| Action Date |
Action |
Description |
DEC Staff |
| 3/26/1993 |
Update or Other Action |
DOD & ADEC joint Technical Memorandum of understanding signed concerning the Base wide Groundwater (GW) signed by: ADEC Jennifer Roberts RPM & USAF Joseph Williamson Chief Environmental Programs & Restoration. Due to the base wide 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 and 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. NOTE to File: “free product” means a concentration of a hazardous substance that is present as a nonaqueous phase liquid; for purposes of this paragraph, a “nonaqueous phase liquid” is a liquid that is not dissolved in water. Soil contamination would be addressed at the source areas. NOTE: addressed at the source areas is interpreted by ADEC as removal through excavation or active treatment systems (e.g. high vacuum extraction, bioventing, etc...). |
Jennifer Roberts |
| 1/19/1995 |
Update or Other Action |
OU5 Groundwater (GW) Modeling Report received. The objectives of the modeling task were to: Evaluate the movement of contaminants across Elmendorf AFB (EAFB) and within Operable Unit (OU) 5; Predict migration over the next 30 years; and Determine if selected receptor points along Ship Creek and an unnamed beaver pond will be impacted. A 3 dimensional finite element model (SALT) was selected because of its versatility in handling complex geology and boundary conditions. It was modified to improve the program's efficiency, to include contaminant decay and site specific boundary conditions along Ship Creek. This revision was called SALT 3 consists of GW flow and contaminant transport models. The hydrogeology of the modeled area was evaluated using lithologic data collected from all available boreholes within the modeled area and water level data collected from shallow water table monitoring wells in March and September 1993.
After a review of the data from September 1993 GW sampling and available OU 1, 2, and SERA site data, benzene and trichloroethene (TCE) were selected as representative compounds due to their potential health impacts. Concentrations in the recharge over the water table was set to zero except for at source areas. Since improvement in soil quality is expected over time, the sources were assumed to cease contributing benzene and TCE to GW after 5 years. All levels in the recharge zone were set to zero at the end of the first 5 years.
The conclusions show benzene and TCE will migrate toward the south and decline over time. Because of infiltration, there may be some localized areas that experience a temporary increase in level as a "pulse" migrates toward the south. Benzene will be detectable in GW for over 20 years, however, the levels in GW base wide should be below the MCL after 15 years (1993-2008). TCE levels will be detectable in GW after 30 years (2023) and should be less than the MCL base wide after 20 years (2013). |
Jennifer Roberts |
| 4/18/1995 |
Update or Other Action |
Air Force AF memo: 18 April 1995 Underground Storage Tank (UST) Meeting. Elmendorf AFB will accomplish the following actions regarding UST Projects. These actions are based upon conversation between, John Mahaffey, Larry Opperman and yourself. EAFB will make every effort to accomplish a clean closure of a UST removal site if possible. UST removal locations requiring cleanup action will be transferred into the State-Elmendorf Environmental Restoration Agreement (SERA).
A list of sites requiring cleanup will be coordinated with your office. The presumptive remedy for contaminated UST sites in the outwash plain only will be bioventing technology. Contaminated soils exceeding cleanup levels may be placed back into the excavation only if the site assessment (SA) indicates a need for further cleanup action. Contaminated UST sites not in the outwash plain will require further investigation to determine appropriate cleanup options. We will make every attempt possible to assure new USTs or new aboveground tanks are not installed in any way that would hamper future access for cleanup. The project will first accomplish removal of all of the USTs. SA information will be used to prioritize sites for cleanup using existing project funds.
Additional funding will be requested to complete cleanup if available. Sites not addressed for cleanup due to exhausted funding will be placed into SERA Phase IV. John Halverson signed on April 21, 1995. Memo was signed by Douglas G. Tarbett, Maj, USAF, Chief, Environmental Compliance. CC: 3 WG/JA and 3 SPTG/CE. |
John Halverson |
| 10/17/1996 |
Update or Other Action |
Air Force memo: Restricted Use of the Shallow Aquifer on EAFB signed by William R. Hanson P.E. GM-14 Chief Environmental Flight dated October 17, 1996 Memorandum for 3 SPTG/CEC/CEO from 3 SPTG/CEV
1) Due to the contamination & commitments to EPA/DEC the use of the shallow aquifer for any purpose on is not allowed. Attached Facilities Board minutes-03/29/1994 0930 Item 9 has Mr. William Hanson, briefing the Board on the policy to not use the shallow aquifer due to contamination. The Board approved this policy. Minutes approved by Thomas R. Case Brigadier General USAF Commander. The IRP has RODs for OUs 3 & 6 which require, the aquifer remain unused. 2) Personnel in the review process within CES must be aware of these policies & review them on a recurring basis. It is imperative this restriction be recognized & observed during engineer reviews & operations. |
Louis Howard |
| 7/10/1997 |
Document, Report, or Work plan Review - other |
ADEC Tim Stevens sent letter to Air Force John Mahaffey. RE: Review of Site Evaluation & Biostudies for SERA Phase V sites. 97 Work Plan.
The following are the Alaska Department of Environmental Conservation, Storage Tank Program’s comments on the SERA Phase V Work Plan:
General: GW monitoring wells will be required at all sites where contamination has reached the GW. ADEC is requiring MWs be installed within the known hot spot of the former UST or POL excavation & within 100 yards down gradient of the site. If existing MWs exist within 100 yards & down gradient of the site they may be used in lieu of installing a new down gradient well. Sampling of the contaminated GW is needed to help the department evaluate the levels & the extent of GW contamination as result of releases from the former UST & POL sites. Periodic GW sampling will be required to help ADEC determine the effectiveness of the corrective action method being implemented. GW samples should be tested for BTEX, GRO & DRO using analytical methods listed in, Table 1, Part B, of the UST Procedure manual. At sites involving releases from waste oil tanks, GW samples shall test for the presence of total chlorinated solvents & PCBs in addition to the standard AK methods if these compounds were detected in the soil samples.
General: The AF is proposing to test for the levels of BTEX in soil using the EPA 8020 analytical method. ADEC’s UST Procedure Manual, dated September 22, 1995, recommends the AK 101 method with methanol field preservation. Using this method may result in a cost savings for the AF because AK 101 analytical method can be used to detect both BTEX & gasoline constituents.
General: On sites where the bioventing is not selected as the presumptive correction action the AF will be required to develop another corrective action plan & submit a work plan for ADEC’s review.
General: It appears contractors performing UST closures for the AF have returned excavated soils containing high levels of contamination back into the excavation. In the past ADEC has allowed the Air Force to backfill the excavation with contaminated soils if the soils slightly exceeded the AK Cleanup Matrix (ACM) level for the site. On many sites soils exceeding this threshold where return to the excavation, eg., ST 509 (AFID 105), ST 516 (AFID 154), ST 522 (STMP 431), ST 523 (AFID 16), ST 524 (AFID 149), ST 525(AFID 330), ST 528 (AFID 857), ST 530 (AFID 893), ST 531 (STMP 240), ST 532 (STMP 243), ST 533 (STMP 246), ST 534 (STMP 300) & ST 535 (STMP 428). At some sites lab samples were not collected & analyzed from the stock pile. Soils were returned to the excavation has positive PID readings, eg., ST 515 (AFID 580). These 2 practices are in VIOLATION of our agreement & SHALL be discontinued.
General: The ACM level determined by the site assessment for all sites included in the SERA Phase V project may change if information gathered during this phase of investigation indicates data used to determine the ACM score was incorrect. Please resubmit a revised ACM score sheet for each site after completing this phase of work. Please note the ACM score sheet used in this report has been updated.
Section 3.0: FIELD INVESTIGATION
The chart on page 3-1 list Louis Howard as the ADEC member of the project team. I have spoken with Mr. Howard about his involvement. He requests that his name be removed from the project team & replace with Timothy Stevens of the ADEC Storage Tank Program.
Section 3.2.1: Initial Soil Boring:
ADEC disagrees with the AF’s contention that a bioventing system cannot be installed if contamination exist within 35 feet of a building that might accumulate vapors. ADEC contends that the AF could construct a vapor recovery system to collect hydrocarbon vapor before vapors could enter the building. ADEC doesn’t necessarily agree with the statement that the contamination soil layer would have to exceed 2 feet in depth to be cost effective to use bioventing as a corrective action. Many factors go into determining the cost effectiveness of a remediation system including: contaminant levels, proximity of the contaminated soil to the water table, depth below the ground surface & the amount of contaminated soil to be remediated. The depth of the contamination layer should not be a sole determinant as to whether bioventing is cost effective for particular site.
See site file for additional information.
|
Tim Stevens |
| 7/28/2002 |
Update or Other Action |
ADEC (CS Program S. Bainbridge, Leslie Pearson PER Program) and Air Force (Daniel Barnett) signed the Operational Agreement (OA) concerning presumptive remedies for cleanup of certain petroleum oil and lubricant releases on the outwash plain portion of Elmendorf AFB, Alaska. This OA establishes and describes pre-approved presumptive remedies but does not establish an exclusive set of cleanup options and nothing in the memorandum prohibits EAFB from seeking or obtaining ADEC approval to implement alternative release response and remedial action plans.
For new POL spills in the outwash plain that occur in areas with no operational restrictions or interference from surrounding structures, ADEC approves immediate remediation of contaminated media after free product has been recovered in a manner that minimizes the spread of contamination into an uncontaminated area by using containment, recovery, disposal techniques appropriate to site conditions. The presumptive remedy for new POL spills on the outwash plain consist of excavation, treatment, and disposal of all impacted soil.
On a case-by-case basis, ADEC will evaluated the need for recovery of free product from the water table. Finally groundwater monitoring and ICs placed on the shallow aquifer restricting its use as a drinking water source will be required until such a time that the appropriate groundwater remedial goals are met. If additional institutional controls are required, these controls will be developed by EAFB in consultation with ADEC.
The OA does not apply to spills impacting surface waters. Nothing in the OA relieves, extends or changes the applicable requirements of 18 AAC 75 and 78 for the proper treatment, storage or disposal of contaminated media that result from the implementation of this OA. |
Steve Bainbridge |
| 10/21/2002 |
Update or Other Action |
Letter sent to Joe Williamson dissolving the State Elmendorf Environmental Restoration Agreement. The Alaska Department of Environmental Conservation (DEC) has reviewed the issue of abolishing the State Elmendorf Environmental Restoration Agreement (SERA) per your recommendation. Elmendorf Air Force Base and DEC entered into the SERA in 1992. The agreement was developed as a tool to bring the Base into compliance with Alaska's regulations addressing underground storage tanks, oil and other hazardous substance releases and solid waste.
Since that time, Elmendorf has made significant progress in investigating and cleaning up historic contamination problems. Many of the sites covered by the SERA have been successfully cleaned up and closed. Cleanup is underway at the remaining sites.
Additionally, Alaska has amended the regulations addressing fuel storage tanks, oil and other hazardous substance spills and solid waste. We concur with you that the SERA is no longer a necessary or beneficial. This letter serves as notice that DEC will end oversight on environmental work at Elmendorf by using the SERA. Instead, it is understood that the sites and programs formerly addressed by SERA: solid waste, underground storage tanks (UST), and oil and other hazardous substance discharges will be addressed in accordance with 18 AAC 60, 18 AAC 78 and 18 AAC 75. |
Jennifer Roberts |
| 12/31/2002 |
Site Added to Database |
Transfer from LUST. DRO and benzene. |
Debra Caillouet |
| 1/13/2003 |
Update or Other Action |
Staff provided comments on the site assessment report for AFID893. The Alaska Department of Environmental Conservation (the Department) is in the process of reviewing our files on storage tank removals and assessment work done in the past to ensure that all sites where releases of oil or other hazardous substances have been documented are cleaned up in accordance with state regulations. Many former tank sites had been incorporated into the State Elmendorf Environmental Agreement (SERA), but it appears that others were not. Now that the SERA has been closed out, releases that have not been cleaned-up and closed out need to be addressed following the applicable current contaminated sites and underground storage tank regulations (18 AAC 75 and 18 AAC 78).
The Department recently completed a review of the document referenced above and has provided comments below. The site is located at 18762 Talley Avenue, previously named Hubble Road, and is formerly known as “Building 43-590”. If the Air Force has any other documents on assessment or cleanup of this site, please provide them for our information and records.
Specific Comments
1.0 Executive Summary Page 1
The text states that Level “B” is the appropriate cleanup criteria for this site. The regulations have changed since this report was produced. 18 AAC 75 Table A1 Method One Category “B” diesel range organics is still set at 200 mg/kg for cleanup in soil. However, for release investigations conducted at this site, in addition to meeting Table A1 criteria, the site must meet the most stringent standards for benzene, toluene, ethylbenzene, and total xylenes (BTEX) for the applicable exposure pathway in Table B1 in (c) of 18 AAC 75.341. The cleanup levels are as follows: benzene 0.02 mg/kg, ethylbenzene 5.5 mg/kg, toluene 5.4 mg/kg and total xylenes at 78 mg/kg.
2.2 Site History Page 2
The text states that the 2,000 gallon UST held heating oil. Unless the Air Force can adequately prove the tank only contained #2 Diesel, it must now analyze for gasoline range organics (GRO) in addition to diesel range organics (DRO) and BTEX constituents in any further investigation/corrective action confirmation sampling. This requirement for GRO analysis is found in the UST Procedure Manual Table 2 (effective December 1, 1999).
4.4 Sampling Procedure Page 8
The text states that a background sample was taken as part of the site assessment. The Department does not require nor request background samples be taken for petroleum releases unless the responsible party is trying to attribute inorganic contamination to naturally occurring background concentrations (e.g. lead for gasoline contaminated sites). Heating fuel does not fall into this category.
5.2 Discussion Page 12
The text states that the cleanup criteria is Level “B” and the Department concurs. However, the original ranking is incorrect for item two which should correctly be scored as a three and not a ten since the Anchorage Bowl’s (including EAFB) average precipitation is typically sixteen inches a year and not over forty inches a year as stated in the document. The score would then be downgraded to 27 and still be considered a Level “B” site.
See site file for additional information. |
Louis Howard |
| 1/13/2003 |
Site Ranked Using the AHRM |
Ranked by staff. Unranked prior to this date. |
Louis Howard |
| 12/5/2003 |
Site Closure Approved |
See Elmendorf ST530 Bldg 18762 AFID 893 filenumber 2101.26.106 reckey 199621X112101 which is conditionally closed and the same site as this one. |
Louis Howard |