| Action Date |
Action |
Description |
DEC Staff |
| 10/12/1942 |
Update or Other Action |
The War Department acquired 1,023,927.22 acres for the establishment of Fort Morrow by PLO 48, dated October 12, 1942, as amended by public land order (PLO) 284, dated June 12, 1945, from the DOI and construction began in July 1942. Following World War II, the Fort was abandoned. Fort Morrow was classified as excess property by the War Department and PLO 562 dated February 18, 1949, returned 1,013,577.22 acres to the public domain and transferred 10,350.00 acres to the Department of Commerce, Civil Aeronautics Administration (CAA), of which 4,058 acres were conveyed by the CAA to the State of Alaska, Department of Aviation, by deed April 15, 1966 (P.L. 85-508).
The assessor found a discrepancy between the 4,058 acres reported as transferred to the State of Alaska by the USACE, Alaska, INPR dated October 8, 1987, and the historical notes provided by Mr. Robert Norton, Chief of Leasing, Alaska Department of Transportation (ADOT) to the assessor on October 3, 2007, which states 3,500 acres were transferred by deed from the U.S. to the State of Alaska. The acreage balance was retransferred to the BLM by PLO 2495, dated September 13, 1961. |
Louis Howard |
| 4/30/1959 |
Update or Other Action |
The Air Force began to work on the DEW Line in northern Alaska in 1953. In January 1957, the Joint Chiefs of Staff approved the extension of the DEW line into the Aleutians. The main site was at Cold Bay with auxiliary sites at Nikolski, Port Moller, Cape Sarichef, Driftwood Bay, and Port Heiden (COB-5). 15 Feb 1957: The Alaska District, US Army Corps of Engineers awarded a $7,246,724 contract to the Manson-Osberg Company to build the DEW Line stations at Cold Bay on the southern end of the Alaska Peninsula and Cape Sarichef about 100 miles to the west on Unimak Island. Several weeks later, the Corps awarded a $3,548,190 contract to Chris Berg, Inc. to build the Aleutian DEW Line (Project Stretch Out) station at Port Heiden and another contract for $4,010,000 to S.S. Mullen Company to build the Port Moller station.
Work was completed in early 1959, and the sites were turned over to Alaska Air Command control on May 1, 1959. Unlike the northern sites, AAC retained responsibility for the operations and maintenance of the sites. Also, unlike the contractor-manned northern sites, military personnel manned the Aleutian sites. About one hundred people maintained the Port Heiden Dew Line site.
The central Alaska Peninsula became even a tighter link in the military chain when military leaders extended a communications system known as White Alice into the region. To improve communications between Alaska's radar sites, the military contracted AT&T to develop a reliable communications system for Alaska. According to Cloe, the communications firm decided on a new system called troposphere scatter, which bounced radio signals off the troposphere.
In 1955, The Western Electric Company began to build several "tropo" and microwave sites which would connect Alaska's air defense sites. In the 1960s, the communications system was extended down the Aleutians to support the Dew Line segment, and Port Heiden became part of White Alice as a repeater station. |
Louis Howard |
| 5/11/1961 |
Update or Other Action |
In May 1961, PLO No. 2374 allowed for the transfer of 62 acres from ANSW No. 247 (Civil Aeronautics Administration-CAA) to the United States Department of the Air Force for military purposes.
The Port Heiden RRS was established by the War Department on 172.04 acres within the existing Fort Morrow Site via PLO 2374, which withdrew 100.45 acres from the public domain for use by the USAF on May 11, 1961. Again, the assessor found a discrepancy in the acreage reported by the 1987 USACE, Alaska, INPR of 100.45 acres and the historical notes provided to the assessor by Mr. Norton, which states 91.83 acres were reserved for the USAF by PLO 2374.
The remainder of the Port Heiden RRS was acquired via 70.39 acres transferred from the BLM by notation on Public Land Records under 44LD513, and 1.20 acres acquired in fee by Declaration of Taking, both on February 18, 1958 (Civil No. A-15, 556). The deed transferring land to the State of Alaska, dated April 15, 1966, included 61.98 acres from the 91.83 acres reserved for the USAF; therefore, the State of Alaska issued Lease No. DACA85-5-76-71 leasing the 61.98 acres to the USAF. |
Louis Howard |
| 2/27/1981 |
Update or Other Action |
The Port Heiden RRS was declared excess by the USAF on February 27, 1981, by disposal report number 514. Notice of relinquishment was filed with the BLM for 38.47 acres on October 2, 1981 (USACE, 1987). Lease No. DACA85-5-76-71 for 61.98 acres, between the State of Alaska and the USAF, expired April 18, 1990. |
Louis Howard |
| 9/30/1981 |
Update or Other Action |
In 1981, the Air Force removed asbestos-containing pipe insulation, scrap metal, wood, water and fish-oil based paints, and 20 empty petroleum, oil and lubricants (POL) barrels from the Port Heiden radio relay station (RRS). These materials were disposed of in Landfill A (asbestos-containing material and building debris) and at BS I, northwest of the composite building. More than 100 empty POL barrels were buried at landfills designated BS II-VIII; however, the locations of the burial sites were unknown.
Assorted oil-based paints, PCB-contaminated electrical transformers, electrical capacitors, unknown fluids, waste oil barrels, 14 boxes of calcium hypochlorite, and toluene liquid were removed by the 5099th [(currently 611 Civil Engineer Squadron [CES)] for shipment to Elmendorf Air Force Base.
NOTE TO FILE: *PCBs belong to a broad family of man-made organic chemicals known as chlorinated hydrocarbons. PCBs were domestically manufactured from 1929 until their manufacture was banned in 1979. Aroclors 1016, 1242, 1254, and 1260 are complex mixtures of polychlorinated biphenyl (PCB) congeners, prepared by the chlorination of biphenyl. For Aroclors 1242, 1254, and 1260, the chlorination reaction was stopped when the weight percent chlorine of the product had reached 42, 54, or 60%, respectively. By contrast, Aroclor 1016 was prepared by the fractional distillation of Aroclor 1242, which excluded the higher boiling (i.e., more highly chlorinated) congeners. Aroclors 1016, 1242, 1254, and 1260 were the most widely used PCBs in the United States, and accounted for 92% of all 1958-1977 production (Monsanto, 1980).
PCBs were versatile materials which found use in a variety of applications including plasticizers, printing inks, and heat exchange, dielectric, and hydraulic fluids. The dielectric properties, chemical stability, and noncombustibility of PCB fluids made them a particularly attractive alternative to flammable mineral oils for use in capacitors and indoor transformers. Concerns in the late-1960s regarding the environmental accumulation of highly chlorinated PCB mixtures resulted, in 1971, in a voluntary cessation of the manufacture of Aroclors 1232, 1248, 1260, 1262, and 1268; the introduction of Aroclor 1016; and to a restriction in PCB usage to totally enclosed systems. The Toxic Substances Control Act of 1976 made the manufacture, importation, sale, or use of PCBs illegal after 1978.
The two most significant examples of closed PCB applications are transformers and capacitors. Capacitors can be found in: Power factor capacitors in electrical distribution systems, lighting ballasts, motor start capacitors in refrigerators, heating systems, air conditioners, hair dryers, water well motors, etc, capacitors in electronic equipment including television sets and microwave ovens. Also some minor usage of PCBs in specialized fluid cooled motors (electrical motors) and in some fluid cooled separating magnets (electrical magnets).
Partially closed applications of PCBs: examples include heat transfer and hydraulic systems and vacuum pumps. Heat transfer fluids: inorganic chemical, organic chemical, plastics and synthetics and petroleum refining industries; Hydraulic fluids: Mining equipment, aluminum, copper, steel, and iron forming industries; Vacuum Pumps: Electrical components manufacture; laboratory, instrument and research applications, and waste water discharge sites; Switches and Voltage regulators: Electric utilities; Liquid Filled Electrical Cables: Electric utilities, and private generation facilities (e.g. military installations), and Liquid Filled Circuit Breakers: Electric utilities. |
Louis Howard |
| 6/29/1984 |
Update or Other Action |
In 1984, the USAF received waste-disposal permits for cleanup operations at Port Heiden (Permit 8421-BA014) and other remote WACS sites. Permit 8321-BA014 was issued on June 29, 1984 for debris disposal, but the application does not indicate a site location. The permit files do not contain record drawings, records of use or closure documentation. According to the USAF (1984), "The 5099th (CEOS) believes that this one-shot cleanup will remove the last of the hazardous material and bury the remaining general debris at the sites." No records exists about the contents or location of the debris buried at Port Heiden during the 1984 effort. Correspondence indicates that the USAF allowed the permit to expire in October 1984. |
Louis Howard |
| 9/30/1984 |
Update or Other Action |
In 1984, the 5099th shipped transformer oil containing poly-chlorinated bipheynls (PCBs), 372 drums of PCB-impacted soil, 5 waste oil drums, herbicides (Esteron 2,4-D), and approximately 6 drums of solvents and cleaning compounds from the radio relay station (RRS). Final disposition of the chemicals is unknown.
A total of 320 drums of PCB-impacted soil was removed from an area on the southeast side of Antenna No. 2; 57 drums of PCB-contaminated soil were removed from an area which had been excavated to a depth of 3 feet, near a doorway on the southeast corner of the composite building; and 33 drums of PCB-impacted soil were removed from an area on the west side of Antenna No. 3. |
Louis Howard |
| 12/21/1985 |
Update or Other Action |
In 1985 & 1986, the 5099th shipped 54 drums & 395 drums, respectively, of PCB-impacted soil to Elmendorf AFB There is no record of final disposal. Actions taken by the 5099th at Port Heiden in 1985 were recorded in two three-ring binders located in the archives of the 5099th. These two binders contained maps of areas that were excavated, results from two field instruments that were used to monitor the progress of the removal action, & daily reports. One instrument was referred to as the "McGraw Edison Machine". The other instrument was not identified. The work began on July 21, 1985, & was completed for the year on December 21, 1985.
According to the documents, grids were established & composite samples collected from each grid area around the composite building & near the south antenna where PCBs were detected in 1984. The daily log mentions removal of PCB-contaminated sod & the use of field test kits to determine the amount of contamination. There is no report or dated figure showing the final disposition of the contaminated soil removed or the final results of PCB confirmation samples from the remaining soil within the excavations. An undated figure shows some excavation areas & the number of drums of impacted soil removed.
A 3-ring binder labeled "ACE 1986" (ACE is the abbreviation for Alaska Cleanup Effort) contained a page of dates & accomplishments that took place at the site in 1985. A November 15, 1985, entry reads "received lab results from ANA labs, the holes are clean & will be backfilled" For the date December 13, 1985, the entry reads "holes have been backfilled."
A figure found in the 5099th archives showed areas where PCB-impacted soil had been removed, & the number of drums of impacted soil removed from those areas. Three hundred & twenty drums of PCB-impacted soil were removed from an area on the southeast side of Antenna No 2. Fifty-seven drums of PCB-contaminated soil were removed from an area which had been excavated to a depth of 3 feet, near a doorway on the southeast corner of the composite building. Thirty-three drums of PCB impacted soil were removed from an area on the west side of Antenna No 3.
These drums do not represent the total amount of soil removed or the only areas where soil was removed by the 5099th "PCB Negative" is written outside of the north & west walls of the composite building. Northwest of the composite building is an area labeled "Dump Debris from Building Non Hazardous". This is the BS I site referred to in paragraph two of this section.
The 5099th wrote daily reports that stated that samples were sent to "town" for analysis & results were received from "town" for confirmation that the remaining excavation soils were "clean" of PCBs. A December 7, 1985, entry reads "Willy & Bradburn arrive from AKN to start things going, all holes came up clean & no more PCB can be found (load things up)" (Alaska Cleanup Effort, 1985).
Mike Hostetter, Engineer & Equipment Operator Foreman, 611 CES participated in the removal of PCB-contaminated soil at the site in approximately 1984 or 1985 According to Hostetter, 611 CES set up a grid & collected samples for analysis using a field gas chromatogram Excavated soil was placed into drums Soil samples from the drums were sent to a USAF laboratory in Texas. He recalled that they generally dug down 2 to 3 feet bgs & in some locations down to 6 feet bgs He recalled that they removed soil in the vicinity of the transformer room & thought they had removed all the contaminated soil. Wind created problems at times, blowing surface soil that was contaminated onto what may have been "clean" soil. |
Louis Howard |
| 5/6/1986 |
Update or Other Action |
Letter from the Dept. of Air Force (D. A. Nuss, Lt Col, USAF, BSC, Command Bioenvironmental Engineer, Office of the Surgeon) to Bristol Bay Area Health Corporation (R. J. Clark) Executive Director. This letter is per our telecon of 5 May 1986, Alaska Cleanup Effort, Port Heiden, Alaska. The Air Force has completed cleanup actions at this site to include the removal of industrial chemicals and contaminated soil. Industrial chemicals included PD 680* solvent, battery acid, paints, engine starter fluid, detergents, lubricating oils, diesel fuel, and motor gasoline. Contaminated soil had PCBs. The soil was removed in overpack drums and shipped to CONUS. We consider the site to be free from hazardous materials/wastes. Field work was monitored by personnel from Bioenvironmental Engineering Services. The State of Alaska Dept. of Environmental Conservation approved this work and the burial of solid waste at the site.
Future work at Port Heiden will be accomplished by the Alaska District, Corps of Engineers, and will most likely be concerned with the building demolition and cleanup of WWII debris in the area.
*NOTE TO FILE: Each item the Govt. orders must have an N.S.N, a National Stock Number, unless the Agency gets special permission to local purchase the item. Each N.S.N. item goes out for bid and has an associated minimum specification. A revieweds of microfiche files on all NSNs for chemicals shows that the specification for PD680, aka. Stoddard Solvent, back in the 1980's and before was for a petroleum based degreaser with a specified flashpoint.
No requirement for non-halogenated existed. Besides that, because Alaska was so far from venders that supplied the Govt., many Agencies in Alaska local purchased solvents, and there were no qualifications on those solvents and most often halogenated solvents worked with less elbow grease than pure petroleum distillates, so they were preferred. A check of NSNs ordered through the PD680 specs normally and some batches were TCE, Methylene chloride, etc; it depended on who the supplier to the Govt. was at the time.
So as a result of the survey between 1980 and 1983, some PD680 batches were in fact halogenated. Research of PD680/Stoddard Solvent/Petroleum Distillate/Degreasing Solvent included sampling of hundreds of new and used drums of product, as well as NSN specifications, in nearly all western military installations, including Alaska.
|
Jennifer Roberts |
| 7/24/1986 |
Update or Other Action |
In 1986, Congress passed the Defense Environmental Restoration Program statute (“DERP”)as part of the Superfund Amendments and Reauthorization Act (“SARA”). DERP requires that the Secretary of Defense “carry out a program of environmental restoration at facilities under the jurisdiction of the Secretary.” DERP also applies to former Department of Defense facilities, providing that the Secretary of Defense:
shall carry out (in accordance with the provisions of this chapter and CERCLA) all response actions with respect to releases of hazardous substances from … [e]ach facility or site which was under the jurisdiction of the Secretary and owned by, leased to, or otherwise possessed by the United States at the time of actions leading to contamination by hazardous substances.
DERP response actions must be carried out “subject to, and in a manner consistent with, section 120 (relating to federal facilities) of [CERCLA].” Among other provisions, section 120 waives the federal government’s sovereign immunity for purposes of CERCLA, and subjects it to CERCLA “in the same manner and to the same extent, both procedurally and substantively, as any nongovernmental entity, including liability under section 107 of this Act.”
|
Louis Howard |
| 12/26/1986 |
Update or Other Action |
While not listed on the NPL, the Army Corps of Engineers must follow CERCLA process per E.O. 12580 [e.g. CERCLA Sections 104(a), (b), and (c)(4), 113(k), 117(a), and (c), 119, and 121) with respect to releases or threatened releases where either the release is on or the sole source of the release is from any facility or vessel under the jurisdiction, custody, or control of their departments. These functions must be exercised consistent with CERCLA Section 120 Federal Facilities.
State laws. -- State laws concerning removal and remedial action, including State laws regarding enforcement, shall apply to removal and remedial action at facilities owned or operated by a department, agency, or instrumentality of the United States when such facilities are not included on the National Priorities List. The preceding sentence shall not apply to the extent a State law would apply any standard or requirement to such facilities which is more stringent than the standards and requirements applicable to facilities which are not owned or operated by any such department, agency, or instrumentality.].
|
Louis Howard |
| 12/31/1986 |
Update or Other Action |
In 1986, soil samples were collected during the US Army Corps of Engineers investigation throughout the Port Heiden area, which includes the Former Facility Area. At the former Composite building, results indicated the presence of PCBs up to 15 parts per million (mg/kg) in the vicinity of the auto shop.
Port Heiden WACS site and Fort Morrow were sampled for the presence of THM during a field visit by the Corps in June 1986. POL in spills and drums, soils, water bodies, and sumps were sampled and analyzed for THM contamination. Areas sampled included obvious oil spills and areas void of vegetation. Preliminary sampling was judgemental and representative of the site as a whole. The Corps· chemist1s efforts were directed at determining the types and location of THM contamination. A tabulation of analysis of the results follows.
SAMPLING LOCATIONS: Port Heiden, Fort Morrow, WACS Site.
SAMPLES
10 SL WACS site auto shop Soil Not tested for: Heavy Metal, Acutely Toxic Substances. PCBS 15.0 ppm
11 SL WACS site wave guide Soil Not tested for: Heavy Metal, Acutely Toxic Substances. PCBS 0.23 ppm
12 SM Outside, generator room Soil matrix Heavy Metals Non. Not tested for: Acutely Toxic Substances or PCBS
13 SL Outside, generator room Soil Not tested for: Heavy Metal, Acutely Toxic Substances. PCBS 3.5 ppm
14 SM WACS site, landfill Soil matrix Heavy metals-none Not tested for: Acutely Toxic Substances or PCBs
15 SL Area 2, barrel lot Soil Heavy metals-none Not tested for: Acutely Toxic Substances or PCBs
16 SM Area 4, barrel, quonset Soil matrix Heavy metals-none Not tested for: Acutely Toxic Substances or PCBs
21 SL Area 7, ACS station Soil Not tested for: Heavy metals, Acutely Toxic Substances or PCBs
22 SL Area 10, near hangar Soil Heavy metals-none Not tested for: Acutely Toxic Substances or PCBs
23 DR Area 13, Meshik tank farm Drum Not tested for: Heavy metals, Acutely Toxic Substances or PCBs
24 SL Area 13, Meshik landfill Soil Heavy metals-none Not tested for: Acutely Toxic Substances or PCBs
25 WA Water Heavy metals-Acutely Toxic Substances: None Not tested for PCBs
26 SD HUD road, landfill Sediment Heavy metals-none Not tested for: Acutely Toxic Substances or PCBs
27 SD HUD, landfill Sediment Heavy metals-Acutely Toxic Substances: None Not tested for PCBs
28 SL Area 12, towers Soil Not tested for: Heavy metals, Acutely Toxic Substances or PCBs
29 SL Area 12 Soil Not tested for: Heavy Metals, Acutely Toxic Substances. PCBs 9.9 ppm
30 SL Area 12 Soil Not tested for: Heavy metals, Acutely Toxic Substances. PCBs - None.
31 WA HUD road, north side Water Heavy Metals, Acutely Toxic Substances: None. Not tested for: PCBs
32 SL Area 8, north of Reeve hangar Soil Heavy Metals-None. Not tested for: Acutely Toxic Substances or PCBs
33 SL Area 8, north of Reeve hangar Soil Heavy Metals-None. Not tested for: Acutely Toxic Substances or PCBs
34 SD Area 10, pumphouse lake Sediment Heavy Metals-None. Not tested for: Acutely Toxic Substances or PCBs
Samples were analyzed for 8 metals, including: Arsenic, Barium, Cadmium, Chromium, Lead, Mercury, Selenium, and Silver.
Identification testing for 64 organic, semi-volatile compounds was done for each sample. The chemicals are identified as Toxic or Hazardous. |
Jennifer Roberts |
| 1/23/1987 |
Update or Other Action |
Executive Order (EO) 12580--Superfund implementation Source: The provisions of EO 12580 of Jan. 23, 1987, appear at 52 FR 2923, 3 CFR, 1987 Comp., p. 193, unless otherwise noted.
(d) Subject to subsections (a), (b) & (c) of this SEC., the functions vested in the President by Sections (SEC.) 104(a) , (b) & (c)(4), 113(k) , 117(a) & (c) , 119, & 121 of the Act are delegated to the Secretaries of Defense & Energy, with respect to releases or threatened releases where either the release is on or the sole source of the release is from any facility or vessel under the jurisdiction, custody or control of their depts.., respectively, including vessels bare-boat chartered & operated. These functions must be exercised consistent with the requirements of SEC. 120 of the Act.
SEC. 104 [42 U.S.C. 9604] Response Authorities-(a)(1) Whenever (A) any hazardous substance is released or there is a substantial threat of such a release into the environment (environ.), or (B) there is a release or substantial threat of release into the environ. of any pollutant or contaminant which may present an imminent & substantial danger to the public health or welfare, the President is authorized to act, consistent with the NCP, to remove or arrange for the removal of, & provide for remedial action (RA) relating to such hazardous substance, pollutant, or contaminant at any time (including its removal from any contaminated natural resource), or take any other response measure consistent with the NCP which the President deems necessary to protect the public health or welfare or the environ.
(b)(1) Information: Studies & Investigations. --Whenever the President is authorized to act pursuant to subsection (a) of this SEC., or whenever the President has reason to believe that a release has occurred or is about to occur, or that illness disease, or complaints thereof may be attributable to exposure to a hazardous substance, pollutant, or contaminant & that a release may have occurred or be occurring, he may undertake such investigations, monitoring, surveys, testing, & other information gathering as he may deem necessary or appropriate to identify the existence & extent of the release or threat thereof, the source & nature of the hazardous substances, pollutants or contaminants involved, & the extent of danger to the public health or welfare or to the environ.
(k) Administrative Record & Participation Procedures.- (1) Administrative record (AR). -- The President shall establish an AR upon which the President shall base the selection of a response action. The AR shall be available to the public at or near the facility at issue. The President also may place duplicates of the AR at any other location. (2) Participation procedures.- (A) Removal action. -- The President shall promulgate regulations in accordance with chapter 5 of title 5 of the USC establishing procedures for the appropriate participation of interested persons in the development of the AR on which the President will base the selection of removal actions & on which judicial review of removal actions will be based.
For additional information see site file.
|
Jennifer Roberts |
| 4/21/1987 |
Update or Other Action |
The U.S. Army Engineer District, Alaska, proposes to clean up debris at former Department of Defense "White Alice" communication sites & an abandoned World War II Army base. The proposed action is to remove & dispose of unsafe & unsightly structures & associated debris, including toxic &/or hazardous materials (THM) identified on-site. In response to concerns raised in a previous review of Port Heiden/[Fort Morrow) Port Moller environmental assessments (Public Notices dated December 16, 1985), the two revised Environmental Assessments & Findings of No Significant Impact (FNSI) are transmitted.
The project consists of removal & disposal of:
1. 280 Quonset huts.
2. 150 collapsed wood frame buildings.
3. Two 250,000-gallon fuel tanks.
4. Three radio towers (two 100-foot, one 50-foot).
5. 8,000 55-gallon barrels.
6. A White Alice site: four 60-foot parabolic troposcatter antennas & feedhorns; one (30,000 sq. ft.) reinforced two-story concrete building with a central five-story tower (45 x 45 ft.); interconnecting electrical conduits; one 24,000-gallon freshwater storage tank; two 20,000-gallon buried fuel tanks; two small concrete buildings (150 sq. ft.); & a septic system.
7. Miscellaneous material, including: metal scraps, equipment, vehicles, steel pipe, wire, & other debris.
8. Asbestos material (approximately 80 cu. yds.).
9. Residue & waste POL, less than 3,000 gallons.
Equipment & vehicular use will be limited to sites on or near the existing road system. Machinery usage in areas away from any roads will be restricted to soft, rubber-tired vehicles or prohibited. Removal of the White Alice site will involve demolishing the concrete buildings by drilling & blasting, using heavy equipment, or use of a wrecking ball. Metal towers will be dismantled, & buried if no use is found. Any petroleum products will be drained or pumped from tanks or fuel lines for reuse or disposal. All disturbed sites will be revegetated following cleanup activities.
Disposal methods & specifications will follow State, Federal, & local regulations & procedures. Ground surface disturbance & equipment noise, are unavoidable short-term impacts. Burning wood materials & equipment operation will produce smoke which will quickly dissipate in the strong, steady winds. Cleanup will promote the long-term positive effects on visual aesthetics, by removing dangerous debris & structures, & by removing the potential for petroleum products to leach from rusting tanks, fuel lines, & barrels. Environmental restoration will occur through natural processes once structures & debris are removed.
See site file for additional information.
|
Louis Howard |
| 12/31/1988 |
Update or Other Action |
In 1987 and 1988, 80 soil samples were collected during the US Army Corps of Engineers investigations, on the north end of the former composite building and analyzed for PCBs (Aroclor 1260). PCB impacted soil was found along the entire northern wall of the composite building up to 190 mg/kg. Highest concentrations were found at the east edge of the concrete slab in front of the large garage doors. |
Louis Howard |
| 1/1/1990 |
Update or Other Action |
The Port Heiden facility included a composite building, which contained a vehicle-maintenance garage, office and storage space, and equipment for standby power generation; four billboard antennas and feed horns (White Alice arrays); storage and distribution facilities for petroleum, oil and lubricants (POL); and a heliport.
The facility was constructed in the late 1950s during the expansion of the Distant Early Warning Line System. The Port Heiden site, which served as a link between King Salmon and Cold Bay, became obsolete with the advent of satellite communication and was abandoned in 1978. The site was demolished in 1990.
The Port Heiden WACS site (CERCLIS ID No. AK8570028698) is within Fort Morrow, halfway down the Alaska Peninsula. The site is about 140 miles southwest of the town of King Salmon and about 4 miles northeast of the Village of Meshik. Situated on the coastal plain of Bristol Bay, the site encompasses 172 acres in Section 15, Township 37 South, Range 59 West, Seward Meridian. |
Louis Howard |
| 8/6/1990 |
Update or Other Action |
In bid documents and previous United States Air Force (USAF) as-builts, it is shown that a 30,000 gallon MOGAS UST northwest of the Composite Building. Underwater Construction conducted a search for the UST by digging 8 feet bgs in the approximate vicinity shown in the as-builts, but was unable to locate a tank.
In a "Memorandum for the Record", dated August 6, 1990, Ronald J. Pflum with the Corps of Engineers stated that "the missing 30,000 gallon UST has been found on city property. The city removed the tank prior to the start of this contract." A tank of the appropriate proportions was found in the vicinity of the POL storage tanks in Meshik. There was not proof (i.e. a resident witness to verify that the tank was taken from the Composite Building." * Therefore, it is unknown if a tank remains in place at that location (Composite Bldg.).
A 600 gallon UST, registered with ADEC, at the Composite Building had also been removed by persons unknown before the project started. The tank was found empty and above ground. It was placed at the UC&AI base of operations. The tank was inspected and showed no signs of leakage or holes. The tank's former location is unknown.
Two 20,000 gallon diesel USTs were shown on the bid documents to be located to the northeast of the Composite Building. UC&AI was contracted to remove these USTs, but when they arrived on site, the 20,000 gallon USTs had been removed, again by persons unknown, and the excavation was open with water in the bottom. The tanks were on site. |
Louis Howard |
| 8/31/1990 |
Update or Other Action |
1990 PCB and TPH Analytical Results
North Side of the Composite Bldg. from NPDL and Chemical Geologicial Laboratory (CG), respectively. Field screening, NP and CG, respectively confirmation PCB results:
Grid Number 01 C field screening 0.3 ppm, NP 2.6 ppm, CG 91 ppm, Grid Number 02 C: ND, 42 ppm, 2 ppm, Grid 03C: ND, 0.58, 29 ppm, Grid 04 C 18 ppm, 5.1 ppm, 1.65 ppm, Grid 5 C: 0.67 ppm, 3.8 ppm, 1.29 ppm, Grid 06 C: 0.31 ppm, 0.14, 19 ppm, Grid 07 C: ND, 24 ppm, 12 ppm, Grid 08 C 1.4 ppm, 7.6 ppm, 3.1 ppm, Grid 09C (Re-excavation of 10C after receiving results from NPDL): 0.84 ppm, 3.6 ppm, 2.09 ppm, Grid 10 C: 2.8 ppm(3.0 ppm field duplicate) field screening, 21 ppm NP, 7.07 ppm CG.
Grid 11 C: 2.1 ppm (2.3 ppm field duplicate) field screening, 10 ppm NP, 4.43 ppm CG, Grid 12 C (6" soil sample): 0.24 ppm, 0.35 ppm 0.16 ppm, Grid 13 C (6" soil sample sent to Chem Geo): 1.1 ppm, 8.6 ppm, 2.3 ppm, Grid 14 C (Composite soil sample of 1st 6"): 2.5 ppm, 6.7 ppm, 3.39 ppm, Grid 15 C (re-excavation of 10 C after receiving results from NPDL): 0.93 ppm, 3.6 ppm, 1.06 ppm, Grid 16 C: ND, 0.29 ppm, ND, Grid 17 C ND, 0.4 ppm, 0.021 ppm, Grid 18 C: ND, 0.52 ppm, 16 ppm, Grid 19 C: 0.64 ppm, 1.3 ppm, 0.29 ppm, Grid 20 C: ND, 52 ppm, 0.17 ppm, Grid 21 C: ND, 32 ppm, 0.14 ppm, Grid 22 C: ND, ND (CG).
Gridline "A" Samples
A 5: ND Field Screening, 0.12 ppm confirmation laboratory PCB results, A 6.5: 15 ppm, 14.8 ppm,
A 7: ND, 4.28 ppm.
Gridline "B" Samples
B 6: 480 ppm field screening, 728 ppm confirmation lab PCB results, B 6.5: ND, ND.
Gridline "C" Samples
C 1: 5.2 ppm (5.3 ppm field duplicate) Field screening sample, 7.75 Confirmation lab PCB results, C 5: ND, 0.62 ppm, C 5.5: ND, 0.68 ppm, CB7: 1.10 ppm, 4.15 ppm, CD2: 6.10 ppm 7.98 ppm.
Gridline "F" Samples
F 2: ND, 6.54 ppm Confirmation lab PCB results.
Gridline "G" Samples
G 3: 1.6 ppm, 2.02 ppm, G 5: ND, 2.85 ppm
Gridline "L" Samples
L 4: 8.0 ppm, 5.73 ppm
Grid 25 C: ND Field screening, 1.0 NP, 0.27 CG, Grid 24C: 2.2 ppm, 27 ppm CG, Grid 23C ND, 9.9 ppm NP, 0.14 ppm CG, |
Louis Howard |
| 9/5/1990 |
Update or Other Action |
Northwest EnviroService Inc. T.G. Poliquin sent letter to Tom Johnston regarding three UST Removals and soil sampling results.
#1- 350 Gallon UST - Hospital Site
This storage facility was removed on 9-1-90. This tank contained approximately 325 gallons of fluids which were removed on 7-15-90 by NWES personnel and placed into 55 gallon drums. These were sampled and found to be comprised of mostly water and minimal fuel oil yielding flash points above 210F.
The tank was damaged during removal which caused it to leak approximately 20 gallons of residual sludge into the excavation. This was shoveled into an 85 gallon open head drum. Soil samples were then obtained from direcly below the lowest tank profile, on the centerline, originating on each end and the midpoint. A sample of the tank residuals (sludge) was also obtained.
Sample # 900901007 Sludge - residuals from tank bottom.
Resul ts of this sludge sample indicate a level of 7600 ppm TPH.
Sample # 900901008 Soil - centerline bottom easterly end.
Results of this soil sample indicate a level of 5200 ppm TPH.
Sample # 900901009 Soil - centerline bottom westerly end.
Results of this soil sample indicate a level of 5300 ppm TPH.
Sample # 900901010 Soil - centerline bottom at midpoint.
Results of this soil sample indicate a level of 11000 ppm TPH.
#2- 500 Gallon UST - Garage Building (Waste Base)
This storage facility was removed on 8-28-90. The tank had a full length opening at the top and resultantly, had collected rain water. The water was removed and placed through the filtering system. A sample of the residual sediment (sludge) from the tank was obtained. Additionally, three soil samples were obtained upon removal of the tank. These three samples were gathered from the lowest point of the tank profile on the centerline, originating at each end and the midpoint.
Sample # 900828003 Soil - centerline bottom at midpoint.
Results of this soil sample indicate a level of 890 ppm TPH.
Sample # 900828004 Soil - centerline bottom south end.
Results of this soil sample indicate a level of 540 ppm TPH.
Sample # 900828005 Soil - centerline bottom north end.
Results of this soil sample indicate a level of 71 ppm TPH.
Sample # 900828006 Sludge - residuals from tank bottom.
Results of this sludge sample indicate a level of 900 ppm TPH.
#3 600 Gallon UST - Composite Building This storage facility was removed prior to DERP work commencing. The tank was found empty and above ground by the
initial UC&A work force. This tank is currently located at UC&A's base of operation. It was viewed and shows no visible signs of holes, cracks or previous leakage. Also there were no PCBs found in the above samples. |
Louis Howard |
| 9/14/1990 |
Update or Other Action |
Larry Wilkinson, Manager of Philip Environmental, Inc. (formerly Northwest EnviroServices, Inc.) stated that in 1990 NWES performed hazardous waste identification and removal from Fort Morrow and the RRS. Approximately 19,000 drums were removed from the surface of a 3 square mile area, steam cleaned, and landfilled on site.
Approximately 4,400 drums had oil, gas, or rainwater in them, 2 drums contained chlorinated solvents, and at least 1 had PCB-oil. PCB-contammated soil was removed from the vicinity of the RRS composite building to a depth of approximately 3 feet bgs Soil was placed into super sacks and into approximately 150 wooden boxes for shipment The cleanup level was 25 mg/kg for PCBs.
Allan Boggs, Independent Environmental Consultant collected many of the soil samples in the vicinity of the RRS during 1990. Soil was removed from the PCB-impacted areas in 6-inch lifts. For example, soil was collected from 1 to 6 inches bgs, if the PCB concentration was above the cleanup level, the top 6 inches of soil were removed and the soil in that location was again sampled from 1 to 6 inches below the new surface.
In areas where TPH concentrations were above the target cleanup level, soil was removed in approximately 1-foot lifts and then retested until the cleanup level was achieved. |
Louis Howard |
| 9/26/1990 |
Update or Other Action |
INTERIM GUIDANCE FOR SURFACE AND GROUNDWATER CLEANUP LEVELS SEPTEMBER 26, 1990
Interim cleanup guidance for contaminated surface and groundwater remediation is necessary to ensure that consistent cleanup levels are being applied by district and regional program staff. The following guidelines should be implemented under 18 AAC 75.140 which specifies that a "discharge must be cleaned up to the satisfaction of the Regional Supervisor or his designee.
Final cleanup levels shall be determined by the Regional Supervisor or his designee based on site-specific conditions. Staff should be aware that if a facility is regulated under RCRA, that RCRA corrective action and cleanup standards should enter into development of final site cleanup levels.
Groundwater should be cleaned up to levels not exceeding the more stringent of the final State or Federal Maximum Contaminant levels (MCLs) for Organic and Inorganic Chemicals. If final MCLs have not been adopted for a contaminant, then groundwater should be cleaned up to levels not exceeding proposed Federal MCLs. The group of compounds collectively identified as total petroleum hydrocarbons (TPH) should be cleaned, up to non-detectable levels as measured by EPA Method 418.1.
Final State MCLs are specified in 18 AAC 80.050 and final Federal MCLs are specified in 40 CFR 141 and 142. Proposed Federal MCLs are specified in the May 22, 1989, Federal Register Vol. 54, No. 97, pages 22155 - 22157 and the July 25, 1990, Federal Register Vol. 55, No. 143, pages 30408 - 30448. Appendix I provides a summary listing of State and Federal Final and Proposed MCLs for selected organic and inorganic contaminants.
For organic and in organic contaminants that have not been assigned a final or proposed MCL, cleanup levels should be based on criteria cited in EPA's Water Quality Criteria. 1986 using a health risk factor of 10-6. EPA's water quality criteria identify concentrations of elements and compounds which have toxic effects on aquatic organisms or toxic and carcinogenic effects on humans.
If groundwater is being used as a drinking water source and alternative water supplies or point of use water treatment cannot be provided, then final or proposed secondary maximum contaminant levels (SMCLs) may be used as cleanup target levels. SMCLs are based on aesthetic properties such as taste and odor, whereas MCLs are based on human health risks. For compounds such as xylenes, the SMCL maybe several hundred times lower than the MCL.
Surface waters used for drinking water should also be cleaned up to levels not exceeding the final or proposed MCLs for organic and inorganic chemicals, as specified above. Under the authority of 18 AAC 70.020, surface waters important to the growth and propagation of aquatic life should be cleaned up to the listed criteria which includes EPA's Water Quality Criteria. 1986. These criteria identify concentrations of specific elements or compounds which have toxic effects on aquatic organisms. The group of compounds collectively identified as total petroleum hydrocarbons (TPH) should be cleaned up to non-detectable levels as measured by EPA Method 418.1.
See site file for additional information.
|
Jennifer Roberts |
| 12/31/1990 |
Update or Other Action |
In 1990, surface soil with total petroleum hydrocarbon (TPH) levels above 5,000 mg/kg on the north side of the former composite building were removed in 1 ft. thick intervals; the remaining soil was then retested. The goal in 1990 was to achived TPH levels of less than 100 ppm throughout the grid area. This goal was not achieved. |
Jennifer Roberts |
| 6/19/1991 |
Update or Other Action |
Work to demolish & clean up an abandoned White Alice military communications site at Port Heiden under the DERP began in 1990 & is still in progress. The DERP project at Port Heiden consists of removing debris & abandoned buildings; cleaning up soils contaminated with petroleum, oil, & lubricants (POL) & asphalt; & restoring the site. An EA was written in 1987 for the removal of 333 buildings, several large fuel tanks, about 8,000 55-gallon drums, various scrap metal & debris, 500 cubic yards (yd) of POL-contaminated soil, & soil contaminated with polychlorinated biphenyls.
The public review process was completed, & State & Federal permits were issued by the regulatory agencies. The Solid Waste Landfill Permit issued by the Alaska Department of Environmental Conservation (ADEC) stipulated that some soils saturated with POL could be landfilled at the approved on-site locations. The term "saturated" has been defined as 5,000 milligrams total petroleum hydrocarbons (TPH) in one kilogram of soil (5,000 mg/kg or 5,000 ppm).
During the process of restoring the site, the AK District determined that additional soil contaminated with POL's should be remediated. The permitted landfills were only large enough for the amount of material initially estimated to require disposal; therefore, not enough space remains for the additional contaminated soils. The ADEC has established interim guidelines which propose cleanup levels of 100 mg/kg. Solid waste landfill permits will not be issued for the disposal of POL-contaminated soils.
An EA was distributed for public review on April 16, 1991, for the remediation of the additional contaminated soil. The quantity is estimated to be between 18,000 & 20,000 cy . This estimate relies upon limited data; the quantity of contaminated soil at the 100 mg/kg level may be significantly higher. The soil would be remediated burning it in a low-temperature incinerator (700 to 1,500 F) at the site.
Recommendations from the Risk Assessment, DERP, Port Heiden, Alaska, Alaska District, U.S. Army Corps of Engineers (COE) dated June 1991. Soil samples were taken from numerous locations throughout the Port Heiden area, including the airport & the White Alice facility.
The tests included TPH, volatile organics, chlorinated hydrocarbons, metals (EP Toxicity), & PCBs. The PCB-contaminated soils were removed under a previous contract. The tests indicated that the contamination consists mainly of weathered diesel & asphalts. No volatile organics or chlorinated hydrocarbons were detected. Soil samples were taken at areas where contamination was expected (e.g., under tanks, near barrel dumps, in surface-stained soil) from the surface down to 12 feet below the surface. Levels of TPH above 60,000 mg/kg were detected.
Contaminants detected within the unsaturated zone above ground water were not detected in ground water or surface water samples. Exploratory digging near the White Alice site indicates that the depth of contamination is 12’. This is one of the largest contaminated areas located on ground that provides relief from the surrounding area. The test pit indicated a layer of clay between the lower limit of the contaminated soil & ground surface.
See site file for additional information. |
Jennifer Roberts |
| 6/20/1991 |
Cleanup Level(s) Approved |
In 1991, ADEC agreed to a 5,000 mg/kg TPH cleanup concentration. Letter to Louis R. Pylant Lt. Col Corps of Engineers, ER/CW Section, USAED, Alaska, PO Box Anchorage, AK 99506-0898 RE: Port Heiden Formerly Used Defense Sites Risk Analysis Dated June 19, 1991. The Department has reviewed the Final Risk Analysis for Alternative Cleanup Levels at Port Heiden, Alaska, submitted by your department on June 19, 1991. The risk analysis adequately addresses the concerns generated by utilizing a cleanup level of 5,000 parts per million total petroleum hydrocarbons (TPH) for remote areas of Port Heiden Formerly Used Defense site (FUDS) cleanup. This 5,000 parts per million does not include: benzene, ethylbenzene, toluene, and total xylenes (BTEX).
It is my understanding that the petroleum contamination at this area is old weathered fuels in which the BTEX components have volatilized off and are no longer an issue. This letter approves of the work proposed in the FInal Risk Analysis with a remote site specific cleanup level of 5,000 parts per million for TPH. Signed Jennifer L. Roberts, Federal Facility Coordinator. *NOTE To file: no mention in the letter was a cleanup level for PCBs.
PCBs less than 10 mg/kg to be placed in the soil caps of landfills A and B. Soil with TPH greater than 5,000 mg/kg and PCBs less than 25 mg/kg were to be stockpiled on site for eventual remediation. Because the amount of POL-contaminated soils far exceeded the capacity allowed in the landfill cap, most of the soils between 100 and 5,000 ppm were also incinerated onsite or left in place.
Soil contaminated with PCB was removed from the WACS and FAA sites [aka CAA Towers?] to below the negotiated cleanup levels (25 and 10 ppm, respectively). Sludge containing PCB was removed from the concrete floor trench in the WACS site composite building to a final level of 1.4 ppm. About 170 cubic yards of PCB contaminated soil were shipped to a licensed PCB incinerator in Kansas.
US Army Corps of Engineers risk assessment-Alternate Cleanup Levels: Total Petroleum Hydrocarbons at 5,000 mg/kg, Total Petroleum Hydrocarbons (TPH) 100 mg/kg near village (POL Tank Area) and polychlorinated biphenyls (PCBs) at 25 mg/kg at the WACS Site Composite Building and 10 mg/kg of PCBs at the FAA Site [aka CAA Towers - due to proximity of residence). *NOTE to file: TPH is no longer an acceptable cleanup criteria, now using Total BTEX, DRO, GRO, and RRO |
Jennifer Roberts |
| 2/19/1992 |
Update or Other Action |
EPA MEMORANDUM
SUBJECT:Permits and Permit "Equivalency" Processes for CERCLA On-site Response Actions
FROM: Henry L. Longest II, Director, Office of Emergency and Remedial Response
TO: Director, Waste Management Division, Regions I, IV, V, VII, and VIII; Director, Emergency and Remedial Response Division, Region II; Director, Hazardous Waste Management Division, Regions III, VI, and IX; Director, Hazardous Waste Division Region X
PURPOSE: The purpose of this directive is to clarify the Environmental Protection Agency (EPA) policy with respect to attaining permits for activities at CERCLA sites. CERCLA response actions are exempted by law from the requirement to obtain Federal, State or local permits related to any activities conducted completely "on-site". It is our policy to assure all activities conducted "on site" are protective of human health and the environment. It is not Agency policy to allow surrogate or permit equivalency procedures to impact the progress or cost of CERCLA site remediation in any respect.
BACKGROUND: In implementing remedial actions, EPA has consistently taken the position that the acquisition of permits is not required for on-site remedial actions. However, this does not remove the requirement to meet (or waive) the substantive provisions of permitting regulations that are applicable or relevant and appropriate requirements (ARARs). (For definitions of "substantive" and "administrative," see 55 FR 8756-S7 and the CERCLA Compliance with Other Laws Manual, Part I, pages 1-11-12.) The proposed and final 1982 National Oil and Hazardous Substances Pollution Contingency Plan (NCP) made no mention of the permit issue. However, EPA addressed the issue in a memorandum entitled "CERCLA Compliance with Other Environmental Statutes" which was attached as an appendix to the proposed 1985 NCP (50 FR 5928, February 12, 1985). The memorandum stated: "CERCLA procedural and administrative requirements will be modified to provide safeguards similar to those provided under other laws. Application for and receipt of permits is not required for on-site response actions taken under the Fund-financed or enforcement authorities of CERCLA."
EPA determined in the final rule [1985 NCP section 300.68 (a)(3)] that "Federal, State, and local permits are not required for Fund-financed action or remedial actions taken pursuant to Federal action under section 106 of CERCLA." The 1986 amendments to CERCLA codified section 300.68(a)(3) of the 1985 NCP with a statutory provision, section 121(e) (I). CERCLA section 121(e) (1) provides that no Federal, State, or local permit shall be required for the portion of any removal or remedial action conducted entirely on-site, where such remedial action is selected and carried out in compliance with section 121.
The 1990 NCP [section 300.400(e)(1)] implements this permit exemption for "on-site" actions, defining "on-site" as "the areal extent of contamination and all suitable areas in very close proximity to the contamination necessary for implementation of the response action." The preamble to the NCP (at 55 FR 8689, March 8, 1990) explains that "areal" refers both to the surface areas and the air above the site. EPA policy further defines "on-site" to include the soil and the groundwater plume that are to be remediated. On-site remedial actions may involve limited areas of noncontaminated land; for instance, an on-site treatment plant may need to be located above the plume or simply outside of the waste area itself.
See site file for additional information.
|
Jennifer Roberts |
| 4/9/1992 |
Update or Other Action |
EPA Memorandum April 9, 1992 Reply to the ATTN of ES-098. Subject Toxicity of Fuels. From Carol Sweeney Toxicologist Health and Environmental Assessment Section. To Wayne Pierre Federal Facilities Superfuend Branch (HW-124). A response has been provided to the frequently-asked question of whether a reference dose or other toxicity information can be provided for fuel mixtures so that these mixtures can be addressed quantitatively in Superfund risk assessments. The memo from ECAO Cincinnati is attached (last attachment). They have developed reference doses for gasoline, JP-5/kerosene, and JP-4, and a cancer potency factor for gasoline. The memo emphasizes that these are provisional numbers and that considerable uncertainty is involved in this quantitative assessment, because of data limitations, and because inhalation studies were used to calculate oral reference doses.
I typed up a summary table showing the numbers (first attachment) and calculated some risk-based concentrations (second attachment). On the risk-based concentration table, I also
included ordnance compounds, because I hadn't made a table of those before that I can remember. The risk-based concentrations were calculated the same way as table II-1 and II-2 of the Region
10 Supplemental guidance; for soil, the same limitations apply, that the numbers presented do not consider pathways other than soil ingestion.
Toxicity Reference Vaules for Fuel Mixtures EPA Region 10 4/9/1992 Non-cancer effects-Gasoline (unleaded) RfD (mg/kg-day) Oral: 2.0E-1, Uncertainty Factor-Oral:1000, Level of Confidence-Oral: Low. Toxicity Data Source-Oral RfD: Memo 3/92. Carcinogenicity-Cancer Potency/(mg/kg/day): Oral 1.7E-3, Unit Risk (/ug/m3) 4.8E-7, Cancer Weight Of Evidence-C, Toxicity Data Source-Oral SF and Inhal. SF: Memo 3/1992.
Kerosene/JP-5 RfD2.0E-2, UF Oral: 10,000, LOC Oral: low, TDS Oral RfD: Memo 3/92
JP-4 RfD 8.0E-2, UF Oral: 10,000, LOC Oral: low, TDS Oral RfD: memo 3/92.
Screening Values for Water RBCs based on Ingestion, Residential
Gasoline-Risk = 10-6 (ug/L) 50, 10-4=5000 HI=1 (ug/L) 7000
JP-5 Kerosene Risk 10-6 10-4=NA HI = 1 (ug/L) 700
JP-4 Risk 10-6 10-4 = NA, HI = 1 (ug/L) = 3,000
Screening Values for Soils- RBCs Based on Soil Ingestion Residential
Gasoline-Risk = 10-6 (mg/kg) 400, 10-4 (mg/kg) 40,000, HQ = 1 (mg/kg) 50,000
JP-5 Kerosene Risk 10-6 10-4 NA, HQ =1 5,000
JP-4 Risk 10-6 10-4 NA, HQ = 20,000
IARC concluded that gasoline is possibly carcinogenic to humans (Group 2B). IARC concluded that marine diesel fuel is possibly carcinogenic to humans (Group 2B), but light diesel fuels and jet fuels are not classifiable as to their carcinogenicity in humans (Group 3). |
Louis Howard |
| 4/12/1994 |
Document, Report, or Work plan Review - other |
EPA Region 10 sent letter to USAF Lt. Colonel Rodney L. Hunt 11th CEOS. The letter was to inform the Air Force that EPA Region 10 has completed the review of the Preliminary Assessment (PA) report for the Port Heiden White Alice Communication site located near Port Heiden, Alaska. The PA and supplemental information have been evaluated in accordance with 40 CFR Part 300 Appendix A, which is EPA's Hazard Ranking System (HRS) used to evaluate federal facilities for inclusion on the National Priorities List (NPL).
From our evaluation, EPA has determined that the facility does not score high enough to be proposed for inclusion on the NPL. Therefore, a recommendation of no further remedial action planned (NFRAP) on the EPA's part will be included in our Federal Agency Hazardous Waste Compliance Docket tracking system. If new or additional information to be proposed for the NPL, EPA must reevaluate your facility accordingly.
EPA's NFRAP designation does not relieve your facility from complying with appropriate Alaska state regulations. The Superfund Amendments and Reauthorization Act (SARA) of 1986*, Section 120(a) (4) requires federal facilities to comply with state cleanup requirements and standards when not listed on the NPL.
This facility will not be removed from the Federal Agency Hazardous Waste Compliance Docket, but as noted earlier, will be listed for no further action by EPA. Mark Adar Federal Facilities, Site Assessment Manager.
|
Louis Howard |
| 12/30/1994 |
CERCLA PA |
Preliminary Assessment received. The assessment was conducted under Contract No. DACA85-92-D-0007 Delivery Order 0007 U.S. Army Engineer District, AK Prepared by: CH2MHill. The preliminary assessment (PA) is the first step in the investigative process under the NCP. It involves a review of existing information & an offsite reconnaissance, if appropriate, to determine whether a release requires additional investigation or action under CERCLA.
Because the Port Heiden WACS site contains several areas of possible contamination, it is referred to in this PA as “the site"; individual areas within the site are referred to as "source areas" or "sources." Potential source areas investigated for this PA were selected based on previous investigations, bldg. or facility use, & historical waste-management practices. During the past 10 years, extensive site investigation & remediation has occurred at the site. Much of the contaminated soil & hazardous material has been incinerated or retrograded to Elmendorf Air Force Base (AFB) for ultimate disposal.
The remaining areas of concern are the tank farm area near the Village of Meshik, the "black lagoon* (outfall & sewer drain) & the "gray lagoon" (diesel storage) areas of the WACS site. The contaminants of concern in each area appear to be long-chain hydrocarbons (diesel & residual range). Because of the hydrogeology of the area, surface water would be the likely pathway of concern. Also, because of the nature of the contaminants, the toxicity is relatively low.
The plans of the USAF to implement final remedial measures at the 3 remaining areas of concern & to give the site a low to moderate priority are appropriate. Final verification of past remediation & proper landfill closure also could be accomplished at that time. Because of the high rate of personnel turnover typical at a military installation, specific information pertaining to historical operations & past waste-mgt. practices at the site was scarce. In the absence of documented spill information, a 10% spill rate was used to account for incidental spills that may have resulted from routine handling & storage of the estimated quantities of products & wastes at the site.
Where possible, historical documentation was obtained to verify assumptions. Because this 10% factor was not considered appropriate for heavy-use items such as petroleum products, a 0.1% spill & leak factor for 20 years of use of petroleum related products at the facility was applied to establish a relative potential for contamination. This amount conservatively estimates incidental overflow, as well as valve & pipe leaks, resulting from operation of a fuel system in the harsh climate of the Alaska Peninsula. Any specific reported fuel release was included in this 0.1% factor to determine the overall potential for fuel contamination over the life of the facility.
Regarding batteries, past history inspection & interviews have shown approximately half of the batteries were shipped out by barge or airlift to Elmendorf AFB for disposal. The other half of the batteries generated at each facility probably were disposed of in the old site landfill.
The relatively high incidental spill rate can be attributed to product & waste handling operations in extreme climatic conditions. Many of the operations occur outdoors, where limited daylight & inclement conditions frequently occur during the winter months. Extreme winds at the site would also be a contributing factor in the high incidental spill rate for outdoor operations.
The estimates of 10% for general wastes, 0.1% for fuel, & 50% for batteries represent a general relative guide for a potential for contaminant release at remote Alaska military facilities. These estimates are based on site inspections, analytical data reviews, interviews, partial inventory lists, periodic retrograde activities, & regulatory inspections of hazardous-material storage facilities at Elmendorf AFB.
The analytical results & field observations identified the following sources of contaminants at the WACS site:
• Asbestos in pipe insulation, floor tiles, & wallboard
• PCB-contaminated sludge in floor trench
• PCB-contaminated soils (200 parts per million [ppm]) to the west & north of the composite bldg. in the upper 2 feet of soil
• Soil contaminated by POL (saturated) & metal (total arsenic, 19 ppm; barium, 136 ppm; chromium, 15 ppm; lead, 28 ppm) in an outfall & sewer drain, called "the black lagoon"
• UST on east side of bldg.
See site file for additional information. |
Louis Howard |
| 3/13/1996 |
CERCLA SI |
A preliminary assessment/site inspection (PA/SI) was conducted by EMCON Alaska Inc. (EMCON) at the former Radio Relay Station (RRS) Port Heiden, Alaska.
IRP site OT001 (composite building and associated White Alice Arrays): IRP Site OT001 is comprised of the former composite building, four former White Alice Arrays, Burial Site I (BS I), and former underground storage tank (UST) locations around the former composite building The composite building was constructed of reinforced concrete slabs and contained offices, dormitories, storage space, and a garage.
From 1981 to 1990, contaminated soil and hazardous materials were removed from OT001 PCB- and
TPH-impacted soil were excavated and remediated, or landfilled. In 1990, asbestos was removed from the composite building and landfilled at AOC07 (Landfill A) Confirmation sample analytical results indicate that TPH- and PCB-impacted soil above the cleanup levels of 5,000 ppm and 25 ppm respectively, have been removed from the site. Soil with TPH concentrations below 5,000 ppm and having PCB concentratmns below 10 ppm was placed into the soil caps of Landfills A and B.
An SI was conducted at the Port Heiden RRS in October 1995. Soil was excavated from the 1990 indicated that TPH-impacted soil above the 5,000 ppm cleanup concentration may remain in this vicinity. Soil was removed to approximately 6 feet bgs PID readings of soil removed from the trench and from the soil at the trench limits were ND There was no odor or visible impact to the soil. No samples were submitted for laboratory analysis and the excavated soil was returned to the trench.
No further action is recommended at site OT001. |
John Halverson |
| 12/15/1997 |
Document, Report, or Work plan Review - other |
Management Action Plan comments provided by ADEC staff to USAF.
General Comments-ADEC has concerns whether the previous investigations have located all of the areas of former & existing facilities & use areas related to the former U.S. Air Force White Alice Communications Site & the former Army Airs Corp Base (Fort Morrow, FUDS site). The RI/FS & Risk Assessment scheduled for FY99 should incorporate all military use areas.
Specific Comments 2. (pg. l) Table of Contents: Chapter 3 should include the history & status of community involvement activities, & proactive community relations strategy & description is necessary within Chapter 4. Please address in the appropriate sections throughout the text. 3. (pg. 2-2) Figure 2-1. The draft Historical Report of Site Remediation & Restoration Activities (dated August 1995) prepared by EMCON should be included in this table. ADEC is not aware of a final version of this document. If one is available, please insert the final version title into this table, & forward a copy of the report to the Department.
Figure 2-1: Some of the categories are presented next to the AOC references. Due to the copying difficulties & the visibility of hatched areas, the appropriate categories should be noted for all the AOC references. Please include a notation for the 600-gallon UST associated with the former composite building.
Summary of Regulatory Agreements: The DEC-approved alternative cleanup level (ACL) of 5,000 ppm for total petroleum hydrocarbon should be clarified within this section & throughout the text. Based on the DEC letter dated June 20, 1991, the ACL does not include benzene, ethylbenzene, toluene, & total xylenes. The currently accepted PCB target cleanup levels for unrestricted land use are 1 mg/kg total PCBs or less within the upper 10 inches of the surface soil, & 10 mg/kg or less within the subsurface soil. Please address these target cleanup levels within this section & throughout the text.
Table 3-1: Solvents should be included within OT001 under the category of "Materials of Concern." 3.2 IRP Sites: It is stated within this document that NFA is planned for site OT001. However, several areas need to be appropriately addressed prior to a NFRAP determination. It appears that no field screening or soil confirmation sampling was conducted within the UST areas in OT001; the tank areas include: two former 20,000-gallon fuel tanks, one former 30,000-gallon MOGAS tank, & one 600-gallon tank. Clarification of the available data & the applicability to the ADEC UST regulations is necessary prior to a determination is made for a NFRAP site status.
The former location(s) of transformers should be noted & soil sampling conducted within the area. It is unclear whether PCB field screening & soil sampling was performed throughout the site area, or just within the outside perimeter of the composite building & the diamond-shaped area northeast of the building. Additional data should be collected for OT001 during the scheduled RI/FS in FY99.
|
Gretchen Pikul |
| 10/28/1999 |
Site Added to Database |
PCB, transformer oil, pesticides and POL. |
Gretchen Pikul |
| 12/5/2000 |
Update or Other Action |
Ownership of the pipeline from the POL Tank Area to the Composite Building Area (OT001) has been transferred to Reeve Aleutian Airways. The airline couldn't withstand the effects of increased competition, deregulation and the continued difficulties of flying to the Aleutians. Reeve Aleutian Airways stopped scheduled air service December 5, 2000, after nearly 70 years. |
Louis Howard |
| 1/30/2001 |
Document, Report, or Work plan Review - other |
Final Site Investigation, Port Heiden RRS, Alaska (dated July 2000) – no draft version was received for ADEC review prior to the final version being submitted – this investigation was performed to update the relative risk evaluation for select sites at Port Heiden and Driftwood Bay RRS, however, a rock slide blocked access to 2 of the sites at Driftwood Bay and therefore the investigation was not conducted at 2 of the selected sites – pending funding, the samples may be collected this field season.
OT 001 includes the former Composite Building, four White Alice Arrays, Burial Site 1, and three former underground storage tank (UST) locations From 1981 until 1986 the USAF, in several mobilizations, removed building material and electrical transformers, excavated
POL and PCB contaminated soil, and shipped drums, barrels, and boxes to Elmendorf AFB
containing the contaminated soil and various liquids of petroleum-based composition, solvents, herbicides, cleaning compounds, and other liquids of unknown composition
In 1986, 1987, and 1988, the COE conducted soil sampling and detected PCBs and halogenated volatile organics. In 1990, Underwater Construction and Associates, Inc (UC&AI) performed demolition, restoration, and remediation activities under a Defense Environmental Restoration Program (DERP) contract Northwest EnviroServices, Inc (NWES) was subcontracted to conduct
environmental sampling during the remediation activities. In 1991, the Alaska Department of.Environmental Conservation (ADEC) approved a final cleanup goal of 5000 ppm for Total Petroleum Hydrocarbons (TPH) and 25 ppm for Polychlorinated Biphenyl compounds (PCBs) in soil.
In order to fulfill the data requirements for completion of an internal risk scoring for this site, the concentration of the compounds benzene, toluene, ethylbenzene, and xylene (BTEX compounds), were analyzed in surface and/or subsurface soils in the vicinity of the composite building Nine subsurface samples were collected from underneath the vegetated cap and analyzed using EPA Method 8020. |
Gretchen Pikul |
| 12/7/2001 |
Update or Other Action |
Management Action Plan received.
This Management Action Plan (MAP) for the Port Heiden Radio Relay Station (RRS) is intended to be a strategic document integrating the Environmental RestoraUon Program (ERP) into a series of response actions necessary to protect human health and the environment. Due to the dynamics
inherent in the strategic planning process, the MAP represents a "snapshot" in time, requiring periodic updating to remain useful. This MAP does the following:
- Describes the environmental response objectives, the MAP purpose, and a brief history of the installation (Chapter 1);
-Identifies all known contaminated sites; environmental condition of property; real property; off-base faclhties and properties; and non-Air Force tenants (Chapter 2);
-Summarizes the status of the Installation Restoration Program (IRP) and regulatory agreements (if applicable); IRP Sites; Areas of Concern (AOCs); and community relations program Chapter 3);
Describes the installation-wide strategy for environmental restoration through the definition of zones (including current scope of removal and remedial activities associated w_th, or to be completed for, each), and contracting and hiring strategy (Chapter 4); and
- Provides a Master Schedule of planned and anticipated acUvitles to be performed throughout the duration of the ERP (Chapter 5).
The MAP will be updated a minimum of once a year. The Remedial Project Manager (RPM) has the options of:
- Marking changes in the MAP as they occur;
- Updating the MAP when there are major changes in the program; or
- Conducting a formal annual review and update.
Removal actions or other interim actions will be conducted, as required, to eliminate identified and potential sources of contamination from the Port Heiden RRS installation. A Remedial Investigation/Feasibility Study (RI/FS) is programmed for FY 2006. The RI/FS will fully investigate the five identified IRP Sites to delineate the extent of the contamination and to determine appropriate removallremedml and interim actions, if any, that are necessary. AFRIMS projects are programmed for FY2008 in anticipation of possible removal/remedial actions; however, no removal actions are currently planned at Port Heiden RRS.
The RI/FS programmed to begin in FY 2006 will provide the information needed to make knowledgeable decisions concerning site cleanup, closure, and eventual close-out. Proposed Plans for remedial actions will be presented for community input prior to finalizing remedaal action decisions. Decision Documents will formalize the cleanup decisions and agreed upon cleanup levels. Our goal at Port Heiden is to have all IRP sites and AOCS closed-out
by the end of FY2008.
All AOCs and IRP Sites are scheduled to be closed by 2008. Upon completion of all
Restoration Program actions the Port Heiden property will be excessed. At that time the Department of Defense will no longer require use of the property for National Defense and it will revert to its previous use. |
Louis Howard |
| 6/13/2002 |
Update or Other Action |
DEC received a fax and letter from the Lake and Pennisula Borough and the City of Port Heiden about a phone call from an annonymous worked who reported dumping drums of hazardous material into a trench on the northwest side of the former White Alice site and that the chemicals could cause health problems for the villlagers. The letters requested DEC assistance in following up on the call and ensuring the former military sites are cleaned up properly. |
John Halverson |
| 6/19/2002 |
Update or Other Action |
DEC sent letter to the Corps of Engineers and the 611 CES (Air Force) informing them on the community concerns and asking for cooperation in compling the site records, conducting a site inspection and community meeting, and ensuring the sites are adequately characterized and cleaned up. |
John Halverson |
| 8/9/2002 |
Update or Other Action |
Butch Douthit
Friday, August 09, 2002 8:18 AM
Halverson, John
'Laurie Mulcahy'; Tom J Schmid
Re: Port Heiden - Airport Improvement Project
Laurie requested I let you know the scope of our airport project. The Runway Resurfacing project will consist of resurfacing both runways (5/23 &13/31), constructing full safety (widening from 200' to 300') areas and replacing the lighting system. Runway 5123 will have a new dimension of 100 feet by 5,000 (previously 6,250) feet and runway 13131 will have a new dimension of 100 feet by 4,000 (previously 4,600) feet. The apron and taxiways will be reconditioned with new lighting and surface course. All the electrical controls and rotating beacon will be relocated to the maintenance building. The barrels on the existing segmented circle will be replaced with panels.
The 100' runway widening Is Into/over areas "worked" during our last project -In 1988 so there should be no surprises there. Our material sites -are on the north side of the airport. One site Is undisturbed ground, the second has seen some previous gravel extraction.
I can be reached at 269-0605 or Tom Schmid, the design engineer can be reached at 269-0612.
H. M. (Butch) Douthit
Halverson, John- wrote:
We are looking through the files now and checking with the Air Force and the Corps to make sure that we have all the pertinent documentation on past assessment and cleanup work. Do you have areas where you're planning to do much digging? If not, It shouldn't be a concern. If yes, you may want to have someone stop over with some diagrams and we could look at what we have.
The Air Force cleanup work was long enough ago that there wasn't any coordination with DEC, but we do have Information showing that they have more to do. The Corps cleanup contract went over budget, they were not able to finish and never even did a report documenting what was completed and what remains.
We are looking at going out to meet with interested community members and doing a site visit sometime during the week of Sept. 9. They received a phone call from someone that used to work at the site and he reported that he was instructed to, and did, dump drums of wastes in a trench near the old white alice site. It has people pretty concerned.
Original Message
From: Laurie Mulcahy [mallto:laurie_mulcahy@dotstate.ak.us]
Sent: Thursday, August OS, 2002 4:34 PM
To: Halverson, John
Cc: Harvey M Douthit
Subject: Re: Port Heiden - Airport Improvement Project
John: we reviewed a previous airport upgrade EA that indicated an ADEC approved site closure. Let me know of your areas of concerns, we are just About ready to advertise that project. Laurie
Halverson, John- wrote:
We recently had some concerns raised by villagers at Port Heiden over contamination associated with the old military sites there. As I was going through our file information I saw a Feb.7, 2002 letter about a runway resurfacing project 1# 55071 that OOT&PF is working on. The letter, from Jerry O Ruehle, and attached Information states that DOT does not expect to run Into contamination but that there Is some potential, to because of past military activities; it states that DEC approved the cleanup and site closure during the 80's and 90's. However, that Is not the case.
Both the Air Force 8nd the Corps of Engineers have done cleanup work in the past and both still have future projects scheduled to complete the necessary cleanup.
This may not adversely effect the planned airport improvement project. But I want to make sure that DOT does not have the mistaken Impression that the site was cleaned up to applicable levels and closed out. |
John Halverson |
| 9/5/2002 |
Meeting or Teleconference Held |
John Halverson traveled to Port Heiden on September 4, 2002 with Ron Pflum (Corps of Engineers) and Larry Underbakke (611 CES, Air Force) to meet with villagers and inspect the site in response to concerns over the old military sites. Sandra Borbridge (Air Force Tribal liaison) joined us later in the day. We met with Lynn Carlson (City and Village), Scott Anderson (Tribal Environmental Coordinator), and Gerta K (City) to discuss the site characterization and cleanup history and their concerns over the sites.
Many residents expressed concern over health problems and their thoughts that there may be a link between past military activities and health problems. Scott Anderson, Tribal Environmental Coordinator and Lynn Carlson helped coordinate the meeting and site inspections. The surface cleanup work appears to have been very thorough and the landfills are adequately covered. Subsurface characterization is needed. Residents want their water wells sampled and had applied for a grant from TASWER to conduct the sampling. DEC, the Corps and Air Force staff said they would work together to help get wells sampled.
They described trenches that had anti-aircraft guns in them between the airport and the shoreline and finding a cache of ammunition (30-06, 45 cal and larger) in the dunes near the shoreline. People used what they thought was salvageable and reported left the rest. We walked the area on Thursday with Amil and Scott, but were unable to find any OE items. The area may have eroded and become grown over with grasses. Someone pointed out concern over what had been dumped off-shore. They said the navigational charts show there is military debris in certain areas that could be a hazard to navigation or fishing gear.
Amil later showed us a 37 mm cartridge and a projectile that had rifling marks (has been fired) that is in his mother's house. The cartridge is cracked and empty but the projectile has been put back into it. |
John Halverson |
| 9/6/2002 |
Update or Other Action |
Email message from John Halverson to Larry Underbakke (611 CES PM at the time)
I talked with Amil Christensen and Lynn Carlson. The 37 mm round we saw was at Amil's mom Anne's house. He is going to talk to her about it, take a couple digital photographs and email them to me. He said hell make sure they leave it alone where it won't get knocked around.
I'11 forward the photos on to the Army EOD Sgt. Sullia. I talked with him earlier today and they are willing to respond but he said that Christensen's would have to agree to tum the item over. He said sending them photos would help identify exactly what it is and how much of a concern it is. Ron, I don' know if you have seen the article and link pasted below.
---Original Message----
From: Underbakke Larry Mr 611CES/CEVR [mailto:Larry.Underbakke@ELMENDORF.af.mil]
Sent: Monday, September 09, 2002 7:43 AM
To: Halverson, John'
Subject: RE: (CPEO-MEF] Old explosives, new jitters in Butner
John, I am checking into this. I will get back to you when I get some info. This is a WWII army round but we will see what we can do. Please let Ron Pflum know also.
--Original Message-----
From: Halverson, John [mailto:JHalvers@envircon.state.ak.us]
Sent: Friday, September 06, 2002 2:36 PM
To: Larry Underbakke
Subject: FW: (CPEO-MEF] Old explosives, new jitters in Butner
Larry, by coincidence Jennifer forwarded this to me this AM. It describes the Army detonating a WWII 37 mm round that been previously fired.
The projectile that has been put back on the casing that Anne had in her house had been fired (based on the rifleing marks). I didn't figure that projectile would have had an explosive charge, but I may be wrong. What do you think? H it does, I need to make sure they are aware of it. |
Louis Howard |
| 9/9/2002 |
Update or Other Action |
Staff contacted the Army Explosive Ordnance Disposal (EOD) team at Fort Richardson regarding the ordnance item in a residence at Port Heiden. The EOD representative (Sgt. Bryant 384-7603) said they were willing to go out and destroy the item, if the home owner wanted. DEC staff coordinated with the village and EOD to dispose of the item. |
John Halverson |
| 9/18/2002 |
Update or Other Action |
After conducting the site visit earlier this month, staff researched options for groundwater characterization at Port Heiden and found out the the City of Port Heiden is on the Village Safe Water program's list for a Water and Wastewater Feasibility Study in FY03. The scope calls for evaluating the current systems, the aquifers, water use and estimated future needs. It may include some limited testing, but not sampling 30 wells; it is a civil works project rather than environmental.
Staff is working with the Corps of Engineers to sample existing wells under the Native American Lands Environmental Mitigation Program (NALEMP). |
John Halverson |
| 9/30/2002 |
Update or Other Action |
Email message from John Halverson (ADEC PM at the time) to Scott Anderson and Lynn Carlson RE: Environmental Work Status with mention of EOD response
Also, the Army Explosives Ordnance Disposal (EOD) group is planning to send a couple of guys out this week, weather permitted, to dispose of that WWII projectile. They are planning to fly out with on a State Trooper flight that is going to Cold Bay and then I think they plant to fly back commercially. Sergeant Bryant is the guy I have talked to the most on this, his number is 384-7603. Other people I have talked with are Sgt. Klein and Sgt. Mitchell.
|
Louis Howard |
| 4/29/2003 |
Meeting or Teleconference Held |
DEC and the Air Force participated in a public meeting at Port Heiden to update the community on Air Force plans for conducting remedial investigation work in 2004 and completing a proposed plan, record of decision and implementing a remedy by 2007. The Corps does not have work planned for Fort Morrow until 2011, but will re-evaluate the schedule based on any new information (water well sample results). |
John Halverson |
| 6/5/2003 |
Update or Other Action |
Keres Environmental is sampling all water wells in Port Heiden under the Native American Lands Environmental Mitigation Program (NALEMP). Sampling plans were reviewed by DEC and the Corps and each well will be tested for VOC, PAHs, PCBs, and metals. Sampling will be conducted during the first week of June and results are anticipated by early August. |
John Halverson |
| 7/17/2003 |
Document, Report, or Work plan Review - other |
Comments on RI/FS sent to Air Force Project Manager. |
Lynne Bush |
| 8/25/2003 |
Document, Report, or Work plan Review - other |
Staff provided comments to the Technical and management approach for the Remedial Investigation/Feasibility Study, Risk Assessment. Sites must be called by specific names which do not change or if they do the documents must be able to explain what sites were combined or dropped out. Applicable Guidance Documents and Regulations: Please include 18 AAC 60 as a reference and consider including 18 AAC 72 and 18 AAC 80.
Staff requested clarification on whether or not DDT was the only pesticide known to be used or will others need to be considered during the investigation of the facility as well as any possible herbicide use. Regarding field screening, staff requested whether or not Envirogard would be able to screen beyond DDT as a contaminant of concern if other pesticides or herbicides were discovered to have been used at the facility.
Delineation of both nature and extent of surface soil contamination should include reference to delineation of vertical and horizontal extent of contamination. Staff requested DRO and RRO be listed separately for analyses being considered instead of being combined in the same row of the tables for soil, surface water and ground water.
Construction scenario must be clarified to refer to construction work scenario in text. Staff requested clarification on whether or not other gradient studies of groundwater being considered after the first round of data collection since seasonal changes in flow and direction may be a factor. |
Lynne Bush |
| 8/29/2003 |
Update or Other Action |
All parties signed Joint Cooperative Agreement Execution Plan. |
Lynne Bush |
| 11/6/2003 |
Update or Other Action |
Keres Environmental sampled 42 domestic (private) wells out of 52 wells identified in Port Heiden during June 2003 under the Native American Lands Environmental Mitigation Program (NALEMP). The 42 domestic wells were the only ones that were either functioning or accessible for sampling. Samples were analyzed for: diesel range organics (DRO), gasoline range organics (GRO), volatile organic compounds (VOCs), polynuclear aromatic hydrocarbons (PAHs), via the selective ion method (SIM), pesticides, polychlorinated biphenyls (PCBs), and safe drinking water act (SDWA) primary metals plus lead, iron, and copper. The first and second areas chosen for potential impact identified by the community members based on their location relative to the Port Heiden housing areas were located north and south of the road to Annie Christensen's house.
The third is west of the New Meshik Mall, and the fourth is north of the new HUD area toward the west end, and the fifth is on the northeast side of the road from new HUD to the airport. Additionally, an old drum storage area is located north and west of the hazardous waste site on either side of an unnamed community road. The drum site is also of interest to the community. The other areas of interest and the other identified hazardous waste site are not located near housing and generally lie west/northwest of Port Heiden.
Only six organic compounds were identified during sampling, ALL were below federal and state maximum contaminant levels (MCLs) for drinking water.
"Maximum contaminant level" or "MCL" means the maximum permissible level of a contaminant in water that is delivered to any user of a public water system. "Contaminant" means a physical, chemical, biological, or radiological substance or material in water that, in sufficient quantity, makes water unfit for human consumption. Arsenic and iron were observed in the analytical results. Arsenic was below the Federal standard of 10 ppb or 10 ug/L (0.010 mg/L) and the State standard of 50 ppb or 50 ug/L (0.050 mg/L).
Iron in 29 of the 42 domestic wells sampled exceeded the secondary maximum contaminant level of 0.3 mg/L or 300 ppb (300 ug/L) applicable only to community water systems not private domestic wells. According to the US EPA, National Secondary Drinking Water Regulations (NSDWRs or secondary standards) are non-enforceable guidelines regulating contaminants that may cause cosmetic effects (such as skin or tooth discoloration) or aesthetic effects (such as taste, odor, or color) in drinking water. EPA recommends secondary standards to public water systems but does not require public water systems to comply. However, states may choose to adopt them as enforceable standards. |
John Halverson |
| 11/6/2003 |
Meeting or Teleconference Held |
Met at Elmendorf to discuss future site plans and contents of work plan. Much of the land is not owned by the Federal government, creating site access issues which may become problematic. Air Force real estate staff will take the lead on this. The Air Force wants a signed Record of Decision in hand by early in 2006, requiring all parties to work closely and to, whenever possible, provide immediate reviews and comments. |
Lynne Bush |
| 12/1/2003 |
Update or Other Action |
Storms in Western Alaska are eroding large sections of land near Port Heiden, including the former above-ground storage tanks on the ocean near Goldfish Lake. The Air Force is mobilizing to help the people in Port Heiden move graves to a new location to avoid being lost to the sea. |
Lynne Bush |
| 12/10/2003 |
Meeting or Teleconference Held |
Alan Wien, DEC PERP, is to be the main contact for shoreline erosion issues. Limited soil sampling will be done during grave repatriation efforts, in an attempt to capture some site characterization data from an area that may be lost to the sea in the near future. |
Lynne Bush |
| 12/11/2003 |
Meeting or Teleconference Held |
Met with Air Force staff to discuss work plans, especially in light of shoreline erosion issues. We discussed screening and sampling protocols, locations, frequency, etc. and how they will be presented in the yet-to-be prepared worrk plan. The Air Force wants to be able to convey the sites as soon as practicable. All parties agreed that a Risk Assessment, or at least the data collection for one, will need to be part of the project now, if the Record of Decision is to be completed by early 2006. This extremely productive meeting will provide the basis for the draft work plan. |
Lynne Bush |
| 1/14/2004 |
Meeting or Teleconference Held |
Site visit. |
Lynne Bush |
| 1/16/2004 |
Document, Report, or Work plan Review - other |
Reviewed Village Safe Water report. Coordinated exchange of information between the Air Force, Village Safe Water and the Federal Native American Lands Environmental Mitigation Program. |
Lynne Bush |
| 2/25/2004 |
Update or Other Action |
Began review of work plan. The risk assessment portion of the work plan will be provided later. |
Lynne Bush |
| 2/27/2004 |
Meeting or Teleconference Held |
Met at the Weston offices to discuss the review of the work plan, the risk assessment work plan currently being prepared by Weston, and to introduce everyone to Lindsay Smith, DEC Risk Assessor, who will be working with the Air Force to develop a risk assessment work plan. |
Lynne Bush |
| 3/3/2004 |
Document, Report, or Work plan Review - other |
Reviewed and offered revisions to meeting minutes from 27 February |
Lynne Bush |
| 3/15/2004 |
Meeting or Teleconference Held |
Met with Weston personnel to discuss changes and additions to the work plan, as well as the risk assessment work plan. |
Lynne Bush |
| 3/24/2004 |
Update or Other Action |
Provided draft comments on work plan to Air Force personnel for discussion purposes. |
Lynne Bush |
| 4/6/2004 |
Update or Other Action |
After discussion and revisions, final comments provided to Air Force staff. The risk assessment portion of the work plan still has to be finalized. Until it is complete, the final locations/frequency/objectives for data collection points aren't available for comment. |
Lynne Bush |
| 4/12/2004 |
Update or Other Action |
Project management change. Bush to Halverson. |
Lynne Bush |
| 4/19/2004 |
Document, Report, or Work plan Review - other |
Change in workplan section dealing with IDW Section A-I: 3-11 Waste Handling Plan proposed by Air Force. "Because returning soil cuttings to the pilot boring during the installation of a monitoring well is not an option, all soil cuttings generated during drilling of monitoring well pilot holes will be drummed. If no contaminants arc found above screening limits (see Section A-I: 4. 1.1 for screening limits) in the boring, the non-hazardous soil will be spread on Air Force property on the northeast corner of Landfill A.
If soil is found above screening limits at any interval in the pilot boring, the soil will be held in drums pending laboratory analysis. If laboratory analysis determines that an interval of soil in the boring was above 18 AAC 75 ADEC Method 2 Cleanup Levels (ADEC, 2003), the drummed cuttings from the boring will be sampled for disposal characterization for contaminants found above Method 2. If results from the disposal characterization samples are below Method 2, the cuttings will be spread on Air Force property on the northeast corner of Landfill A. If above Method 2, the soil will be treated following the 611th Air Support Group Waste Handling Handbook and the 3rd Wing OPLAN 19-3 and shipped to the EAFB DRMO."
Section 5 response to ADEC Comment:
Comment:
"The frequency of screening and sampling is not discussed. This should be discussed at length, here and in Appendix A-i. Deviations should also be discussed, such as when obvious contamination is encountered."
As indicated to ADEC during the early planning of this project, without significant faith in the data collected to date, The Air Force is "wiping the slate clean" on this RI and starting from scratch. To focus resources in areas that are most in need of study, we want to retain as much flexibility in the field as possible. As such, we're depending on significant "real-time" interaction between the stake holders to drive sampling locations and frequency. The total estimated number of samples planned includes up to 3,000 screening samples, 450 soil samples, and 100 water samples.
Air Force preliminary response is as follows:
"All screening and sampling locations and frequencies will be determined in the field based on site conditions. All parties will have the opportunity to review and comment on the data collected in "real time" to ensure that all State, Air Force, and AFCEE requirements are fulfilled and data are sufficient to support the risk assessment and feasibility study. This language will be added to the text." |
John Halverson |
| 4/20/2004 |
Document, Report, or Work plan Review - other |
ADEC response to changes in work plan: IDW soil cuttings - the proposed wording looks good as long as the screening and subsequent sampling/analysis will be focussed on the contaminants of potential concern in each area. Obviously screening methodologies differ for PCB, semivolatiles, and VOCs. Screening/sampling frequency - ADEC agrees flexibility on selecting sampling locations is important and inclusiong of a decision tree/matrix may be the best way to address this issue. ADEC needs to take a look at the draft workplan to see how these issues are currently addressed. |
John Halverson |
| 4/4/2005 |
Document, Report, or Work plan Review - other |
Review comments from ADEC to Air Force RE: Draft RI/FS Report dated January 2005.
2-1 Table 2-1
Private water well sampling conducted in 2003 was done by the Dept. of Defense under the Native American Lands Environmental Mitigation Program (NALEMP) rather than by DEC. Please revise the table & associated text accordingly.
FYI, DEC Village Safe Water Program conducted a drinking water & wastewater feasibility study for Port Heiden & referred to the NALEMP water sampling results in that study
2-5 2.1.1.3
The last sentence in the first paragraph describing the USTs states, “It is unknown if a tank remains in place at that location.” The RI work demonstrated the tank is no longer in place so the sentence should be revised.
2-13 to 2-15 2.1.7.3
The second sentence on this page refers to Fig. 2-2 as showing the confirmation sample results where the coastline has not yet eroded. The wrong figure is referenced & I did not find one with the sample results shown; the sample results could be added to Fig. 2-5.
2-16 2.1.8
Text should be revised to state the drinking water wells were sampled by DOD under the NALEMP.
Also, the last sentence in the section should be revised. The conclusions of the water well sampling should be that village drinking water wells have not been adversely impacted by previous Air Force & Army activities. Water quality in the aquifer was not assessed beyond the area where drinking water wells currently exist.
3-9 3.7
The second paragraph on background sampling is not clear. My understanding is that background soil samples were analyzed for inorganics & background tissue samples were analyzed for inorganics along with PAHs, PCBs, & pesticides.
See site file for additional information.
|
John Halverson |
| 4/27/2005 |
Meeting or Teleconference Held |
WESTON Meeting Summary of April 27 2005 RE: Port Heiden Remedial Action Objectives.
The Air Force held a meeting at the office of Weston Solutions on 27 April 2005 to discuss upcoming cleanup activities at the former Port Heiden Radio Relay Station (RRS). The discussion provided a summary of the contamination found during the 2004 Remedial Investigation (RI) and presented some of the alternatives that were being considered for cleanup of the site. The meeting was held to initiate discussion with stakeholders not present at the community meetings in Port Heiden but with property ownership or interests on or near the RRS. These included representatives of the State of Alaska Department of Transportation (AKDOT), the Alaska Peninsula Corporation, and the Bristol Bay Native Corporation (BBNC). One of the goals of the meeting was to determine what Remedial Action Objectives (RAGS) would be acceptable to the stakeholders.
In attendance were Larry Underbakke (61lth CES/CEVR), James Kiasen (l1th Air Force JAV), Mark Goodwin (AFCEE), Ralph Angasen Sr. (Alaska Peninsula Corporation), Sam Fortier (Attorney for Alaska Peninsula Corporation), Tiel Smith (BBNC), Jack Moore (BBNC), Jacques Gusmano (United States Environmental Protection Agency [USEPA]), John Halverson (Alaska Department of Environmental Conservation [ADEC], Bob Thomas (AKDOT), Ron Stroman (AKDOT), Scott Blount (Weston Solutions), Leslie Boughton (Weston Solutions), and Russ Beck (Weston Solutions). A copy of the participant record is attached to this meeting summary.
The meeting began with discussion of property ownership and a review of property maps. It was confirmed that the majority of the Former Facility Area (former location of the antennas and composite building) is located on AKDOT property. Some portions (such as the RRS landfill and septic outfall) are located on Native Corporation land (surface rights belong to Alaska Peninsula Corporation and subsurface rights belong to BBNC). It was discussed whether the Air Force had the option of buying the property from the AKDOT. The AKDOT indicated that the State would be willing to convey the property to the Air Force and it should be considered and option in the Feasibility Study (FS).
Mr. Underbakke and Mr. Blount then provided a summary of the contamination found during the 2004 RI. They indicated that all of the information being presented would be provided in the Final RI/FS, which would be published within a year. The discussion included a summary of the contamination found at the Marine Terminal Area, along the Former Pipeline Corridor, and at the Former Facility Area.
Mr. Underbakke then provided a summary of the alternatives that were under consideration in the FS. At the Marine Terminal Area, very little contamination was found and the likely alternative would be no action because the entire area is being rapidly eroded by heavy waves during storms. Along the Former Pipeline Corridor, five small areas of soil and groundwater contamination were found and the option that appears to make the most sense is source removal with groundwater monitoring. This could include enhanced bioremediation or chemical treatment. At the Former Facility Area, several options are being considered for the various media found to be contaminated. For PCBs in surface soil; they include excavation and off-site disposal and/or off-site remediation, excavation and on-site remediation; and in-situ remediation.
See site file for additional information.
|
John Halverson |
| 5/3/2005 |
Update or Other Action |
File number issued 2637.38.002.05 |
Aggie Blandford |
| 7/15/2005 |
Document, Report, or Work plan Review - other |
Staff provided review comments on the Final Remedial Investigation Report, dated May 2005.
We received the report on June 16, 2005 and have reviewed it with respect to comments provided on the draft document. The remedial investigation and risk assessment were thorough and are well documented in the report. The department approves the report as meeting the site characterization requirements in 18 AAC 75.
Attachment one to the report is a draft remedial technology screening memorandum. Preliminary comments on it were forwarded to you and Weston Solutions via email on June 30th; final comments are attached and are essential the same.
ADEC comments on the Draft Remedial Technology Screening and Alternatives Development Memo, dated May 2005.
1. Tables 2.3-1 and 2.3-2:
• A broader range of institutional controls should be included. Deed notices provide information to people that conduct title searches, but are not very effective at limiting land use. Land use controls/land management planning are listed as NA for effectiveness and cost, but may be more effective both for soil and groundwater controls than deed notices; this would need to be determined through coordination with the landowners.
• Under ex-situ soil treatment - solidification or stabilization of PCB soil should be considered as an alternative; this comment also applies to Table 2.4-2.
• Natural attenuation is listed as effective for soil; it should list the COCs for which it is effective, natural attenuation is not effective for PCBs. Also, recommend changing "natural attenuation" to "monitored natural attenuation" throughout the document.
2. Sect 2.4.1:
• For remedial alternatives analysis, defining surface soil as from the surface to between 9 and 11 feet bgs is ok. Please note, State cleanup regulations define surface soil as the top 2 feet, and subsurface soil as > 2ft bgs and that ingestion and inhalation cleanup levels apply to a depth of 15 ft. bgs.
3. Table 2.4-2 Surface Soil:
• Excavation, solidification and on-site disposal should be considered for PCB soil, especially for soil with < 50 mg/kg PCB. There is already a landfill on the AF property that warrants land use restrictions; consolidation of PCB waste in that area may be a protective and cost effective remedy.
• Excavation and off-site disposal should be considered for PCB contaminated soil, especially that with > 50 mg/kg PCB.
• Variations of this could be evaluated (remove, solidify and dispose on-site all PCB >1 and < 50 with off-site disposal of soil containing > 50 mg/kg PCB; remove, solidify and dispose of all soil > 10 and < 50 PCB with off-site disposal of > 50, or use of some other mutually agreeable risk based levels).
4. Sect 3.1:
• Here the text defines subsurface soil as > 15 ft bgs.
5. Sect 3.2.3.2:
• In describing Monitored Natural Attenuation it refers to sampling infrequently (such as every ten years). Monitoring would need to be conducted more frequently initially and then may be reduced after adequate baseline and initial trend data are developed.
6. Sect 3.2.3.3:
• For in-situ groundwater treatment the monitoring plan and timeframe would need to be developed; one sampling event ~2 wks after treatment would not likely be adequate as we would want to ensure the system has time to move back into its natural equilibrium.
7. Sect 3.3.1.3 - see comment above on Table 2.4-2.
8. Table 3.3-2
• In-situ biological treatment (i.e., bioventing) should be evaluated.
|
John Halverson |
| 7/22/2005 |
CERCLA RI Report Approved |
DEC approved the final RI report dated May 2005. The AF property was evaluated in three main areas, the former WACS facility, the pipeline corridor and the former fuel tank farm. The former facility area has PCB contamination in soil, petroleum contamination in soil and groundwater and TCE contamination in groundwater. Groundwater flows toward the northwest away from the village. Localized areas of petroleum contamination in soil and surface water were found along the pipeline corridor, with one area near the airport and Frosty Fuels pipeline having groundwater contamination. The former tank farm area did not have contamination above cleanup levels.
26 samples were collected from soil borings around the perimeter of the antenna pads, two had PCBs (Aroclor 1260) above screening criteria (1 mg/kg). Borings RRS-SB-18 (northwest corner of Antenna Pad 1) and RRS-SB-20 (southeast corner of Antenna Pad 2). PCB levels in RRS-SB-18 was detected at 1.1 mg/kg and RRS-SB-20 was detected at 15 mg/kg. Due to the proximity of the antenna pads to the contaminated soil removal areas, it is possible that the PCBs detected were not associated with the antenna pads, but are present due to another source. These conclusions are supported by the fact that all other shallow native soil samples around the perimeter of other antenna pads did not contain PCBs above the screening criteria. Although PCBs detected above the soil screening criteria in concrete samples collected from pads 2 and 4 could be present due to operation of the antennas, it appears unlikely that there was a significant release of PCBs associated with the antennas.
Drum storage area is located in the northwestern portion of the Former Facility Area pad. The highest PCB result was in surface soil sample DSA-SS-12-S01-0 most northern portion of the Drum Storage Area at 19 mg/kg for Aroclor 1260 NOT in sample DSA-C51-01-01-0 in the central portion of the Drum Storage Area (16 mg/kg flagged "M" for matrix effect was present) as stated in the RI Report. Groundwater contamination is present in the Former Facility Area as high as 690 ug/L (sample DSA-MW-02-W01-0) for trichloroethylene. It should be noted that groundwater flow direction at the Former Facility Area is to the north away from the village of Port Heiden and all current drinking water well locations. The groundwater resources currently utilized by the residents of Port Heiden are not threatened by the plumes present at this area.
Groundwater at the center of the Former Facility Area pad averaged approximately 60 feet bgs. At the Black Lagoon Outfall, groundwater was encountered between 40 and 45 feet bgs; at the
southern portion of the pad, groundwater was encountered at approximately 60 feet bgs; and at the Radio Relay Station Landfill, groundwater was found between 30 and 50 feet bgs (depending on the elevation of the boring).
Since there was no continuous overlying confining layer encountered during the subsurface investigation, the host saturated zone is considered unconfined. As the aquifer transitions from the glacial moraine deposit underlying the Former Facility Area to the outwash plain to the north of the Radio May Station Landfill, groundwater continues to flow to the northwest.
See site file for additional information.
|
John Halverson |
| 7/22/2005 |
Risk Assessment Report Approved |
DEC approved the human health and ecological risk assessments as part of the remedial investigation report. The risk assessments show potential carcinogenic and non-carcinogenic risks above acceptable State risk levels for the Former Facility Area. Contaminants of concern exceeding risk based levels include PCBs, TCE, pesticides, PAHs and arsenic (however, arsenic was within background levels). The risk assessments showed negligible risk along the pipeline cooridor and no unacceptable risk at the former tank farm. |
John Halverson |
| 9/16/2005 |
Update or Other Action |
Project management change. Halverson to Howard. |
Louis Howard |
| 11/22/2005 |
Document, Report, or Work plan Review - other |
Draft RI/FS dated August 2005 reviewed by staff
3-9 3.3.1.2
The last sentence in the first paragraph describing a soil cap not being necessary if the alternative were combined with a DOD facility controlled scenario (i.e., residential use is restricted at the property). There is no mention of a soil cap in Altern. FFASS2, please delete sentence from this paragraph.
3-11, 3.3.1.3
The first paragraph references old TSCA cleanup criteria which are not applicable at this facility. ADEC cleanup criteria for PCBs is 1 mg/kg for unrestricted land use (e.g. site closure) without any ICs. For PCbs in soil at levels between 1-10 mg/kg: cap each area & deed notation in appropriate land records that PCBs remain in soil, contaminated soil has been capped, & subsequent interest holders may have legal obligations with respect to the cap & contaminated soil.
For all other levels of PCBs, an approved risk assessment may set an alternative cleanup with ICs (see 18 AAC 75.341 Note 9 in Notes to Tables B1 & B2) appropriate to the land use assumptions in the risk assessment. A soil cap would be necessary regardless of land use (i.e. residential or commercial/industrial) if PCBs are above 1 mg/kg. Deed restrictions/land use controls may only be placed on property that is owned or managed by the federal government & not private property without their consent.
3-11 3.3.1.4
This section states that the cleanup level of 7.8 mg/kg was based on a risk assessment protective of a subsistence use scenario for both child & adult. ADEC disagrees. The 7.8 mg/kg level for PCBs does not take into account for cumulative risk from other chemicals of concern (compounds). 18 AAC 75.325 (h) states “…, a responsible person shall ensure that the risk from hazardous substances does not exceed the cumulative carcinogenic risk standard of 1 in 100,000 across all exposure pathways & the cumulative noncarcinogenic risk standard at a hazard index of 1.0 for each exposure pathway.”
Taking into account the cumulative risk from other compounds in addition to PCBs would likely lower the cleanup level of PCBs from 7.8 mg/kg. PCBs above 1 mg/kg would also require a cap.
4-30 4.1.3.3
This section refers to a risk based cleanup criteria of 7.8 mg/kg. See comments for section 3.3.1.4 regarding taking into account the cumulative risk from other compounds in addition to PCBs. This “risk-based” number would probably be lower than 7.8 mg/kg factoring in other contaminants.
See site file for additional information.
|
Louis Howard |
| 6/6/2006 |
Document, Report, or Work plan Review - other |
FYI entry: John Halverson (ADEC) denies 611 CES/CEVR request for waiver of the requirement that an "Impartial Third Party" conduct sampling.
We received your request for a waiver of the state requirement that a qualified, impartial third party conduct sampling, analysis, interpretation and reporting of characterization and cleanup data for work planned at Barter Island this summer. Specifically, the request was for the Civil Engineering Squadron, Environmental Operations Section (CES/CEVO) staff to be approved for collecting soil, sediment and concrete samples at Installation Restoration Program and Clean Sweep sites.
However, ADEC has several concerns over past work conducted by the CES/CEVO, which lead to our denial on the request for a waiver. It has come to our attention that the CEVO work crew allegedly discovered releases of oil or other hazardous substances and failed to report the releases to DEC in a timely manner as required by 18 AAC 75.300; assessment/cleanup reports prepared by the CEVO lack detail and required information; the field crew has reportedly not followed approved work plans. A few examples of this include:
- Point Lay where "gross petroleum contamination" was found during removal of bulk fuel tanks in 2005. We have found no record of a spill report being submitted, our contaminated sites staff working on the site was not informed, the draft report submitted this year failed to describe the release or extent of contamination clearly and instead described sampling in downgradient test pits and recommended natural attenuation for the area.
- Point Lonely, where several large fuel tanks, a pumphouse and associated piping, and petroleum contaminated soil were removed in 2005. The draft report does not adequately describe fieldwork that was conducted during the characterization and removal of the contaminated soil and lacks required information (no data quality review, lack oflaboratory data). DEC comments on the draft report have yet to be addressed and no final report has been submitted.
• North River RRS - Fieldwork was not conducted in accordance with the approved work plan (no field screening to guide excavation); the draft report lacked detail describing the field work and lacked laboratory reports and a quality assurance review, there were QA/QC problems. DEC comments on the draft report have only been partially addressed, and a final report has not been submitted. The excavation was left open with a liner placed in the bottom and rocks on it; the excavation was not properly backfilled and secured nor is it being inspected and maintained as requested by the department.
A survey of our project managers indicates there has a consistent problem with the CEVO reporting information in a clear, understandable and complete manner.
Based on these issues, we regrettably must deny your request for a waiver of the impartial third party sampler. As discussed with Mr. David Longtin of the 611 CES/CEVR, Air Force staff may conduct field screening and sampling to evaluate whether a release of oil or hazardous substances has occurred; however, a qualified impartial third party must conduct or oversee sampling, data collection and interpretation and reporting for contaminated site characterization and cleanup work on sites where releases have been confirmed. |
John Halverson |
| 2/2/2007 |
Update or Other Action |
In an interview on February 2, 2007, with representatives from the Native Village of Port Heiden, including Mr. Scott Anderson, POC for the Native Village of Port Heiden; Ms. Virginia Graham, IGAP Assistant and Council Vice President; Ms. Lynn Carlson, administrative assistant and Council member; Mr. Derek Schraffenberger, Brownfields Coordinator and Council member; Ms. Gerda Kosbruk, Tribal Administrator, and Mr. John Christensen, Council member, the group reported that the USAF disposed of a live shell in the summer of 2003.
It had been in the possession of Ms. Annie Christensen who had picked it up from the site. Ms. Kosbruk provided the assessor with a photograph taken September 2002 of her son, Mr. Morgan Fox, holding the shell. Mr. Larry Underbakke, POC for the USAF, was able to confirm on June 4, 2007, that explosives and ordnance technicians demolished a World War II era 37-mm M-17 anti-tank shell at Port Heiden in the summer of 2003. While this shell was demolished, there is the potential for additional, undiscovered ordnance on the site |
Louis Howard |
| 9/18/2007 |
Update or Other Action |
Workplan approval requirements and quality assurance oversight on Performance Based Contracts letter from John Halverson (ADEC) to Scott Hansen (611 CES). ADEC is writing to remind you of contaminated site workplan approval requirements in Alaska’s oil and hazardous substance pollution control regulations and underground storage tank regulations. Additionally, the department is concerned over quality assurance on Performance Based Contracts (PBCs).
Work Plan Approval-Several 611 CES environmental restoration projects were implemented this summer without obtaining prior workplan approval from DEC. The site cleanup rules require department approval on workplans before beginning interim removal actions (18 AAC 75.330), site characterization work (18 AAC 75.355), or cleanup operations (18 AAC 75.360). Similarly, the underground storage tank regulations specify the department may require a corrective action plan be submitted for approval prior to conducting corrective action at an underground storage tank release site (18 AAC 78.250).
Department staff strives to complete plan reviews and respond to responsible parties within thirty (30) days after receipt of plans, although this is not always possible nor is it a requirement. At times expedited plan reviews are feasible based on project manager work load, adequate up-front planning, and contractors providing complete, well written plans. However, if significant workplan revisions are required, additional review and comment resolution time will be needed. To facilitate successful project implementation, I recommend DoD project managers and contracting staff:
• Coordinate schedules with DEC project managers in advance and throughout projects.
• Include DEC project managers in project planning meetings (DQO meetings, UFP QAPP development meetings, Triad and other Technical Project Planning team meetings, etc.).
• Plan and maintain project schedules that include a sixty (60) days for reviewing draft work plans, comment resolution, any necessary revisions and a final review and approval.
• Review contractor planning documents prior to submission to DEC to ensure compliance with state and federal regulations consistency with agreements made during project planning meetings.
Failure to obtain workplan approval before implementing site work described above is considered a violation of Alaska regulations and may result in field work not being approved or additional work being required and may subject responsible parties and/or contractors to a Notice of Violation (NOV).
Independent QA oversight on Performance Based Contracts-As DoD transitions more ER projects to Performance Based Contracting (PBC) concerns have risen regarding the level of Quality Assurance (QA) oversight. The site cleanup rules require that “collection, interpretation, and reporting of data, and the required sampling and analysis is conducted or supervised by a qualified, impartial third party”. Depending upon the specific terms in a PBC, a contractor may no longer be considered an impartial third party with respect to collecting, interpreting and reporting data. This should be taken into consideration when preparing scopes of work. DEC strongly recommends the Air Force provide an on-site Quality Assurance Representative or a third party QA oversight contractor to monitor fieldwork for consistency with approved plans and contract requirements.
DEC is beginning to conduct more frequent independent Quality Assurance site inspections to evaluate conformance to approved work plans and regulatory compliance. Because we lack staff resources to conduct independent QA on all of the anticipated PBC projects, we intend to include contracting support for field QA oversight in the DSMOA Joint Execution Plans and budget. |
John Halverson |
| 11/7/2007 |
Update or Other Action |
Rough draft of the Proposed Plan received. The Preferred Cleanup Option is as follows:
PCB Cleanup-Surface Soil (Surface Soil Option 10)
The AF proposes to excavate this contaminated soil & perform on-site treatment using a chemical & mechanical processing system without a release of PCBs or other secondary contaminants or waste products to the environment. The approach of excavating, decontaminating, & possibly replacing the soil is thought to be superior to the other options in that the method is efficient & the soil will be clean when returned to the ground.
This will also provide an economic advantage to the community in terms of jobs, training, income & development through local hires & more on-site support services such as food, lodging & equipment/vehicle rental. This treatment process involves:
1. Constructing a treatment area with a lined area for the receipt & staging of contaminated soil,
2. Excavating (ex-situ) contaminated soils,
3. Mechanically screening the soil to separate large & small soil particles, washing the small soil fraction. (Soil that is larger than 2” in diameter is presumed to be clean.)
4. The soil that is smaller than 2” in diameter is run through a sand screw & mixed with a chemical to remove contamination, then allowed to dry, &
5. Soil that meets the cleanup standards will be returned to the excavations & reseeded. Any soil that fails to meet cleanup standards will be reprocessed up to two more times, for a total of not more than three treatment cycles.
If cleanup standards cannot be reached for all contaminants in surface soil after 3 rounds of treatment or some other practicable limit is reached, the AF proposes to dispose of the soil either on- or off-site depending on the properties & volume of the remaining soil. On-site disposal would be by burial with a 3’ thick, clean soil cover.
Off-site disposal would be through placement of the soil in a permitted landfill. Only soil that is clean enough for surface use in industrial areas (with concentrations below 10 ppm) would be buried on site. Soil disposed of off-site would be “super sacked” for protection).
See site file for additional information.
|
Louis Howard |
| 11/8/2007 |
Meeting or Teleconference Held |
Meeting Summary with attendees: Mark Goodwin, AFCEE Larry Underbakke, 611th, Guy Warren, ADEC Louis Howard, ADEC, Jacques Guzmano, EPA, Scott Blount, WESTON and Skip Koch, WESTON. Subj: Port Heiden RRS, Preliminary Proposed Plan for Port Heiden Cleanup.
The Proposed Plan must incorporate alternatives addressed in the feasibility study (FS) for Port Heiden. Because the proposed cleanup technology is not addressed in the FS, an addendum to the FS must be prepared, submitted, and approved before the Proposed Plan can be actually published. Mr. Guzmano will review this addendum to the FS.
Guy Warren questioned whether the proposed soil washing technology could actually clean up PCBs. AFCEE and WESTON will provide him with a copy of the draft white paper prepared on this technology based on a bench scale test of this technology using PCB contaminated soil from Port Heiden. (A copy of the white paper is attached to this document.)
WESTON provided a copy of the schedule for this project to ADEC. This schedule had already been reviewed by AFCEE. Preparing an addendum to the FS prior to publishing the Proposed Plan was not included in the schedule for this project. Adding this to the schedule will not allow treatment of the PCB contaminated soil to be performed in the summer of 2008. In order to take some action on the cleanup, it was agreed that the POL cleanup could be addressed separately from the PCB cleanup. The POL cleanup would require a work plan only, and will not have to be addressed in the Proposed Plan.
All present agreed that the Remedial Investigation (RI) for Port Heiden will be used to define the areas to be treated during the cleanup. There will not be any additional investigation to look for new contamination during the cleanup.
Mr. Guzmano said that the proposed soil washing technology to treat the PCB contaminated soil was presented at the Alaska Forum on the Environment in Anchorage. At that time there was some discussion on whether this technology required a national permit under TSCA. WESTON will investigate the status of this and provide information to all attendees.
Port Heiden needs to construct a new landfill. It is possible that Port Heiden may be interested in disposing of soil with less than 10 parts per million PCB contamination in this new landfill. Mr. Howard will check with the ADEC landfill permitting group to see if this would be considered by them.
There was some discussion on what would be the impact if ADEC were to lower the cleanup level for PCBs from the current 1 mg/kg to 0.3 mg/kg. It was agreed that:
If the ROD for Port Heiden were signed before the regulations were changed, the regulatory levels at the time the ROD was signed would be the applicable levels for the cleanup.
If the ROD were about to be signed when the regulations were about to be changed, ADEC might delay signing the ROD until the new levels were effective which would change the proposed ROD.
If the lower cleanup level became effective after the ROD was signed, the new lower levels would have to be considered during the five year review of the ROD. It is unlikely that reducing the remaining PCBs to the lower level would be required, but this is a possible outcome.
To eliminate the need for separate “Draft Final” document submittals, ADEC agreed to perform a review of WESTON’s responses to their comments on documents if the changes were provided electronically in a red-line/strike-out version of the document.
AFCEE said that mobilization for this project would not be allowed to occur until ADEC had indicated in writing (email is sufficient) that the work plan for the phase of work was acceptable. |
Louis Howard |
| 1/2/2008 |
Meeting or Teleconference Held |
Meeting Summary attendees: Kevin Thomas, AFCEE Glen Verplancke, 611th Louis Howard, ADEC Marty Brewer, ADEC Earl Crapps, ADEC Brent Porter, ADEC Jacques Guzmano, EPA Scott Blount, WESTON
and Skip Koch, WESTON. Subj: Port Heiden RRS Site Cleanup Options.
At 2:00 PM on January 2, 2008, the personnel listed above met in the 2nd floor conference room of the Alaska Department of Environmental Conservation (ADEC) to discuss Port Heiden cleanup options. Specifically, the intent of the meeting was to address the pros and cons of soil washing PCB-contaminated soil and biotreatment of POL-contaminated soil versus excavation and disposal of PCB soil and biopiling of POLs. This included a discussion of the regulatory, contractual, funding, schedule and community constraints associated with either option. The topics discussed are addressed in the bullets below:
Items discussed regarding the soil washing technology are as follows:
-Strongly preferred by the community.
-Greater potential for more local work.
- Long term developmental opportunity if the PCB cleanup technology is proven on site.
- Will be fall-out from community / team if another alternative chosen.
-Results from Big Mountain study not as favorable as anticipated.
-Expect over 90% of PCB-contaminated soils to be treated successfully to below 10 ppm and 60%-70% of the total PCB-contaminated soils to below 1 ppm.
-Will leave approximately 5,000 yards “treated” soil on site.
-10% above 10 ppm is currently funded for shipment off site by the AF.
-Projected 20% between 1 ppm and 10 ppm is not.
Options for addressing the 20%-30% soil are as follows:
-Per EPA, cannot bury on site as once excavated under CERCLA, cannot re-bury.
-Cannot be removed to a 3rd party-owned location and monitored per current Alaska law.
-Cannot be “covered in place” (without excavation or treatment) as this would require unenforceable institutional controls and long term O&M that the AF is not willing to fund. Contract requirements also stipulate that AF land be returned without land restrictions. State of Alaska land has similar requirements.
-Can be placed in an on-site (or off-site) permitted landfill.
-Funding for transport and disposal of the 1 ppm to 10 ppm soil off-site is not available from the Air Force.
- Funding for transport and disposal will fall to WESTON or its subcontractors.
- There is no guarantee that this volume will be 20% -30% (may be more or less).
- There is no funding in the WESTON contract for this effort.
- WESTON’s subcontractors are not willing to bond 90% treatment of the soil to 1 ppm.
-There is no permitted landfill at Port Heiden and no funding to construct one.
-There is significant political pressure (based on other landfill failures at Port Heiden) to ensure this soil is properly addressed.
Items discussed regarding the excavation and disposal option are as follows:
-Shorter field season, lower risk, similar cost.
-Permanently removes all PCB-contaminated soil from site.
-Biopiling is a reasonable alternative for POL-contaminated soils.
-Will receive strong pushback from the community.
Conclusions on treatment options:
-No funding for addressing soils between 1 ppm and 10 ppm.
-No reasonable, local disposal options for this soil.
-EPA and ADEC primary missions are environmental protection / cleanup. Both prefer the lower risk, more permanent solution.
-Schedule constraints (2008-2009 seasons) were also discussed. |
Louis Howard |
| 1/8/2008 |
Update or Other Action |
Proposed Plan (Draft) received. This Proposed Plan only discusses cleanup options for non-fuel contamination because the Plan is being prepared under the authority of CERCLA, which does not consider fuel a hazardous substance. However, the fuel contamination at the Port Heiden RRS will be addressed in the future by the Air Force under ADEC authority. As required by CERCLA, the Air Force will hold a public meeting on the cleanup options presented in this Proposed Plan.
The Preferred Cleanup Option as described in this Plan is comprised of one option each for surface soil and groundwater, and is as follows:
Surface Soil Option 6 – Soil Excavation (> 1 ppm) and Off-Site Disposal in a Permitted Landfill
In this option, all surface soil contaminated with PCBs, pesticides, and PAHs would be excavated at levels down to the required cleanup level (1 ppm). This ensures that this alternative would be protective under an unrestricted use scenario (i.e., protective of a residential child and adult). The excavated soil would then be shipped off-site and disposed of in a permitted landfill. Soil from a local borrow source would be used to backfill the excavations. No soil cap or institutional controls would be required under this alternative.
Groundwater Option 2 –Natural Attenuation and Long-term Monitoring
Two TCE plumes are present in groundwater at the Former Facility Area. The depth of the water table at this location is approximately 60 feet below ground surface. The low risk at this site and the depth of the plumes make active remedial systems (such as pump and treat or enhanced natural attenuation) technologically impractical.
Therefore, the Air Force proposes to use up to four existing wells to establish a network such that monitored natural attenuation of the plume can be conducted. As other contamination (i.e., fuels) in the groundwater breakdown over time, their by-products will help to breakdown the TCE. Therefore, no treatment is proposed for the TCE-contaminated groundwater. This approach is supported by the fact that there are no residences within the groundwater contamination region and there are currently no drinking water wells being used and none are planned so the risk from drinking and or bathing would be low.
Summary of Preferred Cleanup Option
Overall, this Preferred Option is: 1) protective of human health and the environment by eliminating contamination in a large quantity of soil and establishes institutional controls and a protection monitoring program for all remaining on-site contaminants; 2) compliant with regulations; 3) utilizes a permanent solution in that removes contamination from Native and State owned land, and reduces the risks at the former RRS to a point where the site is ultimately suitable for residential use; and 4) moderately priced compared with the other alternatives; and 5) uses a cleanup strategy that provides an economic advantage to the community in terms of more on-site support services such as food, lodging and equipment/vehicle rental. |
Louis Howard |
| 2/5/2008 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft 2008 Proposed Plan Port Heiden RRS. Introduction Page 2 Last Paragraph: The text states fuel contamination will be addressed in the future by the Air Force under ADEC authority. ADEC requests the text state the fuel contamination will be addressed in the future by the Air Force under Alaska State law and environmental regulations.
Site Characteristics Page 4 and Table 1: The text states “Levels of contaminants were compared to screening criteria which are based on State (ADEC) and EPA risk and cleanup levels. The screening criteria used for surface soil and groundwater is ADEC Method 2 cleanup levels (18 AAC 75 Tables B and C), which is protective of human health and the environment and allows unrestricted land use and access.” ADEC requests deleting “screening criteria” and inserting cleanup levels.
Additionally, cleanup levels for soil specified in Table B at 18 AAC 75.341 apply to both surface and subsurface soil. For the majority of contaminants, the migration to groundwater cleanup levels in Table B are those that allow for unrestricted use and not inhalation or ingestion cleanup levels that are typically higher and require land use controls. However, certain contaminants have higher migration to groundwater cleanup levels than ingestion/inhalation levels. For these contaminants, use the most stringent level as the “unrestricted use” level. For example, the contaminant: Benzo (a) pyrene has a cleanup level of 1 mg/kg for ingestion and 3 mg/kg for migration to groundwater. In this case the more stringent cleanup level for ingestion would be the level that allows for “unrestricted use”.
The text states: “All non-fuel found above screening criteria at the Former Facility Area are provided in Table 1, along with the maximum concentration found and the screening criteria used.” Delete “screening criteria” and insert “cleanup levels” referenced in text.
The text states “Surface soils at the Former Facility Area contain PCBs, pesticides, and PAHs in concentrations above screening criteria (Figure 3). The most common contaminant found were PCBs, which were discovered in a number of surface soil samples at concentrations above the screening criteria of 1 part per million (ppm). The maximum level of PCBs found in surface soil was 930 ppm. The study determined that thousands of cubic yards of soil at the Former Facility Area contained contaminants in excess of screening criteria.” ADEC requests deleting the phrase “screening criteria” and insert “cleanup levels” referenced in text. Also, ADEC requests mg/kg be used instead of ppm for soil contamination.
Table 1 requires a heading change to “Summary of Contaminants of Concern and Cleanup Levels for the Former Facility Area” Add text to Surface Soil heading or a footnote indicating mg/kg as the units and not ppm. Strike ppm from the table. Add text to Groundwater heading or a footnote indicating units are mg/L not ppm. Delete Proposed Cleanup Level column and change “Screening Criteria” column heading to “Cleanup Standard”.
The contaminant “PAHs” is misleading as well as a maximum concentration listed at 7.8 ppm (mg/kg) and a proposed cleanup level of 1 ppm. There are many types of PAHs and the cleanup level varies. Either change the table for PAHs to read “cleanup level varies” or list each specific polycyclic aromatic hydrocarbon and cleanup level associated with each contaminant.
The 2004 RI lists benzo(a) pyrene from the Radio Relay Station Landfill (NLF) at 7.8 mg/kg (M). A M qualifier means that there was a matrix effect present. However, higher levels were found at the Septic System Outfall (SSO) for the same analyte at 31 mg/kg (Sample ID SSO-TP-04-S01-O “J” qualified).
Cleanup Objectives Page 6:The text states “…contaminants in concentrations greater than screening criteria are:….” Screening criteria are applicable for use in risk assessments and are typically 1/10th the ADEC cleanup levels in 18 AAC 75. ADEC requests the text be changed to read “…contaminants in concentrations greater than cleanup levels are….” ADEC requests the section be renamed Remedial Action Objectives. Cleanup objective 1 states: “to protect the current and future residents of Port Heiden by cleaning up the site to acceptable levels,” ADEC requests text be changed to read“...by reducing the PCB, PAHs, and pesticides in soils and the benzene and chlorinated solvents in groundwater to meet cleanup levels.”
Cleanup Options Pages 6 and 7: ADEC requests changing heading of this section to “Summary of Alternatives”. The text states
“Final cleanup levels will be established through input from the Air Force, ADEC, EPA, and community and documented in the ROD.” This is incorrect, the final cleanup level has been determined and established by environmental statutes/regulations and it is the preferred alternative which will be selected and documented in the ROD based on input from EPA, Community and ADEC. |
Louis Howard |
| 2/8/2008 |
Update or Other Action |
Draft sampling strategy received.
PCB/PAH/Pesticide Cleanup Confirmation Sampling Strategy
-Boundaries of contaminated areas were delineated during the RI.
-Sample only for contaminants discovered above cleanup levels in each of these areas during the RI.
-Excavate contaminated soils to bottom of known contamination (RI results) and then take confirmation samples.
-Sample using 15 ft by 15 ft squares as a decision point. Composite four samples from within each square for single analytical sample**
-In areas that are still contaminated, excavate an additional foot and resample using same procedure as above.
-Concrete was not addressed in the FS and is not a media of concern.
**This results in approxiamtely 400 laboratory analytical samples (1600 samples composited into 400). This "decision unit" is defined based on a reasonable area to find and re-visit for excavation using available equipment (e.g., smaller areas might entail crossing clean intervls to re-excavate areas of concern).
PCB/PAH/Pesticide Waste Characterization
-Waste characterization of soils collected from areas known to be below TSCA levels will be conducted using RI/FS data.
-Hot spot (PCB > 50 ppm) characterization will be conducted at a rate of 1 composite sample per 50 CY (10 bags).
-Hot spots (PCB > 50 ppm) will be excavaterd and bagged separately.defined as extending from the hot sample 2/3rds of the distance to the closest sample < 50ppm.
-Hot spots will be defined as extending from the hot sample 2/3rds of the distance to the closest sample < 50ppm.
POL Sampling Strategy
-Boundaries of contaminated areas were delineated during the RI.
-Sample only for contaminants discovered above cleanup levels in these areas during the RI.
-Excavate POL contamination above dermal contact levels to max depth of 15 ft bgs. Excavate POL contaminated soil above leaching levels to 2 ft bgs to protect surface water.
-Use PID to guide depth and extent of excavation.
-Conduct confirmation sampling in excavations > 2 ft bgs and < 15 ft bgs.
-Confirmation sampling at rate of 2 for every excavation over 2 ft bgs with an additional sample per 250 sqft of side wall and floor of the excavation.
-In areas that are still contaminated, excavate an additional foot (or more) and resample using same procedure as above.
-No confirmation sampling in excavations extending to 15 feet bgs. |
Louis Howard |
| 2/19/2008 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed. |
Louis Howard |
| 2/29/2008 |
Meeting or Teleconference Held |
Meeting Summary Attendees: Mark Goodwin, AFCEE, Glen Verplancke, 611th, Jim Klasen, 611th, Louis Howard, ADEC, Earl Crapps, ADEC, Jacques Guzmano, EPA, Scott Blount, WESTON, and Skip Koch, WESTON. Subj: Port Heiden RRS, Implementation of Land Use Controls on Land Not Owned by the USAF.
At 1:00 PM on 20 February 2008, the personnel listed above met in the 2nd floor conference room at Weston Solutions, Inc. (WESTON) to discuss the method for the Air Force to implement Land Use Controls (LUCs) on property that they do not own. The Proposed Plan to cleanup Port Heiden would leave POL contaminated soil in place that is over 15 feet below the ground surface (bgs) and would leave in place contaminated groundwater under lands that have been conveyed by the Air Force to other entities in the past. Since these lands have already been conveyed to other owners, it is not possible for the Air Force to put LUCs in the land title transfer documents.
Mr. Guzmano said that this same issue occurred at the Arctic Surplus cleanup site. At this site the Department of Natural Resources (DNR) worked with the Defense Logistics Agency and the current landowners to implement LUCs on contaminated soil and groundwater that remained on site after the cleanup had been completed. The DNR implemented the LUCs in a Management Right Assignment document. Mr. Guzmano provided a copy of this document for the Arctic Surplus site to Mr. Verplancke.
LUCs will be required on the soil below 15 ft bgs at the Black Lagoon (Department of Transportation and Public Facilities (DOT)land); and on the soil below 15 ft bgs, and on the groundwater beneath the Landfill (APC land).
Mr. Klasen noted that easements will appear on property records. The Air Force will perform five year reviews of the contamination remaining at the sites, however, the lands have already been transferred to the DOT and APC.
Mr. Klasen glanced over the Management Right Assignment document and believed that it was feasible at Port Heiden.
The EPA, ADEC, and the Air Force agreed that a Record of Decision (ROD) for the Port Heiden cleanup could be published prior to completing the Management Right Assignment document with the DNR. However, the boundaries of the areas that will have LUCs must be defined in the ROD.
Mr. Goodwin said that the ROD will address the PCB contaminated soil used to cap the landfill on APC’s land, but the ROD will not address the actual wastes in place in the landfill. He also said that the ROD would not address the US Army Corps of Engineer’s mono-fill.
Mr. Goodwin said that John Smith is trying to obtain the right of entry to APC owned land for the proposed clean up action.
The final topic was a discussion of travel arrangements for the Public Meeting to review the Proposed Plan for Port Heiden on Tuesday 11 March. WESTON will charter an aircraft that will depart for Port Heiden at approximately 11:00 AM and return to Anchorage at approximately 10:30 PM. Nine seats will be available. The Air Force will have three seats, WESTON will have four seats (including a court reporter), ADEC will have one seat, and the EPA will have one seat. |
Louis Howard |
| 5/29/2008 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (ADEC), Contaminated Sites (CS) Program has reviewed the information provided on the chemical pentanonic dated April 30, 2008 and received in our office on May 1, 2008. Additional review and discussion occurred during the requested meeting on May 8, 2008, between Ms. Teresa O'Carroll of Iliaska Environmental LLC, Mr. Earl Crapps of ADEC, and yourself.
All of the technical information provided on the chemical pentanonic, including but not limited to, its chemical composition and toxicity data has been evaluated and the CS program has determined that it is acceptable for use as a remediation technique for petroleum contaminated sites within the State of Alaska. The following conditions apply to the use of pentanonic for all CS projects (NOTE TO FILE: which includes the PBC POL Pipeline project-SS006).
Alternative additives fiom the standards discussed must be proposed and approved by the department on a site specific basis. The standard additives are Magnesium oxide (builder), Sodium 1-butanesulfonate (anionic surfactant) and Sodium stearate (nonionic surfactant). Additives should be identified in a work plan submitted to the department for approval.
The minimum dilution ration of pentanonic prior to application is seven parts water to one part pentanonic (7:l). Additional dilution of the chemical pentanonic may be required on a site specific basis, e.g. applications on or near environmentally sensitive areas (*NOTE to File:18 AAC 75.990(35) “environmentally sensitive area” means a geographic area that, in the department's determination, is especially sensitive to change or alteration, including
(A) an area of unique, scarce, fragile, or vulnerable natural habitat; (B) an area of high natural productivity or essential habitat for living organisms; (C) an area of unique geologic or topographic significance that is susceptible to a discharge;(D) an area needed to protect, maintain, or replenish land or resources, including floodplains, aquifer recharge areas, beaches, and offshore sand deposits; (E) a state or federal critical habitat, refuge, park, wilderness area, or other designated park, refuge, or preserve; and (F) an area that merits special attention as defined at 6 AAC 80.170;). NOTE: 6 AAC 80.170 repealed see AS 46.40.210(1) "area which merits special attention".
The dilution ratio should be identified in a work plan submitted to the department for approval.
Monitoring for pentanonic breakdown, as well as contaminants of concern (COCs), should occur. Pentanonic breakdown will be demonstrated through pH monitoring, with a basic pH indicating the presence of the chemical and a neutral pH indicating pentanonic breakdown. COCs should always include Volatile Organic Compounds (VOCs) by SW-846 method 8260B to confirm any short chain petroleum compounds produced through the reaction with pentanonic are below applicable cleanup levels.
All other applicable regulations and guidance for the characterization, remediation and/or cleanup of petroleum contaminated sites must be adhered to. Please note that site specific workplans must be submitted and approved by the department prior to implementing cleanup work at contaminated sites or leaking underground storage tank sites.
This letter should not be considered an endorsement, nor approval, of the chemical pentanonic or its effectiveness. It may be considered a determination, based on a review of the provided information, that its use under department approved conditions on a site specific basis will not pose an unacceptable risk to human health, safety, or the environment.
Thank you for providing requested information on the chemical pentanonic for department review. If you have any questions regarding this letter, please contact me at (907) 269-7545 or john.halverson@alaska.gov. Signed by John Halverson Environmental Program Manager. |
John Halverson |
| 9/19/2008 |
CERCLA Proposed Plan |
Letter from ADEC to USAF: Proposed plan accepted as final version.
While not listed on the NPL, Cape Romanzof LRRS must follow CERCLA process per E.O. 12580 [e.g. CERCLA Sections 104(a), (b), and (c)(4), 113(k), 117(a), and (c), 119, and 121) with respect to releases or threatened releases where either the release is on or the sole source of the release is from any facility or vessel under the jurisdiction, custody, or control of their departments. These functions must be exercised consistent with CERCLA Section 120 Federal Facilities.
State laws. -- State laws concerning removal and remedial action, including State laws regarding enforcement, shall apply to removal and remedial action at facilities owned or operated by a department, agency, or instrumentality of the United States when such facilities are not included on the National Priorities List. The preceding sentence shall not apply to the extent a State law would apply any standard or requirement to such facilities which is more stringent than the standards and requirements applicable to facilities which are not owned or operated by any such department, agency, or instrumentality.]. |
Louis Howard |
| 10/1/2008 |
CERCLA Proposed Plan |
Proposed Plan presents the cleanup alternatives proposed by the Air Force (USAF) and reviewed by the ADEC for an Environmental Restoration Program (ERP, formerly Installation Restoration Program) site known as the Former Facility Area. While there are other sites at the Port Heiden RRS that the USAF has studied, this Proposed Plan looks at cleanup alternatives for only this site. Cleanup plans for other sites at Port Heiden RRS will be prepared in the future.
ADEC is the lead regulatory agency and the Air Force is the lead cleanup agency for Port Heiden RRS. This Proposed Plan is prepared according to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) “Superfund” Program, under Section 117(a), and the National Contingency Plan (NCP), Section 300.430(f)(2). These federal laws regulate the cleanup of old hazardous waste sites that contain substances covered under CERCLA. The USAF cleanup program follows CERCLA guidance; however, the investigations of the sites described in this Proposed Plan were also conducted under ADEC’s Contaminated Sites regulations (Title 18 Alaska Administrative Code [AAC], Section 75, Article 3 “Discharge Reporting, Cleanup, and Disposal of Oil and Other Hazardous Substances”). Petroleum products such as crude oil or refined fuel are not considered hazardous substances under CERCLA. The term “hazardous substance,” as defined in CERCLA, excludes “petroleum, including crude oil or any fraction thereof,” unless specifically listed or designated under CERCLA (Sections 101(14) and 102(a)).
This Proposed Plan only discusses cleanup alternatives for non-fuel contamination because the Plan is being prepared under the authority of CERCLA, which does not consider fuel a hazardous substance. However, the fuel contamination at the Port Heiden RRS will be addressed in the future by the USAF under Alaska State law and environmental regulations.
The Preferred Cleanup Alternative as described in this Plan is comprised of one alternative each for surface soil and groundwater, and is as follows: Surface Soil Alternative 10 – Soil Excavation, Washing, and Off-Site Disposal in a Permitted Landfill
In this alternative, all surface soil contaminated with PCBs, pesticides, and PAHs would be excavated to a depth necessary to meet the required cleanup level (refer to Table 1) and removed entirely from the site. This ensures that this alternative would be protective under an unrestricted use scenario (i.e., protective of a residential child and adult). The on-site washing of soil with PCB contaminant concentrations = 10 mg/Kg would require the participation of local workers from the community of Port Heiden. All excavated soil would then be trucked and disposed of in a permitted landfill in the vicinity of Port Heiden. Soil from a local borrow source would be used to backfill the excavations. No soil cap or institutional controls would be required under this alternative.
Groundwater Alternative 2 –Natural Attenuation and Long-term Monitoring-Two TCE plumes are present in groundwater at the Former Facility Area. The depth of the water table at this location is approximately 50 feet below ground surface. The depth of the plumes make active remedial systems (such as pump and treat, which has a significant power requirement, complex discharge requirements, and limited effectiveness) technologically impractical. Therefore, the USAF proposes to use up to four existing wells to establish a network such that monitored natural attenuation of the plume can be conducted. As other contaminants (i.e., fuels) in the groundwater breakdown over time, their by-products will help to break down the TCE. Therefore, no treatment is proposed for the TCE-contaminated groundwater. This approach is supported by the fact that there are no residences within the groundwater contamination region and there are currently no drinking water wells being used and none are planned. Therefore, the risk from drinking and or bathing in groundwater would be low. However, institutional controls would be implemented to restrict the use of groundwater and would remain in place until groundwater cleanup levels were achieved through natural attenuation.
Because this remedy would result in hazardous substances, pollutants, or contaminants remaining on site above levels that allow for unlimited use and unrestricted exposure, a statutory review will be conducted every five (5) years after initiation of the remedial action to ensure that the remedy continues to provide adequate protection of human health and the environment. These reviews will be conducted until cleanup levels are achieved at the site. |
Louis Howard |
| 10/23/2008 |
Meeting or Teleconference Held |
Staff traveled with Air Force, EPA, and contractor to Port Heiden for public meeting on Proposed Plan for Former Facility Area. Community members had very few comments and did not disagree with the LTM/MNA for groundwater, soil washing/landfill for soil as the preferred alternatives presented by the Air Force. |
Louis Howard |
| 11/24/2008 |
Meeting or Teleconference Held |
Meeting Summary Attendees: Kevin Thomas, AFCEE Glen Verplancke, 611th, Jim Klasen, 611th, Louis Howard, ADEC, Earl Crapps, ADEC Jacques Guzmano, EPA, Skip Koch, WESTON Larry Vanselow, WESTON, & Paul Swift, WESTON.
At 9:30 AM on 24 November 2008, the personnel listed above met in the 2nd floor conference room at the Alaska Department of Environmental Conservation. (ADEC The purpose of the meeting was to discuss the newly promulgated cleanup levels for pesticides in soil. Of particular concern is dieldrin for which the cleanup level has been reduced from 0.015 mg/kg to 0.0076 mg/kg.
The PP has been issued & a public meeting held which does not reflect the newly promulgated levels for pesticides which have been reduced by approximately 50%. ADEC stated that since no decision document had been published at the time the new cleanup levels were promulgated, the new cleanup levels are the allowable levels.
The Air Force questioned how the pesticides got into the soil in the first place. They mentioned that there were no high levels of the pesticides & no evidence of unintentional releases of pesticides. The pesticides present in the soil were likely the result of mosquito control.
WESTON discussed their concern with obtaining low enough analytical DLs for the pesticides in the treated soil in the presence of allowable PCBs at levels of 10 mg/kg. Obtaining the lower pesticide DLs may require additional washing of soil to remove the PCBs & allow pesticides to be detected at the required levels. It was brought up that Method 8270 may be able to attain the lower cleanup levels in the presence of higher levels of PCBs.
It was also discussed that the low cleanup levels for dieldrin could potentially result in “chasing” soil due to dieldrin exceedances only. This soil would be processed through the soil washing process just to remove dieldrin since the cleanup level is based on protection of GW. The result of the new lower cleanup levels for dieldrin could mean that more soil needs to be excavated & treated through the soil washing process greatly increasing the volume to be treated & the cost.
A question was raised as to whether dieldrin was found in GW under the site. WESTON performed a quick review of the site analytical database & indicated that dieldrin was not detected in any GW well samples. It was mentioned that if after 40 yrs no dieldrin was detected in GW, then it was likely that the existing dieldrin levels in soil at this site are probably not a concern.
The conversation then centered on dieldrin partitioning to GW & that Method 3 could be used with site specific total organic carbon data to determine if a site specific cleanup level would be different than the promulgated concentration.
The PP process was briefly discussed. If a new cleanup level for dieldrin was to be used that was higher than that published in the PP, a revised PP & new comment period would be needed. WESTON mentioned that this would be a problem with the schedule since the work plan for the site work is currently planned to be submitted after the ROD is signed unless ADEC would agree to review the two concurrently. ADEC said that was a possibility but if the Method 3 calculations indicated the old cleanup level of 0.015 mg/kg would be protective, then no change to the PP would be needed & the ROD could proceed with the levels listed in the PP. The only requirement would be that in the ROD, an explanation would need to be provided that discusses why the old cleanup levels are adequate & being used instead of the newly promulgated cleanup levels.
If the Method 3 calculated concentration was below the old level of 0.015 mg/kg, a more appropriate dieldrin cleanup level could be based on human exposure through direct contact since GW does not appear to be impacted by dieldrin in soil based on the numerous samples collected during the RI. Since the dieldrin direct contact value is greater than 0.015 mg/kg, the value used in the proposed plan would not need to be changed.
It was then discussed whether treating soil for dieldrin to reduce the levels to the level protective of GW would be required. It was mentioned that dieldrin impacted soil could be disposed in the new landfill without treatment as long as a membrane cover or liner was installed to prevent leaching from contact with rainwater. Since the landfill would be controlled through fences & signage, human exposure to dieldrin contaminated soil through direct contact would not be a concern. It was also said that although this was a newly permitted Class III landfill, enhancements to the Class III landfill could still be made such as adding a liner to cover a cell containing dieldrin contaminated soil.
WESTON said that the plan was to keep PCB/Pesticide soil segregated from non-pesticide contaminated soil & that this soil (treated or untreated) could be placed in separate landfill cells.
For additional information see site file. |
Louis Howard |
| 12/17/2008 |
Meeting or Teleconference Held |
Meeting Summary Attendees: Glen Verplancke, 611th Louis Howard, ADEC, Earl Crapps, ADEC Jacques Guzmano, EPA, Skip Koch, WESTON Larry Vanselow, WESTON & Kris Hadden, WESTON.
Subj: Delineation of Contaminated Areas & Confirmation Sampling.
At 8:30 AM on 17 December 2008, the personnel listed above met in the 3rd floor conference room of WESTON Solutions, Inc. at 425 G Street, Anchorage AK. The purpose of the meeting was to discuss methods to delineate areas of contaminated soil for excavation & the approach for confirmational sampling.
WESTON provided a set of handouts to all attendees who consisted of a set of flow diagrams & brief text describing the approach. The handout is attached to these meeting minutes.
The first handout discussed was the approach proposed for PCB soil containing greater than or equal to 10 ppm PCBs which will undergo soil washing. WESTON noted that of the approximately 400 samples collected in the Radio Relay Station Former Facility Area, approximately 20 locations contained PCBs greater than 10 ppm. Most of these areas were isolated from one another but a few were close enough that they could be consolidated into one area for excavation.
WESTON indicated it was considering using an instrument manufactured by SiteLab which uses UV florescence for field analyses of PCBs. WESTON said the field PCB analysis instrument would be calibrated using site soil, standards developed for the site soil, & actual laboratory soil analysis data. It would be tested on several site soil samples to provide a confidence interval for the instrument & the error of the instrument would be factored into the concentration reading.
WESTON’s proposed approach was to draw a boundary approximately 7.5 feet outward of each location containing PCBs greater than or equal to 10 ppm as an initial estimate of the extent of the hot spot. WESTON proposed to collect 1 perimeter sample (made from 2 individual samples over a 2 foot depth) per every 20 feet of perimeter but not less than 1 per side. This sample would be analyzed in the field for PCBs using the field analysis instrument.
If the sample exceeded 10 ppm PCBs (corrected for the estimated error of the field instrument), the boundary would be moved out in the direction(s) with high results until none of the samples exceeded the 10 ppm concentration. This would become the boundary of the hot spot. WESTON indicated small step out distances were being proposed to prevent diluting hot spot soil with lesser contaminated soil & to avoid unnecessary soil washing costs.
WESTON would then excavate the soil, ship the soil to the soil washing equipment, & sample the bottom of the excavation on 15’x15’ grids & analyze the samples using the field instrument to make sure all soil over 10 ppm was removed. WESTON indicated 10% of the perimeter & bottom soil samples would be sent to an offsite laboratory for analysis to confirm the accuracy of the field instrument. If bottom sampling indicated PCBs were still present at concentrations greater than 10 ppm, then the “hot” area would be excavated 1 foot deeper & be resampled.
ADEC said that if the composite sample was made from 2 individual samples, then the criteria would be 5 ppm PCBs (cleanup level divided by number of samples in the composite) & the instrument reading would have to be less to account for inaccuracies. ADEC also recommended that at least one sample from every individual excavation area (either perimeter or bottom) should be sent to the lab for analysis rather than just a standard 10%, & the sample should be the sample with the highest PCB concentration reading.
WESTON indicated that with this approach, it was estimated that 70 perimeter samples would be collected & 30 bottom samples would be collected at a minimum; more would likely be needed due to stepping out.
WESTON then discussed the approach for delineating the soil exceeding cleanup levels that would be excavated & sent to the landfill. The approach was similar to the “hot spot” approach in that the boundary would be estimated based on RI data & perimeter samples collected at a frequency of 1 per 40 linear feet of perimeter but not less than 1 per side. These samples would be analyzed for PCBs using the field instrument to show the concentration was less than 1 ppm.
ADEC mentioned again that if a 2 part composite sample was used, the concentration would need to be 0.5 ppm PCBs & include a factor of safety for the field instrument.
If the boundary samples exceeded the criteria, then the boundary would be moved out approximately 10 feet. USEPA mentioned that more flexibility should be allowed in moving the boundary outward, i.e., do not restrict the distance to 10 feet. |
Louis Howard |
| 12/17/2008 |
Meeting or Teleconference Held |
WESTON said that because there is no field instrument to detect pesticides at the low cleanup levels, the boundary samples once screened for PCBs, would need to be sent to a lab for analysis of the other constituents. If any of the COCs exceeded the cleanup level, the boundary would need to be moved outward. This process would continue until all boundary samples were less than cleanup levels. Once the boundary was established, the soil would be excavated to the boundary, & bottom samples collected in the 15’ grids. Field screening for PCBs would occur & if below the cleanup level of 1 ppm, the sample would be sent to a lab for analysis of the other COCs. If a grid exceeded the cleanup level, it would be excavated deeper.
USEPA brought up the idea multi-incremental (MI) sampling should be considered.
WESTON mentioned the concern of obtaining high standard deviations which would cause in the MI sample result to indicate the area as still contaminated above cleanup levels. In addition, if the result was above the cleanup level, then the whole area would need to be excavated deeper. It was mentioned that it was possible to break an excavation area into several decision units.
ADEC said the largest decision unit they had approved was 100’ x 100’. WESTON indicated they would look further into the MI approach as an alternate to grid sampling.
Several other items related to sampling were discussed.
1. WESTON noted that the sampling approach to define the boundary & confirm the bottom is clean after soil removal was to only analyze for the COCs found to exceed cleanup levels at that specific location of the site in the RI.
2. It was mentioned that it was unlikely the excavation would be over 4 feet in depth since the extent of the contaminated soil is estimated at 2 feet & that no or few excavations were likely to have sidewalls. WESTON said that if a sidewall over 4 feet in height was present, then WESTON would collect a sidewall sample & analyze for the COCs at that location.
3. It was said that the sampling approach was to determine the horizontal boundary & when the extent of one of the COCs had been determined, further step out sampling would not include that particular COC. The same situation was proposed with bottom sampling; when the bottom of an excavation met the cleanup levels for a particular constituent, further sampling at depth would not include that constituent.
4. Excavation of tundra to attain dieldrin cleanup levels was discussed. It was postulated that the native tundra may exceed pesticide cleanup levels due to application of pesticides, & was the damage to the tundra worth the benefit gained by attaining cleanup levels for pesticides. ADEC mentioned that due to all the organic carbon in the tundra, it was unlikely that pesticides posed a threat to GW & that the concentration for protection of human health via dermal contact should be used in determining when tundra should be excavated. It was agreed, & WESTON committed to preparing a revision supplement to the draft ROD which was currently under review.
5. WESTON indicated that a recent review of the dieldrin data seemed to indicate that soil contaminated with dieldrin above cleanup levels was present on the south side of the site & on the west side of the site but that the other areas appeared to have no or minimal concentrations of dieldrin. This could have been the result of pesticide application on these portions of the site due to water accumulation along these areas. WESTON proposed investigating the dieldrin data further. If this trend held true, WESTON proposed identifying a boundary on the site based on the RI data where dieldrin is not present & eliminating dieldrin from analysis in any samples collected from these areas. The basis for this is that during the RI, a very comprehensive sampling program of the RRS was completed which appears adequate to define the extent of dieldrin.
Overall, the attendees agreed with the approach discussed above with 2 modifications.
-If a 2 part composite sample is taken, then the acceptance value for that sample is half the cleanup criteria.
-When using the field instrument to determine the boundary of a hot spot excavation & confirm the bottom of the hot spot excavation meets cleanup levels, at least one sample from that excavation should be sent to the lab to confirm the field instrument reading. |
Louis Howard |
| 2/11/2009 |
Update or Other Action |
Draft Record of Decision received. The Site includes the following CERCLA Source Areas: Former Composite Building (OT001), Septic Tank & Septic System Outfall (SS004), Landfill & Debris Burial Areas Including LF07 (Radio Relay Station Landfill) Other Areas(Antenna Pads, Contaminated Soil Removal Areas, Drum Storage Area & the Focus Area). Landowners within the Port Heiden RRS include the Alaska Peninsula Corporation, the Alaska Department of Transportation (AKDOT), and the United States Air Force (USAF).
There are some areas contaminated with Petroleum, Oil & Lubricants (POL) at the RRS. The remedies for POL are not selected in this ROD, but will be addressed in a subsequent WP submitted in accordance with ADEC regulations.
There are several CERCLA hazardous substances identified as contaminants of concern (COCs) at the Site. The soil COCs consist of Polychlorinated biphenyls (PCBs), & pesticides (Dieldrin, Heptachlor Epoxide), & Polycyclic Aromatic Hydrocarbons (benzo(a)pyrene, benzo(a)anthracene, dibenzo(a,h)anthracene). GW COCs consist of Trichloroethylene (TCE) & benzene.
The soil cleanup levels to be attained by the selected remedy (PCBs 1 mg/kg, dieldrin 0.015 mg/kg, heptachlor epoxide 0.2 mg/kg, benzo(a)pyrene 0.49 mg/kg, benzo(a)anthracene 3.6 mg/kg & dibenzo(a,h)anthracene 0.49 mg/kg). These cleanup levels, once they are attained, will allow the current use of the site. Pesticides may remain at the site after cleanup at levels above migration to GW standards (per 18 AAC 75.341 Table B1, October 2008).
The cleanup will be accomplished by first excavating the portion of soil that contains PCBs greater than or equal to 10 mg/kg (soil may include incidental pesticides & PAHs). This portion of the contaminated soil will be washed in an alcohol-based solvent to extract PCBs & reduce the PCB level in the treated soil to less than 10 mg/kg. Sampling of the treated soil will be performed to confirm PCB levels are below 10 mg/kg. Recalcitrant soil that cannot be treated using soil washing to meet required PCB level (<10 mg/kg) will be barged offsite for proper disposal.
Upon confirmation the treated soil contains PCBs less than 10 mg/kg, the soil will be loaded into trucks & taken to the local permitted Class III landfill for disposal. The remaining soil containing PCBs greater than 1 mg/kg will be excavated. This soil which contains PCBs greater than 1 mg/kg but less than 10 mg/kg will also be loaded into trucks & taken to the offsite Class III Landfill for disposal.
Soil containing levels of PCBs less than 10 mg/kg but with levels of pesticides & PAHs above their cleanup levels will be excavated & taken to the local Class III landfill for disposal.
Tundra will only be excavated to remove dieldrin in soil where levels exceed the 18 AAC 75.341(c) Method 2 human health risk direct contact value of 0.32 mg/kg. At the existing Port Heiden RRS Landfill, excavation of contaminated soil will stop upon encountering landfill solid waste & the cap will be restored with clean soil.
After all soil washing is complete, the PCB, pesticide, & PAH enriched residue generated during the soil washing process will be handled & disposed in accordance with state & federal regulations. Upon completing the excavation, confirmation samples will be collected & analyzed to ensure the remaining soil meets the cleanup levels for PCBs, PAHs &/or pesticides. Any soil not meeting cleanup levels will be further excavated & resampled.
The new Class III landfill will be constructed with separate cells identified for disposal of soil containing only PCBs & other cells for disposal of soil containing mixtures of PCBs, pesticides, and PAHs. Cells containing PCB/pesticide/PAH contaminated soil will be covered with an impermeable liner as an enhancement to the landfill to prevent rainwater from leaching pesticides/PAHs from these soils. Approximately 6,000 to 7,500 cy of soil is contaminated with PCBs, PAHs & pesticides at levels above cleanup levels. It is also estimated that approximately 1,500 cy of soil contain PCBs greater than or equal to 10 mg/kg which will undergo soil washing.
A notice type of IC will be implemented (with the land owners consent) to control the use of soil containing residual levels of dieldrin above 0.0076 mg/kg. This notice will make the Land Owner aware that ADEC approval is required for any disturbance of soil (the goal of this IC is to prevent the constant contact of this media with water which could impact GW or SW quality.
The AF will submit an IC Performance Report to the ADEC on an annual basis for the first five years post-remedial action in-place. The frequency of the IC Performance Report will be evaluated with the five-year review under 42 USC 9621(c). This report shall include information pertaining to any breaches to IC’s, corrective actions taken, & any property transfer. |
Louis Howard |
| 2/27/2009 |
Document, Report, or Work plan Review - other |
Staff sent letter to Patrick Roth 611 CES/CEAR re: Draft work plan and appendices for soil washing PCBs at Port Heiden. Work Plan 4.6.2 Soil Removal: ADEC requests clarification on the rationale for sampling a grid cell measuring 15 feet long by 15 feet wide has been excavated, a single soil confirmation sample will be collected from that cell to confirm the remaining soil contains PCBs less than 10 mg/kg. Typically the procedures outlined within CFR 761.283 and CFR 761.286 bulk PCB remediation waste will be followed to characterize the soils in the areas that have exhibited PCB contamination during prior investigations. These regulations state “for spills where there are insufficient visible traces yet there is evidence of a leak or spill, the boundaries of the spill are to be determined by using a statistically based sampling scheme.” According to 40 CFR 761.61(a)(2) Subpart N and 40 CFR 761.61(a)(6) Subpart O, the grid should be centered in the cleanup area. EPA Region 10 must provide written consent to the proposed sampling in the draft work plan for characterization of PCB soil contamination for this project. The minimum number of samples is three samples for each type of bulk remediation waste location, take a minimum of three samples for each type of bulk PCB remediation waste or porous surface at the cleanup site, regardless of the amount of each type of waste that is present. There is no upper limit to the number of samples required or allowed.
The text states excavation at the RRS Landfill will stop when debris is encountered regardless of the concentration of PCBs. ADEC requests clarification on what the definition of debris is inferred in this section( e.g. debris in any measurable amount or debris significant enough to impede excavation). ADEC also requests the Air Force further detail its rationale for stopping excavation be provided for the reader (i.e. cite the specific Department of Defense guidance, policy and/or regulation prohibiting such activities when “debris” is encountered). ADEC requests the Air Force describe in this section whether or not confirmation samples will be taken when “debris” is encountered to document what is left in place in the floor and sidewalls of the excavation to be documented in the required institutional controls for the RRS Landfill.
4.8 Non-PCB Hot Spot Soil Removal Page 15: The text states contaminated soil surrounding these wells will be removed to within 3 feet of the well. ADEC requests the Air Force elaborate on why it is not feasible to hand excavate soil closer to the monitoring wells and how the residual soil will be noted by institutional controls for the PCB contamination left behind by the Air Force.
4.10.4 POL Excavation Confirmation Sampling Page 18: The text states no floor samples are planned for excavations greater than fifteen feet. If the Air Force is excavating beyond fifteen feet, then ADEC will require confirmation sampling of the excavation floors. The Air Force can use the excavator bucket to collect the samples as it is doing for the shallower samples. ADEC will require sidewall samples from excavations greater than two feet in depth or “subsurface soil ”. ADEC proposes at least one sidewall sample per side be taken for excavations greater than two feet but less than four feet per side. For those excavations less than two feet in depth (or “surface soil ”), ADEC will not require sidewall excavations. EPA may have other requirements
Appendix C QAPP 4.4.8 Field Duplicate (Replicate) Samples Page 4-18: ADEC will require field duplicates be collected once per 10 field samples, not per 20 field samples as stated in this document.
5.1.2 Sample Volumes, Container Types, and Preservation Requirements Page 5-1: ADEC will require methanol preserved volatile organic compounds (VOC) soil samples be collected, unless detection limits in methanol do not meet project objectives. If low level is necessary, provide information on how the samples will be frozen onsite to -10 C and remain at this temperature until laboratory receipt.
|
Louis Howard |
| 2/27/2009 |
Institutional Control Record Established |
John Halverson (ADEC) signed the Record of Decision for Port Heiden. A notice type of institutional control (IC) will be implemented (with the land owners consent) to control the use of soil containing residual concentrations of dieldrin above 0.0076 mg/kg. This notice will make the Land Owner aware that ADEC approval is required for any disturbance of soil (the goal of this IC is to prevent the constant contact of this media with water which could impact GW or surface water quality).
At the RRS landfill, ICs will be established to provide notice that the remaining buried wastes may contain contaminants of concern, that the cover should be maintained, & excavation into or development over landfill should be restricted to maintain the integrity of cap & to prevent migration of contaminants. If future property use includes disturbance of the IC area such that the remaining pesticide contaminated soil comes in constant contact with water, or other information becomes available which indicates the site may pose an unacceptable risk to human health, safety, welfare or the environment, the land owner &/or operator are required under 18 AAC 75.300 to notify ADEC & evaluate the environmental status of the contamination in accordance with applicable laws & regulations. Further site characterizations & cleanup may be necessary under 18 AAC 75.325-.390.
In the future, if soil is removed from the site it must be characterized & managed following regulations applicable at that time. Pursuant to 18 AAC 75.325(i)(1) & (2), ADEC approval is required prior to moving or disposing of soil that is, or has been, subject to the cleanup rules found at 18 AAC 75.325-.370. The Air Force will submit the report to the ADEC on an annual basis for the first five years post-remedial action in-place. The frequency of the report will be evaluated with the five-year review under 42 USC 9621(c). This report shall include information pertaining to any breaches to IC’s, corrective actions taken, & any property transfer.
Since GW contaminants will be left onsite for many years until cleanup goals are met, ICs will be necessary to control human exposure to GW. Institutional GW controls shall include limitations on GW use as approved by ADEC, & notices to the land owner & Village Council of site status. These ICs will remain in place until GW cleanup levels are achieved through natural attenuation. The objectives of the GW ICs are to prevent the drinking of TCE & benzene contaminated water & to prevent its extraction & surface use without treatment.
Any planned use of GW at the site must be approved by ADEC. In the event information becomes available which indicates that site GW may pose an unacceptable risk to human health, safety, welfare or the environment, the land owner &/or operator are required under 18 AAC 75.300 to notify ADEC & evaluate the environmental status of the contamination in accordance with applicable laws & regulations. Further site characterizations & cleanup may be necessary under 18 AAC 75.325-.390. Any contaminated GW that is encountered must be managed in accordance with applicable regulations, for example any dewatering must be done following ADEC approved plans that include any necessary treatment to meet discharge standards.
In the future, if GW is removed from the site it must be characterized & managed following regulations applicable at that time. Pursuant to 18 AAC 75.325(i)(1) & (2), ADEC approval is required prior to moving or disposing of GW that is, or has been, subject to the cleanup rules found at 18 AAC 75.325-.370. |
John Halverson |
| 3/19/2009 |
Meeting or Teleconference Held |
Meeting Summary Attendees: Glen Verplancke, AFCEE, Louis Howard, ADEC, Earl Crapps, ADEC Mark Goodwin, WESTON, Skip Koch, WESTON & Barbara Pape, WESTON. Subj: Port Heiden RRS Low Level PCB contamination in Soil Treatment Area.
At 1:45 PM on 19 March 2009, the personnel listed above met via conference call to discuss Port Heiden Low Level PCB Contamination in Soil Treatment Area. Specifically, the intent of the meeting was to address the levels of PCB in the footprint of the soil treatment lay down area (refer to attached drawing, areas 1-8). This included a discussion of the regulatory, contractual, funding, schedule & community constraints associated with this contamination. The topics discussed are addressed in the bullets
below:
Items discussed regarding the PCB levels are as follows:
-The levels in cells used to screen were composite samples of 9 individual locations.
-The levels of PCBs found in areas 1,2,3,4,7 & 8 were below 0.4 ppm, but due to the nature of composite samples they could be biased as high as 9 times the number reported since there were 9 different areas combined.
-The levels found in areas 5 & 6 were 1.01 ppm & 0.982 ppm, respectively.
-Skip mentioned these levels could be from dust blown in.
-Earl mentioned it could have been from other sources since the extract was dark & had to be diluted. Earl further mentioned that the samples contained PAHs.
-Weston’s subcontractor has removed the top few inches of soil based on leveling out the site & stockpiled the soil. Possible estimates for stockpiled soils are from 1000 to 1500 CY of soil.
Options for addressing the soil areas are as follows:
-Discussion for further screening that one discrete sample & 6 composite locations from each area 1, 2, 3, 4, 7, & 8, is acceptable.
-ADEC would like to further consider sampling requirements following pulling the liner.
Discussion regarding MI sampling for the stockpiled soil from areas 1, 2, 3, 4, 7, & 8.
-ADEC would like to further consider this item.
-Can place liner prior to receiving the results the second set of samples, per ADEC.
Consider field screen again in areas 5 & 6 & accomplish 2 discrete samples based on one at the high level & one at the low level from the field screening.
-These areas shall not be disturbed as part of site operations.
-AFCEE requested Weston provide a cost estimate for additional screening at 5 & 6. |
Louis Howard |
| 3/25/2009 |
Update or Other Action |
Final Soil Washing Operations Plan Port Heiden RRS received. Soil washing will be conducted by Trucano Construction Company (Trucano) & their subcontractor DMC Technologies, Inc. (DMC) under a subcontract to the Prime Contractor, Weston Solutions, Inc. (WESTON). Trucano & its subcontractors will comply with all federal & state regulations pertaining to this work.
The scope of work for this project includes the following tasks:
Design & construct a portable soil washing facility at the Former Facility Area of the Port Heiden RRS.
Receive approximately 1000 cubic yards of soil contaminated with PCBs that have been excavated from the Former Facility Area.
Receive approximately 500 cubic yards of soil contaminated with PCBs & pesticides &/or PAHs that have been excavated from the Former Facility Area.
Remove PCBs/Pesticides/PAHs from the soil particles using a soil washing technology.
Collection of laboratory analytical samples to document attainment of Alaska Department of Environmental Conservation (ADEC) soil cleanup levels in washed soil.
Documentation of all field & laboratory sample results.
All work activities that are associated with soil washing will be conducted in accordance with applicable regulations & guidance including:
ADEC’s Soil Treatment Facility Guidance (ADEC, 2002a).
ADEC’s Underground Storage Tank Procedures Manual (ADEC, 2002b).
Title 18 Alaska Administrative Code Chapter 75 (18 AAC 75) Oil & Other Hazardous Substances Pollution Control, as amended through October 9, 2008 (ADEC, 2008b).
18 AAC 78 Underground Storage Tanks, as amended through October 27, 2006 (ADEC, 2006a).
Toxic Substances Control Act (TSCA), 40 Code of Federal Regulations 761 (40 CFR 761)
Resource Conservation & Recovery Act (RCRA), 40 CFR 260
USAF 611th Air Support Group, Waste Handling Handbook. As revised January 2005 (USAF, 2005).
Trucano will implement the soil washing program under the direct supervision of WESTON. Trucano will utilize the following second tier subcontractors:
• DMC – soil washing technology
• Aniakchak LLC (Aniakchak) – heavy equipment, labor, lodging, & local transportation support
• TO BE DETERMINED – at the request of the USAF or ADEC, Trucano will subcontract with an ADEC approved & qualified third party independent contractor to oversee &/or provide confirmation sampling support
DMC will provide the chemicals, technical knowledge, & professional oversight of the soil washing effort. To the greatest extent practical, DMC will direct the local labor force provided by Aniakchak in preparing stockpiles, handling soil, assisting in sample collection, & stockpile & facility breakdown.
WESTON will excavate the soils in accordance with their approved work plan & deliver any soils with concentrations of PCBs that are 10 milligrams per kilogram (mg/Kg) or greater to a soil washing facility operated by Trucano & DMC. Trucano has been subcontracted by WESTON to remove PCBs, PAHs, & pesticides from the contaminated soils. DMC in turn, has been subcontracted by Trucano to provide the soil washing technology, oversee the application of chemicals, & direct local resources (Aniakchak) who will aid in implementing the technology. It is estimated that approximately 1,500 cubic yards of soil will require soil washing. Approximately 500 cubic yards of the PCB contaminated soil will also have concentrations of PAHs &/or pesticides that exceed the established site soil cleanup levels.
As defined in the Record of Decision for the site (USAF, 2009b), soils will be washed until PCB concentrations are below 10 mg/Kg. Laboratory confirmation samples will be collected to document the removal of PCBs from the soils. Sampling procedures & frequency are discussed in greater detail in this Operations Plan & Addendum I (FSP). It is anticipated that the PAHs & pesticides will be effectively removed during the washing process. Representative samples will be collected the PCB/PAH/pesticide washed soils to document any residual concentrations of PAHs & pesticides, as well as PCBs.
After soil washing is complete, washed soils with PCB concentrations less than 10 mg/Kg will be relinquished to WESTON for disposal at the Port Heiden landfill. Soils with PCB concentrations equal to or greater than 10 mg/Kg & process waste (adsorbent. filter cartridges, residual solvent) will be shipped off-site & properly disposed of by Trucano/DMC in accordance with TSCA & RCRA requirements. |
Louis Howard |
| 3/27/2009 |
CERCLA ROD Approved |
John Halverson signed the Record of Decision presents the Final Selected Remedy for the source areas at Port Heiden RRS, located in Port Heiden, AK. There are some areas contaminated with Petroleum, Oil & Lubricants (POL) . The remedies for POL are not selected in this ROD, but will be addressed in a subsequent work plan submitted in accordance with ADEC regulations.
By signing the ROD, the ADEC concurs with the AF's selected remedies. The decision may be reviewed & modified in the future if new information becomes available that indicates the presence of contaminants or exposures that may cause unacceptable risk to human health or the environment. If additional contaminants are discovered, USAF & ADEC will determine the compliance levels for soil & GW cleanup actions
The soil COCs consist of PCBs, pesticides & PAHs. GW COCs consist of TCE & benzene. This ROD is issued by the USAF in accordance with & satisfying the requirements of the DERP, 10 USC 2701 et seq.; CERCLA 42 USC 9601 et seq.; E. O. 12580, 52 Federal Register 2923 (23 January 1987); & NCP, 40 CFR 300.
The EPA has been consulted consistent with the requirements of 10 USC 2705 & has chosen to defer to ADEC for regulatory oversight of the Port Heiden RRS. The cleanup will be accomplished by first excavating the portion of soil containing PCBs > or = to 10 mg/kg (soil may include incidental pesticides & PAHs). This portion of the contaminated soil will be washed in an alcohol-based solvent to extract PCBs & reduce the level in the treated soil to < 10 mg/kg. Sampling of the treated soil will be performed to confirm PCB levels are below 10 mg/kg. Recalcitrant soil that cannot be treated using soil washing to meet required PCB level (<10 mg/kg) will be barged offsite for proper disposal. Upon confirmation that the treated soil contains PCBs < 10 mg/kg, the soil will be loaded into trucks & taken to the local permitted Class III landfill for disposal.
The remaining soil containing PCBs greater than 1 mg/kg will be excavated. This soil which contains PCBs > 1 mg/kg but < 10 mg/kg will also be loaded into trucks & taken to the offsite Class III Landfill for disposal. Soil containing levels of PCBs < 10 mg/kg but with levels of pesticides & PAHs above their cleanup levels will be excavated & taken to the local Class III landfill for disposal (PCBs 1 mg/kg, dieldrin 0.015 mg/kg, heptachlor epoxide 0.2 mg/kg, benzo(a)pyrene 0.49 mg/kg, benzo(a)anthracene 3.6 mg/kg & dibenzo(a,h)anthracene 0.49 mg/kg).
Tundra will only be excavated to remove dieldrin in soil where levels exceed the 18 AAC 75.341(c) Method 2 human health risk direct contact value of 0.32 mg/kg. At the existing Port Heiden RRS Landfill, excavation of contaminated soil will stop upon encountering landfill solid waste & the cap will be restored with clean soil. After all soil washing is complete, the PCB, pesticide, & PAH enriched residue generated during the soil washing process will be handled & disposed in accordance with state & federal regulations. Upon completing the excavation, confirmation samples will be collected & analyzed to ensure the remaining soil meets the cleanup levels for PCBs, PAHs &/or pesticides. Any soil not meeting cleanup levels will be further excavated & resampled.
A notice type of IC will be implemented (with the land owners consent) to control the use of soil containing residual levels of dieldrin above 0.0076 mg/kg. This notice will make the Land Owner aware that ADEC approval is required for any disturbance of soil (the goal of this IC is to prevent the constant contact of this media with water which could impact GW or surface water quality).
GW is contaminated with TCE & benzene. The selected remedy for GW is Monitored Natural Attenuation (MNA) and applies to the Black Lagoon Outfall Plume & the Former Facility Area Plume. GW monitoring will be conducted in accordance with a plan approved by ADEC & the AF to monitor NA the plume. As other contaminants (i.e., fuels) in the GW breakdown over time, their by-products will help to break down the TCE & benzene.
Since GW contaminants will be left onsite for many years until cleanup goals are met, ICs will be necessary to control human exposure to GW. Periodic monitoring & subsequent review will be conducted to verify the effectiveness of NA & that cleanup goals are achieved.
After the 1st 5 yrs. of GW monitoring (performed at a frequency no less than annually during the summer period), the AF & ADEC will evaluate the progress of NA. Wells to be monitored will be determined as part of a GW Monitoring Plan to be submitted to ADEC for coordination & approval. The 5 yr. evaluation will compile, analyze, & review all GW data collected, to determine the effectiveness of NA. If during this evaluation, the data indicates contaminant levels in GW are not declining as estimated, the AF & ADEC may reconsider the remedy decision. |
John Halverson |
| 3/31/2009 |
Update or Other Action |
Final Work Plan Remedy Selection & Implementation, Demolition & Debris Removal Port Heiden Radio Relay Station, Alaska received. This Work Plan (WP) outlines the basic technical approach to complete the Remedy Selection & Implementation, Demolition & Debris Removal (including soil washing to treat PCB contaminated soil) at the Port Heiden Radio Relay Station (RRS) in Port Heiden, Alaska.
The approach to completing the scope of work includes:
• identifying, excavating, & performing soil washing on soil containing PCBs greater than or equal to 10 mg/kg;
• identifying & excavating the remaining PCB/Pesticide/PAH contaminated soil above cleanup levels & disposing of it in a local landfill;
• excavating POL contaminated soil & placement in biopiles for bioremediation;
• & demolition & removal of miscellaneous items & debris.
The approach outlined in this work plan is based on results from the Port Heiden RRS RI (USAF 2006). During the RI, over 400 soil samples were collected from targeted areas known to be potentially contaminated. These samples were collected from an area referred to as “The Former Facility Area” approximately 4 acres in size providing a very high sample density. Since nature of contamination at the site was accurately determined during the RI, it forms the basis for cleanup. As a result, the site was divided into numerous areas targeted for soil removal.
The areas to undergo removal, the contaminants of concern, & the selection of analytes for confirmatory analyses are based on those exceeding cleanup levels in each specific area of the site as determined in the approved RI.
Based on the RI data, the areas of soil containing PCBs greater than or equal to 10 mg/kg (which will be treated by soil washing) can be approximated. It is estimated that approximately 1,500 cubic yards of soil contain PCBs greater than or equal to 10 mg/kg. Overall, it is estimated that another 5,500 cubic yards of soil are contaminated with PCBs less than 10 mg/kg but greater than 1 mg/kg & Pesticides/PAHs above cleanup levels which will be excavated & placed in a landfill.
Soil samples at the RRS were also collected to define the nature & extent of POL contamination consisting of DRO, RRO, & GRO. It is estimated that approximately 4,500 cubic yards of soil are contaminated with DRO, RRO & GRO above their respective cleanup levels & will be excavated & placed in biopiles.
To achieve the project goals, WESTON will execute the following tasks:
• Develop project plans/documentation, & attend meetings.
• Develop the WP, a Construction Quality Plan, a Health & Safety Plan & various other plans required for this work.
• Procure materials & subcontractors, & mobilize equipment & personnel to Port Heiden, Alaska.
• Perform field work in accordance with the WPs.
• Demobilize personnel, equipment, & materials.
• Report monthly on the status of the project level of effort by submitting a project schedule; weekly field reports with photos; & a Contractor’s Progress, Status & Management Report (CPSMR).
• Prepare draft & final technical reports.
• Provide appropriate management & oversight throughout the entire project.
Borrow Source Location
Areas excavated more than 3’ deep will be backfilled to at least 2’ below the surrounding grade. The perimeters of areas excavated less than 3’ deep will have their perimeter graded to a 2:1 slope. This borrow pit will be located on AF lands that were not used for, or near, a development. It is anticipated that the pit will be located on the east side of the road leading north.
It is estimated that a borrow source approximately 250’ wide by 300’ long will be needed to provide backfill for the areas excavated. It is assumed that the borrow area will be excavated to a depth of 5’. After borrow material is through being excavated, the sides of the pit will be graded to a slope of 2:1 & the pit seeded. Alternatively, spoils from excavating the new Class III landfill may be used for borrow material.
Borrow Material Sampling
Samples from in-place borrow material to be used for backfill will be collected with a hand auger or from the bucket of an excavator at a depth of 1' & 4' over the borrow area. Samples will be collected at a frequency of one per every 1,000 c.y. of in-place material & analyzed for PCBs, PAHs, DRO, RRO, Dieldrin & Heptaclor Epoxide. Assuming borrow material is excavated to a depth of 5', 1 sample would be collected every 10,800 sq ft of area. Borrow material must meet the cleanup criteria prior to being excavated.
If the new permitted landfill excavation spoils are used, one sample will be collected from every 1,000 cubic yards of stockpiled material. The new permitted landfill is located in an area where no contamination is known to exist. |
Louis Howard |
| 4/24/2009 |
Cleanup Plan Approved |
Staff sent letter approving the Final Versions of: Work Plan, CQP, SSHSP, QAPP, SWPPP, FSP and Soil Washing Work Plan for Remedy Selection and Implementation; Demolition and Debris Removal
Port Heiden RRS, Alaska FA8903-04-D-8681, Task Order No. 0305 and 0334 Project Number: TNYH20077201 & TNYH20087201.
The Alaska.Department of Environmental Conservation (ADEC) has received the documents via electronic mail on March 27,2009 for final review and approval. ADEC willapprove the work plan and associated documents for the following tasks in the scope of work:
• identifying, excavating, and performing soil washing on soil containing polychlorinated biphenyls (PCBs) greater than or equal to 10 mg/kg;
• identifying and excavating the remaining PCB/Pesticide/Polynuclear aromatic hydrocarbons (P AH) contaminated soil above cleanup levels and disposing of it in a local landfill;
• and demolition and removal of miscellaneous items and debris.
The approval for the work plan to treat the POL contaminated soil in biopiles is not granted at this time. ADEC has not reviewed and commented on the "2009 Petroleum-contaminated Soil Biochemical Treatment Operations Plan" (April 16, 2009) submitted on April 22, 2009 via electronic mail. ADEC will provide review comments on the operations plan no later than May 22, 2009 and expects a revised operations plan for review and approval no later than June 8,
2009.
All references to the treatment using the biopiles or multi-incremental (MI) sampling approach for confirmation samples from the biopiles are not approved by ADEC at this time.
Until an approved work plan for treatment is granted, the Air Force may construct biopiles/stockpiles of petroleum contaminated soils on Air Force property for future disposal/remediation. If budgetary constraints or other unforeseen circumstances prevent treatment of the soils this field season, then storage ofthese soils may not exceed two years. |
Louis Howard |
| 4/29/2009 |
Update or Other Action |
Staff reviewed and commented on the 2009 Petroleum-contaminated Soil Biochemical Treatment Operations Plan dated April 16, 2009 for Port Heiden Radio Relay Station, Alaska FA8903-04-D-8681.
The Alaska Department of Environmental Conservation (ADEC) has received the Soil Biochemical Treatment Operations Plan for treatment of petroleum contaminated soil at Port Heiden RRS via electronic mail on April 22, 2009 for review and comment. ADEC has the following comments on the document.
1.1 Scope of Work Page 1-3: ADEC requests the Air Force delete reference to soil washing from this specific work plan when discussing the biochemical treatment process which is different from soil washing. ADEC has already provided comments on the soil washing process for PCB/PAH/Pesticide soils. ADEC requests the Air Force add to the list of applicable regulations and guidance: ADEC’s letter to DMC Technologies dated May 29, 2008 outlining the applicable conditions that apply to the use of Pentanonic.
1.2 Project Organization and Key Personnel:Last bullet states it is to be determined – at the request of the USAF or ADEC, Trucano will subcontract with an ADEC approved and qualified third party independent contractor to oversee and/or provide confirmation sampling support. The Air Force will ensure that the collection, interpretation, and reporting of data, and the required sampling and analysis is conducted or supervised by a qualified, impartial third party (18 AAC 75.355 Sampling and analysis).
Table 2-1: Soil Treatment Criteria Page 2-2:The table lists residual-range organics (RRO) treatment level as 11,000 mg/kg. ADEC disagrees. The most stringent pathway (in this case ingestion) applies for RRO: 10,000 mg/kg. According to 18 AAC 75.341: Notes to Tables B1 and B2: The cleanup level from Table B1 or B2 that applies at a site is the most stringent of the applicable exposure pathway-specific cleanup levels based on direct contact, inhalation, or migration to groundwater.
2.2 Data Quality Objectives Page 2-2:ADEC requests the Air Force change the text stating analytical results will be compared to the most stringent soil cleanup levels in 18 AAC 75.341 (Tables B1 and B2).
Table 2-2 Data Quality Objectives for Soil Washing Page 2-3:See comment above regarding soil washing not being applicable to this plan. The table states action levels for gasoline range organics (GRO), diesel range organics (DRO), residual range organics (RRO) are not applicable for the baseline soil sampling from the facility footprint prior to setup. ADEC disagrees. The applicable cleanup levels (18 AAC 75 Table B2 Method 2) for soil at the facility footprint are the most stringent levels for GRO (300 mg/kg), DRO (250 mg/kg) and RRO (10,000 mg/kg). If samples come back higher than Table B2 cleanup levels at the facility footprint, then the area is a new site for the Air Force to investigate.
The table lists data to be collected for confirmation samples will be compared to migration to groundwater soil cleanup levels. ADEC requests the text be changed to either add text for RRO soil cleanup level (ingestion) or simply state the most stringent pathway specific soil cleanup level will be met. The table states that baseline soil sampling will be taken from the facility footprint after facility demobilization and soil conditions above baseline concentrations will be documented. ADEC disagrees. If samples come back higher than Table B2 Method 2 cleanup levels at the facility footprint, then it appears the residual contamination is from the facility operations since previous sampling before operations presumably came back below cleanup levels. It appears the contractor would have to address any contamination from operations under Section 5.2 Protection of Land and Water Resources. If the contractor will not address the residual contamination, then the Air Force will be responsible for site characterization and remediation of the contamination. |
Louis Howard |
| 5/13/2009 |
Update or Other Action |
Email from Teresa O'Carroll to WESTON and DMC re: 1091815.
On May 6, DMC collected 8 soil samples and 1 duplicate sample from the footprint of the proposed treatment facility. The attached figure shows the sample locations. Initially, an 300 x 211 foot area immediately north of the access road was staked out and then divided
into 6 primary grid sections of roughly equal size (100 x 100). The 2 grids closest to the road, grids 5 and 6, were located on an elevated area.
The vegetation appeared relatively undisturbed and the area did not appear to have been graded in the past. Some debris had been pushed/piled up in grid 6. Just beneath the tundra rocky outcrops were encountered. These two grids are not conducive to grading or leveling for use in the treatment facility. Therefore, the footprint was expanded approximately 100 feet to the north and 2 additional primary quadrants were measured off and subdivided in the same manner as described above. These 2 quadrants were numbered 8 and 9. See attached figure for quadrant locations.
The orientation of the footprint as sampled is a variation from the one shown on Figures 1-2 and 1-3 in the Final Work Plan. This variation was necessitated by an elevated area consisting of a rocky outcropping located in the northwest section of the proposed site footprint. The facility footprint was rotated in a clockwise direction such that the long center axis is roughly oriented on a northeast to southwest trend rather than the northwest to southeast trend depicted in the figures.
Each of the 6 primary grids were then subdivided into 25 sub-girds. Nine of the 25 subgrids in each primary grid were selected using a random number generator approach and a sample was then collected from each of the 9 random sample locations in that grid and placed into
a stainless steel bowl. Each sample was collected from 0 to 6 inches in depth.
The 9 sample aliquots were thoroughly mixed using a stainless steel spoon and then composited into one sample. This procedure was repeated at each of the remaining 7 primary grids, resulting in 8 samples. A duplicate (Sample no. 9) was collected from primary grid 7. The duplicate was collected from 9 independently and randomly selected locations within grid 7.
The final analytical results for the composite footprint samples are attached. They indicate that one of the six quadrants has PCB concentrations slightly above 1 ppm (Quadrant 5 at 1.010 mg/Kg) and one quadrant is slightly below 1 ppm (Quadrant 6 at 0.982 mg/Kg). Steve and
I had already decided that the treatment facility would be north of these quadrants due to the higher elevation and rocky nature, but we wanted to document the levels in them because of their proximity to the road and our planned facility area.
Since the levels are slightly elevated in quadrants 5 and 6 DMC will use care and minimize disturbance of the natural ground surface, as well as traffic through these areas. A perimeter ditch will be constructed between these quadrants and our treatment facility to prevent any runon from or runoff to our work area.
Our area will now encompass quadrants 8 and 9 (northern most quadrants) and 1, 2, 3, and 4. DMC will begin removing the vegetation and topsoil in the area encompassed by quadrants 1,2,3,4,7,8 immediately. One this material has been removed the site will be graded and sloped to control runon and runoff. Ditches and berms will be constructed according to the
approved site design. Once these tasks are complete, and prior to
placement of any geofabric or liner, another set of footprint samples
will be collected, again using a grid and random sampling approach.
|
Louis Howard |
| 5/13/2009 |
Update or Other Action |
May 13, 2009 email message from Teresa O'Carroll to WESTON and DMC forwarded by Air Force (Pat Roth) project manager to ADEC project manager.
On May 6, DMC collected 8 soil samples and 1 duplicate sample from the footprint of the proposed treatment facility. The attached figure shows the sample locations. Initially, an 300 x 211 foot area immediately north of the access road was staked out and then divided into 6 primary grid sections of roughly equal size (100 x 100). The 2 grids closest to the road, grids 5 and 6, were located on an elevated area. The vegetation appeared relatively undisturbed and the area did not appear to have been graded in the past. Some debris had been
pushed/piled up in grid 6.
Just beneath the tundra rocky outcrops were encountered. These two grids are not conducive to grading or leveling for use in the treatment facility. Therefore, the footprint was expanded approximately 100 feet to the north and 2 additional primary quadrants were measured off and subdivided in the same manner as described above. These 2 quadrants were numbered 8 and 9. See attached figure for quadrant locations.
The orientation of the footprint as sampled is a variation from the one shown on Figures 1-2 and 1-3 in the Final Work Plan. This variation was necessitated by an elevated area consisting of a rocky outcropping located in the northwest section of the proposed site footprint. The facility footprint was rotated in a clockwise direction such that the long center axis is roughly oriented on a northeast to southwest trend rather than the northwest to southeast trend depicted in the figures.
Each of the 6 primary grids were then subdivided into 25 sub-girds. Nine of the 25 subgrids in each primary grid were selected using a random number generator approach and a sample was then collected from each of the 9 random sample locations in that grid and placed into
a stainless steel bowl. Each sample was collected from 0 to 6 inches in depth. The 9 sample aliquots were thoroughly mixed using a stainless steel spoon and then composited into one sample. This procedure was repeated at each of the remaining 7 primary grids, resulting in 8
samples. A duplicate (Sample no. 9) was collected from primary grid 7. The duplicate was collected from 9 independently and randomly selected locations within grid 7.
The final analytical results for the composite footprint samples are attached. They indicate that one of the six quadrants has PCB concentrations slightly above 1 ppm (Quadrant 5 at 1.010 mg/Kg) and one quadrant is slightly below 1 ppm (Quadrant 6 at 0.982 mg/Kg). Steve and
I had already decided that the treatment facility would be north of these quadrants due to the higher elevation and rocky nature, but we wanted to document the levels in them because of their proximity to the road and our planned facility area.
Since the levels are slightly elevated in quadrants 5 and 6 DMC will use care and minimize disturbance of the natural ground surface, as well as traffic through these areas. A perimeter ditch will be constructed between these quadrants and our treatment facility to prevent any runon from or runoff to our work area.
Our area will now encompass quadrants 8 and 9 (northern most quadrants) and 1, 2, 3, and 4.
DMC will begin removing the vegetation and topsoil in the area encompassed by quadrants 1,2,3,4,7,8 immediately. One this material has been removed the site will be graded and sloped to control runon and runoff. Ditches and berms will be constructed according to the
approved site design. Once these tasks are complete, and prior to placement of any geofabric or liner, another set of footprint samples will be collected, again using a grid and random sampling approach. |
Louis Howard |
| 5/14/2009 |
Document, Report, or Work plan Review - other |
ADEC provided comments to Air Force on the rough Draft version of the February 5, 2010 Port Heiden Remediation Soil Washing Report.
The Alaska Department of Environmental Conservation (ADEC) has received the above document April 27, 2010 for review and comment. ADEC has reviewed it and the following comments on the documents.
Settling In Primary Basin Page 35
ADEC requests the Air Force clarify what happened to the pumice removed from the basin and subsequently placed in the tank shell or debris basin.
8.2 PCB Stockpile Baseline Samples Page 47
The text states: “The average PCB concentration in the large lot of the contaminated soil stockpile was 47.8 mg/kg. The average PCB concentration in the small lot of the contaminated soil stockpile was 628.3 mg/kg. The total PAH average concentration was identified as 0.1041 mg/kg. The average concentrations of the three PAH analytes of interest were: Benzo(a) anthracene - 0.2062 mg/kg; Benzo(a)pyrene - 0.1933 mg/kg and Dibenzo(a,h)anthracene - 0.0316 mg/kg.” ADEC cleanup levels are based on the maximum detected concentration of total PCBs and not the average concentration. PAHs are regulated on an analyte specific basis and for the maximum detected concentrations and not the average concentration or total PAHs. It appears the PAH levels were already below cleanup levels established by 18 AAC 75 prior to treatment.
9.0 PCB Soil Washing Data Page 50
The text states: “In summary, the 101 laboratory samples of successfully washed soil and debris including sacrificial soil had an average PCB concentration of 1.16 mg/kg
ranging from no detect to 5.8 mg/kg.” ADEC requests the Air Force provide text in this section regarding the rationale for reporting only Aroclor 1260 instead of total PCBs (i.e. previous investigations have determined that only Aroclor 1260 is at the Port Heiden site and therefore that is what is being reported).
9.1 Round One Washing Sample Results Page 52
The text states the PAH sampling was terminated after round one washing and only traces of PAH were detected in washed soils. This may be true, however all PAH analytes from the PCB Stockpile Baseline Samples (Large Lot) were already below cleanup levels found in 18 AAC 75 Table B2 cleanup levels before they were washed and retested.
Benzo(a)anthracene 3.6 mg/kg migration to groundwater, Benzo(a)pyrene and Dibenzo(a,h)anthracene: 0.49 mg/kg direct contact (Under 40 Inch Zone), 1-Methylnaphthalene and 2-Methylnaphthalene: 6.2 mg/kg migration to groundwater, Acenaphthene and Acenaphthylene 180 mg/kg migration to groundwater, Anthracene 3,000 mg/kg migration to groundwater, Benzo(a)anthracene 3.6 mg/kg, Benzo(g,h,i)perylene 1,400 mg/kg direct contact (Under 40 Inch Zone), Benzo(k)flouranthene 49 mg/kg direct contact (Under 40 Inch Zone), Chrysene 360 mg/kg, Fluoranthene 1,400 mg/kg migration to groundwater, Fluorene 220 mg/kg, Indeno(1,2,3-c,d)pyrene 4.9 mg/kg migration to groundwater, Naphthalene 20 mg/kg migration to groundwater, Phenanthrene 3,000 mg/kg migration to groundwater, and Pyrene 1,000 mg/kg.
9.4 Rewashing Confirmation Samples Round 3 Page 55
The text states: “The soil was replaced on the conveyor, moved to the mixer and rewashed. A higher dose of chemicals was applied to the washing process.” ADEC requests the Air Force specify what chemicals were used and the amount of chemicals used in this “higher dose”. The final approved work plan states in Section 4.3.3 Soil Washing-Secondary Soil Washing: “The sand screw is a wet operation and additional Alcohol A may be added to the sand screw to facilitate particle separation.”
12.1 Upper 10 mil Liner and Upper Felt Layer Samples Page 58
The text states: “Samples indicated PCB concentrations ranging from 1.1 mg/kg to 8.04 mg/kg with an average of 3.7 mg/kg.” ADEC cleanup levels are based on the maximum detected concentration of a contaminant and not the average concentration.
12.3 Lower Felt Layer Samples Page 58
The text states: “The PCB concentration in the lower felt beneath tears averaged 6.5
mg/kg. The PCB concentration in the soil beneath the lower felt averaged 0.246 mg/kg.” ADEC cleanup levels are based on the maximum detected concentration of contaminants detected and not the average concentration.
13.1 Spent Solvent Filtration Samples Page 61
The text states the average PCB concentration in the unfiltered liquid was 49.7 mg/L ranging from 4.29 mg/L to 79.2 mg/L. ADEC requests the Air Force change the units in the table from mg/kg to mg/L since the samples are from spent liquid solvents and not soil. ADEC requests the Air Force provide clarification and PCB sampling results for the pumice which was screened out during the treatment process (Settling in Primary Sedimentation Basin Page 35) and added to the debris pile.
See site file for additional information.
|
Louis Howard |
| 5/24/2009 |
Update or Other Action |
WESTON Daily Construction QC Report - Notified DMC of higher PCB concentrations. Possibly need repeated washing will have further discussion as data is collected and volume determined. Miscellaneous Issues (Delay, Problems, etc) - High concentration PCBs (4,500 mg/kg) have been detected. These high concentrations could lead to a contract change. We will "wait and see", treatment is possible, but may require higher doses on repeated washing. This determination needs further consideration and discussion. Treatment data is also needed. |
Louis Howard |
| 5/29/2009 |
Offsite Soil or Groundwater Disposal Approved |
ADEC (Solid Waste Program) sent letter to Lynn Carlson (Native Council of Port Heiden) re: Disposal of Polluted Soil in the Port Heiden Landfill (Class III). ADEC has reviewed the proposal for the disposal of polluted soils in the Port Heiden Class III Landfill. The plan, dated March 18, 2009, was submitted by Weston Solutions, Inc. on behalf of the Native Council of Port Heiden.
The soils originate from the cleanup of the U.S. Air Force Port Heiden Radio Relay Station (Port Heiden RRS). According to the definition in Title 18, Chapter 60 of the Alaska Administrative Code [18 AAC 60.990(97)(A)], polluted soil "contains a hazardous substance in a concentration exceeding an 'over 40 inch zone' migration to GW level set in 18 AAC 75.341 Table B1 or Table B2 .... " The Solid Waste Regulations (18 AAC 60.025) allow the disposal of polluted soil in a landfill when it is demonstrated that the contaminants in the soil will not migrate from that landfill.
The plan included a fate & transport model that indicated that the soil contaminants will not migrate from the disposal site. Based on our review of the request, the polluted soils from the Port Heiden RRS, represented by the analytical data included in your request, are approved for disposal in the Port Heiden landfill with the following conditions:
1. Only soil with a polychlorinated biphenyl (PCB) concentration of less than 10 mg/kg may be disposed at the landfill.
2. Soil containing pesticides must be disposed in an area which will be covered with a 30-mil geomembrane liner prior to capping.
3. The final soil cap must consist of at least 2 feet of soil material, with the top 6 inches consisting of sufficient organic material to support vegetation.
4. The polluted soil disposal site must be completely fenced, separate from the public landfill area. The gate must be kept locked.
5. The Native Council of Port Heiden must submit a report at the completion of the disposal project, but no later than February 15, 2010, including: as-built drawings of the cell; quantity of disposed soil; soil sampling results for all soil disposed at the landfill; photographs of the disposal cell while in operation & after it is completed; & the appropriate notation to the deed of the property.
6. The Native Council of Port Heiden must perform annual inspections of the cell & repair any areas that show signs of erosion or are failing to revegetate.
Although this letter authorizes the disposal of certain polluted soils at the Port Heiden Landfill, this letter does not obligate the Port Heiden landfill to accept those soils. The Port Heiden Landfill must employ engineering controls to ensure that polluted soils disposed in the landfill will not contaminate ground water or adjacent surface water.
This authorization is specific to soil from the Port Heiden RRS intended for disposal at the Port Heiden Landfill & does not represent a general ADEC policy. Similarly, the conditions described in this authorization are site-specific conditions applicable only to this project. |
Louis Howard |
| 5/29/2009 |
Update or Other Action |
Letter sent by ADEC (Solid Waste Program) To Lynn Carlson (Native Council of Port Heiden) RE: Solid Waste Permit No. SW3A069-14. The ADEC has completed its evaluation of your permit application for the Class III municipal solid waste disposal facility at Port Heiden, Alaska. Please review the conditions & stipulations in the permit & ensure that they are understood. This permit is being issued in accordance with Alaska Statute (AS) 46.03; Title 18, Chapter 15 of the Alaska Administrative Code (18 AAC 15); & the Solid Waste Regulations (18 AAC 60).Date Issued: May 29, 2009 Date Expires: May 29, 2014.
ADEC, under authority of AS 46.03 & 18 AAC 60, issues a solid waste disposal permit to: The Native Village of Port Heiden 2200 James Street, Port Heiden, Alaska 99549, & designated representatives for the management & operation of a Class III municipal solid waste disposal facility. It authorizes the operation of a burn box & disposal cells for the disposal of an annual average of less than 5 tons per day of domestic & commercial refuse at the community 28-acre site. Household hazardous waste & used oil will be collected & stored on site for re-use or recycling.
The landfill is located at Port Heiden, Alaska, approximately 2.5 miles south of the community, within Section 31, Township 37 South, Range 58 West, Seward Meridian.
Specific Conditions
1. Perform visual monitoring & random waste load inspections at least once monthly & record the results on the Visual Monitoring form. The completed monthly Visual Monitoring form will be kept with the landfill operating record.
2. All open burning on the ground is prohibited. Any reduction of materials through the use of burning must be done with proper use of a burn box, burn cage, burn barrel or incinerator.
3. Prior to lighting the burn box, the landfill operator will remove large plastic or rubber items that would cause black smoke when burned.
4. The gate at the entrance to the landfill must be locked outside the normal hours of operation. A sign at the gate will be posted with the hours of operation, an emergency contact phone number & the list of prohibited items on page 2 of the Operations Plan.
5. Maintain fencing to help control windblown waste. Keep the landfill facility free of litter by conducting periodic site cleaning.
6. Polluted Soil may NOT be disposed at the landfill without specific written permission from ADEC.
This permit expires on May 29, 2014 & may be revoked or amended in accordance with 18 AAC 60.260. The permit can be renewed if the facility will operate beyond this date. To avoid expiration of this permit, a renewal application must be submitted to ADEC at least 30 days before the expiration date, as set forth in 18 AAC 15.110. |
Louis Howard |
| 7/30/2009 |
Update or Other Action |
WESTON Daily Activity Report: Hauling stopped around 8:45 a.m. due to a truck accident. Truck was recovered frorn the tundra and then deconned to clean fluids that leaked from the vehicle. Soils from the truck accidernt were shoveled into a super sack. Serviced (1) dumptruck; This was the dumptruck that rolled over in the accident. |
Louis Howard |
| 8/14/2009 |
Update or Other Action |
WESTON sent ADEC (John Halverson) a request for third party sampling waiver per waiver of 18 AAC 75.355(b). Air Force Center for Engineering and the Environment Prime Contract No. FA8903-04-D-8681, Port Heiden Soil Washing Sampling Effort
Weston Solutions, Inc. (WESTON) and DMC Technologies, Inc. (DMC) have received final confirmation results from SGS Environmental for the Port Heiden PCB-soil washing effort for samples that were collected by the qualified impartial third party sampler, SLR, on Aug 5, 2009. The samples were collected from 1,500 cubic yards of soil washed by DMC. Forty samples and five duplicates were collected from the washed soil and six samples plus one duplicated from the sacrificial soil used in the stockpiles. Two blind blank samples were submitted to SGS along with the project samples.
All but one sample was below the 10 milligram per kilogram cleanup level. The one sample came from a batch (lot) of soil that was approximately 200 cubic yards. Based on the exceeding sample result, this soil will be rewashed and subdivided into four batches (lots) of soil of approximately 50 cubic yards each. A sample will be collected from each of the 50-yard lots (4 samples total). Each sample will be a composite of nine randomly located sample aliquots from that individual lot. A duplicate should not be required because the frequency already collected for washed soil exceeds ten percent.
The 611th Civil Engineer Squadron, Environmental Restoration Section request a waiver to ADEC18 AAC75.355(b) "Impartial Third Party Requirement" for collection of four confirmation samples from the re-washed soils. The U.S. Air Force (USAF) Title II representative, Jacobs Engineering will be onsite to oversee sampling efforts. Jacobs Engineering is contracted by the USAF under a separate contract to provide oversight of site actions by WESTON and. Attached are the resumes for the Jacobs Engineering qualified persons who are or will be onsite at Port Heiden and can supervise the confirmation sampling activities. This request is made to facilitate the sampling using personnel that are already on site in Port Heiden, thus reducing costs and accelerating sample collection, analysis, and interpretation of results.
All final confirmation data will be independently validated, ADEC checklists completed, and a QAR prepared by SLR. After such review is complete, a request will be submitted to by WESTON, on behalf of the Air Force, requesting that the soil can be transported to the Port Heiden landfill. |
John Halverson |
| 8/14/2009 |
Update or Other Action |
John Halverson sends email message (8/14/2009 4:44 P.M.) to WESTON: The waiver request is approved for the specific sampling that is described in your Aug 14 request (SUBJECT: Air Force Center for Engineering and the Environment Prime Contract No. FA8903-04-D-8681, Port Heiden Soil Washing Sampling Effort). |
John Halverson |
| 8/18/2009 |
Offsite Soil or Groundwater Disposal Approved |
Staff sent WESTON (H. Graham) and email regarding the Request for Disposal of Washed Soils at Port Heiden Landfill-Approved Lots 1-9, and 11-17.
1) Based on the data and information provided in the August 18, 2009 email with attachments sent to ADEC, it appears Lot 10 (200 cubic yards of contaminated *soil) is still above 10 mg/kg total PCBs (see client sample L10-C/SGS Ref# 1093890028 27.4 mg/kg total PCBs) and is NOT approved for transport or disposal at the Port Heiden Landfill (Solid Waste Permit No. SW3A069-14) until further treatment and laboratory analysis demonstrates otherwise.
*18 AAC 75.990 (117) “soil” means an unconsolidated geologic material, including clay, loam, loess, silt, sand, gravel, tills, or a combination of these materials.
FYI: EPA has a different definition of “soil”: § 761.123 Definitions Soil means all vegetation, soils and other ground media, including but not limited to, sand, grass, gravel, and oyster shells. It does not include concrete and asphalt.
2) However, in accordance with: 18 AAC 75.325. Site cleanup rules: purpose, applicability, and general provisions (i) A responsible person shall obtain approval before disposing of soil or groundwater from a site
(1) that is subject to the site cleanup rules; or
(2) for which the responsible person has received a written determination from the department under 18 AAC 75.380(d)(1); and more specifically,
18 AAC 75.370. Soil storage and disposal (b) A responsible person shall obtain approval before moving or disposing of soil subject to the site cleanup rules. (Eff. 1/22/99, Register 149; am 8/27/2000, Register 155; am 10/9/2008,Register 188)
The specific request for **transport and disposal of Lots 1 through 9, Lots 11 through 17 (approximately 1,300 cubic yards of washed soil) at the permitted Port Heiden Solid Waste Landfill IS approved by ADEC, based on the data and information provided by WESTON which demonstrates the 10 mg/kg total PCBs cleanup level has been met. All other requests for transport for other soil** associated with other "Lots" or associated with this project must be made on a case by case basis for ADEC review and approval.
**The transport of the soil must comply with 18 AAC 75.360. Cleanup operation requirements.(4)(D) provisions for transporting contaminated soil as a covered load in compliance with 18 AAC 60.015.
18 AAC 60.015. Transport. (a) A person who transports solid waste shall keep the waste contained during transport.
(b) A person who spills solid waste during transport shall promptly pick up the waste and any waste residue resulting from the spill. (Eff. 1/28/96, Register 137)
3) Please provide all documentation for our files associated with transport and disposal of the soil at the permitted Port Heiden Landfill for this specific request (i.e. manifests signed by the generator of the soil and the certificates of disposal detailing the quantity of soil received and signed by the owner/operator of the landfill which provides ***certification that the disposal activity took place).
***Certification means a written statement regarding a specific fact or representation that contains the following language:
Under civil and criminal penalties of law for the making or submission of false or fraudulent statements or representations (18 U.S.C. 1001 and 15 U.S.C. 2615), I certify that the information contained in or accompanying this document is true, accurate, and complete. As to the identified section(s) of this document for which I cannot personally verify truth and accuracy, I certify as the company official having supervisory responsibility for the persons who, acting under my direct instructions, made the verification that this information is true, accurate, and complete.
ADEC review and approval of this specific request for transport and disposal of soil 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 approval on the specific request for transport and disposal does not relieve responsible persons (or agents, contractors, subcontractors acting on their behalf) from the need to comply with other applicable laws and regulations. |
Louis Howard |
| 8/18/2009 |
Update or Other Action |
Iliaska (Teresa O'carrol) sent to WESTON who sent it to ADEC a request for disposal of washed soils at Port Heiden.
All of the PCB-contaminated soil that was delivered to DMC at Port Heiden (approximately 1500 cubic yards) has been washed as described in the Remedial Work Plan and approved ADEC Modifications. Such soil was placed in 16 lots and field tested. Three of the 16 lots were rewashed as described in the Remedial Work Plan and approved ADEC Modifications.
Following initial washing of all soil and rewashing of three lots, all soil was sampled for laboratory confirmation on August 5, 2009. The confirmation samples were collected by SLR International Corp (SLR) for DMC Technologies (DMC), and were submitted to SGS North America Inc., Alaska Division
(SGS).
Soil in a single lot (Lot 10) requires a tertiary wash to achieve the desired clean-up level. Lot 10 contained approximately 200 cubic yards of soil. It was divided into four zones (A, B, C, and D) for confirmation testing. Each zone in Lot 10 represented approximately 50 cubic yards of soil. Only soils in Zone C representing 25% of the Lot soil volume were found to contain concentrations of PCB at > 10 milligram per kilogram (mg/Kg).
All soils associated with Lot 10 have been segregated, rewashed, and will be resampled on or about August 20, 2009 under the supervision of Jacobs Engineering personnel, who are approved to act as the independent third party sampler. This soil will remain in a lined and bermed mini-stockpile until analytical results indicate the soils have attained cleanup levels, and a separate approval is received from ADEC to transport and dispose of Lot 10 soils.
Sample results for all other washed and sampled soils were below the 10 mg/Kg project cleanup criteria. These soils are associated with Lots 1 through 9 and 11 through 17. These samples represent approximately 1300 cubic yards of washed soil. Additionally, laboratory samples were collected from sacrificial soils that were placed on top of liner systems to protect them from heavy equipment puncture and tears. Sacrificial soils were tested from the un-treated and treated stockpile areas. Six representative samples and one duplicate were collected from sacrificial soils. These soils are represented by samples labeled SAC-1 through SAC-3. All sample results for sacrificial soils were below 10 mg/Kg.
Following confirmation sampling, mini-stockpiles other than Lot 10, were stacked to facilitate aeration and dewatering. Aeration and dewatering are required so that washed soils would pass the paint filter test prior to landfill disposal. Stacking changed the mini-stockpile from a flat and layered cell to a mixed standing stockpile. Mini-berm containments of sacrificial soil are mixed into washed soil as part of the stacking process. These soils will be transported to the permitted landfill and disposed of along with the washed soil that meets the < 10 mg/Kg cleanup level upon receipt of approval by ADEC.
Finally, two samples were collected from approximately 3 cubic yards of oversized material that had been mechanically screened from the contaminated soil prior to washing. This material was called debris and consists of oversize gravel, rocks, and concrete pieces that had been excavated with the soil. This debris was collected and washed separately because it would not pass through the screen. This material is segregated in the treated soil area. The two samples were submitted to the laboratory at oversized material. The laboratory informed DMC that the samples could not be run as is due to the size. These samples were then withdrawn from the Work Order. This material will be resampled and crushed in the field and then re-submitted to the laboratory on or about August 20, 2009. This material will remain segregated and in the washed stockpile area until approval is obtained from ADEC to transport and dispose of it.
DMC requests authorization to dispose of the 1300 cubic yards of washed soils and associated sacrificial soils in the permitted Port Heiden Solid Waste Landfill based on laboratory results and the field paint filter tests. The attached files include the Laboratory Report for Work Order 1093890, ADEC Laboratory Data Review Checklist, and the Laboratory Data Quality Assurance Summary. The ADEC checklist and Quality Assurance Summary were prepared by SLR who performed an independent review and validation of the data.
|
Louis Howard |
| 8/19/2009 |
Update or Other Action |
WESTON Daily Activities Report: "Pat Roth said he saw what appeared to be 'fresh soil' on the haul road. Pat Roth noticed soils were being sprinkled from 2 haul trucks. A-I & A-2 (locally rented trucks). Weston and client followed the two trucks to note if further soil was coming out of tailgate area. Minimal amounts were noticed falling out at two places. per Pat Roth,
Mickey Lopez, Kate Daniel (title II). These trucks were taken out of the haul and parked until a solutions to the 1/2" gap at the tailgate is found. Weston walked the New Hud housing roadway with Title II to identify any 'suspect' dribbles of soil. Apx. 43 spots less than 1 tsp. found and removed by sutface sweeping and shovel. Less than 3 oz of suspect soil was found on the road surface.
TK spoke with Weston Anch. office. DEC was notified by client Field will retrofit the tailgates to avoid any loss of matelials. TK noted to Pat Roth, that this is likely due to the changed conditions. First day loading with a loader (new method) and first day hauling treated soils, which are a very different consistency than prior excavated soils. The DMC treated soil is more clay-like-much more moisture content. Weston also noted that we follow these trucks as well as Title II rep, this is the first time we have ever noticed loss of soils from truck beds." |
Louis Howard |
| 8/21/2009 |
Update or Other Action |
Staff sent email with photos taken by Air Force Project Manager while observing site work at Port Heiden to WESTON regarding Disposal of Washed Soils at Port Heiden cross contamination issues.
Housekeeping issues need to be addressed to prevent cross-contamination of “clean” areas with “dirty” areas.
Observations noted by AF project manager. Please advise on how this will be addressed ASAP.
Wet vs Dry decontamination procedures
The work plan states dry decontamination methods will be used until it is ineffective and then wet decontamination methods will be implemented. I asked the Weston site supervisor with the rain and muck at the site, how Weston determines when to switch to a wet decontamination method. She replied they are only using dry decontamination methods unless they are switching out the use of a truck/piece of equipment. If the truck was hauling PCB soil and then was going to haul clean soil a wet decontamination method was used. While in theory the trucks should not be driving across contaminated soil, there are concerns of cross contaminating sites.
Potential cross contaminate is a issue
In the photo below left, the two are sweeping contaminated soil off the mud mat – spilled from loading the truck. Instead of sweeping all the soil back into the soil cell, the half of the area away from the cell was swept off into a clean area.
The photo below right shows the workers as they walk about with their booties on – potentially spreading contamination.
In the below photo, personnel walk about the site, from excavation to excavation across the ‘clean’ road. It appears (not confirmed) that contamination is being spread via booties. Some site workers/communities members told me their concerns of equipment also cross contaminating the site. This has not been verified but is a concern.
The concern of these three walking on site is they go from walking on soil that may have been contaminated to climbing into the dump truck and loader.
Even if all the above are fine, the Weston site manager did admit that the samplers do walk into the contaminated zone and back out across the clean areas to the contamination reduction zone. I have heard from Kate Daniels that personnel coming through the decontamination reduction zone do not step over the clean line as they take off their booties. This creates the potential for contamination to be carried out of the exclusion zone on the individual’s personal boots. |
Louis Howard |
| 8/22/2009 |
Update or Other Action |
WESTON Daily Activity Report: "Weston/Aniakchak: Remedy for haul road from site to landfill based on soils spilled from 2 haul trocks on 19-Aug, and DEC required cleanup. 1) take discrete samples every 1/2 mile-starting from site 2) float/scrape top surface aprx. 1/2" and remove material and haul to landfill. 3) if samples show levels greater than (1ppm) of PCB then Weston may add materials to surface at the end of any site activity, may take further samples if Air Force concurs. Meanwhile haul may commence once 1 & 2 are complete.
Aniakchak will take samples as per (1), under their own accord without any guidance from Weston. Kate Daniel (Title II) will only observe the samplingl/floating of the road-not to direct any activity. NOTE: Weston site manager identified suspect material as being the loose surface materials no greater than 1/2" deep.
To meet DEC requirement to remove suspect rristerial, Weston pulled this loose material from the road surface ranging from 1/2" to 1" depth in some areas. Hard packed surfaces were not removed as the field supervisor did not identify these as suspect material. These surfaces are so packed, much like concrete that the light sprinklings of soil that was observed falling from the tailgates on 19-Aug-09 could not have adhered to these surfaces. Grading and scraping up of loose materials with a loader was the process for removing the loose suspect materials from the site to the landfill. The loader placed material in two dump trucks (14 cyd trocks) for a total of 11 full loads apx. 110 cyds."
INSPECTION DATA: "12 discrete samples (11 + 1 dupe) taken at 1/2 mile intervals, beginning at site and ending at Class III Landfill. Rapid assay of MHR (Main Haul Road). Results show non detect for all samples. NOTE: Aniakchak took similar samples at the same time."
DMC: DMC: No daily as of 25-Aug-09 asked several days in a row, both Steve and Dan. TK & Title II observed DMC (StevelDan) take samples from "re-treated" LOT 10, 4 batches A-D one dupe-at C. Dan noted he would send a very wet sample to the lab and also dry out one sample overnight. DMC will not run rapid assay. |
Louis Howard |
| 8/24/2009 |
Update or Other Action |
Daily Activity Report (WESTON): Stopped hauling from DMC because water was saturating soils. Took a paint filter test as per workplan, 5-minutes each. No free fluids made it through. Weston commenced hauling of DMC soils. TK spoke with Anchorage office and noted that there is standing water on the DMC soils, especially those on the ground. The material is sloppy and flowing, some free water is accumulating in LF-Cell #2. Anchorage office advised field that the only concern is that it pass the paint filter test, also that no liquids or soifs release on haul roads.
DMC/Weston will haul as long as paint filter test passes. If this becomes a concern, then DMC may have to mix dryer material with treated in order to haul. Weston's priority is to get all of DMC soils placed at the LF, before exceeding its current capacity.
NOTE TO FILE: DQO Soil Washing-Field test washed soils using Method 9095B, Paint Filter Liquids Test, COC-Free Liquids, Data use-Determine if free liquids, alcohol and water, remain in soils after drying period of 7 days, Action Level-Free liquids present – soils require additional drying prior to confirmation sampling and disposal. One sample from each 50 cubic yard mini-stockpile of treated soil. Field duplicates are collected at a frequency of 10%.
Place sample in the filter. A funnel may be used to provide support for the paint
filter. If the sample is of such light bulk density that it overflows the filter, then the sides of the filter can be extended upward by taping filter paper to the inside of the filter and above the mesh. Settling the sample into the paint filter may be facilitated by lightly tapping the side of the filter as it is being filled.
Allow sample to drain for 5 min into the graduated cylinder. If any portion of the test material collects in the graduated cylinder in the 5-min period, then the material is deemed to contain free liquids for purposes of 40 CFR 264.314 and 265.314.
PROBLEMS/RESOLUTIONS: Weston stopped hauling DMC soils because they were too wet and seeping out of 2 of the haul trucks. Moved operations over to Area 10 until a paint filter test was observed by Weston/Title II, 1002 until1315 3 hrs 15 minutes off of DMC haul
Started with 5 trucks, but issues with water dripping out of 2 local trucks. Stopped these two and worked with only 3 trucks until a mod to trucks can achieve no leaking. Truck 18~138 had issue with tailgate latch when leaving site with a load of DMC material. Some soils were observed sprinkling out of back end.
Title II stopped truck (occurred between Main entrance to site and the crew parking area). Weston/Aniakchak immediately stopped truck, returned it to DMC to dump load until a repair to latch. Weston/Aniakchak scraped up surface of road with loader. All was observed by Title II, who noted to Weston Site~M that Weston responded appropriately. Minimal impact, all soils cleaned up.
Decon workers have been stuffing sorbent rolls in tailgates of two yellow local trucks. This worked until there was too much moisture then they would fall out during haul. Weston and Title If followed behind trucks to ensure no loss of materials. Several times trucks had to be stopped. 1 truck after 1 1oad of extreme wet DMC material. |
Louis Howard |
| 8/27/2009 |
Meeting or Teleconference Held |
Meeting Summary Attendees: Glen Verplancke, AFCEE, COR Hudson Graham, WESTON, Pat Roth, 611th CES Mark Goodwin, WESTON, Louis Howard, ADEC Earl Crapps, ADEC, Jacques Gusmano, EPA and Kris Hadden, WESTON.
Subj: Port Heiden RRS Project Completion/Closeout Meeting.
On Thursday August 27, 2009, the personnel listed above met in person and via
teleconference to discuss Port Heiden Project Completion/Closeout Issues. The topics
discussed are addressed in the bullets below:
Discussed PCB Delineation / Excavation / Treatment;
- Excavated / Hauled / Treated and/or Landfilled 9120 cy PCB contaminated soil.
- Cubic yardage measurements per truckload counts, loose yardage.
- Per differing site conditions, delineated significant “new” PCB contamination, resulting in delineation level of effort of approximately 35% beyond original scope. EPA stated that RI was excellent; though EPA was not surprised additional contamination has been discovered.
- All excavation boundaries and boundaries of additional contamination defined by GPS.
- No Pesticides were found in any 2009 analytical samples.
- All contamination left behind needs to be documented; AF should write a ROD amendment.
- There is a sign at the entrance to the site stating that there is contamination present on the site.
Discussed POL Excavation / Remedy-in-Place;
- Excavated / Hauled / Stockpiled approximately 5,720 cy POL contaminated soil.
- Per differing site conditions, delineated significant “new” POL contamination.
- Absolute extent unknown as delineation defined during excavation.
- All excavations defined by GPS.
Discussed pending work to Landfill and POL Stockpiles;
- To be completed per the approved WP.
- ADEC stated that POL stockpiles are not bio-piles. Some options per ADEC were to leave as a stockpile for up to 2 years, or to treat now before leaving the site.
-ADEC said that regulations were changing and no additional permits would be granted to dispose of >1ppm PCB soils in Alaska. The Port Heiden Landfill is not yet permitted for the expansion, but should consider applying for the permit immediately.
Discussed disposition of Exposed PCB Hot Spots;
- AF, ADEC, and EPA concurred that covering these areas with two feet of clean fill is acceptable.
Discussed disposition of Weston Roads and Points of Ingress / Egress (cross-contamination
question)
- AF, ADEC, and EPA concurred that scraping 1” to 3” to remove cross-contamination concern on roads and in decon areas (except areas of known subsurface PCB contamination where additional cover was applied), sample soil, and landfill, is acceptable.
- AF concurs that one road will be broken up, between POL stockpiles and pipeline area.
Discussed Disposition of seeding
- AF to provide guidance to Weston of areas to be seeded.
Additional Work Pending
- Excavation of Underground Pipes expected to be completed by 01SEP09 |
Louis Howard |
| 8/27/2009 |
Offsite Soil or Groundwater Disposal Approved |
ADEC sends email to WESTON (G. Hudson) re: ADEC Approval granted for Request for Disposal of Washed Soils at Port Heiden Landfill
1) In accordance with: 18 AAC 75.325. Site cleanup rules: purpose, applicability, and general provisions (i) A responsible person shall obtain approval before disposing of soil or groundwater from a site
(1) that is subject to the site cleanup rules; or
(2) for which the responsible person has received a written determination from the department under 18 AAC 75.380(d)(1); and more specifically,
18 AAC 75.370. Soil storage and disposal (b) A responsible person shall obtain approval before moving or disposing of soil subject to the site cleanup rules. (Eff. 1/22/99, Register 149; am 8/27/2000, Register 155; am 10/9/2008,Register 188)
the specific request for *transport and disposal of Lot 10 (approximately 200 cubic yards of washed soil) at the permitted Port Heiden Solid Waste Landfill IS APPROVED by ADEC, based on the data and information provided by WESTON (refer to email dated 8/27/2009 below) which demonstrates the 10 mg/kg total PCBs cleanup level has been met.
*The transport of the soil must comply with 18 AAC 75.360. Cleanup operation requirements.(4)(D) provisions for transporting contaminated soil as a covered load in compliance with 18 AAC 60.015.
18 AAC 60.015. Transport. (a) A person who transports solid waste shall keep the waste contained during transport. (b) A person who spills solid waste during transport shall promptly pick up the waste and any waste residue resulting from the spill. (Eff. 1/28/96, Register 137)
2) Please provide all written documentation for ADEC files associated with transport and disposal of the soil at the permitted Port Heiden Landfill for this specific request (i.e. manifests signed by the generator of the soil and the certificates of disposal detailing the quantity of soil received and signed by the owner/operator of the landfill which provides **certification that the disposal activity took place).
**Certification means a written statement regarding a specific fact or representation that contains the following language:
“Under civil and criminal penalties of law for the making or submission of false or fraudulent statements or representations (18 U.S.C. 1001 and 15 U.S.C. 2615), I certify that the information contained in or accompanying this document is true, accurate, and complete. As to the identified section(s) of this document for which I cannot personally verify truth and accuracy, I certify as the company official having supervisory responsibility for the persons who, acting under my direct instructions, made the verification that this information is true, accurate, and complete.”
ADEC review and approval of this specific request for transport and disposal of soil (Lot 10) 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 approval on the specific request for transport and disposal does not relieve responsible persons (or agents, contractors, subcontractors acting on their behalf) from the need to comply with other applicable laws and regulations. |
Louis Howard |
| 9/1/2009 |
Update or Other Action |
Air Force (P. Roth) sent email to WESTON regarding Housekeeping issues observed in the September 1, 2009 daily report:
Port Heiden Daily Report 9-1-09
Importance: High
Hudson,
Here is Kate's (Kate Daniel JACOBS Engineering) report for yesterday. Several issues raise my concerns. In no particular order, with quotes from Kate's report:
1) Concerns of not all impacted soil being removed prior to backfilling:
"additional impacted soils were confirmed visually and remained in the excavation when the operator was given direction to backfill. The equipment manager stated that enough material had been removed."
2) Scope not being completed: "The location was not excavated or confirmed visually. The site manager stated that the excavation has the potential to impact PCB-contaminated soils and therefore he will not proceed with any further excavation." From our conversation this morning, it sounded as if the septic tank was in a confirmed PCB area. Is this really the case?
3) Deviations from the workplan: "most of the backfill has already been placed, the samples were collected from what remains in the borrow pit not what will be used for backfill"
4) On-going decon and cross contamination issues: "Clorox wipes were used to decontaminate the cabs of the trucks, however the seats were not decontaminated." and "Forks from the front end loader that were used to push contaminated mud mats yesterday were not decontaminated and were removed from the exclusion zone then used to move a connex and materials.
When site management was notified, no action was taken." and "Equipment manager was notified that the forks on the front-end loader were contaminated. The forks were then used to move super sacks and personnel were observed touching the forks with bare hands." and "Personnel walked through the designated contaminated PPE pathway in booties, then climbed into the decontaminated dump truck cab without removing contaminated PPE." and ... it keeps going on in the daily report.
|
Louis Howard |
| 3/10/2010 |
Meeting or Teleconference Held |
Skip Koch already briefed AFCEE, ADEC, and the EPA on this matter. Pat Roth from 611th is on vacation this week. This is the email with drawings that we promised during the phone call.
In late August we had spilled a small amount of soils that had been washed by DMC and contained less than 10 mg/kg of PCBs. These soils were spilled while being transported from the soil washing area to the landfill. As part of the cleanup after this spill we:
-Took samples every 0.5 miles along the haul road from the soil washing area to the landfill;
-Floated this road with a grader; and
-Then took additional screening and analytical samples from approximately the same locations (e.g. every 0.5 miles).
Three of the analytical results had PCB concentrations above 1 mg/kg. Attached are two figures showing the location of the analytical results that came back above 1 mg/kg in the main haul road. The three locations at which these excedences occurred are MHR-GS-01, MHR-GS-03, and MHR-GS-004. The figures show two samples taken at each location. The first sample taken was prior to floating the road, these samples are denoted with a MHR-SS-0XX, while the samples taken after floating are MHR-GS-0XX.
MHR SG-01 is located next to the DMC soil washing facility and is next to the area where preconstruction background composite of 9 discrete samples had a PCB concentration greater than 1 mg/kg. MHR-GS-03 is within 40 feet of the samples taken after the truck rollover accident. The results at MHR-GS-03 at 19 mg/kg are higher than but comparable to the highest 12 mg/kg found in the roadway after the rollover. The third result of 5.7 mg/kg after the road was floated at MHR-GS-04 are in an area that had not been sampled previously.
The final analytical results for these locations were not available until after we demobilized from the site. WESTON will, at the earliest possible time allowed by site conditions is; place 6” of clean gravel over each spot covering 30’ on both sides of the GPS location of the sample points. This will take into account the accuracy of the portable GPS units available on site.
This is the same method used to cover the PCB contamination discovered in the roadway during the investigation of the vehicle rollover accident. The area with sample ID’s of VRO was addressed during the activities that took place during the field season and are currently covered with 6” of clean gravel.
(There are multiple results at VRO-BG-001, VRO-RE-002, VRO-BG-003 because duplicate samples were taken at these locations per sample requirements.) |
Louis Howard |
| 6/3/2010 |
Document, Report, or Work plan Review - other |
Staff reviewed and commentd on the Draft Confirmatory Sampling Work Plan Port Heiden Radio Relay Station May 2010. Worksheet #17: Sampling Design and Rationale
17.1 Former Facilities Area – Soil Washing Area
Procedures for sample size and collection Page 50 of 121
ADEC requests the Air Force rewrite this section by deleting the following from the section:
The guidance on numbers of samples for petroleum products will be used as a guide for the recommended number of soil samples for this project. (1st paragraph)
For sites larger than 250 square feet, the ADEC guidance specifies two samples plus one sample for each additional 250 square feet. The soil wash area and drainage swale cover approximately 40,000 square feet. This suggests laboratory samples should be collected from approximately 163 locations, not including quality control samples. (Complete 2nd paragraph)
Because the ADEC guidance does not recommend any particular sort of sampling grid,… (3rd paragraph)
New sentence for 3rd paragraph to start off with: “The grid system outlined in 40 CFR 761.283 will be used.”
Add text to the first sentence of the last paragraph as follows:
“By using the grid and compositing method from TSCA, the total number of samples collected at the soil wash site and drainage swale will be slightly more than the 163 recommended by the ADEC guidance for sampling soils contaminated with petroleum products.”
Procedures for Sample size and collection procedure:
ADEC requests the Air Force to delete the following: Because the ADEC guidance does not specify a quantity of soil to be collected...”
New 1st sentence to read: “This plan follows the specifics of TSCA.”
Worksheet #33: Quality Assurance Management Reports Table Page 99 of 121
The table shows the Laboratory Data Review Checklist/Quality Assurance Summary and the Informal Technical Information Report will be delivered:
Once, after each sample delivery group is generated on the projected delivery date of 180 days after field work is completed.”
ADEC requests the Air Force shorten the frequency on these two reports to a shorter frequency (e.g. 60 days after field work is completed). The 2005 AFCEE QAPP states in 12.0 Quality Assurance Reports to Management Page 12-1: “At a minimum, the QA coordinator of the laboratory shall prepare a quarterly [e.g. 90 days] summary report of the status of the project, of QA/QC problems, corrective actions taken, and unresolved RCAs with recommended solutions for management. The report shall also include results from all PE samples, audit findings, and periodic data quality assessments.”
CERCLA Federal Facility Agreement standard language in the Sampling and Data/Document Availability section states: “The Parties shall make available to each other quality-assured results of sampling, tests, or other data generated by or on behalf of any Party under this Agreement within sixty (60) days of collection or field testing. If quality assurance is not completed within sixty (60) days, preliminary data or results shall be made available within the sixty (60) day period and quality assured data or results shall be submitted as they become available but in no event later than one hundred (100) days after the testing or the submittal of the date to the laboratory.”
|
Louis Howard |
| 6/22/2010 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft Remediation Work Plan Port Heiden Radio Relay Station June 2010.
1.0 Introduction Page 4
The text states: “Boretide has been retained by the PHNC to provide guidance and empower the local community to perform as much of the project work as possible. At the end of the three year period, it is anticipated the PHNC will have several members who become proficient with relevant regulations, sampling techniques, surveying, remediation, reporting, and project controls.”
ADEC has regulatory requirements in 18 AAC 75 which regarding a “qualified person ”.
Specifically:
18 AAC 75.335 Site Characterization
(b) A responsible person shall submit a site characterization workplan to the department for approval before beginning site characterization work. The department will approve the site characterization workplan if the workplan is
(1) prepared by a qualified person
The Air Force will identify who the “qualified person” that has prepared this work plan which will be used to guide remediation activities that will be conducted at the Former Port Heiden Radio Relay Station (RRS) during the next three years and provide written documentation that the person is “qualified” as described in 18 AAC 75.990(100).
The text states: “Upon concluding project activities at the end of summer, a Report of Findings (ROF) will be developed for each of the upcoming three years. These annual ROFs will present results and provide a summary of field activities performed during the prior work season; each will serve as an updated project summary. ROFs will present recommendations and inform upcoming remedial decisions as required.”
18 AAC 75.335 (c) states: After completing site characterization work, the responsible person shall submit to the department for approval a site characterization report that
(1) is prepared by a qualified person
The Air Force shall ensure that the site characterization report or as referred to in the work plan, a Report of Findings, is prepared by a “qualified person” as defined by 18 AAC 75.990(100).
3.6.1 Barge/Disposal Contractor Page 14
The text states: “Thereafter, contractor will transport the roughly 900 super sacks to a certified Class III Landfill for disposal.”
ADEC requests the Air Force identify the certified Class III Landfill that the PCB soil will be transported to for disposal. If permit conditions allow, soil with PCB concentrations between 1 and 10 mg/kg may go to a landfill permitted (under Solid Waste regulations 18 AAC 60) by ADEC with prior Contaminated Sites Program and Solid Waste Program approval. Soil with PCB concentrations greater than 10 mg/kg will have to be sent to an approved out of state facility.
Disposal of soils with PCB concentrations greater than 25 mg/kg requires compliance with TSCA regulations, TSCA approval and a TSCA permitted disposal/treatment facility. Off-site disposal of PCB contaminated soil will need to comply with the “Off-Site Rule” which defines criteria for approving facilities for receiving waste from response actions taken under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA).
4.1 Job Sequence Page 16
The text states: “Excavate and dispose of a septic tank and approximately 100' of connecting pipe. This apparatus is located in the Black Lagoon/Septic System Outfall (BLO/SSO). Upon removal, contents contained in the tank and/or pipe will be characterized and disposed accordingly”
ADEC requests the Air Force clarify how the septic tank contents will be characterized prior to shipment/disposal. The septic tank and lines may need to be washed prior to cutting/disposal. ADEC requests further clarification on the washing process and to include it in the IDW plan.
4.3 Excavation of PCB Soils Page 19
The text states: “The PHNC will excavate approximately 4,500 CY of PCB contaminated soil from the Former RRS, super sack the material, and transport it to the Staging Area near the beach.”
ADEC requests the Air Force to provide further detail on what the PCB concentrations that will be excavated. For example, all soil with concentrations between 1 and 10 mg/kg? Or are there soil concentrations in some areas being excavated greater than 25 or 50 mg/kg which would invoke TSCA regulations.
4.4 PCB Confirmation Sampling Page 26
The text states: “One dedicated steel sampling spoon will be used to scoop soil from each of the nine locations. These nine scoops will then be deposited in an 8-ounce sample container.”
ADEC requests the Air Force describe the approximate size/mass of the “scoop” to be composited and whether nine “scoops” will fit in an 8 oz jar and be adequately “mixed” prior to shipment to the laboratory.
The ADEC Draft Field Sampling Guidance (May 2010) specifies sidewall sampling based on linear feet, not area/square feet. ADEC requests the Air Force ensure that sidewall sampling based on linear feet. |
Louis Howard |
| 6/24/2010 |
Enforcement Agreement or Order |
ADEC signed the Explanation of Significant Differences for Port Heiden Radio Relay Station. By signing the document, ADEC accepts the Explanation of Significant Differences for Port Heiden Radio Relay Station. This decision may be reviewed and revised in the future if new information indicates the site may pose an unacceptable risk to human health, safety, or welfare, or to the environment.
The ESD documents refinements to the original remedy at the Port Heiden Radio Relay Station (RRS) Site. The Record of Decision (ROD), signed by the US Air Force (USAF) 19 March 2009 and by the Alaska Department of Environmental Conservation (ADEC) 27 March 2009, presents the selected remedial actions for the Port Heiden RRS Site. This ESD updates the ROD as there are two significant differences. One difference is the quantity of soil contaminated with polychlorinated biphenyls (PCBs). The other difference is in how the USAF intends to remediate the PCB-contaminated soil (greater than 1 parts per million (ppm) aka 1 mg/kg total PCBs).
Since the ROD was signed in March 2009, data collected during the 2009 remedial action gave new information to the agencies and the Native Village of Port Heiden (NVPH). Specifically,
- Significant differences in the quantity of PCB-contaminated soil were discovered.
- With the discovery of greater quantities of PCB-contaminated soil, the final disposition of the soil will be limited to barging it off-site to a permitted facility for disposal. (Shipped to a disposal facility in the Lower 48.)
The final disposition of the PCB-contaminated soil (estimated quantity was 7,000 cubic yards) was selected for disposal as noted below.
Soil which contains PCBs greater than 1 mg/kg but less than 10 mg/kg will be trucked to the offsite Class III Landfill for disposal. (The NVPH permitted Class III landfill.) Soil containing concentrations of PCBs greater than 10 mg/kg will be barged off-site to a permitted facility for disposal. (Shipped to a disposal facility in the Lower 48.) Soil washing was selected as an interim step to reduce the quantity of soil to be barged off-site by reducing the PCB concentration to less than 10 mg/kg so as to allow it to be disposed of in the NVPH permitted Class III landfill. There are two significant differences.
Based upon previous investigations, the ROD stated there were approximately 7,000 cubic yards of PCB-contaminated soil. During the 2009 remedial action, approximately 9,200 cubic yards of PCB-contaminated soil was disposed of in the NVPH permitted Class II landfill. Additional sampling during the 2009 remedial action identified approximately 4,000 additional cubic yards of PCB-contaminated soil remaining at the Port Heiden RRS.
With 2,245 cubic yards more than anticipated already in the landfill and another 4,000 cubic yards estimated, the NVPH is not willing to accept additional PCB-contaminated soil as it is using up their landfill capacity and adds to their long-term liability. The main issue driving the change in disposal location is the fact that disposing of PCB-contaminated soil (less than 10 ppm) in the community landfill is no longer an option. Furthermore, even if they were, the state is reluctant to permit additional capacity for landfilling PCB-contaminated soil. Therefore it is not feasible to construct/expand an on-site landfill.
Since the contractor cannot guarantee the soil can be washed to less than 1 ppm (PCB), then the soil must shipped off-site to a permitted disposal facility. This would apply to all soil- whether or not the contamination level is between 1 and 10 ppm; or 10 ppm and over. PCB-contaminated soil not less than 1 ppm PCB must be shipped of-site. Thus, the washing becomes an unnecessary step prior to disposal.
Soil washing could technically continue. However, it is noted the soil washing was never intended to be the final treatment. It merely allowed some soil to be disposed of in the local landfill (no longer an option) as opposed to being shipped offsite. According to Table 2-3 of the Record of Decision (ROD), the soil washing and disposal in the local landfill was only 18.2% less than the dig and haul scenario. This did not include any additional weight due to moisture content that washing the soil would cause. Including the extra weight of the moisture, the cost of barging all soil would increase. Eliminating the soil washing, will save approximately one million dollars. Funds saved from not washing the soil will cover half of the difference in the dig and haul scenario.
With the changes (excavating and shipping the PCB-contaminated soil above 1 ppm to a permitted facility for disposal in the lower 48) the remedy remains protective of human health and the environment and continues to meet Applicable or Relevant and Appropriate Requirements. |
Louis Howard |
| 6/30/2010 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft Final Remediation Work Plan Port Heiden Radio Relay Station June 2010. The comments below still have NOT been addressed in this revised draft final work plan.
3.6.1 Barge/Disposal Contractor Page 15
ADEC requests the Air Force identify the certified Class III Landfill that the PCB soil will be transported to for disposal. If permit conditions allow, soil with PCB levels between 1 & 10 mg/kg may go to a landfill permitted (under Solid Waste regulations 18 AAC 60) by ADEC with prior Contaminated Sites Program & Solid Waste Program approval. Soil with PCB levels greater than 10 mg/kg will have to be sent to an approved out of state facility.
Disposal of soils with PCB levels greater than 25 mg/kg requires compliance with TSCA regulations, TSCA approval & a TSCA permitted disposal/treatment facility. Off-site disposal of PCB contaminated soil will need to comply with the “Off-Site Rule” which defines criteria for approving facilities for receiving waste from response actions taken under the Comprehensive Environmental Response, Compensation, & Liability Act (CERCLA).
§ 300.440 Procedures for planning & implementing off-site response actions.
(a) Applicability. (1) This section applies to any remedial or removal action involving the off-site transfer of any hazardous substance, pollutant, or contaminant as defined under CERCLA sections 101 (14) & (33) (‘‘CERCLA waste’’) that is conducted by EPA, States, private parties, or other Federal agencies, that is Fund-financed &/or is taken pursuant to any CERCLA authority, including cleanups at Federal facilities under section 120 of CERCLA, & cleanups under section 311 of the Clean Water Act (except for cleanup of petroleum exempt under CERCLA). Applicability extends to those actions taken jointly under CERCLA & another authority.
(b) Acceptability criteria. (1) Facility compliance. (i) A facility will be deemed in compliance for the purpose of this rule if there are no relevant violations at or affecting the unit or units receiving CERCLA waste:
(A) For treatment to standards specified in 40 CFR part 268, subpart D, including any pre-treatment or storage units used prior to treatment;
(B) For treatment to substantially reduce its mobility, toxicity or persistence in the absence of a defined treatment standard, including any pre-treatment or storage units used prior to treatment; or
(C) For storage or ultimate disposal of CERCLA waste not treated to the previous criteria at the same facility.
(ii) Relevant violations include significant deviations from regulations, compliance order provisions, or permit conditions designed to: ensure that CERCLA waste is destined for & de-livered to authorized facilities; prevent releases of hazardous waste, hazardous constituents, or hazardous substances to the environment; ensure early detection of such releases; or compel corrective action for releases. Criminal violations which result in indictment are also relevant violations. In addition, violations of the following requirements may be considered relevant:
(A) Applicable subsections of sections 3004 & 3005 of RCRA or, where applicable, other Federal laws (such as the Toxic Substances Control Act & sub-title D of RCRA);
(B) Applicable sections of State environmental laws; &
(C) In addition, land disposal units at RCRA subtitle C facilities receiving RCRA hazardous waste from response actions authorized or funded under CERCLA must be in compliance with RCRA section 3004(o) minimum technology requirements. Exceptions may be made only if the unit has been granted a waiver from these requirements under 40 CFR 264.301.
4.1 Job Sequence Page 17
ADEC requests the Air Force clarify how the septic tank contents will be characterized prior to shipment/disposal. The septic tank & lines may need to be washed prior to cutting/disposal. ADEC requests further clarification on the washing process & to include it in the IDW plan.
4.6 Septic Tank & Pipe Removal Page 30
ADEC requests the Air Force clarify whether the septic tank/line contents will be sampled & what the sampling will entail. ADEC also requests the Air Force clarify whether or not the excavated area of the tank’s associated pipeline will be properly characterized as part of this work plan. It is not apparent for the document whether the pipeline removal will involve any field screening & confirmation sampling.
TABLE 2
Sample Containers, Preservation Techniques, Volumes, & Holding Times Page 22
HCL is used as the preservative used for Ground, Surface, Waste & Marine WATER samples (it is not used for soil samples) for VOCs, GRO, TAH & DRO/RRO. ADEC requests the Air Force to please correct Table 2 for soil samples to be analyzed by DRO/RRO using: Amber glass, TLC (Teflon lined screw caps) 14 days to extraction, 40 days to analysis of extract. |
Louis Howard |
| 7/8/2010 |
Cleanup Plan Approved |
Staff reviewed and commented on the Final Remediation Project Work Plan Port Heiden Radio Relay Station July 2010. ADEC has reviewed it and will approve it as the final work plan. .
ADEC review and approval on this work plan is to ensure 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 approval on the work plan does not relieve the Air Force from the need to comply with other applicable laws and regulations.
The Air Force is responsible for the actions of contractors, agents, or other persons who perform work to accomplish the approved work plan. For any activity that significantly deviates from the approved plan, the Air Force shall notify ADEC and obtain written approval in the form of a work plan amendment before beginning the activity. Any action taken by the Air Force, or an agent of the Air Force, that increases the project's overall scope or that negates, alters, or minimizes the intent or effectiveness of any stipulation contained in this plan will be deemed a significant deviation from the approved plan. Therefore, it is recommended ADEC be consulted immediately when a deviation from the approved plan is being considered. |
Louis Howard |
| 8/31/2010 |
Update or Other Action |
Soil washing report received. DMC performed this work as a subcontractor to Trucano Construction who was subcontracted to Weston Solutions (WESTON) working under a United States Air Force contract.
Soil washing was conducted using a proprietary chemical system developed by DMC consisting of Alcohol A (denatured alcohol), Alcohol B (ethoxylated alcohol), and a proprietary chemical facilitating washing. Processing of 1,505 CY of contaminated soil was conducted to reduce PCB, Pesticide and PAH contamination to below project clean-up levels prior to disposing of washed soils in a permitted landfill. Approximately 1,700 CY of washed soil, fabric, and liner were delivered to WESTON for landfill disposal following paint filter testing to confirm the absence of free liquid.
The soil excavated and delivered by WESTON for DMC soil washing contained PCB concentrations reported in 2009 sampling as high as 2,800 mg/kg PCB. The 1,505 CY stockpile was divided into two lots containing 1,401 CY and 104 CY with average PCB concentrations of 48 mg/kg and 158 mg/kg PCB respectively. A significant number of Rapid Assay screening samples were collected and analyzed, but were determined to be ineffective in guiding washing activities due to alcohol interference. Accordingly, no results are provided in this report. The 101 laboratory samples of successfully washed PCB contaminated soil (17 lots), contaminated debris (1 lot), and sacrificial soil (3 lots), indicated an average PCB concentration of 1.16 mg/kg ranging from 0.0103 mg/kg to 5.8 mg/kg all meeting the established clean-up level of 10 mg/kg PCB.
Pesticides discovered during the Remedial Investigation were not detected in soil placed in the contaminated stockpile and no further pesticide testing was required. PAH concentrations from the contaminated soil stockpile and first 560 CY of washed soil were all below clean-up levels.
Spent liquid solvents from the washing process were collected, sampled and filtered. Solvent was carefully controlled and reused as often as practicable to reduce solvent volumes. Five major rounds of filtration were performed. The average PCB concentration in the unfiltered solvent was 49; 7 mg/l ranging-from 4.29 mg/l to 79.2 mg/l.
Filtered solvent PCB concentrations were reduced by single filter-pass processing to an average PCB concentration of 19.6 mg/l ranging from 0.108 mg/l to 44.7 mg/l before reuse. Some solvent remaining at the end of washing process was used to wash screened debris (rocks, etc.). This volume was then filtered a final time to a PCB concentration of 0.108 mg/I before disposal by evaporation.
Footprint samples of the pre-graded and post graded PCB Washing Area (21 samples) were collected utilizing multi-incremental methodology prior to performing work. Minor adjustments to the PCB Washing Area location were made after the footprint samples of the pre-graded soil were analyzed to avoid areas whose 1 O-point composite samples had PCB concentrations of 0.982 and 1.01 mg/kg PCB. Footprint samples of the post graded PCB Washing Area (16 samples), including the bottoms of the four sumps, were then repeated, after performing work, also utilizing multi-incremental methodology. No impact to the soil under the PCB Washing Area was noted.
After removing the upper felt, the 20 milliner was carefully inspected. Only five tears in the 20 mil liner were identified in the large soil stockpile area. The lower felt liner beneath each tear was sampled and soil beneath the lower felt layer was also sampled. The PCB concentration in the lower felt beneath tears averaged 6.5 mg/kg ranging from 1.21 mg/kg to 10.3 mg/kg. The PCB concentration in the soil beneath the lower felt averaged 0.246 mg/kg PCB ranging from non-detect to 1.16 mg/kg.
A four square foot section of the lower felt beneath each tear was cut and removed for disposal with filter cartridges as TSCA waste. Two inches of soil under the lower felt was also removed and disposed as TSCA waste. The remaining lower felt below intact 20 mil liner was disposed in the landfill. Two composite samples of PPE were collected and analyzed indicating PCB concentrations ranging from 0.0065 mg/kg to 0.0248 mg/kg. The PPE was first staged in a connex at the landfill and then later disposed in the landfill. Residue in the evaporator was collected on paper towels and disposed with the filter media and lower felt cut-outs as TSCA waste. |
Louis Howard |
| 10/1/2010 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft Soil Washing Report. Main comments were as follows: ADEC requests the Air Force provide clarification on “single filter pass processing” since this is not in the final field sampling plan for reducing solvent contaminated with PCBs. The cleanup level from 18 AAC 75 Table C Groundwater Cleanup level for PCBs is 0.0005 mg/L. Filtered solvent containing 0.108 mg/L is greater than Table C & if the work plan were followed, the solvent would have been transported off-site for reuse instead of actively evaporated.
ADEC requests the Air Force delete all references to multi-incremental methodology from the document. The final work plan approved composite sampling & not multi-incremental sampling methodology. The composite sampling described in the draft report did not follow ADEC’s March 2009 draft guidance on Multi-Increment Soil Sampling.
The “disposal” as described in 12.2 & 12.3 of sump liquid & rinsates appears to be different than what was approved in the final approved field sampling plan. ADEC requests the Air Force explain this change in sump liquid & rinseate disposal methods from those methods approved in the final work plan.
ADEC requests the Air Force demonstrate that the PCB contaminated evaporator was sampled by a standard wipe test with standard wipe samples to ensure the equipment was decontaminated as described by § 761.79 (c). ADEC requests the Air Force provide clarification on if the stockpiles were sampled at the frequency above if the “mini-stockpiles” or lots were greater than 50 cubic yards in size & whether the number of samples was increased as the stockpile increased in size beyond the 50 cubic yard volume. ADEC requests the Air Force provide clarification on SGS samples since it was SLR who conducted the third part sampling or DMC conducting their own sampling as described in this section.
There have been subsequent sampling conducted in 2010 from the former soil washing area & in the landfill where the treated PCB soil was disposed. The sampling results contradict the statements made in the soil washing report. In 2010, the Air Force had another contractor sample a soil/geotextile liner soil pile left behind from soil washing activities & the fines/soil present in the sediment basins & filtration tanks improperly disposed on Alaska Dept. of Transportation property. The results from the sampling show PCB concentrations in excess of allowable limits.
ADEC cannot approve the draft 2C Soil Washing Report & will be sending a separate letter regarding the landfill permit conditions being violated with regards to PCB disposal & requests for action at the former soil washing area & ADOT property. |
Louis Howard |
| 10/8/2010 |
Spill Transferred from Prevention Preparedness and Response Program |
Spill transferred by PERP staff Mark Sielaff. Spill no. 09269924401; spill date = 9/1/09; substance = PCBs, quantity = unknown (4 tanks of PCB-contaminated soil). |
Mitzi Read |
| 10/18/2010 |
Update or Other Action |
The U.S. Air Force (USAF) 611th Civil Engineering Squadron Environmental Restoration Section (CES/CEAR), Elmendorf AFB, AK, is mobilizing the Environmental Operations Section (CES/CEOR) to the USAF Port Heiden Radio Relay Station (RRS), AK, in November of 2010.
The mobilization objectives include USAF CES/CEOR employees obtaining soil & sediment, samples at Installation Restoration Program sites as specified in the project's work plan. The intended, & requested USAF 611 CES/CEOR personnel that will be conducting the sampling are Mr. Joseph Millhouse & Mr. D. Thomas Donley. They were listed on the ADEC qualified persons website as qualified samplers, & were previously granted waivers to the Alaska Department of Environmental Conservation (ADEC) 18 AAC 75.355(b) Impartial Third Party Requirements via ADEC letters.
A summary of their qualifications as Qualified Samplers is attached. Previous waivers have been granted to personnel listed on the 611 organization chart that has been provided to ADEC. All aforementioned personnel are listed on the chart.
We cordially request an Impartial Third Party Waiver letter be issued for these personnel as the qualified samplers for the November 2010 mobilization dates.
|
John Halverson |
| 10/21/2010 |
Update or Other Action |
Email from John Halverson to Tom Donley 611 CES/CEOR. DEC approves this project specific waiver request (18 AAC 75.355(b) Impartial Third Party Requirements). |
John Halverson |
| 10/22/2010 |
Cleanup Plan Approved |
ADEC (J. Halverson) sent letter to Tom Donley (611th Air Force) RE: Port Heiden Time Critical PCB Contaminated Soil Removal Draft Work Plan.
Thank you for submitting the revised workplan referenced above, which we received via electronic mail on Thursday October 21 st. The plan describes proposed steps to remove, characterize & properly contain PCB contaminated soil that is in & around three steel tanks that had been used during PCB soil treatment at the former Air Force White Alice site in Port Heiden & are cUlTently located behind the DOT shop at the airport.
It describes confirmation & characterization sampling grid analysis for the area around the tanks & plans for properly securing the tanks (including poly tanks from the project) & PCB contaminated soil back at the former White Alice site.
The revised plan adequately addresses comments DEC provided on an earlier draft version of the plan. Therefore, DEC approves the plan as an interim removal action under 18 AAC 75.330 & in accordance with the site characterization provisions defined in 18 AAC 75.335.
Additionally, DEC approves your request for a waiver, under 18 AAC 75.355(b), of the requirement that an impartial third party conduct the collection, interpretation & reporting of sampling & analysis data for work described in the workplan. My understanding is that you &/or Mr. Joe Millhouse will serve as the qualified persons conducting this project. |
John Halverson |
| 10/29/2010 |
Enforcement Action |
Alaska Department of Environmental Conservation (ADEC) John Halverson sent the 611 CES (S. Mattson) a compliance advisory letter. ADEC appreciates the Air Force's on-going coordination & cooperation in responding to the apparent failure of the selected remedy for this site. Information gathered over the past several months documents that portions of the remedial action conducted at the Port Heiden Radio Relay Station have not been done in accordance with the February 2009 Record of Decision (ROD) for the site. The ROD specifies, among other requirements, the following:
• Soil containing more than 10 mg/kg polychlorinated biphenyls (PCBs) will be excavated, washed to reduce the concentration below 10 mg/kg, & disposed of in a local Class III permitted solid waste (SW) disposal facility;
• Soil containing more than 1 mg/kg & less than 10 mg/kg PCB will be excavated & disposed of in a local Class III permitted SW disposal facility;
• Residue generated during soil washing will be handled & disposed of in accordance with state & federal regulations.
Based on apparent & reported discrepancies between the fieldwork conducted by some of the AF contractors during 2009 & the approved remedial action plans, the Air Force contracted with the AECOM & the Native Village of Port Heiden to conduct follow-up sampling in 2010. Data from these sampling events indicates a failure of the remedy & alleged violations of State regulations.
Polluted Soil Disposal in the Landfill-The SW disposal permit (permit #: SW3A069-14) issued to the Native Village of Port Heiden for the Class III landfill prohibits disposal of polluted soil in the landfill without specific written permission from ADEC. In a letter dated May 29,2009 the ADEC SW Program authorized disposal of soil containing less than 10 mg/kg PCB in the landfill.
AECOM collected eighty (80) discrete soil samples from the PCB disposal cell at the landfill; forty (40) samples were collected near the top of the cell & forty (40) were collected near the bottom. Twenty-one (21) of these samples contained PCBs at levels above the 10 mg/kg landfill permit limit. This is an alleged violation of the ROD, approved work plan, the landfill permit & the Site Cleanup Rules (18 AAC 75.360 - Site Cleanup Operations) & the SW Disposal regulations (18 AAC 60.025 - Polluted Soil). Polluted soil improperly disposed of in the landfill needs to be removed, treated &/or disposed of properly.
Soil Washing Tanks & Treatment Residues-Steel & poly-tanks used during the soil washing were improperly disposed of off-site & found to contain residual contaminated soil. Subsequent sampling conducted by the Native Village of Port Heiden documented up to 91.5 mg/kg PCB in the soil. This off-site disposal is an alleged violation of the approved work plan, ROD, the Site Cleanup Rules (18 AAC 75.360-Cleanup Operations Requirements) & the CERCLA off-site rule. In a letter dated October 1st ADEC requested the AF fence the area around the tanks & develop a plan to remove & properly dispose of the tanks & contaminated soil in & around them as soon as feasible.
In response, the AF fenced the area & submitted a Time Critical Removal Action plan on October 21, which ADEC approved on October 22. I understand the plan will be implemented after EPA completes additional investigation at the site in early November. DEC requests advanced notification on the planned mobilization date.
PCB contamination at the Soil Washing Area-Twenty-one (21) soil samples were collected from the soil washing area before & sixteen (16) soil samples were collected after conducting the soil washing operations by DMC Technologies. The results reportedly did not contain PCB above the 1 mg/kg cleanup level. However, the 2010 AECOM report, submitted to DEC by the AF, documents the soil washing area has been impacted with PCB-contamination above the cleanup level.
AECOM collected three-hundred-twenty-one (321) composite soil samples at the soil washing area (not including quality control samples); one-hundred-thirty-seven (137) samples contained PCB above the cleanup level, with the maximum reported level being 27 mg/kg PCB. Additional remedial action is required in the former soil washing area.
For additional information see site file. |
John Halverson |
| 11/15/2010 |
Enforcement Action |
Robyn M. Burk Colonel USAF Commander sent letter to ADEC (John Halverson) received by ADEC on 11/15/2010.
This is in response to your 29 Oct 10 compliance advisory letter regarding Port Heiden Radio Relay Station. ADEC requested a written response from the Air Force within twenty-one (21) days of receipt of your letter. The 61lth Civil Engineer Squadron (611 CES) has been working diligently with the Air Force Center for Engineering & the Environment (AFCEE), legal counsel & contracting personnel to respond to your concerns. However, due to the complex nature of these issues, we request an extension to provide our plan NL T 15 Jan 11. We have not taken your original request lightly. Provided below is additional information outlining the steps we are actively taking to mitigate the situation & prepare a sound plan for resolving all your concerns.
The 611 CES placed fencing & signage around the tanks as part of our initial response on 2 Oct 10. At the suggestion of Environmental Protection Agency (EPA) Criminal Investigation Division (CID), we delayed further work to provide them an opportunity to conduct their own field investigation. The EPA CID & Air Force Office of Special Investigations (OSI) arrived at Port Heiden on 8 Nov 10 to take samples as part of their ongoing investigation. 611 CES/CEOR arrived 9 Nov 10 to implement the ADEC approved (22 Oct 10), time-critical work plan.
Work is expected to be complete by 12 Nov 10 with a report to follow for ADEC review & approval. AFCEE issued a show cause letter to Weston Solutions on 26 Oct 10. The show cause letter notified Weston of their failure to perform under the provisions of the contract. It also provides them an opportunity to address Air Force & regulatory concerns. Weston originally had until 5 Nov 10 to respond, but requested an extension until 1 Dec 10, which was approved by AFCEE. We anticipate the response from Weston will help us formulate significant aspects of our plan.
Lastly, you requested my staff meet with the EPA & your team to discuss the need for another Explanation of Significant Differences (ESD) or a Record of Decision (ROD) amendment. We agree this is will be a necessary step in our plan to address the alleged remedy failure but suggest that at this early stage we would focus our discussions more broadly on coordinating the major aspects of that plan. We would gladly meet with your staff to discuss this matter further.
We remain committed to our responsibilities to address the restoration of the Port Heiden site; as well as all 611 ASG restoration sites in coordination with your office & in compliance with the records of decision developed & agreed within that partnership & in concert with the local authorities. Please do not hesitate to contact my Restoration Lead, Mr. Steve Mattson (907) 552-4496 or steve.mattson@elmendorf.af.mil.
|
John Halverson |
| 11/18/2010 |
CERCLA ROD Periodic Review |
Institutional Control Performance Report received. The US Air Force (USAF) will complete an ICPR annually for five years as required by the Record of Decision (ROD). The frequency of the ICPR will be evaluated with the five-year review under 42 USC 9621(c).
2.1 INSTITUTIONAL CONTROLS FOR SOIL
Per the (Feb. 2009) Record of Decision (ROD), a notice type of institutional control (IC) will be implemented (with the land owners consent) to control the use of soil containing residual concentrations of dieldrin above 0.0076 mg/kg. This notice will make the Land Owner aware that the Alaska Department of Environmental Conservation (ADEC) approval is required for any disturbance of soil (the goal of this institutional control is to prevent the constant contact of this media with water which could impact groundwater or surface water quality).
At the RRS landfill, ICs will be established to provide notice that the remaining buried wastes may contain contaminants of concern, that the cover should be maintained, and excavation into or development over the Port Heiden RRS Landfill should be restricted to maintain the integrity of cap and to prevent migration of contaminants.
If future property use includes disturbance of the institutional control area such that the remaining pesticide contaminated soil comes in constant contact with water, or other information becomes available which indicates that the site may pose an unacceptable risk to human health, safety, welfare or the environment, the land owner and/or operator are required under 18 AAC 75.300 to notify ADEC and evaluate the environmental status of the contamination in accordance with applicable laws and regulations. Further site characterizations and cleanup may be necessary under 18 AAC 75.325-.390.
In the future, if soil is removed from the site it must be characterized and managed following regulations applicable at that time. Pursuant to 18 AAC 75.325(i)(1) and (2), ADEC approval is required prior to moving or disposing of soil that is, or has been, subject to the cleanup rules found at 18 AAC 75.325-.370.
The landowner has not accessed the site for any activities beyond a routine site visit. In spite of fencing and warning signs, it appears some residents have driven through the site. Since they did not disturb the soil, this is not a violation of the ICs. Regardless, additional fencing and signs were posted. This topic was discussed at the public meeting conducted in September, 2010.
Additional quantities of PCB-contaminated soil were identified during the 2010 field season however dieldrin was not identified at the existing sites. As such, no new sites were established. No new source was identified and this area was likely contaminated at the same time and from the same source as the rest of the RRS. No new exposure pathways were identified. There has been no change of property ownership; no land transfers, sales, or leases. The AF did renew the Right of Entry from the Alaska State Department of Transportation to allow for continued access.
Other than for sampling purposes, no groundwater was used at the site. The landowner has not accessed the site for any activities beyond a routine site visit. The landowner made no attempt to access/use groundwater. There is no evidence that any other visitor to the site attempted to use groundwater. Sample results will be presented in a separate report.
No additional groundwater contamination was identified. No new contaminates, no new sites, and no new sources were identified. No new exposure pathways were identified. There has been no change of property ownership; no land transfers, sales, or leases. The AF did renew the Right of Entry from the Alaska State Department of Transportation to allow for continued access.
Since the ROD was signed, the site has been in an active remediation status. No violation of the ICs has been noticed. Once all activities on site are complete, if the ROD requires amending, it will be completed at that time as will formal notice to the landowner on any IC remaining in place. |
Louis Howard |
| 12/14/2010 |
Update or Other Action |
Time-critical remedial action report received. This time-critical remedial action report has been prepared to document the work performed to remove several abandoned tanks & polychlorinated biphenyl (PCB) contaminated soil from the Alaska Department of Transportation (ADOT) Maintenance Facility at Port Heiden, Alaska. This report also details the construction of a temporary security fence around a second area of PCB contaminated soil at the former Air Force Radio Relay Site (RRS), & construction of a temporary containment cell for the recovered tanks & soil. Details of the approach & rationale were provided in the Final Work Plan, Time Critical PCB Contaminated Soil Removal, Port Heiden, Alaska, October, 2010. The work was conducted by the 611 Civil Engineer Squadron (CES) in-house forces in November, 2010.
The overall objective of the project was to remove the risk of exposure to PCBs from the improperly disposed tanks, & residual contaminated soil at the ADOT & soil washing sites. The project Work Plan described the various tasks, work approaches, field sampling, & data quality objectives to accomplish the cleanup. As described in the Work Plan, the tasks included the following:
a) Install temporary snow fencing around the former soil washing site contaminated with PCBs.
b) Remove 3 steel & 4 polyethylene tanks from an area behind the ADOT building adjacent to the airport runway.
c) Containerize soil in the 3 steel tanks, & any soil that had spilled from the tanks.
d) Collect PCB cleanup verification samples in area(s) where PCB contaminated soil had spilled on the ground.
e) Transport the 7 tanks to a temporary storage area at the former RRS site.
f) Collect a series of composite PCB characterization samples from the fenced area area surrounding the 3 steel tanks.
g) Construct a temporary lined containment cell on Air Force property for the 7 tanks, recovered soil, & personal protective equipment (PPE).
Analytical data from soil samples collected from the tanks by NVPH were used to provide initial waste characterization data. The four polyethylene tanks (NVPH sample numbers DMC-01 thru 04) contained soil with PCB concentration of 89.5, 96.9, 33.5, & 5.2 mg/Kg, respectively. Soil from the 3 steel tanks (NVPH sample numbers DMC-05 thru 07) was sampled & found to contain 16.4, 91.3, & 9.5 mg/Kg PCBs, respectively. At the soil washing area, the AECOM data was used to establish the security fence boundary.
The soil washing area is an approximately 2-acre site east of the former RRS site . The area was used to treat PCB contaminated soil from the former RRS site. AECOM conducted a study at the site & determined that the soil beneath the wash area was contaminated with PCBs above ADEC cleanup levels. Using the data from the AECOM report to establish the limits of the PCB contamination, 1,400 linear feet of snow fencing was erected to prevent local residents & wildlife from being exposed to PCBs. The site was also placarded with 16 warning signs (4 per side) warning of the presence of PCBs.
The four polyethylene tanks were found in an upright position with no evidence that soil had spilled on the ground. The tanks were moved to a temporary storage cell constructed at the former RRS site. No samples were collected. The 3 steel tanks were found lying on their sides approximately 40 feet northeast of the polyethylene tanks. Tanks DMC-05 & DMC-07 had little residue in the bottom, & there was no evidence that soil had spill from the tanks. Tank DMC-06 contained the most soil, & some had spilled from the tank onto the ground. The contaminated soil contained in the 3 tanks was shoveled into 1 cubic yard (cy) super-sacs.
Approximately 2 ¼ cy were recovered from the tanks, most of which came from tank DMC-06. The soil that spilled from tank DMC-06 was also shoveled into super-sacs. An additional 6 inches of underlying soil (beneath the spilled soil) was also removed prior to confirmation sampling. Approximately 1-inch of soil was excavated from in front of tank DMC-07, even though there was no evidence soil had spilled from the tank. Tank DMC-05 rested on a thick vegetation mat comprised of low-shrub sedge, & dwarf tundra. No soil was present on the surface, therefore no soil was excavated from this site. Approximately ¼ cy of soil was excavated from in front of the two other tanks. After the tanks were cleaned of residual soil, they were transported to the temporary storage cell constructed at the former RRS site.
Tank DMC-06
Confirmation sampling following the excavation of soil with documented PCB concentration above 50.0 mg/Kg (tank DMC-06) consisted of grid sampling, as detailed in EPA-560/5-86-017 (Field Manual for Grid Sampling of PCB Spill Sites to Verify Cleanup, 1986). PCBs were detected in all 7 cleanup verification samples & the duplicate. The concentrations ranged from 5.69 mg/Kg to 22.2 mg/Kg.
For additional information see site file. |
Louis Howard |
| 1/3/2011 |
Document, Report, or Work plan Review - other |
ADEC commented on the draft PCB removal report. Main comments were regarding the need for properly removing, treating and/or disposing of polluted soil properly associated with the PCB contaminated soil at the former RRS. Staff requested the Air Force submit a work plan which(at a minimum) will provide details on how the Air Force will assess the nature and extent of PCB contamination associated with the abandoned tanks DMC-05 and DMC-06 and the fenced area surrounding the tanks. |
Louis Howard |
| 1/14/2011 |
Enforcement Action |
Air Force sent response to J. Halverson (ADEC) regarding the October 29, 2010 compliance advisory to the Air Force. This is a follow-up to your 29 Oct 10 Compliance Advisory letter regarding the Air Force environmental restoration project at the former Port Heiden Radio Relay Station, Alaska. As part of our initial response to the remedy failures cited in your letter, on 30 Sep-1 Oct 10, personnel from the 611th Civil Engineer Squadron (611 CES) erected fencing & signage around the tanks located on Alaska Department of Transportation (ADOT) property to secure the site.
On 9 Nov 10, after the EPA Criminal Investigation Division & the Air Force Office of Special Investigation completed their on-site investigation, 611 CES personnel containerized the contaminated soil from the steel tanks, & relocated the containerized soil & seven tanks to Air Force property at the former radio relay station. As reported to your office in the draft report "Time-Critical PCB Removal Action," 10 Dec 10, there is residual contamination on the ADOT property where the tanks were previously abandoned.
In a letter dated 7 Jan 11, the Air Force Center for Engineering & the Environment contracting officer directed Weston Solutions to return to Port Heiden this summer to correct the remedy failures pursuant to ADEC's, 29 Oct 10, Compliance Advisory letter as well as those noted in the 3 Jan 11, ADEC comment letter on the Air Force PCB removal action report. These actions shall include:
1) actions necessary to bring the Class III landfill into compliance with the permit;
2) remediation of the treatment area;
3) removal of any remaining PCB contamination to within ADEC clean up standards related to tanks abandoned/stored on ADOT property; &
4) decontamination, removal & proper disposal of any other equipment, materials, & supplies remaining in Port Heiden from Weston and/or their subcontractors to an authorized location.
Weston will be required to produce a work plan & after action report first as a draft for ADEC review; & then as a final product after comments are addressed. Additionally, if needed, they will complete another Explanation of Significant Differences (ESD) or Record of Decision (ROD) amendment.
I believe the plan outlined above will bring these sites into compliance with state regulations. To that end, the contractor's performance will be monitored very closely, in concert with your office, to ensure timely execution & full compliance with ADEC regulations & approved work plan. If the contractor fails to perform adequately, we will execute alternative means to fulfill our regulatory obligations for these sites.
Please do not hesitate to contact me or my Environmental Restoration Program Manager, Mr. Steve Mattson at (907) 552-4496 or steve.mattson@elmendorf.af.mil.
signed by Robyn M. Burk Colonel, USAF, Commander
CC: 11 AF/JA.
|
John Halverson |
| 2/4/2011 |
Update or Other Action |
Letter from DMC (Dan McNair) to Jennifer Currie (AK Dept. of Law). Subject Port Heiden Events.
This correspondence provides information regarding work performed at Port Heiden by Trucano/DMC Technologies. Inc. (TRDMC). A conclusion that the PCB washing technology deployed at Port Heiden failed is erroneous & damages TRDMC. Legal counsel has been deployed to refute the actions taken by Weston.
It must be recognized that washed soils & decontaminated lands & equipment associated with TRDMCs work were clean when TRDMC left Port Heiden on September 2nd, 2009. Third party confirmation sample anlayses & other substantial information support a determination that recontamination of the site is responsibility of Weston & or others.
Resampling of the areas in question was performed 260 days after TRDMC left Port Heiden. TRDMC is aware that the work performed has been rejected by Weston Solutions (Weston) as inadequate & that Weston has been requested to correct deficiencies. Weston is ultimately responsible for the recontamination as the primary contractor with the USAF. A variety of documented issues associated with project sampling, oversight & the deteriorated relationship of various parties with Weston is important in understanding the events at Port Heiden. Weston Solution is premature in blaming TRDMC for project failures. Such blame in view of the facts is responsible & will be resolved through appropriate legal channels.
A former DMC employee filed complaints with the USAF after being terminated alleging that DMC illegally & fraudulently conducted labor & sampling practices during the work at Port Heiden. The employee was terminated by DMC on November 19th, 2009 for a variety of causes including irresponsible behavior at Port Heiden, which was witnessed by Weston; & criminal behavior including forgery & grand theft. The employee also stole & altered Company documents including a project Filed Log Book.
Upon termination, the employee attempted to extort a settlement from DMC, which was rejected. The employee then filed complaints with the USAF & the Department of Labor. DMC filed a criminal complaint against the employee, which has not yet been acted upon by the State. Civil actions relative to the employee are pending. The complaints filed by the employee were clearly the actions of a disgruntled employee in retribution for termination & as an attempt to cover criminal behavior.
The employee's complaint was submitted to a USAF Contract Officer with a personal motivation to see DMC fail. The complaint regarding labor practices was investigated by the Department of Labor & found to be false. The employee had lied. The complaint regarding fraudulent sampling handling is also false. However, this complaint resulted in the USAF returning to Port Heiden in 20 I 0,260 days after DMC left the site, to collect samples. These samples identified the presence of PCBs. The unresolved sampling mismanagement complaint & the laboratory results from resampling in 2010 form the basis of actions taken to date.
Sample results presented in a final report to Weston, USAF, & ADEC substantiate DMC claims that the work performed met contract & remedial work plan requirements. In 2009, DMC Technologies, Inc. was contracted by Trucano Construction through Weston Solutions to perform remediation of PCB contaminated soil at Port Heiden, Alaska. DMC prepared a addendum to Weston's Remedial Work Plan to wash 1,505 CY of PCB contaminated soil to less than 10 ppm. A laydown area near known historic areas of PCB contamination was selected by Weston & prepared by DMC for washing contaminated soil. The entire work area was lined & bermed. Soils were excavated & placed in the PCB washing area by Weston.
See site file for additional information. |
Louis Howard |
| 2/7/2011 |
Meeting or Teleconference Held |
Meeting Held: Monday 7 February 2011 Location: WESTON Alaska Office, 2nd Floor Conference Room. Attendees:Kevin Thomas, AFCEE, Scott Blount, WESTON,Glen Verplancke, AFCEE, Skip Koch, WESTON, Jim Klasen, AFLOA/JACE, Louis Howard, ADEC, Pat Roth, 611th CES, Lori Aldrich, ADEC, Jack Gusmano, USEPA Region X, Earl Crapps, ADEC, Dan Duncan, USEPA Region X, Jenn Currie, Alaska DOL, Dave Bartus, USEPA Region X
Subject:Port Heiden RRS, Minutes from the Port Heiden Regulatory Review & Status Meeting.
At 10:00 AM on 7 February 2011, the meeting opened in WESTON’s 2nd Floor Conference Rm.
Scott Blount started the meeting stating that the purpose of the meeting was to better understand the State & EPA positions on the level of corrective action required to satisfy the requirements at the Port Heiden RRS site. No agenda was prepared since there might be overlap between issues at the various sites. Three areas of concern were identified: the Native Village of Port Heiden (NVPH) Landfill (“the landfill”), the former laydown area used by WESTON’s 2nd-tier subcontractor DMC (“the laydown area”), & the assortment of equipment left by DMC around the Village prior to leaving the site. It was decided to address the landfill area first.
LANDFILL:
Lori Aldrich stated that the approved limit for PCBs in the landfill was less than 10 mg/kg. It was the State’s opinion that the results from the AECOM sampling indicated sufficient “comingling” of high & low hits of PCBs that the entire volume of soil in the landfill would have to be removed. In the conversation that followed, WESTON provided maps of the AECOM data with overlays of where the treated (washed) vs. untreated soils were placed, along with references to the distinct locations of where treated vs. untreated soils were placed within the landfill. Outside of the areas of “post-treated” soils, the most elevated concentration of PCBs was below 25 ppm. It was clear to all that the “post-treated” soils largely exceeded 50 ppm (TSCA threshold) & that those soils exceeding this threshold needed to be removed.
Jack Gusmano reminded the group that all soils placed in the landfill by WESTON as “warm” soils (between 1 ppm & 10 ppm) were done so according to a State- & EPA-approved workplan, & that a requirement to remove “all” soils would set a precedent which could call into question the integrity of many landfills in the State as well as the integrity of past environmental efforts conducted in good faith according to agency-approved workplans. He indicated that a requirement for total removal would be “tragic”, particularly since all knew at the time the workplan was being prepared that the soil being excavated for removal to the landfill was extremely heterogeneous. Jack also questions whether the penetration of the landfill cover jeopardized the ROD for the project. Because the landfill was not on-site, the ROD matter was dropped.
Scott Blount pointed out the complexity of the issue, stating that a compromise position on the non-treated, “warm” soils would help mitigate any continued controversy over these soils into the future between WESTON & the Air Force. It was pointed out that without the post-treated soils, the average concentration of the remaining soils was near 4.74 ppm, with a standard deviation of 4.04 ppm, & that a small percentage of soils exceeding 10 ppm was expected given the nature of environmental sampling / environmental remediation. It was noted that over 1,000 samples had been collected to ultimately characterize what was placed in the landfill, & that the reason the meeting was being held was that the soil washing remedy, not the placement of the warm soils, had failed. It was also noted that waste characterization “at the point of excavation” was standard practice under federal regulations (TCSA), & that sampling after emplacement was extraordinary.
A dialog ensured regarding the potential for any increased risk for the warm, non-treated soils. It was noted that a fate & transport model had been performed for the current landfill that indicated it was significantly protective of human health & the environment for soils up to 10 ppm, & that it was likely that the model used would indicate similar protectiveness of soils with marginally higher concentrations (such as those up to 25 ppm). An additional foot or two of soil cover was also discussed as an added measure of protection for the warm soils already in place.
ADEC agreed to review a model / proposal if it were presented that indicated that soils up to 25 ppm would not present an unacceptable risk. The State has the authority to accept soils up to 49 ppm PCBs by regulation. However, the State pointed out that the permit holder was the NVPH, & that the NVPH would have to agree to allowing soils with the higher concentrations to remain in their landfill before the State would accept them.
For additional information see site file. |
Louis Howard |
| 2/17/2011 |
Update or Other Action |
WESTON submits a draft proposed corrective action approach to ADEC for review and comment.
1) Weston is planning on removing all treated soils & all miscellaneous items that are currently mixed with these soils from the Class III landfill & transport off site.
2) Weston will provide Alaska Department of Environmental Conservation (ADEC) & the Native Village of Port Heiden (NVPH) the original Fate & Transport model rerun with concentrations of PCB’s at 50 ppm & 30 ppm to validate the level of risk associated with any polluted soil left on site.
3) Weston will characterize the soils at the soil washing area. The soils will be characterized into soils greater than or equal to 10 mg/kg & soils with concentration of greater or equal to 1 mg/kg to less than 10 mg/kg.
4) Weston will remove soils that are characterized greater than 10 mg/kg off site & soils with concentrations greater or equal to 1 mg/kg to less than 10 mg/kg to the existing Class III landfill.
Weston’s approach for this is below; the details about transporting the soils including how Weston will deal with decontamination of the vehicles used in the transportation of these soils will come at a later date.
Cleanup Landfill:
1) Provide Fate & Transport model to ADEC & NVPH. The model will be run with two different concentrations; 50 ppm, & 30 ppm.
a) Removing washed soil from front of Cells 2 & 3
b) Propose to:
i) Remove top two feet of clean overburden (cap), & pull back liner to expose washed soils.
ii) Excavate washed soils: Use visual & olfactory methods to guide excavation, place excavated washed soils in 5 CY supersacks, stage supersacks for transportation to an approved off-site disposal facility. Excavation will continue until the depth of the original landfill floor has been reached.
iii) Excavate & remove debris (disposal liners, tires, etc.) that was contaminated during the previous soil washing activities & placed with the washed soils within Cells 2 & 3 of the landfill. Excavation will continue to the original floor of the landfill.
iv) After washed soils & debris are removed sidewall samples will be collected at 1 sample per 225 ft2 (15-ft by 15-ft square). Excavation will continue until PCB analytical results are less than 10 mg/kg.
v) Excavation will be backfilled with excavated soil from the soil washing area with PCB levels less than 10 mg/kg (see below).
vi) Replace the clean overburden material to a depth of two feet.
2) IDW generated during this field effort will be sampled to determine if it is contaminated or not, & disposed of properly.
a) 5% of the IDW will be sampled. This will be 1 in 20 bags of IDW waste.
b) If IDW has analytical results less than 10 mg/kg it will be disposed of in the landfill along with the excavated soils from the soil washing area. If concentrations are greater than 10mg/kg it will be disposed offsite.
Soil Washing Area – Overview:
1) Soil Washing Area perimeter is to be defined by AFCEE & WESTON. (Air Force responsible to reduce areas not used by DMC to less than 1 mg/kg.)
2) Surface soil in this area was characterized during the AECOM site investigation.
a) The site investigation sample results will be used to set up exclusion areas for sampling. PCB soil results less than 10 mg/kg & greater than 1 mg/kg will be used for the boundaries.
b) For consistency purposes, the same site investigation surface soil sample locations will be used to collect additional soil samples at depth in order to characterize the subsurface soil & further delineate the extent of contaminated soil prior to removal activities.
3) Sampling of the soils in the settling tank areas will start at the depth where the bottoms of the tanks were located.
4) During sampling & or excavation if landfill debris in encountered near USACE landfill work in that area will stop. Areas will be marked using GPS.
5) Transport PCB contaminated soils greater than 1 mg/kg but less than 10 mg/kg to landfill. All PCB contaminated soil greater than or equal to 10 mg/kg will be placed into supersacks & stage for transportation to an approved off-site disposal facility.
For additional information see site file. |
Louis Howard |
| 2/22/2011 |
Update or Other Action |
WESTON submits revised Port Heiden screening data via electronic mail. While reviewing the screening data from Port Heiden related to the spreadsheet you forwarded on Friday (2-18), I discovered that 9 of the 18 screening results in the table were incorrect. When I verified these results in our database, and screening logs I noted a discrepancy on these 9 samples. The discrepancy was due to a transcription error between a field logbook and the field screening logbook.
The Rapid Assay process has 2 dilutions to account for when analyzing samples – a 2X dilution made during the extraction process and any additional dilution performed during the analysis process. The results in the spreadsheet you sent (from our database) accounted for the extraction dilution, but not the analytical dilution for these samples.
Copies of the field book and screening log are attached to this email along with a spreadsheet with corrected results for these samples to show the errors. I have corrected the errors in the project database and will send out a corrected results spreadsheet. The samples in question were collected in early-mid May and 100% lab confirmation was being performed at this time. Richard M. Vicente Weston Solutions, Inc. |
Louis Howard |
| 2/24/2011 |
Update or Other Action |
WESTON submits PCB SESOIL Model Results to ADEC via electronic mail. In February 2011, OASIS performed additional modeling to evaluate two new input scenarious: PCBs at 30 mg/kg and 50 mg/kg. No other input parameters were changed from the 2009 modeling. The SESOIL Model result for PCB concentrations of 30 and 50 mg/kg at the Port Heiden landfill. They indicate that there will not be any leaching to the groundwater above acceptable levels at either concentration. |
Louis Howard |
| 2/25/2011 |
Document, Report, or Work plan Review - other |
611 CES sends comments out regarding PCB SESOIL Model results. The comments may apply more to the upcoming work plan than they do to the SESOIL modeling - but reading this addendum brings these questions to mind. Though Weston may have already thought of all these questions, please forward these comments to Weston for their consideration as they develop their work plan.
If I recall correctly (and I may be wrong), the original modeling - as with this addendum - did not account for two items. One, the soil going into the landfill still having a substantial amount of alcohol in it (though it passed the paint filter test). Second, as results now show, there being over 50 ppm of PCBs in the landfill.
I hear one proposal is to take all soil treated by DMC out of the landfill. If that comes to fruition, my concerns are:
1) does this capture all soils over 50 ppm? Or in other words, is the landfill characterized sufficiently to know this?
2) since it has been approximately 18 months (and longer by the time field work starts), what will be accomplished to determine how far PCBs have migrated? Since the SESOIL did not account for the alcohol in the sol or the high level of PCBs, we have no idea how far these may have migrated.
3) since the alcohol/PCBs may not migrate straight down, how will soils adjacent to the DMC treated soil be addressed.
Pat Roth |
Louis Howard |
| 2/25/2011 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (ADEC) has reviewed the Weston Solutions, Inc. (Weston) Proposed Corrective Action Approach, received February 17, 2010. The Proposed Corrective Action Approach outlines a path forward for development of a work plan for remediation of contamination, at the Port Heiden Landfill and the soil washing area, discovered after completion of a cleanup project at the u.S. Air Force Port Heiden Radio Relay Station (Port Heiden RRS).
For the original Port Heiden RRS cleanup project, the final Work Plan, dated March 2009, requires soil with a concentration of polychlorinated biphenyls (PCBs) greater than 1 mg/kg to be excavated. As a part of the project, in conjunction with the Native Council of Port Heiden, Weston received ADEC approval to dispose of soil with a PCB concentration of less than 10 mg/kg in the Port Heiden landfill.
Excavated soil less than 10 mg/kg PCBs was to be directly disposed at the landfill, and soil greater than 10 mg/kg PCBs was to be washed by the approved process to less than 10 mg/kg PCBs, then disposed at the landfill. Subsequent third party (AECOM) sampling indicates PCB levels as high as 74 mg/kg in the landfill, and 27 mg/kg in the soil washing area. Although the source of these discrepancies is under investigation, all parties have agreed that as primary contractor, Weston is responsible for corrective action at the sites.
ADEC has the following comments on the Weston Proposed Corrective Action Approach:
Further Data Analysis
Weston has provided a fate and transport model for 30 mg/kg and 50 mg/kg PCB contaminated soil to support their request to leave soils that were not washed prior to disposal in the landfill, but have tested above 10 mg/kg PCBs. Based on a review of the screening versus analytical data presented in the final report on the Port Heiden RRS project, ADEC has concerns with the efficacy of Weston's use of screening samples to accurately determine PCB contamination levels. ADEC will require Weston to submit a correlation study for all samples that were analyzed by both field screening and laboratory methods.
Also, Weston must calculate the 95% Upper Confidence Limit (UCL) for PCB levels, for any soil that they are requesting to leave in place at the landfill, using the AECOM landfill sampling data including duplicate samples. ADEC will review the analyses and may require additional characterization of the landfill and/or additional removal of PCB contaminated soil at the landfill based on the results.
Confirmation Sampling Requirements
ADEC will require confirmation samples to be collected using EPA hexagonal grid sampling methodology (Field Manual For Grid Sampling of PCB Spill Sites to Verify Cleanup May 1986). Specifically, an excavated area will be subdivided into 1S-foot squares. Centered within each of these squares will be four S-foot square grids. Composite samples will be collected from the nine points of intersection created by these S-foot grids. One dedicated steel sampling spoon will be used to scoop soil from each of the nine locations. ADEC will require sidewall PCB confirmation samples be collected at a frequency of one sample per each 20 linear feet (or portion thereof) of the sidewall for each excavated lift.
Excavation will continue until PCB analytical results are less than or equal to 10 mg/kg for samples from the landfill and less than or equal to 1 mg/kg for samples from the soil washing area.
Landfill
1) b) ii) Text states: " ... using visual and olfactory methods to guide excavation. Excavation will continue until the depth of the original landfill floor has been reached."
ADEC will require confirmation samples from the floor and sidewalls of the excavation that meet the confirmation sampling requirements above. Excavation will continue until PCB analytical results are less than 10 mg/kg. The extent of excavation is undetermined at this point in time since PCB infused alcohol used as part of the soil washing may have migrated in this area to depths greater than the original landfill floor.
v) Text states: "Excavation will be backfilled with excavated soil from the soil washing area with PCB levels less than 10 mg/kg."
Any additional disposal of PCB contaminated soil will require approval of the ADEC Solid Waste Program AND the Native Village of Port Heiden. If approval for disposal of additional contaminated soil at the landfill is not received, soils must be transported to an off-site disposal facility in the Lower 48 and Weston must backfill the excavation with clean soil and grade the site to the original contours of the landfill.
For additional information see site file. |
Louis Howard |
| 2/28/2011 |
Update or Other Action |
Staff received the Draft Final GW Monitoring Report (GWMR) for the Former Port Heiden Radio Relay Station (RRS). It summarizes GW monitoring results & activities that were conducted at the Former Port Heiden RRS during the 2010 field season by the Native Village of Port Heiden & Boretide Consulting.
None of the daughter products for TCE (cis-1,2-dichloroethene [cis-1,2-DCE], trans-1,2-DCE, & vinyl chloride [VC]) were detected in any GW samples. Related to the topic of contaminant reduction, it is important to note that a third plume was identified at the Former RRS in the RI/FS (Weston Solutions, 2006). In addition to the POL & TCE plumes defined in Figure 3, an additional POL plume existed in 2004 in the vicinity of well UST-MW-01. This well had been scheduled for sampling in 2010 but was found to be cracked at a riser connection at 30 feet below ground surface. After extensive efforts, it was determined that none of the Grundfos sonde, a bailer, or tubing could pass this break, & the well was thus abandoned.
Although data to make defensible claims about the ongoing effectiveness of natural attenuation in GW at the Former Port Heiden RRS are not sufficient, an excellent set of baseline data have been gathered.
Sufficient annual attenuation data to evaluate trend changes in geochemical indicators are not yet available, the current data set & future data will be used to determine whether reductive dechlorination is occurring. These data are expected to include the results of analysis from future sampling events for standard geochemical indicator parameters, including DO, oxidation reduction potential, temperature, nitrate, ferrous iron, sulfate, & methane. These parameters will be used to evaluate aquifer conditions.
Data from these parameters will indicate whether reductive chlorination is occurring within the aquifer, & will assist in future site management & long-term monitoring decisions for the site. Additionally, a summary of the daughter products (cis & trans-1,2-DCE, VC, methane, & ethane) will be presented & discussed in future reports to support the occurrence of reductive chlorination.
Annual sampling events are recommended at each of the three AOCs. To maintain data consistency, it is recommended these events occur in the fall, the season when the previous two sampling rounds were conducted.
FPC-066: MW-05 was the only well out of four wells sampled that exceeded cleanup level for DRO (1.5 mg/L) at 2.25 mg/L.
The contaminants present at FPC-066 are in a one-well plume. Well MW-05 is the only one of the four wells sampled in 2010 that had a compound (DRO) above cleanup criteria. No additional wells are available for sampling in this area to better define this boundary. Unless it is deemed enough of a priority to install additional wells at the FPC-066 location, it is recommended that DRO sampling of these four wells continue annually.
FPC-215: MW-09 had DRO at 4.18 mg/L in October 2009 & in October 2010 it had 9.68 mg/L. In 2009 MW-10 had DRO at 3.99 mg/L & in 2010 it did not exceed cleanup levels. MW08 did not exceed any cleanup levels in 2009 & 2010.
Much like FPC-066, the contaminants present at FPC-215 are in a one-well plume. Well MW-09 is the only one of the three wells sampled in 2010 that had a compound (DRO) above cleanup criteria. No additional wells are available for sampling in this area for use in adding value to the existing delineation. Unless it is deemed enough of a priority to install additional wells at the FPC-215 location, it is recommended that DRO & BTEX sampling of these wells continue annually.
|
Louis Howard |
| 3/7/2011 |
Update or Other Action |
Proposed Corrective Action Approach dated March 7, 2011 Revision 4.
Weston Solutions, Inc. (Weston) proposes to execute the following corrective actions in support of the Port Heiden Cleanup Project:
1) Remove all washed soils & all miscellaneous items that are currently mixed with these soils from the Class III landfill (Cells 2 & 3) & transport & dispose off site.
2) Provide the Alaska Department of Environmental Conservation (ADEC) & the Native Village of Port Heiden (NVPH) the original Fate & Transport model was rerun with levels of PCB's at 30 ppm & 50 ppm validating that risk associated with any polluted soil left on site was acceptable at these levels.
3) Characterize the soils at the Soil Washing Area. The soils will be characterized into two categories: soils with levels of PCBs > or = to 10 mg/kg or soils with PCBs > or = to 1 mg/kg & <10 mg/kg.
4) Remove all soils from the Soil Washing Area that are characterized >10 mg/kg & transport to an approved offsite disposal facility & transport all soils with PCBs > or = l mg/kg & <10 mg/kg to the existing Class III landfill.
Weston's approach for the execution of these corrective actions is presented below. Details regarding soil transportation & the decontamination of the vehicles used in the transportation of these soils are not included in this approach & will be provided at a later date.
Cleanup Landfill:
1) Weston provided the Fate & Transport model to ADEC & NVPH. The model will be rerun with two different concentrations: 30 ppm, & 50 ppm. The Fate & Transport model indicated no leaching of PCBs to ground water will occur at 30 ppm or 50 ppm.
2) Cleanup of the landfill will be accomplished with the following steps:
a)Remove washed soil from the front of Cells 2 & 3; by doing so the following:
i) Remove top 2 feet (ft) of clean overburden (cap), & pull back liner to expose washed soils.
ii) Excavate washed soils - Use visual & olfactory methods to guide excavation, place all excavated washed soils in 5-cubic yard (CY) Super Sacks®, stage Super Sacks® for transportation to an approved offsite disposal facility. Excavation will continue until the depth of the original landfill floor has been reached.
iii) Excavate & remove debris (disposal liners, tires, etc.) that was contaminated during the previous soil washing activities & from Cells 2' & 3 of the landfill. Excavation will continue to the original floor of the landfill.
iv) After washed soils & debris are removed floor samples will be collected at one sample per 225 square feet (ft2) (15-ft by IS-ft square). The floor will be subdivided into 15-ft squares. Centered within each of these squares will be four 5-ft square grids. Composite samples will be collected from the nine points of intersection created by these 5-ft grids. In addition one sample will be collected from each 20 linear ft (or portion thereof) of the sidewall (If sidewall is > 2-ft of continuous slope, take a composite of five individual samples spread evenly across face of sidewall). Excavation will continue until PCB analytical results are <10 mg/kg.
v) Excavation will be backfilled with excavated soil from the Soil Washing Area with PCB levels <10 mg/kg (see below).
vi) Replace the clean overburden material to a depth of 2 ft.
3) Investigation Derived Waste (IDW) generated during this field effort will be sampled to determine whether or not it is contaminated, & disposed of properly.
a) 5% of the IDW will be sampled. This equals one in 20 bags of lDW waste.
b) If IDW has analytical results <10 mg/kg it will be disposed of in the landfill along with the excavated soils from the Soil Washing Area. If PCBs are > 10 mg/kg it will be disposed off site.
Soil Washing Area - Overview:
1) The Soil Washing Area perimeter, which will delineate the area of PCB soil that is Weston's responsibility, is to be defined by AFCEE & Weston &/or by using the surveyed area as shown in Maps 1-5 to the extent practicable (The Air Force is responsible for remediating areas outside of the perimeter as defined above).
2) Surface soil in this area was characterized during the AECOM site investigation.
a) The site investigation sample results will be used to set up exclusion areas for sampling. PCB soil results <10 mg/kg & > 1 mg/kg will be used for the boundaries within the area for which Weston will be responsible.
b) For consistency purposes, the same site investigation surface soil sample locations will be used to collect additional soil samples at depth in order to characterize the subsurface soil & further delineate the extent of contaminated soil prior to removal activities.
3) Initial sampling for PCB levels will be conducted prior to equipment delivery on site. The initial sampling will consist of one analytical sample from the center of a 15-ft by 15"ft grid using the same grid centers as used by AECOM in their sampling.
For additional information see site file. |
Louis Howard |
| 4/6/2011 |
Document, Report, or Work plan Review - other |
Email message re: Site Characterization Report responses to comments are acceptable and document may be finalized. |
Louis Howard |
| 5/4/2011 |
Update or Other Action |
Draft Soil Characterization & Disposal Work Plan received. This WP describes polychlorinated biphenyl (PCB) soil excavation & disposal procedures, soil & GW sampling efforts, & landspreading protocol for soils affected by petroleum, oils, & lubricants (POL). Guidelines for soil sampling presented herein are consistent with state & federal sampling policies & procedures. During the course of fieldwork to be conducted during 2011, the NVPH will perform the following activities.
Excavate PCB-contaminated soil, place this material in Super Sacks, & ship it offsite to be disposed of in a certified landfill.
Excavate & stockpile POL-contaminated soil. This material will be treated onsite, with landspreading.
Of the 10 soil AOCs present at the Former RRS, excavation of PCB-contaminated soil will occur at 7 & possibly 8 AOCs.
No additional excavation or sampling activity is recommended for the road between the Former RRS Pad & the Port Heiden Airport in 2011. There remains some uncertainty about what entity or entities are responsible for this AOC. Until oversight & financial responsibility can be equitably established, no action can be recommended.
It is also anticipated that excavation activities will not occur at the NLF in 2011. This location is a fair distance from the Former RRS Pad & the excavation will likely be slow because buried surprises are anticipated to be found in this old landfill; therefore, it is suggested that the NLF be addressed in 2012. Additionally, as is the case with the road between the Former RRS & the Port Heiden Airport, there remains some uncertainty about who is responsible for oversight & funding at this AOC.
Estimated volumes of PCB-contaminated soil at 8 of the 10 The POL stockpiles & the road AOC have been excluded. Tight volumes are loose volumes. The loose volumes assume a 25 percent expansion factor after affected soils have been excavated.
The NVPH will excavate PCB-contaminated soil (concentrations that exceed 1 mg/kg) from the Former RRS, place the material in Super Sacks, & transport it to the Staging Area near the beach. Analytical sample results & surveying coordinates gathered in 2009 & 2010 will be used to guide these activities.
Disposal of soils with PCB concentrations greater than 50 mg/kg, when encountered, will be guided by the Toxic Substances Control Act (TSCA) regulations in Title 40, Part 761, of the Code of Federal Regulations (40 CFR 761), in Subpart D, Sections 50 to 79. Specifically, when PCB samples are collected upon removing a given lift, the relevant sample identification will be written on the appropriate Super Sack. Upon receipt of analytical results, each Super Sack with a concentration in excess of 50 mg/kg of PCB will be manifested for off-site disposal according to TSCA regulations.
The landfill chosen for disposal will meet the acceptability criteria presented in 40 CFR 300.440. Specifically, these soils will be disposed of in a hazardous waste landfill permitted by the U.S. Environmental Protection Agency (EPA) under Section 3004 of the Resource Conservation & Recovery Act (RCRA) or by a state authorized under Section 3006 of RCRA. The landfill should have no recent violations or significant deviations from regulations, compliance order provisions, or permit conditions. This landfill will be identified upon selection of the barge/disposal contractor that will transport the material off site during fall 2011.
With the exception of the POL stockpiles & RRS road, 8 of the 10 Former RRS AOCs contain locations at which PCB concentrations exceed 1 mg/kg. At each location, the same procedures will be followed. The perimeter of each location will be relocated using the existing survey coordinates & will be staked & flagged. Material will then be excavated in “lifts”; the thickness of each lift.
FCS/PG1 PCB Excavation Area: Before excavating this location in 2011, it is recommended that the top approximately 16 inches of clean cover be removed & stockpiled. Material deeper than this level will thereafter be excavated in accordance with guidelines presented in Section 4.3.1. It is estimated this AOC will yield approximately 1,100 loose CY.
BLO/SSO Excavation Areas:
PCB Excavation Area
The BLO/SSO has one location from which PCB-contaminated soil will be excavated. It is estimated this AOC will yield approximately 550 loose CY.
POL Excavation Area
The BLO/SSO has one location from which POL-contaminated soil will be excavated. This location was identified in 2009 during Weston’s field activities. The POL-contaminated soil will be hauled to the POL stockpiles.
|
Louis Howard |
| 5/4/2011 |
Update or Other Action |
Staff received the draft Work Plan Addendum (WPA) of the (2009) Port Heiden Radio Relay Station (RRS) Cleanup Project Work Plan (WP), to address field activities planned for completing the revised scope of services under task orders (TO) 305 & 334. These TOs were issued by the United States Air Force (USAF) 611th Civil Engineer Squadron (CES) for the Port Heiden RRS Cleanup Project, located in Port Heiden, Alaska. This addendum addresses the Landfill & Soil Washing Area Cleanup & Removal portion of the revised scope of work, & includes the decontamination & removal of previously used DMC equipment, that remains on-site, & the characterization & potential removal of soils within the Tank Abandonment Area.
The Class III landfill remediation at Port Heiden RRS will consist of the excavation & proper disposal of washed soils containing =10 mg/kg PCB concentrations, miscellaneous debris, & liners within Cells 2 & 3 of the landfill area. The excavation will be guided using visual & olfactory methods & will continue until confirmation samples indicate all washed soils have been removed.
Landfill excavation will begin by removing the top 2 feet of clean overburden (cap) & pulling back the existing liner to expose the contaminated soils. This portion of cap will be staged on cap areas that will not be disturbed, for later reuse. When debris is encountered during the removal of washed soils, it will be segregated within the landfill cell with the excavator bucket for later removal after the washed soil removal is complete. Washed soils excavated from the landfill for disposal will be placed into 5 CY supersacks on a lined area. PCB concentration levels for disposal will be based on AECOM sample results & will be marked on each supersack after being filled.
Upon reaching the original floor of the landfill, after the removal of all washed soils & debris, confirmation sampling will take place from the landfill floor & side walls (Section 4.0). Excavation will continue until PCB confirmation results are <10 mg/kg. Once excavation of the landfill is complete, Cells 2 & 3 will be backfilled with PCB-contaminated soil ranging =1 mg/kg but <10 mg/kg from the Soil Washing Area. To ensure the rear wheels of the dump trucks are kept clean, an 8-inch x 8–inch timber will be secured into position at the entrance of each landfill cell when the PCB-contaminated soils are being placed into the landfill cells. After backfilling is complete, the cap of clean overburden will be replaced to a depth of 2 feet & regraded to ensure proper runoff, & the cap will be seeded.
Prior to soil removal activities, a clean area will be established along the road that runs through the northwestern portion of the Soil Washing Area (Figure-5 [Attachment A]). This area will be excavated to a depth below PCB contamination of 1 mg/kg starting from the southwest side & working towards the northeast side. The road will act as a decontaminated area for dump trucks to use while transporting soils to either the landfill or beach staging area. Dump truck routes will be clearly marked using survey tape &/or lathe to prevent deviation into PCB-contaminated areas.
All soils identified by AECOM & the April 2011 sampling as having =10 mg/kg of PCBs will be placed in supersacks, decontaminated as discussed in Section 3.3, & transported to the beach staging area to await removal. As dump trucks rotate through the Soil Washing Area the excavator will load soil =1 mg/kg but <10 mg/kg, as indicated by AECOM & the April 2011 sampling, across only one side of the dump truck beds. Before departing the Soil Washing Area any soils & dust on the top rails of the bed will be brushed into the main bucket. Contaminated soils on the bottom outside rails of the trucks will be brushed into 5 gallon (gal) buckets.
During excavation of the exclusion area, PCB contamination data gaps from the area that formerly housed DMC’s two sump tanks & large alcohol mixing tank will be filled. Samples were not taken during the April 2011 field effort due to the depths in the bottoms of the tanks. An excavator will remove soil to the estimated depths of the bottoms of the tanks.
All soil excavated above the bottoms of the tanks will be assumed PCB-contaminated >10 mg/kg & will be loaded into supersacks over a lined area. Supersacks will then be brushed off to remove all contaminated soils & be transported to the beach staging area to await transport off-site. Soil samples will be taken every 4 inches below ground surface (bgs), starting at the former depth of the bottoms of the tanks.
For additional information see site file.
|
Louis Howard |
| 5/4/2011 |
Update or Other Action |
PCB soil removal action plan for site road received. The selected remedy for the PCB-contaminated roadway is a phased removal action of the PCB-contaminated soil exceeding the ADEC Method Two cleanup criteria of 1 mg/kg. The roadway consists of a 2-lane gravel road, approximately 22’ wide, connecting the Port Heiden RRS & the airport. Phase I will be an IRA & will focus on the portion of the roadway containing PCB levels > 10 mg/kg, to allow industrial usage of the roadway for approximately 4 weeks in July & August 2011. Phase II will finalize the removal action by excavating the roadway soil with PCB levels greater than 1 mg/kg, & staging the material in Super Sacks® &/or stockpiles pending offsite transportation & disposal.
Phase I will consist of the following:
The three locations identified in Additional Soil Sampling Technical Memorandum (NVPH 2011) as having PCB levels > 25 mg/kg will be excavated & either placed in Super Sacks® or staged into the appropriate stockpiles, as described below. Contaminated soil will be removed by excavating 1 cubic yard at each contaminated site, then backfilling with clean fill.
The entire roadway will be sampled using a composite sampling approach with eight subsamples collected from each 100-foot section of roadway. Subsamples will be spaced 25’ apart & located in the center of each lane.
PCB-contaminated soil with levels of > or = 50 mg/kg shall be excavated, segregated, & staged in Super Sacks® assuming only a limited portion of the roadway contains levels > or = 50 mg/kg. Other containment options (open-top containers or stockpiles) may be utilized if significant portions of the roadway contain these higher PCB levels. This soil will be transported offsite for disposal during the 2011 field effort.
Soil containing PCBs > or = 25 mg/kg & < 50 mg/kg will be excavated, segregated, & staged in stockpiles.
All soils containing PCBs greater than 10 mg/kg will be removed from the road surface to allow industrial usage of the roadway. This soil & any additional soil with PCB levels > 1 mg/kg will staged in stockpiles.
Roadway samples for Phase I will be analyzed via an onsite lab utilizing a gas chromatograph (GC). Samples collected for stockpile pre- & post-construction, onsite lab correlation, & excavation confirmation (when levels < 1 mg/kg are expected) will be analyzed by the fixed lab [SGS-Alaska]).
Phase II will consist of the following:
All soil, whether surface or sub-surface within the roadway, with PCB levels > 1 mg/kg shall be excavated, staged, & segregated as described above. Contaminated soils will be contained in Super Sacks®, stockpile(s), or other approved containers.
Analytical sampling via an onsite lab will aid in guiding excavation activities, soil segregation, & waste stream characterization. During the initial phase of the TCRA, samples were analyzed by both the onsite lab & the fixed lab (SGS-Alaska) to develop a correlation between the two results. Results reported by SGS-Alaska were approximately 2.3 times greater than those reported by the onsite lab, presumably due to the different extraction methods. Based on this correlation, all results from the onsite lab greater than 0.2 mg/kg will be assumed to potentially exceed 1.0 mg/kg, & further analysis will likely be necessary.
Confirmation soil samples will be collected & analyzed to ensure cleanup levels have been met. All samples used to confirm that PCB levels are < 1 mg/kg will be analyzed by SGS-Alaska. Confirmation samples will be collected using an EPA-specified grid sampling system. Once ADEC cleanup criteria is met, locally available clean fill will be used to return the roadway to a usable state.
All excavated soil will be handled in accordance the 40 CFR Part 761 (TSCA) requirements. Soil containing PCB levels > or = 50 mg/kg will be contained in Super Sacks® or other approved containers & will be shipped to a permitted Subtitle C landfill during the 2011 field effort.
Soil containing PCB levels > or = 25 mg/kg but < 50 mg/kg will be segregated, contained in stockpiles, & shipped to a permitted, approved Subtitle D landfill as soon as practical. If these stockpiles must remain onsite for the winter, a fence & signage will be installed around the stockpile(s) in accordance with 40 CFR 761. Soil containing PCB levels < 25 mg/kg but > or = 1 mg/kg will be contained in stockpiles onsite & will be shipped to a permitted, approved Subtitle D landfill. All stockpiles will be constructed as long-term stockpiles. |
Louis Howard |
| 5/4/2011 |
Update or Other Action |
Draft QAPP for the former Port Heiden Radio Relay Station received. Before samples are collected, the site ground surface may be inspected to help determine field sampling approaches and locations. Inspection results will be recorded in the field logbook. Inspection activities may include the following:
-Inspect for aboveground utilities
- Locate underground utilities
- Visually inspect for surface indications of releases
Field screening methods will not be used to characterize polychlorinated biphenyls (PCBs) in site soils. It is assumed the uncertainty with correlations between field screening estimates and laboratory results and the time required to establish such will render these methods more trouble than they’re worth. Thus, the analytical laboratory has been contracted to provide 3-day turnaround times for soil samples with suspected PCB contamination.
A photoionization detector (PID) will be used during remedial activities to provide a rough characterization of petroleum, oils, and lubricants (POL) organic vapors present in site soils.
PIDs can measure groups of volatile organic compound (VOC) vapors in soil (using a headspace technique) or in air. PID results will be expressed as parts per million (ppm).
Although olfactory or visual methods can also be used to field screen, field screening techniques mentioned in this QAPP refer only to mechanical methods.
The PID will be used to support field screening during site investigations. If the soil is heavily contaminated, alternative screening techniques may be used.
The collection and analysis of soil samples are required to v erify that a site meets the cleanup requirements established by the ADEC. Samples should represent the soil remaining at the site and should be collected after contaminated soil has been removed or remediated. Sample locations and frequencies are described in the Draft Former Port Heiden Radio Relay Station Soil Characterization and Disposal Work Plan (NVPH, 2011).
If necessary, soils will be stockpiled in accordance with applicable ADEC regulations. It is not anticipated that soil stockpiles will be generated for this project; POL-contaminated soil will be deposited directly into a planned biocell.
However, if a stockpile must be generated during the remediation project, these guidelines will be adhered to. Characterizing stockpiled soil is necessary for determining whether treatment or disposal of the soil is needed. If treatment or disposal is required, adequate characterization will be necessary to accomplish the following:
- Select a method of treatment or disposal
- Establish baseline data for use in evaluating treatment effectiveness
Stockpiled soil will be characterized by laboratory analysis of discrete grab samples
collected from the stockpiles. |
Louis Howard |
| 5/5/2011 |
Document, Report, or Work plan Review - other |
Staff reviewed & commented on the Draft Work Plan PCB Soil Removal Action for Site Road at Former Port Heiden Radio Relay Station, May 3, 2011. ADEC will require the Air Force to include the borrow pit location in the text of the document (assume it is the source of the fill material) & sampling requirements to document clean soil (fill) is being used for backfilling activities &/or returning roadway to a usable state. There is no mention of the borrow pit, however there is a figure which shows a “Site Road Borrow Pit” on Figure A-5.
ADEC requests the Air Force clarify if confirmation samples will be collected during Phase I. Overview -4 (final bullet), Worksheet #11 (11-2), Worksheet #14 (14-1), etc. indicate they will be collected. If so, then include sampling protocol/design & example figure for confirmation sampling.
Scope of Work Phase II-The text states all soil, whether surface or sub-surface within the roadway, with PCB concentrations greater than 1 mg/kg shall be excavated, staged, & segregated. ADEC requests clarification on the term “all soil” & whether this includes the shoulders of the roadway & adjacent vegetated areas where it has been demonstrated to be contaminated above 1 mg/kg for total PCBs (See Figures 5, 6 & 7 of the Site Characterization Report – NVPH March 2011). If there is to be a follow-up effort beyond Phase II to address the shoulders of the roadway & other adjacent vegetated areas, then state it in the document.
Work Plan Organization ADEC requests the Air Force provide a copy of the addendum for review & comment which further details the approach & methods for Phase II that will be completed prior to beginning that phase of the project (especially if the Air Force is going to try to excavate to 1 mg/kg this field season, if time allows).
ADEC requests the Air Force include the EPA’s Region 10 Regional PCB Coordinator: Daniel Duncan (duncan.daniel@epa.gov), (206) 553-6693), as a recipient of the approved QAPP & subsequent revisions, addenda, & amendments as well as this work plan for his review/files. While ADEC may comment on other state & federal laws & regulations, our comments on the plan does not relieve the Air Force or contractors, agents or other persons acting on its behalf from the need to comply with other applicable laws & regulations.
Worksheet #9 Project Scoping Session Participants The text states: “Soil greater than or equal to 25 mg/kg & less than 50 mg/kg will be segregated & placed into a stockpile(s) pending transport & disposal.” ADEC requests the Air Force consider placing this soil into Super Sacks® instead of stockpiling on site. This soil will also have to be shipped off-site & not be disposed of on-site & it would be more efficient to place the soil in Super Sacks® in the first place instead of doing it at a later time.
Consensus Decision item not shown here was for the Air Force to coordinate with Daniel Duncan from EPA Region 10’s Regional PCB Coordinator regarding his involvement on this project since PCBs are present in the soil greater than 50 mg/kg. His name is on the cover sheet, but he is not mentioned anywhere else in the document.
Worksheet #11 Project Quality Objectives/Systematic Planning Process Statements-The text states that ninety-five (95) primary 8-point composite soil samples for PCBs – Field laboratory will be used for road surface characterization. ADEC requests the Air Force clarify how the composite results will be used in conjunction with the historical discrete results to make excavation/removal decisions. NVPH’s sampling interval for the road was based on 500’ spacing & the proposed sampling for this work plan is based on 100’ spacing.
Summary of Project Tasks-ADEC requests the Air Force confirm with the off-site disposal facility accept field screening samples as adequate waste characterization. Soil that is segregated based on field screening may need to be re-sampled prior to off-site disposal.
ADEC will require additional sampling beyond the 4 samples for post construction samples if there is a breach or tear in the liner material. Sampling will also be performed of the soil at the location of breached/torn liner.
The text also states: “…soil with PCB concentrations between 25 mg/kg & 50 mg/kg will be placed in TSCA-regulated stockpiles, which will include
fencing & signage in accordance with 40 CFR 761 if this soil will remain onsite during the winter. Soils with concentrations between 1 mg/kg & 25 mg/kg may be placed into stockpiles.” ADEC will require the Air Force to fencing & signage for all stockpiles with PCB contamination greater than 1 mg/kg total PCBs, not just those with concentrations between 25 mg/kg & 50 mg/kg total PCBs.
ADEC requests the Air Force rectify the discrepancies between waste characterization stockpile descriptions on Worksheet #14 & on Worksheet #17. |
Louis Howard |
| 5/5/2011 |
Update or Other Action |
Draft Groundwater Monitoring Work Plan received. This WP describes groundwater sampling efforts in support of the ongoing monitoring program at the Port Heiden RRS. Guidelines for groundwater sampling presented herein are consistent with state and federal sampling policies and procedures. According to guidance in the Port Heiden RRS Record of Decision (ROD; U.S. Air Force [USAF], 611th Civil Engineer Squadron [611 CES], 2009), analytical data from site samples will be compared to applicable 18 AAC 75 regulations to determine the extent of contamination and to formulate future remedial actions if warranted. A Quality Assurance Project Plan (QAPP;
NVPH, 2011b) and a Health and Safety Plan (HSP; NVPH, 2011a) have been prepared for the Former Port Heiden remediation project.
Upon concluding project activities at the end of each summer, a Groundwater Monitoring Report (GWMR) will be developed for each of the upcoming 2 years. The annual GWMR will present results and provide a summary of field activities performed during the prior work season; each will serve as an updated project summary. Recommendations will be presented in each GWMR to inform upcoming remedial actions as required. Each GWMR will meet the applicable reporting requirements identified in 18 AAC 75.380(b)(1-11).
DRO will be analyzed for groundwater samples from MW-04, MW-05, MW-06 and MW-07. FPC-215: DRO/BTEX analysis will be conducted from wells: MW-08, MW-09 and MW-10. Groundwater monitoring will be performed on an annual basis. To maintain consistency with previous years, samples will continue to be collected in early October. A GWMR will be prepared each year, after obtaining sampling results, to summarize groundwater characteristics at the three groundwater Port Heiden vicinity groundwater AOCs.
In addition to groundwater sampling, surface water and soil sampling will be conducted. This sampling will be performed based on recommendations from a 2010 field sampling report by DMC Technologies, Inc. (DMC, 2010).
FPC-074: A previous investigation conducted in 2004 indicated that surface water was affected at FPC-074. The pipeline was not in place adjacent to this site, and soil removal actions were not planned for FPC-074 in the 2008 work plan. The area was inspected periodically and after major rainfall events during the 2008 field effort. At no time was standing water observed in this area, except immediately adjacent to the roadway in a ditch. No evidence of contamination was observed in this area.
Surface water samples will be collected at FPC-074 if surface water is encountered during the field effort. The samples will be analyzed for BTEX and polynuclear aromatic hydrocarbons (PAHs).
FPC-086: All detected constituents in the surface water samples were below applicable ADEC Water Quality Standards (ADEC, 2009). No further surface water monitoring should be required. Soil sample analytical results indicate that DRO was the only detected COC that exceeded ADEC soil cleanup levels. The concentrations of all other COCs were below Table B1 and B2 cleanup levels. However, the method detection limit in one sample was above the cleanup level for benzene; therefore, the result for benzene from this sample was not usable to evaluate cleanup compliance. Additional soil investigation should be conducted at FPC-086 to determine the extent of impacts. Soil samples should be analyzed for DRO and BTEX. Soil samples will collected in the general area of the samples that were collected for the 2010 DMC report. The samples will be analyzed for DRO only. |
Louis Howard |
| 5/6/2011 |
Interim Removal Action Approved |
ADEC (J. Halverson) signed the Action Memorandum (AM) for a time-critical removal action of PCB contaminated soil at the former Port Heiden Radio Relay Station (RRS). The purpose of this AM is to document the decision by the U.S. Air Force (USAF) to conduct a Time-Critical Removal Action (TCRA) to remove Polychlorinated Biphenyls (PCB) contaminated soil from the access road (shoulders & adjacent areas) running from the Port Heiden airport to the Port Heiden RRS, Port Heiden, Alaska. This TCRA will be performed to prevent, limit, & mitigate a substantial threat to public health, welfare, or the environment.
The removal site evaluation pertains to PCB contaminated soil located on & in the vicinity of the access road to the Port Heiden RRS. During a 2009 removal action at the RRS, a dump truck overturned. During the clean-up from the truck accident, PCB-contaminated soil was identified on the access road. In 2010, additional samples were taken.
AF responsibility for the cleanup was not clear until early 2011. During a 2011 USACE TRIAD meeting for a Fort Morrow project, comments from community members indicated this road is used to access subsistence areas. With the road being used to haul subsistence foods back to community member's homes, sampling results indicated the food was subject to potential direct exposure to PCB-contaminated soil as the vehicles drove the access road raising a dust cloud. This is an on-going concern for community members as a new subsistence season is rapidly approaching.
The threats posed by the PCB-contaminated soils at the former Port Heiden RRS are time-critical based on their presence in the vicinity of nearby human populations, & plants & animals used as a subsistence food source. It is difficult to control access to the road, & due to the relatively flat & open terrain access points are almost unlimited.
The initial assessment of the site indicated traffic through the area has not substantially spread the PCB contamination; however more sampling off the road will be required. One other primary concern is the road use can create dust & it is possible PCB-contaminated dust could come into direct contact with people & subsistence foods.
PCBs are hazardous as determined by the Toxic Substances Control Act (TSCA) of 1976, CERCLA & ADEC regulations. The PCB levels in the soil exceed 50 mg/kg (the level at which the contaminated soil becomes a TSCA regulated waste) and present a threat to public health or welfare or the environment. The TCRA presented in this memorandum is consistent with 40 CFR 300.415(e)(8) - which states, "Containment, treatment, disposal, or incineration of hazardous materials - where needed to reduce the likelihood of human, animal, or food chain exposure."
This AM documents the decision for the TCRA for PCB contaminated soil on the access road to the former Port Heiden RRS & adjoining areas. This decision has been developed in accordance with CERCLA, as amended & is consistent with the NCP. This decision is based on the administrative record file for the site. Conditions at the site meet the NCP section 300.415(b)(2) criteria for determining that the removal action was appropriate. The EPA & the ADEC have been participants in the planning & implementation of this action & supported the recommended action.
The access road is to be remediated in 2011. The project is currently funded at $5,000,000 of $7,201,334 expected total requirement. Additional funding has been requested. The priority, to eliminate/reduce the current threat, will be the removal of the PCB-contaminated soil from the road (which is expected to be completed within the current funding). Then, as funding allows, the PCB-contaminated soil will be disposed of at appropriate permitted facility(s) in the Lower 48. If additional funds are not received in time to complete all disposal activities this year, the final disposition may not be completed until 2012.
A delayed action, or no action, will increase the potential for the migration of PCB contamination over a wider area and could affect subsistence resources, damage the environment, or endanger human health. PCB contamination will potentially impact area wildlife & therefore the AK Native subsistence resources. Contamination may potentially be transported to humans through the impacted wildlife & used for subsistence as well as direct exposure traveling the road.
These signatures by the AF (5/5/2011) & ADEC (5/6/2011) document the decision made to complete the TCRA for the access road to the Port Heiden RRS. By signing this AM, the ADEC concurs with the AF's selected TCRA. The decision may be reviewed & modified in the future if new information becomes available that indicates the presence of contaminants or exposures that may cause unacceptable risk to human health or the environment. If additional contaminants are discovered, USAF & ADEC will determine the compliance levels for soil cleanup actions. |
John Halverson |
| 5/12/2011 |
Document, Report, or Work plan Review - other |
US CORPS provided comments on the Draft Soil Characterization and Disposal Work Plan and Draft Groundwater Monitoring Work Plan by NVPH/Boretide Consulting. The ADEC’s Site Characterization Work Plan and Reporting Guidance for Investigation of Contaminated Sites states that a Cover Page is required. Also required are: Name and signature of qualified person who prepared the Work Plan, ADEC File number.
4.0 Scope of Work 2nd paragraph after bullets: This paragraph addresses the PCB removal along the road between the RRS and the Port Heiden Airport as not happening. In the recent emails being circulated, isn’t this PCB removal from the road occurring now or soon and being performed by Jacobs Engineering? If so, this paragraph needs to be rewritten.
Table 3: First line underneath PCB Contaminated Soil Concentration: “>100 – 25”. As written, this is confusing to me. Should it be >25, or 25 – 100 and another line added with >100? Recommend all ranges be consistently expressed as lowest number to highest number (e.g., 10 – 25 mg/kg, 0.5 – 1 ft, etc.).
Figure 12: It’s not clear to me what depths the results are coming from. Recommend adding corresponding depth(s) for each sample location presented. Suggest labeling the shaded polygons as proposed excavation area(s).
Figure 12: Recommend adding a symbol to the key identifying soil sample locations. Recommend adding something to the key that identifies what the squares represent.
Figure 13: Recommend adding a symbol to the key identifying soil sample locations.
Figure 14: Recommend adding something to the key that identifies what the squares represent. Recommend adding a symbol to the key identifying soil sample locations. Recommend identifying the soil sample depths corresponding to the presented results.
Figure 15: Recommend adding a symbol to the key identifying soil sample locations. Are these all surface soils.
Figure 16: Recommend adding a symbol to the key identifying soil sample locations.
Figure 18: Recommend adding a symbol to the key identifying soil sample locations. |
Louis Howard |
| 5/12/2011 |
Meeting or Teleconference Held |
ADEC received meeting notes from JACOBS.
Port Heiden Workplan Discussion
Meeting Agenda
May 12, 2011, 12:00 AK / 1:00 WA
Denali Conference Room
Call in number:
1-866-365-4406 seven digit code 7785157
1-866-365-4407
Attendees:
Kelly McGovern, Jacobs PM
Carrie Godden, Jacobs
Greg Rutkowski, Jacobs
Sava White, Jacobs
Jaclyn Christensen, Native Village of Port Heiden
Pat Roth, 611 CES/CEAR
Dan Duncan, EPA
Dave Bartus, EPA
1. Beyond Zero – Safety: Discussed summer and bike recreational safety
2. Port Heiden Overview: Kelly provided the overview of the project as it is outlined in the work plan. Included in this overview was the statement that Jacobs will surgically excavate the single > 50 ppm PCB spot and ship it off site this season. All other material will be stockpiled as generated with required fencing and signage. The goal for the initial effort taking place between now and June 16 is to remove contaminated soil from the road to provide a drivable road surface with less than 1 ppm. Jaclyn Christensen stated that the overall purpose is to clean up this site for the health community. There was discussion about an addendum to this work plan later in the season.
3. EPA comments and discussion
EPA representatives Dan Duncan and Dave Bartus confirmed that ADEC is the lead agency for this project. EPA did not have any comments or concerns about the work plan or project at this time. There is no requirement to submit the Formal Notification Procedures to EPA on form 7710-53.
4. Open Discussion
Pat asked for Jacobs to check on the fencing requirements for the stockpiles and to send out meeting notes. |
Louis Howard |
| 5/13/2011 |
Update or Other Action |
WESTON preliminary sample results received from the 611th. WESTON took 29 screening samples approximately every 0.3 miles (every 1,580 feet). From the soil washing area down the main haul road towards the airfield and the last sample we took was the hit of around 4 mg/kg. From the far side of the runway along the haul road to the landfill. WESTON did not sample in the middle of the HUD housing area but sampled on both side of it to try not to raise concerns locally. From the beach landing up the road parallel to the water to where this road intersects with the road between the airfield and the landfill.
Sample RDS-003-01-0 was the only one at 4.8 mg/kg total PCBs exceeding the cleanup level of 1 mg/kg.
|
Louis Howard |
| 5/16/2011 |
Document, Report, or Work plan Review - other |
ADEC Contaminated Sites Program reviewed and commented on the draft work plan addendum.
Cover Letter
ADEC will require the AF provide a written concurrence for our files from the NVPH regarding the disposal of PCB-contaminated soil (10 mg/kg or less) into their Class III landfill (ADEC SW Permit No. SW3A069-14) from field activities this year.
Section 1.1: It was ADEC’s understanding the AF was to completely remove all washed soils from cells 2 & 3 without further characterization for offsite disposal.
ADEC expects the AF to address all of the DMC contaminated equipment, PPE, the tank associated with past soil washing/remediation activities the 611th removed from the ADOT area, & other materials located within the connex boxes & the connex boxes themselves located behind the ADOT building & at the landfill.
Section 3-1: Since these two activities are taken in accordance with & satisfying the requirements of the 42 USC 9601 et seq.; E.O. 12580 & the NCP, 40 CFR 300, no permit is required for a SWPP for the excavation at the soil washing area or surface water discharge of contaminated decontamination water after it has been treated with granular activated carbon system on-site versus disposed of off-site. The Off-Site Rule applies to wastes generated from CERCLA-authorized cleanups that are sent off-site for management. CERCLA-authorized cleanups include those taken under lead-agency authority, Consent Orders, Consent Agreements, & Consent Decrees.
Acquisition of permits is not required for on-site remedial actions. However, this does not remove the requirement to meet (or waive) the substantive provisions of permitting regulations that are applicable or relevant & appropriate requirements (ARARs). Federal, State, & local permits are not required for Fund-financed action or remedial actions taken pursuant to Federal action under section 106 of CERCLA.
Section 3.3: ADEC had previously thought the AF will remove all washed soils & all miscellaneous items that are currently mixed with these soils from the Class III landfill (Cells 2 & 3) & transport & dispose off site. No recharacterization of the washed soils will take place in attempt to segregate the washed soils above 10 mg/kg & the washed soils below 10 mg/kg to leave a portion of the washed soils in the Class III landfill.
The text states Supersacks containing PCBs > 50 mg/kg will be properly marked for removal as Toxic Substance Control Act (TSCA) wastes. Supersacks containing TSCA level soils (>50 mg/kg PCBs) will be staged separately from supersacks of non-TSCA soils. According to EPA Region 10 TSCA program (Dave Bartus email communication May 6, 2011) “The definition of PCB remediation waste at 40 CFR 761.3 includes materials that are currently at concentrations less than 50 ppm, if they are from sources unauthorized for use, as well as from sources >= 500 ppm beginning April 18, 1978, or >= 50 ppm beginning July 2, 1979. Given the history of Port Heiden, which the ROD documents as being in operation as late as 1981, it is possible some soils <50 ppm are regulated for disposal under 40 CFR 761.61”
ADEC requests the AF confirm whether or not the permitted disposal facility will accept AECOM’s sampling grid of 10 by 10 meters as adequate characterization for disposal at their facility.
Section 4.2.1: Soil cannot be backfilled into soil wash area. Previous sampling documents PCBs >1 mg/kg. MI (MULTI INCREMENT® is a registered trademark of EnviroStat, Inc.) results from excavated soil that are <1 mg/kg are considered dilution, which is not allowed. If this does occur, the stockpile will still be considered >1 mg/kg & <10 mg/kg & be required to be disposed of in the landfill.
Lab. ADEC requests the AF specify the ADEC approved lab that will be performing the MI sample processing & analysis. Lab MI SOP may be requested for review by department.
It is recommended all sample processing be performed at the lab. Therefore, the bulk MI sample should be shipped to the lab & sample processing text (drying, sieving, subsampling, etc.) removed from workplan.
Table 4: Example Bucket Loads Chart – ADEC requests the AF clarify how this table is used. It appears only to be an example of triplicate sampling for a 180 bucket excavation and 30 increment MI sample.
ADEC requests the AF explain why there is the third DU proposed for triplicate sampling. Approval to move and dispose soil will only be given based on the 95% UCL calculated results. ADEC requests the AF clarify whether the three stockpiles (at a minimum) remain onsite awaiting lab results.
ADEC requests the AF specify how duplicate/triplicate samples will be taken for excavations less than 50 & 120 buckets.
The final mass (30 to 50 g) is not subsampled by the lab. Again, it is recommended the text be removed and the bulk MI sample be submitted to an approved lab for processing & analysis. |
Louis Howard |
| 5/17/2011 |
Document, Report, or Work plan Review - other |
May 17,2011
Subject: Draft Port Heiden Work Plan Addendum - Solid Waste Program Comments
Solid Waste (Lori Aldrich) sent out a comment letter on the Draft Work Plan Addendum.
The Alaska Department of Environmental Conservation (ADEC) Solid Waste Program has reviewed the Port Heiden Radio Relay Station (RRS) Draft Work Plan Addendum (Plan), dated May 3, 2011. The Plan was submitted for remediation of remaining polychlorinated biphenyl (PCB) contamination at the Port Heiden RRS and Port Heiden Landfill, and in response to the ADEC comment letter on the Port Heiden PCB Contaminated Soils - Proposed Corrective Action Approach - Revision 4, dated March 15, 2011.
I have also reviewed comments submitted by you on May 6, 2011, and the comments submitted by Louis Howard, ADEC Contaminate Sites Program, on May 16, 2011. In addition to these comment regarding the Port Heiden Landfill, the Plan fails to address the following comment from the March 15, 2011 letter:
Based on the ProUCL documentation presented by Weston, it appears that the landfill samples with 21 mg/kg and 23 mg/kg PCB are outliers for the data distribution: The correlation study also showed only a very weak correlation between the screening levels and the laboratory analysis. ADEC will require Weston to obtain additional approval from NVPH to leave the higher concentrations in place, or perform spot removal of the identified areas with confirmation sampling.
The final Plan must clarify the chosen option for these areas surrounding the AECOM sample points with levels of21 mg/kg and 23 mg/kg PCB. Spot removal must include work and sampling plans; a proposal to leave the waste in place must include specific approval by the Native Village of Port Heiden in a Memorandum of Agreement, and a request for modification of the original ADEC approval for disposal of polluted soil at the Port Heiden Landfill, dated May 29, 2009.
Please contact me at (907) 269-7622 or by email at Lori.Aldrich@Alaska.gov if you have any comments or questions.
|
Louis Howard |
| 6/6/2011 |
Update or Other Action |
Settlement & Release Agreement received for NVPH & WESTON. WHEREAS, Weston was retained by the United States Air Force ("USAF") to perform various remediation services between 2009 & 2011 ("the Remediation") in connection with the Port Heiden Radio Relay Station ("Radio Relay Station") in Port Heiden, Alaska, including demolition & debris removal, & removal of polychlorinated biphenyl ("PCB')-contaminated soil;
WHEREAS, the Council constructed a Class III Municipal Solid Waste Disposal Facility in Port Heiden, Alaska (the "Landfill") for the purpose of receiving contaminated soil & other debris from the Remediation at the Radio Relay Station, & received Solid Waste Permit No. SW3A069-14 from the Alaska Department of Environmental Conservation ("ADEC") as well as authorization from ADEC to dispose of ceI1ain polluted soils at the Landfill in accordance with a regulator approved Work Plan for the Remediation;
WHEREAS, the Council has asserted certain claims arising from the Remediation, which Weston denies, & Weston has proposed a corrective action approach for additional work during the contract period, a copy of which is attached as Exhibit 1 ("Corrective Action Approach");
WHEREAS, the Corrective Action Approach has been accepted by ADEC & the Council;
WHEREAS, Weston is preparing a Corrective Action Work Plan to implement "the Corrective Action Approach & that Corrective Action Work Plan will be submitted for review by ADEC, USAF, & Council;
NOW THEREFORE, in consideration of the mutual covenants & promises contained herein, & other valuable consideration, the receipt & sufficiency of which is acknowledged,
(a) Subject to the terms of this Agreement, & in consideration of the covenants set forth herein & in full settlement & release of any potential claims against Weston, Weston shall pay the sum of$1,500,000to the Council as follows in paragraphs (b) & (c).
(b) Payment of $750,000 shall be made by Weston to the Council no later than thirty (30) days after approval of the Corrective Action Work Plan by USAF, ADEC, & the Council.
(c) Payment of $750,000 shall be made by Weston to the Council no later than thirty (30) days after completion of the work specified in the Corrective Action Work Plan.
Subject to the conditions below & in consideration of the covenants set forth herein, Weston agrees to perform or arrange for the performance of the work to be governed by & conducted in accordance with the Corrective' Action Work Plan at the Landfill & Radio Relay Station, contingent upon applicable approvals & completion of the Air Force's remediation of the Main Haul Road.
The Council hereby releases & discharges Weston & its agents, servants, officers, directors, employees, heirs, executors, administrators, representatives, insurance carriers, predecessors, successors, affiliates, assigns, parent & subsidiaries, members, related entities, & representatives of any of them from, & relinquishes, all rights, claims & actions that the Council now has against Weston. With this settlement & release, the Council intends to settle, release, & forever discharge Weston from all liability for all claims or actions for all known & unknown, manifested & unmanifested, suspected & unanticipated damages, injuries, &/or statutory or regulatory rights existing at the time of execution of the Agreement.
In addition, If Weston performs the work in accordance with the Corrective Action Work Plan, the Council hereby forever releases & discharges Weston & its agents, servants, officers, directors~ employees, heirs, executors, administrators, representatives, insurance carriers, predecessors, successors, affiliates, assigns, parent & subsidiaries, members, related entities, & representatives of any of them from, & relinquishes, all claims, known & unknown, andlor statutory or regulatory rights that may arise from or relate to performance of that work.
The Council hereby waives any stipulation, limitation or other requirement or right it may have that limits the volume of contaminated soil with PCB concentrations of less than 25 mg/kg that will be permitted to remain in the Landfill.
The Council hereby waives any stipulation, limitation or other requirement or right it may have that limits the volume of contaminated soil with PCB concentrations of less than 10 mg/kg that may be added to the Landfill. |
Louis Howard |
| 6/9/2011 |
Update or Other Action |
Contaminated Sites Program and Drinking Water Program, Laboratory Certification Officer, Lance Morris approves TestAmerica Anchorage-Port Heiden Mobile Lab (UST-093) for analysis of Aroclor-1260 (PCB-1260) in soil, which expires June 7, 2012. |
Louis Howard |
| 7/15/2011 |
Cleanup Plan Approved |
Lori Aldrich (ADEC Solid Waste Program) sent a letter to Pat Roth 611 CES/CEAR. Subject: Amendment to Approval of Disposal of Polluted Soil in the Port Heiden Landfill.
The Alaska Department of Environmental Conservation (ADEC) Solid Waste Program has reviewed the request, submitted by Weston Solutions, Inc. (Weston), to amend the ADEC Approval for the Disposal of Polluted Soil (Approval), dated May 29, 2009. The Approval allowed polychlorinated biphenyl (PCB) contaminated soil with a concentration of less than 10 mg/kg to be disposed in a secure cell at the Port Heiden Landfill. Weston has requested that the Approval be modified to allow soil, already in place at the landfill, with identified concentrations of 10 - 23 mg/kg PCB to remain at the landfill.
The soils disposed at the landfill were generated from the clean-up of the U.S. Air Force Port Heiden Radio Relay Station (Port Heiden RRS) under an ADEC approved work plan & the original Approval. Subsequent third party (AECOM) sampling of the landfill found levels of PCBs exceeding the 10 mg/kg limit. Weston agreed to remove all the soils disposed at the landfill that had been treated by washing, which left only a small number of un-washed soil samples that exceeded 10 mg/kg.
A statistical analysis of the AECOM sampling data showed that that landfill samples with 21 mg/kg & 23 mg/kg PCB were outliers for the data distribution. A correlation study of Weston's data for PCB screening levels versus the laboratory analysis also showed only a very weak correlation. ADEC determined that the outlier samples could not be considered to meet the requirements for statistical confidence, & would need Jo be addressed either by removal or additional approval.
In support of their request, Weston demonstrated through fate & transport models for 30 mg/kg PCBs & 50 mg/kg PCBs that soil contaminants are not likely migrate from the disposal site. Weston also presented a Settlement & Release Agreement with the Native Council of Port Heiden (NCPH) which includes NCPH approval to allow the soil in question to remain in the landfill.
ADEC has determined that the allowing the soil to remain in place is not likely to cause a threat to the public or to the environment. ADEC approves the request to leave the un-washed soil in place, with the following stipulations:
1. All identified washed soil must be removed from the landfill. Only un-washed soil with a polychlorinated biphenyl (PCB) concentration of less than 10 mg/kg, based on the approved sampling plan, may added to the disposal area at the landfill.
2. The final soil cap must consist of at least 2 feet of soil material, with the top 6 inches
consisting of sufficient organic material to support vegetation.
3. The polluted soil disposal site must be completely fenced, separate from the public landfill area. The gate must be kept locked.
4. Weston must submit a final report within 90 days of completion of the washed soil removal & un-washed soil disposal project, including:
• as-built drawings of the cell
• quantity of washed soil removed from the cell
• confirmation sampling for washed soil removal
• quantity of new unwashed disposed soil
• soil sampling results for all additional soil disposed at the landfill
• photographs of the disposal cell while in operation & after it is completed
• the appropriate notation to the deed of the property
This approval is specific to soil from the Port Heiden RRS intended for disposal at the Port Heiden Landfill & does not represent a general ADEC policy. Similarly, the conditions described in this authorization are site-specific conditions applicable only to this project.
ADEC will require additional investigation, assessment, monitoring, or remediation if new information regarding conditions at the landfill indicates that further actions are necessary to protect human health or the environment. |
Louis Howard |
| 7/26/2011 |
Document, Report, or Work plan Review - other |
Staff provided comments on the Draft Port Heiden Work Plan Addendum PCB Soil Removal Action For Site Road July 2011 Contract No. W911KB-06-D-0006, Task Order No. 46.
Overview-2 and -3 Scope of Work:ADEC requests the Air Force include the correlation data with for all the samples used to compare field laboratory sample with fixed laboratory sample results. ADEC will require all results greater than 0.2 mg/kg from the onsite laboratory will be assumed to exceed 1.0 mg/kg. See Appendix C PCB Analysis Laboratory Results-specifically see:
Road Section RD028 Sample ID 11PH-RD028-E4-36 (Jacobs Field Lab 0.33 mg/kg and Fixed Lab SGS 2.53 mg/kg, 7.6 times greater than those reported by Jacobs)
Sample ID 11PH-RD028-F3-36 (Jacobs Field Lab 0.36 mg/kg and Fixed Lab SGS 1.12 mg/kg, 3.2 times greater than those reported by Jacobs) and
Road Section RD092 Sample ID 11PH-RD092-D3-R-36 (Jacobs Field Lab 0.29 mg/kg and Fixed Lab SGS 1.51 mg/kg, 5.2 times greater than those reported by Jacobs).
Use of 0.4 mg/kg screening data (Onsite Lab) would leave behind PCBs greater than 1 mg/kg. All results from the onsite laboratory (Jacobs) greater than 0.2 mg/kg shall be assumed to exceed 1 mg/kg for PCBs. ADEC considers the onsite laboratory results to be field screening level data which requires final confirmation by a certified off-site laboratory (SGS) to demonstrate compliance with 18 AAC 75.
Overview-3 2nd Bullet: Road Shoulder Characterization Sampling
ADEC will require 100% confirmation from each layer of composite samples (0”-6” and 6”-12” bgs) to be sent off for analysis at SGS-Alaska to show that cleanup levels have not been exceeded and are below 1 mg/kg total PCBs. See comment #1 above regarding the composite sample concentration required to be 0.2 mg/kg (onsite analysis) for the threshold level when soil will be excavated and stockpiled or delineated further.
For each 100 linear feet of road shoulder, if the onsite analysis is less than 0.2 mg/kg, then one confirmation sample will need to be taken from each layer (0-6” and 6”-12” bgs) and sent off-site (SGS Lab).
The Work Plan Addendum does not describe how excavation and confirmation sampling will proceed, once the road shoulders/tundra and road sub-surface areas has been characterized. |
Louis Howard |
| 8/3/2011 |
Update or Other Action |
Super sacks that fell off the 40’ Flat bed truck around 11:00 am this morning. While transporting super sacks from the Landfill area to the Barge Landing area one 5 cy super sack rolled off the truck bed. In previous trips the super sacks have been more stable, but with all the rain, the super sacks are getting rain water into the super sack thru the zipper on top. The super sack is still for the most part in-tack, with the exception of the one area on the top portion of the super sack (near the Zipper) were some soil has leaked out upon impact.
Estimated that there is 2-5 gallon buckets of TSCA regulated soil on the ground. Crews trans-loading the soil from this super sack into a new one via hand shovels. Quantity of PCBs spilled was calculated based on a preliminary, worst case estimate that ~10 gallons of soil (1.33 cu. ft.) at a density of 130 lbs/cu. ft. for an estimated 173.33 lbs of soil. The highest PCB detection from where soils were removed was 74 ppm, and this was conservatively increased to a PCB concentration of 100 ppm. These conservative quantity spilled and contaminant level gives a maximum of 0.017 lbs of PCB released. The actual volume released was only 2 gallons of spilled soil which were recovered from torn zipper location."
No soil has gone into the ditch line and no soil was spilled along the scrape line of the bag.
Title II oversight agrees that no soil leak out in the scrape area as outlined, but will sample to confirm. This super sack is from cell 2 of the landfill (DMC’s washed Soil), which is greater than 50 mg/kg. Materials were contained in new 5-yd super sack, and transported to staging area with other super sacked PCB contaminated soils pending transportation this fall.
Future bags will be tie down while in transport mode and other super sacks awaiting transportation will be covered to prevent any further water from entering the super sack. |
Louis Howard |
| 8/3/2011 |
Update or Other Action |
Letter from 611 CES/CEAR (Pat Roth) to ADEC SW Program (Lori Aldrich) Subject: Disposal of PCB-Contaminate Soil (less than 10 ppm), Port Heiden RRS & NVPH (Gerda Kosbruk)
As you know, Weston is excavating debris & pcb-contaminated soil from the Class III landfill in Port Heiden in accordance with the plans & agreements made with your office & the Native Village of Port Heiden. Weston is excavating more debris & soils than anticipated. While they will be backfilling with soils (less than 10 ppm) from the Soil Washing Area, we anticipate a gap of approximately 1,000 cubic yards.
In lieu of Weston using clean backfill to bring the landfill up to grade, the AF is requesting other pcb-contaminated soils (less than 10 ppm) from the Radio Relay Station be disposed of in the landfill. The quantity to be disposed of will be limited to what is required to bring the landfill back up to grade. At that time, the cap will be replaced.
This work is in accordance with the original approval for Disposal of Polluted Soil in the Port Heiden Landfill, dated May 29, 2009 & amendment, dated July, 15, 2011. Signed Pat Roth Remedial Project Manager.
The Native Village of Port Heiden, as owner/operator of the Class III landfill, concurs with the above information & request approval from ADEC. Work Plans/Sampling Plans will be submitted as necessary to both the Solid Waste & Contaminated Sites Departments. Once the landfill has been brought up to grade, the remaining pcb-contaminated soils (greater than or equal to 1 ppm) will be shipped to a permitted disposal facility in the Lower 48. Signed Gerda Kosbruk NVPH Administrator.
|
Louis Howard |
| 8/3/2011 |
Update or Other Action |
Letter from Air Force (Pat Roth) to Solid Waste (Lori Aldrich)
SUBJECT: Disposal of PCB-Contaminate Soil (less than 10 ppm), Port Heiden RRS
As you know, Weston is excavating debris and pcb-contaminated soil from the Class III landfill in Port Heiden in accordance with the plans and agreements made with your office and the Native Village of Port Heiden. Weston is excavating more debris and soils than anticipated. While they will be backfilling with soils (less than 1 0 ppm) from the Soil Washing Area, we anticipate a gap of approximately 1,000 cubic yards.
In lieu of Weston using clean backfill to bring the landfill up to grade, the AF is requesting other pcb-contaminated soils (less than 10 ppm) from the Radio Relay Station be disposed of in the landfill. The quantity to be disposed of will be limited to what is required to bring the landfill back up to grade. At that time, the cap will be replaced.
This work is in accordance with the original approval for Disposal of Polluted Soil in the Port Heiden Landfill, dated May 29,2009 and amendment, dated July, 15,2011
The Native Village of Port Heiden, as owner/operator of the Class III landfill, concurs with the above information and request approval from ADEC. Work Plans/Sampling Plans will be submitted as necessary to both the Solid Waste and Contaminated Sites Departments. Once the landfill has been brought up to grade, the remaining pcb~contaminated soils (greater than or equal to 1 ppm) will be shipped to a permitted disposal facility in the Lower 48. |
Louis Howard |
| 8/4/2011 |
Update or Other Action |
Revised Tech Memo for landfill backfilling received. The following information is provided in compliance with Site Characterization Work Plan & Reporting Guidance for Investigation of Contaminated Sites, prepared by the Alaska Department of Environmental Conservation, September 23, 2009.
This technical memorandum, which serves as a work plan addendum, has been prepared to provide a technical approach to haul soil from the Former Port Heiden Radio Relay Station (RRS) to the Class III Landfill in Port Heiden, Alaska. Related fieldwork is described in the Final Soil Characterization & Disposal Work Plan, Port Heiden RRS, Port Heiden, Alaska (Native Village of Port Heiden, May 2011).
-In line with its existing agreements, Weston will finish removing contaminated soil from the Landfill.
- In line with its existing agreements, Weston will finish removing contaminated soil from the Soil Wash Area near the Former Port Heiden RRS. Depending on PCB contaminant levels, some of this material will be shipped off site in super sacks & some will be transported to the Landfill & used as backfill.
When Weston finishes hauling backfill soils from the Soil Wash Area to the Landfill, it is anticipated that additional backfill volumes will still be required. At this point, the CA Project will begin its backfill hauling operations. In doing so, the CA will meet the following stipulations:
-Only soils with a PCB concentration of between 1 & 10 milligrams per kilogram (mg/kg) will be hauled from the Former RRS to the Landfill.
-Approximately 10-CY end dumps will be used to haul the material. The bottoms & sides of each truck bed will be lined, & each load will be covered. As previously noted, the transport route is shown on Figure 1.
-Former RRS soils to be used as backfill will be excavated from Contaminated Soil Remediation Area 2 (CSR2). The CSR2 location from which these backfill soils will be removed is shown on Figure 2. Soil will deposited directly in the back of the lined end dumps, covered, & transported to the Landfill.
-CSR2 soils will be excavated in 1-foot thick lifts. According to sampling methodologies described in the Work Plan (Section 4.3.3), composite PCB samples will be collected from a 9-point grid for each 225-square feet of excavated area. Grid square excavations & subsequent sampling will proceed until PCB results are less than 1 mg/kg.
- Enough volume will be hauled to fill whatever empty space exists after Weston’s operations conclude. Although the exact quantity is unknown at this time, the material hauled will be sufficient so that the resultant Landfill cap will be smooth & consistently sloped. Any additional Former RRS soil the CA Project excavates with a PCB concentration in excess of 1 mg/kg will be shipped off site for disposal.
- Upon conclusion of backhauling operations, the Landfill will be covered in accordance with permit stipulations. The permit states: “The final soil cap must consist of at least 2 feet of soil material, with the top 6 inches consisting of sufficient organic material to support vegetation.”
All fieldwork conducted will be overseen by a person who meets the qualifications of a “qualified person” under Title 18, Section 75.990 (125), of the Alaska Administrative Code. A summary of the hauling effort results will be provided in the upcoming 2011 Site Characterization Report, Port Heiden Radio Relay Station, Port Heiden, Alaska. With input & oversight from Lesa Nelson, Anthony Pennino, & Thor Kallestad (who all meet the definition of a “qualified person”), the Native Village of Port Heiden will prepare this document this winter.
|
Louis Howard |
| 8/4/2011 |
Update or Other Action |
Memorandum to the Site File. This memo applies to all PCB contamination associated with the Port Heiden Radio Relay Station (RRS) Site, Port Heiden, Alaska. The Port Heiden RRS Site includes the following CERCLA Source Areas (Indicated Numbers Correspond to those numbers used in the 2006 Port Heiden Remedial Investigation (RI) Report):
- Former Composite Building (OTOO1),
- Septic Tank & Septic System Outfall (SS004),
- Landfill & Debris Burial Areas Including LF07 (RRS Landfill)
- Other Areas (Non-Numbered) Identified in the RI Report
- Antenna Pads
- Contaminated Soil Removal Areas
- Drum Storage Area
- Focus Area
The purpose of this Memorandum to the Site File is to present non-significant or minor changes to the Record of Decision (ROD) signed for the entire Port Heiden RRS. The minor changes to the Port Heiden RRS involve documenting the removal & replacement of PCB-contaminated soil in the Native Village of Port Heiden Class III landfill & the offsite disposal of certain PCB-contaminated soils.
This Memorandum to the Site File was prepared in accordance with the US Environmental Protection Agency's (USEP A) A Guide to Preparing Superfund Proposed Plans, Records of Decision, & Other Remedy Selection Decision Documents, July 1999, Section 7.3.1, & will become a part of the Administrative Record for the Port Heiden RRS.
The Administrative Record is kept at Elmendorf AFB. It is open for public review; point of contact is Tommie Baker, Community Relations Coordinator, (907) 552-4506. The Administrative Record is also available online at www.admimec.com.
This memorandum documents minor revisions to the selected remedial action for PCB-contaminated soil associated with the Port Heiden RRS. Since the ESD was signed, work had progressed as agreed to with approximately 3,000 cubic yards of PCB-contaminated soil shipped off-site for disposal as a permitted facility in the Lower 48. During this time, confirmation sampling occurred at the Soil Washing Area & Native Village of Port Heiden permitted Class III landfill to confirm work was completed in accordance with the ROD.
The contractor who completed the scope of work as described in the ROD needs to remove from the Class III landfill some debris & the PCB-contaminated soil that went through the soil washing process. Some of this washed soil is substantially over 10 mg/Kg (which should not have been placed in the landfill to begin with) & it also contains some of the chemical used to wash the soil; making the PCBs more mobile. The removed soil & debris from the landfill will be barged off-site to a permitted facility in the Lower 48 for disposal. The newly created available space in the Native Village of Port Heiden permitted Class III landfill requires backfilling to maintain proper drainage.
Instead of backfilling the landfill with clean fill, this Memorandum to the Site File will allow additional PCB-contaminated soil (associated with the RRS) containing greater than 1 mg/kg but less than 10 mg/kg PCBs to be trucked to the offsite Class III Landfill (The Native Village of Port Heiden permitted Class III landfill) for disposal; replacing the soil & debris being removed. This minor change documents a substitution of approximately 800 cubic yards of greater than 1 mg/kg but less than 10 mg/kg PCB-contaminated soil for the soil & debris being removed & barged offsite.
Once the landfill is refilled back to grade, the cap will be replaced. All remaining PCB-contaminated soils associated with the RRS containing greater than 1 mg/kg will be barged offsite to a permitted facility for disposal without utilizing the Native Village of Port Heiden permitted Class III landfill.
With the changes the remedy remains protective of human health & the environment & continues to meet Applicable or Relevant & Appropriate Requirements.
|
Louis Howard |
| 8/5/2011 |
Update or Other Action |
Email From Air Force to Boretide consulting
How are you going to define where to pull the less than 10 ppm soil from? I know we have a lot of sampling data from when you all found the limits of the contamination - but doesn't that also need to be spelled out in the work plan. |
Louis Howard |
| 8/5/2011 |
Update or Other Action |
Email from ADEC (L. Howard) to Boretide
Please elaborate more specifically on where the soil containing 10 mg/kg or less total PCBs will come from.
-Identify specifically with laboratory data summary tables demonstrating the proposed stockpiles being transported actually contain 10 mg/kg or less total PCBs,
-estimated volume of the stockpile(s) proposed for transport, and
-a figure(s) or other description of the current stockpile(s) location which are planned to be transported to the Class III landfill. |
Louis Howard |
| 8/5/2011 |
Update or Other Action |
Email from Boretide to ADEC
As much as I'd prefer to use soil from the Debris Pit as Landfill backfill, a cursory look at our results leads me to believe this isn't feasible due to the tight timeline; too many locations are well above 10 ppm. Hence, I'll create a new figure that augurs out a part of CSR2 (likely the south-southeast section, PAD-81 through PAD-83 region, Figure 15, SC&D WP) for use as backfill. |
Louis Howard |
| 8/8/2011 |
Update or Other Action |
Letter from Solid Waste Program (Lori Aldrich) to USAF 611 CES/CEAR (Pat Roth) Subj: Disposal of Additional Polluted Soil in the Port Heiden Landfill.
The Alaska Department of Environmental Conservation (ADEC) Solid Waste Program has reviewed the request, dated August 3,2011, to amend the ADEC Approval for the Disposal of Polluted Soil (Approval), dated May 29, 2009 (and Amendment approved July 15, 2011) to allow the addition of soils not included in the original plan.
The Approval allowed polychlorinated biphenyl (PCB) contaminated soil, generated during a cleanup of a portion of the U.S. Air Force Port Heiden Radio Relay Station (Port Heiden RRS), with a concentration of less than 10 mg/kg to be disposed in a secure cell at the Port Heiden Landfill. Your requested amendment would allow for disposal of soils, with a concentration less than 10 mg/kg PCB, from a different area of the Port Heiden RRS cleanup.
ADEC approves the disposal of the additional soils at the landfill. Although the soils were not specifically included in the original Approval, they meet all the requirements for sampling and the condition that .they are from the cleanup of the Port Heiden RRS. No amendment to the Approval is required, and all conditions of the Approval and Amendment apply.
Please contact me at (907) 269-7622 or by email at Lori.Aldrich@Alaska.gov if you have any comments or questions.
|
Louis Howard |
| 8/10/2011 |
Update or Other Action |
Email from WESTON Dale Greinke
Attached is the latest Landfill excavation map (as of 1:00 pm today) showing cell 3 Sidewalls and Bottom with results less than 10 kg/mg.
Weston would like to get your approval that this cell is complete as outlined in our Work plan. Weston has as also Completed 90% of cell 2, however due to the volume increase of sol removed, we had to switch gears and move to the Soil washing area with the remaining super sacks we have left on site (more are coming) and will be in Port Heiden by Monday the 15th and the remaining 200 yards of soil that is stockpiled in cell 2 will be removed, and then the remaining
sidewall and bottom confirmation samples will be taken.
The reason I am asking for approval for cell 3 is that Weston is currently building the MI piles in the SWA (soil Washing Area) and have three total built, and sampled per our work plan. Weston will be sending you the ADEC contaminated soil transportation form for each pile shortly, once we have confirmation samples that these are less than 10 mg/kg. Weston would like to start hauling these once confirmed less than 10 mg/kg to Cell 3 of the landfill. Unfortunately due the increased volume, Weston is trying to continue to stay on schedule and this approval will let us to continue.
Also, the grids in the SWA that we have excavated and placed into a MI pile, the bottom and sidewall samples have come back
Less than 1 mg/kg and Weston would like to know if it is ok to place clean backfill in a selected few of these confirmed clean grids
as this will Provide Weston with a access road into and out of the SWA for transportation of other soils.(MI piles or Super sacked soil)
|
Louis Howard |
| 8/15/2011 |
Offsite Soil or Groundwater Disposal Approved |
Results for MI Decision Units #01, 02, and 03 received. Soil being moved in accordance with ADEC approved work plan dated June 7, 2011 Addendum Remedy Selection Implementation, Demolition and Debris Removal. Destination - Port Heiden Landfill. Reviewed and approved by ADEC PM. |
Louis Howard |
| 8/19/2011 |
Update or Other Action |
Ahtna sends email on behalf of Boretide/Air Force
CA activities performed last week include the following:
- POL excavation activities continued in the GLO (RRS POL Areas 2 and 3).
- Due to the depth of the POL excavation, ~20 feet bgs currently, the excavation size will be quite large. The top two tiers of the excavation is most likely going to be clean and will require lots of field screening and analytical samples to meet ADEC requirements. We are proposing considering the top two tiers as a separate excavation from the targeted POL excavation and decreasing the required field headspace screening samples and analytical samples when observed to be clean. Samples will be collected at half the quantity specified in ADEC regulations. Field headspace screening samples and analytical samples will be collected per ADEC regulations and specified in the WP.
- The landspreading area was expanded to the east of the landspread area 3 by 60 feet. A total of 10 analytical samples, to ensure no contamination is present, were collected at 50 foot increments to be analyzed for DRO/RRO, VOCs, GRO/BTEX, PCBs, and PAHs. These sample results are expected November 1. The extent of the landspreading area was documented utilizing the Trimble.
- PCB grid site characterization samples were collected from area north of the main road and south of the Weston cleanup area (please see attached figure). This area is proposed for removal due to visual safety hazards it presents. All sample results were documented utilizing the Trimble.
- All samples in this 45 foot by 45 foot area were between 0.409 to 3.35 mg/KG.
- We are proposing removing this area at ½ foot lifts and temporarily stockpiling in the CSR2 on geotextiles and liner. This soil will be moved to the landfill once it is ready to receive material. PCB grid site characterization samples WILL be collected at each ½ foot lift to ensure only soil containing PCBs between 1 and 10 ppm will be disposed of at the landfill.
- The surface vegetation was removed from the CSR2 area.
- Rototilling activities were not completed this week due to the excess moisture creating mud in the landspreading area.
Activities planned for the week of 22-August through 28-August are summarized below:
- Continue screening and excavating POL contaminated soil in the GLO excavation
- POL contaminated soil from the GLO excavation will be hauled to the landspread area
- Landspread soils will be attempted to be rototilled
- Area north of the road and south of the Weston work area will be removed at ½ foot lifts and temporarily stockpiled in CSR2. |
Louis Howard |
| 8/22/2011 |
Offsite Soil or Groundwater Disposal Approved |
Results for MI Decision Units #04 received. Soil being moved in accordance with ADEC approved work plan dated June 7, 2011 Addendum Remedy Selection Implementation, Demolition and Debris Removal. Destination - Port Heiden Landfill. Reviewed and approved by ADEC PM. |
Louis Howard |
| 8/23/2011 |
Offsite Soil or Groundwater Disposal Approved |
Results for MI Decision Units #05, 06, 07 and 08 received. Soil being moved in accordance with ADEC approved work plan dated June 7, 2011 Addendum Remedy Selection Implementation, Demolition and Debris Removal. Destination - Port Heiden Landfill. Reviewed and approved by ADEC PM. |
Louis Howard |
| 8/24/2011 |
Update or Other Action |
Amendment 1 to Work Plan Addendum – Final, Remedy Selection & Implementation, Demolition & Debris Removal, Port Heiden Radio Relay Station, Port Heiden, Alaska, June 2011, received.
In accordance with the three referenced documents, Weston Solutions (WESTON) submits the following amendment to the Work Plan Addendum – Final, Remedy Selection & Implementation, Demolition & Debris Removal, Port Heiden Radio Relay Station, Port Heiden, Alaska, June 2011 to the Alaska Department of Environmental Conservation (ADEC) for approval.
The last sentence of the last paragraph in Section 3.3 Landfill Cleanup of the Work Plan Addendum which states “After backfilling is complete, the cap of clean overburden will be replaced to a depth of 2 feet & regraded to ensure proper runoff, & the cap will be seeded” will be deleted. The following sentences will replace this deleted sentence:
“After WESTON has completed transporting & placing soils containing < 10 mg/kg of PBCs in Cell 3, these soils will be sloped at approximately 45º towards the front of the landfill. An impermeable liner will be placed over the 45º slope to separate the WESTON placed soils from other soils. The horizontal portion of these new soils will be capped with clean overburden to a depth of 2 feet & regraded to ensure proper runoff, & this portion of the cap will be seeded.
The remaining space in Cell 3 & the available space in Cell 2 will be backfilled with soil containing < 10 mg/kg of PCBs & covered with two feet of clean soil by the Native Village of Port Heiden.”
This amendment has already been coordinated with the Air Force Center for Engineering & the Environment (AFCEE), & the United States Air Force 611th Civil Engineer Squadron (CES).
|
Louis Howard |
| 8/25/2011 |
Update or Other Action |
Email from Boretide to ADEC Proposed GLO Sampling around Debris Areas.
1. Excavate soil from around these debris areas. Segregate and stockpile in the landspread area. Stockpiles will be sampled at the frequencies listed in Table 2A (pasted below) of the ADEC Field Sampling Guidance
2. Collect grab samples from each stockpile. Analyze for RCRA Metals, GRO/BTEX, DRO/RRO, VOC, SVOCs, and PCBs. If there's a noticeable POL odor (as is expected), no POL samples will be collected
3. If all analytes are beneath regs, landspread the stockpile
4. If non POL analytes are above regs, super sack stockpile and send off site for disposal via waste disposal contractor
|
Louis Howard |
| 8/26/2011 |
Update or Other Action |
The on-site evaluation conducted on August 5, 2011 covered TestAmerica-Port Heiden Mobile Lab (TA PH ML) facility & equipment, sample receiving, quality control, data documentation, reporting & archiving. The following certified methods were reviewed in this audit:
EPA
3550B-Ultrasonic Extraction
8082-Polychlorinated Biphenyls (PCBs) By Gas Chromatography
The purpose of this evaluation was to determine if the TA PH ML has the facilities, qualified staff, instrumentation, quality procedures, & experience to analyze soil samples in support of the State of AK CS Regs, & to verify that the TA PH ML is operating in accordance with their approved Lab Quality Assurance Plan (QAP). It is the intention of the State of AK that the information contained in this report will enhance the TA PH ML’s ability to provide quality analytical services.
Date of Evaluation: August 5, 2011 Evaluator: Lance W. Morris CS Approval Officer – CS Program
Status Definitions:
An “Approved” lab meets all the regulatory performance criteria as explained in 19 AAC 78 Sections 800, 810 & 815.
A “Provisionally Approved” lab has deficiencies, but demonstrates its ability to consistently produce valid data.
Results of the On-Site Evaluation:
1. Facility & Equipment:
The TA PH ML is located at Port Heiden, Alaska. The facility has enough cabinets & bench space for the sample preparation, storage, & analysis of soil samples by the methods listed in this report. The facility has fume hoods, drying ovens, & enough glassware, refrigerators, thermometers, analytical balances & other essential equipment for the analysis of soil samples.
2. Personnel:
Staffing levels are adequate for the methods listed above. The staff met the minimum requirements for their specific roles.
Lab Personnel Interviewed:
Colin McKean – Analyst, 10 Years Experience
Richard Losche – Analyst, 40 years experience
ADEC Findings & recommendations:
1. Sample Receipt: There were no observed deficiencies.
The auditor was walked through the sample receipt procedure & even spoke with some of the staff of the engineering firm collecting the samples for analysis. The refrigerator for sample holding is monitored on a daily basis & this is recorded in log TA-AK-0091. The thermometer ID is 9525. Samples are submitted with an appropriate Chain of Custody (COC) & a scanned copy of this is sent electronically to Terri Torres in the TestAmerica Seattle Facility. She then logs the samples into the TestAmerica LIMS system. Given the slow connection speed at the mobile lab, this is a good approach to logging in samples.
In most of the sample COCs submitted, a MS/MSD pair is indicated for one of the samples. When asked, it was indicated that the samples for the MS/MSD pair were chosen randomly & not selectively.
2. Sample Extraction: There were no observed deficiencies.
The auditor had the staff demonstrate the extraction procedure. The analytical balance is calibrated every day of use & is recorded in log TA-AK-0021. The weights used in the calibration have been recently calibrated as shown in Attachment C. The calibration ranges from 1g to 50g which brackets the extraction & percent moisture weights. A new, clean jar is used to weigh & extract samples. 20g of sample is weighed out & a drying agent (Na2SO4) is added. Then three volumes of solvent (20mL) are combined & diluted to 100mL final volume in a Class A volumetric flask. All weights & temperatures were recorded in the TA-AK-0091 logbook.
The drying agent is not baked at 400°C for four hours. This could lead to phthalate contamination of the extract. The auditor recorded the Vendor & Catalog # for the drying agent (Na2SO4). These were JT Baker & 3375-05 respectively. Though the drying agent should be baked, it was concluded by the auditor that due to the small mass of drying agent used (~10g) & the 100mL final volume of the extract, the effects of phthalate contamination in the samples is considered minimal to non-existent in this instance.
A mass of sample is then weighed (7-10g), & placed in a drying oven for the percent moisture
determination. The oven thermometer ID is 7914.
The samples are spiked with the following working solutions:
Surrogate: TCMX & Decachlorobiphenyl (DCB) at 2ppm as the working standard Concentration. 100uL is spiked into the samples.
PCB 1260 Spike: Aroclor 1260 at 10ppm as the working standard concentration.
Recommendation: It is recommended that the stock, intermediate & working standards be given unique identifiers & that these identifiers recorded in the mobile lab log. The standards are recorded by date in the TA-AK-0091 log, but no unique identifier is given. This will add to the traceability of the standards. They are recorded in LIMS, but the LIMS identifier should be placed in the log.
These levels agree with the SOP No. PH-OP-0334, Rev.2.
For additional information see site file. |
Louis Howard |
| 8/29/2011 |
Offsite Soil or Groundwater Disposal Approved |
Results for MI Decision Units #11 received. Soil being moved in accordance with ADEC approved work plan dated June 7, 2011 Addendum Remedy Selection Implementation, Demolition and Debris Removal. Destination - Port Heiden Landfill. Reviewed and approved by ADEC PM. |
Louis Howard |
| 8/29/2011 |
Update or Other Action |
ADEC approves the amendment as written. Concerns regarding creation of a slip-plan on the slope of the liner are mitigated by the below grade structure. Any subsidence or slippage would be minimal and could be addressed during annual monitoring events. |
Louis Howard |
| 8/30/2011 |
Update or Other Action |
Boretide email to ADEC
1) We will go back and collect discrete samples for VOCs in the area previously sampled utilizing the PCB grid sampling.
2) Those samples were collected prior to the discovery of the suspected solvent area (The GRO/BTEX and DRO/RRO sample). We are leaving the area as is at the moment and once the samples for the whole suite are received we will collect samples to delineate the area suspected of solvent contamination.
3) Regarding the Rototilling: we are able to rototill utilizing the bulldozer but we are unable to use other equipment due to the mud. Rototilling last week began again utilizing the bulldozer and continued this week utilizing the bulldozer.
Email from ADEC to Boretide CA Update 8/22 - 28, 2011
ADEC does not recognize EPA PCB grid sampling for VOCs. Only discreet soil samples will be allowed when VOC sampling soils. PAHs sample results are questionable when using grid sampling.
The EPA grid sampling technique is typically for PCBs only.
o The area immediately surrounding the area suspected of solvent contamination contains high concentrations of POLs. Field Headspace samples were collected.
? Field headspace sample = 320 ppm
? Field headspace sample = 482 ppm. A sample was collected from this area to be analyzed for DRO/RRO and GRO/BTEX.
Why weren’t the samples analyzed for VOCs as well as DRO/RRO, GRO/BTEX, since it is an “area suspected of solvent contamination”?
Last bullet states: Landspread soils will be rototilled. Incorrect since other text states it is too muddy to rototill.
The previous text states: “Rototilling activities continued utilizing the bulldozer. The skid steer and roto-tillers are unable to be utilized due to the mud.”
|
Louis Howard |
| 8/31/2011 |
Update or Other Action |
WESTON EMAIL (Dale Greinke)
Weston is near completion of the PCB soil removal at the soil swashing area, and wants to proceed with closing out this area. A couple of things need to be resolved for complete closure to the area Weston used (Green Grids, less than 1ppm) for access to the site, for hauling of both Super sacked soil (> 10 ppm of PCBs) transported to the beach staging area, and soils with less than 10mg/kg of PCBs that was trucked to the landfill. The methods we used to prevent any cross contamination within the green grids are as follows:
1 The excavator always maintained clean tracks outside of the excavated grids (or if we were working within ALL yellow soils we kept the excavator within these grids)
2 The clean loader path was always upon green grids,
3 The loader would drive up to a poly liner and hold the bucket over the liner for the excavator to fill and compact soils within the bucket. Lloader tires always stayed on green grids.
4 The loader would then haul these soils to an MI stockpile
5 The loader would dump the soils in one spot at the MI stockpile, never getting the loader tires into the soil as this location. A second excavator was sitting on the MI and would gather the soils that the loader transported/dumped eliminating any need for the loader to get tires into contaminated soils.
The first approach is to not sample any of the area’s that Weston used (green grids) as access, and that are previously noted to be less than 1 ppm, per AECOMS samples.
The Second approach would include: proposing to complete MI sampling to characterize the approx. 292 cubic yards of material which were driven over during hauling operations at the soil washing area, per the attachment. The limits would be the area only used for the access and the depth to be 4 inches. If results come back less than 10, this MI unit would be transported to the landfill, If the result is less than 1ppm, then that MI unit stays in place. Any excavated MI unit, limits of the access areas and at a depth of 4 inches, would be removed and no further sampling would be completed after removal. I believe this is the best approach for this area.
Figure text:
During field operations at the SWA, Weston cleared outlying cells >1 mg/kg in accordance with the WP. Soil was brought in to backfill these small excavations around the larger areas of concern. Weston utilized the areas illustrated as DU-01, DU-02, and DU-03 as an interior haul road to facilitate loader and truck operations during removal of the larger areas. Much of the haul road Weston used was characterized as 'clean' by AECOM grab samples collected from the centers of the grid cells.
Weston surveyed the area of this haul road using RTK GPS and it was found to be approx. 23,700 square feet. The thickness of the haul road is negligible as it was only surface materials which Weston drove over during field operations. Weston proposes to consider the thickness of this haul road as 4 inches (0.333 feet) in determining the quantities of the proposed DUs. The total volume of this haul road is then approx. 292 cubic yards. Weston proposes to split this area into three decision units (DU-01, DU-02, and DU-03) for MI sampling.
Weston utilized GIS software to create the interior haul road polygons (DUs), and estimate the area. The area of DU-01 is approx. 8,145 square feet, the area of DU-02 is approx. 8,018 square feet, and the area of DU-03 is approx. 7,536 square feet. At an estimated thickness of 0.3333 feet, the volume of materials comprising DU-01 is approx. 100 cubic yards, DU-02 is approx. 99 cubic yards, and DU-03 is approx. 93 cubic yards. Weston utilized a random point generator within GIS to randomly place 40 MI subsampling locations for DU-02 and DU-03 to facilitate collection of Primary samples, and 120 subsample locations for DU-01 to facilitate collection of a Primary, Duplicate, and Triplicate sample. The RSD% and 95%UCL will be calculated for these three DUs. Weston proposes to use MI sampling to characterize the approx. 292 cubic yards of materials which were driven over during hauling operations at the SWA. |
Louis Howard |
| 8/31/2011 |
Offsite Soil or Groundwater Disposal Approved |
Results for MI Decision Units #12 and 13 received. Soil being moved in accordance with ADEC approved work plan dated June 7, 2011 Addendum Remedy Selection Implementation, Demolition and Debris Removal. Destination - Port Heiden Landfill. Reviewed and approved by ADEC PM. |
Louis Howard |
| 9/1/2011 |
Update or Other Action |
Email from ADEC to Thor Kallestad (Boretide)
Submit the forms on the day the soils are being ready to be transported. Two weeks out may be too early. The sheen factor is for petroleum contamination only – this does not apply to soil contaminated or comingled with other COCs (PCBs, Pesticides, chlorinated solvents). Sheen* is an observation utilized for surface water not soils.
The concern was for spreading contamination beyond the GLO Site boundaries during excavation activities. Discharge of contaminated water to the lands of the State is not allowed – the contaminated water must be treated to levels below Table C prior to discharge** or properly disposed of if not treated.
*18 AAC 70.990 (53) "sheen" means an iridescent appearance on the water surface.
**18 AAC 75.990 (32) “discharge” has the meaning given in AS 46.04.900, except that, as used in this chapter, “discharge” applies only to an unpermitted discharge into the environment
Thor Kallestad email last bullet from GLO Excavation and Sheens:
When would you like to receive the soil transport forms? It sounds like we're a week or two away from being able to ship soils to the Landfill. |
Louis Howard |
| 9/2/2011 |
Update or Other Action |
Email from WESTON (Dale Greinke)
Attached is the REVISED Soil Washing Area map showing the proposal to complete MI sampling to characterize the approx. 292 cubic yards of material which were driven over during hauling operations at the soil washing area, per the attachment. The limits would be the area only used for the access and the depth to be 4 inches. If results come back less than 10, this MI unit would be transported to the landfill, If the result is less than 1ppm, then that MI unit stays in place. Any excavated MI unit, limits of the access areas and at a depth of 4 inches, would be removed and no further sampling would be completed after removal and Weston would Stay with random point generator approach as proposed above, but take an additional triplicate sample set at DU-03.
The attached Map shows both DU-01 and DU-03 having triplicate sample locations.
|
Louis Howard |
| 9/2/2011 |
Update or Other Action |
EMAIL from WESTON:
Attached is the REVISED LF interior road sampling map as outlined below in your Counterproposal. Weston will proceed with this plan.
Original WESTON Proposal: DU-01 to facilitate collection of a Primary sample, and 120 locations for DU-02 to facilitate collection of a Primary, Duplicate, and Triplicate sample.
Counterproposal: ADEC requests WESTON to utilize DU-02 to facilitate the collection of a Primary sample, and DU-01 to facilitate the collection of a Primary, Duplicate and Triplicate sample (in other words, reverse of WESTON’s proposal for sampling of DU-01 and DU-02).
|
Louis Howard |
| 9/6/2011 |
Update or Other Action |
Boretide email to ADEC
RE CA Update 8/29 - 9/4/2011
Our responses to your questions are shown in red below. I hope this clarifies and we look forward to any more questions or concerns.
o An area in the southeastern portion of the excavation at approximately 6 feet bgs contained an odor similar to the solvent area in BLO. A soil sample was collected and analyzed for DRO, RRO, GRO, BTEX, PCB, PAH, VOCs, RCRA metals, and TCLP – VOCs.
? A buffer of approximately 50 feet was kept in case sample results indicated additional contaminants are greater than ADEC cleanup levels.
? The Field Headspace Screening = 434 ppm
? All analytical results were less than the ADEC cleanup level including DRO at 90.2 mg/kg.
ADEC COMMENT: Then what is the odor?
CA Response:
• I had the field headspace reading incorrect. The actual field headspace reading was 26.0 ppm. The 434 ppm field headspace reading was collected from an area that contained strong diesel odors and was stained grey. This soil was removed to the landspreading area.
• The odor just seemed a bit sweeter than the typical diesel odor so to ensure only POL contaminants were being transported to the landspread area we collected a sample from that area for DRO, RRO, GRO, BTEX, SVOCs, VOCs, PCBs, PAHs, RCRA Metals, and TCLP-VOCs.
• Once again, to ensure that no additional contaminants were in the area we collected 10 field headspace screening samples from the area and collected a soil sample from the area with the highest reading. The soil sample was collected from the location of a field headspace screening sample result of 53 ppm and is scheduled to be analyzed for DRO/RRO, GRO/BTEX, SVOCs, PCBs, PAHs, and VOCs.
o On August 16, 2011 ten surface soil samples were collected from the eastern portion of the landspreading area (extended to the east 262 feet and north at 110 feet). The samples were collected at 50 foot increments. The samples were analyzed for: VOCs, DRO/GRO, GRO/BTEX, and PCBs/PAHs.
? All sample results were below the ADEC cleanup levels except for DRO. I believe the DRO results were greater than the ADEC cleanup level due to rain leaching some of the DRO contamination from the adjacent landspreading area.
ADEC COMMENT: Doesn’t the landspread area have leachate controls (i.e. soil berms at a minimum?) ADEC requests the Air Force to please verify and provide documentation regarding these berms or other leachate controls. Otherwise it appears the Air Force may be in violation of the CS regs by contaminating “clean” soil from leachate.
CA Response:
• Only three of the ten samples contained DRO greater than the ADEC cleanup level of 230 mg/kg (590, 413, and 283). These samples were collected from an area directly adjacent to another landspreading area.
• A berm was in place prior to the clearing of the extended landspread area but was removed when we began clearing the area.
• Berms are in place around the first landspreading area except for at the entrances.
• Soils have not been added to the newest landspread area yet.
• We have a few hypothesis how these samples were greater than the ADEC cleanup level:
o The area was cleared for approximately one week before the samples were collected and the samples were not collected from the virgin tundra.
o The area was cleared utilizing the bulldozer, which has been used in the landspreading areas.
o I also heard that there was a Quonset hut and potentially other buildings in that area at one point.
• We are proposing the following solutions:
o Today, we are going to recollect samples in the areas the DRO analytical results were above the ADEC cleanup level at approximately 1 foot bgs. This will potentially show that it is a small surficial problem and provide a clean baseline.
o We are also planning on collecting samples surrounding the landspreading area showing that the contaminants are not leaching and contaminating the surrounding soil and vegetation.
o In addition, first thing tomorrow morning we will complete the construction of the berms in the new landspread area and provide maintenance to the berms in the older landspreading areas.
o Soils have not been added to the newest landspread area yet.
o Photos and a schematic will be provided tomorrow. |
Louis Howard |
| 9/18/2011 |
Update or Other Action |
Email from Boretide to ADEC, CORPS, 611, NVPH
CA activities performed last week include the following.
• Excavation continued at the GLO POL dig site. The sidewalls appear to be less than regs, but the pit bottom does not. The excavation has roughly taken on the shape of an inverted cone. The surface diameter is approximately 200-foot whereas the bottom diameter is roughly 50-feet. Vertical depth from the extrapolated surface plane to the bottom of the pit is about 25-feet
• Removal of a 1-foot lift began from the area within CSR2 that is marked for the landfill. Hauling also began; the material was loaded into end-dumps and hauled downhill to the landfill. Prior to the onset of hauling, open landfill cell dimensions indicated empty volume existed to accomodate ~1,500 CY
• 225 SFT PCB grid square confirmation samples were collected from excavated CSR2 area
Activities planned for the upcoming week are listed below.
• Field screen the GLO excavation sidewalls extensively
• Perform the GW well sampling
• Per previous emails, begin blading landspread "Area #2"
• Continue excavating POL soils from the bottom of the GLO excavation. Begin hauling these to the new landspread location
• Ship roughly 30 CSR2 PCB grid samples to SGS on Monday. 3-Day TAT
• Per the Landfill Hauling TM, continue excavating CSR2 and hauling this material to the landfill
• Collect additional CSR2 PCB grid samples from excavated areas within CSR2
NOTE TO FILE: No approval to transport request forms were submitted to haul CSR2 soils as per 8/31/2011 and 9/1/2011 email commmunication between Boretide and ADEC. Discrete soil samples were actually taken (four total) from CSR2.
|
Louis Howard |
| 9/23/2011 |
Update or Other Action |
Pat Roth (611 CES) to Thor and ADEC
Here is a filled out form from WESTON as well as a blank. Please start submitting. If you already sent some soil to the landfill, please send the sample results for that soil. |
Louis Howard |
| 9/23/2011 |
Update or Other Action |
Email from Thor (Boretide) to ADEC , 611, and NVPH. RE: Landfill backfill request for transportation forms Hauling has begun and I forgot to submit the forms. |
Louis Howard |
| 9/23/2011 |
Update or Other Action |
Email from Thor to ADEC SW Program and CS Program, 611 and NVPH. PCB Landfill Update
On Monday of this week, we began hauling PCB contaminated material from the Former RRS to the Port Heiden Landfill. It was made very clear to me that before doing so, we needed to complete the Contaminated Soil Transport and Treatment Approval Form. I simply forgot to do so. That form is attached to this email.
Due to size constraints, the Backfill Hauling Technical Memorandum we wrote to describe our operations will be sent in a subsequent message; it is 10 MB. Also attached to this email are SGS lab results. These show that PCB results for the soil slotted for removal in the Tech Memo are less than 10 mg/kg.
As for an update of our current operations, we're essentially half done. We estimated approximately 1,500 CY would fit in the empty cell. That cell is now half full. We plan to continue hauling next week and fill the cell. In line with our permit, it would be capped and covered during the first week of October |
Louis Howard |
| 9/23/2011 |
Update or Other Action |
Email from Boretide re: Find-it summary of the data packages
Neither Pad-26 nor Pad-111 have or will go to the Landfill. The appendages on the removal area that captured these two samples on the Tech Memo were mistakes. The excavation extents we've staked omit these two locations.
Pad-111 has not been super sacked; it still exists south of the excavation. The Pad-26 location is undisturbed north of the excavation
The Pad-26 location has not, and will not, go to the Landfill. No sample locations with a PCB concentration above 10 mg/kg have or will be hauled to the Landfill.
For ease of sorting....
• Results for Pad-46 (WB-PAD-46) are found in data package 1103661. It is attached to this email.
• Results for Pad-80, Pad-82, and Pad-83 are found in data package 1104361
• Results for Pad-100 are found in data package 1104547
• Results for Pad-111 and Pad-112 are found in data package 1104796 |
Louis Howard |
| 9/25/2011 |
Update or Other Action |
CA Update Sept. 25, 2011 to ADEC, 611, CORPS, NVPH
Activities performed during the week of September 19 - 24 are listed below.
• Approximately 750 CY of PCB contaminated soil (less than 10 mg/kg) was hauled from CSR2 to the Landfill. The Landfill cell is now approximately half full. The CSR2 soil was excavated from the location shown in the Backfill Hauling TM. Average lift depth is about 12-inches
• Stockpiled PCB contaminated soil (less than 50 mg/kg) from the Access Road excavation was super sacked. Approximately 95 super sacks were filled last week
• The FPC-066 and FPC-215 wells were sampled. Three Former RRS wells were also sampled. These samples will arrive at SGS on Monday. Standard 14-day TAT
• RFPs for super sack removal/disposal were sent to three service providers. Proposals are due Tuesday. Anticipated sack quantity is about 100-200
Activities planned for the week of September 26 - October 1 are summarized below.
• Sample remaining Former RRS GW wells
• Collect FPC-086 soil samples
• Continue super sacking Access Road stockpile. Not much is left; this should conclude Monday
• If permission is granted, continue hauling material from CSR2 to the Landfill. Per the fact that I forgot to submit the Contaminated Soil Transport and Treatment Approval Form last week, we will not haul any additional soil until approval to do so is granted. Louis, please let us know if we can continue these hauling efforts
• Determine winner of the sack removal RFP process
• Time permitting, begin collecting sidewall samples from the GLO POL excavation
|
Louis Howard |
| 9/26/2011 |
Update or Other Action |
Email from Boretide
When looking at Figure 2 in the TM, if you draw a line from sample location Pad-46 to Pad-81, all of the orange shaded area to the left of this line (w/the exception of Pad-111) has been brought to the landfill. I estimate that area at about 20K SFT. Average lift depth is about 1-foot.
We have stopped hauling until we hear otherwise, but our plan is to bring the orange shaded material to the right of that line (minus Pad-26) to the landfill, if approved, this week.
|
Louis Howard |
| 9/26/2011 |
Update or Other Action |
ADEC email to Thor: Question-Was CSR2 Sampled on a 15 foot-grid square as CSR1?
4.5 CSR2 (Site Characterization Report, 2011):
While sampling the southwest side of the Former RRS Pad perimeter for windblown PCBs (Section 4.1.1), several results in excess of 1 mg/kg were received from the location that would ultimately become CSR2. This area proved to be quite large. Because of extensive delineation efforts and the need to wait for laboratory sample turnarounds, fieldwork at CSR2 lasted much of the 2010 field season. Therefore, no soil removal activities occurred at CSR2 in 2010. To conduct sampling in CSR2, a sample grid was overlain on CSR1, as described in Section 3.3, and lifts/sampling occurred on the 15-foot grid squares within this AOC. Samples in these locations were from an approximate depth of 2 to 4 inches bgs.
ANSWER from Boretide:
Composite grid samples were not collected from CSR2 last year. All of the data shown are grab samples. However, ~50 grid sample results are due back today from beneath the first CSR2 lift. I will forward these results to this email thread when they arrive. |
Louis Howard |
| 9/26/2011 |
Update or Other Action |
Email to Boretide and 611 CES, SW Program
This information conflicts with what was in your report per text below. The discrete sampling for CSR2 was not approved as per the final work plan since it was supposed to be 9 pt. composite on 15x15 grids.
Additionally, we have lab results from PAD-01 through PAD-133. ALL of these results are not shown on the figures or referenced in the TM figure or text.
PAD-110 and PAD 111 results on the TM Figure are incorrect when compared to the laboratory data reports. PAD 101 results were also incorrect when compared with the laboratory data report.
ADEC will require a new figure(s) with ALL of the PAD laboratory results (1-133) before proceeding any further with this project.
Also include field notes from the CSR2 sampling effort, a review of the field notes [from the 2011 Site Characterization, ADEC] cannot locate any of the CSR2 sampling.
If this can’t be resolved to the Department’s satisfaction, all the soil will need to be removed from the landfill and disposed off-site per the original FINAL work plan.
|
Louis Howard |
| 9/26/2011 |
Update or Other Action |
Email from Boretide to ADEC, 611 and NVPH:
The 56 grid sample results we collected beneath the first CSR2 lift just arrived. Every one of these PCB results is less than 1 mg/kg.
The figure with all of the PAD sample results is under construction. We hope to distribute that Wednesday; it'll be Thursday at the latest. |
Louis Howard |
| 9/26/2011 |
Offsite Soil or Groundwater Disposal Approved |
Results for MI Decision Units #09 and 10 received. Soil being moved in accordance with ADEC approved work plan dated June 7, 2011 Addendum Remedy Selection Implementation, Demolition and Debris Removal. Destination - Port Heiden Landfill. Reviewed and approved by ADEC PM. |
Louis Howard |
| 9/27/2011 |
Update or Other Action |
Email from Boretide to ADEC
The field crew is going to prioritize collecting the remaining 225 SFT grid samples from the excavated areas of CSR2 that have not been sampled. We estimate there is probably 40-50 grid squares left to sample. This is in addition to the 56 from which we received results yesterday.
These grid square samples should ship to SGS tomorrow. They'll be on the fastest TAT SGS can deliver.
|
Louis Howard |
| 9/28/2011 |
Update or Other Action |
Email from Boretide to ADEC & 611
The updated CSR2 Figure is attached. A few notes about it.
• Pad samples -01 through -129 are shown
• Where a duplicate sample was the higher of the two readings, the "D" result has been presented
• Pad samples -130 through -133 have been removed. While QC-ing this data, we realized those four sample ID's were used twice last year
• PCB results greater than 10 mg/kg have been made bold
• The orange area targeted for Landfill disposal has been divided in two. A ~12-inch lift, from the left orange area, has been placed in the Landfill cell. All of the material from the right orange area remains on site at the Former RRS
|
Louis Howard |
| 9/29/2011 |
Update or Other Action |
Email from Boretide to ADEC & 611
While reviewing the figure again last night, we noticed the Pad-85 and Pad-108 results were missing from the data tables; their locations were shown. Those two PCB results (0.117 mg/kg and 0.135 mg/kg, respectively) are shown on this figure. |
Louis Howard |
| 9/29/2011 |
Update or Other Action |
Staff received a sampling plan for the stockpiles (1 in landfill & 2 outside of the landfill). The Sampling Plan describes the project approach & methods required for sampling PCB contaminated soil in Port Heiden, Alaska. The soil to be sampled & tested is suspected to have PCB levels between 1 mg/kg & 10 mg/kg. All sampling & lab analysis procedures shall be performed in accordance with the ADEC multi-increment (MI) protocols. All lab analyses shall be conducted to detect non-volatile PCBs.
Jacobs will document, both photographically & in written-report form, all sampling activities conducted at the project site. The MI samples will be submitted to a DoD Environmental Lab Accreditation Program (ELAP) certified lab for MI-sample preparation & nonvolatile PCB detection analysis (e.g. sieving, sample preparation, sub-sampling, & analysis).
MI samples & subsample quantities will be collected at the following minimum frequencies:
1) Each MI sample representing up to 50 cy will contain at least 30 subsamples.
2) Each MI sample representing up to 100 cy will contain at least 50 subsamples.
Each one (1) ft. horizontal layer in each stockpile may be treated as a decision unit if the total volume represented is less than 100 cy. If that layer represents more than 100 yards, then the stockpile or landfill area will be split into two or more sections & treated as separate stockpiles so that each layer does not represent more than 100 cy. One primary MI sample will be collected per decision unit, & a duplicate & triplicate MI sample collected from 0-1 ft. below grade (BG).
Each stockpile (or portion of stockpile) will be gridded into a 6 x 5 grid pattern if 30 subsamples are required, or a 5 x 10 grid pattern if 50 subsamples are required, & three locations within each grid (primary, duplicate, & triplicate) will be identified. Specific locations within each grid cell for the collection of the primary, duplicate, & triplicate aliquots will be identified by further dividing each grid cell into 4 quadrants, & locating the primary, duplicate, & triplicate in three of the 4 quadrants. The location selected as the primary will remain consistent through the final sampling depth of each stockpile or landfill location.
Sub-sample aliquots for each one (1) ft. layer will be collected & place in one Ziploc bag representing each layer for each stockpile, or stockpile section as necessary. The methods Jacobs intends to utilize for MI sample collection include, but may not be limited, to the following: Direct-push sampling using a Geoprobe 540MT, Manual hand auger sampling or Excavator bucket sampling.
Jacobs will prioritize the use of the sampling methods in the order listed above. Aliquots collected from each of the above sampling methods will be performed in a manner that provides a representative sample of the entire 1 ft. interval.
The area to be characterized at the landfill is believed to be approximately 100 ft. x 80 ft. x 6 ft. Actual depths will be verified prior to sampling. This area may be divided into smaller subsections so that each one foot lift does not represent more than 100 cy, & then each section will be gridded into the appropriate grid pattern as necessary. In Attachment 1, the sample area can be identified as the area noted as “Standing Water” & “New Fill Placed”. All subsurface MI sample collection shall occur at each systematic increment grid location for each one (1) ft. layer; therefore, samples will be collected from 0-1, 1-2, 2-3, 3-4, 4-5, & 5-6 ft. BG. Duplicate & triplicate samples will be generated at the zero to one (0-1) ft. layer (BG).
Any standing water will be removed from the landfill sampling area & treated using a large particle filter/small particle filter/granulated activated carbon system, & tested prior to disposal.
The temporary stockpile size under the white tarp is approximately 25 ft. x 29 ft. x 5 ft. (approximately 130 cy) and will be gridded into a 6 x 5 grid pattern. All subsurface MI sample collection shall occur at each systematic increment grid location for each one (1) ft. layer (each layer representing less than 50 yards); therefore, samples will be collected from 0-1, 1-2, 2-3, 3-4, and 4-5 ft. BG. Duplicate and triplicate samples will be generated at the 0-1 ft. layer (BG). For the existing temporary stockpile located under the white tarp, a total of seven (7) structured composite samples will be generated onsite and prepared and analyzed at the lab.
The temporary stockpile size under the black tarp is approximately 21 ft. x 52 ft. x 10 ft (approximately 400 cy). Due to the height of the stockpile, and for ease of sampling, the entire stockpile will be spread out to a uniform 5 ft. thickness and will be gridded into a 5 x 10 grid pattern. For the existing temporary stockpile located under the black tarp at the RRS, a total of seven (7) structured composite samples will be generated on site and prepared and analyzed at the lab. |
Louis Howard |
| 9/30/2011 |
Document, Report, or Work plan Review - other |
Minor details/concerns, but the Air Force needs to ensure adequate mass is collected per our [Draft MI 2009] guidance, 30-60 grams per increment. This should not be a problem if the Air Force is collecting the entire one (1) foot [direct push] DP core. As discussed in the meeting, this could change with other collection approaches. Otherwise, it looks like the Air Force captured most of the items we discussed at the meeting.
ADEC will not approve until all the information is received from Weston (e.g. as built for liner in landfill) and the lab.
MI guidance states: “The project laboratory must be contacted prior to mobilizing to the field to determine the sample mass normally extracted for the required non-volatile analyses. The DEC project manager must be assured that the laboratory is willing to meet MI-specific requirements prior to approving the work plan. Clear communication between the environmental professional, the lab and DEC prior to field mobilization is essential.”
ADEC is still concerned on using the new lab and what exactly the “modified” procedure is going to be from the California? MI Method to be in full compliance with all requirements in the ADEC Draft Guidance on Multi Increment Soil Sampling (March 2009).
Additional Issues:
Issues:
General:
• DU size as discussed. 30 increments for up to 50 cy of soil, 50 increments up to a max of 100 cy of soil.
MI sampling plan:
• Additional detail on how systematic random increment location will be determined (primary, dup, trip) to meet MI guidance requirements
• Specify which sample collection method will be utilized of the three listed, since MI technique/requirements may be different for each.
Landfill
• Additional information on possibility of Weston liner
• How standing water will be handled
• How will DUs be determined given the uncertainty of the dimensions of placed soil, especially depth
Black Tarp Stockpile
• Additional/revised details to include 100 cy (max) DUs and 50 increments
Laboratory and data
• What lab will perform the MI preparation
• How will the MI sample be processed, subsampled and documented to meet MI Guidance requirements
• Specify how 95% UCL will be calculated and will be used to determine compliance (<10 mg/kg PCB)
|
Louis Howard |
| 9/30/2011 |
Document, Report, or Work plan Review - other |
Lori Aldrich, SW Program comments on the [draft] final work plan for MI sampling soil in the landfill.
To be addressed in an addendum (email is acceptable) to this plan, I would clarification on the procedures for the proposed removal, sampling, and disposal of the leachate, as well as a clarified landfill sampling plan once you have the Weston landfill completion figures. I also want to clarify that for the soils disposed subsequent to installation of the Weston liner, I will consider them commingled; if any of the landfill samples are greater than 10mg/Kg PCB, all the soil deposited above the liner must be removed. |
Louis Howard |
| 10/2/2011 |
Update or Other Action |
NVPH/Boretide email to ADEC, 611, CORPS.
Activities performed during the week of September 25 – October 2 are listed below.
• Excavation Activities continued on the southern area of the exaction. Contaminated soil hauled to date = 8,239 CY.
1. PID field headspace samples were collected from the western sidewall down to approximately 20 feet bgs. The samples were collected per the ADEC Field Sampling Guidance. A total of 63 PID field headspace samples were collected.
2. Analytical confirmation soil samples were collected from the PID field headspace locations with the highest readings per ADEC field sampling guidance. A total of 31 confirmation soil samples were collected. These samples are on a 7 day TAT and scheduled to be analyzed for DRO/RRO and GRO/BTEX.
3. All samples’ locations were documented with a Trimble R8 receiver and Trimble R8 rover as part of the surveying requirements.
• Groundwater sampling continued. The following wells were sampled: BLO-MW-01, BLO-MW-02, BLO-MW-05, BLO-MW-06, DSA-MW-01, and DSA-MW-02. These samples are on a 14 day TAT.
• Continued supersacking the access road PCB soil. Was unable to complete because the hopper broke.
• Sampling was completed in the CSR2 area that was excavated from the location shown in the Backfill Hauling TM. A total of 90 samples were collected utilizing the grid sampling method for PCB analysis.
1. For samples 1 through 56 final results were received from SGS and all indicated that PCB concentrations are less than 1 ppm.
2. Preliminary results were received for samples 57 through 90. Samples 72, 73, 88, 89, and 90 indicated that PCB concentrations were between 1 and 10 ppm. This is the area closest to the access road.
3. All samples’ locations were documented with a Trimble R8 receiver and Trimble R8 rover as part of the surveying requirements.
• Twenty-two baseline samples were collected from the new landspread area to determine if any additional contaminants are present. These samples are scheduled to be analyzed for DRO/RRO, DRO/RRO (silica gel), TOC, VOC, GRO, SVOC, PCB, and PAHs. These samples are on a 14 day TAT.
1. All samples’ locations were documented with a Trimble R8 receiver and Trimble R8 rover as part of the surveying requirements.
Activities planned for the week of October 3 - October 9 are summarized below.
• Sample remaining Former RRS GW wells
• Collect the field headspace samples from the eastern sidewall of the POL excavation and confirmation soil samples.
• Collect field headspace samples and confirmation samples from the clean stockpile.
• Continue super sacking Access Road stockpile.
|
Louis Howard |
| 10/3/2011 |
Update or Other Action |
EMAX-SM01 Addendum revision 5, Section 5.13.2, Sept. 30, 2011 Ref. # SM01.5.1 received.
Laboratory Soil Sub-sampling Project Specific Procedure for 2011 Jacobs Alaska Project
SECTION 5.13.2 SHALL READ:
5.13 Sub-Sampling
5.13.1 ….
5.13.2 Soil Samples
5.13.2.1 Empty the sample container in glass tray and air-dry within a reasonable time approximately one to two days. If sample is relatively surface dry, proceed to sieving.
5.13.2.2 Pass the sample through #10 sieve. Discard the sample retained in the sieve.
5.13.2.3 Spread the passing #10 sieve sample in a flat clean tray. Take 30 incremental sub-samples of about 1-g of soil (approximately as illustrated below) into a properly labeled sub-sample container. For each increment scoop down to the bottom of the tray to obtain appropriate particle size representativeness. |
Louis Howard |
| 10/3/2011 |
Document, Report, or Work plan Review - other |
ADEC request to Jacobs
Please forward the EMAX-SM01 SOP for review. The submitted 1 page addendum does not demonstrate all of the MI criteria will be met. For example,
1) Per Molly’s email, is the lab aware that the MI samples may be up to 3 kg in size and the entire mass must be dried, sieved, subsampled?
2) The lab has “glass trays” and facilities large enough to accommodate multiple MI samples of this size?
3) The entire ~30 gram subsample must be extracted and analyzed?
4) Etc.
|
Louis Howard |
| 10/6/2011 |
Update or Other Action |
Jacobs is submitting additional information contained in this e-mail as requested by ADEC to clarify our plan to collect MI samples from the stockpiles and landfill at Port Heiden.
Landfill
Estimated Volume of Landfill Soil
A model of landfill soil volume was developed based on Weston’s as-built and additional measurements collected by Jacobs (See attached Landfill Volume Calculations). Soil volume is estimated at 809 cubic yards.
Water Removal and Management
Standing water currently contained in the landfill will be treated through a granulated activated carbon (GAC) system, and then pumped outside of the landfill area to holding ponds. Water in holding ponds will be tested for TAH, TAqH, and PCBs to demonstrate that water is acceptable for discharge.
GAC
Due to the potential high sediment concentration in the standing water, a 3 part GAC treatment system will be used. Water will first be processed through pillow scrubbers, followed by three particulate filters (20, 10, and 1 micron pore size), and finally through a 55 gallon GAC drum. Water will then be delivered to the holding ponds.
Holding Ponds
Holding ponds will be constructed outside the fenced landfill area (See attached Holding Pond Location). Holding pond dimensions will be approximately 30 feet by 50 feet, and 3 feet in depth. Surface of floor and sidewalls will consist of fine pumice overlaid by two 20 mil liners. Pre- and post sampling of soil underlying holding ponds will be conducted to demonstrate that no release of PCBs to the holding pond areas occurred.
Landfill Grading
Once the standing water in the landfill has been removed, the surface of the landfill cell will be sloped to promote run-off and avoid further collection of standing water.
MI Sampling of Landfill
The area to be characterized at the landfill is approximately 100 ft. x 80 ft. x 6 ft. Actual depths will be verified prior to sampling. After the landfill has been sloped to prevent accumulation of standing water, a sampling grid will be established over the area (See attached Landfill Sampling Plan). For the purposes of MI sample collection, the landfill will be divided into decision units as shown in Attachment 2. This will result in 12 decision units horizontally distributed to cause each to represent less than 100 cubic yards.
In each decision unit, a grid of sample borings will be equally distributed in general accordance with Attachment 2. Based on the depth of the material to be characterized, borings in locations not currently covered with water will be advanced in 1 foot intervals and an aliquot collected from each interval. The areas currently covered by standing water will be characterized to a depth of 9 inches. A total of at least 30 primary aliquots will be collected from decision units representing 50 cubic yard or less. A total of at least 50 primary aliquots will be collected from decision units representing between 50 and 100 cubic yards.
Stockpiles
Stockpile Spreading
As described in the “Multi-Incremental Sampling: Port Heiden PCB Landfill & Stockpiles at Radio Relay Station,” stockpiles will be flattened to a height of approximately 5’ prior to sampling. ADEC is not requiring that any liner be placed under these stockpiles as the underlying soil is believed to be contaminated.
MI Sample Analysis and Laboratory Related Processes
Laboratory MI Sample Preparation Clarifications
All laboratory MI sample preparation related issues have been resolved to the satisfaction of ADEC Chemist. (See attached Laboratory MI SOP and Laboratory Addendum).
Additional project specific requirements are as follows:
1) In addition to the field duplicate and triplicate samples, laboratory will collect duplicate and triplicate MI subsamples from the dried and sieved soil.
2) The entire 30 gram subsample will be extracted.
3) Results will be reported on a dry weight basis. The %solids sample will be collected at the same time as the subsample.
|
Louis Howard |
| 10/8/2011 |
Update or Other Action |
Email update sent to ADEC by AHTNA on behalf of Boretide and the Air Force
Activities performed during the week of October 3 – October 9 are listed below.
• Excavation Activities continued on the POL excavation. Contaminated soil hauled to date = 10,213 CY.
1. PID field headspace samples were collected from the eastern sidewall down to approximately 20 feet bgs. The samples were collected per the ADEC Field Sampling Guidance. A total of 78 PID field headspace samples were collected.
2. Analytical confirmation soil samples were collected from the PID field headspace locations with the highest readings per ADEC field sampling guidance. A total of 29 confirmation soil samples were collected. These samples will be on a 7 day TAT and scheduled to be analyzed for DRO/RRO and GRO/BTEX. The remaining 10 confirmation soil samples will be collected next week.
3. All samples’ locations were documented with a Trimble R8 receiver and Trimble R8 rover as part of the surveying requirements.
• Groundwater sampling continued. The following wells were sampled: RRS-MW-02, PG1-MW-01, and RRS-MW-04. These samples are on a 14 day TAT.
• Completed supersacking the access road PCB stockpile.
• PCB grid sampling was conducted in the area south of the stockpiled PCB soil.
1. These sample results were received and all sample results indicated PCB concentrations between 1 and 10 mg/kg.
2. All samples’ locations were documented with a Trimble R8 receiver and Trimble R8 rover as part of the surveying requirements.
• The lagoon was created to contain the water from the landfill and PCB grid sampling was completed in this area.
1. These sample results were received and all were non-detect.
2. All samples’ locations and the corners of the lagoon were documented with a Trimble R8 receiver and Trimble R8 rover as part of the surveying requirements.
• The second lagoon was also created in case the water from the landfill still contains PCBs greater than the ADEC cleanup level. The sampling of this area will be completed next week. The location of this lagoon was documented with a Trimble R8 receiver and Trimble R8 rover as part of the surveying requirements.
• The water filtration setup was completed and the majority of the water in the landfill has been processed.
Activities planned for the week of October 10 - 16 are summarized below.
• Collect the field headspace samples from the POL excavation and confirmation soil samples.
• Collect field headspace samples and confirmation samples from the clean stockpile.
• Complete filtrating the landfill water and collect confirmation samples.
|
Louis Howard |
| 10/11/2011 |
Update or Other Action |
Revised work plan received due to Friday 10/7/2011 meeting with AF & contractor as well as changing site conditions at the landfill. [NOTE to file: MI Sampling has already taken place for the stockpiles outside of the landfill and is ongoing at the landfill.]
For this project, soil samples will be extracted & analyzed using the MI method at the following three locations:
1. An existing landfill, approximately 100 ft. x 80 ft. x 3 ft;
2. An existing stockpile currently located at the former Radio Relay Station (RRS) site,
approximately 25 ft. x 29 ft. x 5 ft. & currently covered with a white tarp.; &
3. An existing stockpile currently located at the former RRS site, approximately 52 ft. x 21 ft. x 10 ft. & currently covered with a black tarp.
For the proposed MI Sampling Plan, Jacobs will follow all protocols outlined in Attachment 1 - ADEC MI Sampling Guidance (March 2009). Jacobs will document, both photographically in written-report form, all sampling activities conducted at the project site. The MI samples will be submitted to a Department of Defense (DoD) Environmental Laboratory Accreditation Program (ELAP) certified laboratory for MI-sample preparation & nonvolatile PCB detection analysis (e.g. sieving, sample preparation, sub-sampling, & analysis).
MI samples & subsample quantities will be collected at the following minimum frequencies:
1) Each MI sample representing up to 50 cubic yards will contain at least 30 subsamples.
2) Each MI sample representing up to 100 cubic yards will contain at least 50 subsamples.
Each one (1) ft. horizontal layer in each stockpile may be treated as a decision unit if the total volume represented is less than 100 cubic yards. If that layer represents more than 100 yards, then the stockpile or landfill area will be split into two or more sections & treated as separate stockpiles so that each layer does not represent more than 100 cubic yards. One primary MI sample will be collected per decision unit in both the landfill & the stockpiles.
The duplicate & triplicate MI sample collected from the landfill will be in the deepest decision unit layer in the northernmost decision unit. The duplicate & triplicate MI sample collected from the stockpiles will be from 0-1 ft BG. Each stockpile (or portion of stockpile) will be gridded into a 6 x 5 grid pattern if 30 subsamples are required, or a 5 x 10 grid pattern if 50 subsamples are required, & three locations within each grid (primary, duplicate, & triplicate) will be identified. The landfill area will be gridded into a 5 x 7 grid pattern.
Specific locations within each grid cell for the collection of the primary, duplicate, & triplicate aliquots will be identified by further dividing each grid cell into 4 quadrants, & locating the primary, duplicate, & triplicate in three of the 4 quadrants. The location selected as the primary will remain consistent through the final sampling depth of each stockpile or landfill location.
Sub-sample aliquots for each one (1) ft. layer will be collected & placed in Ziploc bags representing each layer for each stockpile, or stockpile section as necessary.
A model of landfill soil volume has been developed based on as-built drawings as well as additional measurements collected by Jacobs. Soil volume is estimated at 809 cubic yards. This area will be divided into 3 smaller decision units so that each one foot lift does not represent more than 100 cubic yards, & then each decision unit will be gridded into the appropriate grid pattern as necessary. All subsurface MI sample collection shall occur at each systematic increment grid location for each one (1) ft. layer. If the subsurface is 3 feet deep then, samples will be collected from 0-1, 1-2, & 2-3 ft. (BG) for a total of 9 decision units.
If the subsurface is 4 feet deep then samples will be collected from 0-1, 1-2, 2-3 & 3-4 ft. (BG) for a total of 12 decision units. If there are 9 decision units then one duplicate & triplicate sample will be generated at the deepest layer (BG) of the northern most decision unit which is the layer most likely to contain contamination. If there are 12 decision units then two sets of duplicates & triplicates will be generated. One set of Duplicate & triplicate samples will be generated at the deepest layer (BG) of the northern most decision unit as well as 0-1 ft. layer of either of the two remaining decision units.
Standing water currently contained in the landfill will be treated through a GAC system, & then pumped outside of the landfill area to holding ponds. Due to the potential high sediment concentration in the standing water, a 3 part GAC treatment system will be used. Water will first be processed through pillow scrubbers, followed by three particulate filters (20, 10 & 1 micron pore size), & finally through a 55 gallon GAC drum.
Water in holding ponds will be tested for TAH, TAqH, and PCBs to demonstrate that water is
acceptable for discharge.
|
Louis Howard |
| 10/12/2011 |
Cleanup Plan Approved |
ADEC Solid Waste (Lori Aldrich) and Contaminated Sites (Louis Howard) approve this revised plan.
Please be aware that the site cleanup rules (18 AAC 75) require department approval on workplans before beginning interim removal actions (18 AAC 75.330), site characterization work (18 AAC 75.355), or cleanup operations (18 AAC 75.360).
Failure to obtain workplan approval before implementing site work is considered a violation of Alaska regulations and may result in field work not being approved or additional work being required and may subject responsible parties and/or contractors to a Notice of Violation (NOV). |
Louis Howard |
| 10/12/2011 |
Update or Other Action |
Email to 611 CES and Boretide Confirmation Sampling: 50 samples for several thousands of cubic yards of “clean” fill previously excavated from 40’ excavation as determined by field screening. The sample results will determine the appropriateness for reuse in the 40’ deep excavation. Laboratory confirmation samples (data report) will be provided before approval to backfill will be provided by ADEC. Laboratory analyses will be for DRO, GRO, BTEX and PAHs unless the Air Force has previous laboratory data that justifies the reduction in contaminants of concern at this excavation.
You may want to split the mega stockpile into thirds or quarters before sampling so that the dirty sample result won’t make the entire stockpile unsuitable for backfill. |
Louis Howard |
| 10/12/2011 |
Update or Other Action |
Email from Boretide RE: Confirmation Sampling. we collected all 50 stockpile samples today. They'll ship to SGS tomorrow. PAH samples have been collected.
The attached figure shows PAH results for samples Weston collected while excavating the GLO area in 2009. Please review these results and let us know if you'll require our 50 PAH samples to be run. There are some "J" and "F" flags, but the results are below regs.
If you deem Weston's results sufficient, I'll have SGS forgo analyzing ours. Otherwise, SGS will analyze our PAH samples with the DRO, GRO, and BTEX samples.
|
Louis Howard |
| 10/13/2011 |
Update or Other Action |
Email to Air Force and Boretide RE: Confirmation Sampling
Direct contact cleanup level of 0.49 mg/kg is the cleanup level for Benz(a)pyrene –figure provided has two exceedances for PAHs out of twenty-two samples
ID Location ID
1254 19-SW-W-R03-10 0.56 mg/kg ABOVE cleanup levels
1255 19-SW-W-R03-10 0.58 mg/kg ABOVE cleanup levels
Air Force response Email 10/13/2011
We'll run the PAHs. THanks for double checking. |
Louis Howard |
| 10/16/2011 |
Update or Other Action |
Boretide email to ADEC & 611, CORPS, NVPH
Tasks performed during the week of 10-Oct through 16-Oct include the following.
• Digging at the GLO excavation (locally known as "Pebble Mine") was halted. This excavation will eventually be backfilled. The pit bottom still emits a strong POL odor, but the sidewalls have no discernable POL odor. The pit bottom perimeter was surveyed
• The remaining GLO excavation sidewall samples were collected and shipped to SGS. Results are expected Thursday
• DRO, GRO, BTEX and PAH samples were collected from 50 locations in the "clean" GLO excavation stockpile. These were also shipped to SGS and results are likewise expected Thursday
• All surveying efforts concluded
• ~140 super sacks were transported to the BSA. No full super sacks remain at the Former RRS. The current ETA for Elm's (waste removal contractor) barge is Friday
The following three items are anticipated to be the final large tasks the CA Project will perform during the 2011 field season. The field team is estimating it will take another two weeks to complete these three items.
1. The super sacks at the BSA will be removed. Based on the dubious premise that the barge will be punctual, this task should conclude around 25-Oct
2. The GLO excavation will be backfilled. The sequence of events for this task is dependent upon analytical results which are due on Thursday. Upon arrival, these results will be forwarded to ADEC. No backfill activities will begin until ADEC approval to do so is granted
3. PCB excavation activities at CSR2 will conclude in an orderly fashion. As is the case with the GLO excavation, the sequence of events for this task depends on the results of analytical lab data. When results from Jacobs' sampling efforts at the Landfill and the CSR2 stockpiles are known, I will email this list with a proposed plan of action. The CA Project will not excavate or transport additional PCB contaminated soils until such time.
|
Louis Howard |
| 10/24/2011 |
Update or Other Action |
Email from Boretide to ADEC, 611, CORPS and NVPH
1. We received lab results last week for the GLO excavation. The bottom still exceeds regs for DRO (~3K mg/kg). We expected this. The bottom perimeter was surveyed and covered with felt. All sidewall and "clean" stockpile samples were below Migration to GW Regs. Hence, we began backfilling the excavation this weekend and are about 75% done. Backfilling will be completed before we demobilize.
2. We sampled both GAC filtered water holding ponds (PCB, TAH, TAqH). These samples shipped to SGS yesterday. Both samples should arrive today. 1-day TAT. We expect results tomorrow.
3. Once we have final PCB soil results for the stockpiles and Landfill, we will propose, via email, an optimal plan of attack based on PCB contaminant levels. No PCB contaminated soil will be excavated until approval to do so is granted.
4. My premise last week that the barge would be punctual did indeed prove to be dubious. The barge ETA is now "early this week." All super sacks though are ready for removal when the barge arrives.
Once these four items are done, we will winterize equipment and facilities and shut down for the year.
|
Louis Howard |
| 10/24/2011 |
Update or Other Action |
Email to 611, Boretide and EPA re: PCB soils not being disposed of and stockpiled or otherwise stored until 2012.
The Air Force has the authority to conduct PCB characterization and disposal and/or remedial activities under CERCLA. EPA Region 10 (Jacques Gusmano 10/19/2010 email attached) has stated there is no need for a TSCA Permit “to exceed the storage time limitations”.
However, any super sacks (now a PCB container*) or stockpiles of “bulk PCB remediation waste (includes soil and sediments) that won’t be disposed of containing PCBs needs meet the substantive requirements of TSCA for storage beyond the deadline required by regulation (e.g. the conditions for storage and labeling/marking** still apply).
*PCB Container means any package, can, bottle, bag, barrel, drum, tank, or other device that contains PCBs or PCB Articles and whose surface(s) has been in direct contact with PCBs.
761.61 PCB remediation waste
(B) Bulk PCB remediation waste may be sent off-site for decontamination or disposal in accordance with this paragraph, provided the waste is either dewatered on-site or transported off-site in containers meeting the requirements of the DOT Hazardous Materials Regulations (HMR) at 49 CFR parts 171 through 180.
(1) Removed water shall be disposed of according to paragraph (b)(1) of this section.
(b) Performance-based disposal. (1) Any person disposing of liquid PCB remediation waste shall do so according to § 761.60(a) or (e), or decontaminate it in accordance with § 761.79.
**Mark means the descriptive name, instructions, cautions, or other information applied to PCBs and PCB Items, or other objects subject to these regulations. Marked means the marking of PCB Items and PCB storage areas and transport vehicles by means of applying a legible mark by painting, fixation of an adhesive label, or by any other method that meets the requirements of these regulations.
While ADEC may comment on other state and federal laws and regulations, our comments do not relieve the Air Force, its contractors, agents or other persons who perform work on the Air Force’s behalf (i.e. responsible persons) from the need to fully comply with other applicable laws and regulations.
Email from Jacques Gusmano (EPA) to 611, Boretide re: PCB soils not being disposed of and stockpiled or otherwise stored until 2012. Louis is right, you must meet the substantive requirements for storage and labeling. TSCA Region 10 , Dan Duncan, should be contacted if a variance is desired. |
Louis Howard |
| 10/26/2011 |
Update or Other Action |
Staff recieved the preliminary sample results from the Large and Small stockpiles ranging from 1.4 mg/kg to 4.8 mg/kg for the Large stockpile and 0.19 mg/kg to 4.8 mg/kg total PCBs for the Small stockpile. |
Louis Howard |
| 10/27/2011 |
Update or Other Action |
Staff received the preliminary sample results for the soil from the landfill. All samples in all decision units were greater than 10 mg/kg total PCBs allowed by the Landfill permit. Concentrations ranged from 13 mg/kg to 24 mg/kg. A work plan will be developed to confirm what is left behind at the landfill was not impacted by the soil which needs to be removed from the landfill. Sampling will be consistent with what was previously approved by ADEC for a very similar activity at the landfill. |
Louis Howard |
| 10/27/2011 |
Update or Other Action |
Email from SW Program to Air Force (Pat Roth) and contractor: I concur that bagging and removal of the soil may proceed while a plan for confirmation sampling and closure is being developed. To clarify, all soil deposited beyond the barrier that Weston place must be removed from the landfill. Sampling, according to an approved sampling plan, must confirm that the remaining soil is <1ppm PCB.
The excavated area must be backfilled with clean soil and a cap must be constructed over both the PCB soil and the clean soil cell that is at least 24 inches of clean soil, at least 1 foot about surrounding tundra grade, graded to promote run off, and revegetated next summer. In addition, the cap must be monitored at least annually for no less than 5 years for any signs of settlement, erosion, or instability.
Please let me know if you have any questions.
Lori
Subsequent email to WESTON contractor from SW Program re: Port Heiden - Tank N Area QC Issue:
You will not be able to dispose the additional soil at the landfill. Based on sampling results, ADEC is essentially rescinding the approval for disposal of additional soil beyond the original project, and requiring removal of all additional disposed soil. |
Louis Howard |
| 10/28/2011 |
Update or Other Action |
Email from Air Force to Contractor (Thor): Original question: what will be the PCB sampling frequency for the clean backfill? I've cc'd Greg DuBois. He will be replacing me on this project
The sampling must cover a bit more than PCBs. If we use the same borrow pit WESTON used in 2009 (the one located near the landfarming area) we will need one per every 1,000 cubic yards of in-place material analyzed for PCBs, PAHs, DRO, and RRO.
If we use any other source (such as the pit closer to town or the material from near Jack's Place) then it will be one per every 1,000 cubic yards of in-place material analyzed for PCBs, PAHs, DRO, RRO, Pesticides and VOCs.
In the work plan, the backfill course areas need to be defined. If after works starts, any other area is to be used, ADEC must be notified before any fill is excavated from the proposed location.
Pat
Subsequent ADEC email on same subject:
Add gasoline range organics (GRO*) and metals** to the list of COCs required for laboratory analysis IF you use ANY other borrow source other than the same borrow pit WESTON used in 2009. Other than the two added COCs, ADEC concurs with the approach listed below by the Air Force.
Per Appendix D – Sample Collection Reference Guide – Soil, Sediment, Sludge, Fill Material, ADEC Draft Field Sampling Guidance May 2010:
*AK101 4 oz. amber glass, TLS Methanol preservative, 4o ± 2oC / 28 days holding time. The AK101 method can be extended for specific determination of volatile aromatics (BTEX) as specified in EPA Method 8021B or 8260B for solids utilizing methanol preservation option only. All AK101 and volatile aromatic samples (e.g. VOCs either 8260C or 8021B) must be preserved with methanol.
**Metals 6010C, 6020A, 100mL Wide mouth HDPE*** or amber glass jar, TLC 6 months holding time. Metals must include arsenic, barium, cadmium, chromium, lead, nickel, and vanadium, unless otherwise noted.
***HDPE, High Density Polyethylene or amber glass sample collection bottles, certified clean for trace metals analysis. |
Louis Howard |
| 10/28/2011 |
Offsite Soil or Groundwater Disposal Approved |
Email from contractor (Thor) GAC Water Results
we have two holding ponds we've been filtering. All PCB, TAH, and TAqH results for water associated with GAC-02 are less than regs. Do we have ADEC's permission to discharge this water to ground surface?
The only analyte above regs for GAC-01 was Aroclor-1260. We will filter this water again and resample for PCBs.
Subsequent email from Air Force
Here is a draft sample of what Weston filed before a water discharge [WW General Permit Contained Water GP]. The final version listed Weston as the responsible party - not me. The one you are doing should list either NVPH or Boretide as the RP.
Subsequent email from ADEC
Also be aware you need to fill out a separate NOI permit for each separate discharge.
|
Louis Howard |
| 10/28/2011 |
Update or Other Action |
WESTON completed a Notice of Intent, State of Alaska Wastewater General Permit Number 2009DB0004 for Contained Water Discharges. Submittal of this document constitutes notice that the responsible party identified in Section 2 intends to be covered by the State of
Alaska General Permit No. 2009DB0004. This permit authorizes wastewater discharges to waters or lands of the State resulting from excavation dewatering activities and obligates the permittee to comply with the terms and conditions of the permit.
Identifying, excavating, and performing soil washing on soil containing PCBs greater than or equal to 10 mg./kg. Identifying and excavating the remaining PCBlPesticidelP AH contaminated soils above cleanup levels and disposing of it in a local landfill. Excavation POL co.ntaminated soil and placementin longterm stockpiles. Demolition and removal of miscellaneous items and debris.
The intended discharge area is in a low-shrub and ericaceous tundra habitat. Groundwater in the area of the Former Facility Area pad averaged approximately 60 feet bgs. The direction of groundwater flow is to the north. The nearest surface water is a: tributary of Reindeer Creek approximately 3/4 ofa mile north of the site.
A Granulated Activated Carbon (GAC) water treatment system is used to remove organic contaminants from waste water generated during the decontamination of field equipment and tools. The GAC filtration system is composed of two 55-gallon drums filled with approximately 175 pounds ofGAC. Sampling data of treated water is attached.
Maximum anticipated discharge flow rate: 2000 gal. per day
Average anticipated dishcarge flow rate: 500 gpd
Total anticipated discharge: 10000 gallons
Discharge velocity at end of pipe: 2 feet per second.
Anticipated Start date: 8/6/2009
Anticipated completion date: 10/1/2009
Signed Hudson Graham 8/6/2009 |
Louis Howard |
| 11/2/2011 |
Update or Other Action |
Email from Greg DuBois APC Services LLC to Dan Duncan Region 10 TSCA Program RE: PCB Impacted Soil Storage
I just left a voice mail message for you and am following up with an email. We are placing PCB impacted soil into super sacks. The PCB sample concentrations range from 13 to 25 mg/kg. We had planned to transport this soil this year and we have an empty liner at the boat landing that has bermed sides, a felt liner on top of the soil with a 20 mil liner on top of the felt.
We've just been told that the barge will not be able to transport the soil this year. We are continuing to place this soil into supersacks at the Port Heiden landfill and we have state permission to transport the soil to the boat landing containment area (assuming temporary storage).
However, since we will now be holding the supersacks over the winter, our understanding is that we need EPA approval regarding the storage location and of course to have acceptable containment and placarding.
Our preference is at the boat landing where we have the containment area prepared and where it can be loaded and transported as soon as possible next barge season.
Please let me know if you have further questions and/or requirements,
|
Louis Howard |
| 11/3/2011 |
Update or Other Action |
Staff received the Draft Corrective Action Report for Remedy Selection & Implementation, Demolition & Debris Removal, Port Heiden Radio Relay Station, Port Heiden Alaska. The purpose of these 2011 corrective actions was to complete the cleanup & removal effort at Port Heiden RRS, as outlined in the Proposed Corrective Action Approach. The goal of the corrective actions was to excavate & properly dispose of all washed soils within the NVPH LF, all debris & associated unwashed soil with PCB levels greater than the NVPH LF permit limit of 10 mg/kg in the NVPH LF, excavate & properly dispose of all soils with concentrations greater than the ADEC Method Two cleanup level for PCBs of 1 mg/kg from the SWA, & to properly dispose of items that that were allegedly left at the RRS by WESTON’s subcontractor, including tanks allegedly used in the soil washing process, connexes, & a cement mixing truck.
The 2011 corrective actions consisted of 5 primary tasks: 1) the removal, transportation, & proper disposal of all washed soils & miscellaneous debris within Cells 2 & 3 of the NVPH LF & associated unwashed soils with PCB levels over 10 mg/kg; 2) the removal, transportation, & proper disposal of contaminated soils with PCB levels greater than 1 mg/kg from the SWA; 3) the characterization, removal, & disposal of PCB-contaminated soils from the TAA; & 4) the sampling &/or decontamination of previously used field equipment, materials, & supplies, & the sampling & proper disposal of investigation derived waste (IDW) allegedly left on site by WESTON’s treatment contractor.
Approximately 1,229 cy of soil containing PCB levels greater than 1 mg/kg but less than 10 mg/kg from the SWA were hauled to the NVPH LF & placed in Cell 3. The final cover was placed on Cell 3 on 11 & 12 September 2011. The cover was comprised of the cap material that was removed from Cells 2 & 3, with 6-8 inches of organics placed on top. A 12-mil polyethylene liner was placed on the western sloped edge between the filled Cell 3 & the open Cell 2 as a delineation of WESTON placed soils & any future placement of materials in Cell 2 as well as cap materials, as agreed upon with the NVPH & USAF.
WESTON surveyed the boundaries of the interior road & loaded them into the project GIS. Using an estimated thickness of 4", the interior road was split into two upper & two lower DUs each approximately 100 cy. A random point generator was used to randomly place 40 subsample locations in DU-01 & 120 subsample locations in DU-02 to facilitate collection of a primary sample from both DUs, & a duplicate & triplicate sample from DU-02. WESTON completed multi-incremental (MI) sampling of the upper DUs, & then used the same locations to gain access to & sample the lower two DUs to avoid cross contamination.
A 2nd triplicate sample was collected from the lower materials. All primary, duplicate, & triplicate MI samples had non-detect results, & therefore, no percent relative standard deviation (%RSD) or 95-percent upper confidence limit (95% UCL) calculations were required in accordance with ADEC guidance.
A pre-final site inspection was conducted with WESTON, AFCEE, the USAF 611 CES, & the AFCEE Title II Representative. A punch list of items was generated during this inspection, & AFCEE designated release authority to the AFCEE Title II Representative after this meeting. Seven items were discussed with regard to the NVPH LF during the pre-final inspection conducted on 6 September 2011. The actions that WESTON agreed to execute in closing out the NVPH LF included:
• Create in-place MI DUs for the access road in the landfill,
• Slope & place divider liner on slope between Cell 2 & Cell 3,
• Decontaminate Cat D6 dozer used to backfill Cell 3,
• Replace clean overburden cap,
• Document the final condition of the landfill post-backfilling & cover,
• Remove personnel connex, &
• Place orange temporary fencing at fence opening for truck access.
All of these items were accomplished & the final inspection was completed with the AFCEE Title II Representative & WESTON Project Manager Dale Greinke on 13 September 2011. The AFCEE Title II Representative did not have any outstanding concerns.
Confirmation sampling at the SWA consisted of 9-point composite sampling of grid square bottoms, & discrete sidewall samples collected from any existing sidewall between adjacent grid squares. Numerous adjacent grid squares were excavated to similar depths leaving no sidewall in between; therefore, no sidewall sample could be collected. Each time a new sidewall sample came back exceeding 1 mg/kg, a new grid square was centered on the sidewall, excavated, & confirmation samples were taken. Sump excavation confirmation samples were collected directly from the excavator bucket, & 5-point composite samples were used to characterize sidewalls greater than 2 feet in depth. |
Louis Howard |
| 11/3/2011 |
Cleanup Plan Approved |
Staff received the draft final Work Plan Addendum: PCB Impacted Soil Removal, Port Heiden Landfill Former Port Heiden Radio Relay Station Port Heiden, Alaska November 2011. SW & CS staff approved the work plan for implementation.
Introduction
The Native Village of Port Heiden (NVPH) is conducting investigation & removal activities at the former Port Heiden RRS as part of a Cooperative Agreement (CA) with the AF. PCB impacted soil was removed from Contaminated Soil Removal Area 2 (CSR2) from the former RRS, & transported to the Port Heiden community landfill. ADEC SW had approved placement of PCB impacted soil up to 10 mg/kg into a designated cell.
(NOTE TO FILE: Transport of soil by NVPH/Boretide was not approved by ADEC as required PRIOR to placement at the landfill nor was the soil sampled via EPA grid sampling procedures and only 4 discrete soil samples represent the 800 CY of PCB contaminated soil placed at the landfill.)
After placement of the soil into the designated landfill cell, Jacobs Engineering collected samples using an ADEC approved Multi-Incremental (MI) sampling method & sent the samples to SGS Alaska for analysis. The MI preliminary sample results ranged from 13 mg/kg to 25 mg/kg exceeding the 10 mg/kg allowable concentration.
In an October 31, 2011 letter from ADEC to the Air Force & the NVPH, ADEC revoked approval to place the CSR2 soil into the landfill. Therefore, ADEC requires removal of the soil that was placed into the landfill from CSR2, backfilling of the cell with clean soil, & seeding of the landfill cap in 2012.
PCB Soils at the Landfill & Cleanup Levels
Earlier in 2011, Weston conducted soil sampling of the floor & walls of the excavation area. Sample analytical results from the floor & walls of the excavation area where CSR2 soil was placed, had PCB results up to 9 mg/kg. Weston placed impacted soil up to 10 mg/kg east of the CSR2 soil cell & placed a fabric liner there to delineate the extent of the soil they placed in the landfill. All CSR2 soil will be removed. After removal of the CSR2 soil confirmation samples will be collected for PCBs with a cleanup level of 10 mg/kg.
Methodology
NVPH will remove the PCB impacted soil to the depth & extent of the original area. The soil will be removed using an excavator & placing it through a hopper into super sacks. Each super sack will be given a unique number identifier, weighed, & manifested for shipment by ELM.
After removal of the CSR2 soil, NVPH will grid the excavation floor into 15’ by 15’ grids & use the USEPA hexagonal grid sampling methodology (1986) for confirmation sampling.
A 10’ square PVC template subdivided into 4 5’ squares will be placed into the center of each grid. Composite samples will be collected from the 9 pts of intersection created by these 5’ grids. One dedicated decontaminated stainless steel sampling spoon will be used to collect soil from each of the 9 locations. The soil will be composited in a decontaminated stainless steel sampling bowl or plastic sealed bag. The composited soil will be placed into an 8 oz sample jar for lab analysis. Sidewall samples will be collected every 20 linear feet or at least one sample per sidewall. The excavation extents & grid locations will be marked/staked. Global positioning system (GPS) readings & taped measurements will be taken so the excavation, grid lines & sample locations can be reestablished.
If analytical results indicate grid areas or a sidewall still exceed the cleanup level, approximately 1' of soil will be removed from that grid or sidewall area & another sample collected for lab analysis. This process will be repeated until all areas of the excavation meet the approved cleanup level of 10 mg/kg for PCBs.
After ADEC has received & approved the excavation confirmation results, the site will be backfilled with clean soil material. ADEC requires sampling of the backfill material prior to its use. The backfill soil will have a minimum of one sample collected for every 1,000 cubic yards of soil.
Approximately 800 cy of soil had been removed from near Ray’s office building and stockpiled at the landfill for the purpose of backfill. One sample will be collected from the stockpiled soil. Approximately 1,000 cy of additional fill material will be required. A “small stockpile” sampled by Jacobs using MI methods had lab analytical results below 1 ppm. ADEC has granted approval to use that soil for backfilling at the landfill. It is anticipated additional soil will be required to bring the site up to the grade required by ADEC.
The ADOT borrow pit is not available, as it can only be used for road work. Therefore, backfill will be obtained from either the Alaska Peninsula Corporation borrow pit, or from a borrow pit near the RRS. |
Louis Howard |
| 11/4/2011 |
Update or Other Action |
Email APC Services LLC working on behalf of NVPH and the Air Force to David Bartus Region 10 TSCA Program. RE: PCB Impacted Soil Storage
I understand that ADEC works with both yourself and Daniel on EPA related issues, and it was suggested that I might contact both yourself and Daniel since depending on your immediate workloads, one of you may have more availability than the other. I recently came on board this project.
Looks like we will be storing PCB impacted soil over the winter and we need EPA approval and guidance as to where and how. Please see below.
We appreciate the EPA's help in this matter. |
Louis Howard |
| 11/4/2011 |
Update or Other Action |
EPA Region 10 Dave Bartus TSCA Program email to Greg DuBois working on behalf of NVPH and the Air Force RE: PCB Impacted Soil Storage.
Thanks for the e-mail. Here's my quick and dirty analysis and suggestion for a path forward. I'm largely relying on my recollection and assumptions, so please consider everything in this e-mail subject to revision.
I'm assuming that this issue relates to PCB-contaminated soils that had been placed in the Port Heiden Landfill. One of the first questions we need to settle is whether or not the soils in question are PCB remediation waste. as defined in 40 CFR 761.3.
Given the very convoluted history of these soils, I think it will be a very difficult to clearly document that the soils with the as-found concentrations cited below do not meet the definition of PCB remediation waste. In these instances, the EPA concludes that such soils do meet the definition of PCB remediation waste, and are subject to the requirements of 40 CFR 761.61.
As a side note, the EPA views the retrieval of PCB-contaminated soils from the Port Heiden landfill as having been proceeding according to the performance-based disposal requirements of 40 CFR 761.61(b), so no written authorization has been necessary.
However, we did not consider the question of storage, which is not provided for under 761.61(b).
In this instance, storage of PCB remediation waste is subject to the requirements of 761.65, including the requirement to have a written storage authorization.
We have two questions that need to be answered concerning storage - first, are the proposed management standards acceptable, and [second] how can they be authorized.
The method of storage outlined below at the boat landing does not appear to meet the technical standards of 761.65(b). For over-winter storage, I'm not comfortable with the method of storage, since it appears to allow accumulation of precipitation, within the lined bermed area.
Accumulated precipitation would then saturate soils in supersacks, which would likely create quite a mess in the spring, since the sacks would be considerably heavier, and likely drip contaminated water once loaded on the barge in the spring.
At a very minimum, there will need to be some sort of a cover to ensure precipitation does not accumulate within the storage area. I also think it would be appropriate to have monitoring of the storage area, such as weekly, to ensure everything remains intact. I recognize that these points are likely to make the proposed storage more complicated than anticipated.
[Second] As far as a mechanism for authorizing over-winter storage, I'd recommending a risk-based disposal approval under 761.61(c). This will require a written request to the EPA, signed by both the property owner and whomever is ultimately responsible for the soils, which I presume is the Air Force.
I think we'll need to have additional discussion before making final decisions. Unfortunately, I'm pretty booked up today, although I may be able to give Greg a call later this morning. We probably should schedule a phone conference next week to make sure I'm up to speed on all of the relevant fact patterns, and to figure out the best option.
I don't have a problem starting with the assumption that there is a legitimate need to store soils over-winter. What we need to figure out are the technical and regulatory requirements that need to be in place to make sure the storage is conducted safely and legally. |
Louis Howard |
| 11/14/2011 |
Update or Other Action |
Title II Oversight MI Sampling Report received.
The Air Force Center for Engineering and the Environment (AFCEE) has tasked North Wind, Inc.
(North Wind) with conducting Title II oversight of activities associated with the Port Heiden Radio Relay Station (RRS) under contract FA8903-08-D-8786, Delivery Order 12. This report describes the activities associated with the multi-incremental (MI) sampling for polychlorinated biphenyls (PCBs) within the stockpiles and landfill associated with the RRS.
Field activities associated with the MI sampling began on October 5, 2011 and were completed on
October 13, 2011.
The purpose of the oversight was to ensure that tasks associated with the MI sampling of the PCB soil stockpiles and landfill were conducted in accordance with the Alaska Department of Environmental Conservation (ADEC) approved Work Plan (Jacobs, 2011) and with the ADEC guidance for MI sampling (ADEC, 2009). Oversight was conducted on the following tasks:
• Removal of standing water from the PCB landfill, treatment of the water, and confirmation testing of the treated water;
• Collection of samples from two soil stockpiles located near the former RRS using the MI sampling method; and
• Collection of samples from the PCB soil landfill using the MI sampling method
The field activities were conducted in accordance with the ADEC approved Work Plan and the ADEC MI sampling guidance. The only noted exception to the Work Plan was the discovery of small, discontinuous areas of deeper soil located within the PCB landfill. Mr. Marty Gililand (of Jacobs) relayed this discovery to Mr. Earl Crapps (of ADEC) and arrived at the decision to include all of these deeper soils in a single decision unit.
The incremental soil material was placed into Ziploc® bags, chilled, labeled, and shipped to the Jacobs office in Anchorage, Alaska. The sieving and subsampling of material at the selected laboratory was not observed and no determination can be made through this oversight of the regulatory compliance of any of the steps beyond the collection of the bulk material. |
Louis Howard |
| 11/15/2011 |
Update or Other Action |
2nd IC Performance report received. The purpose of this report is to document reviews of the remedial actions selected in the 2009 Record of Decision (ROD) for the remediation of sites at the Port Heiden Radio Relay Station (RRS) & to determine whether these actions are protective of human health & the environment, & are functioning as designed.
During the 2009 remedial activities approximately 9,200 cy of PCB-contaminated soil had been removed from the RRS. Dieldrin, originally identified in the RI (2006) was not found at the RRS during the 2009 field season. It is noted no work took place at the RRS Landfill & dieldrin may be present at that site.
As approved by ADEC, the excavations were backfilled to within 2’ of the original surface. Edges were contoured to eliminate a sharp drop. Rainwater would from time to time pool in these depressions. As dieldrin was not present, no further steps were taken to eliminate the temporary ponding of water. The AF plans to submit a modification to the ROD to eliminate the need for an IC related to dieldrin at the RRS.
During the 2010 field season, another (approximately) 3,000 cy of PCB-contaminated soil was removed from the site in accordance with the ROD & ESD. During a heavy-rain event, a substantial amount of water was pooling at site. A trench was dug thereby allowing the water to drain from the site. Again, no work was completed at the RRS Landfill where rainwater continues to naturally flow off the existing cap.
During the 2011 field season, Weston Solutions (Weston), Jacobs Engineering (Jacobs), & the Native Village of Port Heiden (NVPH) were involved in removing PCB-contaminated soil. A combined total of (approximately) 16,763 cy of PCB-contaminated soil & PCB-contaminated debris was excavated from the site in accordance with the ROD & ESD & (approximately) 10,000 cy of the excavated PCB-contaminated soil remain in Port Heiden pending final disposal.
Weston removed approximately 2,700 cy of PCB-contaminated soil & debris from the Class III landfill. Weston partially backfilled the landfill with approximately 1,229 cy of PCB-contaminated soil from the Soil Washing Area near the RRS. (The remainder of the landfill excavation was left open to be closed by the NVPH.) Additionally Weston shipped off-site (approximately) 396 cy of PCB-contaminated soil & 16 cy of PCB-contaminated debris from the Soil Washing Area near the RRS; 10 cy of PCB-contaminated soil from the Tank Abandonment Area, 8 cubic yards of PCB-contaminated soil from the New Tank Area, & 4 cy of PCB-contaminated soil & debris from Area 10 of the RRS. In addition to the soil & debris excavated, Weston removed several connexes, tanks, & a cement truck. These actions by Weston were corrective actions to the 2009 field season.
See site file for additional information.
|
Louis Howard |
| 11/15/2011 |
Document, Report, or Work plan Review - other |
Staff reviewed and approved via email the 2nd annual IC performance report. |
Louis Howard |
| 11/21/2011 |
Update or Other Action |
TECHNICAL MEMORANDUM: PORT HEIDEN PCB SOIL WASTE TRANSPORTATION AND DISPOSAL - OVERWINTER STORAGE OF NON-TSCA SUPER SACKS
The U.S. Army Corps of Engineers (USACE) contracted Bethel Services Inc. (Bethel) on behalf of the U.S. Air Force (USAF) to prepare this Technical Memorandum to address the temporary storage of 88, five-cubic yard super sacks of polychlorinated biphenyl (PCB)-contaminated soil. This soil was packaged and staged for transport via barge and disposal at an off-site disposal facility. Due to inclement weather conditions, these sacks will be temporarily stored until 2012.
This Technical Memorandum will outline the storage plan for the super sacks until they are transported and disposed of during 2012. This Technical Memorandum will be appended to the September 2011, Waste Transport and Disposal Plan (WTDP).
Bethel was contracted by USACE on behalf of the USAF to fill, transport, and dispose of 200 super sacks (1,000 cubic yards/l,058.26 tons) of non-Toxic Substances Control Act (TSCA), PCB-contaminated soil along with 10 cubic yards/8.76 tons (two super sacks) of TSCA regulated soil in 2011. The contract also includes handling, transporting, and disposing of additional quantities of soil during 2012.
Bethel filled these 200 super sacks during September 2011 and staged the sacks near the barge landing for barge loading and transport from the site during 2011, weather and site conditions permitting.
A total of 112 non-TSCA super sacks and the two super sacks of TSCA-regulated soil were loaded onto a barge on November I and 2, 2011. Currently, these are being transported via barge to Seattle, Washington and will ultimately be disposed of at Waste Managemenfs facilities in Arlington, Oregon.
The 88 super sacks that remain could not be transported via barge from Port Heiden during 2011 due to inclement winter weather conditions experienced after November 2, 2011. Currently, these super sacks are staged on a reinforced 10-mil polyethylene liner.
This non-TSCA regulated contaminated soil contains PCB concentrations ranging between 1.72 mg/Kg and 16.4 mg/Kg as determined through analytical testing. The sampling was performed by Jacobs Engineering (Jacobs) during the Site Road Characterization and Cleanup effort performed in Port Heiden during the summer of 20 II. The samples were analyzed by Environmental Services and the results are included with this Technical Memorandum.
As of the date of this Technical Memorandum, 88 super sacks remain on site near the Port Heiden Barge Landing. The sacks are staged on a 10-mil polyethylene liner and will be moved onto a thicker minimum 20-mil petroleum resistant liner that meets the specifications outlined within the Alaska Administrative Codes 18 AAC 75.370 Table D Bottom Liner Specifications. A top liner with the minimum specifications of no less than 10-mil will be used to cover the super sacks and the cover liner will be secured in place using sand bags. The specification sheets for the super sacks and bottom liner options are included with this Technical Memorandum. The liner will be sited in a lay-down area that has been cleared of detritus and other sharp objects.
The footprint of the temporary storage area will be approximately 1,500 square feet in size if the super sacks are stacked two high. The schedule for moving the super sacks is dependent on weather, availability of equipment and labor. Bethel is working with Aniakchak for scheduling and has tentatively planned to perform the work during the week of November 28,2011.
The temporary storage area will be located near the barge landing but located greater than 100 feet from all surface water bodies, all private water systems, all Class C Public water system as defined in 18 AAC 80.1990, or any fresh water systems that use groundwater for a use designated in 18 AAC 70.020(a)(I)(A) and 18 AAC 70.050(a)(2). There are no community wells in Port Heiden and all public water systems are more than 3,000 feet from the proposed storage area.
The storage area will be visually inspected a minimum of once a week to ensure that the cover liner remains secured. The liner will be secured as necessary until the material is transported from the site. Photographs will be taken for documentation and provided to the USACE. |
Louis Howard |
| 11/23/2011 |
Document, Report, or Work plan Review - other |
Staff approved the technical memorandum for storage awaiting disposal in 2012. ADEC has reviewed the technical memorandum with regards to storing PCB contaminated soil currently in super sacks awaiting disposal next season at a permitted facility in the Lower 48. ADEC will approve the proposed storage for a period of no more than 180 days (approximately May 24, 2012). Extensions beyond this date will be reviewed by ADEC.
For example, good cause for extension requests could be due to barge scheduling issues. Please note, ADEC review and concurrence on the proposed storage technical memorandum 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 approval does not relieve the Air Force or agents acting on its behalf(i.e. CORPS of Engineers, contractors, subcontractors or other civilian personnel) from the need to comply with other applicable laws and regulations (i.e. 40 CFR 761). |
Louis Howard |
| 12/4/2011 |
Update or Other Action |
NVPH Cooperative Agreement Update:
PCB Impacted Soil Removal, Confirmation Sampling, and Backfilling
Confirmation sample results were received November 29, 2011. Soil samples from six grid cells had analytical results above the 10 mg/kg cleanup level: A1, A2, A3, B2, B3 and D1. On November 30, 2011 additional soil was removed from those same grid cells and those areas were re-sampled and air-shipped to SGS. SGS provided preliminary sample results on December 3, 2011with the samples from A1, A2, A3, B2 and B3 non-detect, and D1 with PCB results at 0.29 mg/kg.
ADEC reviewed the data and provided approval to backfill the excavation with a notation that if the Final laboratory report has results above the 10 mg/kg cleanup level, that the area will require re-excavation and re-sampling.
NVPH began backfilling the excavation December 3, 2011. Backfilling continued December 4, 2011 and was near completion by the end of the day.
Water treatment system
Water storage cells are frozen and were covered with 20 mil liner.
Impacted Soil Covers
At the RRS the PCB impacted soil stockpiles and grid cells were covered. The super sacks at the boat landing were also covered with one liner including the super sacks of Bethel Services, Inc. All covers were anchored with clean soil around the outside of the liners. Clean soil was placed on top of the stockpiles and a limited number of sandbags were available to place on top of the covers. Additional sand bags need to be obtained, filled and placed on top of the covers.
Plans
1) Receive final laboratory report from SGS.
2) Finish backfill and grading of landfill for end of the year (it is likely the soil will settle and require additional grading in 2012).
3) Decontaminate any remaining equipment and collect wipe samples prior to returning equipment.
4) Submit landfill closure report.
5) Place additional sandbags on covers.
6) Monthly inspection of stockpile and super sack liners and reporting. |
Louis Howard |
| 12/8/2011 |
Update or Other Action |
Stockpile Winter Inspections At Port Heiden received, reviewed and approved.
Jacobs Engineering Group Inc. (Jacobs) requests that Aniakchak Contractors, LLC (Aniakchak) perform inspections of Port Heiden site road storage areas and contaminated soil cells once every two weeks throughout the winter months. The purpose of these inspections is to identify suspected deterioration, failure, or defects at any storage or contaminated soil cell site, and to ensure regulatory compliance and continued project success.
In the event that storm conditions and/or winds exceeding 50 mph occur in the area, the inspections would need to be performed immediately after each high wind or storm event subsides. Any event that could negatively affect containment cells should be followed by an inspection to ensure that the covers remain intact.
These inspections are requested to begin in mid-November 2011 and continue until May 2012 when staff from Jacobs or Bethel Services will return to Port Heiden. The information that follows provides additional details of this request including reporting, personnel safety, costs, a list of qualified inspectors, and invoicing. An inspection report form is attached.
In the event of a discovered actual or predictable deficiency or failure, Jacobs requests that Aniakchak personnel notify a listed Jacobs representative immediately, but take no corrective action before safety protocols are firmly in place and Jacobs authorization has been received.
Jacobs requests that Aniakchak notify us by telephone after each inspection, and follow up with written inspection documentation using the attached inspection report form. This form includes the date and time of inspections, duration of inspections, name of individuals conducting the inspections, signs of site access, and any problems noted. A signed copy of the report will be submitted to Jacobs within 24 hours after each inspection is complete. |
Louis Howard |
| 12/9/2011 |
Update or Other Action |
Draft TCRA Report received for the Site Road in Port Heiden.
The TCRA involved mobilization, field characterization, and removal of PCB-contaminated soil from the access road referred to as Site Road that runs from the Port Heiden Airport to the former Port Heiden Radio Relay Station (RRS).
This TCRA was performed to “prevent, limit, and mitigate a substantial threat to public health, welfare and the environment”. The remediation of PCB-contaminated soil exceeding ADEC Method 2 cleanup criteria of 1 mg/kg (18 Alaska Administrative Code [AAC] 75.341) was accomplished to limit exposure resulting from the frequent use of Site Road for subsistence activities. The removal action objective (RAO) of the TCRA was to eliminate the immediate threat posed by PCB-contaminated soil on the roadway surface.
Upon completion of the TCRA, all field screening indicated that the drivable surface of Site Road had PCB levels below a field-screening action level of 0.43 mg/kg, which meets the RAO.
A mobile lab was used to field-screen the samples. Due to differences in methods used by the field lab and the fixed lab, sample result correlation studies occurred throughout the field effort. Initial correlation between the labs indicated a bias factor of approximately 2X (i.e. fixed lab results were 2X higher than field lab results); therefore, a field-screening action level of 0.43 mg/kg PCB was used to direct excavation activities.
When field-screening results for these grid samples indicated levels of PCBs above the field-screening action level, additional material was removed as time allowed. When field screening results for the grid sample results indicated levels of PCBs below the field screening action level, the sample was submitted to the fixed lab for confirmation.
With 35 exceptions, fixed lab sample results indicated that the PCB cleanup criteria of 1 mg/kg had been achieved prior to backfilling. Excavation side walls were lined with a geofabric and backfilled with clean material. Those grids that were backfilled prior to achieving the 1 mg/kg cleanup goal will be addressed during the Non-Time-Critical Removal Action (NTCRA) planned for 2012.
Section 37 contained an area previously identified with PCBs > 50 mg/kg, as regulated under TSCA (NVPH 2011b). This area was located with a RTK GPS unit for focused removal action. Soil from this area was excavated and placed into two 5-cy Super Sacks.® Field screening was not performed prior to the excavation of the soil from this area. After removal, a sample was collected from the excavation floor & field screening was performed. The field-screening results found a level of 5.81 mg/kg from this floor sample; this level indicated that the remaining soil was not TSCA regulated waste. The area was backfilled using material from the borrow pit.
See site file for additional information.
|
Louis Howard |
| 12/13/2011 |
Update or Other Action |
Draft Landfill Closure Report received for the PCB Impacted Soil Removal.
The Native Village of Port Heiden (NVPH) is submitting this report to fulfill a requirement by the Alaska Department of Environmental Conservation (ADEC) regarding removal of polychlorinated biphenyl (PCB) contaminated soil from a landfill cell at the Port Heiden community landfill.
On November 18, 2011, NVPH submitted an approved “Addendum to May 2011 Final Soil Characterization and Disposal Work Plan, Former Port Heiden Radio Relay Station, Port Heiden, Alaska”. Consistent with ADEC’s October 31, 2011 letter, the approved cleanup level was established as 10 mg/kg.
NVPH removed PCB impacted soil to the approximate depth and extent of the original area. Initially, the soil was removed using an excavator and placed it into super sacks. The supersacks were transported to the boat landing staging area and placed on to a 20 mil liner underlain by geotextile fabric to protect the liner. Each super sack was given a unique number identifier, and weighed. On November 19, 2011, it was decided to truck and stockpile the remaining PCB contaminated soil from the landfill at the RRS site to expedite removal from the landfill. On November 20, 2011, the areal extent of the original cell had been reached. The soil on the east wall was within 1 foot of the liner placed there by Weston and Weston had placed 1 foot of clean fill over the liner, and a horizontal liner around the other walls of the excavation (that separated clean top cover soil from PCB impacted soil in adjacent cells) was exposed and draping into the excavation. In fact the top of the walls of the excavation were always visible because the CSR2 soil did not fill the cell. It was estimated that the depth of the original excavation had been reached based on a change of soil color on the excavation floor from a dark brown/black to a light brown/orange color.
The floor of the excavation was gridded into 15’ x 15’ grid cells in accordance with the approved Work Plan addendum with the exception of three grid areas in the northern part of the excavation (F1, F2, and F3) and the grid cells on the very east side of the excavation (A5, B5, C5, D5, and E5) where there wasn’t enough space for complete 15’ 15’ girds. The grids were designated by letters from south to north (A through F) and numbers from west to east (1 through 5). Floor samples were collected using the EPA 9-point composite sample method as described in the Work Plan Addendum. Wall samples were collected as grab samples every 20 feet.
The samples were transported using proper COC methods and received by SGS in Anchorage, Alaska. The samples were analyzed on a rush basis and results were received on November 29, 2011. Analytical results indicated there were 6 grid sample results above the cleanup level of 10 mg/kg: A1 @ 17.9 mg/kg, A2 @ 19.4 mg/kg, A3 @ 12.3 mg/kg, B2 @ 19.6 mg/kg, B3 @ 12.3 mg/kg and D1 @ 38.8 mg/kg. On November 30, 2011 the 6 grid cells with results exceeding the cleanup level were re-measured and marked using spray paint and soil was excavated from those grid areas an additional 1 to 2.5 feet in depth. Those grid areas were sampled again using the approved EPA 9-point composite sampling method and the samples were shipped by air to SGS. SGS received the samples December 1 and provided preliminary samples results on December 3, 2011.
The preliminary sample results were ND for grid cells A1, A2, A3, B2 and B3, and <1 mg/kg for the sample from cell D1. ADEC reviewed the preliminary results and granted permission to backfill the excavation. The final analytical results for the six cells that were re-sampled were received December 8, 2011, with results of ND or <1 mg/kg.
Two sources of backfill material were identified. Soil that was excavated from Ray’s community center was transported and stockpiled at the landfill and soil from the Alaska Peninsula Corporation borrow pit at Trapper Hill. Samples were collected from both sources and analyzed in accordance with the Work Plan Addendum.
All results are below ADEC cleanup levels. The stockpiled soil from Rays was estimated to be 700 cubic yards of soil. The volume of soil removed from the Trapper Hill borrow pit and placed in the landfill was 860 cubic yards (approximately 80 cubic yards were also removed from the Trapper Hill borrow pit and used for berms and anchoring of stockpile covers at the RRS and the boat landing staging area).
Backfilling at the landfill was completed for the season on December 5, 2011. Some of the backfill soil was frozen into large chunks and there was also some snow in the excavation. Therefore settling of the soil will likely occur once the soil thaws. Final backfilling, grading and seeding of the cell cover soils is planned to occur in spring/summer 2012. |
Louis Howard |
| 12/14/2011 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the draft Landfill Closure report.
The report did not include a section on Quality Assurance Summary as required by ADEC’s Technical Memorandum. ADEC will require the Air Force to provide a Quality Assurance (QA) Summary as part of the landfill closure report.
“All reports submitted to the Department containing analytical laboratory sample results shall contain a completed Laboratory Data Review Checklist and a Quality Assurance (QA)
Summary. The QA Summary must be included as a specific text section of the report. All laboratory results, including laboratory quality control (QC) sample results, must be reviewed and evaluated for quality, validity and usability. The text must include any affects on data validity and/or usability due to field sampling and laboratory quality control discrepancies.
Page 2 PCB Soil Cleanup Levels
ADEC approved 10 mg/kg total PCBs as a threshold for disposal into the landfill consistent with the requirements listed in the Solid Waste Program’s May 29, 2009 approval of polluted soils from the Port Heiden RRS.
Page 4
Excavation Backfill
The final requirements for the landfill are found in the May 29, 2009 Solid Waste letter to the Native Council of Port Heiden:
1. Only soil with a polychlorinated biphenyl (PCB) concentration of less than 10 mg/kg
may be disposed at the landfill.
2. Soil containing pesticides must be disposed in an area which will be covered with a 30-
mil geomembrane liner prior to capping.
3. The final soil cap must consist of at least 2 feet of soil material, with the top 6 inches consisting of sufficient organic material to support vegetation.
4. The polluted soil disposal site must be completely fenced, separate from the public landfill area. The gate must be kept locked.
5. The Native Council of Port Heiden must submit a report at the completion of the disposal project, but no later than February 15, 2010, including: as-built drawings of the cell; quantity of disposed soil; soil sampling results for all soil disposed at the landfill; photographs of the disposal cell while in operation and after it is completed; and the appropriate notation to the deed of the property.
6. The Native Council of Port Heiden must perform annual inspections of the cell and repair any areas that show signs of erosion or are failing to revegetate
Lab data review checklists
ADEC has reviewed the first checklist (Laboratory Report Number 1115727) of this report and found the following errors. There may be other errors in the other checklists (1115782 and 1115429001), therefore it is the Air Force’s responsibility to ensure a qualified person with laboratory experience (i.e. chemist) review the data and fill out the ADEC Laboratory Data Review Checklists properly.
1) PCBs are organic analysis. Checklists must be corrected and completed correctly for all criteria/requirements pertaining to organic analyses.
2) Organics LCS cannot be “NA.” A minimum of one LCS per 20 samples is required (LCS/LCSD for AK petroleum methods). All must meet acceptance criteria.
3) Metals/Inorganics LCS should be “NA,” for PCB Landfill soil samples since no inorganic analyses were requested or performed as part of the 2011 removal of PCB soil at the landfill. However, for the excavation backfill source material, metals analyses were required. Please correct the checklist as needed.
4) If a CCV was outside of acceptance criteria, the data quality is affected. Associated sample data may need to be rejected. (The statement in section 6(b)(v) needs to be clarified and moved to the correct section).
5) Field duplicate results and RPD should be documented in the report. Just because the primary/duplicate samples both had results below 10 mg/kg, does not mean that the data usability is not affected with a 59% RPD. This statement is unacceptable and needs to be revised and discussed in the QA text section of the report. |
Louis Howard |
| 12/29/2011 |
Update or Other Action |
After Action Report for sampline and analysis activities in October 2011 that were associated with landfill and stockpiles at Port Heiden RRS in Port Heiden received.
Three soil units were assessed; one unit was comprised of soil recently placed in the PCB landfill, and two units were comprised of soil stored in one small and one large stockpile located adjacent to Site Road near the former RRS. The scope of work was conducted for the u.S. Air Force 611 th Civil Engineer Squadron via the U.S. Army Corps of Engineers, Alaska District (USACE), under Environmental Remediation Services Contract No. W911KB-06-D-0006, Task Order No. 46.
In September 2011, the Alaska Department of Environmental Conservation (ADEC) requested that the United States Air Force conduct MI sampling of polychlorinated biphenyl (PCB)-contaminated soil located in the Port Heiden PCB landfill and two stockpiles near the fonner Port Heiden RRS. The landfill volume of soil contained approximately 792 cubic yards (cy) of material. The small stockpile and large stockpile were estimated to contain 54 cy and 126 cy, respectively.
The objective of this effort was to determine the concentration of PCBs in soil recently placed in the landfill and soil stored in two stockpiles as requested by the 611 CES.
The area and volume of soil at the three locations were calculated as follows:
The dimensions of soil recently placed in the PCB landfill was approximately 100 feet by 80 feet, and 3 to 4 feet deep. The volume of soil in the landfill was calculated as 792 cy based on the number of subsample cells sampled in each DU. Ten DU samples were collected.
The dimensions of the small stockpile located at the former RRS were reported to be a pyramid of approximately 25 feet by 29 feet, and 5 feet tall. The small stockpile was partially flattened for ease of sampling and safety of the samplers, resulting in a flat topped pyramid with dimensions approximately 30 feet by 21 feet, and 3 feet tall. The volume of soil was calculated as 54 cy based on the number of subsample cells in each DU (Figure A-4, Appendix A). Three DU samples were collected.
The dimensions of the large stockpile located at the former RRS were reported to be a pyramid of approximately 52 feet by 21 feet, and 10 feet tall. The large stockpile was flattened for ease of sampling and safety of the samplers, resulting in a rectangular prism approximately 15 feet by 75 feet, and 3 feet tall. The volume of soil was calculated as 126 cy based on the number of subsample cells in each DU. Three DU samples were collected.
Sixteen multi-increment samples were collected from DUs. The ten DU soil samples from the PCB landfill reported PCB concentrations ranging from 13 to 25 milligrams per kilogram (mg/kg). The three DU soil samples from the small stockpile reported PCB concentrations ranging from 0.19 to 0.71 mg/kg. The three DU soil samples from the large stockpile reported PCB concentrations ranging from 1.6 to 4.8 mg/kg.
Stockpile volumes were initially reported to be 130 and 404 cy for the small and large stockpiles, respectively. During MI sampling, the volumes were re-estimated to be 54 cy for the small stockpile and 126 cy for the large stockpile as described in Section 2.0.
Soil in the PCB landfill was reported to be 3 feet deep. During investigation, soil was observed to be approximately 3 feet deep with a few dispersed areas observed to be approximately 4 feet deep. A fourth DU was created from 3 to 4 feet below ground surface
(bgs) for the 32 subsample cells that were 4 feet deep. |
Louis Howard |
| 1/25/2012 |
Enforcement Action |
PERP (M. Sielaff) sent letter to Alaska Logistics (acting on behalf of the Air Force) a certified letter. Certified Mail Return Return Receipt Requested 7010-2780-0000-2089-9911 RE: FIB Logistics Provider 5.5 Ton PCB Release, Case #11269930801.
This letter is to advise you that on November 4, 2011 a pollution incident occurred in Nushagak River approximately 60 feet from Dillingham City Dock. It is understood that a 20 foot wood deck flat gave way during a barge to barge transfer releasing a 5.5 ton doubled lined sealed bag of 15ppm-50ppm PCB's into Nushagak River. Following our November 22,2011 meeting it was determined safer to remove the super sack when ice accumulation was no longer a safety issue and a barge could be used as a platform directly above the super sack in the spring of 2012.
Alaska Statute, Title 46, authorizes the state government to respond to this pollution incident and to take appropriate action to minimize damages to human health, safety, or welfare of the environment. Under this Act, if the owner or operator of the source fails to take adequate removal actions, the owner or operator may be held financially responsible for any actions taken by the State.
Removal is adequate and being done properly if it is done in accordance with Federal and State statutes and State regulations 18 AAC 75. Two weeks prior to conducting removal of the super sack ADEC must be notified so we may be available to monitor the event. Please provide ADEC with the following:
1. Detailed removal plan - The removal plan should include how you plan to remove the super sack including containment used to contain liquid draining from the sack, break strength of super sack exposed to sea water, and harness strength used to retrieve super sack.
2. A response plan - The cleanup/response plan under 18 AAC 75.325 should address cleanup of PCB's from the river bottom if the super sack fails.
3. Sampling plan - The sampling plan outlined in and 18 AAC 75.355 will be required to identify any PCB contamination on the river bottom. Water draining from the super sack must also be sampled for presence of PCB contamination.
4. Final report - Under 18 AAC 75.300(e) a final report enclosed must be completed. The State is especially interested in what actions you will take to prevent reoccurrence and why a wooden platform was used instead of a steel one. 18AAC75.307 requires final report be submitted within 15 days after cleanup is complete.
Alaska Statute 46.08.070 requires recovery be sought for costs incurred by the State in response to this incident, which includes any oversight activities. Please be advised that we may be billing you at a later date for state expenditures associated with this spill. Billable state expenditures include all direct time and materials costs and indirect overhead costs. Billable staff time will comprise all time spent on activities related to the incident, including time spent for site visits, response and report reviews, telephone conversations, and meetings. |
Mark Sielaff |
| 2/8/2012 |
Update or Other Action |
From a review of currently available results, it is recommended that all Former Port Heiden RRS wells continue to be sampled for the same COCs that were targeted in 2011. However, it is recommended that natural attenuation sampling be augmented in coming years. The geochemical suite for attenuation samples in 2011 consisted of methane, alkalinity, sulfate, dissolved iron, manganese, and nitrate.
Natural attenuation is expected to be identified as the optimal remedial option for the Former RRS groundwater. A solid baseline of COC concentrations and attenuation data has been acquired, and it is recommended the same data be collected in 2012 and subsequent years to evaluate COC and geochemical indicator changes during time. Note also that monitoring wells DSA-MW-03 and RRS-MW-04 are damaged and are no longer able to be sampled. At this point, it is not recommended that these wells be replaced.
The contaminants present at FPC-066 are in a one-well plume. Well MW-05 is the only one of the four wells sampled in 2011 that had a compound (DRO) above cleanup criteria. No additional wells are available for sampling in this area to better define this boundary. Unless it is deemed enough of a priority to install additional wells at the FPC-066 location, it is recommended that DRO sampling of these four wells continue annually. In 2011, wells in this area were only sampled for VOCs and all results were nondetect. It is recommended that wells in this area no longer be sampled, pending concurrence from the ADEC.
Much like FPC-066, the contaminants present at FPC-215 are in a one-well plume. Well MW-09 is the only one of the three wells sampled in 2011 that had a compound (DRO) above cleanup criteria. No additional wells are available for sampling in this area for use in adding value to the existing delineation. Unless it is deemed enough of a priority to install additional wells at the FPC-215 location, it is recommended that DRO and BTEX sampling of these wells continue annually.
FPC-086 Monitoring Recommendations
On the basis of 2011 soil sampling results, for which all concentrations were found to be below cleanup levels, no future soil sampling is recommended at this location. |
Louis Howard |
| 2/13/2012 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the: "DRAFT FINAL Landfill Closure Report PCB Impacted Soil Removal, Port Heiden Landfill Former Port Heiden Radio Relay Station Port Heiden, Alaska dated January 2012" received by ADEC Contaminated Sites Program on 1/31/2012.
1) Please provide a summary table documenting the initial sample, field duplicate results and calculated Relative Percent Difference (RPDs) for all 3 sampling events.
2) Please provide the other 2 lab reports for review. Only SGS 1115727 was included.
3) QA 1115429 Sensitivity – If the lab results were reported to the detection limit (DL) with estimated (J flag) concentrations, evaluate these levels as a line of evidence “to discern whether the concentration in the sample is above or below the associated cleanup level.”
4) QA 1115727 – Editorial comment. For the Matrix Spike/Matrix Spike Duplicate (MS/MSD), data was not impacted by the low precision (not high). High RPD = Low Precision. |
Louis Howard |
| 2/21/2012 |
Document, Report, or Work plan Review - other |
Solid Waste program provided comments on the Draft Landfill Closure Report.
Page 2 PCB Soil Cleanup Levels
Text: ADEC approved 10 mg/kg total PCBs as a threshold for disposal into the landfill.
ADEC: The ADEC approved contaminant concentration in the landfill for this stage of the project was 1 mg/kg, per the ADEC letter dated October 31, 2011. Please revise the report accordingly
Page 4 Soil Sampling & Additional Excavation
Text: ADEC reviewed the preliminary results and granted permission to backfill the excavation
ADEC: May want to clarify that backfill was conditionally approved via email on December 3, 2011, and/or attach the email.
Page 7 Excavation Backfill
Text: The final requirements for the landfill are found in the May 29, 2009 Solid Waste letter to the Native Council of Port Heiden
ADEC: Final requirements for this portion of the project are found in the ADEC letter dated October 31, 2011. Please revise the report accordingly.
In addition, ADEC Solid Waste will approve final closure of the landfill only after the landfill cap has been graded and seeded, the cap surveyed, and as-built drawing submitted to ADEC. |
Louis Howard |
| 3/5/2012 |
Update or Other Action |
Draft EE/CA received.
This Engineering Evaluation and Cost Analysis (EE/CA) analyzes three alternatives to meet the Removal Action Objective (RAO) of protection of human health by preventing direct contact with polychlorinated biphenyl (PCB) concentrations above the Alaska Department of Environmental Conservation (ADEC) Method Two cleanup level of 1 milligram per kilogram (mg/kg) at Site Road in Port Heiden, Alaska.
The preferred alternative for Site Road is Alternative 2: Removal and Offsite Disposal. Both Alternatives 2 and 3 would remove all PCB contamination above 1.0 mg/kg, but Alternative 2 removes all soil to a treatment, storage, and disposal facility (TSDF), which eliminates the need to dispose of contaminated soil at Port Heiden.
The contaminant of concern (COC) at the site is PCBs. According to the site characterization results, PCB contamination remains at levels above the ADEC Method Two cleanup criterion in the subsurface and shoulders of Site Road, as well as areas immediately adjacent to Site Road. The highest levels of PCB contamination were found on the road shoulders. In all zones contamination decreased with distance from Site Road.
It is estimated between 19,867 to 23,391 cubic yards of contaminated soil remain along Site Road and the adjacent areas in a contamination plume that encompasses approximately 894,025 to 1,052,581 square feet. From waste characterization samples taken during the TCRA and site characterization, which were sent to a definitive lab, it is estimated that 69 percent of the remaining contaminated soil has concentrations between 1 and 10 mg/kg, 30 percent of the remaining soil has concentrations between 10 and 50 mg/kg, and 1 percent of the remaining soil has concentrations greater than 50 mg/kg, the concentration at which PCBs are regulated under the Toxic Substances Control Act (TSCA).
Because PCB contamination appears to be limited to near the surface and no groundwater was observed onsite, no groundwater sampling was conducted as part of this EE/CA. PCBs in soil present unacceptable exposure risks via the ingestion, dermal absorption and inhalation pathways (as fugitive dust). These exposure pathways, coupled with the current contaminant concentrations identified along Site Road, pose unacceptable risks to the health and safety of the surrounding population and the environment.
See site file for additional information. |
Louis Howard |
| 3/13/2012 |
Update or Other Action |
John Halverson (ADEC) sent Steve Mattson (611th) a letter regarding the October 2010 compliance advisory.
The Alaska Department of Environmental Conservation (ADEC) has determined that the Air Force has satisfactorily addressed the issues raised in the Compliance Advisory Letter referenced above. That letter documented alleged violations of state laws concerns over polluted soil disposal in the landfill, disposal of the soil washing tanks and treatment residues, and PCB
contamination at the soil washing area. Documentation on resolution of these matters is contained in the Final Corrective Action Report, received by ADEC on March 2, 2012.
I appreciate the Air Force's cooperation and response in resolving these serious issues. ADEC considers the compliance advisory closed. |
John Halverson |
| 3/14/2012 |
Update or Other Action |
Draft Site Road PCB-Contaminated Soil Removal Action: 2012 Work Plan for conducting the non-time critical removal action. Excavation will begin where soil samples with PCBs above the cleanup level have been previously identified. Excavation will proceed in vertical increments of approximately 6 inches or less until confirmation sample definitive results report concentrations less than the cleanup level. Confirmation samples will be collected after each excavation increment.
Soil containing PCBs > or = 1 mg/kg & less than 50 mg/kg will be excavated, segregated, & staged in stockpiles & treated as non-hazardous Toxic Substance Control Act (TSCA) waste. Stockpiles will be constructed as long-term stockpiles using the criteria specified in PH-SOP-6 Stockpile Construction & Maintenance. Soil containing PCBs identified > or = 50 mg/kg shall be excavated, segregated, staged in Super Sacks,® & treated as hazardous TSCA waste. Soil with PCB contamination > 50 mg/kg has been identified in two locations: a definitive shoulder composite sample at Section 08R & at the Section 35 shoulder profile in a field screening sample. Other containment options (open-top containers or stockpiles) may be utilized if significant amounts of soil with PCB concentrations that are equal to or exceed 50 mg/kg are found.
Sampling will be conducted for each cell of the sampling grid re-established as part of additional characterization sampling where soil is excavated from the road (RD), shoulder (SS), or tundra & adjacent areas (TU). Samples will be field screened for PCBs using an onsite laboratory using a gas chromatograph (GC). If field screening concentrations indicate the sampling area may be below the cleanup level, then the sample will be sent to an offsite DoD certified lab for definitive results.
Samples from the following locations will be analyzed by an offsite laboratory:
• Characterization sample locations that do not have definitive results from the 2011 EE/CA (USACE 2012a) with field screening concentrations that may report definitive laboratory results below 1 mg/kg;
• Confirmation sample field screening concentration that may report a definitive laboratory result below 1 mg/kg;
• Samples with reported field screening concentrations > or = 10 mg/kg;
• All stockpile storage area pre- & post-construction samples;
• All waste characterization samples;
• All equipment wipe samples; &
• All field laboratory correlation samples.
Sampling techniques will include confirmation sampling, pre- & post-construction sampling, waste characterization sampling, & equipment wipe sampling.
See site file for additional information. |
Louis Howard |
| 3/19/2012 |
Document, Report, or Work plan Review - other |
Comments on the Draft Site Road PCB Removal Engineering Evaluation/Cost Analysis, Port Heiden, Alaska March 2012.
Executive Summary
Add regulatory citation for the source of cleanup level. For example: “…PCB contamination remains at levels above the ADEC 18 AAC 75 Method Two cleanup criterion in the subsurface & shoulders of Site Road, …”
Add text to first paragraph as follows: “the concentration at which PCBs are regulated under the Toxic Substances Control Act (TSCA) 15 USC §2601 et seq. (1976).”
3.2.3 Road Shoulder Correlation Analysis
ADEC requests the Air Force elaborate on PCB sampling & why Aroclor-1260 is the only aroclor of concern at Port Heiden. This is the first mention of Aroclor-1260. The text prior to this section should state that only Aroclor-1260 is found at the site & all other aroclors have not been detected in previous sampling. Otherwise, the reader is left wondering if there are other aroclors (e.g. 1016, 1210, 1216, 1221, 1231, 1232, 1240, 1242, 1254…) that are not being reported. ADEC regulates on a total concentration of PCBs not individual aroclors.
2nd Paragraph
PCV should read PCB.
Table 4-8 Storage Area Pile Background Samples
ADEC requests clarification on how Storage Area 1 will be further characterized to minimize waste due to sample D1 being above 1 mg/kg PCBs from the east side of the southernmost end of the pile.
10.0 References
ADEC. 2011. Oil & Other Hazardous Substances Pollution Control. 2011 (October).
Appendix A ARARs
The text states: Each ARAR has been assessed on its applicability to the site, & categorized as follows: applicable, potentially applicable, relevant & appropriate, or to be considered (TBC) as guidance.
The listings of ARARs should not include the label “potentially applicable”. A determination of whether ARARs apply is made at this point in the EE/CA. The purpose of listing the ARARs is to ensure it is considered in the design of the action, & to determine whether waivers need to be obtained. If that isn’t made now, then ADEC requests the Air Force clarify when they would propose to make this finding if not in the EE/CA.
Table A-1 Potential Chemical-Specific Applicable or Relevant & Appropriate Requirements
Clean Air Act of 1963
Applicability: Strike potentially
Comments & Analysis/Rationale for Decision: Strike potentially, it is applicable. Two of these alternatives (& the one chosen) involve digging, dumping & hauling.
Resource Conservation & Recovery Act of 1976
RCRA
Applicability: Strike potentially. It is applicable.
Comments & Analysis/Rationale for Decision: It is applicable. If there doesn’t turn out to be RCRA regulated wastes, then you don’t have to comply with the statute. But you must be prepared in case (since it might happen in this instance).
Protection & Enhancement of Environmental Quality
Applicability: Insert Relevant. It is Relevant & Appropriate.
Alaska State Regulations
Alaska Water Quality Standards
Applicability: Strike TBC. It is applicable.
Comments & Analysis/Rationale for Decision: Alaska’s water quality standards also apply to such things as runoff. There have to be precautions taken to ensure that, while removal is ongoing, surface water in the area doesn’t violate WQS due to the removal activities.
See site file for additional information. |
Louis Howard |
| 5/18/2012 |
Document, Report, or Work plan Review - other |
Staff reveiwed and approved the final Site Road Removal action work plan and the EE/CA via email to the Air Force Project Manager. |
Louis Howard |
| 5/21/2012 |
Update or Other Action |
Site Characterization Report received.
The NVPH field crew succeeded in conducting a successful field season. 923.14 tons of PCB-contaminated soil were removed from the Former Port Heiden RRS & were safely transported to the US Ecology landfill. 2011 was the second year of a 3-year plan to (1) remove all PCB waste from the site, (2) excavate all POL-contaminated soil, & (3) initiate on-site treatment of the POL contaminated soil. If the same level of productivity achieved in 2011 can be accomplished during the 2012 field seasons with early start dates, these three goals should be achievable under the CA.
The septic pipeline was successfully removed from the BLO/SSO & was disposed of in 2010. Additionally, it was verified that residual contamination does not exist in the pipeline trench or tank/vault excavation. However, historical data indicate an area of POL contamination remains west of the pipeline excavation. Further, a significant area of PCB-contaminated soil has been identified south of the pipeline excavation.
In 2011, additional test pits & soil samples were collected from this area to further delineate & characterize any PCB & petroleum-related contamination. Results from these samples showed DRO, TCE, & PCE above cleanup levels in soil. It is recommended that additional site characterization for DRO & VOCs be conducted in 2012with the goal of obtaining lower reporting limits for VOC results, & if possible, excavation of site soils will be conducted.
Excavation/removal of PCB-contaminated soils at CSR1 largely concluded in 2010. Concentrations of soil in one grid square remain above 1 mg/kg. The analytical result for PCBs at this location was 1.3 mg/kg before it was covered for the winter. The remaining soil with contamination in excess of the cleanup level at one grid square was removed in 2011 until analytical results confirmed a PCB result of less than 1 mg/kg. It is recommended that this AOC be considered closed.
Excavation activities did not occur at CSR2 in 2010; delineation of this AOC consumed much of the short work season. But with the boundary established in the 2010 season, additionally sampling & soil removal was conducted here in 2011. Analytical results from the excavation showed that site soils with PCB concentrations above cleanup levels remain in the following areas:
• CSR2-G88 & CSR2-G90
• CSR2-G72 & CSR2-G73
• CSR2-G91 through CSR2-G113
See site file for additional information.
|
Louis Howard |
| 6/22/2012 |
Document, Report, or Work plan Review - other |
ADEC has reviewed the final version of the Final Soil Characterization and Disposal Work Plan Former Port Heiden Radio Relay Station Port Heiden, Alaska dated June 2012 and will approve the work plan submitted on June 21, 2012 as written.
ADEC’s review and comment on this work 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 comments on the work plan does not relieve responsible persons from the need to comply with other applicable laws and regulations.
The Air Force is responsible for the actions of contractors, agents, or other persons who perform work to implement the approved work plan. For any activity that significantly deviates from the approved plan, the Air Force shall notify the ADEC and obtain written approval in the form of a work plan amendment before beginning the activity. Any action taken by the Air Force, or an agent of the Air Force, that increases the project's overall scope or that negates, alters, or minimizes the intent or effectiveness of any stipulation contained in this work plan will be deemed a significant deviation from the approved plan. The final determination as to the significance of any deviation and the need for a work plan amendment is the responsibility of the ADEC. Therefore, it is recommended that the ADEC be consulted immediately when a significant deviation from the approved work plan is being considered
|
Louis Howard |
| 10/16/2012 |
Cleanup Plan Approved |
Email from L. Howard to Chris Fell (JACOBS) and Path Roth (611)
RE: ERS-UR TO 46 Memo Work Plan - Draft
NOTE, this is a one-time approval by ADEC of the DRAFT PCB TSCA-Hazardous Soil Removal from Stockpile 1.2 (dated October 12, 2012) and must not be taken by the Air Force as blanket approval by ADEC for future work of this type. Future requests by the Air Force or agents/contractors acting on its behalf, must be submitted to ADEC for review on a case-by-case basis and may or may not be approved.
Additionally, ADEC approval of this one-time activity does not relieve the Air Force or agents/contractors acting on its behalf, of the requirement to comply with other federal laws, regulations and/or applicable guidance for PCB remediation waste storage, transport, disposal activities. |
Louis Howard |
| 11/16/2012 |
Update or Other Action |
Institutional Control Report received.
The purpose of this report, the Institutional Control Performance Report (ICPR), is to document reviews of the remedial actions selected in the 2009 Record of Decision (ROD) for the remediation of sites at the Port Heiden Radio Relay Station (RRS) & to determine whether these actions are protective of human health & the environment, & are functioning as designed. To achieve this purpose, reviews which evaluates the status of implementation of the selected remedies, identifies any significant variances from the ROD, & makes recommendations for reconciling variances &/or improving performance of remedial actions are completed. In addition, the review identifies any new information that becomes evident, documents that no new contaminant sources or exposure pathways were discovered, confirms that no new sites were established, & verifies that no additional work was performed that was not identified in the ROD. This report shall include any information pertaining to any breaches of institutional Controls (ICs), corrective action taken, & any property transfers.
Specifics concerning Petroleum, Oil, & Lubricant (POL)-contamination were not addressed in the ROD. No POL-contaminated soil was excavated this year though operations at the landfarm continued. One area, known as LSA5, was sampled & found to meet cleanup standards. LSA5 contained approximately 2,900 cubic yards of soil. Roughly 2,700 cubic yards was already used as backfill leaving approximately 200 cubic yards for future use.
Per the ROD (USAF, 2009), a notice type of institutional control (IC) will be implemented (with the land owners consent) to control the use of soil containing residual concentrations of dieldrin above 0.0076 mg/kg. The location of the institutional control area is depicted on Figure 2-1. This notice will make the Land Owner aware that the Alaska Department of Environmental Conservation (ADEC) approval is required for any disturbance of soil (the goal of this institutional control is to prevent the constant contact of this media with water which could impact groundwater or surface water quality).
At the RRS landfill, ICs will be established to provide notice that the remaining buried wastes may contain contaminants of concern, that the cover should be maintained, & excavation into or development over the Port Heiden RRS Landfill should be restricted to maintain the integrity of cap & to prevent migration of contaminants.
If future property use includes disturbance of the institutional control area (see Figure 2-1) such that the remaining pesticide contaminated soil comes in constant contact with water, or other information becomes available which indicates that the site may pose an unacceptable risk to human health, safety, welfare or the environment, the land owner &/or operator are required under 18 AAC 75.300 to notify ADEC & evaluate the environmental status of the contamination in accordance with applicable laws & regulations. Further site characterizations & cleanup may be necessary under 18 AAC 75.325-.390.
See site file for additional information.
|
Louis Howard |
| 11/21/2012 |
Document, Report, or Work plan Review - other |
Draft Final ICP report approved-finalize document for our files. |
Louis Howard |
| 2/28/2013 |
Update or Other Action |
Time-critical removal action report received.
This document is issued in accordance with the requirements of the Comprehensive Environmental Restoration, Compensation, & Liability Act (CERCLA) (42 U.S. Code (USC) 9601 et. Seq.), as further implemented by the National Contingency Plan (NCP) (40 Code of Federal Regulations [CFR] part 300). The Installation Restoration Program (IRP) is authorized in the Defense Environmental Restoration Program (DERP) (10 USC 2701 et seq.) as the environmental restoration program the military services use to take CERCLA response actions & satisfy its CERCLA lead agency function as delegated by Executive Order 12580. This document is consistent with Alaska State law & regulations including, but not limited to, Title 46 of the Alaska Statutes & regulations. NOTE: Port Heiden RRS is not on the NPL as a “superfund” site, but the Air Force must meet the substantive requirements of CERCLA.
Jacobs Engineering Group Inc. (Jacobs) performed this Time-Critical Removal Action (TCRA) at Site Road in Port Heiden, Alaska for the U.S. Army Corps of Engineers (USACE), Alaska District under Environmental Remediation Service contract W911KB-06-D-0006 Task Order No. 46. The TCRA involved mobilization, field characterization, & removal of polychlorinated biphenyl (PCB)-contaminated soil from the access road referred to as Site Road that runs from the Port Heiden Airport to the former Port Heiden Radio Relay Station (RRS).
This TCRA was performed to “prevent, limit, & mitigate a substantial threat to public health, welfare & the environment” (U.S. Air Force [USAF] 2011c). The remediation of PCB-contaminated soil exceeding Alaska Department of Environmental Conservation (ADEC) Method Two cleanup criteria of 1 mg/kg (18 Alaska Administrative Code [AAC] 75.341) was accomplished to limit exposure resulting from the frequent use of Site Road for subsistence activities.
The removal action objective (RAO) of the TCRA was to eliminate the immediate threat posed by PCB-contaminated soil on the roadway surface. The appropriateness of the removal action is based on the following factors listed in 40 Code of Federal Regulations (CFR) 300.415(b)(2) of the National Contingency Plan (NCP):
(i) Actual or potential exposure to nearby human populations, animals, or the food chain from hazardous substances or pollutants or contaminants;
(ii) High levels of hazardous substances or pollutants or contaminates in soils, largely at or near the surface that may migrate.
Mobilization to Port Heiden began on 16 May 2011 & this TCRA field effort was completed on 17 June 2011. A field laboratory was utilized to screen potentially contaminated soil & guide excavation of PCB-contaminated soil. Ten cubic yards of Toxic Substance Control Act (TSCA)-regulated PCB-contaminated soil & 9,419 cubic yards of non-TSCA PCBcontaminated soil were removed.
See site file for additional information.
|
Louis Howard |
| 3/1/2013 |
Update or Other Action |
Draft Site Road PCB removal after action report received.
Sections 00 to 10
Due to conflicts with Storage Area 1, the ARFF building foundation, fill placed in 2011, & several storage containers (see Appendix F), characterization sampling & excavation activities remain to be completed in Road Sections 00 to 10.
Sections 11 to 45
A total of 80 grids & walls above cleanup levels remain in this section to be excavated. One grid cell RD29-L2-E has been identified as being TSCA hazardous & will be excavated into Super Sacks® as discussed in Section 4.8. Once all contamination has been excavated, Site Road will be backfilled & made safe for vehicular traffic.
Sections 81 to 90
A total of 11 grids above cleanup levels currently remain in this section to be excavated. Characterization is not complete as there is a conflict between work zones as discussed in Section 4.9 of this report
Sections 91 to 92
One grid & eight excavation walls above cleanup levels currently remain in this section to be excavated. Further characterization is also required but interfered with the NVPH work areas so it was not undertaken. This field decision is discussed in detail in Section 4.9
Excavated soil was split into two waste streams based on the TSCA classification for bulk remediation waste (40 CFR 761). The two waste streams were classified as TSCA hazardous (PCB concentration greater than or equal to 50 mg/kg) or TSCA nonhazardous (PCB concentration less than 50 mg/kg). Excavation of soil is described in Section 2.2. TSCA nonhazardous soil was staged in stockpiles in Storage Areas 1 & 2. TSCA hazardous soil was temporarily staged in Super Sacks® at the excavation location & later moved to Stockpile 1-7. Both waste streams will be removed in 2013 by a waste contractor under separate subcontract with the USACE. Excavated volumes are estimated as bank yards & do not take into account inflation due to excavation & transport.
Approximately 320 cy of TSCA hazardous soil from Stockpile 1-2 was excavated into sixty-six 5-cy Super Sacks® & stored in Stockpile 1-7 in Storage Area 1 as described in Section 2.3.5. Plastic bags with soil samples where analytical results exceeded the TSCA hazardous criteria were placed into Super Sack® Number 33, which was also placed in Stockpile 1-7. This included the 17 samples collected from Stockpile 1-2 during removal of the TSCA hazardous soil. The waste contractor will transport the Super Sacks® from the site in 2013 by barge.
During 2012 field activities, approximately 18,774 cy of TSCA nonhazardous soil was excavated & placed into nine stockpiles. Excavation removed approximately 17,024 cy from grid cells & 1,750 cy from decommissioning Storage Area 2 stockpiles.
4.9 The Site Road 2012 removal action began to encroach on a remediation project being conducted by NVPH. Based on field observations, field personnel established a boundary between the two projects as shown on Figures A-23 & A-24 (NVPH Work Area) to prevent operational conflicts. No formal boundary definition or agreement between the two projects occurred. The deviation to the Work Plan occurred when grid cell analytical results indicated PCB concentrations above the cleanup level existed on the NVPH side of the boundary. These grid cells were not excavated in 2012, but their excavation is planned for the 2013 field season.
Field activities stopped in November 2012 when weather prevented safe and productive fieldwork. To complete the removal action described in the Work Plan (USAF 2012a), the remaining fieldwork includes excavation of 215 grid cells and walls with analytical results exceeding the cleanup level, decommissioning of stockpiles in Storage Area 1, decommissioning of the Storage Area 1 and Storage Area 2 pads, and restoration of the excavated portions of Site Road and adjacent areas. |
Louis Howard |
| 5/15/2013 |
Document, Report, or Work plan Review - other |
Staff provided comments on the Draft After Action Report.
ES-1 Executive Summary
ADEC requests a copy of the Site Road PCB Removal Engineering Evaluation/Cost Analysis (EE/CA) be included as an appendix to the document.
1-3 1.3 Geography of Site Road
Please provide the following location information of the land that Site Road covers: Section X, Township XX N, Range XX E Sections XX & XX, Township XXN, Range XXE, Seward Meridian. Additional information such as lot/tract, block, subdivision, quadrangle (e.g. Chignik D-2) is requested if applicable.
Petroleum-Impacted Soil Waste
2-14 Table 2-6 Characterization Analytical Results for Petroleum-Contaminated Soil
While the concentrations of VOCs GW RCRA metals were compared to TCLP from 40 CFR 261.24 Table 1, for waste disposal purposes, had they exceeded ADEC’s migration to groundwater cleanup levels (18 AAC 75.341 Table B1), the Air Force would be required to properly characterize GW remediate/dispose of the contaminated soil. Also, The cleanup level from Table B1 or B2 that applies at a site is the most stringent of the applicable exposure pathway-specific cleanup levels based on direct contact, inhalation, or migration to groundwater.
Therefore, the cleanup level for RRO is actually 10,000 mg/kg (ingestion Under 40-Inch Zone) GW not 11,000 mg/kg.
2-16 2.3.3 Wipe Samples
Pleases specify the area of each wipe sample. EPA has specific definition for “Standard wipe samples”:
Standard wipe sample means a sample collected for chemical extraction GW analysis using the standard wipe test as defined in § 761.123. Except as designated elsewhere in part 761, the minimum surface area to be sampled shall be 100 cm2. The reader shouldn’t have to go to the Appendix B to find out this information.
4.0 General Comment
ADEC requests the Air Force briefly describe the time when the “qualified person” was not present on site at Site Road while excavation activities (i.e. site cleanup) were occurring due to an off the job accident.
See site file for additional information.
|
Louis Howard |
| 5/17/2013 |
Update or Other Action |
Draft Landfarming report received for review and comment.
Landfarming was selected as the preferred method to remediate Petroleum, Oil and Lubricant (POL)-contaminated soil from Areas of Concern (AOC) within the boundaries of the former Port Heiden Radio Relay Station (RRS), Port Heiden Alaska. POL-contaminated soil stockpiled during excavations at the site in 2009 and 2011 was transported to five Landspreading Areas (LSA) constructed north of the Black Lagoon Outfall (BLO). Soil was spread in a layer approximately 12 inches thick over a combined area of approximately 28,900 square yards. Each LSA was rototilled at monthly intervals in 2012 to promote microbial biodegradation of petroleum products within the soil through aeration.
In July 2012, 16’ x 16’ grids were staked out at each LSA and soil within each grid square screened using a photoionization detector (PID) to assess levels of remaining POL-contamination. Soil samples were collected from anomalies identified by PID for laboratory analysis for Diesel Range Organics (DRO) using Alaska Method AK102 to evaluate the progress of remediation and whether Alaska Department of Environmental Conservation (ADEC) clean-up levels had been achieved.
It was determined that soil within LSA5 was below ADEC clean-up levels, per 18 AAC 75.345 (ADEC, 2012). Approval was received from ADEC to use material from LSA5 as backfill. Areas LSA1 and LSA4 contain POL-contaminated soil that tested marginally above ADEC clean-up levels and will require additional rototilling in 2013. All soil samples from within LSA2 and LSA3 were below ADEC clean-up levels.
DRO-contaminated soil from AOC’s within Port Heiden RRS from stockpiles resulting from previous excavations was transported to five un-lined landspreading areas, constructed north of the Black Lagoon Outfall and spread in a layer approximately 12 inches thick. Each LSA was rototilled at regular intervals to promote microbial biodegradation of POL contamination within the soil. Soil within each LSA was screened in 2012 to assess the extent of remediation and to determine whether ADEC clean-up levels had been achieved.
It was determined that soil within LSA5 was below ADEC clean-up levels and approval was received from ADEC to use material as backfill. LSA1 and LSA4 contain POL-contaminated soil that tested above clean-up levels and will require additional rototilling. Soil within LSA2 and LSA3 was below ADEC clean-up levels, but may still benefit from additional rototilling. |
Louis Howard |
| 5/23/2013 |
Document, Report, or Work plan Review - other |
Responses to ADEC's review comments are accepted for the DRAFT 2012 Port Heiden PCB Contaminated Soil Removal After Action Report. |
Louis Howard |
| 5/23/2013 |
Document, Report, or Work plan Review - other |
After conducting a review of the information from both FUDS and Air Force, ADEC concurs with the Air Force's statements in the responses to comments, Comment #7 4-2 4.2 Pre-construction Sampling. As part of the review, ADEC has determined that the likely source of the 2,790 mg/kg PCBs is not from the Site Road Air Force site, but it is from the powerhouse site feature A-PR-2 (1 of 14 powerhouse locations) associated with the former Fort Morrow.
Unless there is documentation which the Corps of Engineers can provide to the contrary regarding the release of PCBs at A-PR-2 powerhouse site feature not being a FUDS responsibility, it is ADEC's expectation that the Corps will investigate this matter as part of the ongoing remedial investigation.
A letter is being sent to the Corps project manager requesting that site controls (fencing/signage) remain at this PCB-contaminated location and be maintained until the Fort Morrow field work resumes. Based on the information to date which demonstrates a release of PCBs has occurred at the powerhouse site feature within Area of Concern "A" the Corps is requested to investigate this location as its highest priority when the Remedial Investigation of Fort Morrow resumes in 2014. |
Louis Howard |
| 5/24/2013 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (ADEC) has received a draft After Action Report on March 1, 2013 for the Site Road PCB Contaminated Site Removal from the Air Force. During response to comments correspondence and a review of the report, it has come to ADEC's attention that the confirmation sample location (sample ID TU10-L18 E) corresponds with the powerhouse A-PR-2 (Area of Concern "A') at the former Fort Morrow Army Post, located at Port Heiden, Alaska (ADEC CS DB Hazard ID 73).
ADEC's review of the information, laboratory data, maps and figures from both the Air Force and Corps of Engineers investigations leads ADEC to determine that the highly elevated PCB contamination is likely associated with the former Fort Morrow site and not the Site Road site being addressed by the Air Force. ADEC requests the Corps of Engineers to make this area the highest priority in its ongoing RI/FS investigation of AOC A based on this recent information provided by the Air Force.
The current fencing and signage initially placed by the Air Force needs to remain m place and maintained by the Corps until such time the Corps of Engineers resumes their investigation of AOC A (estimated to be 2014). |
Louis Howard |
| 6/12/2013 |
Update or Other Action |
Draft PCB-Contaminated Soil Characterization Report received.
The Native Village of Port Heiden (NVPH) and APC Services, LLC (APCS) conducted investigation and contaminated soil removal activities at the former Port Heiden Radio Relay Station (RRS), Port Heiden Alaska. The work was conducted in accordance with the US Army Corps of Engineers (USACE) Alaska District Cooperative Agreement (CA) “Remediate Former Port Heiden RRS.” The scope of work for this project has been derived from two CA’s, numbers 11AF-09-0100 and 11AF-10-0100.
Site characterization and remediation work was undertaken in 2012 to delineate and remove polychlorinated biphenyls (PCB) contaminated soil and to treat water contaminated by petroleum, oils and lubricants (POLs) and PCBs at the Port Heiden Community Landfill.
Three Areas of Concern (AOC’s) at the former Port Heiden RRS were sampled for PCB concentrations by collecting composite samples within 15’ x 15’ grid squares and analyzing in the laboratory using Method SW8082A. Soil with PCB analytical results above 1 milligrams per kilogram (mg/kg) and less than 50 mg/kg was excavated. After excavation the grid was re-sampled and additional soil lifts were made until the grid square tested below 1 mg/kg or field conditions prevented additional excavation. Soil with PCB content in excess of 50 mg/kg was left in-situ.
The excavated PCB contaminated soil was placed into long term stockpiles. Three lined and bermed cells of approximately 8,100 ft2 area were constructed and filled with PCB-contaminated soil from the AOC’s. The AOC’s included Contaminated Soil Removal Area 2 (CSR2), Water Tank Hill (WTH), and the Black Lagoon Outfall (BLO) area.
At CSR2, over 150,000 ft2 was sampled and approximately 2,569 yds3 of PCB-contaminated soil was excavated and transported to Cells, 1, 2 or 3. Almost 18,000 ft2 was determined to have PCB contamination above 50 mg/kg and was left in-situ for future remediation. At the BLO an area of over 27,000 ft2 was screened and 208 yrds3 of PCB-contaminated soil excavated and transported to Cells 1, 2 or 3. At WTH, an area of over 15,000 ft2 was screened and 200 yrds3 excavated and removed to the stockpile cells.
The areal extent of PCB contamination was not defined and future investigations will require additional characterization to the east, west, and south. In addition, based on a Weston 2009 investigation, there may be soil above the clean-up level buried underneath clean fill material in sections of CSR2. |
Louis Howard |
| 7/17/2013 |
Update or Other Action |
Draft Work Plan received for review and comment.
The objective of this Work Plan is to remove soil with PCB concentrations greater than or equal to the Alaska Department of Environmental Conservation (ADEC) Method Two direct contact cleanup level of 1 milligram per kilogram (mg/kg) (18 AAC 75.341) associated with the former RRS. This includes approximately 2,309 tons of non-toxic material as defined by the Toxic Substances Control Act (TSCA) (greater than 1 mg/kg and less than 50 mg/kg) and 2,260 tons of TSCA (greater than or equal to 50 mg/kg) PCB-contaminated soil from the former RRS site. In addition, approximately 25,550 tons of non-TSCA and 360 tons of TSCA PCB-impacted soil is currently onsite.
All PCB-impacted soil will be containerized into LiftPacs®, SuperSacks®, or the equivalent, (here on referred to as “bags”); loaded onto barges; transported to Seattle, Washington; then transported to the Columbia Ridge Landfill and Recycling Center in Arlington, Oregon. Removal activities will be conducted in a manner that will minimize the waste generated. The goal of the removal effort is to prevent potential ingestion or direct contact exposure to soil containing PCB concentrations greater than or equal to 1 mg/kg.
The stockpiles currently contain approximately 11,900 tons of non-TSCA regulated soil; however, by the end of the 2013 field season, it is estimated that an additional 8,000 tons of non-TSCA regulated soil will be excavated from Site Road. Approximately 360 tons of PCB-contaminated soil with concentrations greater than 50 mg/kg is currently containerized in bags and staged onsite. It is estimated that an additional 60 tons of material with PCB concentrations greater than 50 mg/kg will be excavated from Site Road during the 2013 field season. |
Louis Howard |
| 7/22/2013 |
Meeting or Teleconference Held |
Email sent to USAC Ken Andraschko and 611 CES Steven Mattson re: Fort Morrow & Port Heiden informal dispute resolution under DSMOA.
7/22/2013 A meeting was held with US Army of Corps of Engineers, Air Force, and ADEC staff to discuss resolution on whether the Air Force or USACE will take responsibility for the PCB contaminated soil within A-PR-2 at Port Heiden.
The Air Force used the site/area for temporary stockpiling of PCB contaminated soil from cleanup work it is conducting along the road between the former RRS site and the airport. Confirmation samples collected when the stockpiles were removed documented an area with significantly higher PCB levels than were present in the stockpiled soil or soil along the road adjacent to the site. Assessment work at the stockpile area included establishing a 10' X 10' grid across the site and collecting composite samples for PCB analysis.
Samples from most of the grids came back as ND or < 1 mg/Kg PCB. However, eight grids contained PCBs > than the 1 mg/kg cleanup level; samples collected from 6-8" below ground surface (bgs) from four of these had results between 1-10 mg/kg, one had 13.5 mg/kg, and one had 2,790 mg/kg PCB. The grid with the highest concentration was also sampled at 12" bgs and contained 181 mg/Kg PCB, and at 18" contained 278 mg/Kg PCB. The AF contractor estimated there are ~ 30 cubic yards of PCB contaminated soil in the gridded area, however, the full extent of PCB contaminated soil is not defined.
The AF contends this PCB contaminated area is not a result of secondary contamination from its' stockpile activities, but is likely the result of past activities associated with the WWII powerhouse that was located on the parcel. The AF is not planning to conduct further PBC cleanup work at the parcel.
The USACE conducted cleanup work at the site in the mid-1980s under the FUDS program and in 2012 developed a Remedial Investigation (RI) work plan for the Fort Morrow FUDS. The plan includes provisions for sampling and analysis for a range of contaminants of potential concern (including PCBs) at A-PR-2, the old powerhouse, as well as many other areas around Fort Morrow.
Portions of the FUDS RI workplan were implemented during 2012 and 2013, however, this site/area was not sampled due to funding limitations and the Air Force contractors working in the area. The USACE now contends this area is not FUDS Program eligible because the Air Force has initiated site work under the ER program and thus the site is categorically excluded from eligibility (FUDS ER 200-3-1, Section 3-1.5.3.10) and that the Air Force should complete the necessary PCB cleanup activities. The USACE is not planning to conduct PCB investigation or cleanup at this area.
See site file for additional information. |
John Halverson |
| 11/25/2013 |
Institutional Control Periodic Reporting |
Staff received the Institutional Control Performance Report (ICPR) for review and comment. The report will document reviews of the remedial actions selected in the 2009 Record of Decision (ROD) for the remediation of sites at the Port Heiden Radio Relay Station (RRS) and to determine whether these actions are protective of human health and the environment, and are functioning as designed. To achieve this purpose, reviews which evaluates the status of implementation of the selected remedies, identifies any significant variances from the ROD, and makes recommendations for reconciling variances and/or improving performance of remedial actions are completed.
In addition, the review identifies any new information that becomes evident, documents that no new contaminant sources or exposure pathways were discovered, confirms that no new sites were established, and verifies that no additional work was performed that was not identified in the ROD. This report shall include any information pertaining to any breaches of institutional Controls (ICs), corrective action taken, and any property transfers.
The US Air Force (USAF) will complete an ICPR annually for five years as required by the ROD. The frequency of the ICPR will be evaluated with the five-year review under 42 USC 9621(c). This report is the fourth annual review.
Soil
During the 2013 field season two different entities (Jacobs Engineering (Jacobs) and Kemron) were involved in excavating PCB-contaminated soil. Bethel Services was on-site too though their role was strictly in transportation and disposal of PCB-contaminated soil already excavated.
Bethel Services barged the 1123 10-CY supersacks of PCB-contaminated soil out for disposal. Kemron loaded 1,553 10-CY supersacks of PCB-contaminated soil that was previously stockpiled by others and shipped 1,427 of them off site for disposal.
Jacobs excavated and stockpiled 2,227 CY of PCB-contaminated soil. Approximately 5,000 cubic yards of PCB-contaminated soil remain at the RRS to be removed. Of this, approximately 2,260 cubic yards will be TSCA waste. Additional work is planned to be completed in 2014.
Specifics concerning Petroleum, Oil, and Lubricant (POL)-contamination were not addressed in the ROD. No POL-contaminated soil was excavated this year though operations at the landfarm continued. While the final reports are not yet complete, it appears all soil being landfarmed have been remediated. The landfarms will need to be decommissioned in 2014.
See site file for additional information. |
Louis Howard |
| 1/23/2014 |
Update or Other Action |
Draft GW Monitoring Report received for review and comment.
The primary project objectives for the 2013 groundwater sampling event were to:
• Conduct groundwater sampling and analysis to provide data for the evaluation of the
current contamination levels
• Evaluate trends in the groundwater at the Former RRS sites to support management
decisions.
FPC-066
Monitoring well 066-MW-05 contained a DRO concentration of 1.6 milligrams per liter (mg/L), which exceeds the ADEC Table C cleanup level of 1.5 mg/L.
FPC-215
Monitoring well 215-MW-09 contained a DRO concentration of 11 mg/L, which exceeded the ADEC Table C cleanup level of 1.5 mg/L.
Former Radio Relay Station
BLO-MW-01
13PH-BLO-MW-01
DRO 1,300 mg/L
RRO 79 mg/L
DSA-MW-01
13PH-DSA-MW-01
TCE 6.2 ug/L
DSA-MW-02
13PH-DSA-MW-02
TCE 500 ug/L
DSA-MW-04
13PH-DSA-MW-04
TCE 120 ug/L
PG1-MW-01
13PH-PG1-MW-01
TCE
21 ug/L
Recommendations
FPC-066
Based on previous sampling results, it is recommended that monitoring well 066-MW-05 be retained on the sampling schedule. The approximate groundwater flow at this site is to the south. Monitoring well 066-MW-06 is located south-southeast of 066-MW-05, and is the closest in proximity to Port Heiden School; it is recommended that monitoring well 066-MW-06 be retained (as a sentry well) on the 2014 sampling schedule. Because DRO has never been detected above the ADEC cleanup level in monitoring wells 066-MW-04 and 066-MW-07, these wells are recommended for removal from the sampling program. However, it is also recommended that the wells not be
decommissioned until results from all wells at the FPC-066 site are below ADEC cleanup
levels.
FPC-215
It is possible that one or more contamination sources remain onsite. All three wells at the FPC-215 site should be retained on the sampling schedule and additional remediation activities should be considered if concentrations of DRO in groundwater do not begin to decrease within site wells.
Former Radio Relay Station
No significant downward
trends in contaminant concentrations were observed. Based on the 2013 concentrations of TCE, DRO, and RRO, and lack of historical natural attenuation, MNA may not meet the timeframe proposed in the RI/FS (USAF 2006). It is recommended that all of the Former RRS wells that were sampled in 2013, excluding RRS-MW-02 and BLO-MW-02, be retained on the sampling schedule for 2014. COCs analyzed in monitoring wells RRS-MW-02 and BLOMW-02 have historically been nondetect. These wells are not considered sentry wells and it is recommended that no further sampling occur at these Former RRS wells. |
Louis Howard |
| 3/20/2014 |
Update or Other Action |
Site Road After Action Report received.
Field activities focusing on the lower sections of site road stopped in October 2013 when weather prevented safe and productive fieldwork. The remaining fieldwork includes the excavation of two grid cells, two excavation sidewalls, and one grid cell sliver with analytical results exceeding the PCB cleanup level. Additionally, 55 step-out grid cells need to be sampled, remaining stockpiles and pads in Storage Area 1 need to be decommissioned, and
the excavated portions of Site Road and adjacent areas need to be restored. These activities
are discussed below.
Waste disposal is scheduled to occur in 2014 under a separate contract. Characterization and remediation efforts for the upper sections are also planned; these activities will be discussed under a separate cover.
EXCAVATION OF REMAINING GRID CELLS AND SIDEWALLS
Two grid cells in Sections 03 and 08, two excavation sidewalls in Sections 03 and 27 and one grid cell sliver in Section 12 remain onsite with analytical results exceeding the PCB cleanup level are shown in dark pink (grid cells) or as red lines (sidewalls) on Figures A-3 through A-23. The depth of contamination ranges from the ground surface to approximately 36 inches
bgs. Excavation of these areas and the 55 (not including the 7 inaccessible grid cells) step-out grid cells shown in light blue on Figures A-3 through A-23 will produce an estimated 250 cy of TSCA nonhazardous PCB soil.
STORAGE AREA 1 DECOMMISSIONING
Following the removal of the stockpiled soil from Storage Area 1, the stockpiles and storage area will be decommissioned. The decommissioning process will be conducted in seven stages:
1. The protective sand layer on top of the liner will be removed.
2. The bottom liners will be carefully pulled back to expose the undisturbed soil underneath.
3. The pre-construction stockpile sample locations will be located using RTK-GPS and post construction samples will be collected from those locations.
4. The pre-construction storage area pad sample locations will be located with RTK-GPS, and post-construction samples will be collected from those locations.
5. Pre- and post-construction samples will be compared, and the area will be remediated as
necessary.
6. High traffic areas (defined as the grids where the dump trucks entered and exited the individual stockpiles) of the storage area will be sampled and remediated using the grid sampling and excavation methods described in the 2012 Work Plan (USAF 2012a) and Section 2.0 of this Report.
7. When analytical results indicate that PCB concentrations are below the ADEC cleanup level, the boundary fence will be removed and the overburden piles graded flat to allow positive drainage. The storage area pad will remain in place for future use.
SITE RESTORATION
Backfilling and grading of Site Road excavations will continue as analytical results for PCBs are confirmed to be below the cleanup level for grid cells and excavation sidewalls. The disturbed segments of Site Road and road shoulders will be backfilled and compacted to a condition usable to the NVPH. Excavations in areas adjacent to the shoulders of Site Road will not be backfilled, but will be graded to promote drainage. |
Louis Howard |
| 4/28/2014 |
Document, Report, or Work plan Review - other |
Staff reviewed and approved the draft After Action Report for Site Road. |
Louis Howard |
| 4/28/2014 |
Document, Report, or Work plan Review - other |
Staff approved the Draft After-Action Report Site Road dated March 2014, Port Heiden Alaska. ADEC has reviewed the document and concurs with the statements regarding the need for remaining field work. Please provide one hard copy and one electronic copy of the final report for our files. |
Louis Howard |
| 6/24/2014 |
Update or Other Action |
Draft First 5YR received for comment.
The following seven issues were noted during the first five-year review.
1. Several soil stockpiles were observed during the site inspection. Some of the stockpiles were not covered. High winds in the area have been known to transport PCB-contaminated soil to other parts of the site (NVPH, 2010).
2. Additional quantities of soil have been identified during the soil RA, conducted since 2009. The decision documents (ROD & ESD) do not account for the additional quantity of soil (USAF, 2009 & USAF, 2010a, respectively).
3. PCB-contaminated soil has been identified within Site Road & some adjacent areas, & the areas are not included in the current decision documents (ROD & ESD) for the site (USAF, 2009 & USAF, 2010a, respectively).
4. The soil RA has not been completed at the site, & is anticipated to continue through at least the 2015 field season. Increased quantities of soil, discrepancies associated with soil washing & landfilling during the 2009 field season, & the presence of contamination within Site Road & adjoining areas has required a longer timeframe to complete the soil RA than originally anticipated in the ROD.
5. During the site inspection of ERP Site LF007, it was observed that the landfill appeared to have subsided in places, & in one instance, the subsidence exposed metallic debris. Some metal debris was also visible on the ground surface. While this is not indicative of current exposure, if left unchecked, the landfill cap may further erode & contaminated soil may be exposed.
6. Although Annual IC Performance Reports are prepared to document reviews of the remedial actions & to determine whether these actions are protective, including whether the intent of the ROD required ICs are being met, ICs for soil & GW have not been put into place formally. Soil ICs will be put into place once the soil remedy is complete, but there is no reason to wait on implementation of GW ICs.
7. The ROD requires an evaluation of the progress of natural attenuation based on 5 years of GW monitoring (at a minimum). Only 4 years of data were available at the time of this five-year review. The purpose of the five-year evaluation is to compile, analyze, & review all GW data collected to determine the effectiveness of natural attenuation. The ROD also states that if during this evaluation the data indicates contaminant concentrations in GW are not declining as estimated, the remedy decision may be re-considered.
See site file for additional information. |
Louis Howard |
| 7/31/2014 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft 5 year review.
1 Issues and Recommendations Identified in the Five Year Review
Issue Category: Remedy Performance
Recommendation:
Text states: “Assess soil excavation and stockpiling practices and implement any changes necessary so that cross contamination of PCB- contaminated soil does not occur.”
ADEC requests the text state: “Review and modify stockpile maintenance plans to ensure contaminated soil stockpiles are covered and contained in a manner that prevents exposure to, and migration of, PCB-contaminated soil.
Affect Current Protectiveness
No
ADEC disagrees. The answer should be “Yes”.
7 Issues and Recommendations Identified in the Five Year Review
Issue Category: Remedy Performance
Issue:
The text states: “The purpose of the five-year evaluation is to compile, analyze, and review all groundwater data collected to determine the effectiveness of natural attenuation.”
ADEC requests the text be expanded to include recommendations on MNA sampling and analysis described on page 42 of pdf (pages 6-2 and 6-3).
4.3.2.1 Evaluation and Compilation of Groundwater Data
The text states: “The Final 2012 Groundwater Monitoring Report (NVPH, 2013) was the only report available for this five-year review; however, it included a comparison of the 2012 groundwater analytical results with the previous 2 years.”
This is unacceptable. ADEC requests the Air Force explain why all the groundwater monitoring reports and data aren’t available for review by its contractor. They should be in the AF and ADEC site files.
The FYR should include a review and summary of the groundwater data and monitored natural attenuation (MNA) effectiveness.
6.4 Data Review
2nd Bullet
The text states: “The report recommends quarterly groundwater monitoring to ascertain if there are seasonal groundwater flow variations. While seasonal flow variations could be possible, it appears as though there is an adequate network of monitoring wells that define the plume boundaries.”
The FYR could recommend using data-loggers to monitor groundwater elevation and potential flow direction changes.
|
Louis Howard |
| 8/13/2014 |
Update or Other Action |
ADEC has reviewed the revised RTCs to ADEC's comments on the First Five-Year Review of Environmental Restoration Program Sites OT001, WP002, SS004, LF007, and Four Unnumbered Sites (Antenna Pads, Contaminated Soil Removal Areas, Drum Storage Area, and Focus Area) Former Port Heiden Radio Relay Station.
The responses are acceptable. However, it shall be noted that 1,4-Dioxane is being requested by ADEC to be monitored in the groundwater where trichloroethylene (TCE) or 1,1,1- trichloroethane (TCA) has been detected (historically or currently) in groundwater above Table C at Port Heiden RRS. The monitoring of 1,4-Dioxane should be noted in the text at Section 9 as a recommendation and follow-up action Table 9-1.
BASIS for request:
AFCEE research has found 1,4-dioxane at Air Force sites contaminated with TCE. The study found detections of 1,4-dioxane at sites with TCE, independent of TCA (Anderson, R. H., Anderson, J. K. and Bower, P. A. (2012), Co-occurrence of 1,4-dioxane with trichloroethylene in chlorinated solvent groundwater plumes at US Air Force installations: Fact or fiction. Integr Environ Assess Manag, 8: 731-737. doi: 10.1002/ieam.1306).
"Surprisingly, 64.4% of all 1,4-dioxane detections were associated with TCE independently," the researchers say in the abstract. "Given the extensive data set, these results conclusively demonstrate for the first time that 1,4-dioxane is a relatively common groundwater co-contaminant with TCE."
The study authors recommend site investigations consider 1,4-dioxane as a potential co-contaminant of TCE at groundwater plume sites. The study explicitly warns that new discoveries of 1,4-dioxane contamination could delay cleanup completions and require more costly revisions to existing remedies, noting that there is strong evidence suggesting that 1,4-dioxane "will migrate much further than chlorinated solvents."
ADEC has promulgated enforceable cleanup levels (not advisories) for 1,4-Dioxane in soil and groundwater (latest version 18 AAC 75 April 2012 Table B1 and Table C) effective since 2008 and has remained unchanged in 2012 revised regulations.
Soil Under 40 inch Zone
540 mg/kg direct contact
0.21 mg/kg migration to groundwater
0.077 mg/L (77 µg/L) Table C groundwater cleanup level |
Louis Howard |
| 10/6/2014 |
Update or Other Action |
ATSDR Health Consultation for Evaluation of PCBs Associated with the Former Radio Relay Station Area, Former Fort Morrow, & Other Former Use Areas, Port Heiden, AK.
The purpose of this Health Consultation is to give community members the information they need to protect their health. Its purpose also is to recommend actions that Defense & other agencies can take where known contamination exists to protect the community’s health.
ATSDR evaluated the possible ways people could have contacted PCBs from the site; then evaluated the exposure doses using the data collected by Defense; filled in some data gaps using what is provided in literature; & then compared the doses with studies used to evaluate harmful effects.
We recommend filling as many data gaps as possible.
1. To minimize any additional exposure, the USAF & USACE should ensure that workers, especially local contractors, are adequately protected & educated about exposures before they handle PCB-contaminated soils.
2. The USAF, USACE, or U.S. EPA should sample for PCBs in the soil within the Village of Port Heiden. Potential is identifiable for the redistribution of soils from the former WACS/RRS, possible use of PCBs oils for dust suppression, as well as other sources.
3. The USAF or Corps of Engineers should sample the remaining roads on which PCBs might have been used for dust suppression. Testing of the borrow landfill sites (particularly drainages) & transportation routes for PCBs is recommended. Additionally, any remaining PCB hot spot areas in soil should be removed (including any associated with the old Army Power Plant, especially if access isn’t restricted to people.
4. ATSDR through its memorandum of understanding could work through Superfund Community Action through Nutrition (SCAN) or a similar program to help the community improve its overall health status to include a focus on local contaminants. A program designed to identify which foods contain the highest levels of PCBs & ways of preparing food or finding substitutes that could reduce exposure is recommended.
5. Should the above studies indicate PCB exposures, further investigation of food sources should be conducted. PCB data are unavailable for clams, sculpins, walruses & other marine mammals, & other animals in the Bristol Bay area near Port Heiden near shore & marine birds & their eggs are also food sources of some of the community.
See site file for additional information. |
Louis Howard |
| 1/20/2015 |
Update or Other Action |
Annual GW monitoring report received for review & comment.
FPC-066 SITE
In September 2014, GW samples were collected from 066-MW-05 & 066-MW-06 at FPC-066 & analyzed for DRO. Monitoring well 066-MW-05 contained a DRO concentration of 1.3 milligrams per liter (mg/L). The cleanup level for DRO is 1.5 mg/L. The field duplicate sample exhibited an identical concentration. Monitoring well 066-MW-06 contained a DRO concentration of 0.032 mg/L. This result was reported below the limit of quantitation (LOQ) but above the detection limit (DL). As such, the results are qualified J & are considered estimated quantities.
FPC-215 Site
In September 2014, GW samples were collected from the three wells at the FPC-215 site & analyzed for DRO. Monitoring well 215-MW-09 contained a DRO concentration of 12 mg/L, which exceeded the cleanup level of 1.5 mg/L. The remaining wells contained DRO at levels less than 1.5 mg/L, ranging from 0.022 mg/L to 0.036 mg/L. These results were reported below the LOQ but above the DL. As such, the results were qualified J & considered to be estimated.
Former Radio Relay Station
DRO was detected at 1,600 mg/L exceeding the cleanup level of 0.005 mg/L in one monitoring well (BLO-MW-01). RRO was detected at a concentration of 150 mg/L, in the same monitoring well, exceeding the cleanup level of 0.005 mg/L. The concentration of 1,1,2,2-tetrachloroethane, reported at 0.027 mg/L, exceeded the cleanup level of 0.0043 mg/L in monitoring well BLO-MW-01.
TCE was detected above the cleanup level of 0.005 mg/L in five wells. The reported levels of TCE ranged from 0.005 mg/L (monitoring well BLO-MW-01) to 0.49 mg/L (monitoring well DSA-MW-02). Monitoring well BLO-MW-07 was successfully sampled for the first time since being installed in 2012. All analytes were reported as nondetect (ND) or at levels well below applicable cleanup criteria. TCE was reported as ND with an LOQ of 0.001 mg/L. All other target analytes at the former RRS were either detected at levels that were less than the cleanup levels or were reported as ND, with a laboratory DL below the applicable cleanup levels.
Based on the available data, TCE levels are not naturally attenuating at a rate that will likely achieve the proposed RI/FS timeframe of 25.7 years in the areas surrounding monitoring wells DSA-MW-01, DSA-MW-02, DSA-MW-04, & PG1-MW-01. In wells containing lower TCE levels, such as BLO-MW-01, natural attenuation may be successful in reducing levels to below the cleanup level within the proposed timeframe.
See site file for additional information.
|
Louis Howard |
| 1/29/2015 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft groundwater monitoring report.
FPC-066 Site
ADEC concurs with the recommendation that one more sampling event for DRO in 2015 is needed prior to recommending site for closure.
FPC-215 Site
ADEC disagrees with the recommendation that the monitoring frequency be reduced from annually to biennial for all FPC-215 wells. Monitoring well 215-MW-09 is increasing in contamination and prior to any remediation, ADEC will require downgradient wells to delineate the full nature and extent of DRO contamination. ADEC recommends the Air Force install at least two wells downgradient of the 215-MW-09 (e.g. 75’ and 150’). The other two existing wells are crossgradient of the groundwater flow at the site (Figure 4-2) and do not give the data necessary to show what the full extent of groundwater contamination at the site.
Without such data, ADEC is unable to determine where the ultimate point of compliance in groundwater should be for FPC-215. In groundwater, the point of compliance where groundwater cleanup levels must be attained is throughout the site from each point extending vertically from the uppermost level of the saturated zone to the lowest possible depth that could potentially be affected by the discharge or release of a hazardous substance, unless ADEC approves an alternative point of compliance as part of the cleanup action under 18 AAC 75.360 [18 AAC 75.345(e)].
Former Radio Relay Station
ADEC disagrees with the recommendation to decrease monitoring of groundwater from every year to every five years. ADEC will allow for monitoring of groundwater to decrease from annually to every five years at the former RRS after two annual groundwater monitoring events for 1,4-Dioxane are conducted and results are below Table C cleanup levels for 1,4-Dioxane (0.077 mg/L) in addition to the other contaminants of concern.
The following EPA methods are recommended by ADEC to analyze for 1,4-Dioxane and have a low enough limit of detection to meet 77 µg/L cleanup level:
EPA 522 (Approved for DW, can be used for groundwater)
EPA SW 846 Method 8270 Modified
EPA SW 846 Method 8270
EPA Method 625 (Validated for waste water)
EPA SW 846 Method 8270SIM
EPA SW 846 Method 8260SIM
Unless there is data to the contrary, it appears that the ALS Laboratory did not run the full analysis of VOCs to include 1,4-Dioxane and ADEC cannot tell whether or not the limit of detection or limit of quantitation for ALS analysis of VOCs by EPA Method 8260 met the cleanup level criteria for 1, 4-Dioxane.
|
Louis Howard |
| 3/18/2015 |
Update or Other Action |
One of several sites with Land Use Controls in effect (LUCMP)in 2015 Pacific Air Forces Regional Support Center Installations, JBER, AK, March 13, 2015.
This LUCMP identifies the LUCs in place for ERP (or Defense Environmental Restoration Account [DERA]-funded) sites at PRSC installations in Alaska, JA, & WIA & documents the responsibilities & procedures for maintaining, managing, tracking, enforcing, & when appropriate, modifying or terminating the LUCs.
Note that the current version of this LUCMP covers the following sites:
• ERP sites & landfills determined to contain hazardous waste, waste assumed hazardous, or nonhazardous waste
• Sites regulated by the U.S. Environmental Protection Agency (EPA), Alaska Department of Environmental Conservation (ADEC), & the ERP
• ERP sites for which information regarding the contamination & LUC status was readily available during the development of this LUCMP
• Landfill sites managed by PRSC determined to contain hazardous waste, waste assumed hazardous, or nonhazardous waste that are not regulated by the ERP
“CZ” is the abbreviation for the Environmental Engineering Directorate of AFCEC, & “CZOP” is the abbreviation for Environmental Engineering Directorate, Operations Division, Pacific.
LUCs on active installations are not recorded in deeds. The USAF uses existing land use planning & management systems to track & manage LUCs at its installations. These systems typically involve including LUC boundaries & attributes into geographic information system (GIS) layers, incorporating LUCs into the installation master plan, & filing LUCs with the installation offices that are responsible for managing the buildings & grounds, utility systems, & construction.
Once LUCs are implemented, they must be maintained as long as site conditions exist that prevent unrestricted land use &/or unlimited exposure. LUCs can be maintained using a variety of separate & collective processes, including the site approval process, LUC boundary markers, periodic site inspections, environmental self-audits, training, internal notices, & 5-year reviews. If it appears a LUC is being violated, then appropriate installation officials should be notified immediately. Furthermore, regulatory agencies may be notified of the violation as applicable & as detailed in DDs, RODs, signed action memoranda, or ADEC letters of concurrence. The officials should take steps to ensure the integrity of the LUC is restored & the necessary corrective action & notifications are made. In addition, if the type of land use at an ERP site changes, the LUCs for the site should be reviewed to ensure that the new land use is compatible with the LUCs. If it is not, then the site remedy & DDs may need to be revised before implementing a land use change.
In addition to ICs established as part of LUCs of the ERP for landfill sites with LUCs in effect, both ERP landfill & non-ERP landfill sites in Alaska under the management of PRSC must also comply with regulations set forth by the ADEC solid waste regulations in 18 AAC 60. Furthermore, landfill sites under the management of PRSC but not categorized as an ERP site must also comply with ADEC 18 AAC 60.
Landfills are defined in 18 AAC 60 as “an area of land, or an excavation in which solid wastes are placed for permanent disposal, & that is not an application site, injection well, reserve pit, or waste pile.” This definition applies to most PRSC ERP & non-ERP sites in Alaska designated as landfills, dumps, or caches. Small PRSC ERP & non-ERP landfill sites at remote installations, such as the long-range radar stations, are regulated as Class III landfills as defined by ADEC.
General requirements to manage landfills in place are established by ADEC. However, alternative criteria can & often are adopted through negotiation with ADEC (see 18 AAC 60.900, Waivers).
Port Heiden Radio Relay Station Landfill LF007
Port Heiden Former Composite Building Foundation OT001
Port Heiden Spill/Leak No. 2 at Septic Tank SS004
LUC_RESTRICTION A notice type of institutional control will be implemented (with the land owners
consent) to control the use of soil containing residual concentrations of dieldrin above 0.0076 mg/kg. This notice will make the Land Owner aware that ADEC approval is required for any disturbance of soil (the goal of this institutional control is to prevent the constant contact of this media with water which could impact groundwater or surface water quality). |
Louis Howard |
| 4/7/2015 |
Update or Other Action |
Interim Status report received for review and comment.
During the 2014 field season, 1,634 bags totaling an estimated 12,634.4 tons (10,403.8 tons
non-TSCA and 2,230.6 tons TSCA) of PCB-contaminated soil was generated from pre-existing stockpiles and newly excavated grid cells. A total certified weight of 10,800.79 tons, consisting of 8,718.68 tons of non-TSCA and 2,082.11 tons of TSCA regulated waste was transported to facilities in Arlington, Oregon for disposal.
An additional 273 bags of non-TSCA soil with an estimated weight of 2,187.9 tons generated in 2014, and 194 bags of non-TSCA soil with an estimated weight of 1,535.4 tons generated in 2013 remain staged onsite at Storage Area J 1 and the former RRS site for transport and disposal during the 2015 field season. All pre-existing stockpiles were removed during the 2014 field season.
An estimated 10,000 tons of contaminated soil is scheduled for transportation and disposal during 2015 field activities. It is anticipated that additional quantities of contaminated soil will be
generated during the upcoming field season. Any additional bags that are unable to be
disposed of will be staged for disposal during the 2016 field season. |
Louis Howard |
| 4/10/2015 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (ADEC) Contaminated Sites Program has received the PCB Contaminated Soil Interim Data Report Port Heiden, AK dated March 2015
on April 7, 2015 for CS DB Hazard ID 185. ADEC has reviewed the report and will approved the document as a final document.
|
Louis Howard |
| 6/2/2015 |
Document, Report, or Work plan Review - other |
Staff reviewed and approved the final groundwater monitoring report. |
Louis Howard |
| 6/2/2015 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (ADEC) has received the Final 2014 Groundwater Monitoring Report Port Heiden RRS dated May 2015 for CS DB Hazard ID 185). ADEC has no further comments on the final version of the document and approves the document
|
Louis Howard |
| 6/3/2015 |
Update or Other Action |
Draft work plan received for review and comment.
The objective of this FSP is to document the collection procedures used for analytical samples that meet the quality requirements identified in the 2013 Work Plan (USAF 2013a). The investigation objective is delineation of PCB-contaminated soil regulated as nonhazardous (between 1 and 50 mg/kg) and hazardous (greater than or equal to 50 mg/kg) by the TSCA at the DSA.
Surface soil samples will be combination of discrete and 9 point composite samples and the subsurface (> 6 inches bgs) will be discrete soil samples.
Asbestos samples will collected by a certified inspector pursuant to 29 CFR 1926.1101(k)(5) and 40
CFR 763.86. If debris is observed that the inspector determines to be PACM, additional samples will be collected to characterize the suspect debris. Soil samples will be collected using a spoon, hand auger, or similar device. Wet methods will be utilized as identified in 29 CFR 1926.1101 and 1910.1001 during sample collection. |
Louis Howard |
| 6/4/2015 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the draft work plan for PCB soil excavation and drum storage work plan addendum. Main comments were to ensure the work involving asbestos removal and abatement meets the substantive requirements of 18 AAC 60 Solid Waste regulations pertaining to asbestos. |
Louis Howard |
| 6/5/2015 |
Document, Report, or Work plan Review - other |
Staff reviewed and approved the final PCB soil removal action 2014 interim data summary report. |
Louis Howard |
| 6/5/2015 |
Document, Report, or Work plan Review - other |
Staff reviewed and approved the final PCB soil removal action 2014 interim data summary report. |
Louis Howard |
| 3/23/2016 |
Update or Other Action |
Site Road PCB After Action report summary for 2013/2014 field work. Fieldwork from May to October 2013 included site layout, excavation & soil sampling of Site Road & the surrounding area, stockpile maintenance & decommissioning, other related sampling activities, decontamination, dust migration, & data management. From May to October 2014 - additional site layout, characterization sampling of stepouts on Site Road, the RRS Access Road, the northern landfill, & the Septic Lagoon, stockpile maintenance & decommissioning, decontamination, & data management. Excavation activities in 2014 were conducted under a separate contract.
The 2012 work plan (USAF 2012a) did not specify the technique for excavating sidewalls greater than 18” high. The grid sampling technique was modified for vertical sidewalls, with aliquots for composite samples collected every 5’ horizontally & 18” vertically. Removal in the adjacent cell was completed by excavating in 6” lifts or excavating vertically equal to the sidewall height.
Several grid cells were excavated in 2013 based on discrete tundra step-out samples from the 2011 RI that returned analytical or field screening results above 1 mg/kg PCBs. This eliminated the need for composite characterization sampling, thereby reducing analytical costs & avoiding potential ambiguity by not excavating locations with results greater than 1 mg/kg. After excavation, confirmation samples were collected in accordance with the 2012 work plan.
Stockpile post-construction samples collected from Storage Area 1 in 2013 were not collected at the same locations as pre-construction samples due to an oversight by the sampling team. The impact to the project is minimal because all of the post-construction samples were below 1 mg/kg PCBs. Future post-construction samples will be collected from pre-construction sample locations unless there are breaches in the bottom liner.
The work plan specified that waste characterization samples should be collected from each completed stockpile at the frequency specified in ADEC’s field sampling guidance. Stockpiles onsite ranged from approximately 2,000 to 2,500 cy, which would have required 13- 15 samples/stockpile. Instead, ADEC granted permission to use the grid cell samples as stockpile characterization samples. Each grid cell sample represents no more than 4 cy of contaminated soil based on a maximum lift thickness of 6”. Thus, a stockpile of 2,000 cy is represented by approximately 500 samples using this method.
Field activities on the lower sections of Site Road stopped in October 2013 when weather conditions precluded safe & productive fieldwork. No additional excavation of contaminated soil was done under this contract in 2014. The remaining fieldwork includes the excavation of two grid cells, two excavation sidewalls, & one grid cell sliver with analytical results exceeding the ADEC PCB cleanup level. Along the upper portion of Site Road, 40 step-out grid cells have been identified for step-out sampling. At the RRS Access Road, North Landfill, & North Landfill Road, delineation sample results above the ADEC cleanup level indicate that additional work is necessary to fully characterize & remove PCB contamination from these areas. One overpack drum containing a transformer found in Tundra section 90 remains staged onsite at the DSA. The overpack drum will be removed during the 2017 field season under a separate contract.
See site file for additional information. |
Louis Howard |
| 4/19/2016 |
Update or Other Action |
Draft Soil Removal Action report received for review & comment. During the 2015 field season, 1,787 bags totaling an estimated 10,324.6 tons non-TSCA & 2,335.0 tons TSCA PCB-contaminated soil were generated from newly excavated grid cells. A total of 1,632 bags with a certified weight of 11,822.36 tons, consisting of 9,638.18 tons of non-TSCA soil, 2,145.78 tons of TSCA soil, 10.5 tons of barge landing construction materials, & 27.9 tons of mistakenly excavated clean soil was transported to facilities in Arlington, OR for disposal. All remaining waste from 2013 & 2014 & approximately 65 percent of the soil excavated in 2015 was transported to the disposal facility.
All material excavated from the DSA (299 bags weighing an estimated 1793.8 tons) & 332 bags of soil from SRA2 (weighing an estimated 2,409.2 tons) remains staged at Port Heiden. Other material staged at the DSA (within the fenced excavation area) includes a large pile of metal debris, more than 100 transformers & batteries, 12 depressurized gas cylinders, an overpack drum with five bottles of unknown liquid, & five bags of crushed & dry-decontaminated drums. Complete characterization & appropriate disposal of DSA debris is yet to be determined. All 636 staged bags will be transported to the disposal facility in 2016 along with the soil excavated under remaining contract quantities in 2016.
Work at the DSA is anticipated to be completed in spring 2016. Three remaining grid cells with PCB results above cleanup levels were inaccessible at the end of 2015 due to pooling of heavy rain in mid-September. End-of-season sampling also delineated five additional excavation sidewalls with PCB concentrations above cleanup levels. All TSCA materials are thought to have been removed from the DSA, with only non-TSCA soil remaining. As PCB contaminated soil was found collocated with buried metallic debris, a geophysical survey was performed at the end of the 2015 field season & revealed no remaining buried metallic debris within 10 feet of the surface.
Levels of 1,2,4-TCB will continue to be screened against ADEC Method Two migration to groundwater cleanup levels at SRA2. PCBs & 1,2,4-TCB are expected to be collocated at the site, as 1,2,4-TCB was historically used as a dielectric fluid in transformers. Removal of 1,2,4-TCB-contaminated soil is expected to occur during the removal of PCB-contaminated soil. The quantities of PCB-contaminated soil remaining at the Port Heiden RRS area are estimated based on sampling results from previous & current removal activities (2013 through 2015). |
Louis Howard |
| 4/21/2016 |
Update or Other Action |
2016 PCB Removal Action Work Plan received for review and comment.
The project goal and objective outlined in this work plan is to remove soil with PCB concentrations greater than or equal to the Alaska Department of Environmental Conservation
(ADEC) Method Two direct contact cleanup level of 1 milligram per kilogram (mg/kg) (18 AAC 75.341) associated with the former RRS (ADEC 2016b). This includes approximately 4,400 tons of non-hazardous material as defined by the Toxic Substances Control Act (TSCA) (greater than or equal to 1 mg/kg and less than 50 mg/kg) and 1,400 tons of hazardous material as defined by TSCA (greater than or equal to 50 mg/kg) PCB contaminated soil from the former RRS site. All PCB-impacted soil will be containerized into LiftPacs, Super Sacks or the equivalent (hereafter referred to as “bags”), loaded onto barges, transported to Seattle, Washington, and transported by truck or rail to the Columbia Ridge Landfill and Recycling Center in Arlington, Oregon. Removal activities will be conducted in a manner that will minimize the waste generated. The goal of the removal effort is to prevent potential ingestion or direct contact exposure to soil containing PCB concentrations greater than or equal to 1 mg/kg.
See site file for additional information. |
Louis Howard |
| 4/25/2016 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft RA work plan.
Main comments were regarding CERCLA on-site remedial actions and permit requirements (there are none for actions conducted on-site) and field duplicate sampling requirements for every day in the field collecting samples. See site file for additional information. |
Louis Howard |
| 5/17/2016 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft GW WP. Main comments were clarification on which lab method was being used and to be consistent in the document text and tables, update references, and double check 1,4-dioxane lab SOPs.
See site file for additional information. |
Louis Howard |
| 7/18/2016 |
Update or Other Action |
Port Heiden Former Radio Relay Station 2016 Removal Action Work Plan Addendum (Draft) received for review and comment.
The purpose of this work plan addendum (WPA)
is to describe the sampling plan to evaluate concentrations of non-PCB soil contaminants of
concern (COCs) specified in the Record of Decision for Port Heiden Radio Relay Station (ROD), as well as a contaminant of potential concern (COPC) described in the PCB-Contaminated Soil Removal Action 2015 Interim Data Report Summary.
The COCs include three polycyclic aromatic hydrocarbons (PAHs) (benzo[a]anthracene, benzo[a]pyrene, and dibenzo[a,h]anthracene) and two pesticides (dieldrin and heptachlor epoxide). Each COC was previously found in exceedance of cleanup levels in soil at the former Soil Removal Area 2 (specifically SRA 2), the drum storage area (DSA), and the former RRS disposal area (North Landfill). The COPC to be sampled (1,2,4-trichlorobenzene [1,2,4-TCB]) was found at SRA 2.
See site file for additional information. |
Louis Howard |
| 7/19/2016 |
Document, Report, or Work plan Review - other |
Staff approved the work plan addendum. |
Louis Howard |
| 10/26/2016 |
Document, Report, or Work plan Review - other |
Staff reviewed the GW Monitoring Tech Memo. ADEC requests clarification on whether the above wells have just reached cleanup levels in the most recent sampling round or have met in for several years of sampling. Please provide additional text on the exact year of when the wells have been below Table C cleanup levels or a table (more preferable) with the wells and specific lab results as in done for Table 1 for each of the wells.
Please clarify whether or not the wells were ever sample for PAHs (Method 8270 and 8270-SIM), GRO (AK 101), BTEX (Method 8260). If so, include the historical results when reporting sampling from June 2018. If not, then add these analytes and laboratory methods to the draft work plan that will be submitted no later than April 1, 2018 for review, comment and approval. Well 66-MW-06 shall also be sampled for BTEX, GRO, PAHs at this time.
Also state in the text when the next five-year review will be conducted: “The next five-year review will be completed by May 2019.”
See site file for additional information. |
Louis Howard |
| 2/1/2017 |
Update or Other Action |
After action report for Kemron & Jacobs work on the non-time critical removal action received for review and comment. From 3 May to 19 May and on 15 August 2016, Jacobs directed the excavation and removal of an estimated 2,330 tons of PCB-contaminated soil from Soil Removal Area 2 (SRA2), from the upper and lower Site Road, and from the Drum Storage Area (DSA) (Figure A-2). This soil was excavated directly from targeted grid cells into 8.5-cy bags.
During the 2016 field season, PCB-contaminated soil was managed as follows:
• Bags containing TSCA soil with a certified weight of 2,476.73 tons were transferred to barges and transported to Chemical Waste Management of the Northwest in Arlington, Oregon for disposal.
• Bags containing non-TSCA soil with a certified total weight of 4,158.49 tons were transferred to barges and transported to Columbia Ridge Landfill in Arlington, Oregon.
• An additional 51.8 tons of uncontaminated operational waste were loaded on barges.
See site file for additional information. |
Louis Howard |
| 2/6/2017 |
Document, Report, or Work plan Review - other |
Staff provided comments on the Draft 2016 After Action Report for PCB-Contaminated Soil Removal Action at Port Heiden RRS dated January 2017.
ADEC wishes to inform AFCEC that proper characterization of the transformer or transformers encountered at Port Heiden RRS (i.e. PCB Article, PCB-Contaminated Electrical Equipment or PCB Transformer as defined by §761.3) may be required to ensure that they are either “non-PCB containing” or “PCB containing” for storage and disposal options under Title 40 of the Code of Federal Regulations (CFR), part 761, subpart D.
NOTE: ADEC does not have legal authority with regards to the requirements of the Toxic Substances Control Act (TSCA) and AFCEC’s use of its CERCLA authority to conduct the environmental cleanup at the Port Heiden RRS. ADEC is merely providing this information on transformers and PCBs as a courtesy to AFCEC and EPA should be contacted to get an official regulatory opinion on this matter should questions arise.
See site file for additional information. |
Louis Howard |
| 3/22/2017 |
Update or Other Action |
Explanation of significant differences provided for review & comment.
Based on the data collected for all sites currently addressed in the ROD or 2010 ESD since the publication of the ESD, the only difference identified as significant & warranting the publication of this current ESD are:
• Significant increases in PCB-contaminated soil quantity were identified.
• The increase in quantities of PCB-contaminated soil will result in increased overall costs.
These differences have arisen as additional site data have become available. Sampling to support the excavation, offsite transport, & disposal of PCB-contaminated soil has identified additional areas of PCB contamination that were not fully characterized during the Remedial Investigation/Feasibility Study. Although the total cost to dispose of these additional contaminated soils has increased, the disposal cost per ton has not changed significantly. The public could have reasonably anticipated these changes.
At the completion of the 2016 field season, approximately 895 tons of containerized non-TSCA PCB-contaminated soil was staged onsite for transport & disposal in 2017. An additional estimated quantity of 2,450 tons of PCB-contaminated soil remains to be excavated at the RRS site. The locations of known in situ contamination are shown on Figure 3-1; these include the North Landfill & North Landfill Road (LF007), the septic outfall (SS004), & the former Composite Facility (OT001) (Soil Removal Area 2 & DSA).
See site file for additional information. |
Louis Howard |
| 4/20/2017 |
Document, Report, or Work plan Review - other |
Staff provided comments on the Draft ESD. Staff requested AFCEC provide clarification on the disposition of the two transformers that were found during the 2016 remedial action. If removal of contaminated soil is to the 0.49 mg/kg ROD cleanup level, then a review of the remedy’s protectiveness will be required for benzo(a)pyrene left in soil above 0.20 mg/kg (200 ug/kg) as part of the next Five-Year Review. This applies to all contaminants which are detected above the human health cleanup levels in Table B1 Method Two 18 AAC 75.341 (March 23, 2017).
Sampling for and reporting the full analytical suite of PAHs and pesticides (not just ROD COCs ) will be necessary to ensure the cumulative risk from the residual soil contamination at the site is protective of human health as required by 18 AAC 75. COPCs which will need to be used in the cumulative risk calculations can be determined using the maximum soil concentration of each contaminant at the site that exceeds one-tenth (1/10th) of the human health levels in Table B1 for the Under 40 Inch Zone (March 23, 2017). If no chemicals at the site exceed the 1/10th threshold, or only petroleum range contamination is present, cumulative risk does not need to be calculated for the site.
For example the following contaminants exceed the human health cleanup levels established in 18 AAC 75 March 23, 2017 Table B1: benzo(B)fluoranthene at 22 & 13 mg/kg "J" exceeds the Human Health (3/23/2017) level of 2.0 mg/kg Indeno(1,2,3-cd) at 13 & 9.1 mg/kg "J" exceeds the Human Health (3/23/2017) level of 2.0 mg/kg - see figure 6.2-17 of the 2009 ROD. 1,2,3-Trichloropropane at 560 ug/kg or 0.560 mg/kg exceeds the Human Health level (3/23/2017) of 0.066 mg/kg or 66 ug/kg BLO-SB-12-S03-0, see page 77 of 119 pages 03-BLO.pdf.
See site file for additional information. |
Louis Howard |
| 5/15/2017 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft Interim 2016 Data Report for PCB Removal Action. Main comment was to ensure that text was added which shows the work was conducted by a "qualified environmental professional" as defined by 18 AAC 75.333. It is implied that this was the case since the final approved work plan stated that would occur but there is no mention of a "qualified environmental professional" or a "qualified sampler" in the document.
See site file for additional information. |
Louis Howard |
| 10/3/2017 |
Offsite Soil or Groundwater Disposal Approved |
Approval given for contaminated soil being transported offsite to permitted TSDFs depending on PCB concentration. TSCA to Chemical Waste Management of the Northwest and non-TSCA to Columbia Ridge Landfill both in Arlington, OR. |
Louis Howard |
| 2/7/2018 |
Update or Other Action |
After action report for 2016/2017 received for review and comment. During the 2016 & 2017 field seasons, Ahtna, with support from Jacobs & Aniakchak Contractors, removed 8,895.46 tons of PCB-contaminated soil, (7,991.74 tons of non-TSCA soil & 903.72 tons of TSCA soil). TSCA & non-TSCA grids targeted for future excavation activities & proposed characterization sample locations are available in the report. An estimated 5,419 tons of non-TSCA soil & 77 tons of TSCA soil remain onsite to be excavated. Contamination at the North Landfill will be addressed under a separate contract.
See site file for additional information. |
Louis Howard |
| 2/14/2018 |
Document, Report, or Work plan Review - other |
After action report reviewed. Staff main comments were on: no mention of this potential PCB-containing transformer as part of this report. ADEC assumes and requests written confirmation from AFCEC that the transformer from Tundra section 90 staged onsite at Drum Storage Area (DSA) has been dealt with appropriately in compliance with all federal regulations.
See site file for additional information. |
Louis Howard |
| 3/6/2018 |
Document, Report, or Work plan Review - other |
Supplemental RI work plan commented on. Main comments were regarding stop work order notification to ADEC as soon as possible if UXO or discarded military munitions were discovered during excavation activities after notifying the AK Troopers and JBER-EOD team. Other comments were regarding the need to calculate cumulative risk with sample results from this investigation and containers with fluids in them that are leaking will not be placed back in the test pit excavation. These containers will be placed in over pack drums and categorized for waste determination and disposal.
See site file for additional information |
Louis Howard |
| 6/1/2018 |
Document, Report, or Work plan Review - other |
Staff reviewed a draft evaluation of potential exposure to releases from historical military use areas at Port Heiden RRS by ATSDR. Main comments were to use the current petroleum contaminant cleanup levels and not reference Minnesota health based screening levels which are based on pyrene toxicity. Pyrene is not a contaminant of concern at any Air Force site or Army (FUDS) site at Port Heiden.
See site file for additional information. |
Louis Howard |
| 9/17/2018 |
Document, Report, or Work plan Review - other |
A letter was sent regarding the 2018 ADEC tech memo which establishes drinking water action levels for six PFAS when detected in groundwater or surface water used for drinking at Port Heiden Radio Relay Station. The tech memo establishes drinking water action levels for six PFAS when detected in groundwater or surface water used for drinking. These compounds, selected in accordance with the U.S. Environmental Protection Agency’s third Unregulated Contaminant Monitoring Rule (UCMR3) under the Safe Drinking Water Act, include: perfluorooctane sulfonate, also known as perfluorooctane sulfonic acid (PFOS), perfluorooctanoic acid, also known as perfluorooctanoate (PFOA), perfluorononanoic acid (PFNA), Perfluorohexanesulfonic acid (PFHxS), Perfluoroheptanoic acid (PFHpA), and perfluorobutane sulfonate (PFBS). Based on review of available information, DEC considers these six UCMR3 compounds to be hazardous substances under state law.
See site file for additional information. |
Louis Howard |
| 9/17/2018 |
Document, Report, or Work plan Review - other |
Staff sent a letter notifying Air Force of Action Levels for PFAS in Water and Guidance on Sampling Groundwater and Drinking Water Technical Memorandum dated August 20, 2018. Action levels for UCMR3 PFAS compounds in groundwater and surface water used as drinking water are as follows: Where one or more of the PFAS compounds, PFOS, PFOA, PFNA, PFHxS, or PFHpA are detected in a water sample analytical result, the sum of the concentrations for all detected compounds will be compared to an action level of 0.07 µg/L. Where PFBS is present in a water sample analytical result, the detected concentration will be compared to an action level of 2.0 µg/L. Please note that all future sampling results for PFAS-impacted groundwater, surface water, and pore water must include results for all six UCMR3 PFAS compounds.
See site file for additional information.
|
Louis Howard |
| 9/17/2018 |
Document, Report, or Work plan Review - other |
Staff sent a letter notifying Air Force of Action Levels for PFAS in Water and Guidance on Sampling Groundwater and Drinking Water Technical Memorandum dated August 20, 2018. Action levels for UCMR3 PFAS compounds in groundwater and surface water used as drinking water are as follows: Where one or more of the PFAS compounds, PFOS, PFOA, PFNA, PFHxS, or PFHpA are detected in a water sample analytical result, the sum of the concentrations for all detected compounds will be compared to an action level of 0.07 µg/L. Where PFBS is present in a water sample analytical result, the detected concentration will be compared to an action level of 2.0 µg/L. Please note that all future sampling results for PFAS-impacted groundwater, surface water, and pore water must include results for all six UCMR3 PFAS compounds.
See site file for additional information.
|
Louis Howard |
| 9/17/2018 |
Document, Report, or Work plan Review - other |
Staff sent a letter notifying Air Force of Action Levels for PFAS in Water and Guidance on Sampling Groundwater and Drinking Water Technical Memorandum dated August 20, 2018. Action levels for UCMR3 PFAS compounds in groundwater and surface water used as drinking water are as follows: Where one or more of the PFAS compounds, PFOS, PFOA, PFNA, PFHxS, or PFHpA are detected in a water sample analytical result, the sum of the concentrations for all detected compounds will be compared to an action level of 0.07 µg/L. Where PFBS is present in a water sample analytical result, the detected concentration will be compared to an action level of 2.0 µg/L. Please note that all future sampling results for PFAS-impacted groundwater, surface water, and pore water must include results for all six UCMR3 PFAS compounds.
See site file for additional information.
|
Louis Howard |
| 11/27/2018 |
Document, Report, or Work plan Review - other |
Staff commented on the draft landfarming report. Main comments were regarding a request to use incremental sampling methodology (ISM) for the landfarm cells instead of discrete soil sampling approach. Additionally, staff requested the laboratory standard operating procedure for combining soil from TerraCore and 4 oz. jars to make a low level VOC sample.
See site file for additional information. |
Louis Howard |
| 12/13/2018 |
Document, Report, or Work plan Review - other |
Staff approved the final 2017 Landfarming Report and 2016 Groundwater Monitoring report. |
Louis Howard |
| 12/21/2018 |
Update or Other Action |
Site location corrected using information provided by USAF PM. Site location used is for LF007 as this may be an ANCSA-conveyed site. |
Eric Breitenberger |
| 6/11/2019 |
Document, Report, or Work plan Review - other |
Staff approved the Final Supplemental Work Plan for Port Heiden RRS, Alaska, Dated May 2019
Contract Number: W911KB-14-D-0007-0008.
|
Louis Howard |
| 6/25/2019 |
Document, Report, or Work plan Review - other |
Staff approved the Draft Final Annual GW Report for Port Heiden RRS dated April 2019. |
Louis Howard |
| 2/18/2020 |
Update or Other Action |
Draft 2019 Technical Project Report for Remedial Action Operations, Land Use/Institutional Control at four sites: Former Composite Building (OT001), Black Lagoon (WP002), petroleum,
oil, and lubricants (POL) Pipeline (SS006) and Landfill and Debris Burial Area (LF007).
During the July 8 through July 11, 2019 field event, evidence of ongoing excavation of soils
(conducted by others) was observed at Site OT001. Concrete footers remain where former
composite building structures once stood. Portions of the past and ongoing excavation
stockpiles and terrace work were noted to be eroding, particularly surrounding well PG1-MW-01
which was noted as destroyed. Approximately 5 to 10 percent (%) of surface
vegetation was remaining where excavation activities had not occurred. Fencing installed to
control unauthorized site access during the ongoing excavation work was found to be damaged
in several places, and liner material was exposed in multiple locations across the site. An
inventory of site monitoring wells was performed (included in Appendix B), and revealed some
wells require repairs or total replacement: Of the 16 monitoring wells, 3 were unable to be sampled and require complete replacement:
o PG1-MW-01 had been removed from the ground entirely;
o UST-MW-02 was frost jacked and is unpassable with a pump below grade;
o GLO-MW-03 was frost heaved above the ground surface by about 6 feet.
See site file for additional information. |
Louis Howard |
| 2/25/2020 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft Remedial Action-Operations Land Use Control Report. Main comments were to replace or repair damaged monitoring wells, cover exposed liner material at OT001, resurvey all monitoring wells if not done in the last three years. Any sampling results that exceeded holding times as specified in the laboratory method shall be treated as screening level data and not to be used for statistical purposes.
See site file for additional information. |
Louis Howard |
| 4/28/2020 |
Document, Report, or Work plan Review - other |
DEC staff reviewed and provided comments to the U.S. Air Force on the "Draft Supplemental Work Plan, Remedial Action Operations, Land Use/Institutional Control, Port Heiden Radio Relay Station Sites OT001, SS004, SS006, LF007 and WP002" dated April 2020. The document describes the USAF's intent to conduct groundwater monitoring well decommissioning and
repair, install land use control (LUC) warning signs, and conduct Incremental Sampling
Methodology (ISM) of soils in two landspread areas (LSA) to support their closure. |
Louis Howard |
| 5/12/2020 |
Update or Other Action |
DEC evaluated and approved the “Final Work Plan, 2020 Remedial Action Operations, Land
Use/Institutional Control, Port Heiden Radio Relay Station, Sites OT001, SS004, SS006,
LF007 and WP002” dated May 2020. The work plan describes the United States Air Force’s intent to decommission and repair groundwater monitoring wells, install land use control warning signs, and conduct incremental sampling of soils in two land spread areas. These activities will occur at the Port Heiden contaminated sites OT001, SS004, SS006, LF007 and WP002. |
Melinda Brunner |
| 3/10/2021 |
Document, Report, or Work plan Review - other |
ADEC submitted comments on the Draft 2020 Technical Project Report, 2020 Remedial Action Operations, Land Use/Institutional Control, Port Heiden Radio Relay Station, Alaska, sites LF007, SS004, SS006, OT001, and WP002, dated February 2021, in a letter on this date. |
Sammi Castle |
| 5/26/2021 |
Document, Report, or Work plan Review - other |
5/25/2021 ADEC approved the Final 2020 Technical Project Report, 2020 Remedial Action Operations, Land Use/Institutional Control, Port Heiden Radio Relay Station, Alaska, sites LF007, SS004, SS006, OT001, and WP002, dated May 2021. |
Daniela Fawcett |
| 6/4/2021 |
Document, Report, or Work plan Review - other |
DEC reviewed and responded to the Draft Final Federal Uniform Policy for Quality Assurance Project Plan for Long Term Management and Remedial Action Operation Activities, Port Heiden Radio Relay Station, Alaska, dated March 2021. The document was received by DEC on May 10, 2021. The work plan describes the LTM and LUCs/RA-Os for four site at the LRRS: OT001, SS006, WP002, and LF007. 23 groundwater monitoring wells are to be sampled, and monitored natural attenuation parameters.
DEC responded with comments to incorporate the recommendations from past sampling events, such as the Final 2020 Technical Project Report, into the Work Plan. |
Cascade Galasso-Irish |
| 8/31/2021 |
Document, Report, or Work plan Review - other |
ADEC Approved the Final Uniform Federal Policy for Quality Assurance Project Plan for Long-Term Management and Remedial Action Operation Activities Port Heiden Radio Relay Station, Alaska, dated August 2021. The proposed plan explains the conceptual site model (CSM), defines the remedial action operations and long-term management and land use control inspections inspection activities to be completed at each site in Port Heiden, Alaska. The sites included in this plan are the Former Composite Building, POL pipeline, Black Lagoon, and Landfill and Debris Burial Area. |
Ginna Quesada |
| 9/9/2021 |
Document, Report, or Work plan Review - other |
ADEC reviewed and sent letter of approval for the Final 2020 Remedial Action Operations, Land Use/Institutional Control Report, Port Heiden Radio Relay Station Sites OT001, WP002, SS006, LF007, dated September 2021. The report presents the results of the 2020 Environmental Long-Term Monitoring program in Port Heiden, Alaska. The sites included in this plan are the Former Composite Building, POL pipeline, Black Lagoon, and Landfill.
Although two signs in good condition were observed at Sites OT001 and LF007, none was observed at Sites WP002 or SS006. The field crew observed evidence of unauthorized site use, including all-terrain vehicle/utility terrain vehicle tracks at Site SS006, and settling of the excavation backfill at the surface within the former pipeline corridor. Of the 16 wells at Sites OT001 and WP002, 5 wells need repair or replacement. Samples from 3 wells exceeded Alaska Department of Environmental Conservation (ADEC) Human Health Cleanup Level for manganese, including BLO-MW01, BLOMW07, and DSA-MW02 (ADEC, 2020). Tetrachloroethene was detected above ADEC Human Health Cleanup Level in DSA-MW02 (ADEC, 2020). Trichloroethene was detected above the ADEC Human Health Cleanup Level in BLO-MW01, DSA-MW01, and DSA-MW02 (ADEC, 2020). Diesel range organics (DRO) concentrations exceeded the ADEC Human Health Cleanup Level (ADEC, 2020) only at BLO-MW01. Of the seven wells at Site SS006, three need repairs. All seven were sampled for DRO and samples from wells 066-MW05 and 215-MW09 exceeded ADEC Human Health Cleanup Levels (ADEC, 2020). |
Ginna Quesada |
| 10/20/2021 |
Document, Report, or Work plan Review - other |
ADEC approved the final 2020 PCB Soil Removal Action report concerning the Port Heiden RRS OT001 Composite Facility and LF007 Landfill. This Polychlorinated Biphenyl Contaminated Soil Removal Action Report describes the soil remediation activities conducted at the former U.S. Air Force (USAF) Port Heiden Radio Relay Station (RRS). During the 2020 field season, significant percentages of the scoped tonnages for both non-TSCA PCB-contaminated and TSCA PCB-contaminated soils were excavated and transported to the Oregon disposal facility without incident. The estimated remaining PCB contaminated soil in the RRS area above the PAL is 450 tons. Further delineation is planned near Antenna Pad 1 where contaminated soil was eroded and migrated down onto grids that had previously been characterized as clean. The USAF conducted a supplemental RI. The report stated the following about LF007 (USAF,
2020b): “Horizontal and vertical delineations of LF007 surface and subsurface soil contamination are incomplete. Known site COCs and other Supplemental RI COPCs exceeded PALs at multiple soil sample locations and depths. Additional surface and subsurface soil data would be required to determine extents for each COPC; however, sufficient data was collected to develop FS alternatives… “Additional data would be needed to fully delineate horizontal and vertical extents of COPC impacted soils. Based on available information, the LF007 contaminated soil volume (petroleum and CERCLA constituents combined) is
estimated to be on the order of 23,000 cubic yards, assuming an expansion factor of 1.15 from in-situ volumes with no reduction for entrained debris volume.” The report stated the following about debris in the landfill (USAF, 2020b): “LF007 debris and trash volume is estimated to be on the order of 8,000 cubic yards, with no reductions for ex-situ debris compaction or separation of entrained soil volumes. This estimate assumes an areal debris extent of 53,600 square feet and the Supplemental RI average
observed maximum debris depth of 3.9 feet bgs.” Certain aspects of the work turned out to be more difficult than expected. |
Ginna Quesada |
| 3/4/2022 |
Document, Report, or Work plan Review - other |
ADEC approved the 2022 Work Plan PCB-Contaminated Soil Removal Action at Port Heiden Radio Relay Station, Alaska, Final, January 28, 2022. The work plan describes the further characterization of the North Landfill and the planned remedial actions to remove PCB contaminated soil at the Radio Relay Station in Port Heiden, Alaska. The sites included in this report are the Former Composite Building OT001, the Landfill LF007, the Black Lagoon WP002, Septic Tank Outfall SS004, the Contaminated Soil Removal Areas, the Focus Area, the Antenna Pads, and the Drum Storage Area. |
Ginna Quesada |
| 8/11/2022 |
Document, Report, or Work plan Review - other |
ADEC reviewed and submitted comments regarding the Draft Final 2021 Remedial Action Operations and Land Use / Institutional Control Report, Port Heiden Radio Relay Station, Alaska, Dated June 2022.The report describes the 2021 Land Use Control (LUC) and landfill cap inspection activities at the Former Composite Building OT001, the Landfill LF007, the Black Lagoon WP002, and the POL Pipeline SS006 in Port Heiden Radio Relay Station, Alaska. Groundwater monitoring was also conducted at OT001, WP002, and SS006. |
Ginna Quesada |
| 10/31/2022 |
Document, Report, or Work plan Review - other |
ADEC submitted comments regarding the Sites OT001 & WP002 Groundwater Remedy Study, draft, Port Heiden Radio Relay Station, dated September 2022.The study evaluates seven different remedies to reduce contamination at the Former Composite Building (OT001) and the Black Lagoon Outfall (WP002) sites located in Port Heiden, Alaska. The proposed remedies were evaluated based on their long-term effectiveness and protectiveness, short-term effectiveness, compliance with ARARs, implementability, cost, capacity to reduce the toxicity, mobility, and volume of contamination, and their ability to protect human health and the environment. |
Ginna Quesada |
| 11/2/2022 |
Document, Report, or Work plan Review - other |
ADEC approved the Final 2021 Remedial Action Operations and Land Use / Institutional Control Report, Port Heiden Radio Relay Station Sites OT001, WP002, SS006, and LF007, Alaska, dated October 2022. The report describes the 2021 Land Use Control (LUC) and landfill cap inspection activities at the Former Composite Building OT001, the Landfill LF007, the Black Lagoon WP002, and the POL Pipeline SS006 in Port Heiden Radio Relay Station, Alaska. Groundwater monitoring was also conducted at OT001, WP002, and SS006. |
Ginna Quesada |
| 1/9/2023 |
Document, Report, or Work plan Review - other |
The DEC approved the Sites OT001 & WP002 Groundwater Remedy Study, Final, Port Heiden Radio Relay Station, Dated January 202. The study evaluates seven different remedies to reduce contamination at the Former Composite Building (OT001) and the Black Lagoon Outfall (WP002) sites located in Port Heiden, Alaska. The proposed remedies were evaluated based on their long-term effectiveness and protectiveness, short-term effectiveness, compliance with applicable or relevant and appropriate requirements, implementability, cost, capacity to reduce the toxicity, mobility, and volume of contamination, and their ability to protect human health and the environment. To ensure the remedy implemented at these sites is protective of human health and the environment, the findings of this study will be used by the U.S. Air Force (USAF) to reevaluate the 2009 Record of Decision. The remedy the USAF selects will be reviewed and approved by ADEC to ensure it is protective of human health and the environment prior to anything being implemented. |
Ginna Quesada |
| 4/7/2023 |
Document, Report, or Work plan Review - other |
DEC reviewed and provided comments regarding the 2022 Polychlorinated Biphenyl Contaminated Soil Removal Action Report Port Heiden Radio Relay Station Port Heiden, Alaska Draft, dated March 10, 2023. The report describes the removal of polychlorinated biphenyl (PCB) contaminated soil and sampling results collected during the 2022 field season at the Radio Relay Station in Port Heiden, Alaska. The sites included in this report are the Fromer Composite Building OT001 and the Landfill LF007. No further action was recommended for the OT001 site and further characterization, and remediation was recommended for LF007. DEC does not concur with the recommendation for no further action at OT001 as PCB contamination remains that exceeds the project action level of 1 mg/kg. |
Ginna Quesada |
| 5/17/2023 |
Document, Report, or Work plan Review - other |
DEC approved the 2022 Polychlorinated Biphenyl Contaminated Soil Removal Action Report Port Heiden Radio Relay Station Port Heiden, Alaska Final, dated May 12, 2023. The report describes the removal of polychlorinated biphenyl (PCB) contaminated soil and sampling results collected during the 2022 field season at the Radio Relay Station in Port Heiden, Alaska. The sites included in this report are the Fromer Composite Building OT001 and the Landfill LF007. No further action was recommended for the OT001 site and further characterization, and remediation was recommended for LF007. |
Ginna Quesada |
| 8/11/2023 |
Update or Other Action |
All polychlorinated biphenyl (PCBs) contamination has been removed from the soil at the site: Port Heiden RRS OT001 Composite Facility, no further action for PCBs is required at this time. |
Ginna Quesada |
| 10/17/2023 |
Document, Report, or Work plan Review - other |
DEC reviewed the Draft Preliminary Assessment Report for Aqueous Film-Forming Foam Areas Port Heiden Radio Relay Station, Alaska, Dated October 2023. The preliminary assessment describes the document search and interviews to identify the potential presence of per- and polyfluoroalkyl substances (PFAS) associated with aqueous film-forming foam (AFFF) at the Port Heiden Radio Relay Station, Alaska. No evidence of AFFF use at the site was encountered. The assessment recommended no further remedial action planned for the site.
|
Ginna Quesada |
| 10/27/2023 |
Document, Report, or Work plan Review - other |
DEC submitted comments regarding the Draft Final 2022 Remedial Action Operations and Land Use / Institutional Control Report, Port Heiden Radio Relay Station, Sites OT001, WP002, SS006, and LF007, Dated August 2023. The report describes the 2022 Land Use Control (LUC) and landfill cap inspection activities at the Former Composite Building OT001, the Landfill LF007, the Black Lagoon WP002, and the POL Pipeline SS006 in Port Heiden Radio Relay Station, Alaska. Groundwater monitoring was also conducted at OT001, WP002, and SS006. |
Ginna Quesada |
| 1/2/2024 |
Document, Report, or Work plan Review - other |
DEC submitted responses to comments for the Draft Final 2022 Remedial Action Operations and Land Use / Institutional Control Report, Port Heiden Radio Relay Station, Sites OT001, WP002, SS006, and LF007, Dated December 2023. |
Ginna Quesada |
| 1/5/2024 |
Document, Report, or Work plan Review - other |
DEC approved the Final 2022 Remedial Action Operations and Land Use / Institutional Control Report, Port Heiden Radio Relay Station, Sites OT001, WP002, SS006, and LF007, dated January 2023. |
Ginna Quesada |
| 4/8/2024 |
Document, Report, or Work plan Review - other |
DEC reviewed and provided comments for the Draft Site Investigation Workplan for 2024 Site OT001 Feasibility Study at Port Heiden Radio Relay Station, Alaska, dated March 2024. The work plan describes the proposed groundwater sampling and monitoring well installation activities at the Radio Relay Station Landfill (LF007) and the Former Composite Building OT001 located at the Port Heiden Radio Relay Station, Alaska. |
Ginna Quesada |
| 11/1/2024 |
CERCLA ROD Periodic Review |
The DEC reviewed and provided comments for the Third CERCLA Five-Year Review for Sites OT001, WP002, LF007, and Four Unnumbered Sites (Antenna Pads, Contaminated Soil Removal Areas, Focus Area, and Drum Storage Area) and Second Non-CERCLA Periodic Review Report for Site SS006 at the Former Port Heiden Radio Relay Station, Alaska. The comment matrix and response letter were sent to the PM on 11/1/2024. The DEC is in disagreement with the Air Force regarding the protectiveness statement. Not enough of the remedy has been implemented since the second FYR to achieve a Protectiveness Statement of Short Term Protective. Based on the provided information, evidence, and DEC’s interpretation of FYR guidance and expected answers to Questions A, B, and C, the DEC requests that the Protectiveness Determination remain Protectiveness Deferred. |
Matthew Fleetwood |
