| 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...). Also included in the letter is the AF 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. |
Jennifer Roberts |
| 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 discoverv 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 |
| 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 |
| 11/22/1996 |
Leaking Underground Storage Tank Release Confirmed - Petroleum |
LUST Site created in CSP for source area ID 77299 |
Former Staff |
| 11/22/1996 |
Leaking Underground Storage Tank Cleanup Initiated - Petroleum |
|
Former Staff |
| 11/22/1996 |
Site Added to Database |
|
Former Staff |
| 11/30/1996 |
Underground Storage Tank Site Characterization or Assessment |
Final Site Assessment Report FY95 O&M Tank Removal at bldg. 21-478 Tanks 878A and 878B received. June 9, 1996 tanks 878A and 878B were removed. Stained soil and hydrocarbon odors were present in the excavation from 2 feet to 10 feet bgs when the USTs and associated piping were removed in 1996. Free flowing liquid was found at 14.5 feet bgs at the north end of one tank. This investigation indicated that a release had occurred.
On inspecting the north, east and west walls of the excavation, dark stains were discovered 2
to 3 ft. below the surface. In some locations the stains were only 1 ft. thick. In other locations, they were over 10 ft. thick. Since the stains began 2 ft. below the surface and Tanks 878A and 878B were 4 ft. below the surface, it is reasonable to assume that this contamination resulted from a previous surface spill. (It is conceivable that the contamination resulted from overflow or spills while fuel was pumped to the tanks.)
Maximum level of DRO was 12,700 mg/kg [NOTE: Maximum allowable concentration is 12,500 mg/kg if ingestion pathway is incomplete which would require 10,250 mg/kg for DRO 18 AAC 75 April 2012] from the tank pit samples 96EAFB-878B-TP1-001SL, 002SL 9,630 mg/kg and 003SL 7,350 mg/kg from a depth of 13.5 ft. bgs at tank 878B. 878A had heavily stained soil with strong petroleum odor but DRO results indicated only 127 mg/kg. Hypothesis is that the soil is contaminated with heavy petroleum products or lubricating oil which cannot be detected with DRO analysis. |
Louis Howard |
| 3/31/1999 |
Update or Other Action |
Six soil borings were advanced during the SERA Phase V investigation in 1997. Two soil samples were collected from each boring and analyzed for GRO, DRO, RRO, and BTEX compounds; six samples were analyzed for SVOCs. DRO exceeded the cleanup level in the two borings advanced in the north central portion of the former UST area and one boring advanced northwest of the former UST area.
The maximum DRO concentration (15,400 mg/Kg) was detected at 15 feet bgs (Sample ID 529-02-01 from between the 2 USTs 878A and 878B), and the DRO concentration in this boring at 25 feet bgs was 2,450 mg/Kg. [NOTE this is above the maximum allowable concentration of 12,500 mg/kg for DRO, absent the ingestion pathway which is 10,250 mg/kg. April 2012 18 AAC 75 Table B2 Method Two] There were no monitoring wells installed during this investigation.
Note that groundwater is at 27 ft. bgs from nearby wells at other sites. |
Louis Howard |
| 10/21/2002 |
Update or Other Action |
State Elmendorf Environmental Restoration Agreement dissolved. The Alaska Department of Environmental Conservation (DEC) has reviewed the issue of abolishing the State Elmendorf Environmental Restoration Agreement (SERA) per Air Force request. 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 |
| 6/30/2004 |
Conditional Closure Approved |
The Department concurs that ST529 LUST Event ID 1795 will not require any further remediation or site investigation; however, groundwater monitoring will have to be conducted at ST529.
In the event the remaining contaminated soil becomes accessible by construction, or other information becomes available which indicates that the site may pose an unacceptable risk to human health, safety, welfare or the environment, the Air Force will be required under 18 AAC 75.300 to notify the Department. Also, any transport or disposal of contaminated soil excavated from the site requires approval from the Department in accordance with 18 AAC 75.325(i). The Base Master Plan needs to be updated to document the locations of contamination and the need to properly manage contaminated soil at ST529.
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 and AS 46.03 to require additional investigation, cleanup, or containment if subsequent information indicates: 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 |
| 6/30/2004 |
Long Term Monitoring Established |
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 wells currently in the Basewide Groundwater Monitoring Program are OU5MW-34, OU5MW-01, and OU5MW-02, located approximately 500 feet southwest, 2300 feet south, and 1600 feet southeast of ST529, respectively. This site is located within the Fairchild trichloroethene (TCE) plume, which is monitored under the Basewide Groundwater Monitoring Program. |
Louis Howard |
| 2/18/2005 |
Update or Other Action |
February 18, 2005 list of sites sent which includes ST529. Well IDs OU5MW-01, OU5MW-02 and 62WL-02 will be sampled on an annual 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.
Soil at ST529 contained concentrations of DRO above Method Two cleanup levels in 1997. In 2005, groundwater at monitoring wells OU5MW-01, OU5MW-02, and OU5MW-34 did not have detectable concentrations of DRO. These wells are located hydraulically downgradient of the ST529 site. |
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 sample 529MW-IN and OU5MW-34 for diesel range organics (DRO). |
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 ST529 the following wells will be monitored: 529MW-IN and OU05MW-34 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 |
Groundwater monitoring wells 529MW-IN and OU5MW-34 were sampled and analyzed by an analytical laboratory for DRO. DRO was detected in both wells, at concentrations below the DRO cleanup level. (NOTE to file: In 2006, DRO was detected above the ADEC groundwater cleanup level
at 4.57 mg/L. However, groundwater results collected in 2007, 2008, and 2009 were below
ADEC cleanup levels)
It is recommended that soil samples be collected again from ST529 in 2017 (if funding is available) to determine if vadoze zone soil contaminant concentrations have been remediated to below cleanup levels. Until soil samples are collected, annual groundwater monitoring at well 529MW-IN should continue for DRO. |
Louis Howard |
| 4/15/2010 |
Update or Other Action |
2009 Annual Report for monitoring of compliance program sites. Elmendorf AFB site ST529 is located northwest of former Building 21-878. The building was located at the corner of 9th Street and Finletter Avenue and originally housed mechanical equipment for steam generation. It was later converted to a car wash and then demolished sometime prior to 1996. ST529 is the former location of two unregulated 57,000-gallon steel USTs which stored diesel fuel for Building 21-878. The USTs and associated piping were removed in 1996.
Groundwater monitoring well 529MW-IN was sampled using the approved procedures provided
in the 2008 Final Work Plan (USAF, 2008b). This sample and a field duplicate were analyzed
by an analytical laboratory for DRO. DRO was not detected above MDLs in either sample.
Soil at ST529 contained concentrations of DRO above cleanup levels in 1997. In 2006,
groundwater in the in-source monitoring well 529MW-IN had concentrations of DRO above the
cleanup level. In 2007 and 2008, that same well had DRO concentrations below the cleanup
level and in 2009, DRO concentrations were not detected above the MDL. The concentrations
reported in this in-source well decreased from 4,570 ug/L in 2006 to 640 ug/L in 2007 to 436
ug/L in 2008, and then to undetected in 2009
The 2008 Annual Report (USAF, 2009c) recommended that soil samples be collected again from
ST529 in 2017 (if funding is available) to determine if vadose zone soil contaminant
concentrations have been remediated to below cleanup levels. ADEC subsequently concurred
with the recommendation (ADEC, 2009a). This is still recommended.
Until soil samples are collected, annual groundwater monitoring at well 529MW-IN should
continue for DRO. |
Louis Howard |
| 7/26/2010 |
Update or Other Action |
2010 Environmental Compliance work plan received. Although ST529 has previously only exceeded ADEC cleanup criteria levels for DRO, the soil will be analyzed for GRO, DRO, VOCs, RRO and PAHs in order to asses whether cleanup is complete. Previous groundwater sample results have indicated that contaminant concentrations are below ADEC cleanup criteria; therefore, groundwater will not be analyzed.
• Advance one boring to approximately 45 feet bgs in the former source area. The proposed soil boring location is presented in Figure A-9 (Appendix A).
• PetroFLAG™ screening samples will be collected and analyzed for every 5 feet of boring in accordance with ELM-SOP-1 (Appendix B).
• Three analytical samples will be collected from the soil boring: one sample will be collected from the upper 10 feet bgs; one sample will be collected at or near the water table and one will be collected from a depth between the surface and the water table.
• Analytical samples will be collected from the locations with the highest PetroFLAG™ screening results. Samples will be collected in accordance with ELM-SOP-2 (Appendix B). Samples will be analyzed for GRO, DRO, RRO, VOCs, and PAHs.
If the soil analysis indicates concentrations below the ADEC cleanup criteria, no
additional samples will be collected.
If the soil analysis indicates any contaminant concentrations above the ADEC cleanup
criteria, the most appropriate path forward will be recommended based on analytical
results.
|
Louis Howard |
| 3/16/2011 |
Update or Other Action |
Draft Annual Report Monitoring of Compliance Restoration Program Sites received. Groundwater monitoring well 529MW -IN was sampled. The sample was analyzed by an analytical laboratory for DRO. DRO was not detected above the MDL in the sample. Soil samples were also collected for this site in 2010. Soil samples were collected by a separate contractor and results are being provided in a separate report. Conclusions and recommendations for this site are provided in a soil sampling report prepared under separate cover. |
Louis Howard |
| 3/25/2011 |
Update or Other Action |
ST516, ST529 and ST600 2010 Investigative Sampling Results received. Site ST529 is the former location of two unregulated 57,000-gallon steel USTs that stored diesel fuel for the former Building 21-878. Building 21-878 originally contained equipment for steam generation and was later converted to a car wash. The building was demolished prior to 1996. The two USTs and their associated piping were removed in 1996.
Groundwater was reached at 28 feet bgs. Soil samples were field screened for total petroleum
hydrocarbons using PetroFLAG® at a frequency of one sample per 5 feet of continuous-core
boring advanced. One analytical sample was then collected from each of three different
intervals: the upper 10 feet bgs (0 to 5 feet bgs); between the surface and the water table (20
to 25 feet bgs); and at or near the water table (25 to 30 feet bgs).
Two DRO results exceeded the ADEC cleanup of 250 mg/kg at 770 mg/kg (20 to 25 feet bgs)
and 10,000 mg/kg (25 to 30 feet bgs). TCE (0.026 mg/kg) was also found above the cleanup
level (0.020 mg/kg) in the sample collected from 25 to 30 feet bgs. All other analytical results
were below ADEC cleanup levels and EPA regional screening levels. Table 3-6 presents
analytical results that exceed the ADEC cleanup level.
Based on the results for soil samples collected for this purpose in 2010, DRO exceeded the
ADEC Method Two migration to groundwater cleanup level of 250 mg/kg for the sample
collected from 20 to 30 feet bgs. Elevated PetroFLAG® screening results suggest that DRO
may also exceed the cleanup level from 15 to 20 feet bgs. While DRO may be present in soil,
analytical results for groundwater samples collected from the in-source well 529MW-IN
during annual monitoring indicate that concentrations of DRO have remained below ADEC
Table C cleanup levels from 2006 to 2008. This suggests that DRO is not migrating to
groundwater. Therefore, comparison of the 2010 soil results to Method Two ingestion and
inhalation criteria may be more appropriate. When evaluated against these criteria, the
concentrations of DRO found in soil (770 mg/kg and 10,000 mg/kg) are below the ingestion
and inhalation cleanup levels of 10,250 mg/kg and 12,500 mg/kg, respectively.
In addition, TCE was detected over the ADEC cleanup level of 0.020 mg/kg at 0.026 mg/kg
in the sample collected from 25 to 30 feet bgs. TCE has not previously been detected in soil or
groundwater; however, its presence is not unexpected given past uses of the site. All other
results for soil samples collected in 2010 were below ADEC cleanup levels and EPA regional
screening levels.
The following activities are recommended to address contaminants remaining in subsurface
soil at ST529:
-Advance three borings in uncontaminated areas in order to collect TOC samples from depths representative of the impacted soil type (total of 9 samples). TOC data may be used to support a Method Three determination for the calculation of site-specific alternative
cleanup levels.
-Advance one boring within the source area and collect several soil samples from various
depths, specifically from 15 to 30 feet bgs. Samples should be analyzed for DRO and VOCs, including TCE. GRO, RRO, and PAHs will be removed from the list of analytes because they have not been detected above cleanup levels during previous monitoring events.
-Collect two additional groundwater samples for DRO at in-source well 529MW-IN; and
expand the analyte list to include VOCs, including TCE. |
Louis Howard |
| 7/15/2011 |
Update or Other Action |
Draft Work Plan Environmental Remedial Action-Operations & LTM & Maintenance received.
Soil borings will be drilled and samples collected from three CRP sites that underwent closure soil sampling in 2010 to obtain additional TOC data (ST516, ST529, and ST600).
Site ST529 is the former location of two unregulated 57,000-gallon steel USTs that stored diesel fuel for the former Building 21-878. Building 21-878 originally contained equipment for steam generation and was later converted to a car wash (Figure 6.5). The building was demolished prior to 1996. The two USTs and their associated piping were removed in 1996. Stained soil and hydrocarbon odors were observed from 2 feet to 10 feet bgs in the excavation of the UST and associated piping. Free flowing liquid was found at 14.5 feet bgs at the north end of one tank.
Closure soil samples were collected from a soil boring at ST516 in 2010. DRO (3,800 mg/kg) exceeded the ADEC Method Two migration to groundwater cleanup level of 250 mg/kg at 35 to 40 feet bgs. All other results for samples collected from this boring were below ADEC Method Two cleanup criteria.
The 2010 Investigative Sampling Results Report (USAF, 2011a) recommended the following activities to address contaminants remaining in subsurface soil at ST516:
?Advance three borings in uncontaminated areas in order to collect TOC samples from
depths representative of the impacted soil type (total of nine samples). TOC data may be used to support a Method Three determination for site-specific alternative cleanup levels;
-Advance one boring within the source area and collect several soil samples from various depths, specifically from 15 to 30 feet bgs. Samples should be analyzed for DRO and VOCs, including TCE. GRO, RRO, and PAHs will be removed from the list of analytes because they have not been detected above cleanup levels during previous monitoring events; and
-?Collect two additional groundwater samples for DRO at in-source well 529MW-IN; and
expand the analyte list to include VOCs, including TCE.
Soil samples will be collected from ST529 in 2011 to obtain additional TOC data that may be used to support an ADEC Method Three determination for site-specific alternative cleanup levels. Field activities at ST516 will consist of direct-push technology to install five soil borings.
One in-source soil boring will be placed near the 2010 closure sample location where samples were collected that exceeded ADEC Method 2 cleanup levels. An additional four borings will be placed outside the contaminated zone to collect samples for TOC analysis. Soil samples collected from the five soil boring will be collected at the following intervals: 15 to 20 feet bgs, 20 to 25 feet bgs, and 25 to 30 feet bgs, as recommended by ADEC in their comments to the draft 2010 Investigative Sampling Results Report (ADEC, 2011a). Each soil sample collected from the in-source soil boring will be collected for laboratory analysis for DRO and VOCs. The four background borings will be sampled for TOC, DRO, and VOCs.
The former UST and spill sites are managed under the JBER
Compliance Restoration Program (CRP) according to the former State-Elmendorf Air Force
Base (AFB)(prior to the establishment of JBER) Environmental Restoration Agreement (SERA).
The contaminants that are tracked in the groundwater plumes at these sites are listed below.
-Site ST401 - GRO, BTEX, DRO
-Site ST402 - GRO, BTEX, DRO, residual range organics (RRO), volatile organic compounds (VOC), ethylene dibromide (EDB)
-Site ST403 - GRO, BTEX, DRO, RRO, VOC
-Site ST421 - GRO, BTEX, DRO
-Site ST422 - GRO, BTEX, DRO
-Site ST426 - DRO
-Site ST507 - GRO, BTEX, DRO
-Site ST510 - GRO, BTEX, DRO
-Site ST516 - GRO, BTEX, DRO, VOC
-Site ST526 - VOC
-Site ST529 - DRO, VOC
-Site ST534 - DRO
-Site ST538 - DRO
-Site ST600 - GRO, BTEX, VOC, Polycyclic aromatic hydrocarbons (PAH)
-Site ST702 - GRO, BTEX, DRO
-Site ST703 - DRO
-Site ST805/806 - DRO
-Site Taxiway-N - GRO, BTEX, DRO
-Site West Ramp Hydrant Fueling Facility (WRHFF) - GRO, BTEX, DRO
Soil borings will be drilled and samples collected from three CRP sites that underwent closure soil sampling in 2010 to obtain additional total organic carbon (TOC) data (ST516, ST529, and ST600). The contaminants that are tracked in the groundwater plumes at these sites are listed below.
-Site ST401 - GRO, BTEX, DRO, TOC, PAH
-Site ST538 - GRO, BTEX, DRO, VOC, TOC
-Site WRHFF - GRO, BTEX, DRO, TOC
-Site ST516 - GRO, BTEX, DRO, VOC, TOC
-Site ST529 - GRO, BTEX, DRO, TOC
-Site ST600 - GRO, VOC, TOC
Soil borings will be completed using direct-push technology to facilitate near real-time soil screening with a photoionization detector (PID) and analytical soil sampling. |
Louis Howard |
| 4/26/2012 |
Update or Other Action |
2011 Annual Report for Compliance Restoration Program Sites received.
Soil samples from the in-source soil boring were collected at the following intervals: 17 to 19 feet bgs, 23 to 25 feet bgs, and 27 to 29 feet bgs. Background soil samples were collected just above the soil/groundwater interface. All samples were analyzed for DRO and VOCs. One of the planned background borings in 2011, 529BG2, was relocated closer to the former UST location during acquisition of the dig permit due to underground utilities. Elevated DRO concentrations were identified at 27 to 29 feet bgs, suggesting this boring is located within or adjacent to the source of contamination. As a result, the sample collected from the boring is being treated as an in-source sample.
DRO concentrations in boring 529IN1 and 529BG2 at 27 to 29 feet bgs exceed the Method Two cleanup level for migration to groundwater. Elevated levels of TCE were also identified in borings ST529IN1 and 529BG2 from approximately 23 to 29 feet bgs as well as from surrounding background borings. However, TCE is likely associated with the Fairchild Avenue VOC Plume which passes beneath the site.
Because previous sampling confirmed that contamination extends to the seasonal high groundwater level at this site, samples were collected immediately adjacent to the groundwater interface in all four background borings for analysis of TOC and site COCs, in accordance with the ADEC Technical Memorandum 08-002 guidance (ADEC, 2008). Triplicate TOC results from the background soil sampling were averaged to obtain an acceptable concentration for use in the Method Three cleanup level determination of an alternative migration to groundwater cleanup level. As previously indicated, elevated DRO concentrations identified in the 529BG2 boring suggests the boring is located within or adjacent to the source of contamination. For purposes of the Method Three Alternate cleanup level determination, the TOC results from this boring were omitted.
The analytical results of the 2010 and 2011 sampling indicate remaining DRO contamination at ST529 exceed the ADEC Method Two cleanup levels. The results were compared to ADEC Method Three Alternative cleanup levels developed using site-specific TOC and moisture data. This method incorporates TOC analyses as indicated in Technical Memorandum 08-002 (ADEC, 2008). A site-specific moisture value of 5.4% was used for input into the worksheet.
Per the Technical Memorandum Guidelines, the average of the lowest order of magnitude TOC values were used for input into the Method Three worksheet. The average of the lowest order of magnitude TOC values is 2,097 mg/kg and was used for calculation of the ST529 site-specific cleanup levels. This TOC value is higher than the default TOC value of 1,000 mg/kg, and results in higher cleanup levels than the Method Two standards.
Groundwater monitoring well 529MW-IN was sampled using the approved procedures provided
in the 2011 Work Plan (USAF, 2011f). The sample was analyzed by an analytical laboratory for
DRO and VOCs. DRO was not detected above the MDL in the sample, but the concentration of
TCE exceeded the ADEC cleanup level.
Annual Compliance Monitoring from 2006 through 2011 confirmed that groundwater in monitoring well 529MW-IN did not have concentrations of DRO above the cleanup level. Analytical results of 2010 and 2011 soil sampling indicate DRO concentrations exceeding Method Two and Three remain in soil from 20 to 30 feet bgs. In addition, elevated levels of TCE were detected at the site. However, TCE is likely the result of the Fairchild Avenue VOC plume which passes beneath the site.
No changes are being recommended to compliance monitoring at this site due to the 2012 PBC. |
Louis Howard |
| 6/22/2012 |
Update or Other Action |
Draft Project Management Plan received for review and comment under the performance based remediation contract.
ST529 (0009CP) CG-C529 (CRP)
Performance objective: Site Closure
Performance indicators:
· Prepare an approved Site Characterization Workplan by December 2012
· Coordinate, mobilize, and execute Site Characterization concurrently with 2013 RA-O Monitoring Event by August 2013
· Prepare an approved Site Characterization Report and Site Closure Report by March 2014
· Conduct final site closure requirements and well abandonment to achieve SC by May 2014
Potential Risk
HRC indicates soil contamination is present exceeding risk levels; HRC indicates
groundwater contamination is present exceeding risk levels.
Risk Mitigation
Excavation or treatment (biovent) will be completed for vadose zone soils exceeding HRC levels to eliminate risk, and evaluation of groundwater impacts will be completed and appropriate treatment (ORC) will be implemented to remediate groundwater.
Date of achieving Performance objective
3rd Quarter 2014
Planned approach
Prepare an approved Site Characterization Workplan with an updated CSM. Coordinate, mobilize, and execute Site Characterization by installing and sampling three soil borings and sample two existing monitoring wells.
Use HRC to evaluate SC based on risk to future residential receptors for all pathways.
Prepare an approved Site Characterization Report with an updated CSM, documented HRC risk evaluation, and include the Site Closure Report requesting Cleanup Complete without ICs.
Receive ADEC concurrence with Cleanup Complete without ICs and provide documentation to AFCEE. |
Louis Howard |
| 6/22/2012 |
Document, Report, or Work plan Review - other |
Staff provided review comments on the PMP.
Page 2-31
The text states: “The WPs will be submitted in the initial phases of the project for Air Force and regulatory review and concurrence according to the schedule outlined in the IMS. If regulatory agencies elect not to review/approve documents, approval will be sought through the Secretary of the Air Force/Installations and Environment (SAF/IE) to proceed with execution of the plan activities. The WESTON Team understands that a procedure has been established for this situation, and that the Air Force controls this process.”
Failure to obtain work plan approval before implementing site work described above is considered a violation of Alaska regulations and may result in field work not being approved or additional work being required and may subject responsible parties and/or contractors to a Notice of Violation (NOV).
7.1.2
For petroleum sites (aka Two Party sites) overseen by ADEC refer to the following:
ADEC will strive to complete plan reviews and respond to JBER within thirty (30) days after receipt of plans, although this is not always possible nor is it a requirement. At times, JBER requested expedited plan reviews are feasible based on project manager work load, adequate up-front planning, and contractors providing complete, well written plans.
However, if significant work plan revisions are required, additional review and comment resolution time will be needed. To facilitate successful project implementation, it is recommended that DoD project managers and contracting staff:
•Coordinate schedules with ADEC in advance and throughout projects.
•Include ADEC in project planning meetings (DQO meetings, UFP QAPP development meetings, Triad and other Technical Project Planning team meetings, etc.).
• Plan and maintain project schedules that include a minimum of forty-five (45) days for reviewing draft work plans, comment resolution, any necessary revisions to the draft-final version and a final review and approval.
See also the Fort Richardson 1994 Environmental Restoration Agreement “Review and Comment on Documents” which states at Section 9. “All draft final work plans for field work, site assessments or remedial actions (both interim and final) must be submitted to ADEC a minimum of 45 days prior to the start of field work or construction. Site Assessment and Remedial Action draft reports must be submitted to ADEC within 120 days after completion of field work.”
• Review contractor planning documents prior to submission to ADEC to ensure compliance with state and federal regulations consistency with agreements made during project planning meetings.
Independent QA Oversight on Performance Based Contracts
The site cleanup rules require that “collection, interpretation, and reporting of data, and the required sampling and analysis is conducted or supervised by a qualified, impartial third party”. Depending upon the specific terms in a performance based contract, a contractor may no longer be considered an impartial third party with respect to collecting, interpreting and reporting data.
This should be taken into consideration when preparing scopes of work. ADEC strongly recommends the Air Force provide an on-site Quality Assurance Representative or a third party QA oversight contractor to monitor fieldwork for consistency with approved plans and contract requirements.
Page 7-6
The text states: “Our Technical Site Managers and Project Chemists will ensure that, prior to sampling activities, full service analytical laboratories to be used are, at a minimum, DoD ELAP accredited and in good standing based on standard business information sources (e.g., Dunn & Bradstreet). In addition to DoD ELAP, the Project Chemist will also ensure that the supporting laboratories are approved for work in the State of Alaska, when required. Analytical methods used will be
Alaska and EPA standard methods, unless technically impractical.”
ADEC disagrees. The full service analytical laboratories have to be both DoD-ELAP accredited AND Alaska approved. Any non-EPA and/or Alaska methods must be approved by the department prior to sample collection.
|
Louis Howard |
| 3/1/2013 |
Update or Other Action |
Draft UFP-QAPP received for review & comment.
The overall objectives for the site are to meet “unrestricted or residential site use” criteria & achieve a “cleanup complete without institutional controls (ICs)” determination.
One boring will be advanced near former location of soil sample 96EAFB-878B-TP1-001SL to resample the soil at the location & depth where previous sampling showed an exceedance of the maximum allowable criteria for DRO & to collect source area soil samples for gasoline range organics (GRO), DRO, residual range organics (RRO), & volatile organic compounds (VOCs) analysis (i.e. to generate source area samples for statistical characterization of the source). The proposed new boring is located where both the vadose zone & the zone of seasonal water table fluctuation (smear zone) are interpreted to be contaminated. The boring & the borings described below will be drilled through the zone of seasonal water table fluctuation. Approximately two vadose zone & two smear zone soil samples will be analyzed for GRO, DRO, RRO, & VOCs. At least one of the relatively heavily contaminated soil samples from the boring will be analyzed for polycyclic aromatic hydrocarbons (PAHs), extractable petroleum hydrocarbons (EPH) & volatile petroleum hydrocarbons (VPH).
One boring will be drilled near former boring SB-529-02 to resample the soil at the location & depth where previous sampling showed an exceedance of the maximum allowable criteria for DRO & to collect source area soil samples for GRO, DRO, RRO, & VOCs analysis (i.e. to generate source area samples for statistical characterization of the source). The proposed new boring is located where both the vadose zone & the zone of seasonal water table fluctuation appear to be contaminated. Approximately two vadose zone & two smear zone soil samples will be analyzed for GRO, DRO, RRO, & VOCs. At least one of the relatively heavily contaminated soil samples from the boring will be analyzed for polycyclic aromatic hydrocarbons (PAHs), extractable petroleum hydrocarbons (EPH) & volatile petroleum hydrocarbons (VPH).
One boring will be drilled approximately 40 to 50 ft west of former boring ST529-BH01A in order to assess the boundary of the non-aqueous phase liquid (NAPL)-contaminated soil source area. Soil samples will be collected & analyzed for GRO, DRO, RRO, & VOCs. The proposed new boring is located where the zone of seasonal water table fluctuation may or may not be contaminated & where the vadose zone is likely not impacted. If the soils in the smear zone appear to be contaminated, then approximately two smear zone soil samples will be collected from the boring from what appears to be the most heavily impacted soil (based on photoionization detector (PID), visual & olfactory screening). Soil samples will be collected & analyzed for GRO, DRO, RRO, & VOCs. If vadose zone soils appear to be contaminated, then one or two vadose zone samples will be collected for laboratory analysis.
If vadose zone soils do not appear to be contaminated, then no vadose zone samples will be collected. If this boring is inside the NAPL-contaminated soil source area, then additional borings will be drilled at about 50 ft increments further to the west, southwest as needed to define the boundary of the NAPL-contaminated soil source area. If the boring does not encounter NAPL-contaminated soils, then the western boundary of the source will have been defined & no additional borings to the west or southwest will be installed.
One boring will be drilled approximately 40 to 50 ft south-southwest of former soil boring ST529-BH01A in order to assess the boundary of the NAPL-contaminated soil source area. The proposed new boring is located where the zone of seasonal water table fluctuation may or may not be contaminated & where the vadose zone is likely not impacted.
If the soils in the smear zone appear to be contaminated, then approximately two smear zone soil samples will be collected from the boring, for laboratory analysis from what appears to be the most heavily impacted soil. Soil samples will be collected & analyzed for GRO, DRO, RRO, & VOCs. If this boring is inside the NAPL-contaminated soil source area then additional borings will be drilled in about 50 ft increments further to the west, southwest as needed to define the boundary of the NAPL-contaminated soil source area. If the boring does not encounter NAPL-contaminated soils then the western boundary of the source will have been defined & no additional borings to the west or southwest will be installed. |
Louis Howard |
| 4/30/2013 |
Update or Other Action |
Draft 2012 Annual Monitoring report received for review and comment.
GC529 is the former location of two unregulated 57,000-gallon steel USTs which stored diesel fuel for Building 21-878.
indicate that DRO concentrations continue to exceed cleanup levels in the soil at CG529. In addition, elevated levels of trichloroethylene (TCE) were detected in the soil samples. However, TCE is likely the result of the Fairchild Avenue volatile organic compound (VOC) plume which passes beneath the site. Groundwater samples collected from 2007 through 2011 at CG529 indicate that DRO concentrations no longer exceed cleanup levels in groundwater at the site. Elevated levels of TCE were also detected in the groundwater samples. Current monitoring requirements at Site CG529 include annual groundwater sampling for DRO and TCE at groundwater monitoring well 529MW-IN.
TCE exceeded ADEC cleanup criterion (5 µ/L) with a result of 46 µ/L.
Soil samples collected from borings advanced within the source area in 2011 indicate that DRO and TCE concentrations continue to exceed cleanup levels in the soil at CG529. Groundwater samples collected from 2007 through 2011 at CG529 indicate that DRO concentrations no longer exceed cleanup levels in groundwater at the site.
However; elevated levels of TCE were detected in the groundwater samples. TCE found in the groundwater and smear zone soil are likely the result of the Fairchild Avenue TCE plume which passes beneath the site. It is recommended that TCE be eliminated from annual sampling for CG529. The Fairchild Avenue plume will continue to be monitored for TCE as required for CERCLA site ST037.
Additional investigation to characterize the current presence/absence of soil contamination is being proposed for CG529 in 2013 under the new PBR contract (Pre-draft CG529 – ST529 Site Characterization Work Plan USAF, 2012e). No changes to the annual monitoring are being proposed for this site other than eliminating TCE from annual sampling for this site. |
Louis Howard |
| 6/13/2013 |
Document, Report, or Work plan Review - other |
ADEC has received the final version of the CG529 (ST529) UFP-QAPP SC Work Plan on June 4, 2013. ADEC has reviewed the final 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: 77299 name: ST529 AFID 878 A&B |
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 529MW-IN was sampled for DRO. The DRO concentration exceeded its cleanup criteria. 529MW-IN DRO 7,000 ug/L (Table C 1,500 ug/L). NOTE to FILE: Maximum solubility of DRO is ~5 mg/L or 5,000 ug/L.
The ADEC site status for CG529 is “Cleanup Complete with ICs.” The groundwater sample from in-source well 529MW-IN had a DRO concentration above cleanup levels in 2013 for the first time since 2006 during annual monitoring.
Additional investigation to characterize the current nature and extent of soil and groundwater
contamination at CG529 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 |
| 5/21/2014 |
Document, Report, or Work plan Review - other |
Staff provided comments on the SC Report.
VPH and EPH Groundwater Results
The text states: “…risk is only assessed for the aromatic and aliphatic fractions of the total measurement, while the total GRO, DRO and RRO measurement includes the aromatics, aliphatics and partially degraded polar organic acids and alcohols.” There is still unknown risk associated with the polar fraction of petroleum hydrocarbons as is stated within the HRC Tables “A DRO polar fraction may be present, the risk posed by the polar fraction is not known.” Sites with exceedances of Table C groundwater cleanup levels will require institutional controls regardless of the calculated risk.
The 2007 Summary of Proposed Modifications for 341 Table B2 states: “Additionally, the fractions and calculation(s) will remain part of the Method Three calculator. Appropriate site specific data, including petroleum fraction(s) data, will still be able to be submitted to DEC when proposing alternative cleanup levels under Method Three or Method Four.”
Alternative petroleum cleanup levels under Method Three by regulation only apply to soil and do not apply to groundwater for modification of Table C values for Total GRO, DRO, and RRO cleanup levels. A risk may be calculated, however, Method Four by regulation is the only way alternative petroleum cleanup levels are allowed to be considered by ADEC for groundwater. This has been discussed in prior meetings and prior comments on work plans involving the Method Three HRC approach on JBER by ADEC.
Nature and Extent of the Groundwater Contamination
The text states: “The only exceedances of 18 AAC 75 Table C criteria were for DRO in 2006 and 2013 and TCE in 2011 and 2012. All other analytical groundwater data have met 18 AAC 75 Table C criteria. The VPH-EPH analysis indicates that the DRO aliphatics and aromatics meet risk criteria, indicating that the 2013 exceedance of DRO is due to DRO polar fraction compounds (organic acids and alcohols).”
The risk from DRO polar fraction compounds are unknown at this time and therefore total DRO Table C cleanup level of 1.5 mg/L shall be the cleanup level that apply at any site on JBER-E and JBER-R for groundwater.
Site-Specific Risk Evaluation Results
The text states: Note that the HRC conclusion only identifies the potential need for an institutional control when the risk standard is exceeded (or when a polar DRO fraction is present at concentrations above 1.5 mg/L). Therefore, CG529 is eligible for a “Cleanup Complete” determination.”
ADEC disagrees. The risk from the polar DRO fraction is unknown and cleanups based on aliphatic and aromatic levels in groundwater is not accepted under current regulations for Method Three. CG529 is not eligible for “cleanup complete” without institutional controls.
Recommendations
Based on the HRC calculations and compliance with environmental criteria, it is recommended that the ADEC grant Site CG529 at JBER a “Cleanup Complete” determination. Institutional Controls do not appear to be applicable at this site.”
ADEC disagrees. The groundwater exceeded Table C for DRO at 7 mg/L in August 2013. In early 2014, the same well (529MW-IN) was resampled and the results were below Table C. A meeting was held May 14, 2014 to discuss this site. It was agreed by ADEC and the Air Force that one more groundwater sample would be taken from well 529MW-IN for DRO during August 2014.
If groundwater results are below Table C for DRO (1.5 mg/L), then the site would be eligible for “cleanup complete” designation by ADEC, pending a signed memorandum of understanding between the Air Force and ADEC regarding Method Three sites with soil contaminated with petroleum above the maximum allowable concentrations within 0-15’ bgs which have:
• no risk exceedances greater than an HI of 1 and cumulative risk of 1 x 10-5 or less,
• no vapor intrusion risks to occupants in current or future buildings,
• no eco-risk at the site as demonstrated by the eco-scoping form,
• no visible surface staining of soils present, and
• no groundwater contamination above Table C.
Absent a signed MOU, the site will remain cleanup complete with ICs.
|
Louis Howard |
| 7/14/2014 |
Document, Report, or Work plan Review - other |
Air Force's responses to ADEC's comments accepted as a satisfactory response for this document (draft SC report). Finalize the document. |
Louis Howard |
| 1/26/2015 |
Update or Other Action |
Staff received the draft SC report for review and comment.
Petroleum hydrocarbon contamination (primarily DRO) is likely the result of spills and leaks from the CG529 tanks and associated piping. The groundwater monitoring data set for CG529 includes: annual DRO results from the in-source monitoring well 529MW-IN since 2006; annual VOC results since 2011; and GRO, RRO, PAH, EPH and VPH results from 2013. The only exceedances of 18 AAC 75 Table C criteria were for DRO in 2006 and 2013 and TCE in 2011, 2012 and 2014. All other analytical groundwater data have met 18 AAC 75 Table C criteria (USAF, 2014).
· The risk evaluation completed using 2013 data in the HRC indicated that the risk posed by the GRO, DRO, and RRO aromatic and aliphatic surrogate fractions meet the human health risk standard for each exposure pathway, assuming a residential land use scenario. The VPH-EPH analyses of groundwater indicate that the DRO aliphatics and aromatics meet risk criteria. However, the HRC indicated an exceedance of the Table C DRO criteria and Table C-1 indicated that an institutional control may be applicable.
· In both of the subsequent April and August 2014 groundwater sampling events, concentrations of DRO were detected in groundwater above the project screening level, but below 18 AAC 75 Table C levels. Therefore, the previous August 2013 analytical DRO result (which was above cleanup level) is considered an anomaly and not considered to be representative of site conditions.
· After updating the HRC with the 2014 groundwater data the risk evaluation continues to indicate that 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. However, since the groundwater results are now under Table C DRO criteria, the HRC Table C-1, Page 12 descriptor indicates closure without ICs can be attained. There is no vapor intrusion risk indicated from the constituents associated with the site. Additionally, the eco-scoping form in the original Site Characterization and Risk Evaluation indicates no eco-risk at the site.
· The HRC calculations demonstrate acceptable risk to human health at the site and that the site meets the risk based closure criteria. However, the current ADEC policy is to require ICs for sites with soil contamination within 0-15’ bgs that is above the Table B maximum allowable concentrations.
Groundwater monitoring can be discontinued at the site since the results from two additional
2014 sampling analyses are below 18 AAC 75 Table C cleanup levels. Since there is an ongoing issue with respect to the ADEC requirement for an IC if soil contaminant concentrations exceeding Table B2 maximum allowable concentrations, a request for a “Cleanup Complete” status will be made upon resolution of the issue.
|
Louis Howard |
| 2/3/2015 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the draft SC report addendum for CG529.
ADEC requests the Air Force elevate these issues through the proper channels to Environmental Chief (Gary Fink) and DoD Program Manager (John Halverson) or as allowed for under DSMOA Section IV “Dispute Resolution [For other sites, it is the intention of the parties that all disputes shall be resolved at the lowest possible level of authority as expeditiously as possible within the following framework. All timeframes for resolving disputes below may be lengthened by mutual consent. 1. Should the RPM and SAC be unable to agree, the matter shall be referred in writing as soon as practicable but in no event to exceed ten (10) working days after the failure to agree, to the installation commander and the chief of the designated program office of the lead State agency or their mutually agreed upon representatives designated in writing].” if you have issues with the regulatory requirements regarding ICs for exceedances of MAC in soil or ICs for exceedances of Table C cleanup levels in groundwater on JBER-E and JBER-R.
Please note there is an alternative to dispute resolution for CG529 (and other JBER-E and JBER-R sites like it) and it would be eligible for a “cleanup complete” designation by ADEC, pending a signed memorandum of understanding between the Air Force and ADEC regarding Method Three; sites with soil contaminated with petroleum above the maximum allowable concentrations within 0-15’ bgs which have:
• no risk exceedances greater than an HI of 1 and cumulative risk of 1 x 10-5 or less,
• no vapor intrusion risks to occupants in current or future buildings,
• no eco-risk at the site as demonstrated by the eco-scoping form,
• no visible surface staining of soils present, and
• no groundwater contamination above Table C
Absent such a signed agreement, ADEC will not assign a “cleanup complete” designation for CG529 and require contaminated soil within the 0-15’ interval be addressed so that it no longer exceeds MAC for DRO if “cleanup complete” without ICs is desired for CG529.
|
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. Main comment was regarding the results of the hydrocarbon risk calculator stating there was no risk and cleanup complete determination is warranted despite petroleum contamination present above maximum allowable concentrations within the 0 - 15' interval. Finally, with no groundwater contamination at the site for several monitoring events, ADEC concurred with the request to discontinue monitoring. However, staff requested that JBER verify that the wells can't be used by compliance program for monitoring, or be used to monitor 1,4-dioxane from releases of TCE or PFOS/PFOA from releases of PFC-containing aqueous film forming foam. |
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
Summary of Previous Investigations
The text states: “One groundwater sample was collected from source area monitoring well 529MW-IN on April 28, 2014, and a subsequent sample collected on August 27, 2014. Samples were analyzed for DRO and the August event also included analysis of VOCs. The DRO and VOC results were below cleanup criterion for the sampling events.”
ADEC disagrees. On page 27 of the 2_144129_e_Level_4.pdf Laboratory Analytical Report Work Order No. 1144129: SGS Client Sample ID: 14CG529-529MWIN-GW-0, SGS Ref. #: 1144129010, Project ID: JBER LTM Sampling, Collection Date/Time: 08/27/14 14:40, shows results for trichloroethene at 27.5 µg/L which is above the 5 µg/L Table C Groundwater Cleanup Level in 18 AAC 75.
|
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 CG529:
? Perform IC inspection |
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. One groundwater sample was collected from source area monitoring well 529MW-IN in April 2014, and again in August 2014. Samples were analyzed for DRO and the August event also included analysis of VOCs. The DRO and VOC results were below cleanup criterion for the sampling events. However, the August event showed results for TCE at 27.5 µg/L, which is
above the 5 µg/L Table C Groundwater Cleanup Level in 18 AAC 75 (ADEC 2017).
The inspection of Site CG529 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. No warning signs relevant to the area of concern were observed. Photographs 1 through 3 in Photograph Log A8 present the general condition of Site CG529.
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 |
| 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 |
