| Action Date |
Action |
Description |
DEC Staff |
| 1/9/1995 |
Update or Other Action |
Army sent a Waiver From USTMP for Leaking USTs to ADEC (L. Howard)
On Thursday, January 5,1995, you had a discussion with Mr. Samuel Swearingen of Public Works, Environmental Compliance Branch, concerning four underground storage tanks(UST) that failed tank tightness testing.
Tanks 754A, 759A, 81 building 59000 and 30A building 79a, failed tank tightness testing, and had release reports filed with Alaska Department of Environmental Conservation(ADEC). Fort Richardson's Underground Storage Tank agreement with ADEC, under attachment C, requires initiation of a siteassessment(SA) within 30 days and submittal of the SA to ADEC within 60 days.
The above referenced tanks have been emptied of all product, the fill lines sealed and padlocked to prevent refilling of the UST. All four tanks are scheduled to be removed and possibly replaced in the spring/early summer of 1995. Fort Richardson is requesting that the SA required by the USTMP be waived until the USTs are removed, at which time a SA and if necessary a release investigation will be conducted on each of the above referenced sites, following the time line specified in attachment C of the USTMP.
Your concurrence, and/or comments are requested as soon as possible to allow Public Works to make alternate arrangements if this course of action is not agreeable. |
Louis Howard |
| 1/9/1995 |
Document, Report, or Work plan Review - other |
Staff reviewed and approved the Army's Request letter for a Waiver of the USTMP schedule at Fort Richardson, Alaska.
The Alaska Department of Environmental Conservation-Defense Facilities Oversight group (ADEC)
has received, on January 9, 1995, a facsimile copy of the above request for delaying site assessment (SA) work as required in Attachment C of the Underground Storage Tank Management Plan
(USTMP). As outlined under para 90 "Modification" ADEC will grant an extension on SA work
for only the following tanks: 754a, 789a, and 81 at bldg. 59000 and 30a at bldg. 798.
Normally, the USTMP requires initiation of a SA within 30 days of confirmation. However, since weather
conditions in Alaska often dictate when work can be conducted, the start date for initiating a SA or release investigation will be no later than May 15, 1995. ADEC will require the timeline in the USTMP be followed for these tanks after this date. |
Louis Howard |
| 10/31/1995 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Site Assessment Report, Bldg 789 UST 789a Fort Richardson, AK September 26, 1995.
The Department of Environmental Conservation-Defense Facilities Oversight group (DEC) has
received a copy of the above referenced report for bldg 789 tank 789A.
General Comments
The document does not specify as to the reason for replacing the piping for tank 789a and
conducting the site assessment. Normally a site assessment is required before a permanent
closure or a change-in-service is completed, or to meet the requirements of AS 46.03.380(b), or
when required by 18 AAC 78.210 or 18 AAC 78.230. DEC requests the Army specify the
reason for replacing the piping under the applicable section mentioned above.
Specific Comments page 2
The text states the piping was found to be in good condition based on visual observations by the
consultant during the removal. DEC requests information that required the piping to be removed
in the first place. DEC further requests information on when the new piping was replaced for
tank 789A and by which firm's certified worker. It is noted on Figure 1 that the 2" feed pipe and vent pipe were removed and replaced with new 2" pipes, but it does not list what specific
materials are used in the piping.
18 AAC 78.055(5) "Repairs Allowed" repaired tanks and piping must be tightness tested as
required by 18 AAC 7S.065(d) and IS AAC 7S.070(c) within 30 days after repairs are complete
and before bing placed back in operation. DEC requests the Army furnish tank and piping
tightness test methodes) and results for UST 7S9A. If the Army cannot provide results for
tightness test results for both the tank and new piping then it must furnish results from the
monthly monitoring of the repaired portion of the UST (i.e. piping) for releases, using a method
specified in 18 AAC 7S.065( e )-(i).
4.1 Project Criteria page 6
The text references ADEC criteria and the previous use of the UST as a waste oil tank for
justification of the EPA test methods used for analyzing the soil from the project. In addition to 8l00M, 80l5M, 418.1,8020, the consult~mt was required to analyze for volatile chlorinated
solvents, PCBs and leachable metals (18 AAC 78.315(g)). ADEC is requesting additional
analyses be performed on the stockpiled soils from this site and if results indicate the soil is
hazardous then it must be disposed of properly. Be aware that soils additionally contaminated
with a hazardous substance other than petroleum product are subject to 18 AAC 75, and may be
subject to 18 AAC 60, 62, 70, and 72.
5.3 Conclusion and Recommendations page 12
ADEC cannot approve a closure at this time until the analyses and results from additional
sampling as indicated above is performed. If the results show no action levels were exceeded for
PCBs, leachable metals and volatile chlorinated solvents, then ADEC will grant closure for
789A.
|
Louis Howard |
| 3/4/1999 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the April 28, 1998, closure of UST, Alternate ID 789-A, located near the west side of building 789 on Fort Richardson, Alaska. Facility ID 0-000788, ADEC tank 7. Event ID 2271.
The Department of Environmental Conservation (Department) has reviewed the site assessment report received on August 7, 1998, documenting the closure of the above mentioned regulated underground storage tank (UST). The report summarizes the information collected during closure of the 1000-gallon UST used to store used oil. Based on the information presented in the site assessment document, the Department is requesting additional information be submitted:
• Information contained in the report indicates approximately 50 cy of soil was excavated from the UST excavation. The soil was temporarily stockpiled and field screened to help determine if hydrocarbon contamination was present. Figure #2, on page 5, lists the field screening results, ranging from 2.9 to 5.1 units. However, no confirmation samples were collected from the stockpile before the soil was returned to the excavation. 18 AAC 78.320(c) [now 18 AAC 78.605(c)] specifies the sampling requirements for untreated stockpiles. It specifically requires a minimum of two grab samples be collected and analyzed for untreated stockpiles of 50 cy or less, and one additional sample for each additional 50 cy of soil. Please provide the Department with an explanation as to why confirmation samples were not collected from the untreated stockpile.
• The Department believes the contractor mistakenly assigned the site a matrix score of 26. The Department believes a mistake occurred by assigning a “0” value to the “Volume of Contaminated Soil” category, for less than 10 cy of contaminated soil. Because the 50 cy stockpile had positive field screening results, and no confirmation samples were collected
and analyzed the to verify the stockpile was not contaminated, the Department has to assume all 50 cy of excavated soil was contaminated. This volume of contaminated soil equates to a category score of five, (5) and changes the over all matrix score to 31. A 31 score would make this site a level “B” site, instead of a level “C” as reported. Please reevaluate the ADEC Matrix Score Sheet submitted in the report, and either submit an explanation defending the score submitted by your contractor, or submit a new matrix score sheet to reflect the changes discussed above.
Upon receipt of the requested information the Department will review all the information submitted and make a determination whether correction action will be required at this site.
Please note, I believe there is a misunderstanding as to the UST identification number assigned to the UST decommissioned under this report. The report indicates the decommissioned tank is assigned an ADEC identification number of 788-789A. Our records list this tank as number #07 for your facility (0-000788). I believe 789-A is an identifier the Department of the Army used to identify this tank, which also corresponds to the alternate ID listed in our data base. The Department will generally list an alternative ID when the owner assigns an identifying number to the UST other than the one we use. There is no need to correct this information in the report. |
Tim Stevens |
| 4/19/2010 |
Update or Other Action |
Email from Mark Prieksat RE: Report of potential contamination at FTR-269C. The USACE geotech drillers reported what appears to be POL contamination that was encountered at the FTR-269C (COF) site, between 5th and 6th Streets, west of the FTR196 Barracks that is currently under construction. The soil registered ~75 ppm on the PID, but the contamination has not been identified at this time. We are working with the USACE to conduct additional site characterization and will notify you as soon as we have data results for this site. |
Louis Howard |
| 4/29/2010 |
Update or Other Action |
Email from the Army re: FTR 269C site fuel contamination.
The USACE collected soil samples from borings at the FTR 269C site during geotech drilling efforts. The samples were analyzed for presence of fuels, RCRA metals, pesticides, VOCs, PAHs, and PCBs, with results indicating that DRO is the only contaminant of concern at this site (see attached trip report). The USACE contractor (Jacobs Engineering) has developed a Work
Plan for further investigation of this site and that WP has been sent to you for review and comment.
I would like to discuss using this WP (or a more generic version) as a pre-approved plan for investigation at other similar sites that may be encountered during this construction season. The Army would provide adequate notification in accordance with the FFA if contamination is detected at a site, but could then proceed to investigate the site using a pre-approved plan. This would allow more timely and proactive investigation of these sites, without continuing to produce similar WPs for every site. Addendums could be produced for each additional site to indicate sample locations, number of samples, and analyses and sent
to you for review and comment. Please consider this and we can discuss next week after the Nike Site meeting. |
Louis Howard |
| 4/29/2010 |
Update or Other Action |
MEMORANDUM FOR CEPOA-PM-M (TeVrucht) SUBJECT: Report of Industrial Hygiene Air Monitoring and Chemical Findings, Brigade Complex, Maneuver Enhancement Brigade (MEB), Phase I , Fort Richardson, Alaska (FTR269, 09-076) received from the Army.
The U.S. Army Corps of Engineers, Alaska District, Engineering Division, Engineering Services Branch, Materials Section (CEPOA-EN-ES-M) was tasked by the Project Management Branch (CEPOA-PM-M) to conduct worker exposure monitoring during geotechnical drilling operations. Thirty-four borings were completed during the geotechnical investigation on the FTR269 project sites. Of
these borings, four were chosen for chemical sampling. Two additional borings were sampled due to field screening measurements that indicated possible contamination. The objectives of the project were to conduct exposure monitoring for project specific locations to evaluate employee exposure to contaminants associated with past military use of the land. See Figure 1 for the
project location.
On 23 March 2010, Ms. Teresa Lee, US Army Corps of Engineers Alaska District (Corps) conducted employee exposure monitoring to BTEX (benzene, ethylbenzene, toluene and xylene). Personal monitoring was conducted on USACE employees during geotechnical drilling operations due to the presumed fuel contamination.
Summary of Field Activities: Two soil samples were collected on 11 February 2010 at the FTR269B project site from boring AP-5522. Two soil samples were collected on 23 March 2010 at the FTR269A project site from boring AP-5544. Six soil samples including a duplicate and a trip blank were collected 24-25 March, 2010 at the FTR269C project site from borings AP-5534 and AP-5528.
All other borings (AP-5517 through AP-5543) were screened using a photoionization detector (PID). USACE chemist Teresa Lee (CEPOA-EN-ES-M) and geotechnical engineers Inocencio Roman and Tu Nguyen (CEPOA-EN-ESSG) performed the field screening activities while senior driller Lyle Cain and junior drillers Paul Owens and Chris Bean performed drilling activities. Clifford
Cormier and Adam Sunders, Dynasty Drilling, also performed drilling operations on the FTR269C project site. PID readings were zero, and no obviously contaminated soil was observed, with the exception of borings AP-5536, AP-5535 and AP-5534. Boring AP-5535 had PID readings beginning at an interval of 2.5-4.5 ft. of 8 parts per million (ppm). The readings increased with depth to a
maximum cold PID reading of 87 ppm at 9.5-11.5 ft. Boring AP-5536 had a cold field screening PID reading of 62 ppm beginning at the depth of 14.5-16.5 ft. USACE chemist Teresa Lee performed all sampling activities.
These results demonstrate that chemicals of concern were not found in the borings that were sampled for project sites FTR269A and FTR269B, with the exception of arsenic. However, arsenic concentrations are considered to be within background limits for all three project sites. DRO contamination was found on project site FTR269C at a concentration above the ADEC clean up limit of 300 mg/Kg associated with boring AP-5536 (4000 mg/Kg). Field screening indicated similar contamination at boring AP-5535 from a depth of 5-15 feet. Further site investigation for FTR269C is scheduled for spring 2010 by Jacobs Engineering Group, Inc.
Based on the enclosed personal monitoring, continue utilizing established work
practices and established safety protocols. Should site conditions or processes change
additional evaluations should be performed. |
Louis Howard |
| 5/13/2010 |
Document, Report, or Work plan Review - other |
ADEC reviewed and commented on the Draft 2010 Work Plan FTR269 Maneuver Enhancement Brigade
Complex Site Investigation, Fort Richardson, AK April 2010.
1.3 Previous Environmental Work Page 1-4
The text states in January 2010, the U.S. Army Corps of Engineers (USACE) conducted geophysical and analytical sampling at the proposed construction sites. Ten borings were advanced at the Barracks site, eighteen at the COF building and parking lot sites, and six at the New Fueling Point. Analytical samples were collected from approximately 10 percent of the soil borings or four borings. The results of this sampling event were not available at the writing of this Work Plan. ADEC requests the Army provide one hard copy and one electronic copy of the complete report of this sampling event to ADEC for its records. The complete analytical laboratory report(s) shall be included as part of all submittals to the department for which environmental samples have been collected, analyzed and reported.
3.2.5 Equipment Decontamination Procedure Page B-3-3
The text states sampling equipment that is not disposable will be decontaminated with a potable water and Liquinox/Alconox solution and rinsed with potable water between sampling. A decontamination or equipment blank is used to determine if contamination occurred from sampling equipment such as pumps and bailers and checks to make sure equipment decontamination procedures have been effective. ADEC will require the Army to collect decontamination or equipment blanks (one per set of 20 samples, minimum of one) should it decide to use equipment which is decontaminated between samples.
3.3.2 Soil Sampling Page B-3-6
The text states one methanol trip blank for analysis of VOCs by SW8260 and one methanol trip blank for AK101 analyses will be included in every cooler containing VOC or GRO samples. In some cases, one trip blank can be used for both analyses. At least one trip blank is required for each cooler for each method. ADEC will require the Army to collect at least the minimum methanol trip blanks at one per set of 20, minimum of one for all soil samples being analyzed for GRO, BTEX or VOCs regardless of the number of coolers used for sampling. ADEC requests the Army update Table B-3-3 to include methanol blanks and decontamination blanks.
Table B-3-1
ADEC will require the Army to use methanol preservative for AK101 and cool to 4o ? 2oC not < 25 oC. RCRA Metals containers-amber glass sample collection bottles are to be certified clean for trace metals analysis. The metals analysis must include arsenic, barium, cadmium, chromium, lead, nickel, and vanadium (e.g. EPA 6010C, EPA 6020A, or 7000 series). PCB has no preservation and 40 days to analysis of extract (recommended).
PCBs must be prepared using extraction method 3540C or 3550C. For releases where leaded gasoline and aviation gasoline are suspected contaminants of concern, ADEC requires analysis for EDB and 1,2-DCA. EPA 8260 is required for the analysis of 1,2-Dichloroethane (1,2-DCA). EPA 8011 or EPA 504.1 should be used when evaluating ethylene dibromide (EDB). EDB soil samples should be field preserved in hexane.
|
Louis Howard |
| 2/8/2011 |
Update or Other Action |
FTR269 MEB Complex Company Operations Facility Work Plan Addendum (Draft) received.
This Work Plan Addendum describes the planned activities to be conducted at the FTR269
Maneuver Enhancement Brigade (MEB) Complex, Company Operations Facility (COF) on Joint Base Elmendorf-Richardson (JBER), Alaska. The work described in this addendum will be conducted in accordance with all plans and procedures outlined in the Fort Richardson Post Wide Work Plan (U.S. Army Engineer District, Alaska [USAED] 2010). Appendices to the Work Plan include the Site Safety and Health Plan (SSHP), Field Sampling Plan (FSP), Quality Assurance Project Plan (QAPP), Environmental Protection Plan (EPP), Storm Water Pollution Prevention Plan, Waste Management Plan (WMP), Stockpile Construction Plan, Geophysics Investigation Plan, and Munitions and Explosives of Concern (MEC) Support Plan.
The primary objective of the work at the COF Building site is to excavate contaminated soil in
preparation for construction-related activities and future site users. Project activities include soil sampling, excavation of contaminated soil, and waste management. These activities are designed to identify and remove soil contaminated with diesel-range organics (DRO) in
concentrations greater than the Alaska Department of Environmental Conservation (ADEC) Method Two, migration to groundwater cleanup level of 250 milligrams per kilogram (mg/kg) (Oil and Other Hazardous Substances Pollution Control 18 AAC 75 [ADEC 2008]) from areas planned for future construction activities.
Project Execution Approach
An estimated 5,400 cubic yards (cy) of soil will be excavated from a triangular area within the
footprint of the proposed COF building (Figure 2). Soil will be excavated and treated or disposed of off site. Although the proposed amount of soil from within the triangular area will
be removed, it is estimated that only 50 percent of this soil will have DRO concentrations
exceeding 250 mg/kg. Analytical samples will be collected to confirm that cleanup levels
have been achieved. All analytical samples will also be submitted for DRO and TCE analysis
since TCE contamination was identified near the excavation area. |
Louis Howard |
| 2/23/2011 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (ADEC) has received the above document for review and comment on February 16, 2011. Based on the information provided, ADEC will approve the work plan as submitted. TCE was mentioned as being identified in the northern portion of the site at concentrations exceeding Table B1, migration to groundwater cleanup levels. If TCE were discovered to be more widespread at FTR269, then it may be eligible as a new source area to be addressed by the Federal Facility Agreement. As it stands now, none of the borings within the proposed excavation area have any detections of TCE. |
Louis Howard |
| 3/3/2011 |
Update or Other Action |
Email from Mark Prieksat (JBER) to Louis Howard: I received your response letter for the FTR269C site and have directed the contractor to finalize the Work Plan. We will be testing for the presence of TCE during excavation and will notify of any changes to site conditions. Attached is a request to transport form for the FTR269C site. We will probably start excavation and testing about 15 Mar 11. |
Louis Howard |
| 4/13/2011 |
Offsite Soil or Groundwater Disposal Approved |
CONTAMINATED SOIL DISPOSAL AUTHORIZATION CS11005 FT. Richardson letter from Municipality of Anchorage-Solid Waste Services Department to Jacobs Engineering, CC: Eileen Olson.
This is in response to your request to dispose of 1200 +/- cubic yards of contaminated soil from Ft. Richardson. On the basis of the information provided in your letter, and with the approval and concurrence of the ADEC Contaminated Sites and Solid Waste Programs, the soil samples meet Solid Waste Services’ criteria for disposal. Accordingly, you are authorized to dispose of this material in the Anchorage Regional Landfill.
Prior to disposal, please have your hauling agent contact Mr. Nissen (ph.317-6864, fax 428-1697) or Mr. Jim Brown (ph.428-1027, fax 428-1697) to make specific disposal arrangements at least 24 hours prior to intended delivery. The hauling agent must present a copy of this letter to the ARL Scalehouse or the load will be rejected NO EXCEPTIONS.
Attendant at the time the soil is brought to the landfill. The fee is No Charge per land agreement.
This authorization expires on May 31, 2011. If this material is not disposed of by this date, you will have to request another letter of authorization. |
Louis Howard |
| 4/29/2011 |
Update or Other Action |
Email to John Halverson (ADEC) from Mark Prieksat (JBER): Since Louis is out, I wanted to ask you for approval to transport/dispose of DRO-contaminated soil at the Muni Landfill. Louis had approved transport/treatment of 2700 cubic yards of soil from this same site at ASR, but subsequent to that request we determined that we could dispose of low level (less than 1000 mg/kg) DRO-contaminated soils at the Muni Landfill at a cost savings of about $100K. We collected the required analyticals for review by the landfill and they have approved the disposal request.
I am attaching the request to transport form (as well as the previous form that Louis had approved), the approval letter from the Muni Landfill, as well as the analytical results. Sorry for the short response time, but we have been working this with the Muni for some time and would like to start transporting soil on 2 May 2011. Please let me know if you need additional information to approve this request.
|
Louis Howard |
| 4/29/2011 |
Offsite Soil or Groundwater Disposal Approved |
Approximately 1200 cubic yards of diesel range organics (DRO)-contaminated soil will be transported to the Municipality of Anchorage Landfill for disposal. The soil contains less than 1000 mg/kg DRO in accordance with the landfill permit requirements, Soils contaminated with DRO at concentrations greater than 1000 mg/kg have been transported to ASR for disposal in accordance with previous ADEC approval. Soil came from the FTR296 COF Building Site - North of 5th Street and D Street, JBER Alaska. Approved by John Halverson Environmental Program Manager I. |
John Halverson |
| 7/6/2011 |
Update or Other Action |
2011 TIME-CRITICAL REMOVAL ACTION MEMORANDUM PROPOSED FTR269C COMPANY OPERATIONS FACILITY PARKING AREA received electronically July 6, 2011. This TCRA Memo documents the decision by Joint Base Elmendorf-Richardson (JBER)-Richardson to remove PCB-contaminated soil from the proposed FTR269C Company Operations Facility (COF) Parking Area, near the current Building 789. As the lead agency, JBER-Richardson has secured funding to conduct this removal action.
The existing Building 789 is scheduled to be demolished & replaced with a paved parking area as part of MILCON activities during 2012. This removal action is being conducted to prevent, minimize, &/or mitigate damage to the public health & welfare or to the environment, which may otherwise result from release of this contamination. This includes actions to prevent &/or minimize potential exposure of PCBs to nearby human & animal populations, & to remove PCBs in the surface/subsurface soil that may migrate offsite as particulates in air or water.
JBER-Richardson is authorized to conduct this TCRA pursuant to the CERCLA 42 USC Section 9604 & Executive Order 12580 (53 Federal Register 2923). In addition, this action is consistent with the Federal Facility Agreement (FFA) for JBER-Richardson signed in 1994 (U.S. Army 1994).
This TCRA Memo was prepared as part of a proposed TCRA under CERCLA Section 104 to address PCB soil contamination identified during a Preliminary Site Evaluation (PSE) at the site. The CERCLIS ID# for the site is AK6214522157.
Contaminants of concern at the site include PCB Aroclor 1260 & TCE; however, since PCBs present a more significant risk to public health & the environment, this TCRA will focus on the PCB contamination only. TCE soil concentrations will be monitored during the TCRA, but excavation activities will be guided by the PCB contamination.
The threats posed by the PCB-contaminated soils & vegetation at the site are time-critical, based on their presence at &/or near the ground surface. Onsite workers, both those currently using the site & those involved in the demolition & construction activities, could be exposed when accessing the site. During construction activities, PCB contamination in the surface soil also has potential to migrate to adjacent soil, water & air. The appropriateness of the removal action to address a threat to public health & welfare or the environment is based on two of the eight factors listed in the CFR Title 40, Section 300.415(b)(2)[4] of the National Contingency Plan (NCP):
1. Actual or potential exposure to nearby human populations (i.e., site construction workers) from hazardous substances, pollutants or contaminants; &
2. Levels of hazardous PCBs in soils largely at or near the surface that may migrate.
The exposure pathways for TCE include direct contact, outdoor inhalation, & migration to groundwater. At this time there does not appear to be a complete exposure pathway for the TCE contamination. TCE near the surface only exceed the ADEC Method Two migration to groundwater cleanup level of 0.020 mg/kg. Soil samples collected at greater depths did exceed the outdoor inhalation cleanup level of 0.57 mg/kg but, due to the significant soil depth, the outdoor inhalation pathway is not complete; therefore, TCE contaminated soils will not be removed under this TCRA.
An estimated 100 cyds of contaminated soil will be excavated & disposed of under the proposed action. All PCB-contaminated soil exceeding the ADEC Method Two cleanup level of 1 mg/kg will be containerized & transported to an approved disposal facility consistent with the offsite rules under CFR 40 121(d)(3).
To verify that cleanup levels have been achieved, excavation confirmation samples will be collected pursuant with the requirements specified in 40 CFR 761.61.
This removal action is consistent with the long-term remedy for the site and will achieve the
cleanup goals to remove PCB contamination above ADEC cleanup criteria and mitigate the
threat to human health and the environment. These measures are appropriate components of
removal actions according to 40 CFR 300.415(e).
Excavation and offsite disposal of the PCB-contaminated soil at a regulated disposal facility is
the only viable, time-efficient option at this site.
This decision document represents the selected TCRA of PCBs in the soil at the FTR269C
COF Parking Area on JBER-Richardson. It has been developed in accordance with CERCLA
as amended, and is consistent with the NCP. Conditions at the site meet the NCP Section
300.415(b)(2) criteria for a TCRA. This decision document is based on the Administrative
Record (AR) for the site. A copy of the AR is available at AK Resources Library and Information Service (ARLIS) located at the University of Alaska Anchorage
(UAA) Consortium Library, 3211 Providence Drive, Suite 111, Anchorage.
|
Louis Howard |
| 7/20/2011 |
Site Added to Database |
A new site has been added to the database |
Mitzi Read |
| 8/4/2011 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (ADEC) has received the Draft 2011 Time Critical Removal Action Memorandum, Proposed FTR269C Company Facility Parking Area, JBER, AK July 2011 for review and comment on July 21, 2011. ADEC has no objection to the JBER-Richardson conducting a removal of PCB-contaminated soil from the proposed FTR269C Parking Area, near the current Building 789.
This site is eligible as a new source area to be addressed by the Federal Facility Agreement. ADEC believes an remedial investigation is necessary to determine fully the nature and extent of the threat to the public health or welfare or the environment caused by the release or threatened release of hazardous substances, pollutants, or contaminants at FTR269C [e.g. trichloroethylene (TCE) and its degradation products]. TCE was found in 6 borings at levels exceeding 18 AAC 75.341(c) Table B1 Method Two migration to groundwater cleanup level of 0.020 mg/kg.
|
Louis Howard |
| 11/1/2011 |
Update or Other Action |
Final TCRA Memorandum received.
This removal action is consistent with the long-term remedy for the site and will achieve the
cleanup goals to remove PCB contamination above ADEC cleanup criteria and mitigate the
threat to human health and the environment. These measures are appropriate components of
removal actions according to 40 CFR 300.415(e).
Excavation and offsite disposal of the PCB-contaminated soil at a regulated disposal facility is
the only viable, time-efficient option at this site.
Compliance with state and federal regulations, to the extent practical, is an overall
requirement for this TCRA. The following federal Applicable or Relevant and Appropriate
Requirements (ARARs) were identified for the site:
• Clean Water Act
• Resource Conservation and Recovery Act
• Toxic Substances Control Act
• Occupational Safety and Health Administration
• Department of Transportation
The following state ARARs were identified for the site:
• Oil and Hazardous Substances Pollution Control regulations
• Alaska Water Quality Standards
• Solid Waste Management regulations
The response actions presented in this TCRA Memorandum are scheduled to begin as soon as
possible to minimize the potential threat to human health and the environment posed by
contamination at the site. Execution of the preferred action remedy will be initiated upon
approval of this TCRA Memorandum.
PCB soil excavation activities will be completed in approximately 3 days unless excavation
confirmation sample results identify additional PCB-contaminated soils. The transport of the
soil to the offsite disposal facility and the final disposal of the soil are expected to be
completed within 30 days of excavation.
JBER is undertaking the proposed removal action as lead agency pursuant to CERCLA,
Section 104(a). In accordance with 40 CFR 300.415(j), onsite removal actions conducted
under CERCLA are required to abate, prevent, minimize, stabilize, mitigate, or eliminate the
release or threat of release of substances hazardous to public health, welfare, and the
environment. ADEC risk-based cleanup levels will be used to indicate when substantial
endangerment to public health, welfare, and the environment has been mitigated, and will be
referenced in regard to CERCLA hazardous substances. JBER followed CERCLA guidance
to evaluate this proposed TCRA.
A delayed action, or no action, will increase the potential for continued endangerment to
public health, welfare, and the environment. Exposure to PCB-contaminated soils exceeding
ADEC cleanup criteria may pose a threat to human health if the use of the site were to change
during the planned future development at the site.
This TCRA Memorandum represents the selected TCRA of PCBs in the soil at the FTR269C
COF Parking Area on JBER-Richardson. It has been developed in accordance with CERCLA
as amended, and is consistent with the NCP. Conditions at the site meet the NCP Section
300.415(b)(2) criteria for a TCRA. This decision document is based on the Administrative
Record for the site. A copy of the Administrative Record is available at Alaska Resources
Library and Information Service (ARLIS) located at the University of Alaska Anchorage
(UAA) Consortium Library, 3211 Providence Drive, Suite 111, Anchorage. |
Louis Howard |
| 11/8/2011 |
Update or Other Action |
Final Removal Action Work Plan addendum received.
This Work Plan Addendum describes the planned activities to be conducted at the FTR269
Maneuver Enhancement Brigade (MEB) Complex, Company Operations Facility (COF)
Parking Area on Joint Base Elmendorf-Richardson (JBER), Alaska. The work described in
this addendum will be conducted in accordance with all plans and procedures outlined in the
Fort Richardson Post Wide Work Plan (U.S. Army Corps of Engineers [USACE], Alaska
District 2010). Appendices to the Post Wide Work Plan include the Site Safety and Health
Plan (SSHP), Field Sampling Plan (FSP), Quality Assurance Project Plan, Environmental
Protection Plan, Storm Water Pollution Prevention Plan, Waste Management Plan (WMP),
Stockpile Construction Plan, Geophysics Investigation Plan, and Munitions and Explosives of
Concern (MEC) Support Plan. An Accident Prevention Plan (APP) detailing the site-specific
safety plans and procedures is attached to this Work Plan Addendum (Attachment 1).
The primary work objective at the COF Parking Area is to excavate contaminated soil in
preparation for construction-related activities and future site users. Project activities include soil sampling, excavation of contaminated soil, and waste management. These activities are designed to identify and remove soil contaminated with polychlorinated biphenyls (PCB) in
concentrations greater than the Alaska Department of Environmental Conservation (ADEC)
Method Two direct contact cleanup level of 1.0 milligrams per kilogram (mg/kg) (Oil and
Other Hazardous Substances Pollution Control, 18 Alaska Administrative Code [AAC] 75
[ADEC 2008]) from areas planned for future construction activities.
This removal action will include the following definable features of work:
• Mobilize all equipment and personnel to the site. Safety signage and truck crossing signs
will be installed prior to and during excavation activities.
• Excavate the area shown in Figure 2 to a depth of 3 feet bgs, thereby removing
approximately 100 cy of soil.
• Collect excavation confirmation samples from the excavation floor and walls to confirm
the removal of PCB contamination greater than or equal to 1.0 mg/kg.
• Excavate additional soil, as necessary, based on excavation confirmation sample results.
• Transport PCB Aroclor 1260-contaminated soil to a permitted treatment, storage, and
disposal facility (TSDF) for disposal.
• Backfill the excavation with clean soil.
• Demobilize all equipment and personnel.
Excavation of soil will be guided by analytical results and field observations. Approximately
100 cy of soil will be excavated. The excavation depth will be 3 feet bgs and extend laterally
30 feet by 30 feet (Figure 2). The estimated 100 cy of contaminated soil will be containerized
into intermodal containers and transported to a permitted TSDF for disposal.
Should potentially hazardous drums or other debris be encountered within the excavation, these items will be removed for further investigation. If MEC or suspected MEC are encountered, then all work will stop until an unexploded ordnance (UXO) technician or explosive ordnance disposal (EOD) personnel evaluates the item. All practices and procedures from the MEC Plan, Appendix H to the Post Wide Work Plan (USACE 2010), will be followed before work continues.
Analytical excavation confirmation samples from both the excavation floor and walls will be
collected at a frequency in accordance with Title 40 Code of Federal Regulations (CFR) Part
761, and specifically the U.S. Environmental Protection Agency (EPA) guidance document
Field Manual for Grid Sampling of PCB Spill Sites to Verify Cleanup (EPA 1986). Samples
will be collected following a 15-foot by 15-foot grid pattern. Subsamples will be collected from
each 15-foot by 15-foot grid block. Each subsample will be spaced 5 feet apart. A maximum
of nine subsamples will be combined into one composite analytical sample.
The proposed excavation area is 30 feet by 30 feet and 3 feet deep, which will result in four
composite samples from the floor and eight from the walls. Samples will be collected and
submitted to SGS of Anchorage, Alaska for analysis with a 1-day turnaround time. All samples will be analyzed by SGS using Methods SW8082 (PCBs) and SW8260 (TCE) in accordance with the FSP, Appendix B to the Post Wide Work Plan (USACE 2010). Although excavation confirmation samples will be analyzed for both PCBs and TCE, the excavation activities will be guided only by the PCB results. |
Louis Howard |
| 11/8/2011 |
Update or Other Action |
Spill Summary Report received from Army to ADEC PERP staff. Estimated 10,000 gallons spilled. Release volume estimated. Plan to excavated about 25 CY and stockpile or ship for thermal treatment. Assigned spill # 11239931001 (case closed and transferred to CS Program 1/5/2012).
FTR 269C construction site. Previously undeveloped area north of intersection of "D" and 5th Streets on JBER-Richardson. This is a known contaminated site. Joint Base Elmendorf-Richardson (Richardson side of installation).
Cause of Spill: Unknown - Former heating oil tank and bldg foundation were discovered during construction activities at the site.
Initial field screening did not indicate presence of contamination. Soil samples collected after tank removal indicate presence of weathered diesel (heating oil). Anticipate excavation of 25 cubic yards of soil to remove the extent of contamination. Soil will either be stockpiled on JBER per 18 AAC 78 or hauled directly to ASR. Excavation could be limited due to location next to building foundation.
Tank was removed, cleaned, and disposed. Soil will either be stockpiled on JBER per 18 AAC 78 or hauled directly to ASR. Excavation could be limited due to location next to building foundation. Treatment will probably occur in April-May 2012.
Historical release from former heating oil tank. Based on analytical data the contamination is weathered diesel fuel (about 1200 mg/kg). The amount of fuel released is unknown as is the date of release. Anticipate that about 25 cubic yards of soil will be excavated and stockpiled pending complete analytical testing. Stockpile will meet requirements of 18 AAC 78 and soil stored pending availability of treatment facility and funding to treat the soil. |
Louis Howard |
| 1/5/2012 |
Spill Transferred from Prevention Preparedness and Response Program |
Spill transferred by PERP staff Michele Sherwood. Spill no. 11239931001; spill date = 11/6/11; substance = diesel; quantity = unknown. |
Louis Howard |
| 1/13/2012 |
Offsite Soil or Groundwater Disposal Approved |
JBER-Richardson emails a request to transport soil from the FTR269C site where they discovered an empty heating oil tank during construction. Tank was probably 40+ years old and was discovered when driving survey stakes to mark the building foundation. Several holes had been cut into the top of the tank and it was partially filled with soil.
Initial field screening did not indicate that contamination was present but they did detect contamination in the analytical samples collected from underneath the tank. Samples were analyzed for GRO/DRO/RRO/PAH/BTEX with only DRO exceeding cleanup levels.
Four of the six analytical samples collected from the excavation exceeded the ADEC migration to groundwater cleanup level for DRO ranging from 445 to 1,210 mg/kg. All other analytes were below cleanup levels. Results in a spreadsheet from SGS laboratory shows only the hits above cleanup levels. Analytes not shown in the table were not detected (BTEX and PAHs). The 6,610 mg/kg DRO result is from the soil removed from the tank and containerized.
Jacobs will attempt to remove the contaminated soil and haul to ASR. Not sure if they can remove all the contamination because the tank was located within about 10 feet of the new building foundation. The entire FTR269C site will be investigated under the PBC contract and we will drill borings and sample the tank site under that contract. Approval to transport granted by ADEC-Based on the information provided in the 1/13/2012 email, in accordance with 18 AAC 75.360 (3)(D), ADEC will approve the transport of an estimated 130 cubic yards of petroleum contaminated soil to ASR for treatment in accordance with their approved facility operations plan. |
Louis Howard |
| 1/2/2013 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 79101 name: JBER-Ft Rich Bldg 789 FTR269C |
Louis Howard |
| 4/22/2013 |
Document, Report, or Work plan Review - other |
Staff commented on the AT035 MEB Complex, COF UST & Soil removal report.
Conclusions and Recommendations
ADEC reviewed and approved, subject to this and other institutional controls, the cleanup as protective of human health, safety, welfare, and the environment at AT035 UST site. No further cleanup is necessary at this site. ADEC has determined, in accordance with 18 AAC 75.325 – 390 site cleanup rules, that cleanup has been performed to the maximum extent practicable even though residual diesel range organics contaminated soil exists on-site. Further cleanup was determined to be impracticable because the remaining contaminated soil is beneath the COF Building foundation.
ADEC will, as part of its approval, modify proposed cleanup techniques or require additional cleanup techniques for the site (following regulations applicable at that time) as ADEC determines to be necessary to protect human health, safety, and welfare, and the environment.
Pursuant to 18 AAC 75.325(i)(1) and (2), notification and ADEC approval is required prior to moving soil that is, or has been, subject to the cleanup rules found at 18 AAC 75.325-.370. At this site, in the future, if soil is disturbed or removed from the site it must be characterized and managed following regulations applicable at that time.
|
Louis Howard |
| 4/22/2013 |
Update or Other Action |
Cleanup complete with ICs granted to UST encountered SE of the COF Bldg. foundation during permitted construction activities. DRO contaminated soil remains but is inaccessible from further excavation without potential damage to the COF foundation. Should the soil become accessible in the future, additional remedial action will be necessary for the petroleum contamination associated with the former UST. PCB and TCE contamination not associated with the UST will be addressed by site AT035. |
Louis Howard |
| 5/28/2013 |
Update or Other Action |
AT035-MEB COF UST and Soil Removal Action Final report received.
The UST encountered southeast of the COF Building foundation during permitted construction activities was successfully removed and recycled in October 2011. In addition, 87.59 tons (approximately 50 cubic yards) of contaminated soil was removed and thermally treated in January 2012. Contamination is still present at the site, as indicated by analytical samples collected during the removal activities. Contaminated soil could not be further excavated without potential damage to the COF Building foundation, which limited the effectiveness of the removal action and the ability to accurately determine the extent of contamination.
The site has been added to the ADEC Contaminated Sites Program and it is recommended that is added to JBER’s Geodatabase. Additional site characterization is necessary to determine the extent of contamination remaining onsite. Based on the current knowledge of the nature and extent of contamination, it is recommended that the site be monitored for natural attenuation; however, subsequent investigation activities may result in additional recommendations.
ADEC reviewed and approved, subject to this and other institutional controls, the cleanup at AT035 UST site as protective of human health, safety, welfare, and the environment. ADEC has determined, in accordance with 18 ACC 75.325 – 390 site cleanup rules, that cleanup has been performed to the maximum extent practicable, even though residual DRO-contaminated soil exists on-site. Further cleanup was determined to be impracticable because the remaining contaminated soil is beneath the COF Building foundation. ADEC, as part of its approval, will modify the proposed cleanup techniques or require additional cleanup techniques for the site (following regulations applicable at that time) as ADEC determines to be necessary to protect human health, safety, and welfare, and the environment |
Louis Howard |
