| Action Date |
Action |
Description |
DEC Staff |
| 12/30/2010 |
Document, Report, or Work plan Review - other |
Staff commented on the draft Decommissioning Report for Site OT092 November 2010.
ADEC did not find the field notes or logbook in the AF’s submittal. ADEC requests copies (electronic & hard copy) be provided for its files & review.
2.1 AOC 92
2.1.1 Segment B Page 2-2
Please note the use of visual confirmation for the absence or presence of contamination is not allowed in lieu of definitive data obtained from lab analysis. Figure 2-2 does not list east end sample SSB2-02 on the figure for East End Segment B2, but it does list the follow-up sample SSB2-04. ADEC will require further site characterization associated with the east end of Segment B2.
Table 2-1
Segment B Soil Sample Results Page 2-3
The detection limit for benzene is above the 0.025 mg/kg migration to GW cleanup level for every sample collected at Segment B.
2.1.3 Segment E3 Page 2-8
The text states: “One soil sample was collected from the floor at the valve pit VP-2B & analyzed for site COPCs. The concentration of DRO exceeded the Method Two cleanup criterion of 230 mg/kg (*Table 2-2).”
*Sample VP-2B SSE-01 lab result for DRO is at 1,410 mg/kg.
The 2009 WP stated: “At least two soil samples will be collected to assess conditions at each valve pit location.” It appears that there should have been at least two samples taken from Segment E3’s valve pit VP-2B. ADEC will require further site characterization of the contamination associated with Segment E3 valve pit VP-2B.
2.2 AOC 93
Segment C Page 2-13
Figure 1-2 only shows two valve pits: former VP-17 & VP-F. However on Figure 2-4 there appears to be another valve pit indicated at Segment C1 Excavation Area 6 “VP”. ADEC requests the AF confirm whether or not this is an erroneous valve pit on the figure or it was not sampled as required by the 2009 work plan.
The 2009 WP stated: “Necessary signage shall be installed, & an environmental site assessment shall be performed near former VP-17.” Figure 2-3 of the draft decommissioning report does not indicate that any soil samples were collected in the vicinity of former VP-17.
ADEC requests the Air Force conduct soil sampling for former valve pit VP-17 as indicated in the approved final work plan for OT092.
Table 2-3 Segment C1 Soil Sample Results Page 2-15: See table 2-1 comments.
Segment C2 Page 2-17
Table 2-4 Segment C2 Soil Sample Results shows that only sample SSC2-02 was collected on October 7, 2009. ADEC requests the AF verify which is correct & amend the table or change the text accordingly.
Segment C3 Page 2-19
ADEC requests the AF obtain a right-of-entry permit to conduct excavation activities at this valve pit & perform confirmation sampling as required by the 2009 WP.
2.7.4 Valve Pit Sampling Page 2-25: “At least two soil samples will be collected to assess conditions at each valve pit location.
If excavation is necessary to expose the valve pits & decommission pipeline segments, then the valve pit area will be sampled & backfilled as detailed in Section 2.7.2.” 2.7.2 Excavation Confirmation Sampling Page 2-24: “Excavations will be sampled at a frequency of one confirmation soil sample per 250 square feet, with two soil samples from the first 250 square feet of excavated area.”
2.2.2 Segment D Page 2-23
ADEC requests the AF obtain a right-of-entry permit to conduct excavation activities necessary to sample the south terminus in accordance with the 2009 WP Segment D Page 2-18--“Environmental site assessments shall be completed at VP-2A & the southern terminus at the railroad tracks.”
“An excavation soil sample (SSD-02) was collected from VP-2A in accordance with site characterization procedures. The sample exceeded the ADEC cleanup criterion for DRO (230 mg/kg) & GRO (260 mg/kg) with results of 5,990 mg/kg & 322 mg/kg, respectively.”
ADEC disagrees. The approved 2009 WP: “At least two soil samples will be collected to assess conditions at each valve pit location.” ADEC requests the AF conduct a site assessment at VP-2A & information on when the last time the active line was last tested for leaks. It appears there is DRO contamination at VP-2A associated with Segment D or the active line.
AOC 94
Segment I Pages 2-27 & 2-28
ADEC requests the AF provide additional information regarding whether drains in FP-E & FP-F were actually connected to the Base storm water system or not. If not, then they may likely meet the definition of an UI well (possibly Class V Wells) regulated by EPA Region 10. It is the responsibility of the AF to ensure that it coordinates all decommissioning of UI wells (i.e. with & EPA approved UIC closure plan) with EPA Region 10 UIC staff to ensure compliance with regulatory requirements found in 40 CFR 144.89. |
Louis Howard |
| 12/2/2011 |
Update or Other Action |
Staff received the draft Decommissioning Report for Site OT092 November 2010 on December 2, 2010 for review and comment. This report and its appendices present the activities conducted by BC Contractors Inc. (BCC) in support of the OT092 fuel pipeline decommissioning. These activities were conducted between 9 September and 12 November 2009, with additional sampling on 2 February 2010, for the U.S. Air Force (USAF), 673rd Civil Engineer Squadron (CES)/Asset Management Flight, Natural Resources Element, Cleanup Section under Air Force Center for Engineering and the Environment, Contract Number FA8903-09-C-8008.
The 2009 OT92 pipeline decommissioning and site assessment activities successfully decommissioned pipeline segments at AOC 92, AOC 93, AOC 94, AOC 95, and AOC 96. All piping was found to be in good condition with no signs of significant corrosion or other integrity problems.
The pipeline segments were decommissioned in place or removed, the ends were sealed, and a site characterization was performed in accordance with ADEC 18 AAC 78.090. (ADEC 2006). The majority of the soil samples collected and analyzed for site COPCs (GRO, DRO, RRO, and BTEX) yielded results below the ADEC cleanup criteria. However, sample results at three locations, Segments B2, C2, and E(VP-2B), contained concentrations of DRO above the ADEC cleanup criterion of 230 mg/kg. Additionally, a soil sample collected from segment D(VA-2A) contained concentrations of DRO and GRO above the ADEC cleanup criteria of 230 mg/kg and 260 mg/kg, respectively. However this GRO exceedance is likely due to the elevated middle distillate contamination and not a gasoline-range distillate.
• Soil removal activities were conducted at Segment B2. Following soil removal, additional
sampling indicated contamination was present. Visible signs of contamination were not
observed surrounding this sample location.
Soil was not removed at Segment D(VP-2A) or Segment E(VP-2B) because both valve pits
contained active fuel lines.
• All pipeline segments were decommissioned in accordance with the approved work plans and
18 AAC 78. Recovered fuel and excavated contaminated soil were transported and properly
disposed of offsite. Witness and signage posts were installed to complete the decommissioning
activities. |
Louis Howard |
| 6/25/2012 |
Site Added to Database |
A new site has been added to the database |
Mitzi Read |
| 11/19/2012 |
Update or Other Action |
Draft UFP QAPP receive for OT092 Abandoned hydrant lines-segments B2, C2, C3 I2 Site characterization and decommissioning.
For Segment Portions B2 and C2, site characterization activities will consist of installing a minimum of six soil borings utilizing direct push technology (geoprobe) in the areas of known
contamination (Segment Portion B2 (East End) sample SSB2-04 vicinity and Segment Portion
C2 sample SSC2-01 vicinity) at each site. Soil borings will be located to vertically and
horizontally delineate the extent of soil contamination, if any, exceeding 18 AAC 75 soil cleanup criteria for the COPC.
Samples from the soil boring cores will be collected and screened utilizing a photoionization
detector (PID). Based upon results of the PID field screening, the sample from each boring
interval with the highest PID reading will be collected and submitted for laboratory analysis of
GRO, DRO, RRO, and BTEX constituents.
If evidence of contamination is observed in the field during the installation of delineation
borings, additional boring locations may be installed in order to vertically and horizontally
delineate the evidence of contamination encountered. The location and depths of these borings,
if necessary, will be determined in the field based on the evidence of impacts observed to the
soil.
Samples from the soil boring cores will be collected and screened utilizing a photoionization
detector (PID). Based upon results of the PID field screening, the sample from each boring
interval with the highest PID reading will be collected and submitted for laboratory analysis of
Benzene only.
Site activities for Segment Portion I2 will consist of investigating the former floor drains in valve pits FP-E and FP-F and determining there discharge points. An initial desktop review of former as-built and I2 segment documentation will be conducted. If needed on-site field work
consisting of but not limited to an electromagnetic survey and soil excavation will be performed
to further investigate the former floor drains and discharge points.
To complete the decommissioning of Segment Portions C3 and D pipes, the ends of the pipes
sticking out of the ground need to be cut back so that they are flush with the ground surface and then the ends need to be capped. Prior to performing the cutting and end capping of these pipes which are located on Alaska Railroad Corporation (ARRC) property, an entry permit from
ARRC Real Estate department will be obtained to perform this work. All decommissioning
activities will be conducted in accordance with 18 AAC 78.090 regulations.
All analytical samples will be collected and sent to an ADEC and Department of Defense (DoD)
Environmental Laboratory Accreditation Program (ELAP) approved analytical laboratory. The
laboratory analytical sample results will be used to document that the cleanup levels for the
analytes described in this UFP-QAPP have been met.
Upon completion of the site characterization and decommissioning activities, WESTON will
prepare a characterization and decommission report documenting the results of the activities
conducted along with conclusions and recommendations. |
Louis Howard |
| 12/10/2012 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the UFP-QAP for OT092.
WS #4, 7 & 8 Personnel Qualifications and Sign-Off Sheet
The site specific QAPP must identify the specific personnel that will be the “qualified persons” as defined by 18 AAC 75(100). Also, the site-specific QAPP must identify which laboratory is being used for this project. The “draft” UFP-QAPP has not been finalized and the UFP-QAPP lists at least four different laboratories. The final version of the site-specific QAPP must detail the qualified person(s) and the primary/backup laboratories being used for this project with their current ADEC approval letters outlining the method/matrices they are approved for as well as when their approval expires.
WS #11 Data Quality Objectives
List the cleanup levels referenced:
Method Two Table B2 Under 40 inch Zone Migration to Groundwater
Gasoline range organics 300 mg/kg
Diesel range organics 250 mg/kg
Residual range organics 11,000 mg/kg (note that if ingestion pathway is applicable it is more stringent at 10,000 mg/kg).
Table B1 Migration to Groundwater
Benzene 0.025 mg/kg
Ethylbenzene 6.9 mg/kg
Toluene 6.5 mg/kg
Xylenes (total) 63 mg/kg (also the outdoor inhalation cleanup level)
ADEC requests JBER elaborate on whether or not PAHs were analyzed for at OT092 previously. If so, then please provide the data for historical reference. If not, then please be aware that 18 AAC 75.341 Notes to Tables B1 and B2 state:
“14. If using method two or method three, the applicable petroleum hydrocarbon cleanup levels must be met in addition to the applicable chemical-specific cleanup levels for benzene, ethylbenzene, toluene, and total xylenes; the chemical-specific cleanup levels for the polynuclear aromatic hydrocarbons acenaphthene, acenapthylene, anthracene, benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, benzo(k)fluoranthene, benzo(g,h,i)pyrene, chrysene,
dibenzo(a,h)anthracene, flouranthene, fluorene, Indeno(1,2,3-c,d)pyrene, naphthalene, phenanthrene, and pyrene must also be met unless the department determines that those cleanup levels need not be met to protect human health, safety, and welfare, and the environment.”
PAH analysis (Method 8270D) for soils would be required for all petroleum releases, unless the sum of the applicable soil cleanup concentrations based on laboratory results in accordance with Table 2, for individual petroleum hydrocarbon fractions or ranges determined for the site by applying the corresponding Method 2 – 4 referenced in 18 AAC 75.340 is equal or less than 500 mg/kg.
Therefore, ADEC proposes that for each area being investigated that has sample results with a sum of applicable soil cleanup concentrations greater than 500 mg/kg, one PAH analyses will be required at the highest field screening result location or absent of any field screening results, one PAH soil sample will be required using best professional judgment by the field sampler.
Unless JBER can show that this pipeline only carried gasoline and JP-4, PAH analyses will be required and the approach outlined above will satisfy the regulatory requirement for PAH analyses. It appears for now that pipeline section B2 is the only one that will require PAH analyses.
|
Louis Howard |
| 1/2/2013 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 79301 name: OT92 Pipeline |
Louis Howard |
| 5/5/2014 |
Update or Other Action |
Draft SC Report received for review and comment.
Segment C2
Benzene and toluene exceedances were observed above ADEC cleanup criteria in soil boring
SB01 at a depth of 3.0 – 3.5 feet bgs. Analytical results for the sample collected from SB01 at
13 – 13.5 feet bgs were below cleanup criteria. Four additional soil borings were advanced
cardinally around SB01 at depths of 15 feet bgs in order to horizontally delineate the extent of
contamination.
One sample, 13OT092-SB01-3.0-3.5-0, exceeded ADEC cleanup criteria for benzene (0.025 mg/kg) and toluene (6.5 mg/kg) with concentrations of 0.069 mg/kg and 10 mg/kg, respectively. All analytes for all other samples were below cleanup criteria. The vertical and horizontal contamination remaining at the site appears to be localized to an estimated 170 cubic yards surrounding SB01.
Segment I2
All analytes for all samples were below cleanup criteria.
Segment C3
Both samples, 13OT092-C3-SO01 and 13OT092-C3-SO02, exceeded the ADEC cleanup criterion for trichloroethylene (TCE) (0.020 mg/kg) with concentrations of 0.11 mg/kg and 0.074 mg/kg, respectively. The decommissioned portion of Segment C3 is located near Operational Unit 5, Seeps 9, 10, and 11 within the ST037 TCE plume. This exceedance is attributed to groundwater contamination in the smear zone at the ST037 site and not attributed to the OT092 fuel hydrant lines. |
Louis Howard |
| 6/9/2014 |
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 OT092 (ADEC CS Database Hazard ID 25887) located on Joint Base Elmendorf-Richardson in Anchorage, Alaska. ADEC concurs with the statements regarding TCE exceedance is attributed to groundwater contamination in the smear zone at the ST037 site and not attributed to the OT092 hydrant lines. ADEC also concurs with the statements regarding Segment C2: The contaminated soil associated with Segment C2 will need to be addressed before this segment can be considered decommissioned. Future actions to address contaminated soil at Segment C2 prior to decommissioning could include excavation of the estimated 170 cubic yards of soil.
|
Louis Howard |
| 4/5/2016 |
Update or Other Action |
Contract awarded in 2015 work to conduct soil removal in 2016 to remove contamination left at one last segment of this site and then CC can be granted. |
Louis Howard |
| 7/15/2016 |
Update or Other Action |
Drzft remedial action work plan received for review and comment.
This work plan describes site characterization activities that are proposed to support site closure
in accordance with the Alaska Department of Environmental Conservation (ADEC) cleanup process for petroleum hydrocarbon-contaminated sites. This site-specific work plan follows the Uniform Federal Policy – Quality Assurance Project Plan (UFP-QAPP) format and the work will be performed under the JBER Basewide UFP-QAPP (AFCEC, 2013).
The site objectives are to meet “unrestricted or residential site use” criteria and achieve a “cleanup complete without institutional controls (IC)” determination. To meet these objectives, soil in the vicinity of Segment C2 will be excavated and confirmation soil samples will be collected in order to demonstrate that the removal of remaining contaminated soil has been accomplished.
See site file for additional information. |
Louis Howard |
| 7/20/2016 |
Document, Report, or Work plan Review - other |
Staff commented on the draft remedial action work plan. Main comments were to ensure that the "clean" soil stockpile determined to be clean by the field screening device (PID) be sampled and have laboratory results confirm whether or not it is "clean". A reading of 20 ppm on the PID is not definitive results for compliance with 18 AAC 75 cleanup levels. Other comments were made regarding the need to collect field duplicates on every day while in the field sampling, and only by sampling groundwater can one determine whether or not it is impacted.
See site file for additional information. |
Louis Howard |
| 4/17/2017 |
Update or Other Action |
Staff received the remedial action and site closure report for review and comment.
Analytical results for samples collected from the excavation limits and from the “clean” soil
stockpile were below the ADEC Method Two Table B1 and B2 cleanup levels. The excavation
was backfilled with soil from the “clean” stockpile, compacted, returned to natural grade, and
reseeded. The objective of removing the contaminated soil was accomplished. Based on the analytical results, the Conceptual Site Model (CSM), and in compliance with environmental criteria, the site meets unrestricted or residential site use criteria.
See site file for additional information. |
Louis Howard |
| 5/5/2017 |
Cleanup Complete Determination Issued |
The Alaska Department of Environmental Conservation, Contaminated Sites Program (ADEC) has completed a review of the environmental records associated with the JBER-Elmendorf OT092 Pipeline located on JBER- Elmendorf. Based on the information provided to date, it has been determined that the contaminant concentrations remaining on site do not pose an unacceptable risk to human health or the environment and no further remedial action will be required unless new information becomes available that indicates residual contaminants may pose an unacceptable risk.
This Cleanup Complete determination is based on the administrative record for the OT092, which is located in the ADEC office in Anchorage, Alaska.
See site file for additional information. |
Louis Howard |
