| Action Date |
Action |
Description |
DEC Staff |
| 3/26/1993 |
Update or Other Action |
DOD & ADEC joint Technical Memorandum of understanding signed concerning the Basewide Groundwater (gw) signed by: ADEC Jennifer Roberts RPM & USAF Joseph Williamson Chief Environmental Programs & Restoration. Due to the basewide gw study & the FY92 field work that occurred at Operable Units (OUs) 1, 2, & 5 it appears a large portion of the gw flows into OU5 (attach. 1-contour map). Based on this fact, Elmendorf (EAFB) will move all upgradient gw into the OU5 Feasibility Study, Proposed Plan & Record of Decision (ROD). This means addressing all gw from upgradient sources (CERCLA (ST20, Ous 3&4) & OUs 1 & portions of OU2) & SERA) at OU5 instead of at each individual source area (see attach. 2-Area Map). Sites with free phased product would be looked at to see if there is an available technology to clean them up in a cost effective way. Soil contamination would be addressed at the source areas. NOTE: addressed at the source areas is interpreted by ADEC as removal through excavation or active treatment systems (e.g. high vacuum extraction, bioventing, etc...). |
Jennifer Roberts |
| 7/13/1993 |
Update or Other Action |
Spill report form prepared by R. Weimer on 7/13/1993 from Larry Opperman. Due to overfills over time, contamination is present around and below tank during the heating oil tank's removal from 22-009 facility. Spill# 93-2-1-1-194-1. This unregulated 2,600-gallon heating oil UST was taken out of service in 1983. |
Robert Weimer |
| 3/2/1994 |
Underground Storage Tank Site Characterization or Assessment |
Heating Oil 2,600 gallon UST AFID 229 STMP 347 and associated piping were removed from excavation on July 14, 1993. Interpolation of the shallow aquifer contour lines indicates the depth to groundwater at this site is 112 feet. However, depth to the tank bottom was approximately 9 feet. Therefore, the calculated depth from the tank bottom to the shallow aquifer is approximately 29 feet. The groundwater gradient is toward the south at this location.
Although there were reports that the tank was leaking, there were no visual indications of damage or leakage when the tank was excavated. Additional investigative measures should be taken at the site to determine whether the shallow aquifer shows any contamination in the vicinity of the site. Installation of monitoring wells is recommended to this end. Level "B" is the calculated cleanup criteria.
Most soil samples tested in the field showed no hydrocarbon contamination. One field sample indicated hydrocarbon contamination of 3,000 ppm [Sample F-4 midway along south side, base of tank and Sample XXX-2 RP22-009 3' from west end of excavation under tank 5,900 mg/kg TPH as Diesel fuel 7' depth].
Larry Opperman of the Base Environmental Office was notified of the contamination found and was advised to notify ADEC in order to be compliant with Alaska Statutes and ADEC regulations. All excavated soil was returned to the excavation hole and approximately 100 tons of additional clean soil was used to bring the excavation site to the original grade elevation.
Soil sampling and testing were done in accordance with ADEC approved Quality Assurance Program Plan (QAPP) prepared by EA Remediation Technologies, Inc. Site history available indicated only the storage and dispensal of diesel fuel. Therefore, laboratory analysis only included screening for diesel and related hydrocarbon contaminants. Field tests indicated a very low level of hydrocarbon contamination. As per the agreement between ADEC and the U. S. Air Force, no attempt was made to cleanup contaminated soil in the vicinity of this tank.
Sample number XXX-2-RP22-09 3 ft. from west end of excavation 7ft. deep under tank had DRO at 5,900 mg/kg. The other two samples were below the cleanup level. All excavated soil and approximately 100 tons of additional clean soil were used to backfill the excavation |
Louis Howard |
| 4/13/1994 |
Update or Other Action |
Letter from Air Force to Kent Patrick Riley UST Site assessment information memo. Tank 209D had only one sample slightly above 100 ppm, therefore it is not expected to be included in the SERA agreement. Tank 229 will be incorporated into SERA. Tank 736 will be coordinated with EPA and ADEC to determine if this tank site can be handled as part of the Operable Unit 5 record of decision. |
Kent Patrick-Riley |
| 6/1/1994 |
Leaking Underground Storage Tank Release Confirmed - Petroleum |
LUST Site created in CSP for source area ID 75972 Low levels of petroluem hydrocarbons. Air Force requests no further delineation USAF 1995b. |
David Allen |
| 6/1/1994 |
Leaking Underground Storage Tank Cleanup Initiated - Petroleum |
|
Former Staff |
| 6/1/1994 |
Site Added to Database |
|
Former Staff |
| 6/3/1994 |
Update or Other Action |
A regulated 500-gallon waste oil UST associated with an OWS was operated from June 1990 through May 1994 and was replaced in 1994. UST Site Assessment Report UST Reg. # 229 bldg. 22-009 spill# 94-2-1--01-103-51. Work has to be done in accordance with the SERA compliance agreement for the 2,600 gallon heating oil UST. Appendix J states that there were field duplicate samples taken and analyzed. Report states 3 samples were collected and analyzed and no duplicate samples were taken. No information on disposal of sludge or rinsate from cleaning of the UST was provided in the report. The Department has no objection to including the site under SERA as proposed in the cover letter to the report. However, the Attachments to the SERA will need to be modified and submitted to establish time frames for conducting the work The department requests submittal of amended attachments in time to allow for programming the additional work for the next fiscal year. |
Louis Howard |
| 8/12/1994 |
Update or Other Action |
Spill report for bldg. 22009 Used oil water mixture 300 gallons estimated released. Oil/water (O/W) mixture was being pumped through a newly replaced oil/water separator. The discharge pipe on the o/w separator had a leaking connection, causing the o/w mixture to go into the ground. The operator of the system later discoved that oil was not going into the oil overflow tank. When piping was excavated, a broken line was found. Most of the spill seems to be under the bldg. As the damaged pipe is within the bldg. Foundation. Further site assessment is planned. Spill# assigned: 94-21-1-224-01. Approximately 35 cubic yards of contaminated soil were excavated from the area between the OWS and the new UST; this soil was transported offsite for remediation. Two soil samples collected below the piping at 3.5 ft. bgs inside the building contained DRO of 3,860 mg/kg and 3,800 mg/kg. Four samples collected between 1 and 6 feet immediately outside the building contained GRO, DRO, BTEX compounds above cleanup levels. |
Louis Howard |
| 11/18/1994 |
Enforcement Action |
Notice of Violation Sent to Lt. Col. Lawrence E. Boese Sections 3007(a) & 3007(c) of RCRA AS Title 46 chapter 03 Section 020. Violation #10: Permit Condition 111.C. requires USAF Elmendorf AFB to use a container lined with materials which will not react with, and are otherwise compatible with, the hazardous waste to be stored, so that the ability of the container to contain the waste is not impaired, as described in Attachment 8, and as required in 40 CFR 264.172 and 18 AAC 62.410.
During the inspection the Department observed two pallets of hazardous waste doors stored
inside of Building 22-009. The doors had been painted with lead based paint and exhibited the
hazardous waste toxicity characteristic for lead. The doors were not containerized, but instead
were simply strapped to the pallets. Attachments 5 and 8 of the Permit specifically address
container management, and these two pallets of hazardous waste were not stored in a manner
consistent with these provisions.
USAF Elmendorf AFB must ensure that hazardous waste is stored in accordance with the
applicable permit conditions. Please inform the Department of the manner in which the
hazardous waste doors have been or will be containerized for storage.
Please submit your response to this Notice directly to Mr. Richard Sundet of my staff at the above listed address. In addition, please send a copy of your response to:
Mr. Daniel J. Garcia
Hazardous Waste Program
Department of Environmental Conservation
410 Willoughby Avenue, Suite 105
Juneau, AK 99801-1795 |
Janice Adair |
| 1/23/1995 |
Update or Other Action |
Memorandum letter from Air Force to John Halverson re: corrective action at bldg. 22009. In response to the NOV sent on 29 Dec 94, a) The oil water separator at bldg. 22009 has been out of service since the suspected underground release occurred. The system will continue to remain out of service until the validity of the UST connection is confirmed. B) The Environmental Compliance Office (CEVC) is currently managing a contract to inspect and correct any dificiencies at fac. 22009. CEVC plans to remove portions of the floor from the separator to the bldg. Perimeter.
Existing piping will be replaced and soils sampled for any contamination which may be present. Contaminated soils encountered will be removed where possible. CEVC is currently reviewing requirements to accomplish a release investigation at the facility pending confirmation that a release from the new UST occurred. Schedules for corective action at 22009 will be forwarded as soon as they become available. |
John Halverson |
| 4/21/1995 |
Update or Other Action |
Air Force Memorandum to John Halverson (ADEC) re: UST meeting. Elmendorf AFB will accomplish the following actions regarding UST projects. These actions are based upon conversation between, John Mahaffey, Larry Opperman and yourself.
a. EAFB will make every effort to accomplish clean closure of a UST removal if possible.
b. UST removal locations requiring cleanup action will be transferred into the State Elmendorf Environmental Restoration Agreement (SERA). A list of sites requiring cleanup will be coordinated with your office.
c. The presumptive remedy for contaminated UST sites in the outwash plain only will be bioventing technology.
d. Contaminated soils exceeding cleanup levels may be placed back into the excavation only if the site assessment (SA) indicates a need for further action.
e. Contaminated UST sites not in the outwash plain will require further investigation to determine appropriate cleanup options.
f. We (Elmendorf) will make every attempt possible to assure new USTs or new aboveground tanks are not installed in any way that would hamper future access for cleanup.
g. The project will first accomplish removal of all the USTs. SA information will be used to prioritize sites for cleanup using existing project funds. Additional funding will be requested to complete cleanup if available. Sites not addressed for cleanup due to exhausted funding will be placed in SERA Phase IV.
John Halverson signed memorandum on April 21, 1995. Memorandum submitted by Douglas G. Tarbett, Maj. USAF, Chief Environmental Compliance (CCs 3 WG/JA and 3 SPTG/CE). |
John Halverson |
| 7/2/1995 |
Update or Other Action |
UST Site Assessment Final Report received for AFID tank 209 and associated piping near bldg. 22-009. The 500 gallon used oil UST was removed on June 16, 1994. Field screening PID results showed the tank pit and excavated soil to contain non-detectable concentrations of volatile hydrocarbons in soil vapor. Soil analytical results for RRO ranged from not detected (ND) to 57 mg/Kg, with the highest result at the center of the tank excavation.
DRO results ranged from 18 mg/Kg to 52 mg/Kg, with the highest result at the center of the excavation. Toluene was detected at 0.05 mg/Kg in the sample from the western portion of the stockpile. Total Xylenes results ranged from 0.08 mg/Kg to 0.12 mg/Kg, with the highest result in the center of the tank pit. Methylene chloride results ranged from 17 ug/Kg to 22 ug/Kg with the highest result in the sample from the eastern portion of the stockpile. The methylene chloride is believed to be a lab contaminant.
No contamination was found above level B criteria. |
John Halverson |
| 8/11/1995 |
Enforcement Agreement or Order |
ADEC (J. Halverson) sent letter to Air Force (L. Opperman) RE: Disposition of petroleum contaminated soil generated during underground storage tank (UST) Closures at Elmendorf AFB. I met with you and Mr. John Mahaffey on April 18, 1995, to discuss UST closures planned at Elmendorf this summer and the issue of how contaminated soil would be handled. We agreed that if "clean closure" could be reached through excavation, all contaminated soil should be removed and taken to an off-site treatment facility.
We also agreed that petroleum contaminated soil could be placed back in the ground, on the condition bioventing systems would be installed starting this year, if clean closure was not feasible. However, it has become apparent the Air Force has not been able to implement corrective action at leaking underground storage tank sites in a timely manner.
Therefore, our April 21, 1995 agreement on soil management must be revoked. Starting immediately, the department requests that all contaminated soil removed from the ground during closure or upgrade of USTs be completely contained in accordance with our petroleum contaminated soil stockpiling guidelines referenced in the UST regulations.
Please notify your project managers, the Army Corps of Engineers project manager and all of your UST contractors of this change. The rationale behind the need to contain all excavated petroleum contaminated soil is provided below.
Failure to implement Corrective Action-Tank #805, at building 24-805, failed a tightness test in 1994 and was removed from the ground.
Tanks #96-104 were also removed from the ground in 1994. Petroleum contaminated soil was excavated during removal of the tanks. The Air Force requested approval to place contaminated soil back in the ground at both sites.
Department approval was granted on the condition corrective action be started at each site no later than June 30, 1995. The Air Force had committed to doing this work under Phase IV of the SERA.
However, we have been informed that contracts for SERA Phase IV have not yet been awarded, work plans have not been developed, and it does not appear the field work will be started this year. This is a violation of the corrective action requirements outlined in the UST regulations and our prior agreements.
Management Action Plan (MAP) for transfer of LUST sites into the SERA-On several occasions the department has requested a formalized process for transfer of leaking UST sites from the UST agreement into the SERA. The January 31, 1995 annual UST report states that a MAP was being prepared to formalize such a process and that a copy would be forwarded to us as soon as it was completed. We have not received a copy of the MAP.
Numerous LUST sites have been identified during the past two years and transfer of sites between the UST and SERA compliance agreements has not been working. It appears the UST agreement needs to be amended to address release investigation and corrective action requirements.
Based on the above and the fact that funding for DoD environmental cleanups is being reduced, we are no longer in a position to allow contaminated soil to be placed back in the ground with the hope it will be remediated in a timely manner. |
John Halverson |
| 8/14/1995 |
Document, Report, or Work plan Review - other |
On February 21, 1995, staff sent the Air Force a letter with comments on site assessment reports prepared by EA Engineering for USTs it closed or upgraded during 1994. The reports were not complete and ADEC requested they be amended to provide the necessary information. Without the complete site asessment reports ADEC is unable to make determinations on site closure or the neeed for additional investigation or corrective action. Until information is submitted, the Air Force has not met its site assessment obligations and may be in violation of release investigation and corrective action requirements.
On March 28, 1995, ADEC sent the Air Force another letter providing comments on site assessment reports prepared by Haliburton NUS and Harding Lawson. Several of the sites may be appropriate for no further action decisions after additional information is provided. However, until it is submitted, ADEC cannot make such determinations.
UST#209 at Building 22-009- EAFB's annual UST report dated January 31, 1995, stated the floor of the building would be cut out to conduct a site assessment beneath the piping. It also state the release investigation and corrective action would be conducted concurrently with work being done at the site under Phase III of the SERA. |
John Halverson |
| 10/17/1996 |
Update or Other Action |
Air Force memo: Restricted Use of the Shallow Aquifer on EAFB signed by William R. Hanson P.E. GM-14 Chief Environmental Flight dated October 17, 1996 Memorandum for 3 SPTG/CEC/CEO from 3 SPTG/CEV
1) Due to the contamination & commitments to EPA/DEC the use of the shallow aquifer for any purpose on is not allowed. Attached Facilities Board minutes-03/29/1994 0930 Item 9 has Mr. William Hanson, briefing the Board on the policy to not use the shallow aquifer due to contamination. The Board approved this policy. Minutes approved by Thomas R. Case Brigadier General USAF Commander. The IRP has RODs for OUs 3 & 6 which require, the aquifer remain unused. 2) Personnel in the review process within CES must be aware of these policies & review them on a recurring basis. It is imperative this restriction be recognized & observed during engineer reviews & operations. |
Louis Howard |
| 3/31/1997 |
Underground Storage Tank Site Characterization or Assessment |
AFIDs 209 and 229 SERA Phase IV ST403 Release Investigation Report Draft Final received. ST403 is a former UST site located at bldg. 22-009 west of Maple street on the southern portion of EAFB. AFID 209 was a 500-gallon waste oil UST located in a small courtyard on the southwest side
of Building 22-009. The UST received the organic discharge from an oil-water separator (OWS) located inside Building 22-009. The UST and piping to the OWS were replaced in June 1994. Low levels of petroleum hydrocarbons were detected during removal of AFID 209, and no further delineation was recommended (USAF 1995).
9 borings were completed at ST403, including one groundwater monitoring well 403WL01, 5 soil gas monitoring arrays and 3 bioventing air injection wells. Two borings had contamination above level "B" cleanup criteria for DRO. 403WL04 at 21 feet had 1,630 mg/kg, 403WL03 (duplicate) at 31 ft had 15,300 mg/kg and at 36 ft. had 4,860 mg/kg DRO. Groundwater was encountered at 38' bgs.
Site disposition recommendations will be submitted under separate cover pending completion of risk assessment work on the affected areas. |
Louis Howard |
| 6/3/1998 |
Document, Report, or Work plan Review - other |
Letter from ADEC to Air Force (J. Mahaffey)- RE: Corrective Action for SERA Phase IV Sites. The Alaska Department of Environmental Conservation (Department) has reviewed the release investigations reports received in March of 1997 by the Air Force as part of the SERA IV Release Investigation Project.
Based on information contained in the release investigation and previously submitted site assessment reports, the Department requests the Air Force to begin correction action on contaminated soils associated with decommissioned underground storage tanks (UST) at the following sites:
1. ST 401; AFIDs 96-104 associated with Building # 22-013,
2. ST 402; AFID 150, associated with Building # 32-127,
3. ST 403; AFIDs 209 & 229, associated with Building # 22-009,
4. ST 422; AFID 471, associated with Building # 41-701,
5. ST 424; AFID 189, associated with Building # 32-189,
6. ST 405; AFID 335, associated with Building 42-335,
7. ST 419; AFIDs 51 & 52, associated with Building # 41-659,
8. ST 407; AFIDs 575, 576 & 578, associated with Building # 43-575,
9. ST 410; AFID 165, associated with Building “Hush House”,
10. ST 421; AFID 425A, B, C & D, associated with Building # 42-425, and
11. ST 428; AFID130, associated with Building # 1-836.
SERA IV sites not listed above may need further release investigation work, or the contamination may be low enough to justify a “no further action” response.
Since all the SERA IV sites listed above have soil contamination that extends to ground water, and groundwater sampling was not performed as part of the SERA IV release investigations, the Department is assuming the groundwater is also contaminated. The Department is requesting the Air Force to submit a corrective action plan to address the contaminated groundwater, or submit a groundwater sampling plan to find the extent of groundwater contamination associated with the decommissioned UST. |
Tim Stevens |
| 11/25/1998 |
Update or Other Action |
Technical Document to support no further action ST75 at 22-009. Adminstratively close site ST75 from SERA Phase III program and move it under the SERA Phase IV program as site ST403. Soil contamination is being addressed under SERA Phase IV as ST403. Monitoring well 403-WL-01 is included in the SERA Phase IV groundwater contaminants of concern effort. Groundwater contamination will continue to be monitored under the Basewide effort until the water meets standards. The document was signed by L. Howard ADEC and J. Williamson Elmendorf AFB on 11/25/98 and 11/13/98 respectively. |
Louis Howard |
| 7/31/2001 |
Leaking Underground Storage Tank Corrective Action Underway |
A bioventing treatability study was also performed during the 1996 release investigation. This study was conducted to establish whether bioventing would be suitable for remediation of POL-Contaminated soils. Results indicated that oxygen levels were depleted, a condition unfavorable for bioventing. ST403 has deep contamination only. Because contamination deeper than 15 feet bgs is not easily excavated, it is proposed that groundwater be monitored at this site to address deep contamination. The monitoring approach will be provided in a groundwater monitoring activities work plan. It is proposed that wells be sampled as part of the basewide environmental monitoring program to monitor any potential impact that soil may have on groundwater. Sampling specifics (such as contaminants of concern) will be included ina groundwater monitoring activities work plan. The monitoring network at ST403 is likely adequate, but will require further evaluation. There are no wells located at the site for monitoring. Well 403-WL-01 is located downgradient of the site or currently in the basewide program. |
Louis Howard |
| 8/21/2002 |
Update or Other Action |
RECKEY has automatically been generated. |
Louis Howard |
| 10/21/2002 |
Update or Other Action |
Letter sent to Joe Williamson dissolving the State Elmendorf Environmental Restoration Agreement. The Alaska Department of Environmental Conservation (DEC) has reviewed the issue of abolishing the State Elmendorf Environmental Restoration Agreement (SERA) per your recommendation. Elmendorf Air Force Base and DEC entered into the SERA in 1992. The agreement was developed as a tool to bring the Base into compliance with Alaska's regulations addressing underground storage tanks, oil and other hazardous substance releases and solid waste.
Since that time, Elmendorf has made significant progress in investigating and cleaning up historic contamination problems. Many of the sites covered by the SERA have been successfully cleaned up and closed. Cleanup is underway at the remaining sites.
Additionally, Alaska has amended the regulations addressing fuel storage tanks, oil and other hazardous substance spills and solid waste. We concur with you that the SERA is no longer a necessary or beneficial. This letter serves as notice that DEC will end oversight on environmental work at Elmendorf by using the SERA. Instead, it is understood that the sites and programs formerly addressed by SERA: solid waste, underground storage tanks (UST), and oil and other hazardous substance discharges will be addressed in accordance with 18 AAC 60, 18 AAC 78 and 18 AAC 75. |
Jennifer Roberts |
| 7/23/2004 |
Institutional Control Record Established |
Because petroleum contaminated soil (e.g. contaminant levels higher than Method 2 cleanup levels in Tables B1/B2 found in 18 AAC 75.341) remains at this site, the Base Master Plan needs to be updated to document the locations of residual contamination and the need to manage contaminated soil properly during any future construction or excavation work.
Hydrocarbon contamination (DRO) remains above the ADEC cleanup level in the subsurface soil at ST403. DRO above the cleanup level was detected at 3.5 feet bgs under piping in the building and likely remains under the building foundation. At UST AFID 209, DRO above criteria was previously detected between 1 and 6 feet bgs but SERA IV investigation results indicated that contamination was only present in the smear zone. At UST AFID 229, DRO above criteria was detected from 7 feet bgs to 20 feet bgs. Petroleum hydrocarbon contamination has not been detected in downgradient smear zone samples. |
Louis Howard |
| 7/23/2004 |
Conditional Closure Approved |
After reviewing the data and reports submitted for ST403, the Department agrees that no additional remediation or investigation is required for ST403 LUST Event ID 2826. However, groundwater monitoring will be required until cleanup levels are achieved.
The Department reserves its rights, under: 18 AAC 75 Contaminated Site regulations, 18 AAC 78 Underground Storage Tank regulations, and AS 46.03 to require additional investigation, cleanup, containment, and/or other necessary actions, if subsequent information indicates: additional contamination remains at the site which was previously undiscovered and presents an unacceptable risk to human health, safety, or welfare, or the environment. |
Louis Howard |
| 7/23/2004 |
Long Term Monitoring Established |
Based on previous investigations, contamination may also be present in shallow soil under the building foundation and immediately adjacent to the building. Excavation of this contaminated soil is not practical and may undermine the building foundation. Based on SERA IV investigation results, petroleum hydrocarbon contamination has not migrated from the source area.
This site is located within the OU5 modeling area as identified in the Operational Agreement (OA) between ADEC and Elmendorf AFB signed 28 July 2002. In the OA, both parties agree that the portion of the unconfined shallow aquifer in the outwash plain has demonstrated, through modeling and sampling, the ability to naturally attenuate residual hydrocarbon contamination from most POL spills in a reasonable period of time.
The Elmendorf AFB Basewide Groundwater Monitoring Program will be utilized to monitor groundwater during implementation of the remedy. The nearest downgradient monitoring well currently in the Basewide Groundwater Monitoring Program is 403-MW-01, located approximately 150 feet south of ST403. Trichloroethylene (TCE) was detected in this well in 2002; however, DRO was not detected. |
Louis Howard |
| 2/18/2005 |
Update or Other Action |
February 18, 2005 list of sites sent which included ST403 event ID 2826 Project # FXSB661505. Well ID 403MW-01 will be sampled on an annual basis for DRO and PAHs. Each well presented in the table submitted will be sampled in 2005 to establish baseline COC concentrations. Proposed sampling frequencies would thus take effect in 2006. An annual sampline frequency has been assigned to sites near the OU5 Bluff whereas all other sites received a biannual frequency. |
Louis Howard |
| 7/6/2006 |
Update or Other Action |
2005 Annual Report Monitored Natural Attenuation of Basewide Compliance Program Wells received. Currently, the 3 CES/CEVQ is required by ADEC to monitor the degree to which certain regulated contaminants are naturally attenuating on 27 sites throughout the Base. The natural attenuation of each of these sites is being monitored by sampling and analyzing the groundwater under the contaminated areas and/or downgradient of the contaminated source.
As presented in the ST403 Decision Document, the selected remedy for ST403 was MNA. This remedy was selected because remaining contaminant concentrations in soil and groundwater exceed the ADEC 18 AAC 75 (ADEC, 2005) cleanup levels at this site. Excavation was not selected because the highest contaminant concentrations in soil were detected at depths greater than 20 feet bgs and required excavation could undermine the stability of the building foundation. Bioventing was also not selected because the maximum contaminant concentrations were detected at the smear zone and the site is located upgradient of the constructed wetland remediation system. The Decision Document recommended MNA at the nearest downgradient monitoring well, 403WL-01 (sometimes called 403-MW-01), located
approximately 150 feet south of ST403.
Remaining contaminant concentrations in soil and groundwater exceeded the ADEC 18 AAC 75 cleanup levels at ST403 in 1996. In 2005, groundwater in monitoring well 403WL-01, located approximately 150-feet downgradient of ST403, did not have detectable concentrations of DRO or PAHs. |
Louis Howard |
| 6/20/2007 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the 2006 Annual Report Monitoring of Compliance Program Sites, Elmendorf Air Force Base (EAFB) dated May 2007. ADEC concurs with the recommendations to continue groundwater sampling for diesel range organics (DRO) and volatile organic compounds (VOCs) at 403MW-IN. Gasoline range organics (GRO), residual range organics (RRO), benzene, toluene, ethylbenzene, and total xylenes (BTEX), metals, and polynuclear aromatic hydrocarbons (PAHs) may be dropped from the monitoring program since they were not detected above cleanup levels in the in-source groundwater well. |
Louis Howard |
| 7/5/2007 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft Work Plan and Field Sampling Plan Compliance Program Sites, Elmendorf Air Force Base (EAFB) dated June 27, 2007. For ST403 the following wells will be monitored: 403MW-IN and OU5KM-03 for GRO, BTEX, DRO, RRO, VOCs, PAHs and Metals.
ADEC has developed a technical memorandum and a Laboratory Data Review Checklist (checklist) summarizing the minimum requirements for both laboratory data packages and quality assurance (QA) summaries (data reduction, verification, evaluation, etc.). All reports submitted by the Air Force which contain analytical laboratory sample results shall contain a completed checklist and a QA summary.
The latest checklist is available online at http://www.dec.state.ak.us/spar/guidance.htm#csp and must be completed, signed and dated by the firm submitting the report to ADEC. It is not to be completed by the analytical laboratory that performed the sample analysis. The 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 effects on data validity and/or usability due to field sampling/laboratory quality control discrepancies.
Upon incorporation of comments regarding the checklist, ADEC will approve the work plans. |
Louis Howard |
| 5/20/2009 |
Update or Other Action |
2008 draft monitoring report received. Monitoring wells 403MW-IN and OU5KMW-03 were sampled. Samples were analyzed by an analytical laboratory for DRO and VOCs. According to the analytical results, TCE concentrations in both monitoring wells were above the cleanup level. DRO concentrations were below cleanup levels in both wells. Once groundwater contaminant concentrations are below cleanup levels, soil samples should be collected to determine if all vadose zone soil has been remediated. Once all groundwater and vadose zone soil contaminant concentrations are below cleanup levels, this site should be considered for “Cleanup Complete” status. |
Louis Howard |
| 5/28/2009 |
Update or Other Action |
Draft 2008 Annual Report, Compliance Program Elmendorf AFB May 11, 2009 reviewed and commented on by staff. 5.3 ST403 Conclusions and Recommendations Page 5-4: ADEC concurs with the recommendations to sample annually for DRO and VOCs from wells 403MW-IN and OU5KMW-03. Finally, ADEC also agrees Elmendorf should strive to avoid redundancies in management of this site and others like it, when its Compliance Program and Restoration Program are conducting like work in the same vicinity (i.e. Kenney A venue Plume and ST403). |
Louis Howard |
| 4/15/2010 |
Update or Other Action |
2009 Annual Report for monitoring of Compliance Program sites received. Elmendorf AFB site ST403 is located southwest of Building 4314, Hazardous Storage, on Kenney Avenue. This site is on the south side of the East/West Runway. The site includes one regulated 500-gallon waste oil tank that received waste oil from an OWS located inside Building 4314 and one former unregulated 2,600-gallon heating oil tank that was taken out of service around 1993.
ST403 2009 FIELD ACTIVITIES AND RESULTS
Monitoring wells 403MW-IN and OU5KMW-03 were sampled using the approved procedures provided in the 2008 Final Work Plan (USAF, 2008b). Samples were analyzed by an analytical laboratory for DRO and VOCs. TCE concentrations in both monitoring wells were once again above their cleanup level. DRO concentrations were below the method detection limits (MDLs) in both wells. DRO and TCE concentrations in soil exceeded the cleanup levels at ST403 in 2006.
Groundwater in both the in-source well and downgradient well continued to have concentrations
of TCE above the cleanup level in 2009.
This site is located within the Kenney Avenue Plume, which is monitored by the Elmendorf Restoration Program. In order to avoid redundancies, management of this site needs to be resolved between the Elmendorf Compliance and Restoration programs. Until that occurs, annual monitoring for DRO and VOCs from wells 403MW-IN and OU5KMW-03 should continue. Once groundwater contaminant concentrations are below cleanup levels, soil samples should be collected to determine if all vadose zone soil has been remediated. Once all groundwater and vadose zone soil contaminant concentrations are below cleanup levels, this site should be considered for “Cleanup Complete” status.
|
Louis Howard |
| 5/7/2010 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the 2009 Annual Report Monitoring of Compliance Program Sites.
5.2 ST403 Conclusions and Recommendations Page 5-4
ADEC concurs with the recommendations to continue groundwater sampling for diesel range organics (DRO) at 403MW-IN and OU5KMW-03. Volatile organic compounds (VOCs) may be not be dropped from the monitoring program. The Restoration program only reports ROD or decision document contaminants of concern under CERCLA for specific chlorinated solvents and not their daughter or breakdown products regardless if there is a State of Alaska cleanup level. ADEC will continue to require the analyses and reporting of all VOCs which exceed cleanup levels in both groundwater wells for ST403.
|
Louis Howard |
| 5/19/2011 |
Update or Other Action |
Wing Instruction 32-7003 dated May 19, 2011 Land Use Control Management. OPR: 673 CES/CEANR Certified by: 673 CEG/CC (Col Russell R. Hula). This instruction implements AFPD 32-70, Environmental Quality, & is used in conjunction with AFIs 32-7020, The ERP, 32-7066, Environmental Baseline Surveys in Real Estate Transactions, & 673ABWI 32-1007, Safeguarding Utilities From Damage. It prescribes the processes & responsibilities for the management of & compliance with land use controls on Joint Base Elmendorf-Richardson (JBER) & applies to all military & civilian organizations that occupy facilities, or conduct business, on the installation. This publication does not apply to the USAF Reserve or Air NG units & members. The current land use control areas can be found on the Environmental Restoration map located on the GeoBase webpage.
General:
1.1. Land use controls (LUC), such as limitations on access, water use, excavations, & property transfers, will supplement engineering controls as appropriate for short-term & long-term mgt to prevent or limit human & environmental exposure to hazardous substances, pollutants, or contaminants.
Examples include limitations on the depth & location of excavations, prohibition of or restrictions on well drilling & use of GW, mgt. of excavated soils, & prohibition of certain land uses. LUCs, often used interchangeably with (ICs), are administrative, procedural, engineering, & regulatory measures to control human access to & use of property.
1.2. LUCs were established at JBER to prevent exposure to contaminated soil & water, based on agreements between the military services & the EPA & the ADEC. LUCs are used to reduce the potential for exposure to hazardous substances or to enhance the protectiveness of a soil &/or water cleanup remedy. They include restrictions on the use of portions of the shallow aquifer south of the Elmendorf Moraine, limitations on the types of buildings allowed in certain areas – primarily occupancy limitations, & land use designations for certain areas as recreational use only.
The LUCs have been implemented at several sites & operable units (OU) as part of the ERP. LUCs were established for DP98 & OUs 1, 2, 4, 5, & 6 on former Elmendorf AFB property in their respective records of decision (ROD), as a component of the selected cleanup remedy. LUCs were also established for restoration & compliance sites formerly part of Fort Richardson in their respective RODs or Decision Documents. LUCs must be in place as long as a property is not available for UU or UE & may include temporary or permanent restrictions or requirements. When all cleanup goals have been achieved for a given site, temporary controls, such as GW use restrictions, may be removed.
2. Responsibilities:
2.1. JBER personnel, tenants, or contractors whose projects or activities require excavation in areas where site-specific LUCs are in effect will comply with all LUCs, 673ABWI 32-1007, & applicable AF instructions. Base contractors & tenant organizations will have LUC compliance requirements incorporated into their contracts & interagency agreements, as will be necessary. Failure to comply with LUCs will be grounds for penalty, in accordance with provisions specified in applicable contract documents. At project completion, the JBER organization or contractor will sign a certification of LUC compliance & return the compliance statement to 673 CES/CEANR.
2.2. The 673d Civil Engineer Squadron (673 CES):
2.2.1. Asset Management Flight (673 CES/CEA):
2.2.1.1. Natural Resources Management (673 CES/CEAN):
2.2.1.1.1. Environmental Restoration (673 CES/CEANR):
2.2.1.1.1.1. Will provide GW & site-specific LUC requirements throughout the installation & identify any known soil contaminated sites & monitoring wells for the area of the proposed project.
2.2.1.1.1.2. Will conduct annual site visits to ensure compliance with LUCs during project implementation.
2.2.1.1.1.3. Will conduct 5-year reviews, at 5-year intervals, or as required by any subsequent RODs.
2.2.1.1.1.4. Will prepare annual LUC compliance reports & submit reports to ADEC & USEPA by 1 February each year.
2.2.1.1.1.5. Will disseminate LUC information to personnel involved in LUC mgt, including real property & 673 CES/CEPT for inclusion into GeoBase.
2.2.1.1.1.6. Will operate an active educational program that includes disseminating updated fact sheets & LUC information, providing notices through the installation intranet & the Arctic Warrior newspaper, & by briefing LUC mgt at project kick-off meetings; Environmental, Safety & Occupational Health Council meetings, & CEB meetings.
2.2.1.1.1.7. Will coordinate any changes in the base general plan (BGP), or real estate transactions, with USEPA & ADEC.
2.2.1.1.1.8. Will maintain copies of signed certificates of compliance, indicating requestor’s adherence to LUCs during project execution.
See site file for additional information.
|
Louis Howard |
| 10/31/2011 |
Update or Other Action |
ST37 TCE Plume & Source Area Investigation Report received. Data collected in support of the treatability study determined that 1) well 403WL-01 is the location of the highest concentration (35 µg/L), & 2) elevated TCE concentrations (10.7 µg/L) were present at sampling location DP-1, located in the outside storage area of the former Hazardous Storage Depot (Building 4314). An unidentified source area near Building 4313 is a likely source of TCE contamination for the eastern lobe of the Western ST37 Plume. The eastern lobe of the Western ST37 Plume corresponds to the former Kenney Avenue Plume.
In 2010, discrete GW samples collected at locations KA01 & KA02 confirmed historical data that indicate the source of contamination for the former Kenney Avenue Plume is west of Kenney Avenue & south of Building 5326. The low TCE concentrations at well OU5MW-03 (2.9/3.8 µg/L) indicate there is no significant source of TCE west of Building 5326. These data confirm the findings from the Kenney Avenue Plume treatability study (USAF, 2009c) that the source area for the former Kenney Avenue Plume is likely associated with activities in & around Building 4314.
Given the depth to GW (10 to 40 feet bgs) & overall depth of contamination (up to 55 feet bgs), in situ treatment of contaminated GW by injection of chemicals that degrade TCE using chemical oxidation processes or enhanced anaerobic/reductive treatment processes may have the highest potential for success. The challenges for an in situ treatment approach include
1) dilute & diffuse contaminant sources that may require relatively large injection volumes & intervals,
2) relatively cold GW temperatures that slow the chemical reaction & biological metabolism rates, &
3) high advective GW transport that makes it difficult to maintain a desired treatment environment over time. If significant contamination is found in the shallow vadose zone during future evaluations, use of excavation-based technologies, such as source excavation with off-site disposal, bioreactors, &/or biowalls, or soil vapor treatment strategies may be a viable treatment approach to supplement or use in lieu of in situ treatment using injectable compounds.
See site file for additional information. |
Louis Howard |
| 4/26/2012 |
Update or Other Action |
Draft 2011 Annual Report received.
Monitoring wells 403MW-IN and OU5KMW-03 were sampled using the approved procedures provided in the 2011 Work Plan (USAF, 2011f). Samples were analyzed by an analytical laboratory for GRO, DRO, RRO, and VOCs. The concentration of TCE once again exceeded the cleanup level in the sample collected from well 403MW-IN. TCE in well OU5KMW-03 was below the cleanup level. Concentrations of GRO, DRO, and RRO were non-detect or below their respective cleanup levels in both samples.
DRO and TCE concentrations in soil exceeded the cleanup levels at ST403 in 2006. In 2011, groundwater in the in-source well 403MW-IN continued to have concentrations of TCE above the cleanup level. The sample collected from downgradient well OU5KMW-03 had concentration of TCE below the cleanup level in 2011 for the first time since 2007.
This site is located within the Kenney Avenue Plume, which is monitored by the Elmendorf Restoration Program. Formal transfer of monitoring wells 403MW-IN and OU5KMW-03 from the CRP to the Restoration Program and ST403 site closure is anticipated to occur in 2012. |
Louis Howard |
| 5/9/2012 |
Update or Other Action |
Draft Site Closure Sampling Work Plan received.
2012 Site Closure Sampling Activities
Soil samples will be collected using direct push technology to the soil/groundwater interface at approximately 38 feet bgs at two locations. Groundwater cleanup requirements have been met, and no further groundwater sampling is required to support site closure. Three soil samples will be collected from each boring at the depths with the highest historic contaminant concentrations and/or based on the highest PID readings. The locations for collecting samples at the site are as follows:
• Near the corner of Building 4314 southwest of the OWS location and within the approximate 1994 spill location, where the highest concentrations of DRO (12,000 and 4,860 mg/kg) were previously detected at 25 and 31 feet bgs, respectively
• Within the center of the former 2,600-gallon UST excavation, where the second-highest concentration of DRO (5,900 mg/kg) was previously detected at 7 feet bgs
Each soil sample collected for laboratory analysis will be analyzed for DRO, GRO, RRO, and VOCs. The sample collected from the interval with the highest PID reading will also be analyzed for PAHs. Specific sampling information (i.e., number of investigative samples, number of quality assurance samples, etc.) is presented in the attached QAPP worksheets.
Six samples from 3 dep;ths to be determined 0 to 38 ft. bgs. 6 investigative samples and 1 field duplicate sample (which will also serve as the MS/MSD sample)= 7 samples total. |
Louis Howard |
| 6/4/2012 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Site Closure Sampling Work Plan for ST403, ST510, ST526 & SS704.
QAPP WS#1 Qualified Person
ADEC requests JBER identify the “qualified person (s) ” involved in this project (i.e. field samplers or person that will directly supervise the personnel in the field conducting the sampling) ADEC will require the final version of the work plan to include the following:
A cover Page with the
* Name and signature of the “qualified person” responsible for collecting samples.
* Name and signature of the “qualified person” responsible for interpreting the data.
* Name and signature of the “qualified person” responsible for reporting the data.
* DEC file number and Contaminated Sites Database Hazard ID as follows: ST403 (file# 2101.38.031 CS DB Hazard ID 23063), ST510 (file# 2101.26.056 CS DB Hazard ID 23046), ST526 (file# 2101.26.015 CS DB Hazard ID 23405), and SS704 (file# 2101.38.049 CS DB Hazard ID 2784).
Resume’
Please provide a copy of the resume’ in an appendix or new section for each “qualified person” involved in this project that demonstrates that they meet the regulatory requirements of 18 AAC 75.990 (100).
Conceptual Site Model
ADEC requests a preliminary conceptual site model be included with the next revision of this work plan for each of the sites. If it is too late at this stage, then ADEC requests a CSM be developed and included in the draft report. For more information on conceptual site model requirements see: ADEC’s “Policy on Developing Conceptual Site Models” (October 2010) found at http://dec.alaska.gov/spar/guidance.htm under the Project Scoping Section as well as the scoping form or the graphic form.
Site Description and Release History
The sample location with 5,900 mg/kg diesel range organics (DRO) was collected three feet from the west end of the excavation under the tank (Sampling Record Tank 229 Page 10). ADEC requests JBER revise the text for this sample’s location to state this instead of “…near the center of the excavation.”
Response Action History
The text states: “DRO concentrations exceeded the ADEC cleanup level in two samples collected at 31feet and 36 feet bgs (12,000 and 4,860 mg/kg, respectively) from one boring located at the 1994 spill area…” Actually the result from a duplicate sample (403WL03S031.0N DUP) collected from 31 ft. bgs was 15,300 mg/kg for DRO. In accordance with ADEC’s Technical Memorandum “Guidelines for Data Reporting, Data Reduction, and Treatment of Non-detect values” August 12, 2008, ADEC regulates based on the maximum result or statistically valid 95% upper confidence limit (UCL) per 18 AAC 75.380(c)(1).
Therefore, ADEC requires that the most conservative detectable sample result of the primary and duplicate results be used for management decision making purposes. ADEC requests JBER use the 15,300 mg/kg DRO result and not the 12,000 mg/kg sample result. |
Louis Howard |
| 6/19/2012 |
Document, Report, or Work plan Review - other |
Staff reviewed and accepted responses to ADEC comments and the document may be finalized. |
Louis Howard |
| 11/13/2012 |
Update or Other Action |
Environmental Restoration Program Draft Final Site Closure Report for ST403 received.
were completed because the samples collected from soil boring ST403-101 during the first event
did not reach the analytical laboratory within the required holding time for the requested
analyses. As such, a second sampling event was completed to recollect samples from soil boring
ST403-01. One in-source boring (ST403-101) was completed to 34 feet bgs near the Former
UST 209 and release area and one soil boring (ST403-100) was completed to 35 feet bgs near
Former UST 229. Three soil samples were collected from each boring and analyzed for GRO, DRO, RRO, and VOCs. The sample collected from the interval with the highest photoionization detector reading in each boring was also analyzed for PAHs.
Maximum contaminant concentrations were 4 mg/kg GRO, 390 mg/kg DRO, and 0.031 mg/kg
TCE. Various PAHs were also detected. DRO and TCE concentrations exceeded their ADEC
18 AAC 75.341 Method Two, Tables B1 and B2, Under 40-Inch Zone, Migration to
Groundwater cleanup levels. All other concentrations were below ADEC 18 AAC 75.341
Method Two, Tables B1 and B2 Under 40-Inch Zone, Migration to Groundwater cleanup levels.
Due to the remaining smear zone soil contamination, excavation/soil movement and groundwater
use restrictions will remain in place at the site, and the use of the shallow aquifer for any purpose is not allowed. As long as hazardous substances remain at levels that preclude unrestricted use, groundwater development and the use of groundwater for any purpose including but not limited to drinking, irrigation, fire control, dust control, or any activity is prohibited in the shallow aquifer south of the Elmendorf Moraine.
Remaining residual contamination in the vadose zone is below regulatory standards, and
remaining groundwater contamination is addressed and monitored. Site closure with institutional
controls is appropriate and protective of human health and the environment.
In accordance with State of Alaska regulation 18 AAC 75, the USAF has completed cleanup
activities at ST403, JBER-Elmendorf.
Analytical results indicate vadose soil contamination levels are below ADEC 18 AAC 75.341
Method Two, Tables B1 and B2 Under 40-Inch Zone, Migration to Groundwater cleanup levels.
DRO and TCE contamination remains in smear zone soils above the ADEC 18 AAC 75.341 Method Two, Tables B1 and B2 Under 40-Inch Zone, Migration to Groundwater cleanup levels. TCE in groundwater is above the ADEC 18 AAC 75.345 Table C cleanup level. Groundwater contamination is addressed and monitored. Excavation/soil movement and groundwater use restrictions will remain in place at the site.
ADEC’s review and concurrence on the request for Cleanup Complete with Institutional Controls status is required in accordance with State of Alaska environmental conservation laws and regulations. While ADEC may comment on other state and federal laws and regulations, ADEC’s concurrence on the site closure does not relieve the USAF or its consultants, contractors, subcontractors, or USAF civilian personnel from the need to comply with other applicable state and federal laws and regulations.
The site has been adequately characterized under 18 AAC 75.335 and has achieved the applicable requirements under the site cleanup rules. Cleanup at the site is complete, subject to a future ADEC determination that the cleanup is not protective of human health, safety, or welfare, or of the environment. ADEC will, as necessary to ensure protection of human health, safety, and welfare, or of the environment, require the USAF to conduct additional actions that meet the requirements of 18 AAC 75 Contaminated Site regulations and Alaska Statute 46.03 – 46.09. |
Louis Howard |
| 12/8/2012 |
Update or Other Action |
In accordance with State of Alaska regulation 18 AAC 75, the USAF has completed cleanup activities at ST403, JEER-Elmendorf.
Analytical results indicate vadose soil contamination levels are below ADEC 18 AAC 75.341 Method Two, Tables B 1 & B2 Under 40-Inch Zone, Migration to Groundwater (GW) cleanup levels. DRO & TCE contamination remains in smear zone soils above the ADEC 18 AAC 75 .341 Method Two, Tables B1 & B2 Under 40-Inch Zone, Migration to GW cleanup levels. TCE in GW is above the ADEC 18 AAC 75.345 Table C cleanup level. GW contamination is addressed & monitored. Excavation/soil movement & groundwater use restrictions will remain in place at the site.
ADEC's review & concurrence on the request for Cleanup Complete with Institutional Controls status is required in accordance with State of Alaska environmental conservation laws & regulations. While ADEC may comment on other state & federal laws & regulations, ADEC's concurrence on the site closure does not relieve the USAF or its consultants, contractors, subcontractors, or USAF civilian personnel from the need to comply with other applicable state & federal laws & regulations.
The site has been adequately characterized under 18 AAC 75.335 & has achieved the applicable requirements under the site cleanup rules. Cleanup at the site is complete, subject to a future ADEC determination that the cleanup is not protective of human health, safety, or welfare, or of the environment. ADEC will, as necessary to ensure protection of human health, safety, & welfare, or of the environment, require the USAF to conduct additional actions that meet the requirements of 18 AAC 75 Contaminated Site regulations & Alaska Statute 46.03-46.09
Signed by AF (G. Fink) & ADEC (L. Howard)
See site file for additional information. |
Louis Howard |
| 6/17/2013 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 75972 name: ST403/75 AFID 209 |
Louis Howard |
| 7/31/2015 |
Update or Other Action |
Staff received a letter work plan for review and comment addressing potential soil vapor intrusion associated with volatile organic compounds groundwater contamination and total petroleum hydrocarbon groundwater contamination. This work plan is intended to describe the overall project implementation plan and methodologies to be used to complete the initial screening and building survey tasks. Field data collection activities associated with soil vapor and ambient air will be addressed in a separate Uniform Federal Policy - Quality Assurance Project Plan (UFP-QAPP) that will be developed prior to the start of field sampling.
The VI Study will include the initial screening and on-site survey of 96 buildings at JBER. Field sampling of sub-slab soil vapor, near-slab soil vapor, and indoor/outdoor air will be conducted for 30 of these buildings. Field sampling results will be used to complete a VI risk assessment and VI Study Report.
See site file for additional information. |
Louis Howard |
| 8/13/2015 |
Document, Report, or Work plan Review - other |
Staff commented on the draft Vapor Intrusion Letter Work Plan for JBER-E and JBER-R Sites dated July 10, 2015.
Main comments were on clarifying what was being screened for during this project, specify current EPA and ADEC vapor intrusion guidance in the document when referenced, and to develop a priority list of buildings after the building surveys are completed.
See site file for additional information. |
Louis Howard |
| 12/10/2015 |
Meeting or Teleconference Held |
Meeting with JBER, ADEC, EPA and contractor to discuss building survey results and draft building of interest (BOI) list.
EPA Comments; the buildings listed were not completely ground truthed against the LOE matrix. I think we want to evaluate all buildings for VI potential, and then narrow the top 30 based on the AF contract limitations but not constrain the priority list.
I’m sure HGL will be providing the basis for the buildings chosen (and those not chosen)
I did a very cursory review today and have a list of buildings to address because they
1) sit over VOC plumes and aren’t evaluated (example, building 18216 for site DP98, map page 2) ;
2) are outside the VOC buffer but make the sampling list (example building 16430, helicopter maintenance, map page 6);
3) Building 12743 (map page 11) and 8549 (map page 10) are rated high priority but don’t make the sampling list.
Additional thoughts:
FT023 : Buildings 18522, 17520 not BOI
LF059: what about building to north if plume emanates from OU1 Landfill to N/NE?
SD025 building outside VOC buffer but BOI (16430)
SD029: 16673 is not a BOI and is in buffer zone; 16716 is BOI and outside buffer zone
ST037N: 7 BOI listed and approximately 20 buildings not BOI (especially the 626x series)
ST037/SS22S: 3 BOI: 8574 BOI but not in VOC buffer or plume; 7508 and 8565 are in buffer not BOI
SS22N: 11735 in plume not BOI: 12755 BOI in buffer
ST048-ST068: 11551 BOI and not in plume or buffer; 11575 on buffer line and not BOI
DA089: Buildings 732, 730, 728 all in plume and VI path potential but not BOIs |
Louis Howard |
| 12/23/2015 |
Update or Other Action |
JBER Key changes made per discussions during last week's meeting/telecom:
* Elevated the VI Pathway floor penetration priorities to include sump/OWS/floor drain (high priority) and seam/crack/conduit (medium priority)
* Elevated the VI Pathway floor level priorities to include crawlspace/skirted trailer as high priority
* Revised Site DP098 to remove Building 18216 and to show only Building 18220 as the single large primary facility
* Confirmed presence of a crawlspace beneath a portion of Building 7535 (Kenai Dining Hall) via the design drawings
* Revised the overall BOI Priorities and BOI List selections and associated rationale
* Added color highlights within subcategories to indicate the priority driver(s) for each
The overall changes to the pathway priorities significantly changed the number of potential "high" priority buildings.
I believe this will be consistent with the revisions requested by the regulators.
Also note this version is reformatted to streamline the overall table for eventual inclusion in the UFP-QAPP.
All of the "X"s are gone, many of the detail columns are combined, and footnotes are included to explain the abbreviations.
Also reviewed an email from Sandra (EPA) that Donna forwarded last week regarding her comments on the previous BOI List.
Most of Sandra's comments were related to the exclusion of numerous buildings located within groundwater plume boundaries from the BOI List.
In general, the building location relative to a groundwater plume is only a supporting criterion for BOI List selection.
This is due to the large number of buildings located within plume boundaries (especially ST037) and our need to limit the sampling program to 30 BOIs.
There is no way we can include all of the buildings located within plume boundaries in the sampling program, so other criteria drive the selection. |
Louis Howard |
| 1/4/2016 |
Document, Report, or Work plan Review - other |
ADEC comments on the revised buildings of interest (BOI) list.
Text: " In general, the building location relative to a groundwater plume is only a supporting criterion for BOI List selection. This is due to the large number of buildings located within plume boundaries (especially ST037) and our need to limit the sampling program to 30 BOIs [funding $$]. There is no way we can include all of the buildings located within plume boundaries in the sampling program, so other criteria drive the selection."
ADEC: If there is a limited number of BOIs (e.g. 1 - 3) in a plume boundary area with several buildings in that plume boundary (e.g. ST037) that were not sampled (for whatever reason); AND the results show there is a risk from vapor intrusion; will AFCEC assume that all buildings (within the same plume boundary) are at risk from vapor intrusion and take some type of additional action since you chose not or could not sample all the buildings "potentially at risk" within the specific plume boundary?
If not, then what is the plan of action at the remaining buildings which were not sampled where VI risk is demonstrated by the limited number of "representative" building(s) being sampled? The Letter Work Plan is silent on this matter. I assume it will be addressed in the UFP-QAPP work plan. |
Louis Howard |
| 1/5/2016 |
Document, Report, or Work plan Review - other |
LUC Inspection report commented on by staff. If well 403MW-IN cannot be located, then ADEC s h all require that it be replaced with a new well using similar construction , installation depth , and screened interval as soon as possible. Well 403MW-IN is used for monitoring natural
attenuation of trichloroethylene (and any daughter products) in groundwater at ST403 |
Louis Howard |
| 4/4/2016 |
Institutional Control Update |
Land Use Control Inspection Report At State-Regulated Sites With ‘Cleanup Complete - Institutional Control’ Status Joint Base Elmendorf-Richardson, Alaska received.
Site CG551/SO550 (ST403) was inspected on 20 October 2015. No deficiencies were noted, however well 403MW-IN could not be located during the inspection. |
Louis Howard |
| 4/11/2016 |
Document, Report, or Work plan Review - other |
Staff commented on the UFP-QAPP WP for PFC investigation at JBER-E and JBER-R. Main comments were regarding application of ADEC proposed cleanup levels (expected in fall/winter 2016) for PFOS and PFOA. WS#10 is especially vague: “Based on the above, the best available screening criteria for PFOA and PFOS releases are the EPA PHAs for groundwater and RSSLs for soil. Because ADEC has proposed lower concentration limits that are in the public comment process, the ADEC levels should also be considered.”
It states that ADEC levels should also be considered, however in WS #11, it states the concentrations of PFOA and PFOS in soil and groundwater will be compared to project screening levels based on the most conservative risk based EPA or ADEC values.
For determining presence or absence of PFOS and PFOA using solely risk based screening levels is not acceptable to ADEC. If the migration to groundwater cleanup level is adopted by ADEC and it exceeds for PFOS or PFOA, a release is confirmed and it is deemed to be contaminated by ADEC. 18 AAC 75.990 Definitions. (23) “contaminated soil” means soil containing a concentration of a hazardous substance that exceeds the applicable cleanup level determined under the site cleanup rules.
If AFCEC chooses to proceed with risk based values (as it is apparent upon review of Table 10-2 Steps 2, 4, & 5), then ADEC reserves the right to require further investigation/cleanup under 18 AAC 75 for all areas of concern/source areas where AFCEC determined no addition action was necessary at an area of concern/source area, but the PFC levels detected exceed migration to groundwater cleanup levels for PFCs.
ADEC no longer recommends the outdated 2009 Draft Multi-Increment Soil Sampling Guidance (March 2009). Instead refer to ITRC Incremental Sampling Methodology Technical and Regulatory Guidance document (February 2012) or US Army Corps of Engineers, Environmental Quality Interim Guidance 09-02 “Implementation of Incremental Sampling (IS) of Soil for the Military Munitions Response Program.
Delete reference to ADEC 2009 Guidance on MI Soil Sampling.
See site file for additional information. |
Louis Howard |
| 5/4/2016 |
Document, Report, or Work plan Review - other |
Staff provided comments on the VI UFP-QAPP.
ADEC and EPA will be the judge of the significance of any changes to the approved UFP-QAPP not JBER and whether or not they require agency approval prior to being implemented. The VI Study for JBER-R has only five buildings associated with two source areas (DA089 and TU064) that will be assessed despite the fact that there are likely more sites with volatile compounds present in either soil or groundwater or both media which were investigated under the PBR contract (SS019 Bldg. 755 ), POL two-party agreement and CERCLA which need to be assessed for vapor intrusion. Please provide ADEC a copy of the list of buildings/sites where were not evaluated or included in the current VI BOI list.
ADEC requests clarification in the text on whether the inability to collect PID readings in some buildings inhibit their inclusion as a BOI? PID screening results in buildings were utilized to create the BOI list; thus the inability to field screen in a building may reduce the chance these buildings would be included in the BOI list. If PID readings were not measured in a building then the building should be assumed to have a positive PID headspace readings as a conservative measure.
If there is VI exposure at a particular BOI category which demonstrates unacceptable risk , ADEC expects AFCEC to investigate all other similar BOIs potentially impacted by VI exposure which were no listed in the original 30 BOIs identified for this study.
ADEC recommends that the composite indoor air samples not be limited to 24 hour intervals. Site conditions may be present such that indoor air composite samples greater than 24 hours (e.g. two weeks) be collected particularly if there is a weather event in which the barometric pressure changed significantly. Additionally, if the during the first event there is significant variation between indoor sample results within a building, collection of samples over a longer time frame may reduce some of the sample results variability.
See site file for additional information. |
Louis Howard |
| 9/16/2016 |
Update or Other Action |
Supplemental WP received to address the groundwater sampling, institutional controls (IC) inspection, and landfill cap inspection activities associated with the 2016 Long Term Monitoring (LTM) at the Joint Base Elmendorf-Richardson (JBER), Sites PL081, CG551, ST408, CG530, SO510, SS522, SO507, SS418, TS003, CG543, CG529, TU107, ST048, CG509, SO508, SO549, AT035, AT029, SS019, and DP009.
As a requirement of the 2016 Environmental Long Term Monitoring contract, the following work shall be performed at JBER Site ST408:
? Perform IC inspection |
Louis Howard |
| 10/4/2016 |
Document, Report, or Work plan Review - other |
Staff reviewed the VI Studies work plan. Main comments were regarding the consequences of proceeding with the work detailed in the work plan prior to ADEC approving it. Staff requested clarification on how a 2006 exceedance of GRO above the maximum allowable level can be a basis for closing out the site with an IC inspection and still be protective of human health and the environment. Staff requested additional detail be presented with regards to any subsequent removal/remedial action that occurred at PL81. Staff requested correspondence demonstrating EPA concurrence with transfer of PL81 valve pit 11 groundwater contamination into Operable Unit 6. Finally, staff requested additional information regarding the sampling of seeps immediately down gradient of PL081 which had exceedances of benzene and total aromatic hydrocarbons.
See site file for additional information. |
Louis Howard |
| 2/23/2017 |
Update or Other Action |
Draft GW sampling report for 1,4-Dioxane received for review and comment.
See site file for additional information. |
Louis Howard |
| 3/16/2017 |
Document, Report, or Work plan Review - other |
Main comments on the GW monitoring report for 1,4-Dioxane is that JBER-E results and JBER-R results will need to be addressed in a cumulative risk review where it exceeds 1/10th the cleanup level of 4.6 ug/L. Staff requested ADEC Data Review checklists be completed for each lab data package.
See site file for additional information. |
Louis Howard |
| 3/22/2017 |
Update or Other Action |
Draft Report for Remedial Action Operation and Land Use/Institutional Control at JBER for review and comment.
The USAF Site Closure Report for CG551 (2012a) indicates that due to the remaining smear
zone soil contamination, excavation/soil movement and groundwater use restrictions will remain
in place at the site, and the use of the shallow aquifer for any purpose is not allowed. As long
as hazardous substances remain at concentrations that preclude unrestricted use, groundwater
development and the use of groundwater for any purpose including but not limited to drinking,
irrigation, fire control, dust control, or any activity is prohibited in the shallow aquifer south of the Elmendorf Moraine.
The inspection of Site CG551 revealed no evidence of ground disturbance at this site. Revegetation
appeared to be occurring at the site and the monitoring wells located at the site were observed to be in good condition. Warning signs alerting visitors to the active onsite fuel shed appeared to be in good condition and no erosion was observed along the access roads. Photographs 1 through 8 in Photograph Log A2 present the general condition of Site CG551.
The USAF Site Closure Report for CG551 (2012a) indicates that the remaining residual contamination in the vadose zone is below regulatory standards, and the remaining groundwater contamination is addressed through the LTM program. Site closure for CG551 with institutional controls was deemed appropriate and protective of human health and the environment by the USAF and ADEC.
See site file for additional information. |
Louis Howard |
| 11/30/2017 |
Update or Other Action |
Draft VI report received for review and comment. Indoor and outdoor air TCE detections during FSE2 indicate similar concentrations. The TCE soil gas detections were both located in the paint shop portion of the building. No spatial bias between indoor air or soil gas results is apparent. The results suggest the potential presence of a complete VI pathway, especially in the paint shop portion of the facility. Based on the above lines of evidence, the VI pathway is considered potentially complete at Building 4314.
See site file for additional information.
|
Louis Howard |
| 1/26/2018 |
Document, Report, or Work plan Review - other |
Staff reviewed the Weldin Construction SABER Trailer TCE sampling results of soil gas/indoor air. The detection limits are above ADEC's VI Guidance for Contaminated Sites Target Levels for Indoor Air and ATSDR Inhalation Minimal Risk Levels and the TO15-SIM DL/LOQ. Bottom line, we need resampling done by either JBER or WELDIN with an approved letter work plan outlining the number of samples (plus required QA/QC samples), the locations being sampled, methods, sampling containers, laboratory used and their LODs/LOQs, sampling staff. It does not have be a large document and they (the contractor) can follow HGLs approved work plan and SOPs to the letter and reference them in their work plan for review and approval by EPA and ADEC prior to resampling.
Please use the laboratory methods originally conducted as part of HGL's VI study on JBER to compare comparable methods and results and sampling by a an impartial third party who meets the Qualified Environmental Professional requirements as defined by 18 AAC 75.333(b) in the same manner and locations (at a minimum, more locations would not be discouraged), duration as found in the HGL document (e.g. Figure 11.33 Site ST037 South Building 4230-Sampling Location and Results). |
Louis Howard |
| 11/1/2018 |
Update or Other Action |
Final vapor intrusion (VI) report received. Of the 30 buildings of interest evaluated, 10 at JBER-E and 3 at JBER-R have a complete VI pathway, 11 at JBER-E and 1 at JBER-R have a potentially complete VI pathway and 4 at JBER-E and 1 and JBER-R have an incomplete VI pathway.
See site file for additional information. |
Louis Howard |
| 4/12/2021 |
Document, Report, or Work plan Review - other |
DEC submitted comments on Draft JBER Basewide UFP-QAPP dated February 2021. |
William Schmaltz |
| 5/19/2021 |
Document, Report, or Work plan Review - other |
DEC Reviewed and approved of Basewide Uniform Federal Policy - Quality Assurance Project Plan. QAPP summarizes general activities for a 5 year period on JBER. |
William Schmaltz |
