| Action Date |
Action |
Description |
DEC Staff |
| 4/1/2010 |
Update or Other Action |
The USACE drilled 26 soil borings to collect geotechnical and chemical samples at the ROF
site from 14 to 28 September 2009 and from 31 March to 1 April 2010 to identify surface and
subsurface conditions, address geotechnical concerns, and obtain a historical perspective of
the site.
Fifty analytical soil samples, including six duplicates, from 22 of the soil borings were collected and analyzed for gasoline-range organics (GRO), diesel-range organics (DRO), residual-range organics (RRO), volatile organic compounds (VOC), polychlorinated biphenyls (PCB), chlorinated pesticides, Resource Conservation and Recovery Act (RCRA) metals, hexavalent chromium, and polycyclic aromatic hydrocarbons (PAH).
Three analytes exceeded ADEC soil cleanup levels; arsenic, bromomethane, and methylene chloride. Arsenic occurs naturally in higher concentrations in Alaska due to volcanic activity and the weathering of arsenic containing minerals and ores. Arsenic levels are only slightly above the background range determined for JBER soils, and is therefore not considered a contaminant of potential concern (USAF 1993). Bromomethane and methylene chloride were also present in associated trip blanks and are attributed to laboratory contamination (USACE 2010b, 2010c).
During the investigation, a crushed, rusted drum covered in vegetation was observed at the site. Field screening samples collected with a photoionization detector (PID) around the drum were below 20 parts per million therefore, this soil was not segregated or removed. |
Louis Howard |
| 11/30/2011 |
Update or Other Action |
Historic DRO contamination was detected during construction activities in November 2011.
Analytical samples were collected by Alaska Resources and Environmental Services from a
small excavation and analyzed for GRO, DRO, RRO, VOCs, PCBs, PAHs, and RCRA metals. Approximately 12 to 15 cubic yards of soil had already been excavated and placed at the end of a clean soil stockpile before a field screening sample indicated VOCs present in the soil. Concentrations of DRO exceeded the ADEC Method Two soil cleanup level in two samples, including one characterization sample collected from the excavation. |
Louis Howard |
| 5/1/2012 |
Spill Transferred from Prevention Preparedness and Response Program |
Spill transferred by PERP staff Michele Sherwood. Spill no. 11239931101; spill date = 11/7/11; substance = unknown (diesel suspected); quantity = unknown; description from spill report: Historical release. Based on analytical data the contamination is weathered diesel fuel (about 300 mg/kg). The amount of fuel released is unknown as is the date of the release. About 50 to 75 cubic yards of soil will be excavated and stockpiled pending complete analytical testing. Stockpile will meet requirements of 18 AAC 78 for long-term stockpiling pending availability of facility and funding to treat the soil. |
Mitzi Read |
| 5/4/2012 |
Site Added to Database |
A new site has been added to the database |
Mitzi Read |
| 5/18/2012 |
Update or Other Action |
Analytical samples were collected beneath several railroad switches and in the drainage
swales in 2012 and were analyzed for GRO, DRO, VOCs, PCBs, and PAHs. Several samples
contained DRO above the ADEC soil cleanup level.
Jacobs removed approximately 80 tons of DRO-contaminated soil from the two stockpiles in
2012. Two waste characterization samples were collected from the stockpiles prior to soil
removal and were analyzed for GRO, DRO, RRO, and PCBs. Analytical results were less
than ADEC cleanup levels for all analytes. However, higher concentrations of DRO were
presumed to be present closer to the base of the stockpiles, which could not be sampled due to
the frozen soil in the stockpile.
The stockpiled soil plus approximately 3 inches of soil from below the stockpiles were removed and transported to Alaska Soil Recycling for thermal treatment. Upon completion of the soil removal the site was returned to grade and the railroad ties that were used for the stockpile berms were stacked adjacent to the former stockpile locations. |
Louis Howard |
| 1/2/2013 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 79286 name: JBER-Ft. Rich FTR266 |
Louis Howard |
| 6/17/2013 |
Update or Other Action |
Draft SC Work Plan received for review and comment.
The goals of this project are to complete a subsurface soil and groundwater investigation to
complete an SC and prepare both an SC Report and a Decision Document for SA015-ROF.
The site location and vicinity are shown on Figure A-1 (Appendix A). In conjunction with
meeting these goals, the project will involve managing all investigation-derived waste (IDW)
and restoring the site for expected future use.
This Work Plan is the primary planning document prepared to ensure that the project goals are
met for the site. This Work Plan also includes appendices that will be used to support the
project goals for Site SS016, the Rapid Deployment Facility, under the same contract.
This Work Plan has been drafted in accordance with the U.S. Air Force (USAF); the Occupational
Safety and Health Administration (OSHA); the Alaska Department of Environmental Conservation (ADEC) guidance and regulations; the U.S. Department of Defense (DoD) Quality Systems Manual for Environmental Laboratories (QSM) version 4.2 (DoD 2010); the Uniform Federal Policy for Quality Assurance Project Plans (UFP-QAPP) Manual (Intergovernmental Data Quality Task Force 2005); and Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA (U.S. Environmental Protection Agency [EPA] 1988).
The primary objective of the 2013 SC is to determine and document the nature and extent of
soil and groundwater contamination at the site. This will be achieved by installing and
sampling soil borings and installing and sampling groundwater monitoring wells. The data
gathered from the SC should provide the necessary information to provide the basis for a
Decision Document for the site. |
Louis Howard |
| 7/2/2013 |
Update or Other Action |
Draft SS016 Proposed Rapid Deployment Facility Corrective Action Work Plan received.
The goals of this project are to characterize, remove, and dispose of or thermally treat soil
contaminated with diesel-range organics (DRO) identified at the site during an investigation
conducted in fall 2011. The Corrective Action will remove the potential safety hazard to
construction workers and future facility occupants posed by the surface contamination.
This Work Plan is the primary planning document prepared to ensure that the project goals are
met for the site. This Work Plan also includes appendices that will be used to support the
project goals for the SA015 – Railhead Operations Facility, which is addressed under the
same contract.
This site is the future location of an RDF that will be located adjacent to railroad siding. The
location is near the south side of JBER-Richardson’s closed solid waste landfill. The area
formerly housed warehouse facilities with railroad loading platforms and underground storage
tanks (UST).
Known contaminated soil is located beneath one of the two railroad switches in the immediate area. The contamination appears to be the result of small leaks or over-filling while lubricating the switch.
2011 Sampling Effort
One surface soil sample collected directly under one of the railroad switches contained DRO
at a concentration of 550 milligrams per kilogram (mg/kg), exceeding the ADEC migration to
groundwater cleanup level of 250 mg/kg.
Excavation activities will begin at the location of the 2011 surface sample RDFSS02 and will be expanded as necessary based on visual and olfactory observations, field screening, and analytical sample results. Up to 34 tons of contaminated soil excavation is anticipated. JBER personnel will be consulted if any modification to the railroad system is required.
Once the suspected contaminated soil has been removed, excavation confirmation samples will be collected for verification. Excavation confirmation sample locations will be based on the locations of the highest field screening results and will be collected at the frequencies specified in Table 2B of the ADEC Draft Field Sampling Guidance. |
Louis Howard |
| 7/2/2013 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the draft work plan for the site.
Executive Summary
3rd Paragraph
The text states: “This Work Plan has been drafted in accordance with the U.S. Air Force (USAF); the Occupational Safety and Health Administration (OSHA); the Alaska Department of Environmental Conservation (ADEC) guidance and regulations; the U.S. Department of Defense (DoD) Quality Systems Manual for Environmental Laboratories (QSM) version 4.2 (DoD 2010); the Uniform Federal Policy for Quality Assurance Project Plans (UFP-QAPP) Manual (Intergovernmental Data Quality Task Force 2005); and Guidance for Conducting Remedial Investigations and Feasibility Studies Under CERCLA (U.S. Environmental Protection Agency [EPA] 1988).”
Although ADEC may accept OSHA air standards to evaluate indoor air when the site COCs are chemicals used in the workplace, ADEC will still require characterization of the vapor intrusion pathway for future unrestricted land use.
There have been three sampling efforts at the site which did not detect CERCLA hazardous substances (e.g. non-POL).
2010/2011 Foundation Study HTRW Survey and Geotechnical Investigation
Analyses included: GRO, DRO, RRO, VOCs, PCBs, chlorinated pesticides, RCRA metals, hexavalent chromium, and PAHs.
2011/2012 Construction Sampling Activities
Analytes included: GRO, DRO, RRO, VOCs, PCBs, PAHs, and RCRA metals.
2012 DRO-Contaminated Soil Removal
Analytes included: GRO, DRO, RRO, and PCBs.
Thus far, only diesel range organics (DRO) has been detected above cleanup levels. Arsenic was ruled out as being associated with background, bromomethane and methylene chloride were attributed to laboratory contamination.
Petroleum hydrocarbons, PAHs, and VOCs are the only contaminants being analyzed for at the site in soil and groundwater samples. It is ADEC’s position that CERCLA RI/FS 1988 guidance need not apply to the site for the petroleum contamination unless chlorinated solvents are detected during investigation with Method 8260. Also this site meets the criteria for inclusion into the 1994 Two Party Agreement (aka Ft. Richardson Environmental Restoration Agreement). Should chlorinated solvents or other CERCLA substances be found, the site should be included in the Federal Facility Agreement Attachment A.
Site Description
State whether or not there are occupied buildings within 30 feet of the contamination (horizontally and vertically) presently known at SA015. With additional site characterization this answer may or may not need to be updated in the draft report. Also state whether or not there is a groundwater well within ½ mile radius of the site, including, but not limited to, drinking, irrigation, fire control, dust control, or any other activity.
How good do the data need to be in order to support the environmental decision?
The text states: All results should have detection limits less than the associated cleanup level, if possible using the proposed methodology. Several analytes in the VOC list are known to have cleanup levels lower than the detection limits achievable by the SW8260 mid-level method.
In cases where the cleanup level is less than the detection level, professional judgment will be used to determine if that analyte is a contaminant of potential concern at the site.”
Be aware that EPA does not approve the use of methanol preserved soil samples for SW8260 VOC analysis. EPA requires that JBER instead use VOC/VOA vials with a water carrier. These samples will be in addition to the methanol-preserved SW8260 samples required by ADEC. EPA no longer recommends low-level analysis (SW8260) with sodium bisulfate preservative. This is applicable to all JBER-E and JBER-R sites using SW8260 to analyze for constituents (TCE, PCE, TCA, etc.) besides petroleum related volatile constituents (e.g. BTEX).
Who will collect and generate the data?
The test states: “The subcontracted laboratory (EMAX) will analyze the samples, review, and generate the data.”
JBER shall ensure and provide documentation that EMAX (UST-031) is both DoD-ELAP accredited AND Alaska approved. Any non-EPA and/or non-Alaska methods must be approved by ADEC prior to sample collection. ADEC is requesting JBER supply a copy of EMAX’s current ADEC approval letter. These letters detail the methods, matrices, and dates for which the lab has approval. Labs must renew their approval and pass performance evaluation samples annually. Failure to do so results in the revocation of a lab's approval. |
Louis Howard |
| 7/11/2013 |
Document, Report, or Work plan Review - other |
Staff commented on the draft SS016 Proposed RDF Corrective action WP.
Overview-9 Previous Investigations
1st Paragraph
The text states: “Soil gas sample results were compared to the lower explosive limit for methane gas listed in 18 AAC 60 (ADEC 2013).”
However, the follow-on discussion of results does not mention whether or not methane is of concern or what the levels of methane gas that were measured (i.e. does it or does it not exceed the lower explosive limit for methane gas listed in 18 AAC 60). The reader has to wait until WS #17 to read that “An associated methane plume and grease pits were also associated with the landfill at the time of closure, however, recent soil gas sampling at the site indicates that no methane impacts are present.”
Discovery of Munitions
Non-training areas: See above comment regarding stop work and notification requirements to ADEC.
Training area: While not unusual or unexpected, munitions being discovered shall be noted in the report (ADEC courtesy notification is requested) and any EOD response report shall be included as part of the report
WS #11 Project Quality Objectives/Systematic Planning Process Statements
Page 11-2
Who will collect and generate the data?
The test states: “The subcontracted laboratory (EMAX) will analyze the samples, review, and generate the data.”
JBER shall ensure and provide documentation that EMAX (UST-031) is both DoD-ELAP accredited AND Alaska approved. Any non-EPA and/or non-Alaska methods must be approved by ADEC prior to sample collection. ADEC is requesting JBER supply a copy of EMAX’s current ADEC approval letter. These letters detail the methods, matrices, and dates for which the lab has approval. Labs must renew their approval and pass performance evaluation samples annually. Failure to do so results in the revocation of a lab's approval.
|
Louis Howard |
| 7/24/2013 |
Document, Report, or Work plan Review - other |
ADEC has reviewed the responses to its comments on the draft SS015 UFP-QAPP work plan and finds the responses acceptable. Please finalize the document. |
Louis Howard |
| 8/27/2013 |
Document, Report, or Work plan Review - other |
ADEC has reviewed JBER responses to ADEC's comments on the corrective action work plan for SS016 (formerly CC-FTRS-16)- Proposed Rapid Deployment Facility. The responses are acceptable. Please finalize the work plan. |
Louis Howard |
| 3/25/2014 |
Update or Other Action |
SS016 Proposed RDF Corrective Action Report received for review and comment.
Contaminated soil excavation was conducted at SS016 to address DRO contamination, which was identified under a railroad track switch in 2011. Approximately 8 cubic yards (12.36 tons) of contaminated soil was excavated and thermally treated at a local facility. Field screening samples were analyzed using PetroFLAG test kits; excavation confirmation samples – which were analyzed for GRO; DRO; RRO; PAHs; and BTEX – were either nondetect or significantly less than the most stringent cleanup levels as per ADEC Method Two, under 40 inch zone, confirming that all contaminated soil was successfully removed. The excavation site was backfilled with clean material and contoured to match site conditions. The railroad track switch, which was the source of contamination at this site, was disconnected and delivered on 24 October 2013 to 773d
Operations personnel.
Recommendations
A ‘Cleanup Complete’ categorization is recommended for SS016. Excavation confirmation samples for GRO, DRO, RRO, PAHs and BTEX were either nondetect or significantly less than the ADEC cleanup levels, which indicates that all contaminated soil was successfully removed. During the RI conducted in 2011, no other contamination was identified at the site (USAF 2012). It is recommended that closure documentation be drafted and that site be categorized as ‘Cleanup Complete’. |
Louis Howard |
| 4/15/2014 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (ADEC) has completed a review of the environmental records associated with the site SS016 (ADEC CS Database Hazard ID 25871) located on Joint Base Elmendorf-Richardson (the former Fort Richardson Army Post) in Anchorage, Alaska.
Contaminants of Concern
During the 2013 investigations at this site, the maximum detected levels of contamination for all contaminants of concern were all below the most stringent Tables B1 and B2 cleanup levels.
Cleanup Complete
In accordance with 18 AAC 75.380(d)(1), after reviewing the final cleanup report submitted under this section, ADEC has determined SS016 has been adequately characterized under 18 AAC 75.335 and has achieved the applicable requirements under the site cleanup rules for a “cleanup complete” designation. The designation shall be noted in the CS Database.
This written determination does not preclude ADEC from requiring additional assessment, investigation, monitoring, and cleanup if future information, site conditions, or new data indicates that action is necessary to protect human health, welfare, safety, or of the environment.
In accordance with 18 AAC 75.325(i) and 18 AAC 75.370(b): A responsible person (the Air Force) shall obtain approval before disposing of soil or groundwater from a site (SS016)
(1) that is subject to the site cleanup rules; or
(2) for which the responsible person has received a written determination from the department under 18 AAC 75.380(d)(1);
Movement or use of contaminated material in a manner that results in a violation of 18 AAC 70 water quality standards is prohibited.
|
Louis Howard |
| 4/15/2014 |
Update or Other Action |
Draft Site Characterization report received for review and comment.
None of the 61 primary soil samples collected from the 29 soil borings contained concentrations of contaminants that exceeded ADEC Method Two most stringent under 40-inch zone or migration to groundwater cleanup level. None of the water samples collected from the six monitoring wells contained concentrations of contaminants that exceeded their respective ADEC cleanup levels.
During the 2013 SC activities, 61 primary soil samples were collected from 29 soil borings, and six primary groundwater samples were collected from six monitoring wells. All of the soil and groundwater samples collected during the field effort contained concentrations of contaminants below their respective ADEC cleanup levels (ADEC 2012). Based on these results, it appears that the removal activities, which were conducted during the Railhead Operations Facility construction, effectively removed the vast majority of contaminated soil from the site. For this reason, it is recommended that the site be granted a cleanup complete status and that a closure report be prepared for the site in accordance with 18 AAC 75.380. |
Louis Howard |
| 4/28/2014 |
Cleanup Complete Determination Issued |
Staff granted a cleanup complete determination for SA015.
Contaminants of Concern
During the 2013 investigations at SA015, the maximum detected levels of contamination for all contaminants of concern were all below the most stringent Tables B1 and B2 cleanup levels. Groundwater samples from monitoring wells were all below Table C cleanup levels.
Cleanup Complete
In accordance with 18 AAC 75.380(d)(1), after reviewing the final cleanup report submitted under this section, ADEC has determined SA015 has been adequately characterized under 18 AAC 75.335 and has achieved the applicable requirements under the site cleanup rules for a “cleanup complete” designation. The designation shall be noted in the CS Database.
This written determination does not preclude ADEC from requiring additional assessment, investigation, monitoring, and cleanup if future information, site conditions, or new data indicates that action is necessary to protect human health, welfare, safety, or of the environment.
In accordance with 18 AAC 75.325(i) and 18 AAC 75.370(b): A responsible person (the Air Force) shall obtain approval before disposing of soil or groundwater from a site (SA015)
(1) that is subject to the site cleanup rules; or
(2) for which the responsible person has received a written determination from the department under 18 AAC 75.380(d)(1);
Movement or use of contaminated material in a manner that results in a violation of 18 AAC 70 water quality standards is prohibited.
Any person who disagrees with this decision may request an adjudicatory hearing in accordance with 18 AAC 15.195 -18 AAC 15.340 or an informal review by the Division Director in accordance with 18 AAC 15.185. Informal review requests must be delivered to the Division Director, 410 Willoughby Avenue, Suite 303, Juneau, Alaska 99801, within 15 days after receiving ADEC’s decision reviewable under this section. Adjudicatory hearing requests must be delivered to the Commissioner of the Department of Environmental Conservation, 410 Willoughby Avenue, Suite 303, Juneau, Alaska 99801, within 30 days after the date of issuance of this letter, or within 30 days after ADEC issues a final decision under 18 AAC 15.185. If a hearing is not requested within 30 days, the right to appeal is waived.
|
Louis Howard |
| 8/19/2014 |
Document, Report, or Work plan Review - other |
ADEC has reviewed the work plan and has some general comments on the document. There were no statements in the work plan regarding whether or not the wells are needed for JBER Compliance Program or any other data need such as for future PFOS/PFOA evaluation of upgradient fire training areas/fire training pits or future 1,4-dioxane evaluation for TCE/TCA releases upgradient of SA015. ADEC requests JBER clarify whether or not these data needs exist. The work plan is approved if there are no such data needs, if this is the case; please finalize the document.
ADEC’s review and comment on this work plan is to ensure that the work is done in accordance with State of Alaska environmental conservation laws and regulations. While ADEC may comment on other state and federal laws and regulations, our comments on the work plan does not relieve responsible persons from the need to comply with other applicable laws and regulations.
|
Louis Howard |
