| Action Date |
Action |
Description |
DEC Staff |
| 1/20/1994 |
Enforcement Agreement or Order |
Janice Adair Regional Administrator Southcentral Regional Office signs the November 29, 1993 Underground Storage Tank Agreement. The Parties enter this Agreement to perform necessary inventory, registration, upgrading or closure, and tightness testing associated with USTs at Elmendorf. All draft final work plans for field work must be submitted to ADEC a minimum of 30 days prior to the start of field work or construction. Site Assessment draft reports for closures must be submitted to ADEC within 60 days after completion of field work.
All reports of confirmed leaking USTs, or the need for further investigation, will be forwarded to 3 SPTG/CEVR (or its) successor organization) for possible inclusion into the SERA*. Initial
abatement activities required under 18 AAC 78.230 will be conducted by the Air Force prior to
transfer of any site to the SERA.
*SERA=Environmental Restoration Agreement between ADEC and the Air Force dated October 1992.
Discovered USTs-All USTs discovered during the life of this Agreement will be addressed under this Agreement and will be added to Attachment A. The Air Force will notify ADEC by next day mail of any discovery within five days of the discovery of an UST, unless release notification is required under 18 AAC 78 220, in which case those provisions will control.
Installation: Any new USTs installed by the Air Force shall be installed in accordance with 40 CFR 280 and 18 AAC 78.022 through 18 AAC 78.090 and will have leak detection, corrosion protectlon, overfill protectIon, and spill protection. The Air Force will notify ADEC at least 30 days prior to initiating installation of an UST. UST installation work will be conducted by a certified UST worker as required by 18 AAC 78.030 and 18 AAC 78.400.
Release Detection: The Air Force shall install and perform release detection in accordance with
the schedules outlined in Attachment A. If release detection is not installed or the tank not
previously permanently closed by the date in Attachment A, the Air Force will close the tank in
accordance with the closure requirements in 18 AAC 78. All tightness testing performed to
satisfy these requirements will be conducted bv a certified UST worker as required bv 18 AAC
78.030 and 78.400
Operation and Maintenance of Corrosion Protection: The Air Force shall meet the requirements of 18 AAC 78.045 and 40 CFR 280.31 for any steel USTs, that have corrosion protection systems The testing of the corrosion protection systems shall be done by a certified UST worker as required by 18 AAC 78.400.
Site Assessment or System Tig:htness Test: The Air Force shall either conduct a system tightness test on all regulated USTs located at the Base or permanently close the USTs in accordance with Attachment A. If site assessments or system tests have been conducted, the Air Force shall submit proof of compliance by the deadlines set in Attachment A. All tightness testing work will be conducted by a certified UST worker as required by 18 AAC 78.400.
Release Investigation and Corrective Action: Release investigations, interim corrective action and corrective action on petroleum contamination identified in work conducted pursuant to this Agreement is not within the scope of this Agreement. These activities will be conducted pursuant to the Environmental Restoration Agreement between ADEC and the Air Force dated October 1992. |
Janice Adair |
| 4/21/1995 |
Update or Other Action |
Air Force Memorandum to John Halverson 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 |
| 8/11/1995 |
Update or Other Action |
ADEC (John 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 3 1, 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.
The 1994 UST tightness testing results report, dated January 1995, identified the following problems: Tank#785 at building 44-785, failed the initial tightness test. An out of use 0.5 inch diameter heating fuel line was located and removed. The system passed the next tightness test. It is not clear whether the out of use line was causing a loss of fuel to the surrounding area. Additional information is needed to make a determination on whether a release occurred at the site. |
John Halverson |
| 10/16/1995 |
Leaking Underground Storage Tank Release Confirmed - Petroleum |
LUST Site created in CSP for source area ID 76217 ADD; Site added to database. |
Louis Howard |
| 10/16/1995 |
Site Added to Database |
|
Former Staff |
| 11/29/1995 |
Underground Storage Tank Site Characterization or Assessment |
UST Decommissioning and Site assessment-AFID 785, Upper GAT/R Site. This was part of bigger project-Repair 17 Underground Storage Tanks (Emergency Generator Tanks) under contract no. F41624-94-D-8070 del. Order no. 0002.
ST 426 is a former UST site (AFID 785) that contained one 700-gallon tank used to store
diesel fuel for the emergency generator. The UST was located adjacent to Building 44-785, referred to as the Upper GATIR site. AFID 785 was removed on October 16, 1995. The details of the excavation are in the UST Decommissioning and Site Assessment-AFID 785, Upper GAT/R Site. Perched groundwater was encountered at approximately 6 feet bgs in the tank excavation
DRO results (no GRO, BTEX or PAH analyses was conducted).
785-SP-O1-Stockpile 1,400 mg/kg
785-SP-02-Stockpile 2,600 mg/kg
785-EX-03-Excavation 12,800 mg/kg
785-EX-04-Excavation 7,300 mg/kg
785-EX-05-Excavation 5,900 mg/kg
785-EX-06-Excavation 7,700 mg/kg
785-EX-07-Excavation 5,700 mg/kg
785-EX-W-08-Water Sample 880 mg/L
Diesel range organics (DRO) ranged from 1,400 mg/kg to 12,800 mg/kg. Twenty-four cubic yards of soil were removed and reused as backfill for the excavation without treatment. DRO was detected in a water sample at 880 mg/L.
Final version January 1998 states: Lab results indicated that clean closure cannot be obtained and that remediation is required at the site. The following information must be obtained prior to designing a site specific remediation program for AFID 785: Nature and extent of the water table, hydraulic gradient, direction of flow, areal extent of contamination and identification of source of free product, if present.
It is also recommended that three monitoring wells around AFID 785 be installed. |
Louis Howard |
| 4/11/1996 |
Update or Other Action |
Tim Stevens sent letter to Air Force regarding October 16, 1995 closure of UST AFID 785 at bldg. 44-785 Upper GAT/R. The Department agrees with the recommendations presented in the final site assessment report, recommending further release investigation work to define the extent of cotamination at the site. It is the Department's understanding that release investigation work is currently ongoing under SERA VII, and has been conducted under SERA IV (ST426) and VI contracts. The Department will defer making any decisions on this site until it has had an opportunity to review all the data collected under the three SERA programs. |
Tim Stevens |
| 10/17/1996 |
Institutional Control Record Established |
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 |
| 12/31/1996 |
Update or Other Action |
SERA Phase IV UST Closures Investigation Report Draft received. The UST was removed in October 1995. Piping attached to Building 44-785 was abandoned in place by crimping and taping the ends. The UST excavation measured approximately 10 feet wide by 13 feet long by 6 deep. Groundwater was encountered in the excavation at approximate'ly 6 feet bgs. The excavation was backfilled with stockpiled soil and clean fill. Seven soil samples were collected from the excavation and stockpiled soil. One water sample was collected. All the samples were analyzed for DRO. DRO concentrations in the soil ranged from 1400 mg/Kg to 12800 mg/Kg, with the highest concentration detected in the excavation. DRO was detected in the water sample at 880 mg/L. Based on these results, the UST removal site assessment detennined that a release investigation was required for the site.
In 1996, four soil borings were advanced during the SERA Phase IV investigation. One boring was converted into a monitoring well (44-785-WL-01). The borings were advanced to a maximum of 41 feet bgs and groundwater was encountered in a perched aquifer at 7 feet bgs and in a sand layer at 24 feet bgs. Two analytical soil samples were collected from each boring and analyzed for GRO, DRO, and BTEX compounds.
DRO exceeded the cleanup level in the sample from 6.5 feet bgs in the boring at the former location of the UST (8,870 mg/Kg) and GRO was detected at 230 mg/kg(J). DRO was not detected at 16.5 feet bgs in this same boring. All other compounds (GRO, BTEX) were not detected or were below cleanup levels. A perched thin confined aquifer encountered at 7 ft. bgs in 24 ft. bgs in boring 785BH03.
Recommendation is to excavate contaminated soils and ask for alternative cleanup level. Groundwater is suspected to be contaminated. A bioventing treatability study was not conducted due to the perched aquifer in the former UST location and dense silts encountered at the site with low apparent air permeabilities, dewatering the perched aquifer, re-excavate the contamination to achieve clean closure. |
Louis Howard |
| 3/25/1998 |
Leaking Underground Storage Tank Cleanup Initiated - Petroleum |
|
Former Staff |
| 6/30/1998 |
Update or Other Action |
SERA Phase IV 1997 RI findings received. Soil samples were analyzed for DRO,
GRO, RRO, BTEX, and PAHs. All were below Method 2 cleanup levels. Water samples were collected from both monitoring wells (44-785WL-01 and 44-785WL-02).
DRO concentration in well 44-785WL01 was 7.630 mg/L, exceeding 18 AAC 75 Table C cleanup level. Other compounds were not detected or were below ADEC cleanup levels (GRO BTEX).
Aquifer pump tests were conducted to determine if the localized aquifer in the proximity of 44-785WL01 could be readily dewatered. The water table aquifer was pumped at a steady rate of 0.6 gpm, the maximum rate possible without having air entering the pump.
Using AQTESOLV well analysis program and the results of the analysis (using the Theis Method) indicated the aquifer has a high transmissivity at 9.094 E-2 sq. ft. per minute, and the storativity is unusually high at 5.176E-1. Both can be assumed to be valid only for an area 6-10 ft. radius of the wellbore based on the short pumping time and the small amount of water actually withdrawn from the aquifer (about 16.8 gallons). These results indicate the aquifer cannot easily be dewatered within the radius of influence of 44-785WL01.
Data gaps: Groundwater gradient, direction and extent of impact require additional characterization through installation of at least 1 or 3 more wells. The extent of soil contamination in the immediate vicinity of the former UST location needs to be determined with greater resolution so the volume of contaminated soil can be more accurately determined.
Disposition recommendations: Continue to pursue ACLs for this site. In developing assume the groundwater flow is to the southeast and the nearest well is at least 7,360 feet downgradient from the site. Soil DRO concentrations are likely to have attenuated significantly since 1995 to the point that DRO levels are no longer greater than 10,000 mg/kg. (NOTE: no data supports this supposition by the Air Force). |
Louis Howard |
| 8/12/1998 |
Meeting or Teleconference Held |
Staff met with Barb Neary of Foothill Engineering, Pauline Schutle (AFCEE) and John Mahaffey to discuss the latest RI work being done under SERA VI. We discussed installation of monitoring wells at ST 426 (Upper Gatr). |
Louis Howard |
| 10/1/1998 |
Update or Other Action |
One soil boring was completed as a monitoring well during the SERA VI investigation in 1998. This well was installed in a downgradient location to the southwest of the site. Two soil samples and one groundwater sample were collected and analyzed for GRO, DRO, RRO, BTEX compounds, and PAHs; all results were below ADEC cleanup levels. |
Louis Howard |
| 10/13/1998 |
Document, Report, or Work plan Review - other |
RE: The October 16, 1995, closure of UST, AFID # 785, located at building 44-785 (Upper GATR) on Elmendorf AFB. Review of the site assessment reports received November 29, 1995 and January 20, 1998, prepared by ASRC Construction Company, Inc. Facility ID 0-001525, tank #238.
The Department of Environmental Conservation (ADEC) has received and reviewed both the draft and final site assessment reports documenting the closure of the above mentioned regulated underground storage tank (UST). The reports summarize the information collected during closure of the 700-gallon JP-8 UST used to supply fuel for an emergency generator.
The Department agrees with the final site assessment report recommendations that further work is required to define the extent of contamination at this site. It is the Departments understanding that release investigation work was conducted under SERA IV (ST426), VI & VII. The Department will defer making any decisions on this site until it has had an opportunity to review all the data collected under the three SERA Programs. |
Tim Stevens |
| 2/28/1999 |
Underground Storage Tank Site Characterization or Assessment |
AFID 785 SERA Phase VII ST426/7 Release Investigation Report Final Draft received. Concentrations of DRO, GRO, and BTEX compounds reported for soil samples collected from
WL03 and WL04 in 1998 did not exceed ADEC Method One Level A or Method Two cleanup standards. It should be noted that coal was observed in a number of the 1998 soil samples. Coal is detected in (approximately) the C20 to C34 range of the ORO chromatogram and, where present, will be reported in DRO results.
In 1997, the water sample from 44-785WL01 contained 7.63 mg/L DRO, which is above the ADEC groundwater cleanup standard for DRO of 1.5 mg/L. Trace amounts of GRO and ethylbenzene were also detected in 44-785WL01 in 1997. The water sample collected from 44-785WL02 that year contained 0.274 mg/L DRO.
The extent of petroleum-impacted soil at ST 426/7 appears to be limited to the immediate vicinity of the former UST excavation. In 3 years of soil sampling, only one soil sample has exceeded the ADEC Method Two cleanup standards: the sample collected from within the former UST
excavation in 1996 contained 8,870 mg/Kg DRO, in excess of the 250 mg/Kg DRO standard. Because impacted soil was placed back in the tank excavation at the time of tank removal, it is
likely that this sample represented contaminated fill. Cleanup standards for GRO and BTEX
compounds have not been exceeded in any soil sample collected in 1996, 1997, and 1998.
Measurable concentrations of DRO have been detected in groundwater samples collected from
all four monitoring wells at ST426/7 at concentrations ranging from 0.487 to 5.85 mg/L DRO.
However, only the sample collected from the well that is in the former UST footprint (WL01, 5.85
mg/L DRO) exceeded the AOEC groundwater cleanup standard for ORO (1.5 mg/L). No other
petroleum hydrocarbon COCs exceed the AOEC groundwater cleanup standards. Because
ST426/7 is not within the OU5 Model Area, dissolved-phase contaminants must be addressed
as part ofthe SERA investigation. |
Louis Howard |
| 4/30/1999 |
Update or Other Action |
Environmental Quality Program Year Two Summary Report for site evaluations and bioventing studies at SERA VI Sites. Data collected in the SERA VII investigation infers that the flow direction may be to the south or southeast, although the data could be interpreted differently. The monitoring well installed and sampled during the SERA VI program verifies that the contamination has not migrated from the site in a southwesterly direction. Until further delineation of the flow direction can be determined in the area, no further action is recommended for the newly installed well. |
Louis Howard |
| 4/30/1999 |
Update or Other Action |
Year Two Summary Report for Site Evaluations and Bioventing Studies at SERA VI Sites Draft April 1999 received. The purpose of this report is to document the results of the follow-on investigations for sites which are part of the State-Elmendorf Restoration Agreement (SERA) Phase VI (SERA VI) on Elmendorf Air Force Base (AFB). The sites initially included in the SERA
VI program in 1997 were ST 402, ST 423, ST 426, ST 506, ST 507, ST 600, and ST 601 Sites ST 423, ST 507, ST 600, and ST 601 were investigated during 1997 and the results are documented in the Year One Summary Report for Site Evaluations and Bioventing Studies at SERA VI Sites, Draft, May 1998. The results of site investigations conducted during the 1998 SERA VI field season are in this report. The 1998 investigations were conducted at ST 423, ST 426, and ST 538. Site ST 538 was originally a SERA V site that was added to the SERA VI program in 1998.
ST 426 was enrolled in the SERA program in 1996, following the removal of a 700-gallon diesel fuel UST referred to as Air Force Identification (AFID) 785. The site has been further investigated during the SERA IV, SERA VI, and SERA VII projects. In the SERA IV investigation, petroleum hydrocarbons were detected in soil and groundwater from 785-WL-01, in the immediate vicinity of the former tank. The DRO concentration detected in the groundwater sample from well 785-WL-01 exceeded the proposed ADEC groundwater standard.
In 1998, additional source investigation work occurred under the SERA VII program, while efforts to define the downgradient extent of groundwater contamination occurred under SERA VI. To achieve this goal, monitoring well WL-05 was installed and sampled during the 1998 SERA Phase VI investigation. No hydrocarbon constituents were detected in soil samples collected during well construction, and no DRO was detected in groundwater samples. The well installed and sampled during the SERA VI program was constructed in a location topographically downgradient from the former tank, and verifies that petroleum hydrocarbons have not migrated from the site in the southwest direction. No further sampling is recommended for the newly installed well. Additional source characterization efforts are occurring in the SERA VII program.
A single downgradient monitoring well, well 785·WL·05, was installed in July 1998 in SERA VI. The well location is shown on Figure 3·1. Soil and groundwater samples from the well were analyzed for petroleum hydrocarbons and PAHs. The soil boring was completed to a depth of 19 feet bgs and monitoring well 785WL·05 was successfully constructed. While drilling the well, soils were screened from each splitspoon interval using a PID and the headspace screening technique.
Soil samples for laboratory analysis were collected from the 6 to 8 foot interval and the 8 to lO foot interval. Analytical results from both samples were below detection limit for all analytes. In August 1998, a groundwater sample was collected from the new monitoring well (785·WL·05) and analyzed for BTEX, DRO, GRO, RRO, and PAHs. Laboratory analysis results were below detection limits for all analytes except RRO at 0.77 mg/l and xylene at 0.0011 mg/l. The concentrations of 0.77 mg/l RRO and 0.0011 mg/l xylene are well below the proposed ADEC groundwater cleanup standards. The RRO may have resulted from organic biomass observed in the boring, and is not believed to be related to the former diesel UST at ST 426.
Two additional wells (785·WL·03 and 785·WL·04) were constructed at ST 426 during the 1998 SERA Phase VII investigation by a separate environmental contractor. The information obtained during the SERA VII investigation was reviewed to assist in recommending a course of action for ST 426. Analytical results from soil samples collected during construction of wells 785· WL·03
and 785· WL·04 did not exceed ACM level A cleanup values or the proposed ADEC cleanup standards. Groundwater samples were collected and analyzed from the two previously existing wells and the two newly constructed wells. DRO was detected in all four wells but only the concentration detected in monitoring well 785·WL·01 exceeded the proposed ADEC groundwater cleanup standards. Prior to the 1998 field investigation, groundwater at ST 426 was believed to flow southwest, based on topography. Data collected during the SERA VII investigation resulted in a revised interpretation of the groundwater flow direction. Groundwater potentially flows to the south/southeast, not the southwest as previously estimated (USAF, 1998d). The actual
direction of groundwater flow is not conclusive with the available information, due to
the complicated nature of subsurface sediments in this area. |
Louis Howard |
| 4/7/2000 |
Document, Report, or Work plan Review - other |
ADEC request CAP for remediating the soil and groundwater contamination associated with the former UST release. Tim Stevens to Colonel Showers Elmendorf AFB. The Department has reviewed the SERA Phase VII final release investigation report for ST426/7 for bldg. 44-785. The Department is requesting an additional release investigation work to further define the extent of the diesel range organics (DRO) dissolved phase plume, and delineate the vertical extent of contaminated soil within the footprint of the former UST excavation.
Groundwater sampling of 4 on-site monitoring wells has demonstrated that groundwater located directly below the former UST is contaminated with DRO above the 1.5 mg/L cleanup level (as high as 7.63 mg/L).
The two most recent groundwater sampling events has demonstrated that the groundwater flow direction is different than what was initially noted. Therefore the department is requesting installation of monitoring wells down gradient of the UST excavation to determine the extent of the DRO contamination plume in the areas not previously investigated. With the exception of monitoring well 44-785WL01, the Air Force has not completed investigation of the vertical extent of soil contamination within the footprint of the former UST excavation. Therefore, any additional site investigative work should include soil borings within the footprint of the former UST excavation. Soil borings should be located based on the areas of highest contamination found during the site assessment. Borings should extend into the groundwater to determine how far the DRO contamination has migrated into water saturated soils. Since the former UST was located outside the OU5 basewide groundwater monitoring area, the Air Force will need to develop, as part of the corrective action plan, a plan for monitoring the contaminated ground water plume. |
Tim Stevens |
| 6/28/2001 |
Leaking Underground Storage Tank Corrective Action Underway |
Corrective Action Plan for SERA IV, V, VII and VIII sites. Although a single bioventing well was installed, a bioventing treatability test was not conducted. There are no known downgradient wells located within one mile of the site. No recommended action under this particular CAP. Site will be evaluated for corrective action or further investigation under a different project. |
Louis Howard |
| 10/21/2002 |
Update or Other Action |
J. Roberts sent a letter 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 |
| 6/29/2004 |
Conditional Closure Approved |
The Department has reviewed the documents associated with ST426 Bldg. 18877 and concurs the site will not require any further remediation or site investigation. In addition to any required groundwater monitoring, there is petroleum contaminated soil which remains at this site that requires institutional controls. The Base Master Plan needs to be updated to document the locations of residual contamination and the need to manage contaminated soil properly.
The Department is basing its decision on the most current and complete data provided by the Air Force. The Department reserves its rights, under: 18 AAC 75 Oil and Other Hazardous Substances, Pollution Control regulations, 18 AAC 78 Underground Storage Tank Regulations, and Alaska Statute 46.03 to require additional investigation, cleanup, or containment if subsequent information indicates that: 1) additional contamination remains at the site which was previously undiscovered and presents an unacceptable risk to human health, safety, or welfare, or the environment; or 2) the information provided was invalid, incomplete, or fraudulent. |
Louis Howard |
| 6/29/2004 |
Long Term Monitoring Established |
Groundwater wells 44-785WL01 and 44-785WL02 will be utilized to monitor groundwater at this site. These wells are located at ST426. Groundwater wells will be collected annually and analyzed for diesel range organics and natural attenuation parameters to determine if the plume is attenuating. |
Louis Howard |
| 2/18/2005 |
Update or Other Action |
February 18, 2005 list of sites sent which included ST426. Well IDs 44785WL-01 and 44785WL-02 will be sampled on an biannual basis for DRO. 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.
The groundwater sample collected from in-source well 44-785WL-01 in 2005 was reported with a DRO concentration that exceeded the cleanup level (2,130 µg/L). This concentration is lower than samples collected in 1997 (7,630 µg/L) and 1998 (5,850µg/L) however. A trend line for DRO concentrations in 1997, 1998 and 2005 shows that DRO is steadily decreasing. At the current rate, DRO concentrations should be below the cleanup level by 2008. |
Louis Howard |
| 6/20/2007 |
Update or Other Action |
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 sample 785WL-01 for diesel range organics (DRO). |
Louis Howard |
| 7/5/2007 |
Update or Other Action |
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 ST426 the following wells will be monitored: 44785WL-01 and 44785WL-02 for DRO.
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 |
Draft groundwater monitoring report received. Groundwater monitoring well 44-785-WL-01 was sampled and the DRO analytical result was above the cleanup level. Once DRO concentrations are below cleanup levels for two consecutive years, this site should be considered for “Cleanup Complete” status. Soil sampling is not necessary for closure because previous investigations only found contaminated soil in the smear zone at this site. |
Louis Howard |
| 4/15/2010 |
Update or Other Action |
2009 Annual Report for monitoring of compliance program sites received. Elmendorf AFB site ST426 is located on the north side of Building 18877, a communications receiver. ST426 is the former location of an unregulated 700-gallon steel UST that contained diesel fuel for an emergency generator at the building. The UST and associated piping were excavated and removed in 1995.
Groundwater monitoring well 44-785-WL-01 was sampled using the approved procedures provided in the 2008 Final Work Plan (USAF, 2008b). The DRO analytical result was above the cleanup level.
The DRO concentration from in-source well 44-785WL-01 was above the cleanup level during
2009. In-source well 44-785-WL-01 should continue to be sampled annually for DRO. Once
DRO concentrations are below cleanup levels for two consecutive years, this site should be
considered for “Cleanup Complete” status. Soil sampling is not necessary for closure because
previous investigations only found contaminated soil in the smear zone at this site. |
Louis Howard |
| 3/16/2011 |
Update or Other Action |
Draft Annual Report Monitoring of Compliance Restoration Program Sites received. Groundwater monitoring well 44-785-WL-01 was sampled. The DRO analytical result was once again above the cleanup level.
Conclusions
The DRO concentration from in-source well 44-785WL-Ol was above the cleanup level during
2010. In-source well 44-785-WL-01 should continue to be sampled annually for DRO. Once
DRO concentrations are below cleanup levels for two consecutive years, this site should be
considered for "Cleanup Complete" status. Soil sampling is not necessary for closure because
previous investigations only found contaminated soil in the smear zone at this site. |
Louis Howard |
| 4/26/2012 |
Update or Other Action |
Draft 2011 Annual report received.
Groundwater monitoring well 44-785-WL-01 was sampled using the approved procedures provided in the 2011 Work Plan (USAF, 2011f). The DRO analytical result was once again above the cleanup level.
In 1996, a soil sample collected from the smear zone of the perched aquifer at this site had DRO
concentrations exceeding the cleanup level. The DRO concentration from in-source well 44-
785WL-01 exceeded the cleanup level in 2011. No changes are being recommended to compliance monitoring at this site due to the 2012 PBC. |
Louis Howard |
| 6/22/2012 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft Project Mgt. Plan.
Table 6-3 JBER-Elmendorf
General comments
Risk mitigation: In general, vadose zone soils shall not exceed maximum allowable levels for petroleum contamination for soil from 0 – 15’ bgs (i.e. direct contact for BTEX, PAHs & ingestion for DRO, GRO, RRO) regardless of HRC calculated levels. Treatment or excavations deeper than 15’ bgs may be warranted on a site-specific basis to prevent the soil from acting as a continuing source of GW contamination.
In addition, sites with existing GW contamination above Table C cleanup levels will require that migration to GW cleanup levels be used for soil & ICs will be required. Once GW is below Table C for for a period of time (per the latest approved “Basewide Monitoring Program Well Sampling Frequency Decision Guide”), the maximum allowable levels may become the cleanup levels as determined by ADEC on a case by case basis.
7.1.2
Independent QA Oversight on Performance Based Contracts
The site cleanup rules require that “collection, interpretation, & reporting of data, & the required sampling & analysis is conducted or supervised by a qualified, impartial third party”. Depending upon the specific terms in a performance based contract, a contractor may no longer be considered an impartial third party with respect to collecting, interpreting & reporting data.
This should be taken into consideration when preparing scopes of work. ADEC strongly recommends the Air Force provide an on-site Quality Assurance Representative or a third party QA oversight contractor to monitor fieldwork for consistency with approved plans & contract requirements.
ST426 SO-C534 (CRP) Page 11-7
GW is already impacted at this site with DRO at 3.1 mg/L so the Table B1 migration to GW cleanup level for soil is applicable. Sites with GW contamination above Table C cleanup levels will not receive a “cleanup complete” designation without ICs.
ST507 CG-C539 Page 11-7
GW is already impacted at this site with GRO at 19.7 mg/L & DRO at19 mg/L so the Table B1 migration to GW cleanup levels for soil are applicable. Sites with GW contamination above Table C cleanup levels will not receive a “cleanup complete” designation without ICs.
Taxiway N PL-C15 (CRP) Page 11-9
GW is already impacted at this site with DRO at 11 mg/L so the Table B1 migration to GW cleanup level for soil is applicable. Sites with GW contamination above Table C cleanup levels will not receive a “cleanup complete” designation without ICs.
ST048 Diesel Fuel Line Leak (IRP) Page 11-14
GW is already impacted at this site with GRO at 7.2 mg/L so the Table B1 migration to GW cleanup level for soil is applicable. Sites with GW contamination above Table C cleanup levels will not receive a “cleanup complete” designation without ICs.
ST066 Leaking Underground Storage Tank – Out of Service (IRP) Page 11-15
GW is already impacted at this site with DRO at 14 mg/L so the Table B1 migration to GW cleanup level for soil is applicable. Sites with GW contamination above Table C cleanup levels will not receive a “cleanup complete” designation without ICs.
SS83 WWII Anti-Aircraft Artillery (IRP) Page 11-16
GW is already impacted at this site with DRO at 3.6 mg/L so the Table B1 migration to GW cleanup level for soil is applicable. Sites with GW contamination above Table C cleanup levels will not receive a “cleanup complete” designation without ICs.
|
Louis Howard |
| 1/11/2013 |
Update or Other Action |
Staff received the draft UFP-QAPP work plan for ST421.
This Uniform Federal Policy – Quality Assurance Project Plan (UFP-QAPP) presents the
proposed site characterization activities that will be conducted at ST421. Site characterization
activities will be conducted to delineate the extent of impacts, if any, exceeding 18 Alaska
Administrative Code (AAC) 75 soil & GW cleanup criteria for petroleum product
contaminants gasoline range organics (GRO), diesel range organics (DRO), residual range
organics (RRO), & benzene, toluene, ethylbenzene, & xylenes (BTEX).
The overall objectives for the site are to meet “unrestricted or residential site use” criteria & achieve a “cleanup complete without institutional controls (ICs)” determination. However, this may not be achieved in the next eight years. The performance objective for the work described in this work plan is to gain the information required to obtain response complete with institutional controls for this site. To meet these objectives soil & GW samples will be collected to characterize risk to human health & the environment within the framework of the Alaska Department of Environmental Conservation (ADEC) site cleanup process (18 AAC 75 Sections 325 to 390 & 18 AAC 78 Section 600).
If ADEC Method 2 criteria are exceeded, the Hydrocarbon Risk Calculator (HRC) approach under Method 3 will be used to assess whether site conditions meet ADEC risk criteria (in which case, a “cleanup complete without ICs” determination will be requested) or whether the site poses unacceptable risk (in which case remediation, ICs, or both may be required). If unacceptable risk is indicated by the HRC, then remedial options that address the compounds & exposure routes that contribute most significantly to the cumulative risk will be evaluated.
Vadose zone contamination may be treated with soil vapor extraction (SVE) & GW contamination may be treated using In-situ chemical oxidation (ISCO). Specific treatment design will be developed in a separate cleanup plan following the site characterization.
A series of soil borings will be installed in the vicinity of the removed USTs to identify & delineate the vadose zone contamination. Samples from the soil boring cores will be collected & screened utilizing a photoionization detector (PID). Based upon results of the PID field screening, the vadose zone sample from each boring interval with the highest PID reading will be collected & submitted for laboratory analysis of GRO, DRO, RRO, & BTEX constituents. One sample from within the vadose zone soils with the highest PID reading in the source area will additionally be submitted for lead, & ethylene dibromide (EDB) analysis.
A series of borings will be completed down to approximately 35 feet below ground surface in a grid pattern as shown on Figure 1-2. The objectives of these borings are to delineate the extents of light non-aqueous phase liquid (LNAPL) hydrocarbon impact at the smear zone. The LNAPL smear zone contamination is the likely source contributing to down gradient impact in the GW. The area of the smear zone with LNAPL present will be the area where ISCO injections are focused in the future. The borings will start at the potential source & step out perpendicular to GW flow. The first step out will be approximately 20 ft to one crossgradient side.
The field screening results of the boring will determine the next step out length in the series of borings. Typical step-outs will be in 20 ft increments. However, larger step-outs may be used if high field screening results are found. This process will continue until clean samples are reached in each cross-gradient direction. Once the lateral extent of the smear zone contamination is delineated, this process will be used to delineate the down gradient extent contamination. Samples for laboratory analytical analysis will be collected from the area of smear zone contamination. Approximately three samples will be collected from the clean soils outside of the smear zone contaminated zone to confirm field screening results are accurate.
All of the smear zone soil samples submitted for laboratory analysis of gasoline range organics (GRO), diesel range organics (DRO), residual range organics (RRO), & benzene, toluene, ethylbenzene, & xylene (BTEX) constituents. One sample from within the source area will be submitted for lead, & EDB analysis.
Soil samples from within the LNAPL-contaminated smear zone will be collected to conduct a bench scale test to determine the most effective ISCO treatment option. Vadose zone & smear zone soil samples from three representative boring locations will be submitted for grain size analysis to assist in ISCO and SVE design. |
Louis Howard |
| 2/4/2013 |
Document, Report, or Work plan Review - other |
Staff reviewed & commented on the draft UFP-QAPP
Executive Summary
2nd Paragraph
The text states: “If ADEC Method 2 criteria are exceeded, the Hydrocarbon Risk Calculator (HRC) approach under Method 3 will be used to assess whether site conditions meet ADEC risk criteria (in which case, a “cleanup complete without ICs” determination will be requested) or whether the site poses unacceptable risk (in which case remediation, ICs, or both may be required). If unacceptable risk is indicated by the HRC, then remedial options that address the compounds & exposure routes that contribute most significantly to the cumulative risk will be evaluated.”
Please note that cleanup complete without ICs will not be granted by ADEC to sites with vadose zone soils that exceed maximum allowable levels for petroleum contamination for soil from 0 – 15’ bgs (i.e. direct contact for BTEX, PAHs &/or ingestion for DRO, GRO, & RRO) regardless of HRC calculated risk levels. Treatment or excavations deeper than 15’ bgs may be warranted on a site-specific basis to prevent the soil from acting as a continuing source of GW contamination.
Institutional controls or L& Use Controls shall be applied when (per July 27, 2012 meeting minutes on the “Use of Hydrocarbon Risk Calculator”):
• The GW under or downgradient of a site was contaminated with POL constituents at concentrations exceeding risk criteria or MCLs; or
• POL contaminants in the soil were above the maximum allowable contaminant concentration given in Table B2 of 18 AAC 75 or at concentrations exceeding risk criteria.
• ICs also needed if direct contact or inhalation risks exceed residential l& use risk-based levels. Sites should be suitable for unlimited use/unrestricted exposure (UU/UE) for ADEC to grant a cleanup complete without ICs determination.
• In addition, sites with existing GW contamination above Table C cleanup levels will require that migration to GW cleanup levels be used for soil & ICs will be required.
Once GW contamination is below Table C for a period of time [per the latest approved “Basewide Monitoring Program Well Sampling Frequency Decision Guide (See Attachment 1 Memo to the Site File for OUs 4, 5, & 6 September 2003)” e.g. two rounds of annual GW monitoring], the maximum allowable levels may become the soil cleanup levels as determined by ADEC on a case by case basis.
Potential Receptors & Exposure Pathways
1st & 2nd paragraphs
To receive a “cleanup complete” without ICs/LUCs:
GW under or downgradient of a site cannot be contaminated with POL contaminants at concentrations exceeding risk criteria or MCLs; or
POL contaminants in the soil cannot be above maximum allowable contaminant concentrations given in Table B2 of 18 AAC 75 or at concentrations which exceed risk criteria; or
POL contaminants’ direct contact or inhalation risks cannot exceed residential l& use risk-based levels. Sites should be suitable for UU/UE for an ADEC cleanup complete determination without ICs/LUCs.
Soils greater than 15 feet below the ground surface have to meet the migration to GW st&ards. The direct contact pathway only needed to be considered within 15 feet of the ground surface at a site (i.e. direct contact for BTEX, PAHs &/or ingestion for DRO, GRO, & RRO).
4th Paragraph
The text states: “There are no drinking water wells in the shallow GW at this time.”
ADEC requests JBER provide information (e.g. location & well construction) on the nearest (within ½ mile of ST426) drinking water [Base] well or st&by drinking water well that may be used on a temporary, intermittent or permanent basis. This comment applies to all future UFP-QAPPs submitted by JBER for review by ADEC.
Table 10-1 Historic Soil Data
Benzene should be bolded for the NDs that are above the Table B1 Method Two Soil Cleanup Level of 0.025 (migration to GW). This would be for 426WL-03 (20’ & 26.5’) & 426WL-04 (6’, 10’ & 15.5’).
WS #15 Project Action Limits & Laboratory-Specific Detection/Quantitation Limits
Lab specific detection/quantitation limits for the contaminants proposed for analysis were not included with ST703. The example & referenced reporting limits included in the Draft Basewide UFP-QAPP are insufficient if Test America (Sacremento, Seattle & Anchorge), Applied Sciences Laboratory (ASL) are not chosen as the laboratory for this project.
Please be aware that the ADEC laboratory approval expires for TA Seattle, WA (UST-011) on March 14, 2013, TA Anchorage (UST-067) approval expires on June 16, 2013 & CH2M Hill Applied Sciences Lab Corvalis, OR (UST-079) approval expires on August 29, 2013. JBER is responsible for ensuring that any laboratory analyses conducted for this project will be performed by a laboratory with current ADEC laboratory approval.
|
Louis Howard |
| 6/17/2013 |
Document, Report, or Work plan Review - other |
ADEC has received the final version of the UFP-QAPP SC Work Plan for CG543 (ST423) on June 14, 2013. ADEC has reviewed the document and has no further comments on it. The document is approved. |
Louis Howard |
| 6/17/2013 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 76217 name: autogenerated pm edit - Elmendorf - AFID 785 ST426 |
Louis Howard |
| 3/13/2014 |
Update or Other Action |
Draft 2013 Annual report received for review and comment.
The overall project objectives included collecting sufficient data to:
• Monitor concentrations of contaminants of concern (COCs) at each site with sufficient
precision and accuracy to evaluate their concentrations with respect to cleanup goals.
• Identify potentially toxic and/or mobile transformation products.
• Verify individual plume characteristics, such as downgradient, lateral, or vertical expansion or retraction.
• Evaluate groundwater flow directions and hydraulic gradients to monitor plume migration and assess contaminant sources.
• Evaluate the effectiveness of land use controls/ institutional controls (LUCs/ICs) to
protect human health and the environment.
• Identify and repair damaged monitoring wells to protect groundwater.
• Identify monitoring wells that are no longer needed or are damaged beyond repair.
During 2013, groundwater monitoring well 44-785WL-01 was sampled for DRO. Analytical laboratory sample results exceeded 18 AAC 75 Table C cleanup criteria (1.7 mg/L).
In addition, a site investigation to fill data gaps needed to further characterize the current nature and extent of soil and groundwater contamination at CG543 was also performed during 2013.
Results of the site characterization are reported in a separate site characterization report.
The ADEC site status for CG543 is “Cleanup Complete with ICs.” DRO remain present in
groundwater above 18 AAC 75 Table C cleanup levels and in soil above 18 AAC 75 Tables B1
and B2 cleanup levels.
Additional investigation to characterize the current nature and extent of soil and groundwater
contamination at CG543 was also performed during 2013 under the JBER PBR contract. A site
characterization report has been prepared under separate cover. Recommendations for the site,
including any changes to the sampling program are provided in the site characterization report |
Louis Howard |
| 5/28/2014 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft annual report for monitoring of State-regulated Sites.
2012 Field Activities And Results
The text states: “In 2012, groundwater monitoring well 44-785WL-01 was sampled for DRO and EPH. EPH was included for future use in calculating risk at the site using the HRC. Analytical laboratory sample results exceeded ADEC Table C cleanup criteria. Table 9-1 presents a summary of analytical results. Table 9-2 presents a summary of EPH results.”
HRC risk-based cleanup levels for petroleum hydrocarbons are applicable only for those allowed by regulation for Method Three - 18 AAC 75.340(e):
alternative soil cleanup levels for the
[1] “migration to groundwater” or
[2] “inhalation” pathways based on site specific soil data, or
alternative soil cleanup levels for the
[3] “direct contact/ingestion” or
[4] “inhalation” pathways based on an approved industrial land use scenario.
The Site Cleanup Rules for Method Three do not allow for changes to Table C groundwater cleanup levels or calculation of risk based groundwater cleanup levels. ADEC will not recognize the use of HRC for calculation of risk of groundwater contamination at any site on JBER-E or JBER-R, except through the use of Method Four [risk assessment as allowed by 18 AAC 75.325(h)]. Therefore, Table C Groundwater Cleanup levels will apply with no alternative groundwater cleanup levels allowed via Method Three (e.g. HRC) for all PBR sites on JBER-R and JBR-E. The promulgated regulations will take precedence over any conflict with what is stated in the regulations vs. technical memorandum or guidance
|
Louis Howard |
| 6/2/2014 |
Update or Other Action |
Draft SC report received for review and comment.
Conclusions
The data set for CG543 supports the following conclusions:
· The average and 95% UCL DRO concentrations within the NAPL source area are 5,952 and 8,292 mg/kg, respectively.
DRO-contaminated soil is interpreted to be in contact with soils that are saturated by perched water within the former UST excavation above the water table during the monitoring events for which all wells have been gauged.
Groundwater samples collected from the monitoring well located in the NAPL-contaminated soil source area and screened across the perched water exceed 18 AAC 75 Table C criteria for DRO. However, the DRO aliphatics and aromatics meet risk criteria.
No visible staining of surface soils, odors, or stunted vegetation was noted at the site during the site characterization field investigation. There is no significant surface water runoff or sediment transport from the site to surface water bodies.
The carcinogenic cumulative risk and noncarcinogenic cumulative risk posed by the individual indicator compounds meet the ADEC risk standard, assuming a residential land use scenario.
The risk posed by the GRO, DRO, and RRO aromatic and aliphatic surrogate fractions meets the risk standard for each exposure pathway, assuming a residential land use scenario.
existing site conditions meet the soil migration to groundwater risk criteria.
The site meets ADEC qualitative ecological/environmental risk criteria in that there were no observed environmental impacts from soil staining, impacted vegetation, surface water or sediment runoff. In addition, groundwater from the site meets TAH and TAqH ambient water quality criteria. The Ecoscoping Form indicates that a more in-depth risk evaluation is not needed and that the CG543 site conditions are protective of the environment.
Recommendations
Based on the HRC calculations and compliance with environmental criteria, it is recommended that the ADEC grant Site CG543 at JBER a “Cleanup Complete” determination. Institutional Controls do not appear to be applicable at this site Following ADEC concurrence with this conclusion, groundwater monitoring of the site should be terminated and the existing monitoring wells at the site should be decommissioned. |
Louis Howard |
| 6/24/2014 |
Update or Other Action |
Staff provided comments on the draft SC report.
6.2 Recommendations
The text states: “Based on the HRC calculations and compliance with environmental criteria, it is recommended that the ADEC grant Site CG543 at JBER a “Cleanup Complete” determination. Institutional Controls do not appear to be applicable at this site Following ADEC concurrence with this conclusion, groundwater monitoring of the site should be terminated and the existing monitoring wells at the site should be decommissioned.”
ADEC does not concur. The status of CG543 shall remain “cleanup complete with institutional controls”. In 2013, monitoring well 44-785WL-01 was sampled and has detected DRO at 1.7 mg/L which currently exceeds the Table C cleanup level for DRO at 1.5 mg/L. DRO has exceeded the cleanup level since 2007 (in mg/L: 2.13, 2.4, 1.68, 2.12, 2.75, 3.1, and 1.7).
Groundwater monitoring will continue for CG543 until two years of groundwater monitoring are below Table C DRO cleanup level of 1.5 mg/L.
|
Louis Howard |
| 12/17/2014 |
Document, Report, or Work plan Review - other |
ADEC has reviewed the Air Force's responses to its comments and finds them satisfactory. Finalize the report. |
Louis Howard |
| 5/19/2015 |
Document, Report, or Work plan Review - other |
Staff commented on the annual State Sites monitoring report which included this site. Staff concurred with the recommendation to continue groundwater monitoring and a request for "cleanup complete" determination will be made upon resolution of the Table C groundwater exceedance and no risk demonstrated by the hydrocarbon risk calculator. |
Louis Howard |
| 4/27/2016 |
Document, Report, or Work plan Review - other |
Staff commented on the Draft Annual Report for Monitoring State Sites (including this one) on JBER.
Site Summary and Recommendations
The text states: “The groundwater sample from monitoring well 44-785WL-01 had a DRO concentration above cleanup levels.
Site CG543 is identified as a Green priority since the HRC demonstrated that CG543 meets the ADEC risk standard for human health and the environment assuming a residential land use scenario (USAF, 2014f). Based on this conclusion, it is recommended to discontinue annual groundwater monitoring at Site CG543. In addition, it is recommended to discontinue site inspections in 2016 since site CG543 does not present an unacceptable risk to human health and the environment. A request for “Cleanup Complete” will be made upon resolution of the Table C exceedance question.”
ADEC disagrees. As long as there are exceedances of Table C cleanup levels in monitoring well 44-785WL-01 for DRO (2016 3.05 mg/L), groundwater monitoring will be required. A “cleanup complete” designation will not be granted to any site which has groundwater with contaminant concentrations that exceeds Table C cleanup levels.
|
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 CG543:
? Perform IC inspection
? Sample well 44-785WL-01 for diesel range organics (DRO) |
Louis Howard |
| 3/22/2017 |
Update or Other Action |
2016 Draft Report for Remedial Action Operation and Land Use/Institutional Control at JBER received for review and comment.
The USAF Compliance Monitoring Report (2006) recommended that in-source well 44-785WL-01 be sampled again in 2017 for DRO and if concentrations are below cleanup levels again in 2017, this site should be considered for closure. The report also concluded that soil sampling is not necessary for closure because previous investigations only found contaminated soil in the smear zone. DRO has not been detected in monitoring well 44-785WL-02 for two consecutive years and continued sampling is not necessary.
The inspection of Site CG543 revealed no evidence of ground disturbance at this site. Revegetation
appeared to be occurring and the monitoring wells located at the site were observed to be in good condition. Active wildlife including moose and squirrels were observed feeding onsite and an active aboveground storage tank was observed adjacent to the site. No warning signs relevant to the area of concern were observed. Photographs 1 and 2 in Photograph Log A7 present the general condition of Site CG543.
See site file for additional information. |
Louis Howard |
| 4/12/2021 |
Document, Report, or Work plan Review - other |
DEC submitted comments on Draft JBER Basewide UFP-QAPP dated February 2021. |
William Schmaltz |
| 5/19/2021 |
Document, Report, or Work plan Review - other |
DEC Reviewed and approved of Basewide Uniform Federal Policy - Quality Assurance Project Plan. QAPP summarizes general activities for a 5 year period on JBER. |
William Schmaltz |
| 2/7/2023 |
Document, Report, or Work plan Review - other |
DEC reviewed the 2023 Letter Work Plan Remedial Action Operations and Long-Term Management, Draft, dated January 2023. The work plan describes the site inspections, maintenance activities, and groundwater, seep, and surface water monitoring, at multiple sites located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. The scope of work briefly summarizes the site locations, sampling/monitoring schedules, and activities such as free-product removal from monitoring wells and monitoring/maintenance activities at the Operable Unit 5 wetlands. The details regarding the procedures for the remedial action operations and long-term management activities will remain consistent with the 2021 Uniform Federal Policy Quality Assurance Project Plan (UFP-QAPP). |
Ginna Quesada |
| 2/16/2023 |
Document, Report, or Work plan Review - other |
DEC reviewed and provided comments regarding the 2023 Letter Work Plan Remedial Action Operations and Long-Term Management, Draft, dated January 2023.The work plan describes the site inspections, maintenance activities, and groundwater, seep, and surface water monitoring, at multiple sites located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. The scope of work briefly summarizes the site locations, sampling/monitoring schedules, and activities such as free-product removal from monitoring wells and monitoring/maintenance activities at the Operable Unit 5 wetlands. The details regarding the procedures for the remedial action operations and long-term management activities will remain consistent with the 2021 Uniform Federal Policy Quality Assurance Project Plan (UFP-QAPP). |
Ginna Quesada |
| 4/25/2023 |
Document, Report, or Work plan Review - other |
DEC approved the 2023 Letter Work Plan Remedial Action Operations and Long-Term Management, Final, Dated April 2023. The work plan describes the site inspections, maintenance activities, and groundwater, seep, and surface water monitoring, at multiple sites located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. The scope of work briefly summarizes the site locations, sampling/monitoring schedules, and activities such as free-product removal from monitoring wells and monitoring/maintenance activities at the Operable Unit 5 wetlands. The details regarding the procedures for the remedial action operations and long-term management activities will remain consistent with the 2021 Uniform Federal Policy Quality Assurance Project Plan (UFP-QAPP). |
Ginna Quesada |
| 5/18/2024 |
Document, Report, or Work plan Review - other |
DEC submitted comments regarding the 2023 Annual Remedial Action-operations And Long-term Management Report for Select State-regulated Sites Draft, Dated April 2024. The report describes the site inspections, maintenance activities, and groundwater monitoring, at multiple sites located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. Site inspections were recommended to continue for all sites to ensure that conditions remain protective of human health and the environment. The report recommends updating land use controls (LUC) site boundaries at CG534, a ‘Cleanup Complete’ determination without institutional controls (ICs) for SS522, the removal of groundwater LUCs at SS041, and a ‘Cleanup Complete with ICs determination for TU101. |
Ginna Quesada |
| 6/25/2024 |
Document, Report, or Work plan Review - other |
DEC approved the 2023 Annual Remedial Action-operations And Long-term Management Report for Select State-regulated Sites Final, dated June 2024. The report describes the site inspections, maintenance activities, and groundwater monitoring, at multiple sites located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. Site inspections were recommended to continue for all sites to ensure that conditions remain protective of human health and the environment. The report recommends updating land use controls (LUC) boundaries at CG534, a ‘Cleanup Complete’ determination without institutional controls (ICs) for SS522, the removal of groundwater LUCs at SS041, and a Cleanup Complete with ICs determination for TU101. |
Ginna Quesada |
| 1/30/2025 |
Document, Report, or Work plan Review - other |
DEC approved the 2025 Remedial Action–Operations and Long-term Monitoring Work Plan Addendum Final, dated January 2024.The work plan describes the site inspections, maintenance activities, and groundwater, seep, and surface water monitoring, activities that will be conducted at multiple sites located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. The scope of work briefly summarizes the site locations, sampling/monitoring activities and schedules. This workplan will remain consistent with the procedures outlined in the 2023 Letter Work Plan Remedial Action-Operations and Long-Term Management. |
Ginna Quesada |
| 4/15/2025 |
Document, Report, or Work plan Review - other |
DEC provided comments for the 2024 Annual Remedial Action-Operations and Long-Term Management Report for Select State-Regulated Sites Draft, dated April 2025.The report describes the site inspections, maintenance activities, and groundwater monitoring, at multiple sites located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. Site inspections were recommended to continue for the majority of the sites to ensure that conditions remain protective of human health and the environment. DEC concurs with the recommendation to close SS522 site without ICs, discontinue groundwater sampling at TU107, and reducing the sampling frequency for some wells at TU103. |
Ginna Quesada |
| 5/6/2025 |
Long Term Monitoring Workplan or Report Review |
DEC approved the 2024 Annual Remedial Action-Operations and Long-Term Management Report for Select State-Regulated Sites Final, dated May 2025. The report describes the site inspections, maintenance activities, and groundwater monitoring, at multiple sites located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. Site inspections were recommended to continue for the majority of the sites to ensure that conditions remain protective of human health and the environment. DEC concurs with the recommendation to close SS522 site without ICs, discontinue groundwater sampling at TU107, and reducing the sampling frequency for some wells at TU103. |
Ginna Quesada |
