control risks to human health and the environment. Remedial actions are to be implemented as soon as site data and information make it possible to do so.
Accordingly, EPA has established the following program goal, expectations, and program management principles to assist in the identification and implementation of appropriate remedial actions.
(iii) Expectations. EPA generally shall consider the following expectations in developing appropriate remedial alternatives:
(D) EPA expects to use institutional controls such as water use and deed restrictions to supplement engineering controls as appropriate for short- and long-term management to prevent or limit exposure to hazardous substances, pollutants, or contaminants. Institutional controls may be used during the conduct of the remedial investigation/feasibility study (RI/FS) and implementation of the remedial action and, where necessary, as a component of the completed remedy. The use of institutional controls shall not substitute for active response measures (e.g., treatment and/or containment of source material, restoration of ground waters to their beneficial uses) as the sole remedy unless such active measures are determined not to be practicable, based on the balancing of trade-offs among alternatives that is conducted during the selection of remedy.
No further action is required for soil contamination at LF04 NB, however, landfill debris on the beach from LF04 will be removed annually as the specific remedy for this area. The removal of debris will include all LF04 Landfill material which has fallen onto the beach which can be reasonably collected for disposal. Hazardous materials encountered during annual removal events will be handled according to appropriate regulations.
The removal of debris from the beach at LF04 is expected to continue annually for 30 years or as long as the landfill remains subject to erosional action by tides. Five year reviews will assess the protectiveness of the remedial action including an evaluation of any changed site conditions. No further action will be required as a means of closing the LF04 Landfill. Soil at LF04 South will require no further action. The estimated time for groundwater cleanup is 14 years. Groundwater will be monitored to evaluate the progress of degradation and dispersion. Further response actions, coordinated with the regulatory agencies may be considered if monitoring finds unacceptable contaminant migration or unacceptable reduction in contaminant concentrations. |
Louis Howard |
| 1/27/1997 |
Institutional Control Record Established |
Institutional controls (ICs) and long term monitoring (LTM) on groundwater established by signing of ROD and subsequently been enforced by land planning department at the Base and environmental restoration staff oversight.
No current receptors exist for the groundwater at the Base due to the institutional controls (ICs). As a requirement of previously signed RODs for the Base, ICs have been established to restrict the use of the shallow aquifer in the outwash plain on Base. These restrictions are enforced through the Base Comprehensive Plan (BCP).
Projects and other activities are reviewed during the planning stage to ensure compliance with the BCP. In addition, construction projects and other activities also undergo an environmental review. This review helps ensures compliance with groundwater use restrictions. |
Louis Howard |
| 3/13/1997 |
Update or Other Action |
UPD action based on Relative Risk Evaluation Worksheet dated 8/22/95. Site description from worksheet entered under "Comments". |
Louis Howard |
| 3/13/1997 |
Update or Other Action |
(Old R:Base Action Code = RI - Remedial Investigation). RI action added by Shannon and Wilson 3/13/97, based on Relative Risk Evaluation Worksheet dated 8/22/95. Pathway: Site is vegetated; surficial soil on beach, landfill slope, top of bluff contaminated with metals, pesticides, dioxins. Seeps run downslope into Knik Arm carrying BTEX from contaminated groundwater. GW occurs in at least three different aquifers, which coalesce in places. Depth to groundwater ranges from 10 feet to greater than 100 feet. "Deep" aquifer at beach level. Receptors: Human receptors are limited. Area is remote and undeveloped but is used recreationally. Beach area used by treasure-seekers. No water supply wells in the area. Knik Arm not used as source of drinking water. Various species of salmon, whales, miscellaneous fish; moose and bear use area. |
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 OUs 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 |
| 6/15/1998 |
Update or Other Action |
Possible that chemical agent identification testing kits may have been disposed of there (personal communication with Joe Williamson 6/98). |
Louis Howard |
| 7/2/1998 |
Document, Report, or Work plan Review - other |
EPA comments on the Final Environmental Cleanup Plan and Quality Program Plan for Surface Debris Removal at Area of Concern OT82 and Site LF04, Elmendorf Air Force Base June 1998.
EPA has reviewed the subject document, which was received by EPA June 22, 1998. Based on our review, the Environmental Cleanup Plan for Site LF04 appears consistent with the requirements of the Operable Unit 6 (OU6) Record of Decision and the Treatability Study Design which served as the Remedial Design for this portion of OU6.
One possible exception is that this document made no mention of documentation and reporting of the types and quantities of materials encountered and removed. EPA believes such documentation, as well as documentation of any hazardous substances, pollutants or contaminants discovered and their disposition is required as part of this project. Such work does not need to be part of this plan if the Air Force will be accomplishing it in some other way, but EPA would like to be apprised of the results. EPA does not approve Health and Safety Plans. EPA has no other comments on the LF04 portion of the document |
Louis Howard |
| 8/24/1998 |
CERCLA ROD Periodic Review |
Five year review of all operable units (OUs) is ending which is an agency review of all remedies in place to ensure that they remain protective of human health and environment. 8/98 remedial action report states 2010 is when the benzene, ethylbenzene, toluene, 1.2-dichloroethane, methylene chloride will meet RAOs. |
Louis Howard |
| 10/27/1998 |
Update or Other Action |
7/98-9/98 quarterly progress report for OU6 North (LF04, SD15 and WP14) received. Groundwater monitoring continuing on a semi-annual basis, LF04 and WP14 free product recovery found on water table removed during monitoring events, annual beach sweeps ongoing at LF04, HVE of groundwater and free product ongoing at SD15. Institutional controls in place to prohibit use of shallow aquifer and/or designate the areas a restrictive use area to prohibit construction of any manned facility. HVE ran only 45% of August due to pulsing to allow enough water in wells for groundwater sampling. 36,000 gallons of water extracted this quarter with no detects of contaminants after running through 1st carbon filter canister. 236 pounds of volatile organic compounds from subsurface in vapor phase extracted. 30,880 pounds of general refuse and 21,000 pounds of recyclable metals from beach sweep recovered. |
Louis Howard |
| 4/13/1999 |
Update or Other Action |
01/99-03/99 quarterly progress report received. 8,166 gallons of water extracted/treated this quarter and nondetectable water discharged. 162 pounds of VOCs extracted from subsurface. |
Louis Howard |
| 6/21/1999 |
Update or Other Action |
04/99-06/99 quarterly progress report received. Beach sweeps to mitigate eroding debris at site begin. GRO, DRO BTEX soil contaminants have met the cleanup level "D" criteria in 1997. Groundwater contaminant Toluene has met the MCL of 1,000 ug/L in 1997 too. Benzene, ethylbenzene, and various chlorinated solvents are expected to be at or below MCLs by 2025. |
Louis Howard |
| 8/7/1999 |
Update or Other Action |
Anchorage Daily News Article which states that the military is conducting a cleanup of the debris at the bluff landfill and beach as a part of a projected annual 30 year project. |
Louis Howard |
| 10/5/1999 |
Update or Other Action |
7/99-9/99 quarterly progress report received. Round 1 analytical results show an overall decline in TCE levels, an increase in benzene levels in OU6MW-77 and decrease in DRO levels using AK sampling methodology. Annual beach sweep recovered 26 tons of material. |
Louis Howard |
| 10/5/1999 |
Update or Other Action |
Elmendorf project manager notified ADEC staff of August LF04 beach sweep cleanup discovery. Unexploded ordnance on August 9 was found and EOD team from Fort Richardson was contacted. 18 items were found. Mostly blank ammo and small arms items. Largest item was a 40 mm antiaircraft round and a primer from a 155 mm shell. Port of Anchorage contacted by Air Force to work out details of putting up signs and fencing to keep people out of LF04 area. |
Louis Howard |
| 11/4/1999 |
Update or Other Action |
Round 2 OU6 sampling results received. POL MW-02 increased for benzene from 12 to 25 ug/l and decreased in POL-MW-01 from 30 to 5.7 ug/l in round 2. OU6MW-63 had detected GRO at 3,400 ug/L. |
Louis Howard |
| 11/5/1999 |
Document, Report, or Work plan Review - other |
Staff sent letter approving draft technical report for surface debris removal from LF04. Staff requested the Air Force keep ADEC informed on any institutional controls revisions and fencing of site to deter trespassers. |
Louis Howard |
| 1/10/2000 |
Update or Other Action |
10/99-12/99 Quarterly report received for OU6 North (LF04, SD15, WP14). Received draft annual report for SD15 HVE system which is in its third year of operation. TCE is decreasing in groundwater, benzene is increasing in well OU6MW-77, and a decrease in DRO levels using new Alaska sampling method. Target date to meet groundwater cleanup levels for chlorinated solvents and benzene is 2025. For ethylbenzene the groundwater cleanup date is 2010. Exposed landfill debris continues to be exposed and picked up annually. |
Louis Howard |
| 3/1/2000 |
Update or Other Action |
Hart Crowser Research Results of Chemical Materiel at PACAF Bases Installations in Alaska (Contract No. DACA85-95-D-0010 Deliv. Order No. 30 A-8534: "Although no disposal records have been found showing that these agents or kits were intentionally landfilled, the CAIS kits may be found in pre-1970 landfills. One should be prepared for the possible occurrence of CAIS discovery when 3 excavating landfill of that era. The personnel performing the excavation should be familiarized with the kits, their hazards, and appropriate protection against them. "Empty" cylinders or containers formerly containing H also may be found in pre-1970 military landfills." |
Louis Howard |
| 4/10/2000 |
Update or Other Action |
1 January- 31 March 2000 quarterly report received. Annual beach sweep scheduled for June 2000. Contracting preparation underway for posting "keep out" signage around bluff and beach area. Municipality Port Authority recalcitrant on granting approval for fencing installation for LF04 entrance points to keep out trespassers. Air Force will keep trying to get approval from the Port, but meanwhile is researching who exactly owns the land from mean high water to mean low water. Port authority contends it was deeded or transferred to them from the State of Alaska years ago but they do not have any hard copy documentation to back up the claim. |
Louis Howard |
| 6/2/2000 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on a draft work plan for the debris removal in the summer of 2000 at the bluff. Main comments centered on the lack of a defined spill response notification to the department. The plan referenced the internal Air Force spill notification should a spill occur but did not have ADEC listed in the work plan for any notification. Letter referenced 18 AAC 75.300 and asked that the specific language be referenced in the plan. |
Louis Howard |
| 8/14/2000 |
Update or Other Action |
2000 Monitoring well results received. Methyl tert-butyl ether (MTBE) was added to the list of analytes at the request of ADEC. No MTBE was detected in any wells. Benzene was above the MCL in seven wells and trichloroethene (TCE) was above the MCL in three wells. OU6MW-77 had 1200 ug/L as the highest level of benzene detected. OU6MW-18 had the highest level of TCE detected. |
Louis Howard |
| 1/12/2001 |
Update or Other Action |
Quarterly report received for 10/00 to 12/00. Round 2 sampling results show out of 16 wells sampled, benzene dropped below MCL at 2 locations and decreased in concentrations at 4 locations. TCE exceeded MCL at 3 wells (October 00). |
Louis Howard |
| 3/20/2001 |
Update or Other Action |
Memo on PDBs being used as a "Beta Test" at Elmendorf AFB and Eielson AFB. The “Kick-off” meeting in Seattle, 20 March 2001, is intended to introduce the Remedial Process Optimization (RPO) process and the Passive Diffusion Bag Samplers (PDBS) guidance document “beta test” project at Elmendorf AFB and Eielson AFB, AK. The HQ Air Force Center for Environmental Excellence (AFCEE) is conducting an exhaustive “beta test” of the Guidance Document for Use of Polyethylene-Based Passive Diffusion Bag Samplers to Obtain Volatile Organic Compound Concentrations in Wells, described below, and provide feedback to the PDBS workgroup to update the Interagency PDBS Guidance Document for Installation Restoration Program (IRP) managers. The RPO and PDBS guidance document “beta test” will incorporate remediation programs at Elmendorf AFB and Eielson AFB, AK.
Passive diffusion bag (PDB) samplers are suitable for obtaining representative concentrations of volatile organic compounds in ground water in observation wells. A typical PDB sampler consists of a low-density polyethylene lay-flat tube closed at both ends and containing deionized water. The sampler is positioned at the target horizon by attachment to a weighted line. The PDB samplers equilibrate within approximately 48 hours for several tested volatile organic compounds, however vinyl chloride and some chloroethanes may require between 96 and 168 hours to equilibrate. The samplers should be allowed to remain in the well a minimum of two weeks prior to recovery to allow the well water to restabilize following sampler deployment. Recovery consists of removing the samplers from the well and immediately transferring the enclosed water to 40-milliliter sampling vials for analysis.
The method has both advantages and limitations. Advantages include the potential for PDB samplers to eliminate or substantially reduce the amount of purge water associated with sampling. The samplers are relatively inexpensive and easy to deploy and recover. Because PDB samplers are disposable, there is no downhole equipment to be decontaminated between wells and there is a minimum amount of field equipment required. The samplers also have the potential to delineating contaminant stratification in the open or screened intervals of observation wells where vertical hydraulic gradients are not present.
A possible disadvantage of the samplers is that they integrate concentrations over time. Depending on the compound of interest, this time may range between about 48 to 168 hours. The samplers are not applicable for all compounds. They are not effective for inorganic ions, for highly soluble organics such as methyl-tert¬-butyl ether, or poorly soluble organic compounds. An additional disadvantage is water must be freely flowing through the well screen for the samplers to be effective. VOC concentrations in PDB samplers represent concentrations in the vicinity of the sampler within the well screen or open interval. This may be a limitation if the ground-water contamination is above or below the screen, or not in the interrogated sample intervals. If there are vertical hydraulic gradient in the well, then the concentrations in the sampler represent the concentrations in the water flowing vertically past the sampler rather than in the formation immediately adjacent to the sampler. Multiple PDB samplers may be needed in chemically stratified wells or where flow patterns through the screen change as a result of ground-water pumping or seasonal fluctuations. |
Louis Howard |
| 7/27/2001 |
Document, Report, or Work plan Review - other |
Staff reviewed and approved the draft quality program plan for debris removal at the site. ADEC has reviewed the quality program plan and will approve the document as submitted. Please note that ADEC review and concurrence on this plan 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 plan does not relieve responsible persons from the need to comply with other applicable laws and regulations. |
Louis Howard |
| 8/24/2001 |
Site Number Identifier Changed |
Changed Work plan from X1 to X9 because of the presence of hazardous substances. |
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 6:
* As a result of the 2001 Decision Guide analysis of the OU 6 program area, none of the wells or
analytical methods met the criteria for removal from the OU 6 program area.
* For wells in the OU 6 program area, free product was detected at one well during the 2001 field season (OU6MW-77). A fuel odor and/or sheen was described at five additional wells as noted.
* OU 6 groundwater COCs exceeded MCLs for five COCs (benzene, ethylbenzene, methylene
chloride, toluene, and TCE). Benzene exceeded the MCL at ten well locations (OU6-MW-06,
OU6MW-17, OU6MW-18, OU6MW-46, OU6MW-63, OU6MW-77, OU6MW-92, 14-MW-120, 14-MW-121, and 14MW-133); TCE exceeded the MCL at three well locations (OU6MW-17, OU6MW-18, and OU6MW-90); and ethylbenzene and toluene at three well locations (OU6MW-46, OU6MW-77, and OU6MW-91). Methylene chloride exceeded the MCL at one location, OU6MW-91.
* Six wells at OU 6 contained statistically valid trends using current available data for benzene. Of these, all six had decreasing trends (K301, K302, OU6MW-77, OU6MW-67, OU6MW-46,
and OU6MW-90). As indicated on Table 4-21, OU6MW-06, OU6MW-17, OU6MW-18, OU6MW-46, OU6MW-63, and OU6MW-77 exceeded the benzene MCL of 5 ,ug/L in 2001. Of the nine wells not exceeding the MCL, only two, OU6MW-67 and OU6MW-90, reported concentrations above the detection limits. Statistically these two wells showed decreasing concentrations.
* The same statistical method was applied to the data set for TCE at OU 6 (Table 4-22). The TCE
MCL was exceeded at three wells, OU6MW-17, OU6MW-18, and OU6MW-90. Statistically, one of these three wells, OU6MW-17, showed decreasing concentrations and the remaining two, OU6MW-18 and OU6MW-90, had no trend.
* Data strongly imply that natural attenuation is effectively removing organic contaminants within OU 6 groundwater. |
Louis Howard |
| 2/21/2002 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the report for debris removal at LF04. The ADEC requests future documents incorporate the Operable Unit (OU) 6 Record Of Decision (ROD) remedial action objectives and the selected remedy language for explaining why the work is being conducted as it has been since 1998. See text below taken from the OU 6 ROD. The OU 6 ROD remedial action objectives state:
Mitigate human dermal exposure, to the extent practicable, to landfill waste or debris.
Mitigate exposure, to the extent practicable, of environmentally sensitive receptors to landfill waste. Relevant exposure pathways for wildlife include incidental ingestion of contaminated soil, ingestion of contaminated vegetation, and ingestion of contaminated animals (e.g. insects and earthworms).
The OU6 ROD selected remedy language states. Soil at LF04-Landfill debris on the beach from LF04 will be removed annually as the specific remedy for the area. The removal of the debris will include all LF04 landfill material which has fallen onto the beach which can be reasonably collected for disposal, as well as debris on the bluff slope or other low lying areas which can be accessed and removed without hazard. Hazardous materials encountered during the annual removal events will be handled according to appropriate regulations. The duration of the soil remedy is indefinite. Further response actions, coordinated with the regulatory agencies, may be considered if additional contamination is discovered during the annual beach sweeps or if the degree of reduction of debris on the beach is unacceptable. The removal of debris from the beach at LF04 is expected to continue annually for 30 years (for the purposes of cost estimating per CERCLA guidance) or as long as the landfill remains subject to erosional action by tides. Five-year reviews will assess the protectiveness of the remedial action, including an evaluation of any changed site conditions. The ADEC requests the date of the last five-year review be included here as well as the projected date of the next five-year review.
Applicable or Relevant and Appropriate Requirements (ARARs)
The ADEC requests incorporation of the OU 6 ARARs (e.g. chemical-specific, location-specific, and action-specific) as defined in the Record of Decision (refer to pages 3-30, 3-31 and Table 3.5-1). |
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, and 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 |
| 11/7/2002 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the landfill site evaluation work plan for the site. The text states soil, sediment, and surface water will be sampled for to determine if the chemical concentrations have changed since the remedial investigation/feasibility study (RI/FS) and Record of Decision (ROD). The Department requests clarification on whether the analyses are different than those performed during the RI/FS or ROD.
Other than this clarification, the Department will concur with the work plan. The Department’s concurrence on the work plan is to ensure that the work is done in accordance with State of Alaska's environmental conservation laws and regulations. While the Department may comment on other state and federal laws and regulations, our concurrence on the document does not relieve the Air Force, its contractors, subcontractors, Air Force civilian personnel, agents or other persons acting for the Air Force, from the need to comply with other applicable. |
Louis Howard |
| 1/14/2003 |
Meeting or Teleconference Held |
Attendees: Joe Williamson (USAF), Gary Fink (USAF), James Klasen (USAF), Kevin Oates (EPA), Louis Howard (ADEC), Cory Hinds (URS), Paul Dworian (URS), Kristin Paul (URS)
Agenda: Discuss ADEC’s request to add the analyses of Diesel Range Organics (DRO) and Gasoline Range Organics (GRO) to several Operable Units at Elmendorf.
Summary of Discussion:
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.
(NOTE to file: 18 AAC 70 Alaska Water Quality Criteria: Total aqueous hydrocarbons (TAqH) in the water column may not exceed 15 ug/l (See note 8). Total aromatic hydrocarbons (TAH) in the water column may not exceed 10 ug/l. Samples to determine concentrations of total aromatic hydrocarbons (TAH) and total aqueous hydrocarbons (TAqH) must be collected in marine and fresh waters below the surface and away from any observable sheen. Concentrations of TAqH must be determined and summed using a combination of: (A) EPA Method 602 (plus Xylenes) to quantify monoaromatic hydrocarbons and to measure TAH; and (B) EPA Method 610 to quantify polynuclear aromatic hydrocarbons.
Use of an alternative method requires department approval. The EPA methods referred to in this
note may be found in 40 C.F.R. 136, Appendix A, as amended as of February 14, 1996, adopted
by reference. They may be reviewed at the department or are available from the Office of
Monitoring Systems and Quality Assurance, Office of Research and Development, United States
Environmental Protection Agency, Washington, D.C. 20460.) |
Louis Howard |
| 2/18/2003 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the report for debris removal at LF04. Approximately 18 tons of non-hazardous solid waste was removed from the beach along LF04 in September-October 2002. Only surface debris that could be removed without disturbance of the tidelands, vegetation, and bluff face were removed. Excavation activities were not conducted to remove debris. The debris was disposed of at the Anchorage Municipal Landfill. Approximately 40 pieces of rifle ordnance were discovered at LF04. Elmendorf's UXO team was dispatched to the site where the ordnance was collected and removed from the site. |
Louis Howard |
| 5/21/2003 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the draft five year review report for the site. Comments centered on the Air Force being reminded that this is the second five year review and not the first five year review. Staff requested the Air Force utilize whatever information it can from the previous efforts to incorporate it into the second five year review. |
Louis Howard |
| 5/22/2003 |
Update or Other Action |
Staff reviewed and commented on the Landfill Operations and Management Plan. The Department has reviewed the document and has no comments regarding the document. This expedited review is done as a courtesy for the Air Force and should not be construed as standard document submittal and review procedures as specified under the Federal Facility Agreement Section XX G. Review and Comment on Draft Documents (20.13) which states that unless the Parties mutually agree to another time period, all draft documents shall be subject to a thirty (30) day period for review and comment. The document may go final as written, pending incorporation of any other outstanding comments from EPA. |
Louis Howard |
| 6/4/2003 |
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 |
Document, Report, or Work plan Review - other |
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.
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 |
| 7/23/2003 |
Document, Report, or Work plan Review - other |
Staff reviewed and approved the draft LF04 debris removal plan. |
Louis Howard |
| 9/25/2003 |
Update or Other Action |
Memorandum to the Site File signed for OU6. The purpose of this document (Memorandum to the Site File) is to present non-significant or minor changes to the Record of Decision (ROD) signed for OU 6 and Source Area SS 19 at EAFB. The minor changes to the OU 6 ROD involve modifying the sampling frequency of groundwater wells and the inclusion of portions of the shallow soils at SO 15 in a high-vacuum extraction (HVE) treatability study. Other components to the OU 6 selected remedy will not be affected by this minor change.
This minor revision to the ROD changes the sampling frequency for groundwater monitoring. Data collected semi-annually over the past seven years has provided an understanding of the nature and extent of contaminant migration and the effectiveness of intrinsic (natural) remediation. In many instances continuation of the semi-annual sampling would not provide any useful new data as compared to less frequent monitoring.
The second component of the minor revision to the ROD includes implementing a high-vacuum
extraction treatability study for shallow soils at SD15. Approximately 170 yd3 of fuel contaminated soil was excavated and treated during the implementation oft.he selected remedy in
1996. Confirmation samples indicate that two of the four areas have elevated levels of
contamination and will, therefore, be included in the high-vacuum extraction treatability study.
Further soil excavation will be determined after evaluation of treatability study results.
Proposed Changes: Sampling changed from semi-annually to a frequency determined by the Decision Guide. The changes to the sampling frequency will continue to provide sufficient data to assess
contaminant migration and timely reduction of contaminant concentrations by intrinsic
remediation as required by the ROD. The revised monitoring frequency will also streamline the
groundwater reporting process and reduce monitoring costs.
The changes to the sampling frequencies were discussed in the 28 Aug 02 meeting between the
USAF, Region X of the EPA and the ADEC. The high vacuum extraction treatability study for shallow soils at SDl5 was agreed upon at the 11 lun 03 Remedial Project Manager Meeting between the USAF, Region X of the EPA and the ADEC. Both EPA and ADEC project managers concurred with the proposed changes. |
Louis Howard |
| 1/27/2004 |
CERCLA ROD Periodic Review |
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). At LF04 "Restricted Use Area" is designated for recreational use of the parcel (such as cross-country skiing, etc.) and construction of unmanned facilities (such as parking lots, storage buildings, or taxiways). The construction of manned facilities (such as office buildings or residential structures) is strictly prohibited. As a former landfill, this designation will remain indefinitely. The use of contaminated groundwater throughout LF04 for any purpose including, but not limited to, drinking, irrigation, fire control, dust control, or any other activity is prohibited. Drilling into the shallow aquifer is also restricted.
Site inspection was performed at LF04 during the December 2002 sampling event. No significant problems were identified. Documentation of the site inspection can be found in Attachment D of this Five-Year Review.
Since signing of the ROD, there have been newly promulgated state soil cleanup levels that apply to the COPCs identified in the ROD and one new groundwater standard for 1,1,2,2-tetrachloroethane (this does not apply to LF02 which had a risk based groundwater standard in the ROD for this chemical). A review of maximum detected levels indicates that all of these COPCs are within current applicable standards; therefore, the remedy is considered protective. In addition, the remedy appears to be effectively remediating BTEX, which is currently monitored as a COC.
Toxicity criteria have changed for three of the COCs: TCE, benzene and ethylbenzene. The toxicity criteria changes do not affect the selected RAOs and because current concentrations are below ADEC risk based levels, concentrations are not a health concern.
Small arms casings and rounds have been discovered on the LF04 beach. These reports of possible ordnance and explosives created a need for Elmendorf Explosive Ordnance Disposal (EOD) to respond, inspect, collect, and dispose of suspect items. Fencing between base and port properties was strengthened and signs warning of potential explosive hazards were posted in 2000. Additionally port security controlled entry, base security patrols, and routine wildlife law enforcement patrols ensure that LUCs continue to limit access to the beach area. EOD will continue to respond, to inspect and properly dispose of suspect items in addition to performing routine EOD walks during the summer season. CEVR personnel perform beach walks monthly, generally May through September after extreme high tide, to monitor any changes to the beach.
Erosion studies determined at the LF04 beach and bluff for the last 15 years is about three (3) feet per year and does not appear to be increasing. The projected period for the landfill to completely erode is 200 years. A five year review fact finding study included consideration of seven alternatives for addressing erosion and reducing debris and contaminant deposits on the beach. The study concluded that the annual beach sweeps remain the most practicably remedy for LF04 at this time. |
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 |
| 4/28/2006 |
Update or Other Action |
PL81 South Limited Field Investigation Report received. The objective of this project was to perform a limited subsurface investigation and dye tracer study at the PL81 South site. Project activities include soil boring and soil sampling, as well
as addition of dye to Operating Unit 6 monitoring well 63 (OU6MW-63) and subsequent seep monitoring. These activities were designed to determine the extent of contamination and to
verify that fuel contamination historically measured in the seep below the site came from the PL81 South fuel spill. This additional data will help to support assessment of remedial alternatives for the site.
Field activities were conducted June through December 2005. This project included subsurface soil sampling and a dye tracer study at the PL81 South site. The purpose of the limited field investigation was to determine the extent of diesel-range
organics, benzene, toluene, ethylbenzene, and xylenes in the vadose zone at the PL81 South site, in support of future remedial activities. Analytical soil results indicated that contamination from the fuel spill migrated downward through site soil until it encountered a layer of low permeability at approximately 20 feet below ground surface.
This layer acted as a barrier. Some contamination accumulated on top of the low permeability layer and flowed over the edges of the layer. Some contamination however has migrated through this layer via small channels. Free-product contamination historically accumulated at the groundwater table surface and traveled down gradient towards seep SP02. Over time, weathering,
biodegradation, smearing, and discharge have reduced fuel concentrations to residual levels.
The limited soil investigation provided data to indicate that contamination from the former pump house has percolated down to a low permeability layer at approximately 20 feet bgs.
In some areas, the low permeability layer acted as a barrier causing contamination to accumulate on top. In these areas, soils above the barrier are currently contaminated and moist. The soil below the barrier, in these areas, is uncontaminated. In other areas, fuel could pass through the low permeability area though seemingly preferential pathways as evident by fuel stained streaks.
The purpose of the dye tracer study was to conduct a qualitative dye test to determine if contamination from the PL81 South site is in fact impacting the beach seep located below the site. One hundred-twenty days after dye was injected into Operating Unit 6 monitoring well 63 (OU6-MW63), it was detected in the seep. This demonstrated the hydraulic connection between the spill site and the seep.
Because only the leading edge of the dye plume was reaching the seep 120 days after injection, actual seepage velocities at the site are slower than previously estimated. Visual observations of surface water flowing from the seep indicate that flow rates are highly variable. During each seep sampling event, at least a minimal amount of water was discharging (base flow). However, during some sampling events, particularly following periods of high precipitation, flow rates were far greater. This bimodal distribution of flows indicates that base flow takes place in relatively low conductivity zones and that higher groundwater levels allow flow through higher conductivity zones. As groundwater levels rise, a steeper gradient toward the seep is created driving greater flow rates through zones of high conductivity. Thus, groundwater flow rate vary significantly with groundwater levels. Biodegradation of fuel contaminants is apparent at the seep by significant iron staining and biogenic sheen. |
Louis Howard |
| 7/6/2006 |
Document, Report, or Work plan Review - other |
Staff reviewed and approved the zone 1 workplan for nine plumes and one landfill (LF04) located through the northern and western reaches of Elmendorf AFB. (LF04) spread through the northern and western reaches of Elmendorf AFB (Figure 1-1). The objectives of the 2006 Zone 1 field effort are as follows:
Assess seasonal and annual variations in the groundwater flow patterns and hydraulic conditions. Compare current data to historical data to identify trends in contaminant concentrations. Characterize and evaluate the plumes based on the data obtained.
Predict movement of contaminants and provide early warning of contaminant movement, especially near base boundaries.
Provide recommendations for necessary actions to prevent contaminant migration off the base and evaluate groundwater flow characteristics and monitoring well integrity. Perform activities to monitor, evaluate, and maintain LF04 to support requirements identified in the record of decision, operations and maintenance, remedial process optimization, and subsequent 5-year reviews. |
Louis Howard |
| 2/26/2007 |
Exposure Tracking Model Ranking |
|
Louis Howard |
| 4/17/2007 |
Update or Other Action |
2006 Annual Phase I RPO report (Draft) received. The RPO process at Site LF04 included the evaluation of the following criteria: The remediation approach is adequately containing contamination to prevent migration toward potential human or ecological receptors; and appropriate decision document controls and base administrative controls are being enforced to prevent undesirable risks due to uncontrolled exposure to contaminants and to ensure adequate protection for remediation workers.
Recommendations: Discontinue sampling at the three LF04 North/Beach seeps. Administratively close LF04 North/Beach groundwater, eliminating all reporting and administrative costs after 2007. Review the Port of Anchorage Expansion Project for potenital effects on the LF04 beach cleanup and modify the operations and management as appropriate to maintain protectiveness of the remedy. |
Louis Howard |
| 5/14/2007 |
Document, Report, or Work plan Review - other |
Draft 2006 Zone 1 Annual Remedial Process Optimization Report, April 2007 received on April 18, 2007. Based on the data presented in the report and any pending U.S. EPA comments, ADEC will approve the document as submitted. |
Louis Howard |
| 5/23/2007 |
Document, Report, or Work plan Review - other |
EPA comments on the Zone 1 RPO Report to Glen Verplancke 3 CES/CEVR Email message:
Great report. I agree with the changes to sampling frequency, fewer MNA parameters and water level measurements. Also the geometric regression may yield better predictions. I also think the use of the geoprobe for deep samples at DP 98 is a good idea.
This was a well written report, I especially like the site overview figure at the end. There are valuable observations made in this report , together with some changes to technique(PDBS), so it will be IMPORTANT for future work to revisit this info. I noted that at a couple sites they observed that we may need downgradient sentry wells to follow the plume, lets revisit that someday also.
Sorry I was late. Again, a very professional report. |
Louis Howard |
| 8/2/2007 |
Update or Other Action |
Staff received the Explanation of Significant Differences (ESD) which documents refinements to the original remedy at Operable Unit (OU) 6 at Elmendorf Air Force Base (AFB), Alaska. OU 6 is composed of three former landfills (LF02, LF03, and LF04), two sludge disposal pits (SD15 and WP14), a surface disposal area around a rock testing laboratory (SD73), and a former storage bunker (SS19). The Record of Decision (ROD), signed by the United States Environmental Protection Agency (USEPA) on 4 December 1996, by the Alaska Department of Environmental Conservation (ADEC) on 2 January 1997, and by the United States Air Force (USAF) on 27 January 1997, presents the selected remedial actions for OU 6 (Elmendorf AFB, 1997). This ESD updates the selected remedial actions based on data collected during remedy implementation and was prepared in accordance with Section 117(c) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) and Chapter 40 of the Code of Federal Regulations (40 CFR) Sections 300.435(c)(2)(i) and 300.825(a)(2) of the National Oil and Hazardous Substances Pollution Contingency Plan (NCP).
Groundwater LF04 South: Access to groundwater at LF04
South will be institutionally controlled. LF04 is currently designated as a "restricted use area" in the Base General Plan. This designation provides for recreational use of the parcel (e.g., cross country skiing) and for construction of unmanned facilities such as a parking lot, storage building, or taxiway, but prohibits the construction of any sort of manned facility such as an office building or a residence. Drilling into the shallow aquifer is also restricted by the Base General Plan to prohibit residential or
agricultural use.of contaminated groundwater. Clarification of LUCs.
Soil North Beach-Access to soil at LF04 North/Beach will be
institutionally controlled. LF04 is currently designated as a
"restricted use area" in the Base General Plan. This designation
provides for recreational use of the parcel (e.g., cross country
skiing) and for construction of unmanned facilities such as a
parking lot, storage building, or taxiway, but prohibits the
construction of any sort of manned facility such as an
office building or a residence. Clarification of LUCs |
Louis Howard |
| 8/10/2007 |
Update or Other Action |
Port of Anchorage Intermodel Expansion project Phase II Permit 2007 US Army Corps of Engineers permit no. POA-2003-502-N Permit to Discharge Dredged Material in Waters of the U.S. Including Wetlands, Necessary for the Expansion of the Port of Anchorage issued August 10, 2007. The permit authorizes the discharge of fill material over 20.5 acres of wetlands associated with the development of the Cherry Hill and North End Runway borrow pits (On Elmendorf Air Force Base). The gravel extraction sites are located within sections 5 & 6, T. 13 N., R. 3 W.; and within sections 27, 28, 33, and 34, T. 14 N., R. 3 W.; Seward Meridian on Elmendorf Air Force Base northeast of the Port of Anchorage.
VII. Fill Material - The following conditions are required to minimize adverse impacts of the discharge on special aquatic sites and other waters outside the project area [33 CFR 321.4 (r), 40 CFR 230.5 (j) and 40 CFR 230 Subpart H including parts 230.71, 230.72 , 230.73 and 230.75]). 1. Fill material shall consist of clean fill, free of unsuitable material (e.g. trash, debris, asphalt, etc.) and free of toxic pollutants.
CFR 40 Part 230 Section 404(b)(1) Guidelines for Specification of Disposal Sites for Dredged or Fill Material Sec 230.10 Restrictions on discharge
(b) No discharge of dredged or fill material shall be permitted if it: (1) Causes or contributes, after consideration of disposal site dilution and dispersion, to violations of any applicable State water quality standard; (2) Violates any applicable toxic effluent standard or prohibition under section 307 of the Act; (3) Jeopardizes the continued existence of species listed as endangered or threatened under the Endangered Species Act of 1973, as amended, or results in likelihood of the destruction or adverse modification of a habitat which is determined by the Secretary of Interior or Commerce, as appropriate, to be a critical habitat under the Endangered Species Act of 1973, as amended. If an exemption has been granted by the Endangered Species Committee, the terms of such exemption shall apply, in lieu of this subparagraph; (4) Violates any requirement imposed by the Secretary of Commerce to protect any marine sanctuary designated under title III of the Marine Protection, Research, and Sanctuaries Act of 1972.
(c) Except as provided under section 404(b)(2), no discharge of dredged or fill material shall be permitted which will cause or contribute to significant degradation of the waters of the United States. Findings of significant degradation related to the proposed discharge shall be based upon appropriate factual determinations, evaluations, and tests required by subparts B and G, after consideration of subparts C through F, with special emphasis on the persistence and permanence of the effects outlined in those subparts. Under these Guidelines, effects contributing to significant degradation considered individually or collectively, include:
(1) Significantly adverse effects of the discharge of pollutants on human health or welfare, including but not limited to effects on municipal water supplies, plankton, fish, shellfish, wildlife, and special aquatic sites. (2) Significantly adverse effects of the discharge of pollutants on life stages of aquatic life and other wildlife dependent on aquatic ecosystems, including the transfer, concentration, and spread of pollutants or their byproducts outside of the disposal site through biological, physical, and chemical processes; (3) Significantly adverse effects of the discharge of pollutants on aquatic ecosystem diversity, productivity, and stability. Such effects may include, but are not limited to, loss of fish and wildlife habitat or loss of the capacity of a wetland to assimilate nutrients, purify water, or reduce wave energy; (4) Significantly adverse effects of discharge of pollutants on recreational, aesthetic,
and economic values.
(d) Except as provided under section 404(b)(2), no discharge of dredged or fill material shall be permitted unless appropriate and practicable steps have been taken which will minimize potential adverse impacts of the discharge on the aquatic ecosystem. Subpart H identifies such possible steps. |
Louis Howard |
| 9/18/2007 |
GIS Position Updated |
61.2509 N latitude -149.8769 W longitude |
Louis Howard |
| 11/20/2007 |
Update or Other Action |
2007 Zone 1 Remedial Process Optimization (RPO) Report received for contaminated sites & associated underlying GW for the western portion of EAFB. This area, referred to as Zone 1, includes: DP98, ST36/66, ST41, ST61, ST69, LF04 North, PL81, WP14, & LF02. Site LF04 was divided into North/Beach & South sections in the OU6 ROD. No GW contamination has been detected in association with LF04 North.
GW in LF04 North/Beach discharges at three seeps along the bluff overlooking Knik Arm: from south to north, LF04-SP06, LF04-SP05, & LF04-SP07. The boundary between LF04 North/Beach & LF04 South is given in the OU6 ROD as an east-west line through monitoring well MW-K302. This monitoring well does not appear on the latest well inventory for Zone 1 & has probably been abandoned. LF04 is included in the OU6 ROD, which was signed in January 1997. Debris is removed from the beach annually. Soil & sediment are collected in support of the 5-year review process. Seep samples were collected until 2007 but never contained significant levels.
The LF04 North/Beach seeps were monitored from 2002 through 2006 as an extension of monitoring conducted for seeps in LF04 South. The GW RAO for LF04 South GW is as follows:
• Prevent the ingestion, dermal contact, & inhalation of vapors from GW having benzene, toluene, ethylbenzene, 1,2-dichloroethane (DCA), & methylene chloride in excess of MCLs &/or resulting in a cancer risk greater than 1.0E-6 or hazard index greater than 1.0.
In 2002, the list of COCs for all seeps was reevaluated in order to be protective of surface
water & eliminate contaminants that had never exceeded cleanup levels. The current COCs for LF04 South seeps are benzene, TAH, TAqH, & sheen.
A 5-year review is scheduled for the LF04 site in 2008. Until the results of the review are
final, receptor monitoring for 2008 should be eliminated due to the ongoing Port construction
in the area. Debris removal in 2008 may be possible in conjunction with the planned construction of a culvert between the bluff area & Port facilities. After construction is
complete, debris removal should occur on a limited, as-needed basis. A Minor Site Letter will
be prepared in 2008 to document this change. Final recommendations for this site should be
made as a part of the 5-year review.
Activity conducted since the 2006 RPO Report (USAF 2007b):
• GW monitoring—In 2007, wells OU6MW-46 & -15 were sampled for benzene, ethylbenzene, & MNA parameters, & well OU6MW-63 was sampled for benzene, GRO, DRO, & MNA parameters. Well OU6MW-46 was sampled at two depths via an in-well pump & a PDB. Well OU6MW-15 was sampled via a PDB. Field parameters & ferrous iron were measured in all wells. No product removal occurred because no free product was encountered in the wells.
• Surface water monitoring—Seep locations LF04SP-02 & LF04SP-02DG were checked for sheen & sampled for benzene, TAH, & TAqH.
• Synoptic water levels—Water levels were measured in all Site PL81 wells within a 48-hour period.
• Long-term water-level monitoring—Water levels were monitored from May through September 2007 via manual methods & recording transducers.
For MNA parameters in this well, low DO (1.03 mg/L), very high ferrous iron (3.3 mg/L), & somewhat negative ORP (-76.3 mV) signify in-plume geochemical conditions too reducing for rapid biodegradation. This well was sampled by PDB in addition to in-well pumping at 1 & 20 feet bswl. The PDB sample at 1 foot bswl had much lower COC concentrations than those collected by in-well pumping, & the two in-well pumping samples were nearly identical. The deep PDB sample results were the highest for both benzene & ethylbenzene & matched the concentrations of both pump samples.
The discrepancy between the shallow PDB sample & the collocated pumped sample is readily explained: The PDB sampled the static water column, which at this depth contained only low COCs; the collocated pumped sample sampled deeper water that was brought up during purging. Although low-flow protocol was observed during purging to facilitate only lateral flow to the pump intake, subsequent investigation revealed that the well is screened only in its lower 10 feet. Thus, the shallow pumped sample actually drew water from approximately the same depth as the deep pumped sample.
To minimize costs, PDBs should be used & MNA & field parameters omitted. If benzene & ethylbenzene remain at their current levels, the remedy should be reevaluated at that time. If extended MNA is selected, the monitoring interval could be as long as 5 years, to minimize monitoring costs. MNA parameters also should be collected every 5 years & should include pH, ORP, DO, & ferrous iron. If an active remedy is selected, extensive & comparatively costly characterization will be required. |
Louis Howard |
| 3/18/2008 |
Update or Other Action |
Memorandum to the Site File Operable Unit (OU) 6 signed by ADEC, US EPA, US Air Force. The purpose of this document (Memorandum to the Site File) is to present a nonsignificant or minor change to the Record of Decision (ROD) signed for OU 6 at EAFB. OU 6 is composed of three former landfills (LF02, LF03, and LF04), two sludge disposal pits (SDI5 and WP14), a surface disposal area around a rock testing laboratory (SD73), and a former storage bunker (SS 19). The minor change to the OU 6 ROD involves the removal of the reference to the LF04 beach at LF04 North. The Port of Anchorage Expansion project has covered or will cover the entire LF04 beach area by 2008. Exposure to beach soils and sediments will not be possible. The groundwater and bluff soils will not be affected by this minor change.
The ROD, signed by the United States Environmental Protection Agency (US EPA) on 4 Dec
1996, by the Alaska Department of Environmental Conservation (ADEC) on 2 Jan 1997, and by
the United States Air Force (USAF) on 27 Jan 1997, presents the selected remedial actions for
OU 6 (EAFB 1997). It was prepared in accordance with Section 117 of the Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA) and Chapter 40 of the
Code of Federal Regulations (CFR), Section 300.430 of the National Oil and Hazardous
Substances Pollution Contingency Plan.
There have been two revisions to the au 6 ROD. The first revision was a memorandum to the
site file, dated 19 Sep 03. This revision outlined changes to the sampling frequency of
groundwater wells and the inclusion of portions of the shallow soils at SD 15 in a high-vacuum
extraction (HVE) treatability study. The second revision was an explanation of significant
differences (ESD), dated 15 Jun 07. This revision allowed for the termination of the HVE
system at SDI5, provided clarification on how land use controls would be implemented at OU 6
sites and established 18 AAC 75.345 as a chemical-specific Applicable or Relevant and
Appropriate Requirements (ARAR) for LF02 and SD15 which resulted in a new cleanup level
for 1,1 ,2,2-tetrachloroethane.
This Memorandum to the Site File was prepared in accordance with the USEPA Guide to
Preparing Superfund Proposed Plans, Records of Decision, and Other Remedy Selection
Decision Documents, July 1999, Section 7.3.1 and Highlight 7-1, and will become part of the
administrative record for OU 6 and EAFB.
This minor revision to the ROD will substitute the words "Port of Anchorage fill that is at the
base of LF04" for the words "beach" or "beach area" because the beach area is or will be
covered or filled in by the Port of Anchorage expansion project. The north extension and barge
berths portion of the expansion project began in 2007 and is scheduled for completion in 2009.
The project will cover all exposed beach area from Knik Arm to the base of the bluff extending
north from the current Port of Anchorage to Cairn Point, the northernmost point, currently
monitored for debris under the LF04 North/Beach remedy. The beach will no longer exist as a
beach because it will be capped by the Port of Anchorage expansion. Therefore, the word
"beach" is no longer appropriate and the phrase "Port of Anchorage fill that is at the base of LF04" will be substituted for "beach" in the OU6 ROD. In addition the site description of LF04
NorthlBeach will be changed to simply LF04 North. These word substitutions will prevent
confusion which could occur if people began looking for a beach described in the OU 6 ROD
that no longer exists.
The Port of Anchorage expansion also will prevent tidal action from reaching the base of the bluff and is expected to drastically reduce erosion in the LF04 North area. Although the bluff will continue to erode by rainfall and snow, the rate of erosion and soil instability are expected to slow. Annual debris removal will continue on the bluff slope or other low-lying areas that can be accessed and removed without hazard. This change in the ROD does not significantly change or fundamentally affect the remedy selected in the ROD; therefore, no public comment is required. |
Louis Howard |
| 1/30/2009 |
Update or Other Action |
Elmendorf Air Force Base's (EAFB) Third Five-Year Review report received.
Recommendations & Follow-up Actions for LF04: Conduct GW monitoring & evaluations in the context of LF04 South requirements of the OU6 ROD. Sample well OU6MW-61 to determine if OU6 LF04 South GW meets cleanup levels for chlorinated solvent COCs.
Protectiveness statement: The remedy at OU6 is expected to be protective of human health & the environment for all sites. The remedy at LF04 North is expected to be protective of human health & the environment through the annual removal of exposed landfill debris. The remedies at LF04 South, WP14 & SD15 are expected to be protective of human health & the environment upon attainment of GW cleanup goals through natural attenuation. In the interim, exposure pathways that could result in unacceptable risks are being controlled.
Site specific land use at OU6 LF04 is restricted use with long term planning for the site is no development planned. Restricted use areas provide for recreational use & construction of unmanned facilities such as parking lot, storage building or taxiway, but prohibit construction of any sort of manned facility such as an office building or a residence.
There is no off-base contamination at LF04, but a portion of LF04 adjoins the expanded Port of Anchorage (POA) facilities. There was no transfer of property between the USAF & the POA for the port expansion project. The expanded port facilities are outside of the Elmendorf AFB LF04 boundary. The expanded port facilities are not anticipated to impact implementation of the LF04 remedies, & will not result in increased exposure to contaminants. EAFB has coordinated closely with the POA to ensure that the USAF can continue to conduct the annual debris removal.
The POA expanded its facilities in 2007 & 2008 just outside of the Elmendorf AFB OU6 LF04 boundary. The beach below LF04 was covered with fill material. The expanded port facilities are outside of the EAFB LF04 boundary. The expanded port facilities are not anticipated to impact implementation of the LF04 remedies, nor result in increased exposure to contaminants. Fill material for the Port expansion project was quarried from the Cherry Hill borrow pit, located to the south of & outside the LF04 North soil LUC boundary, LF04 South & WP14.
The borrow pit area was designated in the Base General Plan as “open space.” Prior to quarrying operations, extensive soil borings were made to define the GW table at the Cherry Hill borrow pit. Quarrying was conducted to avoid contact with GW by leaving a five-foot buffer zone between the bottom of the excavation & the shallow aquifer GW table. Borrow pit activities did not result in a significant change in land use or any increased exposure to contaminants.
The ROD was updated by a memorandum to the site file to update monitoring frequency & establish a sampling frequency decision guide in September 2003. The ROD was updated with an explanation of significant differences (ESD) in March 2007. The ESD modified the SD15 remedy so that HVE system operations could be terminated because that system was no longer effective, & monitored natural attenuation (MNA) was selected as the remedy for the remaining contaminants. The ESD also adopted a new state cleanup standard for 1,1,2,2-tetrachloroethane in GW at LF02 & SD15.
The OU6 ROD identified 1,1,2,2-tetrachloroethane as a COC for LF02 & SD15 GW, but no ARAR existed at that time. Finally, the ESD also provided details on how LUCs would be implemented to comply with Air Force policy. The ESD did not change the LUC performance objectives from the ROD. The ROD was updated again by a memorandum to the site file in 2008 to indicate that the beach below LF04 North has been filled as part of the POA expansion. The USAF will continue to remove debris annually from the base of the bluff (i.e., the location of the former beach). The expansion of the port facilities will reduce wave-action erosion at LF04, & has also covered what was once the beach area, where sediment samples were formerly collected. Sediment samples are no longer collected & were last collected in 2002.
GW is monitored at LF02, LF04 South, WP14, & SD15. LF04 South monitoring wells are evaluated in annual reports as part of the monitoring programs for WP14 & a state program site, PL81. The GW monitoring program is updated annually in accordance with the monitoring frequency decision guide to ensure the program remains comprehensive & protective. Several key changes were made to the monitoring plan during the past five years.
|
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 |
| 12/1/2009 |
Update or Other Action |
Semi-annual progress report received. Summary of Work Performed During Last Six Months: Awarded contract for soil removal at SD15 (Jun 09), Sampled groundwater at 6 monitoring wells and 3 seeps at LF04 South and WP14 (Jul 09), Conducted annual land use control (LUC) site inspections (Jul 09), Performed annual LF04 debris removal (Sep 09) and Removed 250 cubic yards of petroleum contaminated soil at SD15 (Oct 09).
Planned Activities for Next Six Months: Award FY10 Zone 1 RA-O project (Jan 10), Submit annual LUC report to EPA and ADEC (Jan 10), Receive final 2009 Zone 1 Field Activities Report (May 10) and Receive final work plan for 2010 summer field work at LF04 and WP14 (May 10). |
Louis Howard |
| 3/3/2010 |
Update or Other Action |
2009 Zone 1 Field Activities Report received. Five sites (LF02, LF04, WP14, ST41, & DP98) are administered under the Comprehensive Environmental Response, Compensation, & Liability Act (CERCLA) with U.S. Environmental Protection Agency (EPA) oversight & are governed by Records of Decision (ROD). The 3 remaining sites (ST36/66, ST61, & ST69) are regulated according to State of Alaska cleanup requirements.
2009 Activities at LF04 North: On 21 May 2009, a survey was completed to record the location of debris at LF04. Most of the debris consisted of metal, glass, & burned trash. Debris was marked with stakes & surveyed using a Leica GPS unit, & three aspects of each marked area of debris were photographed. The first aspect captured the general location of the debris relative to the bluff. This aspect photo is also part of a comprehensive, uninterrupted series of overlapping photos over the entire length of LF04 North, taken from evenly spaced points. The second aspect captured the marked debris along with an area of the bluff sufficient to relate the image to a location on the bluff. The third aspect captured details of the marked debris.
LF04 erosion monitoring: Historically, tidal action at LF04 undercut the bluff & exposed portions of the landfill, which sloughed onto the beach. However, recent expansion of the Port of Anchorage in 2007 through 2009 has filled most of the former LF04 beach area, eliminating most tidal erosion, & may have greatly reduced the rate of landfill exposure. Erosion at LF04 continues to be monitored annually through photography. Only 0.15 tons of debris was removed in 2009, a weight much closer to the weight removed in 2008 than the average of the previous decade.
Concentrations of COCs did not exceed the cleanup levels in well OU6MW-63, seep LF04SP-02, or downgradient seep LF04SP-02DG. A strong fuel odor & extensive iron staining were noted at both seeps. LF04SP-03 Benzene-25 ug/L. In 2007, the predicted cleanup date for seep LF04SP-02 was 2010, but now it is 2024 because the spike in benzene in 2008 is included in the analysis. Actual cleanup could occur much sooner if there are no further pulses of benzene.
Although the COCs have attenuated in groundwater at monitoring well OU6MW-63, the MNA field parameters in the well remain characteristic of fuel contamination (no DO, negative ORP, elevated conductivity, & substantial ferrous iron). Additionally, the seeps have a fuel odor, & substantial iron staining is present along the entire corridor from LF04SP-02 to its downgradient sampling location (LF04SP-02DG). Based on previous cleanup predictions for DRO, a reasonable assumption is that DRO is still present in groundwater & is responsible for these observations.
No COCs exceeded the cleanup level in monitoring well OU6MW-67. Benzene levels at this location have been less than the cleanup level since 1999, & all other LF04 South COCs have been less than cleanup levels since 1996. However, the MNA field parameters in OU6MW-67 remain characteristic of fuel contamination, probably reflecting the continued presence of GRO & DRO. When these parameters were monitored from 1999 to 2007, GRO levels in this monitoring well exceeded cleanup levels while DRO concentrations hovered near the cleanup level.
Recommendations for future monitoring at LF04 South are as follows: Change the frequency of sampling for monitoring well OU6MW-63 to every 5 years, per the decision tree for upgradient wells. OU6MW-63 can now be considered an upgradient well due to the lack of contamination since 2006. The next planned sampling event for well OU6MW-63 is in 2010. However, based on the lack of COCs, sample collection at this frequency is not necessary, & the next sample should be scheduled for 2012 to coincide with other wells in the area on a 5-year schedule.
Sample monitoring well OU6MW-67 for WP14 COCs only & change the frequency of sampling to every 5 years, per the decision tree for upgradient wells. The 2009 sample results for LF04 COCs confirmed that methylene chloride & 1,2,-DCA do not exceed the cleanup levels & are no longer a concern in this well. The well now can be considered an upgradient well for WP14 due to the lack of WP14 COCs since 2000. The next planned sampling event for monitoring well OU6MW-67 is in 2011. However, based on the lack of COCs, sample collection at this frequency is not necessary, & the next sample should be scheduled for 2012 to coincide with other wells in the area on a 5-year schedule.
Sample monitoring well OU6MW-61 for LF04 South COCs. This well had the highest concentration of benzene & 1,2-DCA during the last monitoring event in September 1994. This monitoring well is perched in a shallow aquifer but is included as part of LF04 South. Sample collection could be scheduled in 2012 or sooner, in order to provide data for the next 5-year review. |
Louis Howard |
| 3/12/2010 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (ADEC) has received the draft monitoring report for review & comment on March 3, 2010. Below are ADEC’s comments regarding the report which covers eight sites: LF02 (CS DB Hazard ID 2770), LF04 (CS DB Hazard ID 1804), WP14 (CS DB Hazard ID 639), ST36/66 (CS DB Hazard ID 1793), ST41 (CS DB Hazard ID 429), ST61 (CS DB Hazard ID (2747), ST69 (CS DB Hazard ID 1795), DP98 (CS DB Hazard ID 2595) & ten GW plumes in Zone 1.
Table 3-2 Contaminants of Concern & Cleanup Levels in LF04 South GW Seeps Page 3-11: The table states as the “Basis for Cleanup Level”: OU6 ESD, Primary drinking water MCL, 40 CFR 141.61. ADEC disagrees. The OU6 ESD’s main purpose was as follows-
1. “This ESD changes the conditions when operation of the HVE system can be discontinued & when the focus can be shifted to MNA of the site.[SD15]”
2. “This ESD establishes 18 AAC 75.345 as a chemical-specific ARAR for LF02 & SD15 which results in a new cleanup level for 1,1,2,2-tetrachloroethane. The new remediation goal for 1,1,2,2-tetrachloroethane in GW at LF02 & SD15 will be 4 µg/L.”
3. “This ESD clarifies the LUCs at the individual sites & describes how the LUCs will be implemented & maintained [WP14 GW & Soil LUCs, LF04 North/Beach Soil LUCs, SD15 Perched Aquifer GW LUCs, & LF02 GW LUCs].”
The regulatory basis for LF04 South groundwater (GW) & seeps did not change nor did it change the Basewide GW Monitoring Program’s fundamental purpose which is still applicable for each of the Zones 1, 2 & 3. The Basewide Monitoring Program was established to integrate [all] the needs of multiple environmental programs & compliance issues included in the FFA, State-Elmendorf Environmental Restoration Agreement (SERA) [i.e. contaminants such as gasoline range organics, diesel range organics, & residual range organics which are regulated under 18 AAC 75 & 18 AAC 78], CERCLA regulations & the Resource Conservation & Recovery Act (RCRA).
ADEC requests the USAF, ADEC & EPA RPMs once again discuss the need to monitor DRO & GRO in GW at LF04 & other sources which are co-mingled or known to have fuel contamination associated with the CERCLA COCs memorialized in Record of Decisions. ADEC requests the Air Force add ADEC Table C (18 AAC 75) as a Basis for Cleanup Level in table 3-2. Additionally, it appears the OU6 ESD is not a basis for cleanup level at LF04 South GW & seeps & should be removed from the table.
Table 3-3
2007 Versus 2009 Sampling Program at LF04 South Page 3-12: ADEC requests the Air Force ensure that it is analyzing for TAH & TAqH at the two seeps associated with LF04SP-03 & LF04SP-04 as well as any other COCs since it is not apparent from the table what COCs are being analyzed.
OU6MW-46 is screened below the water table, with the PDB [placed] at screen level. ADEC requests the Air Force discuss the significance of this monitoring well’s top of the well screen being below the water table & impacts to monitoring GW at WP14 given the main contaminants are not benzene & ethylbenzene (commonly associated with petroleum contamination). It appears that monitoring well OU6MW-46 has a saturated interval of 34.37 feet (Appendix A RPO Report 2006 Zone 1 Annual Remedial Process Optimization Report).
ADEC requests the RPMs discuss the future use of multiple PDB samplers installed vertically across the screened or open interval to determine the zone of highest concentration & whether contaminant stratification is present. In lieu of this, ADEC requests the RPMs discuss the use of a PDBs in conjunction with borehole flow meters or other techniques to characterize vertical variability in hydraulic conductivity & contaminant distribution as discussed above by USGS & ESTCP.
3.7.1 Implications of Contaminant & Geochemical Monitoring Page 3-17: ADEC requests the Air Force provide an explanation or a memorandum to the site file as an appendix to the document on why DRO & GRO were eliminated from the monitoring program as previously agreed to in a January 14, 2003 meeting with ADEC, USAF & EPA.
3.8 Summary & Recommendations for LF04 Pages 3-18 & 3-19: ADEC concurs with the most of the recommendations for LF04 South & WP14. It appears that GRO & DRO contamination will be an issue at LF04 under State of Alaska regulations. ADEC agrees that GRO & DRO are not listed as contaminants of concern in GW under CERCLA (Table 3.3-7 1997 OU6 ROD) nor were they analyzed for in 2009 despite a previous agreement between ADEC, USAF & EPA to monitor for them in 2004 (reference: Elmendorf Basewide Monitoring Program January 14, 2003 meeting minutes) at sources associated with fuel plumes.
It should be noted that DRO & jet fuel were monitored prior to 1999 & reported above GW cleanup levels for LF04/WP14 (See August 1996 Basewide Monitoring OU6-Rounds 1 & 2, Table 2-3 Summary of Results for Organic Constituents Above the Detection Limit). |
Louis Howard |
| 3/24/2010 |
Document, Report, or Work plan Review - other |
EPA has reviewed the Draft Zone 1 Field Activities Report, February 2010, Elmendorf A.F.B., Alaska and has the following comments:
General: There appear to be several significant issues that need further discussion among the RPMs as a result of interpretations and conclusions made in this Report or practices described in this Report. The proper use of PDBs and the rationale for their use seems to be unclear. There also could be an issue with the consistency of their use. The purpose of a Base-wide Monitoring Program should be to integrate all info on all contaminants and not deal with CERCLA COCs, alone. This Report seems to take" liberties" with the interpretation of the OU6 ESD; EPA agrees with the ADEC clarification of the purpose of the ESD in their comments on the above Report. The QA Lab reports, as an Appendix to this Report outline flagged issues dealing with sample temperature and volatile organic analysis (VOA) collection discrepancies that compromise the data in this Report and cast doubt on adherence to Management Plan SOPs.
Specific:
1.1 2009 Zone 1 Project Objectives Page 1-1 EPA agrees with the comments made by ADEC . The Zone or "Basewide Monitoring Plan" should deal with all programs, otherwise we would have only OU Monitoring Plans.
1.3.1 Ground Water and Surface Water Sampling Page 1-7 Since technique and consistency of sampling appears to be an issue, EPA agrees with ADEC suggestions to include SOPs as an appendix to work plans. This section calls into question the value and use of PDB sampling. This is a topic for FFA discussion and possibly consultant briefing.
Table 3-2 Contaminants of Concern and Cleanup Levels in LF04 South Groundwater Seeps Page 3-11: EPA agrees with ADEC's clarification of the purpose of the ESD.
Table 3-3 2007 Versus 2009 Sampling Program at LF04 Page 3-12: The issue of the need and purpose of PDB sampling needs to be discussed by the RPMs. This report places doubt on the location and use of these PDBs.
3.7.1 Implications of Contaminant and Geochemical Monitoring Page 3-17: The need for including GRO and DRO needs to be re- visited by the RPMs.
3.8 Summary and Recommendations for LF04 Pages 3-18 and 3-19: Same issue as above.
Appendix C Sample Summary and Cooler Receipts Pace Analytical Services noted head space non-compliance for VOA samples from cooler AAT240 , cooler AAF842, cooler AAD995, ,AAD783 ,AAT317.
This calls into question data validity and VOA collection technique. Also, coolers "To Where"," 000801 Can You", were beyond temperature controls. Data Validation and QA should be the first step before writing a Report |
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 (Attachlnent 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 ofconcem (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 (TAH, 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 |
| 6/10/2010 |
Update or Other Action |
Staff received the Source LF04 Operations and Maintenance Plan for review and comment.
This Operations and Management (O&M) Plan describes activities, procedures, and requirements for cleanup activities at Landfill (LF) 04 on Elmendorf Air Force Base (EAFB), Alaska. The effort is performed in support of the 3rd Civil Engineer Squadron (3 CES)/Asset Management Flight, Natural Resources Element, Cleanup Section (CEANR).
This LF04 O&M Plan’s objectives are to:
Consistently monitor and measure changes occurring at LF04 so that future planners will have an improved base of knowledge upon which to make decisions and develop policies regarding the management of LF04.
Identify activities to monitor, evaluate, and maintain LF04 to support selected remedy and gather data to evaluate the effectiveness of the remedy during subsequent Five-Year Reviews.
Objectives for each activity identified in this O&M Plan are presented below:
Site Access – Identify site access routes through EAFB and through the Port of Anchorage. Identify and provide guidance in complying with requirements for accessing the site and for performing work on EAFB.
Debris Monitoring and Classification – Identify, quantify, and track visible debris at LF04 to further characterize the landfill.
Quantify and describe visible debris at the site, including all suspect ordnance and explosive waste (OEW), unexploded ordnance (UXO), medical waste, and potentially hazardous materials.
Survey and photograph debris for location tracking and to determine whether individual landfill cells can be identified and characterized.
Monitor the location and track the migration of debris eroding from the LF04 bluff and identify specific source areas for contaminants and hazardous materials, if possible.
Maintain a database to track debris and assist in identifying and characterizing individual landfill cells.
Erosion Monitoring – Proactively monitor significant geological changes along the bluff.
Contaminant Monitoring – Monitor chemical concentrations in soil and sediment, where applicable. Determine whether detected contaminant concentrations are related to individual landfill cells.
Debris Removal – Perform annual debris removal in accordance with ROD requirements to prevent the accumulation of fallen debris and reduce the chance of human or wildlife contact with the debris.
Receptor Monitoring - Monitor the presence and frequency of visitation by humans and wildlife to the LF04 bluff area. Determine whether visitors could potentially be exposed to hazardous materials.
RECORD OF DECISION REQUIREMENTS-The ROD, as modified by the LF04 Memorandum to the Site File, specifies the following requirements:
LF04 Landfill debris on Port of Anchorage fill that is adjacent to LF04 will be removed annually as the specific remedy for this area.
The removal of debris will include all LF04 landfill material that has fallen onto the newly constructed Port of Anchorage fill and can be reasonably collected for disposal, as well as debris on the bluff slope or other low-lying areas that can be accessed and removed without hazard.
Hazardous materials encountered during the annual removal events will be handled according to appropriate regulations.
The removal of fallen debris from LF04 is expected to continue annually for 30 years or as long as the landfill remains subject to erosional action. Five-Year Reviews will assess the protectiveness of the remedial action, including an evaluation of any changed site conditions.
SCHEDULE
Debris removal will occur annually during the summer period.
PROJECT OBJECTIVES
Following are the objectives of the LF04 field sampling program:
Monitor for potential changes in chemical concentrations in soil and sediment, where applicable.
Determine whether chemical concentrations measured in soil and sediment can be related back to individual landfill cells.
Characterize waste streams generated as a result of debris removal activities.
Assess the potential for exposure of recreational visitors to hazardous materials at the beach and assess any potential risk to recreational visitors when they take collectible debris from the site.
Generate sufficient chemical information to aid in determining if the remedy identified in the Record of Decision (ROD) continues to be protective of human health and the environment (USAF 1997). |
Louis Howard |
| 6/21/2010 |
Document, Report, or Work plan Review - other |
Staff reviewed and approved the LF04 Operations and Maintenance Plan. |
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 I field work activities for 2010 were complete. She provided some highlights of this summer's field work. At landfill(LF) 04 approximately 0.25 tons (500 lbs) of solid, non-hazardous debris was removed from the base of the LF04 bluff This is the 3rd year in a row that 0.25 tons or less has been removed, which is a 99% reduction from the previous lO-year average of 16.5 tons/year.
JBER Community Involvement Plan - Ms. Renee Wright explained the importance and upcoming project activities that will be conducted in an effort to ensure that our community relations activities for JBER incorporates community concerns. In Jan 2010, an interim JBER Community Involvement Plan was published that combined previous plans from Fort Richardson and Elmendorf. In an effort to complete the interim document prior to initial operational capability (IOC), we delayed the community survey requirement until after the stand-up of the joint base.
A contract was awarded in Sep 2010 to conduct all aspects of the community survey, including preparing a survey results report and a final JBER Community Involvement Plan. The community survey is anticipated to. begin in Spring 2011. The final reports will be added to the administrative record and will be available to the public through the information repository.
Land Use Controls (LUCs) Update to Wing Instruction - Ms. Wright discussed the update
being made to a Wing Instruction that addresses LUCs throughout JBER. The 673d Air Base
Wing Instruction is being updated to incorporate both JBER-Richardson and Elmendorf LUC
programs and will result in a single document with the roles and responsibilities for each unit involved in a project being conducted at a site with LUCs. The final Instructio.n is expected in Spring 2011. |
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 (South) - Access to groundwater at LF04 South will be institutionally controlled. LF04 is currently designated as a "restricted use area" in the Base General Plan. This designation provides for recreational use of the parcel (e.g., cross country skiing) and for construction of unmanned facilities such as a parking lot, storage building, or taxiway, but prohibits the construction of any sort of manned facility such as an office building or a residence. Drilling into the shallow aquifer is also restricted by the Base General Plan to prohibit residential or agricultural use of contaminated groundwater.
Soil (North) - Access to soil at LF04 North will be institutionally controlled. LF04 is
currently designated as a "restricted use area" in the Base General Plan. This designation
provides for recreational use of the parcel (e.g., cross country skiing) and for construction
of unmanned facilities such as a parking lot, storage building, or taxiway, but prohibits
the construction of any sort of manned facility such as an office building or a residence.
Evaluation - A land use control inspection was performed and land use controls are in place and continue to be protective at LF04. The bluff area of LF04 has gated access and access to the base of the landfill is controlled by the Base and the Port of Anchorage.
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 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 |
| 2/7/2011 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 72782 name: dump |
Bianca Reece |
| 2/10/2011 |
Update or Other Action |
Zone 1 Draft Field Activities Report received. Debris removal continues annually from the base of the bluff where debris can be safely accessed & removed without hazard. Soil samples are collected every five years in support of the 5-year review process to determine whether contaminant concentrations have changed since the ROD, but sediment samples are no longer collected from the beach area because the beach is covered by Port of Anchorage fill.
On 7 & 8 September 2010, approximately 500 pounds (0.25 tons) of solid, nonhazardous debris was removed from the site.
LF04 South
The MNA parameters in wells OU6MW-61 & OU6MW-63 showed low DO (0.65 to 1.22 milligrams per liter [mg/L]), somewhat reducing ORP (-80.4 to -76.0 millivolts [mV]), high conductivity (901 to 1,045 microSiemens per centimeter [µS/cm]), & very high ferrous iron (>3.3 mg/L), typical of in-plume conditions for fuel spills. Well OU6MW-61 exceeded cleanup levels for benzene, but chlorinated COCs detected in 1994 were not present in 2010.
Levels of COCs did not exceed the cleanup levels in OU6MW-63. Downgradient from this well, seep LF04SP-02 exhibited an increase in benzene, which exceeded the cleanup level, but seep LF04SP-02DG did not show the same increase or exceed any cleanup levels. A strong fuel odor & extensive iron staining were noted at both LF04SP-02 & LF04SP-02DG.
In OU6MW-63 & seep LF04SP-02, benzene exhibited gradually declining trends from 1999 through 2005 or 2006 & then dropped precipitously in 2006. Seep LF04SP-02 rebounded to previous benzene & ethylbenzene in 2008 & in 2010. The statistical geometric regressions for benzene in OU6MW-63 & in seep LF04SP-02 predict cleanup dates of 2008 & 2062, respectively. For OU6MW-63, the geometric regression analysis confirms that the benzene plume has passed this well.
In 2007, the predicted cleanup date for seep LF04SP-02 was 2010, but the rebound in benzene since then have caused the estimated cleanup dates to advance to 2024 & then to 2062. The low correlation coefficient of 0.02 shows that the data do not exhibit a significant trend. Estimated cleanup dates will continue to fluctuate until a steady downward trend becomes established.
The return of high benzene in seep LF04SP-02 in 2010 shows that plume behavior is more than the result of high water levels leading to increased dissolution of residual product in the contaminated smear zone. Benzene was high in 2008, which was a very wet year with high GW levels, & was high again in 2010, which was a normal year, but benzene was low in 2009, which was also a normal year. Instead, other reservoirs of contamination such as that perched around OU6MW-61 may be tapped periodically & contribute to discharge at the seep.
MNA parameters in OU6MW-63 remain characteristic of fuel contamination (no DO, negative ORP, elevated conductivity, & substantial ferrous iron). OU6MW-61 exhibits similar values for MNA parameters & exceeds the benzene cleanup level. Additionally, the seep has a fuel odor, & substantial iron staining is present along the entire corridor from LF04SP-02 to its downgradient sampling location (LF04SP-02DG). Based on previous predictions for DRO, a reasonable assumption is that DRO is still present in GW & is responsible for these observations.
In LF04 South, conditions and trends in groundwater are as follows:
Upgradient of seep LF04SP-02. The source has attenuated in the vicinity of OU6MW-63. OU6MW-61, not sampled since 1994, contained benzene at 1,300 µg/L and might be contributing to the high benzene (56 µg/L) in seep LF04SP-02 if the two are hydraulically connected. The water level in OU6MW-61 was approximately 30 feet above the continuous water table, indicating a perched zone of saturation that might or might not be connected to the seep. Benzene has yet to establish a trend at seep LF04SP-02, but all other COCs have always been less than cleanup levels. A defensible cleanup prediction will be possible when a steady downward trend becomes stablished.
Recommendations for LF04 South are as follows:
Integrate OU6MW-61 into the sampling plan. The well should be sampled annually, starting with the next sampling event occurring in 2011 or as soon as it can be added to the program. In accordance with the 1997 OU 6 ROD, the well should be sampled for the LF04 COCs and MNA parameters.
Implement an isotopic analysis study in 2012 with deuterated water or other tracer to
determine the connectivity between OU6MW-61 and seep LF04SP-02. If it is shown that OU6MW-61 is a perched aquifer, proceed with evaluation for in situ chemical oxidation. Reduce sampling for OU6MW-63 from annually to once every 5 years.
Increase seep sampling for LF04SP-02 from annually to quarterly per Appendix A of the OU6 Memorandum to the File.
Sample OU6MW-63 for DRO and LF04SP-02 for TAH/TAqH to evaluate whether cleanup levels have been met. |
Louis Howard |
| 2/10/2011 |
Update or Other Action |
Zone 1 Draft Field Activities Report received. Debris removal continues annually from the base of the bluff where debris can be safely accessed & removed without hazard. Soil samples are collected every five years in support of the 5-year review process to determine whether contaminant concentrations have changed since the ROD, but sediment samples are no longer collected from the beach area because the beach is covered by Port of Anchorage fill.
On 7 & 8 September 2010, approximately 500 pounds (0.25 tons) of solid, nonhazardous debris was removed from the site.
LF04 South
The MNA parameters in wells OU6MW-61 & OU6MW-63 showed low DO (0.65 to 1.22 milligrams per liter [mg/L]), somewhat reducing ORP (-80.4 to -76.0 millivolts [mV]), high conductivity (901 to 1,045 microSiemens per centimeter [µS/cm]), & very high ferrous iron (>3.3 mg/L), typical of in-plume conditions for fuel spills. Well OU6MW-61 exceeded cleanup levels for benzene, but chlorinated COCs detected in 1994 were not present in 2010.
Levels of COCs did not exceed the cleanup levels in OU6MW-63. Downgradient from this well, seep LF04SP-02 exhibited an increase in benzene, which exceeded the cleanup level, but seep LF04SP-02DG did not show the same increase or exceed any cleanup levels. A strong fuel odor & extensive iron staining were noted at both LF04SP-02 & LF04SP-02DG.
In monitoring well OU6MW-63 & seep LF04SP-02, benzene exhibited gradually declining trends from 1999 through 2005 or 2006 & then dropped precipitously in 2006. Seep LF04SP-02 rebounded to previous benzene & ethylbenzene in 2008 & in 2010. The statistical geometric regressions for benzene in OU6MW-63 & in seep LF04SP-02 predict cleanup dates of 2008 & 2062, respectively. For OU6MW-63, the geometric regression analysis confirms that the benzene plume has passed this well.
In 2007, the predicted cleanup date for seep LF04SP-02 was 2010, but the rebound in benzene since then have caused the estimated cleanup dates to advance to 2024 & then to 2062. The low correlation coefficient of 0.02 shows that the data do not exhibit a significant trend. Estimated cleanup dates will continue to fluctuate until a steady downward trend becomes established.
The return of high benzene in seep LF04SP-02 in 2010 shows that plume behavior is more than the result of high water levels leading to increased dissolution of residual product in the contaminated smear zone. Benzene was high in 2008, which was a very wet year with high GW levels, & was high again in 2010, which was a normal year, but benzene was low in 2009, which was also a normal year. Instead, other reservoirs of contamination such as that perched around OU6MW-61 may be tapped periodically & contribute to discharge at the seep.
MNA parameters in OU6MW-63 remain characteristic of fuel contamination (no DO, negative ORP, elevated conductivity, & substantial ferrous iron). OU6MW-61 exhibits similar values for MNA parameters & exceeds the benzene cleanup level. Additionally, the seep has a fuel odor, & substantial iron staining is present along the entire corridor from LF04SP-02 to its downgradient sampling location (LF04SP-02DG). Based on previous cleanup predictions for DRO, a reasonable assumption is that DRO is still present in GW & is responsible for these observations.
In LF04 South, conditions and trends in groundwater are as follows:
Upgradient of seep LF04SP-02. The source has attenuated in the vicinity of OU6MW-63.
OU6MW-61, not sampled since 1994, contained benzene at 1,300 µg/L and might be contributing to the high benzene (56 µg/L) in seep LF04SP-02 if the two are hydraulically connected. The water level in OU6MW-61 was approximately 30 feet above the continuous water table, indicating a perched zone of saturation that might or might not be connected to the seep. Benzene has yet to establish a trend at seep LF04SP-02, but all other COCs have always been less than cleanup levels. A defensible cleanup prediction will be possible when a steady downward trend becomes established.
Recommendations for LF04 South are as follows:
Integrate OU6MW-61 into the sampling plan. The well should be sampled annually,
starting with the next sampling event occurring in 2011 or as soon as it can be added to
the program. In accordance with the 1997 OU 6 ROD, the well should be sampled for the
LF04 COCs and MNA parameters (USAF 1997).
Implement an isotopic analysis study in 2012 with deuterated water or other tracer to
determine the connectivity between OU6MW-61 and seep LF04SP-02. If it is shown that
OU6MW-61 is a perched aquifer, proceed with evaluation for in situ chemical oxidation.
Reduce sampling for OU6MW-63 from annually to once every 5 years.
Increase seep sampling for LF04SP-02 from annually to quarterly per Appendix A of the
OU6 Memorandum to the Site File (USAF 2003c).
Sample OU6MW-63 for DRO and LF04SP-02 for TAH/TAqH to evaluate whether
cleanup levels have been met. |
Louis Howard |
| 2/24/2011 |
Document, Report, or Work plan Review - other |
Staff reviewed and approved the recommendations in the draft field activities report for this source area in Operable Unit 6. |
Louis Howard |
| 5/19/2011 |
Update or Other Action |
Wing Instruction 32-7003 dated May 19, 2011 Land Use Control Management. OPR: 673 CES/CEANR Certified by: 673 CEG/CC (Col Russell R. Hula). This instruction implements AFPD 32-70, Environmental Quality, & is used in conjunction with AFIs 32-7020, The ERP, 32-7066, Environmental Baseline Surveys in Real Estate Transactions, & 673ABWI 32-1007, Safeguarding Utilities From Damage.
It prescribes the processes & responsibilities for the management of & compliance with land use controls on Joint Base Elmendorf-Richardson (JBER) & applies to all military & civilian organizations that occupy facilities, or conduct business, on the installation. This publication does not apply to the USAF Reserve or Air NG units & members. The current land use control areas can be found on the Environmental Restoration map located on the GeoBase webpage.
General:
1.1. Land use controls (LUC), such as limitations on access, water use, excavations, & property transfers, will supplement engineering controls as appropriate for short-term & long-term mgt to prevent or limit human & environmental exposure to hazardous substances, pollutants, or contaminants.
Examples include limitations on the depth & location of excavations, prohibition of or restrictions on well drilling & use of GW, mgt. of excavated soils, & prohibition of certain land uses. LUCs, often used interchangeably with (ICs), are administrative, procedural, engineering, & regulatory measures to control human access to & use of property.
1.2. LUCs were established at JBER to prevent exposure to contaminated soil & water, based on agreements between the military services & the EPA & the ADEC. LUCs are used to reduce the potential for exposure to hazardous substances or to enhance the protectiveness of a soil &/or water cleanup remedy. They include restrictions on the use of portions of the shallow aquifer south of the Elmendorf Moraine, limitations on the types of buildings allowed in certain areas – primarily occupancy limitations, & land use designations for certain areas as recreational use only.
The LUCs have been implemented at several sites & operable units (OU) as part of the ERP. LUCs were established for DP98 & OUs 1, 2, 4, 5, & 6 on former Elmendorf AFB property in their respective records of decision (ROD), as a component of the selected cleanup remedy. LUCs were also established for restoration & compliance sites formerly part of Fort Richardson in their respective RODs or Decision Documents. LUCs must be in place as long as a property is not available for UU or UE & may include temporary or permanent restrictions or requirements. When all cleanup goals have been achieved for a given site, temporary controls, such as GW use restrictions, may be removed.
2. Responsibilities:
2.1. JBER personnel, tenants, or contractors whose projects or activities require excavation in areas where site-specific LUCs are in effect will comply with all LUCs, 673ABWI 32-1007, & applicable AF instructions. Base contractors & tenant organizations will have LUC compliance requirements incorporated into their contracts & interagency agreements, as will be necessary. Failure to comply with LUCs will be grounds for penalty, in accordance with provisions specified in applicable contract documents. At project completion, the JBER organization or contractor will sign a certification of LUC compliance & return the compliance statement to 673 CES/CEANR.
2.2. The 673d Civil Engineer Squadron (673 CES):
2.2.1. Asset Management Flight (673 CES/CEA):
2.2.1.1. Natural Resources Management (673 CES/CEAN):
2.2.1.1.1. Environmental Restoration (673 CES/CEANR):
2.2.1.1.1.1. Will provide GW & site-specific LUC requirements throughout the installation & identify any known soil contaminated sites & monitoring wells for the area of the proposed project.
2.2.1.1.1.2. Will conduct annual site visits to ensure compliance with LUCs during project implementation.
2.2.1.1.1.3. Will conduct 5-year reviews, at 5-year intervals, or as required by any subsequent RODs.
2.2.1.1.1.4. Will prepare annual LUC compliance reports & submit reports to ADEC & USEPA by 1 February each year.
2.2.1.1.1.5. Will disseminate LUC information to personnel involved in LUC mgt, including real property & 673 CES/CEPT for inclusion into GeoBase.
2.2.1.1.1.6. Will operate an active educational program that includes disseminating updated fact sheets & LUC information, providing notices through the installation intranet & the Arctic Warrior newspaper, & by briefing LUC mgt at project kick-off meetings; Environmental, Safety & Occupational Health Council meetings, & CEB meetings.
2.2.1.1.1.7. Will coordinate any changes in the base general plan (BGP), or real estate transactions, with USEPA & ADEC.
2.2.1.1.1.8. Will maintain copies of signed certificates of compliance, indicating requestor’s adherence to LUCs during project execution.
See site file for additional information.
|
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).
After JBER-Elmendorf was placed on the USEPA NPL, environmental restoration activities were separated into three separate management zones. Environmental Restoration Program Zone 1 Management Area covers the comparatively sparsely developed portions of JBER-Elmendorf to the west, north, & east of the airfield & administrative core of the base. Eleven sites are now managed under Zone 1: LF02, LF03, LF04, WP14, ST36/66, ST41, ST61, ST69, SS83, & DP98. LF02 & LF03 are located in the southeastern portion of the base, near the Boniface gate, whereas the remaining nine sites are distributed throughout the northwestern portion of the base, between the airfield & Knik Arm. GW contamination is tracked in nine plumes at these sites, & exposed landfill debris is of concern at LF04.
Six sites (LF02, LF03, LF04, WP14, ST41, & DP98) are administered under the Comprehensive Environmental Response, Compensation, & Liability Act (CERCLA), with USEPA oversight, & are governed by ROD. The five remaining sites (ST36/66, ST61, ST69, & SS83) are regulated according to State of Alaska requirements. GW COCs for most of the sites (WP14, ST36/66, ST41, ST61, & SS83) are fuel constituents (one or more of benzene, toluene, ethylbenzene, xylenes, or diesel-range organics [DRO]). These sites were contaminated by pipeline & storage tank leaks & past practices. The primary sources have been removed, leaving secondary sources comprised of residual fuel distributed in contaminated smear zones at the water table. Two sites have chlorinated-solvent GW COCs: LF04 (1,2-dichloroethane & methylene chloride, as well as fuel constituents), & DP98 (chlorinated solvents). The chlorinated solvents occur in shallow GW as dissolved contaminants at LF04 & in conjunction with a DRO contaminated smear zone at DP98.
The overall objectives of RA-O activities within the Zone 1 Management Area are to monitor the COCs & geochemical parameters affecting natural attenuation in GW plumes, & to detect contaminant migration patterns & provide early indication of unforeseen environmental or human health risks. Data quality objectives directly linked to Zone 1 project objectives are defined in the FSP & UFP-QAPP, within the SAP.
Additional entry requirements exist for access to JBER-Elmendorf Restoration Zone 1 sites LF04
and DP98. When accessing LF04 via the bluff road to the whale watching station, all individuals
must sign in and out on the visitor log at the locked gate. When accessing the base of the LF04
bluff via Denai’na Road (also known as “the Haul Road”) from JBER-Elmendorf, individuals
will notify the Port of Anchorage prior to entry and the 673d Security Forces Squadron prior to
return. LF04 can also be accessed directly through the Port of Anchorage. A letter listing all
contractor and subcontractor personnel requiring access to the site will be furnished to the guards at the Port of Anchorage security checkpoint.
Additional Zone 1 Management Area project objectives in 2011 include:
Evaluate & maintain the integrity of monitoring wells;
Evaluate GW flow characteristics while continuing to study trends in GW level with the monitoring wells; &
Evaluate erosion rates & characteristics of the LF04 bluff.
The activities to be performed under this TO include:
Collect & analyze GW & surface water samples;
Conduct GW level survey;
Perform maintenance of existing wells, as needed;
Install a maximum of 2 new/replacement GW wells;
Decommission a maximum of 5 damaged/redundant wells; &
Conduct LF04 erosion survey & debris removal.
|
Louis Howard |
| 8/4/2011 |
Document, Report, or Work plan Review - other |
Staff provided review comments on the Draft Work Plan Environmental Remedial Action – Operations & Long-Term Monitoring & Maintenance July 2011.
{The purpose of this project is to perform RA-O & LTM activities for several programs including sites distributed across both JBER-Elmendorf & JBER-Richardson. This Work Plan addresses remedial activities in JBER-Elmendorf Zones 1, 2, & 3 Mgt Areas, JBER-Elmendorf CRP sites, the JBER Elmendorf OU 1 Landfill, JBER-Richardson Multiple IRP Sites, & JBER-Richardson Poleline Road & OUE Armored Vehicle Maintenance Area (AVMA).
Field tasks performed will include groundwater, surface water, seep, sediment, & subsurface soil sampling. Also included are operation & maintenance (O&M) of an engineered Wetland Remediation System & landfill cap & routine landfill cap inspections & land use control (LUC) inspections. New GW monitoring wells will be installed & wells no longer being used will be properly abandoned. The field activities also include debris removal & erosion surveys, O&M of the EAFB Restoration Staging Facility, which is also commonly referred to as the “Contractor’s Yard.”]
5-3 Table 5-1: Whenever EDB is being analyzed for as a contaminant of concern, ADEC will require lead also be analyzed unless previously ruled out from prior sampling.
6-1 6.0: If the borings & samples are for demonstrating whether or not residual contamination in the vadose zone is below ADEC Method 2 Cleanup Levels, then it is not clear why total organic carbon (TOC) analysis is being performed nor for what purpose it would serve to close out the site. ADEC will require the TOC sample collection on JBER to be conducted in strict accordance with ADEC’s Technical Memorandum – 08-002 “Guidelines for Total Organic Carbon (TOC) Sample Collection & Data Reduction for Method Three & Method Four” (September 30, 2008).
For example: It is recommended that the sampling locations be selected at points surrounding (on each side of) the contaminated zone to ensure adequate characterization of the soil TOC variability. If the zone of contamination extends over a significant area, additional samples may need to be collected from the soil horizon below the impacted soils.
If the depth to seasonal high groundwater is more than 5 feet below the deepest contaminated vadose soil statum, one sample must be collected from the deepest contaminated vadose soil stratum & a second sample collected from 5 feet below the contaminated soil stratum. This will result in a total of eight (8) TOC samples.
If the contamination extends to within 5 feet, but not to the seasonal high groundwater level, one sample must be collected from the deepest contaminated soil stratum & one sample immediately adjacent to the groundwater interface. This will result in a total of eight (8) TOC samples.
If the contamination extends to or below the seasonal high groundwater level, the TOC samples must be collected immediately adjacent to the groundwater interface. This will result in a total of four (4) TOC samples.
Supporting documentation must be provided to ADEC for the proposed site specific TOC value. Supporting documentation includes, at a minimum, a narrative of site characterization activities, a diagram depicting boring locations & sample collection depths in relation to the contaminated soil mass, boring logs & soil description for TOC & contaminated zone sampling points; tabulated sample results, laboratory reports including results of all TOC analyses; & the proposed mean TOC value.
8-8 & 8-9 8.2.2: Water quality parameters are considered stable when 3 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), &
• ± 10% for turbidity.
A minimum of three (minimum of four if using temperature as an indicator) of these parameters should be monitored & 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 & 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 & 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 & analyzed whenever volatile organic samples are required.” ADEC will require 1 trip blank per analysis & 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). |
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.
OU6:
Site LF04
Groundwater (South) - Access to groundwater at LF04 South will be institutionally
conlrolled. LF04 is currently designated as a "restricted use area" in the Base General
Plan. This designation provides for recreational use of the parcel (e.g., cross country
skiing) and for construction of umnanned facilities such as a parking lot, storage building,
or taxiway, but prohibits the construction of any sort of manned facility such as an office
building or a residence. Drilling into the shallow aquifer is also restricted by the Base
General Plan to prohibit residential or agricultural use of contaminated groundwater.
Soil (North) - Access to soil at LF04 North will be institutionally conlrolled. LF04 is
currently designated as a "restricted use area" in the Base General Plan. This designation
provides for recreational use of the parcel (e.g., cross country skiing) and for construction
of unmanned facilities such as a parldng lot, storage building, or taxiway, but prohibits
the construction of any sort of manned facility such as an office building or a residence.
Evaluation - LUCs are in place and continue to be effective at LF04. 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.
TIle bluff area of LF04 has gated access, which is controlled by the Base. Access to
the base of the landfill is gated and controlled by the Base and the Port of Anchorage. |
Louis Howard |
| 4/10/2012 |
Update or Other Action |
Draft 2011 Zones 1, 2, 3 annual report received.
On 28 September 2011, all accessible debris was removed, including metal, glass bottles, and burned debris. Travel to and from the site was conducted through the gate on Dena’ina Road between JBER-Elmendorf and the Port of Anchorage. The removal included only exposed debris that could be removed safely without disturbing the tidelands, vegetation, and stabilization of bluff face. All work was conducted from the base of the bluff.
The work crew collected debris in 5-gallon buckets and hand-carried it to a central collection point for transport offsite. Approximately 840 pounds (0.42 tons) of solid, nonhazardous debris was removed from the site. No potentially hazardous waste items were identified during debris removal activities. Debris was transported offsite and disposed of at the Anchorage.
Monitoring well OU6MW-61 exceeded cleanup levels for benzene, but chlorinated COCs detected in 1994 were not present in 2010 or 2011. However, it should be noted that nondetect results for 1,2-DCA [0.005 mg/L] and methylene chloride [0.066 mg/L] had limits of detection that exceeded the cleanup levels in 2011. This was due to dilutions required during analysis for high concentrations of other analytes in the sample, such as benzene.
Concentrations of COCs did not exceed the cleanup levels in monitoring well OU6MW-63. Downgradient from this well, a decrease in benzene concentrations was observed at seep LF04SP-02, which was below the cleanup level. Concentrations of COCs were ND or below cleanup levels at seep LF04SP-02DG. A strong fuel odor 1603 and extensive iron staining were observed at both LF04SP-02 and LF04SP-02DG.
LF04 North, minimal debris was present in 2011. The Port of Anchorage 1708 expansion project has reduced the area of the bluff exposed to tidal action, which seems to have slowed the rate of exposure of debris. Annual debris removal will continue, but the scale of the effort will likely resemble that of the past three years rather than the preceding decade. A new cleanup date for LF04 North will be evaluated during the next five-year review. No changes to LF04 North debris monitoring and removal are recommended for 2011.
In LF04 South, conditions and trends in groundwater are as follows:
• Upgradient of seep LF04SP-02. The source has attenuated in the vicinity of OU6MW-63. OU6MW-61, not sampled since 1994, contained benzene at 1,300 µg/L and might be contributing to the benzene (4 µg/L) in seep LF04SP-02 if the two are hydraulically connected. The water level in OU6MW-61 was approximately 30 ft above the continuous water table, indicating a perched zone of saturation that might or might not be connected to the seep. Benzene has yet to establish a trend at seep LF04SP-02, but all other COCs have always been less than cleanup levels. A defensible cleanup prediction will be possible when a steady downward trend becomes established.
Recommendations for LF04 South are as follows:
• Reduce sampling for OU6MW-63 from annually to once every five years.
• Sample OU6MW-63 for DRO and LF04SP-02 for TAH/TAqH to evaluate whether cleanup levels have been met.
• Reduce sampling for OU6MW-67 from once every two years to once every five years. |
Louis Howard |
| 6/6/2012 |
Update or Other Action |
Draft Project Management Plan received which includes LF004 (OOO9EA) LF04 Knik Bluff Landfill (IRP).
Performance objective: Optimized exit strategy for Site Closure.
Performance Indicators
Prepare an approved Optimized Exit Strategy Workplan by August 2012
Prepare an approved Addendum to Current LTM Workplan by September 2012
Prepare and conduct an approved 2012 CERCLA 5-Year Review by October 2012
Prepare an approved Site Investigation Workplan by December 2012
Conduct 2012 RA-O Monitoring Event with an approved Annual RA-O Monitoring Event Memo by February 2013
Coordinate, mobilize, and execute Site Investigation concurrently with 2013 RA-O Monitoring by July 2013
Prepare an approved Site Investigation Report by January 2014
Continue RA-O Monitoring and CERCLA 5-Year Reviews as scheduled to meet ROD and ADEC
requirements
Prepare an approved a Site Characterization Workplan and coordinate, mobilize and execute Site Characterization
Prepare an approved Site Characterization Report and EE/CA for MSW Removal
Prepare and implement an approved Optimized Exit Strategy Report to achieve SC
Potential Risk
Deficiencies in the landfill cap are identified; COCs increase.
Risk Mitigation
Cap repairs will be made as required, and treatment options to bring COC levels back to a
decreasing state will be evaluated.
Planned Approach
Develop Monitoring plan with an approved Annual Workplan detailing monitoring and debris removal
activities.
Implement and conduct annual groundwater monitoring, debris removal, and cap inspections.
Annual Monitoring Reports will document results of groundwater LTM with results of debris removal.
Develop and submit 5-Year Reviews (2012 and 2017). Prepare an approved Characterization Workplan
detailing geophysical survey approach.
Implement Characterization and complete geophysical survey.
Prepare an approved Characterization Report documenting the results of the geophysical
investigation with estimated quantities of solid waste and develop EE/CA for removal options and costs.
Prepare an approved an Optimized Exit Strategy Plan to achieve SC. |
Louis Howard |
| 3/1/2013 |
Institutional Control Update |
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 (South) - Access to groundwater at LF04 South will be institutionally controlled. LF04 is currently designated as a "restricted use area" in the Base General Plan. This designation provides for recreational use of the parcel (e.g., cross country skiing) and for construction of unmanned facilities such as a parking lot, storage building, or taxiway, but prohibits the construction of any sort of manned facility such as an office building or a residence. Drilling into the shallow aquifer is also restricted by the Base General Plan to prohibit residential or agricultural use of contaminated groundwater.
Soil (North) - Access to soil at LF04 North will be institutionally controlled. LF04 is
currently designated as a "restricted use area" in the Base General Plan. This designation
provides for recreational use of the parcel (e.g., cross country skiing) and for construction
of unmanned facilities such as a parking lot, storage building, or taxiway, but prohibits
the construction of any sort of manned facility such as an office building or a residence.
Evaluation -Inspection conducted on 29 Aug 12 and LUCs are in place and continue to be protective at LF04. The bluff area of LF04 has gated access, which is controlled by the Base. Access to the base of the landfili is gated and controlled by the Base and the Port of Anchorage.
|
Louis Howard |
| 4/1/2013 |
Document, Report, or Work plan Review - other |
EPA approves the Basewide UFP-QAPP.
The quality assurance (QA) review of the Final Base-wide Uniform Federal Policy - Quality Assurance Project Plan (UFP-QAPP) prepared by WESTON for the United States Air Force Joint Elmnendorf/Richardson, Alaska, dated, March 2013 has been completed.
All of US EPA Region 10's comments and concerns in the previous submissions were sufficiently
addressed in this Final QAPP.
The Final UFP-QAPP is now approved for use at the JEER site. Approval of this QAPP will expire in 5 years. Significant organizational or project goal changes must be documented in a QAPP Amendment or Addendum requiring the approval of US EPA and ADEC prior to implementation. |
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).
Debris Removal
The LF004 Debris Removal was conducted on 28 August 2012. WESTON removed approximately 50 pounds of material (three 5-gallon buckets) consisting of metal scrap, household items, & a tire. Since the Port of Anchorage expansion, debris removed in 2012 had a 94% reduction from the volume removed in 2011 which is a sign of bank stabilization. Tire tracks from construction activities were observed near the bluff where the road ends. The debris removal logbook & a photo log are included in Appendix A. Table 6-1 summarizes the debris quantities & types removed from 1997 to 2012.
Groundwater Sampling
During 2012, groundwater monitoring well OU6MW-63, & seeps LF04SP-02, LF04SP-02DG, LF04SP-03, & LF04SP-04 were sampled. Quarterly sampling was conducted at LF04SP-03 & began in the second quarter of 2012. All samples were analyzed for VOCs. Analytical results exceeded the OU6 ROD cleanup criteria in seeps LF04SP-04 & LF04SP-03 for benzene (16 µg/L & 7.4 µg/L, respectively). All other analytical laboratory sample results were below OU6 ROD cleanup criteria. Table 6-2 presents a summary of the results. Historic results are presented on Figure 6-1. The established monitoring schedule did not require sampling at OU6MW-61and OU6MW-67 in 2012.
A LUC inspection performed at LF004 on 29 August 2012 did not identify any issues.
Site Summary
In 2012, benzene concentrations at seep LF04SP-02 marks the second year in a row of decreasing levels of benzene to below clean-up criteria, after two past sample rounds of benzene exceedances in 2008 & 2010. A trend for benzene levels at LF04SP-02 has yet to be established. All other COCs are below cleanup levels at seep LF04SP-02. The downgradient seep (LF04SP-02DG) results have been below clean-up criteria since 2002 indicating that benzene has not been migrating vertically.
In 2012, OU6MW-63 was sampled, with all results below the OU6 ROD cleanup criteria. In 2011, it was recommended that sampling in OU6MW-63 be reduced from annually to once every five years, since the source has attenuated in the vicinity of the well; however the well was sampled erroneously in 2012.In 2011, it was also recommended that LF04SP-02 be sampled for TAH & TAqH to evaluate whether cleanup levels had been met.
TAH & TAqH samples include collecting & analyzing for PAHs & VOCs compound, however an error occurred on the 2012 work plan & the PAH analysis was omitted for LF04SP-02. LF04SP-02 will be sampled for TAH & TAqH in 2013. Additionally in 2011, it was recommended that sampling of OU6MW-67 be reduced from once every two years to once every five years. In 2013, seep LF04SP-02 will be sampled for TAH & TAqH constituents in order to evaluate whether cleanup levels have been met. No other changes to the remedial activities are being proposed for this site.
|
Louis Howard |
| 6/10/2013 |
Update or Other Action |
Draft Letter Work Plan received for review and comment.
The purpose of this letter work plan is to conduct quarterly, semi-annual, and annual environmental monitoring; an annual erosion survey and debris removal; land use control/institutional control (LUC/IC) inspections, and the necessary tasks related to the operation and maintenance of the Operable Unit (OU) 5 Wetland Remediation System. These programs include sites at both JBER-Elmendorf and JBER-Richardson.
In accordance with the most recent Source LF04 Operations and Management Plan (USAF, 2010) and LF04 Memorandum to the Site File (USAF, 2008), exposed debris at the base of the LF004 bluff will be surveyed during the spring and removed and appropriately disposed of during the late summer in the 2013 field season.
Access to the bluff must be requested and coordinated with the Port of Anchorage prior to entering the secured site. Also before contractor personnel enter the LF04 landfill area, base explosive ordnance disposal (EOD) personnel will be asked to conduct a sweep of the area to identify and remove any potentially dangerous ordnance. Site workers will also be EOD trained prior to going on-site. After clearance, the spring survey will classify and photograph all debris, establish its geodetic location, and manage any potentially hazardous findings. As part of the ongoing study of erosion at LF04, the survey will document the physical state of the bluff with a sequence of photographs of the bluff taken from the west.
All debris will be removed and appropriately disposed of after it is classified and geodetically surveyed in accordance with Source LF04 Operations and Management Plan (USAF, 2010). Nonhazardous debris fallen from the hillside will be loaded onto vehicles for transport to the onsite staging area. Debris will be transferred to appropriate disposal container (e.g., 55-gal drum, 5-gal bucket) at the onsite staging area for transport to an appropriate disposal center. All nonhazardous debris will be transported to the Anchorage Municipal Landfill for disposal. |
Louis Howard |
| 6/13/2013 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation has received the 2013 Letter Work Plan Addendum on June 10, 2013 for review and comment. One minor comment for the LUC/ICs Inspections at both CERCLA and State sites, ADEC will require photo documentation of the sites’ LUCs/ICs and inspections of major items on the checklists (where not strictly prohibited by concerns of national security) in addition to the inspection forms in Attachment 1A.
|
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 6
The EPA concurs that the remedy for OU 6 is currently short-term protective of human health and the environment because Land Use Controls are preventing exposure to contaminated groundwater and soil. Groundwater contaminants at sites LF04 South, WP14, and SD15 are not showing decreasing trends, therefore the levels will not meet cleanup goals by 2020 as specified in the Record of Decision (ROD) by 2020. In order for the remedy to be protective in the long term, EPA agrees alternative remedies should be evaluated under the process established in the FFA to accelerate attainment of cleanup levels in groundwater at OU6.
Additionally, 2-methylnapthalene was detected in the groundwater at WP14 at a maximum level of 630 micrograms per liter (ug/L) in sampling prior to the ROD, however a cleanup standard for this compound did not exist at the time of the ROD in 1997. A cleanup level for 2-methylnapthalene of 150 ug/L was established in groundwater by the State of Alaska under 18 AAC 75, Table C Groundwater Cleanup Tables in 2009. Land Use Controls for OU6 prohibit access to contaminated groundwater as a source of drinking water. EPA agrees with the recommendation to assess current concentrations of 2-methylnapthalene in groundwater at WP14, and to discuss the results of groundwater concentrations with EPA and Alaska Department of Environmental Conservation to determine if additional action is warranted. |
Louis Howard |
| 5/14/2014 |
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.
The annual LF004 debris removal was conducted on 18-19 September 2013. WESTON personnel removed approximately 960 pounds of debris material consisting of metal scrap, household items, vehicle related debris, and construction related debris. Directly prior to the LF004 debris removal, several large, high precipitation storms had moved through the Anchorage area. Several mass wasting events were evident along the Knik Arm bluff within the landfill area and outside of the landfill area. As a result, debris was mainly concentrated along an unnamed drainage just north of the Port of Anchorage expansion area and in the ditch at the base of the bluff along the Port expansion area.
Benzene concentrations at seep LF04SP-02 have been below the OU 6 ROD clean-up level and have decreased for three consecutive years. Prior to that, the benzene concentration at the seep
exceeded the clean-up level in 2008 and 2010. All other COCs are below cleanup levels at seep
LF04SP-02. However, the TAH and TAqH levels exceeded the 18 AAC 70 water quality standards in LF04SP-02. The downgradient seep (LF04SP-02DG) results have been below clean-up criteria since 2002 indicating that benzene has not been migrating vertically.
Monitoring well OU6MW-61, last sampled in 2011, has concentrations of COCs above the OU6 ROD cleanup levels. The 2011 Annual Report (USAF, 2012a) recommended that the sampling frequency for well OU6MW-67 be reduced from once every two years to once every five years. Results from 2013 sampling had a benzene concentration exceeding the OU6 ROD cleanup level for the first time since 1999. It is recommended this well be sampled again in 2014 to determine if benzene concentrations persist above the cleanup level. No other changes to the monitoring program are proposed for this site. |
Louis Howard |
| 6/4/2014 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft CERCLA GW report.
See comments regarding dig permits issued within the last 12 months. ADEC concurs with the recommendations for LF004. |
Louis Howard |
| 11/5/2014 |
Document, Report, or Work plan Review - other |
EPA provided comments on the draft CERCLA Report.
Comment: The graphical plume boundaries as displayed on Figure 6.1 are unsupported as there are in many cases only one or two wells that define each plume. More specific comments on this cluster of plumes was made on the site characterization workplan for WP-14 (summer 2014) |
Louis Howard |
| 7/23/2015 |
Update or Other Action |
Draft Annual Field Activities Report received for review and comment.
SITE SUMMARY AND RECOMMENDATIONS
Benzene concentrations at seep LF04SP-02 and monitoring well OU6MW-67 have increased and exceed the OU6 ROD cleanup level of 5 µg/L. Prior to 2014 concentrations at seep LF04SP-02 were been below the clean-up level and exhibited a decreasing trend for three consecutive years. Because of increased benzene and ethylbenzene concentrations the TAH and TAqH levels exceeded the 18 AAC 70 water quality standards in LF04SP-02. The downgradient seep (LF04SP-02DG) results have been below clean-up levels since 2002 indicating that benzene has not been migrating vertically.
Five-Year Review
Areas in OU6 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 LF004 documented during the first five-year review period in 1998, or for
the second five-year review in 2003. The third five-year review report recommended conducting groundwater monitoring and evaluation of LF004 South to determine if the area met the OU6 ROD cleanup levels and sampling of well OU6MW-61 to determine if LF004 South groundwater met cleanup levels for chlorinated solvent COCs.
The fourth five-year review report recommended performing a remedial process optimization for the LF004 South site to reevaluate the cleanup timeframe as well as a sampling event to identify if concentrations of 1,4-dioxane exist at the site and, if so, present an unacceptable risk. The review also recommended continuation with sampling LF004 seeps for TAH and TAqH to assess whether the seeps were meeting surface water quality standards. If the seeps are not meeting water quality standards, fuel-related compounds DRO and GRO in upgradient wells are to be analyzed to predict when and if the LF004 seeps will meet surface water quality standards.
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
LF004 is identified as a Yellow priority. LF04SP-02 does not meet surface water quality levels and is recommended for quarterly sampling in accordance with the Well Sampling Decision Guide (USAF, 2006). Following recommendations from the fourth five-year review. |
Louis Howard |
| 8/10/2015 |
Document, Report, or Work plan Review - other |
Staff provided comments on the Annual CERCLA Report. Main comment was a recommendation to either cut back the overgrown trees blocking the kiosk at the site and repost information about the site or remove the kiosk since it is blank. |
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 LF004 is identified as a Yellow priority. Seep LF04SP-02 does not meet surface water quality
levels and continued quarterly sampling is recommended in accordance with the Basewide
Monitoring Program Well Sampling Frequency Decision Guide presented in Attachment 1 of the
Memorandum to the Site File for OU6 (USAF, 2003e). Following recommendations from the
fourth five-year review, sampling of both OU6-MW61 and OU6MW-63 for GRO and DRO is
recommended.. It is also recommended that LUC inspections continue until the site reaches RC.
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 waa 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).
Seep location sampled at LF004 detected PFOS above EPA health advisory level and above Table C groundwater cleanup level. PFOA results were below EPA HA level and Table C cleanup level.
See site file for additional information. |
Louis Howard |
| 6/13/2017 |
Document, Report, or Work plan Review - other |
Staff reviewed the Draft SI Report for AFFF Areas on JBER-E and JBER-R sites. Data indicate that ST037 and LF004 seeps, located at the southern and southwestern Base boundaries, have been impacted by PFAS in groundwater and may be migrating off base in groundwater and surface water.
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.
See site file for additional information. |
Louis Howard |
| 6/19/2017 |
Update or Other Action |
EPA email requests clarification on whether AFCEC has a coordinated review on the data (especially lab packages) before it goes to the regulatory partners [EPA & ADEC] for review. For example, does Cornell Long (AFCEC) or someone else with PFAS expertise review and comment on the data from the AF sites. |
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 & 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 & data review was done by the government prior to submittal of the report to EPA & have not received a clear response.
EPA’s initial review has identified a number of data quality issues & that the government data review should be completed & submitted to EPA before we are asked to finalize our comments. The comments submitted reflect only those requiring clarification on the narrative or figures & do not concern data quality or final conclusions on the source areas based on the data. The comments are not inclusive of review of the laboratory data & therefore cannot substantiate any conclusions drawn on the presence or absence of PFAS at the twenty-six areas of concern.
The subsections of Section 2.3 do not clearly identify the potential sources of per- and polyfluorinated alkyl substances (PFAS) associated with the two seep sites, LF004 and ST037 (e.g., disposal of AFFF, migration in groundwater from other AFFF areas, etc.). Please revise Section 2.3 to clearly identify the potential sources of PFAS associated with the two seep sites, LF004 and ST037.
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 |
| 2/8/2018 |
CERCLA SI |
SI responses to ADEC's comments are satisfactory and may be incorporated into the final report. with the exception of lack of clarity in the response on which program the PFAS contamination will be investigated under at JBER: RI/FS in accordance with CERCLA as new source areas under the Federal Facility Agreements OR as new sites under State Authority (i.e. 18 AAC 75).
ADEC is requesting specific responses as to which path the investigation will occur (RI/FS per the FFA or Site Characterization per 18 AAC 75..335). Please respond. Additionally, ADEC is reviewing the Data Quality Evaluation Report AND the Technical Memorandum for Data Quality Findings Perfluorinated Compound Site Inspection for Joint Base Elmendorf-Richardson |
Louis Howard |
| 2/9/2018 |
Document, Report, or Work plan Review - other |
Draft annual RA-O Monitoring report for CERCLA sites reviewed and commented on. Main comments are: Clear vegetation noted in 2015 and 2016 and commented on by ADEC for two years in a row, repost information at the kiosk. Benzene and ethylbenzene have more conservative cleanup levels in Nov. 7, 2017 18 AAC 75 Table C Groundwater cleanup levels than those listed in the 1997 OU6 ROD. Staff asked AFCEC to reevaluate cumulative risk as a result of these more conservative cleanup levels and any impacts to remedy protectiveness during the next Five Year Review. This comment applies to all source areas with this contaminant in groundwater above current cleanup levels. The exceedances of TAH and TAqH should be discussed as part of the upcoming Five-Year Review regarding protectiveness of the selected remedy.
ADEC also requests that future sampling from this point forward include PFOS and PFOA in all groundwater and surface water/seep sampling. PFOA was detected at a concentration below the EPA HA and the ADEC cleanup level. PFOS was detected at a concentration above the EPA HA and the ADEC cleanup level in seeps. Data indicate that ST037 and LF004 seeps, located at the southern and southwestern Base boundaries, have been impacted by PFASs in groundwater and may be migrating off base in groundwater and surface water.
See site file for additional information.
|
Louis Howard |
| 6/12/2018 |
Document, Report, or Work plan Review - other |
Staff commented on the Draft Annual Remedial Action Operations & monitoring work plan addendum.
Main comments were to include sampling for PFAS substances in groundwater since it has been documented since the 2017 site inspection report that the groundwater is contaminated with PFOS and has the potential to be migrating off base in groundwater and surface water.
See site file for additional information. |
Louis Howard |
| 1/15/2019 |
Update or Other Action |
Draft Five year review received for Operable Unit 6 which includes source area LF004. Issue: Cancer risks exceed 1 x 10-4 or have an HQ greater than 1 for the following non-COC chemicals: [in groundwater (GW)] 2-methylnaphthalene, 4,4-DDD, cis-1,2-DCE, naphthalene, TCE, vanadium, & total xylenes; (in surface water) benzene, ethylbenzene, & total xylenes; & (in soil) 1,1,2,2-PCA, 2,methylnaphthalene, 4,4-DDD, aldrin, alpha-hexachlorocyclohexane, benzene, cis-1,2-DCE, dibenzofuran, dieldrin, ethylbenzene, naphthalene, thallium, TCE, & total xylenes. Recommendation: Investigate by conducting a sampling event for potential inclusion as remedy COCs: (in GW) 2-methylnaphthalene, 4,4-DDD, cis-1,2-DCE, naphthalene, TCE, vanadium, & total xylenes; (in surface water) benzene, ethylbenzene, & total xylenes; & (in soil) 1,1,2,2-PCA, 2-methylnaphthalene, 4,4-DDD, alpha-hexachlorocyclohexane, aldrin, benzene, cis-1,2-DCE, dibenzofuran, dieldrin, ethylbenzene, naphthalene, thallium, TCE, & total xylenes. Document any changes to COCs in a decision document.
Issue: Limited natural attenuation of benzene in GW is occurring at the site, & RAOs were not be achieved within the projected time frame. Recommendation: Conduct additional studies to optimize approach to achieve remediation goals. Other studies may include, but are not limited to: site characterization, ecological assessment, focused feasibility studies, GW modeling, treatability studies, &/or sampling.
See site file for additional information. |
Louis Howard |
| 2/14/2019 |
Update or Other Action |
The Alaska Department of Environmental Conservation (ADEC) has reviewed and approved the final
JBER Site Inspection (SI) Report dated May 20181 for Aqueous Film Forming Areas. In the SI are several new source areas that exceed cleanup levels in soil and/ or groundwater/ surface water for Perfluorooctane Sulfonate (PFOS) and Perfluorooctanoic Acid (PFOA) as listed in 18 AAC 75 Tables B1 and C (as amended through October 2018). ADEC has had promulgated PFOA/PFOS cleanup levels since July 1, 2017.
AFCEC has stated numerous times that any further action for PFOA and PFOS cannot be initiated until 2020. As it is now February 2019, ADEC believes the timeline for action by AFCEC will be more likely to be in 2021 or later since no JBER PFOA/ PFOS sites have been validated by AFCEC.
ADEC asserts these new PFOA/ PFOS source areas require additional investigation (e.g. remedial
investigation) and/ or remediation to comply with the Federal Facility Agreements (FFAs) for JBER-E 1991-Elmendorf Air Force Base) and JBER-R f 1994-Fort Richardson). ADEC believes AFCEC is out of compliance with the terms of the FF As for not scheduling and investigating PFOA and PFOS source areas in a timelier manner in accordance with CERCLA. |
Louis Howard |
| 8/14/2019 |
Document, Report, or Work plan Review - other |
Staff reviewed the annual monitoring report for select CERCLA sites. Main comments were to sample for perfluorinated compounds at LF004. This will require the Air Force to conduct additional investigation through a remedial investigation/feasibility study under CERCLA or as required by 18 AAC 75.335 Site Characterization (as amended through October 27, 2018) either under the existing LF004 source area or under a new site designation. This additional investigation will either take place in 2020 or more likely 2021.
See site file for additional information. |
Louis Howard |
| 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 |
| 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 |
| 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 |
| 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 |
| 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 |
| 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 |
| 3/4/2025 |
Document, Report, or Work plan Review - other |
DEC provided comments regarding the LF004 – Knik Bluff Landfill Limited Field Investigation Work Plan Draft, dated, February 2025. The work plan describes the proposed field screening and sampling activities associated with the release of a green liquid containing polychlorinated biphenyls (PCBs) and petroleum compounds at the LF004 site located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. Soil, seep water, surface water, and sediment samples will be collected during the spring and summer of 2025 and the stability of the landfill slope will be inspected. Samples will be analyzed for PCBs, petroleum compounds, volatile organic compounds, semi-volatile organic compounds, herbicides, pesticides, chromium, 1,4-dioxane, metals, and polycyclic aromatic hydrocarbons. |
Ginna Quesada |
| 3/17/2025 |
Exposure Tracking Model Ranking |
A new updated ranking with ETM has been completed for source area 72782 dump. |
Ginna Quesada |
| 4/4/2025 |
Document, Report, or Work plan Review - other |
DEC provided comments regarding the Data Gap Study Management Plan For LF004, WP014, And DP098 Draft,
dated March 2025.The work plan describes the proposed investigation activities to address the data gaps identified in the Five-Year Reviews for LF004, WP014, and DP098 sites located on Joint Base
Elmendorf- Richardson (JBER), Anchorage, Alaska. The potential groundwater connectivity between
LF004, WP014 and an adjacent site PL081 will be evaluated in this effort. A clustered shallow/deep
monitoring well pair will be installed at across these sites to understand aquifer conditions, evaluate continuity between the plumes,and investigate the potential migration pathways present at the sites. Soil and groundwater samples will be collected. At WP014 samples will be analyzed for gasoline range organics (GRO), diesel range organics (DRO), residual range organics (RRO), and volatile organic compounds (VOCs). At DP098 samples will be analyzed for total organic carbon, DRO, RRO, and
VOCs. The collected data from this study will be used to model new remediation timeframes and to
inform potential adjustments to remediation efforts at the sites. |
Ginna Quesada |
