| Action Date |
Action |
Description |
DEC Staff |
| 12/10/2010 |
Potentially Responsible Party/State Interest Letter |
ADEC M. Sielaff sent EAFB Danny Barnett a state interest letter RE: F-22 Crash 48 miles SW Cantwell, AK Spill# 10239932001.
This letter is to advise you that on November 16, 2010, a pollution incident occurred 48 miles SW of Cantwell, Alaska when an F-22 crashed creating a large hole in the surrounding wetland area. You reported that 1,343 gallons of jet fuel, 13 gallons oil, 31.7 gallons hydraulic fluid, and 19 gallons of polyalphaolefin was on board the aircraft at the time of the accident which you may be financially responsible for. You identified only residual sheening at the crash site and dug a trench to aid in removal of water to access the plane parts . You are using absorbent pads to remove oil and fuel from the water surface. Under Alaska statutes, the State has an interest in this incident and may take appropriate action to minimize the damages that are threatened or which may be cause by this incident.
Alaska Statute, Title 46, authorizes the state government to respond to this pollution incident. Under this Act, if the owner or operator of the source fails to take adequate removal actions, the owner or operator may be held financially responsible for any actions taken by the State. Removal is adequate and being done properly if it is done in accordance with Federal and State statutes and State regulations 18 AAC 75. As long as you continue removal actions adequacy of such actions shall be determined by the undersigned as the project manager.
Please provide a cleanup plan for approval to the project manager for the assessment, removal, and disposal of contaminated soil as outlined in 18 AAC 75.325. Prior to conducting confinnation
sampling of the spill site ADEC must be notified so they may monitor the event. 18AAC75.307
requires final report be submitted within 15 days after cleanup is complete.
Alaska Statute 46.08.070 requires recovery be sought fOI·costs incun"ed by the State in response to this incident, which includes any oversight activities. Please be advised that we may be billing you at a later date for state expenditures associated with this spill. Billable state expenditures include all direct time and materials costs and indirect overhead costs. Billable staff time will comprise all time spent on activities related to the incident, including time spent for site visits, response and report reviews, telephone conversations, and meetings. |
Mark Sielaff |
| 5/9/2011 |
Update or Other Action |
Draft Final F-22 Recovery, Investigation, Remediation, & Restoration Work Plan received. The primary project objective is to locate & recover any additional human remains, the Crash Survivable Memory Unit (CSMU) or “black box” & as much of the aircraft as possible. This includes one engine & the vertical stabilizer, which are believed to be buried within the impact crater area, covered by water.
The secondary objective is to characterize the nature & extent of fuel contamination present at the site. The project team will use the results to provide a Site Characterization Report & Remedial Action Work Plan for USAF & Alaska Department of Environmental Conservation (ADEC) review & comment. The Remedial Action Work Plan will detail steps to address contamination at the site.
Once all aircraft components, debris, & remains are recovered & removed from the site, the nature & extent of any POL contamination at the site will be characterized. The primary environmental concern is contamination related to the petroleum fuel (JP-8) & its constituents that were on board the aircraft at the time of the crash. The site characterization & environmental investigation will be conducted through field screening & analytical sampling of environmental media including surface & subsurface surface water.
Once the nature & extent of contamination is identified, a Site Characterization Report will be provided to USAF & ADEC. Cleanup levels will be proposed in accordance with 18 AAC 75 & estimates of the volume of contaminated media will be provided.
The Remedial Action Work Plan will outline steps to be taken to address site contamination. The plan will be developed based on the volume of contaminated media, fate & transport properties of the contaminants, regulatory limits, & access constraints. Upon concurrence from USAF & ADEC, remediation activities will begin. These may include excavation & offsite treatment or disposal of contaminated soils, onsite bioremediation, or other approaches.
Upon mobilization to site, two surface water samples will be collected from the impact crater. The samples will be submitted to the analytical laboratory for gasoline-range organics (GRO), diesel-range organics (DRO), residual-range organics (RRO), benzene, toluene, ethylbenzene, & xylenes (BTEX) & polycyclic aromatic hydrocarbon (PAH) analysis. Analytical results will be compared to 18 AAC 75 Table C cleanup criteria & provided to USAF & ADEC. The results will be used by the USAF, in conjunction with ADEC, to determine if water from the impact crater may be discharged to the ground surface without treatment.
It was reported that the water in the crater originally had a heavy fuels odor & a light (red) sheen from hydraulic fluid. Very little fuel appeared to be present in the water. Analytical results from a sample of the water from the impact crater reported 29 micrograms per liter (µg/L) of benzene (exceeds the 18 AAC 75 Table C cleanup criteria of 5 µg/L). All other results were reported to be below 18 AAC 75 Table C cleanup criteria.
Contaminated soil will be stockpiled & addressed under the Remedial Action Work Plan, which will be presented to USAF & ADEC for review & comment. Clean soil will be staged adjacent to the excavation & used to contour the area during back fill & restoration operations. All excavation activities will be conducted in a manner that preserves the available topsoil to the extent practicable.
Field screening will be conducted through use of a PID, PetroFLAG® kit, or other screening method based on site conditions & project needs. A minimum of four field screening samples will be collected from each decision unit. As field screening & characterization activities expand to the low debris areas, screening will only be conducted one decision unit in each direction beyond any unit that contained debris or has visual or olfactory indications of contamination. This method will be used to fully delineate the extent of contamination without spending time & material unnecessarily screening areas that would not feasibly contain contamination. If excavation is necessary to characterize contamination in an area, the field screening frequencies outlined in the ADEC Field sampling guidance will be followed.
Environmental media including soil and surface water samples will be collected for analytical testing. Soil samples will be collected at a minimum of two per decision unit at the location of the highest field screening result for that unit. Analytical results will be the basis for the Site Characterization Report and the Remedial Action Work Plan.
It is assumed that Watana Creek is a surface manifestation of the local groundwater aquifer, therefore surface water samples collected from Watana Creek will serve as indicators of potential migration of contamination to groundwater. |
Mark Sielaff |
| 6/2/2011 |
Update or Other Action |
IMPACT CRATER DEWATERING AND TREATMENT PLAN received.
This dewatering and treatment plan was developed to provide guidance in the removal of both petroleum contaminated water as well as underlying clean water to enable the collection of aircraft components within the impact crater. The water system will also treat any water draining from soils removed and stockpiled during debris collection. This plan is an addition to the F-22 Recovery Work Plan, and is designed to work specifically with Section 4.0, Site Characterization Plan.
The crater dewatering and treatment operation will consist of pumping water from the impact crater to primary and secondary settling ponds, manual skimming, filtering, and treatment with granular activated carbon (GAC) and discharge of treated water to adjacent surface soils and vegetative mat.
The impact crater discharge water will be pumped with a 3-inch diaphragm pump into one of four to six primary settling ponds. Conceptual design diagrams are attached. Fuel will be manually skimmed from the surface of the pond as sediment settles. Water will be detained in the primary settling ponds for 12 to 24 hours until visibly clear water is available for pumping to secondary containment ponds. Any visible contamination will be manually skimmed from the secondary containment pond. Water will be allowed to further settle and clarify in the secondary containment pond. Water will then be pumped from the secondary ponds through inline sediment filters into an array of GAC drums. Treated water will be discharged onto adjacent vegetated areas.
System maintenance will include removal of the settled sediment from the containment
ponds and replacing the GAC drums. Sediment will be removed from the containment
ponds and sump regions and transferred to soil stockpile areas, as necessary. GAC drums
will be replaced after each week of operations, or approximately every 80,000 gallons. |
Mark Sielaff |
| 7/6/2011 |
Update or Other Action |
Pre-Draft F-22 Characterization Report memorandum received.
Analytical soil samples were collected & analyzed for diesel-range organics (DRO),
gasoline-range organics (GRO), & residual-range organics (RRO). In addition, 10 percent
of the samples were analyzed for polycyclic aromatic hydrocarbons (PAHs)& benzene,toluene, ethyl benzene & xylene (BTEX) as follows:
• 50 analytical soil samples from field screening locations in the minimal debris areas
• 9 samples from the west, central & east blast areas
• 20 characterization samples for stockpiled soil removed from the crater during debris removal activities
• 10 characterization samples of the crater wall after debris removal
• 6 pre-construction samples under soil stockpile locations 1, 2 & 7
• 2 samples from the November 2010 crater de-watering discharge area
In addition, 7 initial characterization samples were collected in targeted areas prior to debris removal activities to ensure that the selected analytical methods were appropriate & the safety precautions were adequate to address the maximum contaminant concentrations.
Targeted sample locations were as follows:
• 2 samples from stained soil locations directly adjacent to the crater prior to debris removal activities
• 5 samples from soil in or removed from the crater prior to debris removal activities
Contaminant levels in these 50 characterization samples did not exceed the most stringent Method Two cleanup levels. None of the six pre-construction samples exceeded Method Two cleanup levels. One of the two surface samples collected in the 2010 crater de-watering discharge area contained a DRO level of 280 mg/kg.
The two samples collected from targeted stained soil locations & 4 of the 5 samples from the crater (or soil removed from the crater) prior to debris removal activities had contaminant levels that exceeded the Method Two cleanup levels (Table 1). Results from the crater or soil removed from the crater indicated DRO, GRO, naphthalene, benzene, 1- & 2-methylnaphthalene that exceeded most stringent Method Two cleanup levels. The results from the crater do not represent final characterization samples for this area because they were collected prior to sifting for debris; soil has been removed & stockpiled since that time.
The current diameter of the crater is approximately 50’. Two other exceedance locations targeted for sampling were in stained soils directly adjacent to the crater. These locations have been removed & stockpiled. The current concentration of any contamination present will be represented by the characterization of the stockpiled material.
Ten samples characterizing the crater walls after debris removal activities were collected but results have not been received. Results have not yet been received for the nine samples characterizing the blast paths or the 20 samples taken to characterize stockpiled soil that was removed from the crater during debris removal activities. These results are expected to be received on 7 & 8 July.
Water samples were collected from the impact crater prior to de-watering the crater for debris removal. The 'results from this sample indicated ORO, GRO, RRO, naphthalene, 1- & 2-methylnaphthalene, benzo(b)fluoranthene & fluorene exceeded Table C criteria; a heavy sheen was observed on the water. Since that time, over 1 million gallons of water have been removed from the crater & treated in an approved granular activated carbon filtration system. Three samples were collected from Watana Creek, as proposed in the Work Plan, & the results did not exceed, Table C or surface water (total aromatic hydrocarbon [TAH], total aqueous hydrocarbon [TAqH]) criteria.
Preliminary contaminants of concern (pCOC) are DRO, GRO, naphthalene, benzene, 1- and
2-methylnaphthalene. In order to evaluate potential alternative cleanup levels (ACL), nine
samples were collected for total organic carbon (TOC) analysis.
Results from three samples and one duplicate collected at the surface were used to calculate a potential surface ACL under Method Three. Surface soils were collected beneath approximately 6 inches of vegetative mat and organic matter. One surface result was not used because it differed by one order of magnitude from other surface samples. This sample was collected in a location away from the other surface soil samples and appeared to represent a soil type more similar to the subsurface soils.
Results from three samples collected from soil that ejected from the crater were used to calculate a potential subsurface ACL. One subsurface result was not used in the calculation due to contamination in the sample that was indicated by the DRO pattern on the chromatogram |
Mark Sielaff |
| 7/11/2011 |
Update or Other Action |
Characterization Report & Remedial Action Work Plan Addendum received. One of the two surface samples collected in the 2010 crater de-watering discharge area contained a DRO level of 280 milligrams per kilogram (mg/kg). The two surface samples collected from targeted stained soil locations directly adjacent to the crater prior to debris removal activities had contaminant levels that exceeded the Method Two cleanup levels. Results indicated DRO, GRO, 1-, & 2-methylnaphthalene concentrations that exceeded most stringent Method Two cleanup levels.
Following debris removal activities, the diameter of the crater expanded to approximately 50 feet. These two exceedance locations have been removed & stockpiled. The current concentration of any contamination present will be represented by the characterization of the stockpiled material.
Nine samples were collected to characterize the blast paths. Results from the western & eastern blast paths did not exceed Method 2 cleanup levels. The results for 3 of the 4 samples in the central blast path did exceed Method 2 cleanup levels with a maximum DRO level of 5400 mg/kg.
Prior to debris removal from the crater, 4 of the 5 samples from the crater (or soil removed from the crater) indicated DRO, GRO, naphthalene, benzene, 1- & 2-methylnaphthalene concentrations that exceeded most stringent Method Two cleanup levels. These 4 exceedence results from the crater do not represent final characterization samples for this area because they were collected prior to sifting for debris; soil has been removed & stockpiled since that time. The current concentration of any contamination present in that material will be represented by the characterization of the stockpiled material
Ten confirmation samples in the crater were collected after debris removal activities were completed in accordance with the ADEC Draft Field Sampling Guidance for excavations at a rate of 1 per 20 linear feet of excavation or higher. Contaminant concentrations did not exceed Method Two cleanup levels in any of the 10 samples.
Stockpiles (DRO concentration)
1 22 cy 1,000 mg/kg, 1,900 mg/kg
2A 6 cy 1,600 mg/kg 2,200 mg/kg
2B (includes 3) 17 cy 2,000 mg/kg 2,200 mg/kg
4 33 cy 1,700 mg/kg (awaiting 2 other sample results)
5 4 cy 320 mg/kg 440 mg/kg
7 (7 piles) 30 cy 60 mg/kg, 120 mg/kg, 180 mg/kg, 240 mg/kg, 250 mg/kg, 250 mg/kg, 310 mg/kg & 340 mg/kg.
Water samples were collected from the impact crater prior to de-watering the crater for debris removal. The results from this sample indicated DRO, GRO, RRO, naphthalene, 1- & 2-methylnaphthalene, benzo(b)fluoranthene & fluorene exceeded AOEC Table C criteria; a heavy sheen was observed on the water. Since that time, over 1 million gallons of water have been removed from the crater & treated in an approved granular activated carbon filtration system. Three samples were collected from Watana Creek, as proposed in the Work, Plan (USAF 2011), & the results did not exceed ADEC Table C or surface water (total aromatic hydrocarbon [TAH], total aqueous hydrocarbon [TAqH) criteria.
Surface/Sub-surface ACLs (mg/kg)
1-Methylnaphthalene 1,700/48
2-Methylnaphthalene 1,600/47
Naphthalene 470/79
Benzene 3.1/0.1
Diesel-Range Organics 10,300/2,000
Gasoline-Range Organics 1,400/2,000
Residual-Range Organics 10,000/22,000
Analytical results will be compared to the proposed Method Three ACLs & used to guide further action. Surface soils adjacent to the crater are on top of or mixed in with the high organic matter surface soils. The elevated TOC levels in this soil should prevent the migration of contamination below the Method Three surface ACL through the soils to the GW. Soils in the crater are at or below the adjacent GW level. Contaminant concentrations in this subsurface soil will be compared to the subsurface ACLs.
Blast path corridors are areas visually identified by leveled vegetation & soil/debris cast from the crater. Soils in these areas were sampled at locations identified by elevated field screening results. Analytical results in these areas will be compared to the proposed surface ACL. None of the surface sample results exceed the ACLs. |
Mark Sielaff |
| 7/18/2011 |
Update or Other Action |
Acting DoD Section Manager Guy Warren emailed Mark Prieksat. Louis Howard (907-269-75S2) will be overseeing this site for the Contaminated Sites Program. Please forward any correspondence regardingthis site to him. I have cc'd him on this e-mail. |
Guy Warren |
| 7/18/2011 |
Update or Other Action |
Email from Mark Sielaff to Mark Prieksat USAF PCAF 673 CES/CEANR. RE: Site Visit Mtg. Notes and Revised Work Plan.
Your statement had me at 12:30 PM on July 12, 2011 as arrival time to the crash site, so I adjusted my time to coincide with yours. After you complete removal of surface contaminates adjacent to Watana Creek from the blast path corridors (ejected material from F-22 crash) this case will be transferred to Contaminated Sites (C5).
A letter of the transfer to CS will be sent upon completion of cleanup. Approval of the monitoring wells is a C5 function (as stated on site). You will also need to provide C5 with the information you used to get your method three values.
John Halverson is currently away from the office at this time, but Guy Warren is in charge in his absence and will aid you with any questions you may have. Good job on your dewatering system and progress made so far. |
Mark Sielaff |
| 8/28/2011 |
Offsite Soil or Groundwater Disposal Approved |
About 47 cubic yards of JP-8 contaminated soil is containerized in supersacks and will be transported from the F-22 crash site to JBER-Richardson for temporary storage in a lined/covered containment cell until an appropriate disposal mechanism can be determined.
Approved for transport from site to JBER. |
Louis Howard |
| 9/21/2011 |
Site Added to Database |
A new site has been added to the database |
Mitzi Read |
| 9/21/2011 |
Spill Transferred from Prevention Preparedness and Response Program |
Spill transferred by PERP staff Mark Sielaff. Spill no. 10239932001; spill date = 11/16/10; substance = 1,343 gallons JP8, 13 gallons oil (mi-L-7808K), 31.7 gallons hydraulic fluid (mil-H-8328-2); 19 gallons polyalphaolefin (milo-PFR-87252). |
Mitzi Read |
| 10/3/2011 |
Meeting or Teleconference Held |
ADEC (SW & CS), JBER-Richardson and contract staff met at ADEC. RE: F-22 RECOVERY SOIL LAND FARMING AND DISPOSAL MEETING. Land farming and disposal of the F22 soil at the old Fort Richardson landfill was discussed.
Requirements for land farming or disposing in the old Ft. Rich landfill:
- 2010 Groundwater Monitoring Report to ADEC
- would need to be a lined land farm
- dispose of as inert waste in unlined cell with results <250mg/kg
- Need standard disposal permit
Other possibilities:
- Dispose of soil at Eielson AFB (after land farming to <250mg/kg)
- Dispose of soil at MUNI landfill (after land farming to <1000mg/kg) if AF Security will allow
ADEC needs more details on the land farming operation as well as disposal methods before moving forward
USAF requested Jacobs begin drafting land farming and disposal work plan
- Land farm work plan will include a lined cell
|
Louis Howard |
| 1/26/2012 |
Update or Other Action |
F-22 Recovery, Investigation, Remediation, & Restoration Report received. This Report describes recovery, contaminant investigation, remediation, & restoration activities completed in 2011 at the F-22 Recovery Site in remote Alaska where, on 16 November 2010, an operational F-22 aircraft crashed. Initial U.S. Air Force (USAF) recovery operations were conducted immediately after the incident but could not be completed due to weather conditions & snow cover at the site. The F-22 was carrying fuel & other petroleum, oil, & lubricant products.
The primary project objectives of 2011 work activities were to locate & recover human remains, personal property, & as much of the aircraft as possible. The secondary objectives were to characterize the nature & extent of fuel contamination present at the site, remediate the contamination, & restore the site. Recovery efforts were conducted within a grid system that encompassed the impact crater, adjacent creek, & surrounding terrain. The crater was filled with GW, which necessitated the removal & treatment of nearly 2 million gallons of water during recovery operations. Aircraft components & debris were excavated from the crater & collected from the ground surface, sorted & weighed, then transported offsite. All human remains & personal effects that were recovered were transported to Joint Base Elmendorf-Richardson (JBER). Aircraft parts were manually collected from soil that was excavated from the crater.
Approximately 75 percent of the aircraft by weight was recovered & transported to JBER. Approximately 140 cubic yards of soil were excavated from the impact crater during aircraft recovery efforts. Excavated soil was placed into lined stockpiles & later sampled to determine the nature & extent of contamination. The site investigation revealed limited presence of fuel compounds in the immediate vicinity of the crater & along two blast path corridors.
Sample results indicated that contaminant concentrations exceeded the Alaska Department of Environmental Conservation (ADEC) Method 2 cleanup levels in soil samples collected from the bottom of the crater at depths up to 12 feet beneath the water table. Sampling determined that about 30 cubic yards of soil contained contamination in excess of the approved cleanup levels; this soil was transported to JBER for further remediation. The remaining 110 cy of soil were placed into an onsite subsurface soil deposition area about 22 feet above the crater in an upland area underlain by bedrock. Surface water & GW samples (July 2011 & August 2011) indicated that contamination was not migrating from the soils to GW or nearby Watana Creek. Additional GW sample collection is planned for Summer of 2012. All water samples will be analyzed for DRO, GRO, BTEX, & PAHs to allow for calculation of TAH & TAqH results for comparison to suface water criteria.
The site was restored by backfilling & compacting the crater & de-watering treatment cells with clean soils & overburden. Soil that contained contaminants at concentrations less than approved cleanup levels was left on site but covered with a minimum of 6 feet of other soil. A reinforced drainage swale was constructed across the backfilled area to minimize the potential for erosion. Bare & disturbed ground surfaces were hydro-seeded &/or covered with topsoil, tundra mat, & mulch that was preserved during initial site clearing activities. |
Louis Howard |
| 2/14/2012 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft F-22 Recovery, Investigation, Remediation and Restoration Report Joint Base Elmendorf-Richardson, AK dated December 2011.
ADEC concurs with the conclusions that the primary and secondary objectives have been met. The site is in long-term monitoring to ensure that residual contamination in the groundwater does not impact Watana Creek and existing site conditions continue to be protective of human health, welfare, safety and the environment. Sampling beyond 2012 may be required to ensure these conditions remain protective. Soil removed from the site and stored within a containment cell located at JBER will need to be addressed in an approved treatment plan.
|
Louis Howard |
| 9/24/2012 |
Update or Other Action |
Pre-Draft 2012 Recovery Site Groundwater Monitoring Summary report received.
This report describes the results of the groundwater and surface water sample collection
activities conducted at the F-22 recovery site located approximately 130 miles northeast of
Joint Base Elmendorf-Richardson (JBER), Alaska, and 47 miles southeast of Cantwell,
Alaska. This work was conducted by Jacobs Engineering Group Inc. (Jacobs) for the U.S. Air
Force (USAF) under Contract No. W912UM-07-D-0002, Task Order ZJ01.
Summary of Site Visit and Sample Results
On 24 July 2012, a field team mobilized to the site via helicopter. The objective of the field
effort was to evaluate the condition of groundwater and surface water at monitoring points
established as part of the 2011 remediation and restoration activities.
A total of two groundwater and three surface water samples were collected in accordance with the F-22 Recovery, Investigation, Remediation, and Restoration Work Plan (USAF 2011b) and the
F-22 Characterization Report and Work Plan Addendum (USAF 2011a) without deviation.
Monitoring results show that all target analytes in both the groundwater and surface water samples are below cleanup levels as provided in the Title 18 Alaska Administrative Code Chapter 75 (18 AAC 75) Table C (Alaska Department of Environmental Conservation [ADEC] 2008a), surface water (total aromatic hydrocarbon [TAH], total aqueous hydrocarbon [TAqH]) criteria (ADEC 2008b), and are consistent with the 2011 results. Although laboratory contamination contributed to polycyclic aromatic hydrocarbon (PAH) detections, the overall data quality is acceptable and no results were rejected. |
Louis Howard |
| 9/28/2012 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the F-22 Technical Memorandum draft.
Staff requested clarificaiton on the missing: original laboratory report with a copy of the analyst signature, chain of custody form, laboratory sample receipt form, and laboratory QC information. Staff requested clarification on additional sampling scheduled for 2013 field season.
|
Louis Howard |
| 1/2/2013 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 79165 name: JBER-Elmendorf F-22 Raptor Crash Site |
Louis Howard |
| 5/28/2013 |
Update or Other Action |
Draft GW monitoring work plan received.
The goal of this project is to conduct semiannual contaminant monitoring of groundwater and
surface water at monitoring points established as part of the 2011 remediation and restoration
activities. In conjunction with meeting this goal, the project will also involve conducting a
visual land-use control (LUC)/institutional control (IC) inspection and managing all
investigation-derived waste (IDW).
It is estimated that approximately 1,343 gallons of aviation fuel, 13 gallons of oil,
31.7 gallons of hydraulic fluid, and 19 gallons of polyalphaolefin were onboard the F-22
Raptor prior to the crash on 16 November 2010. Therefore, these are all considered
contaminants of concern for the site. A chemical analysis of the groundwater and surface
water at the site will be conducted to determine whether contaminants of concern have
migrated to nearby water sources.
During 2011 field activities, a total of approximately 140 cubic yards of soil were excavated
from the impact crater. Soil samples collected from the bottom of the impact crater at depths
up to 12 feet beneath the water table suggested contaminant concentrations exceeding the
ADEC Method 2 cleanup levels may remain at this depth. The impact crater was backfilled,
graded, and seeded with native grasses to restore the damaged area and prevent erosion. A
visual LUC/IC inspection is being conducted at the site to determine the level of recovery at
the site and to determine whether the site poses a potential risk to recreational users.
Groundwater samples – will not be field screened. Samples will be submitted to the analytical laboratory for GRO (AK101), DRO (AK102), RRO (AK103), and VOCs (SW8260) analyses.
Surface water samples – will not be field screened. Samples will be submitted to the analytical laboratory for GRO (AK101), DRO (AK102), RRO (AK103), and VOCs (SW8260) analyses.
Visual land-use inspection – Jacobs personnel will inspect the area using the visual land-use inspection checklist included in Appendix A. |
Louis Howard |
| 2/10/2014 |
Update or Other Action |
SS105 GW Monitoring Annual Sampling Report Summary received. The objectives for the field efforts were to evaluate the condition of groundwater and surface water at five monitoring points, and to perform visual inspections of the site.
July 2013
Five primary field samples and one field duplicate were submitted to TestAmerica in Anchorage, Alaska as a single sample delivery group on 30 July 2013 before being sent to TestAmerica in Tacoma, Washington. All coolers and samples were received in good condition and below 4 degrees Celsius at the Tacoma TestAmerica laboratory. All sample results were below the groundwater cleanup levels of Title 18, Alaska Administrative Code, Chapter 75 (8 AAC 75), Table C (ADEC 2012a) and surface water criteria for total aromatic hydrocarbons (TAH) and total aqueous hydrocarbons (TAqH) (ADEC 2012b). Validated sample results are included in Table 1.
September 2013
Five primary field samples and one field duplicate were submitted to TestAmerica in Anchorage, Alaska as a single sample delivery group on 13 September 2013. Samples were stored overnight in a refrigerator at Jacobs, packaged, and brought to the Anchorage laboratory before being sent to TestAmerica in Tacoma, Washington. Samples and coolers were received in good condition and below 4° C at the Tacoma TestAmerica laboratory. All sample results were below the 18 AAC 75, Table C groundwater cleanup levels (ADEC 2012a) and surface water criteria for TAH and TAqH (ADEC 2012b). Validated sample results are included in Table 2.
Visual Site Inspection
A visual site inspection was performed at SS105 on both 30 July and 12 September 2013 to
evaluate site conditions and look for signs of unauthorized access to the subsurface of the
area containing the aircraft impact crater. SS105 is a gently sloped area upgradient of Watana Creek. Noticeable site features include a drainage swale across the face of the slope and several large boulders along the Watana Creek Trail. Site photographs of the observations described below are included in Attachment 2. Site inspection checklists from 30 July and 12 September 2013 are presented in Attachment 3.
At the times of the site visits, grasses and other native vegetation covered most of SS105 and showed no signs of stress. No evidence of unauthorized site access to subsurface soil was observed during either site visit. The soil at the site was not eroded, contained no ponded water, and appeared to be structurally intact. Vegetation in the area showed no signs of stress and appeared healthy. Several small pieces of metallic and carbon fiber were observed along the slope at the site and around Watana Creek.
Plywood, 2-inch by 4-inch planks, and 4-inch by 4-inch planks were present at the location of the former camp, where field personnel were previously housed during site work. In July, the wood was collected and staged in a central location. At the conclusion of both the July and September monitoring events, many pieces of wood debris, within the constraints of available helicopter space and weight loading requirements, were loaded into the helicopter and transported to Anchorage for disposal at the Anchorage Municipal Landfill. A photograph of the wood that remains onsite is included in Attachment 2. |
Louis Howard |
| 2/21/2014 |
Document, Report, or Work plan Review - other |
Staff provided comments on the groundwater monitoring annual sampling summary.
1st Paragraph
The following text should be added to the last sentence: “This Annual Sampling Summary was prepared by qualified persons, as required by Title 18 of the Alaska Administrative Code (AAC) Chapter 75 Section 360 (18 AAC 75.360) and defined in 18 AAC 75.990(100). The field efforts were conducted by or directly supervised by “qualified persons” who are listed in Appendix “X” of the document.” The final approved July 2013 monitoring work plan WS #7 did not list who the field samplers were to be – “TBD” was all that was given. Please provide the names and information of these staff that are “qualified persons” as defined by 18 AAC 75.990(100) and these must be specific dates that the degree was obtained [i.e. December 2000 or January 2001 as well as years and months of full-time work experience (minimum 12 months) that was after the degree or “equivalent” was obtained.].
Monitoring Well Access and Bailing
Page 2
3rd Paragraph
The text states: “Each well was purged by removing at least three casing volumes of water and samples were collected using a separate disposable bailer for each monitoring well.”
Page 3
3rd Bullet
The text states: “Three 40-milliliter vials preserved with HCl were used for volatile organic compound (VOC) analysis by Method SW8260.”
Please note, in the future for all monitoring of groundwater at this site and any other JBER-Elmendorf/JBER-Richardson site, bailers shall NOT be accepted for volatile organic compounds (BTEX or GRO) or any other air sensitive parameters. Please amend all future work plans UFP-QAPPs (WS #21 Project Sampling SOP References Table) to delete bailers from the referenced sampling equipment and use the appropriate sampling equipment as specified by the ADEC Draft Field Sampling Guidance (May 2010).
ADEC Draft Field Sampling Guidance (May 2010):
Page 29
IV. Groundwater Guidelines
A. General Guidelines
“Peristaltic pumps (section D2 of Groundwater Sample Equipment) and bailers (section D1) are NOT the preferred method for the collection of volatiles or other air sensitive parameters.
Rather the use of bladder pumps (section D3), positive pressure submersible pumps (section D4), gear pumps (section D5), passive diffusion bag samplers (section D6), or samplers like HydraSleeve (section D8) or Snap Samplers (section D9) are preferred to reduce the loss of volatiles during sampling.”
Page 34
Disadvantages
• “Cannot provide reliable or reproducible data for air sensitive parameters, e.g., dissolved oxygen, pH, carbon dioxide or iron and its associated forms.
• Volatile organic analytical results may be biased low (due to aeration) and metals results may be biased high (due to turbidity).”
ADEC Laboratory Data Review Checklist
12/2/2013
Laboratory Report Number 580-40299
Angela DiBerardino (project chemist) is not listed in the Final Groundwater Monitoring Work Plan Appendix A Resumes section as a “qualified person”. Please provide information which shows that she meets the minimum requirements of 18 AAC 75.990(100) for a “qualified person”.
Groundwater Sampling Data Sheet
KWM and CAG as well as DS and CG are listed as the samplers for the site. It is assumed by ADEC that KWM and DS directly supervised CAG/CG if they were not a “qualified person” as defined by 18 AAC 75.990(100).
Onsite staff are Kevin Maher and Courtney Gritsch. Courtney Gritsch is not listed in the Final Groundwater Monitoring Work Plan Appendix A Resumes section as a “qualified person”. Please provide information which shows that she meets the minimum requirements of 18 AAC 75.990(100) for a “qualified person” or provide a written statement that she was directly supervised by Mr. Maher while they were both onsite during sampling activities.
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Louis Howard |
| 4/22/2014 |
Document, Report, or Work plan Review - other |
Staff provided comments on the responses to ADEC's comments on the GW tech memo.
The 2013 groundwater technical memorandum for SS105 (F-22 Raptor Crash site) may be finalized, with the caveat that ADEC still has concerns regarding the Air Force's sampling equipment choices for future groundwater sampling at SS105 with bailers.
1) ADEC disagrees with the Air Force's responses to ADEC's comments regarding continued VOC (BTEX)/GRO sampling with bailers at monitoring wells for 2014 and beyond. ADEC will not approve future work plans with bailers being used for VOC (BTEX) and GRO sampling at the F-22 crash site. Be aware that ADEC will not accept the data generated with bailers for statistical/closure purposes (See comment #2 below).
2) If the Air Force continues to use bailers in monitoring wells, despite ADEC comments to the contrary, the results will be qualified as biased low and not accepted by ADEC for closure purposes nor use for any trend analysis or statistics. Just because you did it incorrectly with bailers for the last two years (and ADEC did not catch it at the time of the work plan review) does not meant you need to continue to sample groundwater with the wrong sampling device in the future.
3) All previous sampling events from early sampling events were with bailers and the low detection of BTEX/GRO is not surprising given the equipment used. Consequently, the results will be considered biased low due to sampling equipment limitations. ADEC has required the use of bailers cease being used at other federal facilities when groundwater analyses includes BTEX and other VOCs as well as GRO. At some of these more remote facilities (e.g. Cape Romanzof, Sparrevohn, Tatalina, Pribilof Islands), they manage to fly in the proper equipment for groundwater sampling without any issues. Plan and budget your field sampling activities without bailers in the future at this site.
Despite statements to the contrary made by JBER in its responses to ADEC's comments, JP-8 does contain significant amounts of BTEX based on 63 samples of JP-8 fuel analyzed as part of the 1996 Howard Mayfield report "JP-8 Composition and Variability" Armstrong Laboratory, Tyndall AFB, FL (AL/EQ-TR-1996-0006).
Benzene ranged from 1.4 mg/L to 4,950 mg/L, (Table C 0.005 mg/L) Ethylbenzene ranged from 19 mg/L to 3,630 mg/L, (Table C 0.7 mg/L) methyl benzene (toluene) ranged from 0.9 mg/L to 6,390 mg/L (Table C 1.0 mg/L) m&p xylenes ranged from 0 mg/L to 15,300 mg/L (Table C 10 mg/L) o xylene ranged from 460 mg/L to 7,130 mg/L.
JP-8 fuels range from C6 to C18
ADEC: GRO is defined as C6 to C10, DRO is defined as C10 to C25
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Louis Howard |
| 6/26/2014 |
Document, Report, or Work plan Review - other |
Staff provided comments on the WP addendum dated May 22, 2014.
After review of the proposed changes listed in the addendum (and below), ADE has no comments and will approve the changes as submitted in the Technical Memorandum.
"The purpose of this addendum IS to identify that a submersible pump will be the primary form of
groundwater sample collection. Backup sampling equipment will be mobilized and used in the event
of submersible pump failure to ensure samples are collected. Backup sampling equipment for the
collection of VOCs and GROs will be a HydraSleeve and backup equipment for the remaining test
parameters (ORO, RRO, and PAHs) will be a disposable bailer. No additional changes to the work
plan are needed" |
Louis Howard |
| 10/15/2014 |
Update or Other Action |
Technical Memorandum received for sampling at the site.
Previous surface water and groundwater monitoring events occurred in 2011, 2012, and 2013. Target analyte results have been nondetect or below cleanup levels for all historic monitoring events, as specified in the 18 AAC 75, Table C Groundwater Cleanup Levels (ADEC 2012a) and 18 AAC 70 water quality standards (ADEC 2012b).
The results from the July 2014 monitoring effort are consistent with historical results. No effect on sample results was noted due to the change in 2014 groundwater sampling equipment. Based on the results from the July 2014 sampling event, in addition the historical data set, no groundwater or surface water contamination is present at the F-22 Recovery Site. It is recommended that an evaluation of the sampling program occur following the September 2014 sampling event. If September 2014 results are consistent with the historical data set, additional groundwater and surface water sampling may not be needed. |
Louis Howard |
| 11/4/2014 |
Document, Report, or Work plan Review - other |
Staff provided comments on the F-22 Recovery Site July 2014 Site Monitoring Summary, JBER-Elmendorf, Alaska dated November 3, 2014
ADEC agrees with the recommendation to discontinue monitoring after the September 2014 sampling event, if there are no exceedances of groundwater cleanup levels or water quality criteria and the data quality is acceptable.
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Louis Howard |
| 7/8/2015 |
Update or Other Action |
Draft decision document received for review and comment.
Based on soil, groundwater, and surface water results, potentially remaining soil contamination is not migrating offsite, and no groundwater or surface water contamination is present at the site. Therefore, the risk of incidental exposure to current and future land users is not likely.
Based on the current conditions at the F-22 Recovery Site SS105, it has been determined that
no significant risk or threat to human health or the environment exists. Therefore, no further
action under State of Alaska regulations (Alaska Oil and Hazardous Substance Pollution Control Act, 18 AAC 75, revised 1 October 2014) is recommended. |
Louis Howard |
| 9/15/2016 |
Cleanup Complete Determination Issued |
Staff reviewed the environmental records at the site & it was determined that the contaminant concentrations remaining at SS105 do not pose an unacceptable risk to human health or the environment & no further remedial action will be required unless new information becomes available that indicates residual contaminants may pose an unacceptable risk.
Pursuant to 18 AAC 75.325(g), when detectable contamination remains on-site following a cleanup, a cumulative risk determination must be made that the risk from hazardous substances does not exceed a cumulative carcinogenic risk standard of 1 in 100,000 across all exposure pathways & does not exceed a cumulative noncarcinogenic risk standard at a hazard index of one across all exposure pathways. Based on a review of the environmental record, ADEC has determined that residual contaminant concentrations meet the human health cumulative risk criteria for residential land use. Due to the remote location of the site, the current land use is limited to the occasional recreational user such as ATV riders & hunters.
This determination is in accordance with 18 AAC 75.380 & does not preclude ADEC from requiring additional assessment &/or cleanup action if future information indicates that contaminants at SS105 may pose an unacceptable risk to human health, safety, or welfare or to the environment.
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Louis Howard |
