Site Report: JBER-Ft. Rich DA090 RV Parking Lot Drum Site

Site Name:	JBER-Ft. Rich DA090 RV Parking Lot Drum Site
Address:	27th Avenue; ~600 Feet SE of Bldg 15920, Formerly Fort Richardson before 10/01/2010, Fort Richardson (JBER), AK 99505
File Number:	2102.38.064
Hazard ID:	25901
Status:	Active
Staff:	Ginna Quesada, 9074515960 ginna.quesada@alaska.gov
Latitude:	61.256119
Longitude:	-149.743948
Horizontal Datum:	NAD83

We make every effort to ensure the data presented here is accurate based on the best available information currently on file with DEC. It is therefore subject to change as new information becomes available. We recommend contacting the assigned project staff prior to making decisions based on this information.

Site Chronology
IC / Closure Details
Documents
Associated Sites

Problems/Comments

On 8/10/12, during excavation activities for the clearing of a large RV storage parking lot, a track loader uncovered an old dump site including metallic solid waste, demilitarized machine gun barrels, and several drums labeled "Dry Cleaning Solvent, Type 1 (tetrachloroethene). While removing the labeled drums one was punctured causing a release of approximately 55 gallons of product to the ground surface. Also known as FTR271. Federal Facility Agreement major milestone update as of December 12, 2018: Draft Proposed Plan June 30, 2020 Draft Record of Decision June 30, 2021

Action Information

Action Date	Action	Description	DEC Staff
8/10/2012	Update or Other Action	Drum punctured during removal from excavation resulting in release of solvent onto the ground surface. Drums have been stockpiled in a lined and covered area to the east of the excavation and the punctured drum has been placed in an overpack for shipment.	Louis Howard
8/22/2012	Spill Transferred from Prevention Preparedness and Response Program	Spill transferred by PERP staff Jonathan Schick. Drum was punctured during removal activies for a new RV parking lot. Spill date = 8/10/12; spill no. 12239922301; substance = tetrachloroethene; quantity = 5 - 55 gallons.	Mitzi Read
8/27/2012	Site Added to Database	A new site has been added to the database	Mitzi Read
10/12/2012	Update or Other Action	Work Plan addendum received for FTR271. The FTR271 RV Lot site, located approximately ¼-mile north of the Davis Highway, along the east side of 27th Avenue on Joint Base Elmendorf-Richardson, Alaska, is currently an active construction site for the FTR271 RV Parking Lot. An emergency removal action will be conducted at the site to remove hazardous drums that present an immediate risk to safety, health, and the environment. These drums and associated debris were identified by the construction contractor in the northeast corner of the site. Drums will be characterized and removed following the procedures described in Section 4.5 of the Fort Richardson Post Wide Work Plan (USACE 2010) Once located, the drums will be evaluated to determine the potential for contents and/or gross contamination. If the drum is intact or has contents, it will be considered potentially hazardous and flagged for further investigation. Flagged drums will be carefully moved and put into a position where they can be opened and sampled. The contents will be characterized using hazard categorization procedures as described in Appendix B, Attachment B-3 of the Fort Richardson Post Wide Work Plan (USACE 2010) and will be sampled by personnel in Level B personal protective equipment. The drums will then be segregated into potential waste streams based on the HAZCAT results and visual observations. Analytical samples will be collected from each waste stream following the procedures described in Appendix B, Section 3.4 of the Fort Richardson Post Wide Work Plan (USACE 2010). Analytical waste samples will be prepared using toxicity characteristic leaching procedures (TCLP) by method SW1311. Once prepared, the samples will be analyzed for the following RCRA toxicity compounds: ? RCRA metals (SW6010/SW7470) ? pesticides (SW8081) ? herbicides (SW8151) ? VOCs (SW8260) ? SVOCs (SW8270) Drums will remain onsite pending the receipt of analytical results. The analytical results will be compared to the applicable ADEC cleanup levels, the RCRA toxicity limits, and the TSCA PCB limits. The waste will be handled, transported, and disposed of in accordance with applicable regulations based on the identified contaminant concentrations. Investigation-derived waste will be disposed of in the same manner as the associated drum contents. Metallic debris will be transported to a local recycling facility. Additional debris that cannot be recycled will be transported to the Anchorage Regional Landfill for disposal.	Louis Howard
10/31/2012	Update or Other Action	Email from JBER contractor Site Report for 30 October 2012 for the FTR271 sites: - Completed removal of all stockpiled soil from the TEMF site, and collected field screening and analytical samples from the north excavation. Field screening results also indicated that all contaminated soil had been removed from the north area. - Surveyed the excavation extents and sample locations at the TEMF site. - Mobilized EX160 to the RV Lot and began excavation and stockpiling of the PCB-contaminated soil. - Collected 3 samples from the excavation following the removal of the PCB-contaminated soil. The floor sample (native soil) had a fuel/solvent odor and had a PID reading of 135 ppm. The sidewall samples also had elevated PID readings. These samples will be submitted for fuels, VOCs, SVOCs, PCBs, and RCRA metals. - Collected one sample from the location of known PCB contamination (WC03) for TCLP lead analysis. LOOK AHEAD: - Continue to excavate and stockpile PCB-contaminated soil and collect remaining excavation samples. - Removal activities will be on hold pending analytical results and receipt of waste profile and manifests.	Louis Howard
1/2/2013	Exposure Tracking Model Ranking	Initial ranking with ETM completed for source area id: 79322 name: Drums	Louis Howard
2/20/2013	Update or Other Action	Draft Tech memo received. Equipment was mobilized to the RV parking lot site on 16 October 2012, & warning barricades & signs were placed around the work area prior to beginning excavation activities. Anomaly investigation activities began on 17 October 2012 at Debris Area 1, where Ancor encountered the buried drums. Soon after beginning the excavation, 55-gallon drums, metallic debris, & empty & crushed 2-gallon fuel cans were encountered. Metallic debris was segregated for recycling & the 55-gallon drums were initially left in place until a containment area could be prepared. An area with potential fuel contamination was identified by odor, & soil from the area was excavated & placed on a liner adjacent to the excavation area. Figure 2 displays the drum & debris removal excavation areas & corresponding geophysical anomalies. On 18 October 2012, investigative excavation activities continued north into the Anomaly 4 area. An exclusion zone was established surrounding the area of buried drums & workers entering the exclusion zone were required to wear Level C personal protective equipment. The field crew began removing drums from Debris Area 1, placing drums with contents into a containment area for characterization & crushing empty drums for recycling. Table 1 presents a summary of the drums with contents. Excavation activities progressed north through the Anomaly 4 area & into Debris Area 3. The drums & metallic debris were found in what appeared to be a disposal trench approximately 15 feet wide by 100 feet long & 8 to 10 feet deep. The soil used to cover the trench was a brown loamy soil, while the native subsurface soil observed at the site was grey sandy gravel with cobbles. Excavation activities continued 3 to 5 feet into the native soil to confirm that no additional debris was located outside the trench area. Metallic debris found in the disposal trench included vehicle tracks, demilitarized rifle barrels, a bus or travel trailer, & other miscellaneous scrap metal. Excavation at the Debris Area 1/Anomaly 4/Debris Area 3 disposal trench was completed on 20 October 2012. Jacobs removed 31 drums from this area in addition to the more than 20 drums previously removed by Ancor. Concentrations of DRO & solvent soil contamination greater than the ADEC migration to groundwater cleanup levels remain at the site. Concentrations of DRO exceeding the cleanup level are present at the east wall, north wall, & excavation floor, ranging from 858 to 1,370 mg/kg. Concentrations of the solvents 1,2-dichloroethane (0.0590 mg/kg) & 1,2,3- trichloropropane (0.109 mg/kg) are present at the excavation floor. Table 5 summarizes the soil contamination remaining onsite. The depth to groundwater at the site is unknown, but is assumed to be 70 to 120 feet bgs based on nearby monitoring well depths. Based on the contaminant concentrations remaining at the site & the depth to groundwater, it is unlikely that these contaminants have migrated to groundwater. The contaminant concentrations remaining at the site do not present a risk to site workers via direct contact or outdoor inhalation. Recommendations Due to the contamination remaining at the site, it is recommended that a site investigation be conducted to further assess the nature & extent of contamination. The investigation should consist of soil borings & sample collection from the soil surrounding & below the disposal trench. Installation of groundwater monitoring well(s) may be necessary if the soil samples indicate the potential for groundwater contamination.	Louis Howard
3/20/2013	Document, Report, or Work plan Review - other	EPA comments on the tech memo EPA received the Draft Recreation Vehicle Parking Lot Drum and Debris Removal Technical Memo for review on February 14, 2013. Figure 1 does not provide enough detail to cite the location of the RV Parking Lot Drum within the JBER installation. Figure 4-2, provided in an appendix of figures but not referenced in the technical memo, does a much better job at identifying street names to better place the physical location of the investigation. It is recommended to add building numbers to Figure 4-2, and reference Fig. 4-2 in the introductory paragraph with Figure 1, the large overview of the vicinity of the site. EPA agrees with the recommendation for additional site characterization . Please note, any future VOC soil analysis should not use a methanol preservative to obtain detection limits that meet EPA CERCLA cleanup levels. It is acknowledged that ADEC sampling guidance requires MeOH preservative for soil VOCs analysis. This may require samples analyzed in both matrices.	Louis Howard
3/20/2013	Document, Report, or Work plan Review - other	The Alaska Department of Environmental Conservation has received the removal after action report on March 15, 2013 for review and comment. ADEC concurs with the recommendations of the report and requests a formal work plan be submitted for review and comment prior to field work commencing. ADEC requires methanol preservation for VOC analysis of soils and EPA requires the detection limits for CERCLA cleanup levels be met that methanol preservation cannot meet. Future analysis of soil samples should have both methanol preserved analysis and “low-level” analysis performed if VOCs are to be analyzed.	Louis Howard
11/4/2013	Document, Report, or Work plan Review - other	Staff reviewed and approved the responses to comments on the technical memorandum.	Louis Howard
4/4/2014	Update or Other Action	PSE II work plan received for review and comment. The objectives of the 2014 PSE II are to determine and document the nature and extent of contamination in soil and groundwater, and determine whether any potential actions are necessary to protect human health and the environment. These objectives will be achieved by advancing and sampling soil borings as well as installing and sampling groundwater monitoring wells. The data gathered from the PSE II should provide the necessary information to determine the cleanup approach for the site, which will be included with the PSE II Report. The following activities will be performed at the site: • Mobilize and prepare for site work. • Advance 16 soil borings to groundwater (approximately 90 feet bgs) or until vertical extent of contamination is delineated. If no evidence of soil contamination (field screening and observations) is identified in the first 30 feet of the soil boring, drilling will cease and an analytical sample will be collected from the bottom of the soil boring and the two highest PID field screening result locations. If the analytical result determines that contamination is present, then the location will be re-drilled to greater depths to determine the lower limit of contamination. • Collect field screening readings using PID every 5 feet for the first 20 feet and every 10 feet thereafter. • Record visual and olfactory observations. • Collect analytical samples from three locations within each boring. • Submit soil samples for offsite laboratory analysis of the following analytes: - GRO by AK101 - DRO by AK102 - RRO by AK103 - VOCs by SW8260 - SVOCs by SW8270 - PCBs by SW8082 - RCRA Metals by SW6020/7471 • Install four groundwater monitoring wells according to the procedures listed in JBERSOP-1200 Monitoring Well Installation and Development; the depth to groundwater is approximately 90 feet bgs. • Develop groundwater wells and collect analytical groundwater samples from the newly installed wells. Groundwater samples will be submitted for the following analytes: - GRO by AK101 - DRO by AK102 - RRO by AK103 - VOCs by SW8260 - SVOCs by SW8270 - PCBs by SW8082 - RCRA Metals by SW6020/7471 • Collect survey data from soil borings and newly installed groundwater monitoring wells using real-time kinematic global positioning survey (GPS) and conventional level loop surveying equipment. • Manage all IDW generated during the field activities. • Restore the site and demobilize	Louis Howard
4/28/2014	Document, Report, or Work plan Review - other	Staff provided comments on the draft PSE II work plan. Project Overview Page 1-1 Please state what authority this work is being conducted under. For example: “These activities were conducted in accordance with the Alaska Department of Environmental Conservation (ADEC) site cleanup rules (18 Alaska Administrative Code [AAC] 75 Sections 325 to 390).” Page 1-2 Please state that the work plan has been also drafted in accordance with: “The Final Basewide Uniform Federal Policy-Quality Assurance Project Plan (Basewide UFP-QAPP), which was approved by the United States Environmental Protection Agency (EPA) and ADEC on April 1, 2013.” Base Description 2rd Paragraph Add text with discusses NPL listing and other Two-Party Agreements, for example: “Fort Richardson was proposed for placement on the CERCLA National Priorities List (NPL) on June 18, 1993 and listed on June 1, 1994. The EPA (Region 10), the Alaska Department of Environmental Conservation (ADEC), and the United States Department of the Army signed a Federal Facility Agreement (FFA) for Fort Richardson on December 5, 1994. Fort Richardson also negotiated the State-Fort Richardson Environmental Restoration Agreement (Two-Party Agreement) for Non-UST source areas with ADEC for petroleum contaminated source areas not associated with USTs on November 3, 1994.” Preliminary Source Evaluation Tasks Add as part of data QA/QC or data interpretation the report will include completed ADEC Laboratory Data Review Checklists. WS #11 Data Quality Objectives QAPP-17 Analytical Approach Soil samples will be taken from the highest PID field screening result or based on best professional judgment if PID results are negative and two intervals (5’ apart) below the highest field screening result. Collecting from the upper and lower limit of contamination and highest PID reading location will not determine the full vertical extent of contamination if the highest PID or lower limit of contamination (based on PID results) is at the bottom of the boring and no additional samples are taken below this location. RCRA Metals analyses is stated as being analyzed by SW6020/SW7471. Be aware that this is for all metals except mercury. Mercury analysis must be conducted by analytical method 7471B and preserved 4 degrees C plus/minus 2 degrees C with a holding time of 28 days (ADEC Draft Field Sampling Guidance Appendix D May 2010). See site file for additional information.	Louis Howard
5/15/2014	Document, Report, or Work plan Review - other	EPA provided comments on the Draft PSE2 WP. 1.0 Project Overview In an effort to be clear about work conducted at the military bases, please clarify if this is action is taken pursuant to any CERCLA legal authority. The reference to an AFCEC contract does not define the authority. Please update the references & corresponding information throughout the document from DoD QSM v4.2 to DoD QSM v5.0, which was released in July 2013. Work plan Rationale 4.0 , p. 4-1 The PSE II report should provide information if contaminants exist above project screening or action levels, but does not include a risk assessment or feasibility study to evaluate remedial actions. This workplan does not include either of these components. Please revise the sentence to be more reflective of the CERCLA process: “the data gathered from the PSEII should provide the necessary information to determine if the site warrants inclusion in the Fort Richardson FFA & follow the cleanup process as established under CERCLA” PS Evaluation Tasks 4.1, p. 4-1 As this is a PSE II workplan & contaminants at the site are unknown, the list of target analyte categories/ method in both soils & GW should be expanded to include: VOCs / SW8260 low level Pesticides / SW8081 Herbicides / SW8151 Explosives / SW8095 Dioxins/Furans / SW8290 for any charred layers encountered in soils or soil borings. Please make these revisions throughout the document or provide rationale as to why these analyte categories should not be investigated. Depending what type of waste is generated & if this work is conducted under CERCLA authority, the listed waste subcontractors are not approved to accept CERLCA wastes (off-site rule interpretation) W#10 CSM Please revise the graphic in Appendix A to include: • for surface soils, under the receptor category Farmers or subsistence harvesters, add C/F to the three exposure routes. Section 1.0 of the ADEC form, as well as the CSM narrative, mentions this pathway. • ECO as a receptor category. The narrative of the CSM on page 12-14 support the inclusion of wildlife as potential receptors. W#12 VOCs p. QAPP-24 EPA approved the JBER Basewide UFP-QAPP in April 2013 & an example of a VOC-SW8260 W#12 is provided as an attachment as an example. Most of the criteria to evaluate PARCCS were included on the approved QAPP W#12 & are recommended to be included in this workplan. Similar comments pertain to W#12 SVOCs, PCBs & Metals. W#14/16 The row with perform fieldwork is very general, & W#17, p. QAPP-65, mentions that GW wells will be located based on the results of the contaminant concentrations in the soil borings. It seems the order of fieldwork & appropriate timelines should include: • Submit soil samples/ obtain laboratory results • Install MW/ submit GW samples/ obtain GW results W#15 For all the W#15 tables, please use a bold font, italic typeface, or shading to represent LODs &/or LOQs that are greater than Project Action Limits. For the SW8260 VOC-low soils; 1,2,3-TCP, EDB, both LODs & LOQs > PAL. For methylene chloride, the LOQ>PAL. How will a determination be made for methylene chloride as a contaminant verses a common laboratory contaminant in the blank? The LOD or LOQ> PAL for SW8260-med (MeOH preserved) for ~15 compounds; for SVOCs, ~10 compounds including munition constituents (NMDA, 2,4-DNT) Please define if there is a difference between Project Action Limits & Project Cleanup Limits. W#15 Metals soils p. QAPP-52 Lead PAL should be footnoted to specify this is based on soil direct contact. The JBER background metal concentrations vary across the installation, but would provide a more realistic project cleanup value than the Migration to GW value. For example, the draft Feb 2013 RI/FS for SS22 (page 4-149) provides for a range of values depending on soil profile depth for these metals in soils. In the SS22 document, arsenic background levels ranged from 9.0 to 6 mg/kg from surface to deep profile. W#15 Metals GW p. QAPP-52 The values for the Project Action Limits are not 18 AAC75 Table C but appear to be 1/10th of the Migration to GW. For example, the Table C GW cleanup level (mg/L) is 0.010; barium is 2.0; cadmium is 0.005, etc… Please revise the table to use the correct Project Action Levels. W#17 Chemical & Non-chemical analysis: please expand on this section to describe the non-chemical techniques (magnetometer, XRF,) that will be employed at the site prior to soil boring & sampling. As the extent of remaining contamination is unknown & the 1957 photos showing this as a debris disposal area, an expanded list of analyte categories is justified (see comment #3)	Louis Howard
6/11/2014	Document, Report, or Work plan Review - other	ADEC agrees with responses to ADEC's comments as long as comment #9 response for VOC analysis complies with the attached 2012 memorandum from the ADEC Laboratory Certification Officer.	Louis Howard
6/12/2014	Document, Report, or Work plan Review - other	Response to ADEC Comments DA090 Preliminary Source Evaluation II Work Plan Upon review of the responses by the Air Force, ADEC has no objection to the responses and the Air Force may finalize the document, pending incorporation of EPA comments on 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 do not relieve responsible persons from the need to comply with other applicable laws and regulations. The Air Force is responsible for the actions of contractors, agents, or other persons who perform work to implement the approved work plan. For any activity that significantly deviates from the approved plan, the Air Force shall notify the ADEC and EPA to obtain written approval in the form of a work plan amendment before beginning the activity.	Louis Howard
6/12/2014	Enforcement Agreement or Order	Federal Facility Agreement (FF A) Document Schedule for DA090 - RV Lot, JBER-Richardson. Attached for your review and acceptance is the proposed document schedule for DA090 - RV Lot on Joint Base Elmendorf-Richardson, Richardson (JBER-R), Alaska. If approved, the schedule will be attached to the current JBER-R FFA (5 December 1994). If you concur with the proposed schedule, please sign in the block provided on the attached signature page and return the original signature page to me. Should you have questions or comments, please feel free to contact me at (907) 384-1824. Primary Document: Draft Preliminary Source Evaluation 2 Report, date due for agency review: 15 May 2015. Signed by G. Fink USAF, S Halstead EPA, L Howard ADEC.	Louis Howard
5/11/2015	Update or Other Action	Draft PSE 2 Evaluation report received for review and comment. Benzene exceeded the PAL for soil in SB05 & detected in borings SB03 & SB16, immediately south & north of SB05. Surface soil sample results from a distressed vegetation area identified near SB06 exceeded PALs for arsenic, lead, cadmium, & TCE, which are all known carcinogens. Surface debris was also observed, but appeared localized. Chromium & arsenic are presumed naturally occurring as the levels detected were consistent with background levels. However, arsenic at the area of distressed vegetation & SB08 had concentrations that slightly exceeded background levels. Benzo(a)pyrene is the only contaminant to exceed the EPA RSL without also exceeding one-tenth the PAL. TCE was above 1/10th the PAL in three of the four monitoring wells, & detected in all four wells, indicating that migration to GW has occurred. The source of TCE is currently unknown. Although benzene results were nondetect in all four wells, additional soil borings & monitoring wells are needed to fully characterize the extent of benzene contamination. There is currently no evidence for benzene migration to GW, but no wells are positioned immediately adjacent to SB05, & the only well downgradient from SB05 (MW03) is located more than 1,200’ to the NW. Future Remedial Investigation (RI) site work should include geophysical surveying, excavation of test pits, GW well installation, soil boring installation, & soil & GW sampling. A minimum of four geophysical transects are recommended to identify potential source areas. Any anomalies identified during the survey should be investigated through test pits, field screening, & analytical sampling. Soil borings should be advanced to GW to further characterize & more fully delineate the lateral & vertical extents contamination identified in this PSE II investigation. In addition, benzo(a)pyrene should be retained for analysis & results compared to the more stringent EPA RSL based on 2014 levels that exceed this more stringent criterion in two surface soil locations. A follow-up RI Report would then be prepared to document the information collected, characterize the environmental conditions, define the nature & extent of contamination, quantitatively estimate the risk to human health & to the environment, & update the conceptual site model. A subsequent Feasibility Study will synthesize RI data to develop & evaluate remedial alternatives where identified risks to human health &/or the environment exceed acceptable levels	Louis Howard
5/12/2015	Document, Report, or Work plan Review - other	Staff provided comments on the draft PSE II Report. Main comment was that staff agreed a remedial investigation (RI) will need to be conducted. The RI will be conducted pursuant to CERCLA, the NCP, applicable state law, pertinent written national guidance, U.S. EPA national policy, and the 1994 Fort Richardson Federal Facility Agreement. Prior to the development of either a Statement of Work, Management Plan, the Project Managers [U.S. EPA, ADEC and JBER] shall meet to develop a Scope of Work to be used when preparing a Management Plan for a RI.	Louis Howard
6/5/2015	Document, Report, or Work plan Review - other	EPA S. Halstead provides comments on the PSE 2 draft report. 1. Sec 1.4, p. 1-7 contains a description of this site relative to the 2 party agreement. That seems a bit out of context and it would be better to cite the NPL and FFA since this isn’t a 2 party site. 2. P. 1-13 references areas of permafrost. Is that true? I’m unaware of any permafrost in SC AK with the exception of a funky block out by Birchwood. 3. Sec 2.3 soil results provide the results for explosives and dioxins. I didn’t catch that at the time of the workplan, but we probably should have used incremental soil sampling for these categories of potential contaminants. Doesn’t need to be changed now, just an FYI for future investigations with these contaminant categories.	Louis Howard
6/29/2015	Document, Report, or Work plan Review - other	Staff reviewed and approved the final version of the Preliminary Source Evaluation II report.	Louis Howard
10/2/2015	Update or Other Action	Staff received the draft RI/FS work plan for review & comment. The following activities will be performed: • Geophysical survey – Complete a minimum of 4 geophysical transects (approximately east to west) to identify the potential for additional buried debris at the site (Figure A-4 in Appendix A). • Test pit excavation – Excavate up to 5 test pits to investigate anomalies identified by the geophysical survey. • Test pit sampling – Collect field screening samples & analyze using a PID & collect up to 5 analytical characterization samples for GRO, DRO, RRO, VOCs, SVOCs/PAHs, PCBs, & RCRA metals. Samples may be analyzed for dioxin/furan (SW8290) if evidence of charring is found, & explosives analysis (SW8330B) may be conducted if warranted based on field observations. • Soil boring advancement – Advance 12 soil borings to GW (approximately 70 to 80 feet bgs). Record visual & olfactory observations & field screening values. • GW well advancement & installation – Install 6 GW monitoring wells according to the procedures listed in JBER-SOP-1200 Monitoring Well Installation & Development (Appendix B) to a depth of approximately 90' bgs based on an approximate depth to GW of 70 to 80' bgs. • Soil sampling – Collect field screening soil samples every 5' to 40' bgs, followed by every 20' to the GW interface, & collect three analytical soil samples per boring/monitoring well location. Soil samples will be analyzed as specified for the test pits. • Well Development – Develop GW wells at least 24 hours after installation using EPA & ADEC low-flow guidelines (EPA 2009b; ADEC 2010). • GW sampling – Collect 1 analytical GW sample at least 24 hours after development from each of the 6 newly installed (2015) wells & from the 4 existing 2014 wells. GW samples will be analyzed for GRO, DRO, RRO, VOCs, SVOCs, PAHs, PCBs, RCRA metals, & ethylene dibromide (EDB)/1,2,3-TCP. • Site Survey – Collect survey data using real-time kinematic GPS equipment to document the locations of the soil borings & newly installed wells. Top of casing elevations for the newly installed wells will be surveyed using differential level-loop methods. • IDW Disposal – Manage all IDW (i.e., used PPE & sampling equipment, soil cuttings, & decontamination/purge water) & ensure proper disposal. The proposed soil boring & GW monitoring well locations presented in Figure A-5 (Appendix A) are based on the areas where soil contamination was previously identified, disturbed areas observed in a 1957 aerial photograph, & the GW flow direction. The soil boring & monitoring well locations may be modified based on site conditions, field observations, & analytical results during the field effort with the overall intent of determining the nature & extent of contaminated soil & GW. Any modifications to soil boring & monitoring well locations will be coordinated with USAF, EPA, & ADEC.	Louis Howard
10/26/2015	Document, Report, or Work plan Review - other	Staff provided comments on the draft RI/FS work plan. Main comments were requesting clarification on the data being used for the risk assessment and how it will be screened out and still represent current and potential future exposures to contamination at DA090. Staff requested TCE contamination at the site be looked at in light of the EPA December 2012 TCE memo regarding TCE contamination and risk assessments. Finally, staff requested that ecological risk assessment be discussed further in the document since the ecoscoping form did not list any "off-ramps" to justify not looking at ecological risk assessment at DA090. See site file for additional information.	Louis Howard
1/4/2016	Document, Report, or Work plan Review - other	Technical memorandum for geophysical investigation at DA090 received. Staff concurred with AFCEC’s recommendations that Anomalies A1 – A5 be characterized by test pit excavation, observation, and soil sampling. The work will be done in accordance with the 1994 Fort Richardson Federal Facility Agreement (FFA). The geophysical results will be incorporated in a future remedial investigation at DA090 to determine fully the nature and extent of the threat to the public health or welfare or the environment caused by the release or threatened release of hazardous substances, pollutants, or contaminants at the Site , and to establish requirements for the performance of an FS for the Site to identify, evaluate, and select alternatives for the appropriate remedial action(s) to prevent, mitigate, or abate the release or threatened release of hazardous substances, pollutants, or contaminants at the Site in accordance with CERCLA and applicable state law . ADEC will approve the technical memorandum as a final version, pending incorporation of EPA’s comments/concerns.	Louis Howard
1/27/2016	Meeting or Teleconference Held	Conference call held with JBER, contractor (Jacobs), EPA and ADEC staff. Decision was made to move three soil borings - on the downgradient portion of MW-04 and one in the "distressed vegetation" area.	Louis Howard
2/21/2018	Update or Other Action	Draft DA090 Remedial Investigation Report received for review and comment. The following COCs have been retained for each media: Surface soil: Lead (future child resident). Subsurface soil: Dioxin/furan compounds (current/future industrial/commercial worker). Combined surface and subsurface soil: 1,2,3-TCP (future adult resident), Dioxin/furan compounds (future adult resident, future child resident), PCBs (future child resident) and Vanadium (future child resident). Groundwater: TCE (future adult resident, future child resident), PCE (future adult resident, future child resident) and Lead (future child resident). Arsenic, in soil and groundwater, was at concentrations similar to background and, therefore, is not retained as a COC. There were no COCs for soil or groundwater retained for the future site employee, current/future construction worker, current/future adult recreator, or current/future child recreator. TCE is bounded downgradient and crossgradient. Although there is a slight exceedance on the upgradient edge, it is at a concentration where attenuation will occur relatively rapidly. PCE is unbounded but is associated with upgradient and crossgradient sources located southeast and west of DA090, which do not overlap with the TCE plume emanating from DA090. Chloroform is widespread and likely associated with an upgradient source. Although it is unbounded, concentrations are not high enough to significantly contribute to human health or ecological risk at DA090. It is recommended that a FS be completed to determine which remedial actions, if any, should be performed at DA090. See site file for additional information.	Louis Howard
4/16/2018	Document, Report, or Work plan Review - other	Staff reviewed and commented on the draft remedial investigation report. Main comments were to state that the source of PCE in the groundwater at DA090 is from DA090 since it is the only logical upgradient source of contamination for well MW-08. Also staff commented on the fact that if you don't know the source of contamination, the persistence of the contaminant is unknown and not known whether the source is a current ongoing release or historical contamination, then you can't say that natural attenuation is expected. See site file for additional information.	Louis Howard
12/18/2018	CERCLA FS	Staff reviewed responses to ADECs comments on the Feasibility Study and approved the responses and redline version of the document incorporating the changes which will proceed to a final version of the document.	Louis Howard
12/18/2018	CERCLA RI Report Approved	Staff reviewed the revised responses to its comments made on the draft-final remedial investigation report and approved the responses and redline version of the document to go to a final version.	Louis Howard
3/26/2020	Update or Other Action	DA090 supplemental RI/FS Management Plan received for review and comment. The objective of this Supplemental RI/FS is to: Determine the nature and extent of hazardous substances, pollutants, or contaminants at the site, and to establish requirements for the performance of an updated FS. The supplemental FS shall update the prior FS and identify, evaluate and select alternatives for the appropriate remedial action(s) that prevent, mitigate or abate those hazardous substances that could pose a potential environmental risk to human health and the environment in accordance with CERCLA, the existing Fort Richardson FFA and the requirements established in 18 AAC 75 and 78. See site file for additional information.	Louis Howard
4/20/2020	Document, Report, or Work plan Review - other	Staff commented on the Draft Supplemental RI/FS Mgt Plan for DA090 – RV Parking Lot Drum Site. Main comments were regrading to-be-considered requirements & referenced in record of decisions. Chemical-specific to-be-considered TBC values such as health advisories & reference doses will be used in the absence of ARARs or where ARARs are not sufficiently protective to develop cleanup goals. After the risk assessment has been conducted, if no ARARs address a particular situation, or if existing ARARs do not ensure protectiveness, to-be-considered advisories, criteria, or guidelines should be used to set cleanup targets. Once a TBC is selected in a Record of Decision as a requirement, it becomes a binding performance standard with which the chosen remedy must comply. All soil results from the supplemental Remedial Investigation will be compared to the more stringent of 1/10th of the Method Two Human Health level & the ADEC migration to groundwater cleanup levels for further action under State authority per 18 AAC 75. Results to be included in a table in the draft & final document. See site file for additional information.	Louis Howard
4/12/2021	Document, Report, or Work plan Review - other	DEC submitted comments on Draft JBER Basewide UFP-QAPP dated February 2021.	William Schmaltz
5/19/2021	Document, Report, or Work plan Review - other	DEC Reviewed and approved of Basewide Uniform Federal Policy - Quality Assurance Project Plan. QAPP summarizes general activities for a 5 year period on JBER.	William Schmaltz
11/3/2021	Document, Report, or Work plan Review - other	DEC Reviewed and approved Addendum #1 to the Final 2020 Field Sampling Plan and UFP-QAPP. Work Plan describes steps and processes to be conducted to perform an additional round of groundwater monitoring, monitoring well gauging, slug testing, and a geophysical survey at Site DA090 – RV Parking Lot Drum Site, Joint Base Elmendorf-Richardson, Alaska	William Schmaltz
4/25/2022	Document, Report, or Work plan Review - other	DEC reviewed and approved Final Data Gap Technical Memorandum Supplemental Remedial Investigation/Feasibility Study, DA090 – RV Parking Lot Drum Site, Joint Base Elmendorf-Richardson, Alaska, March 2022. The Technical Memorandum (Tech Memo) addresses data gaps identified as part of the 2021 investigation activities for the Supplemental RI/FS being conducted at DA090.	William Schmaltz
5/26/2022	Document, Report, or Work plan Review - other	DEC reviewed Draft-Final Quality Assurance Project Plan Addendum #2 to the Final 2020 Field Sampling Plan and UPF-QAPP, Supplemental Remedial Investigation/Feasibility Study Site DA090 – RV Parking Lot Drum Site, Joint Base Elmendorf-Richardson, Alaska. Disagreements about DEC’s comment #1 in regards to projects screening levels remain. DEC recognizes the importance of the intended field sampling, and the USAF’s commitment to ensure analytical methods have limits of detection that are able to achieve the DEC migration to groundwater cleanup levels. DEC approves this document with the exception of QAPP WS# 11 and 15. DEC will evaluate the results of this field effort as presented in the draft report, to include whether the nature and extent of the contamination has been delineated, and whether the sufficient information has been gathered to determine the fate and transport of contamination over time.	William Schmaltz
9/14/2022	Offsite Soil or Groundwater Disposal Approved	ADEC approved the Contaminated Media Transport and Treatment or Disposal Approval Form for 41 tons of soil contaminated with TCE, PCE, and SVOCs to be transported to Chemical Waste Management of the Northwest in Oregon. Soil cuttings were generated from 7 test pits, 8 soil borings, and installation of 5 monitoring wells. Soil samples were analyzed for GRO, DRO, RRO, VOCs, SVOCs, PAHs, pesticides, herbicides, PCBs, and metals. Analytical results reported contaminants at concentrations less than the regulatory limit and waste is considered non-hazardous. TCE was detected at concentrations greater than EPA RSL and ADEC MTGW cleanup level. Soil cuttings are located in 23 55-gallon drums and 35 1-CY supersacks.	Ginna Quesada
3/9/2023	Document, Report, or Work plan Review - other	DEC reviewed Draft Site Inspection Report for DA090. Report summarized field activities that were conducted over multiple field season at the site. Additional soil and groundwater characterization activities are proposed for the site. DEC recommends additional characterization of PFAS to investigate PFAS detected in IDW water.	William Schmaltz
5/11/2023	Site Characterization Report Approved	DEC received and approved Final DA090 Site Characterization Report.	William Schmaltz

Action Date

Action

Description

DEC Staff

8/10/2012

Update or Other Action

Drum punctured during removal from excavation resulting in release of solvent onto the ground surface. Drums have been stockpiled in a lined and covered area to the east of the excavation and the punctured drum has been placed in an overpack for shipment.

Louis Howard

8/22/2012

Spill Transferred from Prevention Preparedness and Response Program

Spill transferred by PERP staff Jonathan Schick. Drum was punctured during removal activies for a new RV parking lot. Spill date = 8/10/12; spill no. 12239922301; substance = tetrachloroethene; quantity = 5 - 55 gallons.

Mitzi Read

8/27/2012

Site Added to Database

A new site has been added to the database

Mitzi Read

10/12/2012

Update or Other Action

Work Plan addendum received for FTR271. The FTR271 RV Lot site, located approximately ¼-mile north of the Davis Highway, along the east side of 27th Avenue on Joint Base Elmendorf-Richardson, Alaska, is currently an active construction site for the FTR271 RV Parking Lot. An emergency removal action will be conducted at the site to remove hazardous drums that present an immediate risk to safety, health, and the environment. These drums and associated debris were identified by the construction contractor in the northeast corner of the site. Drums will be characterized and removed following the procedures described in Section 4.5 of the Fort Richardson Post Wide Work Plan (USACE 2010) Once located, the drums will be evaluated to determine the potential for contents and/or gross contamination. If the drum is intact or has contents, it will be considered potentially hazardous and flagged for further investigation. Flagged drums will be carefully moved and put into a position where they can be opened and sampled. The contents will be characterized using hazard categorization procedures as described in Appendix B, Attachment B-3 of the Fort Richardson Post Wide Work Plan (USACE 2010) and will be sampled by personnel in Level B personal protective equipment. The drums will then be segregated into potential waste streams based on the HAZCAT results and visual observations. Analytical samples will be collected from each waste stream following the procedures described in Appendix B, Section 3.4 of the Fort Richardson Post Wide Work Plan (USACE 2010). Analytical waste samples will be prepared using toxicity characteristic leaching procedures (TCLP) by method SW1311. Once prepared, the samples will be analyzed for the following RCRA toxicity compounds: ? RCRA metals (SW6010/SW7470) ? pesticides (SW8081) ? herbicides (SW8151) ? VOCs (SW8260) ? SVOCs (SW8270) Drums will remain onsite pending the receipt of analytical results. The analytical results will be compared to the applicable ADEC cleanup levels, the RCRA toxicity limits, and the TSCA PCB limits. The waste will be handled, transported, and disposed of in accordance with applicable regulations based on the identified contaminant concentrations. Investigation-derived waste will be disposed of in the same manner as the associated drum contents. Metallic debris will be transported to a local recycling facility. Additional debris that cannot be recycled will be transported to the Anchorage Regional Landfill for disposal.

Louis Howard

10/31/2012

Update or Other Action

Email from JBER contractor Site Report for 30 October 2012 for the FTR271 sites: - Completed removal of all stockpiled soil from the TEMF site, and collected field screening and analytical samples from the north excavation. Field screening results also indicated that all contaminated soil had been removed from the north area. - Surveyed the excavation extents and sample locations at the TEMF site. - Mobilized EX160 to the RV Lot and began excavation and stockpiling of the PCB-contaminated soil. - Collected 3 samples from the excavation following the removal of the PCB-contaminated soil. The floor sample (native soil) had a fuel/solvent odor and had a PID reading of 135 ppm. The sidewall samples also had elevated PID readings. These samples will be submitted for fuels, VOCs, SVOCs, PCBs, and RCRA metals. - Collected one sample from the location of known PCB contamination (WC03) for TCLP lead analysis. LOOK AHEAD: - Continue to excavate and stockpile PCB-contaminated soil and collect remaining excavation samples. - Removal activities will be on hold pending analytical results and receipt of waste profile and manifests.

Louis Howard

1/2/2013

Exposure Tracking Model Ranking

Initial ranking with ETM completed for source area id: 79322 name: Drums

Louis Howard

2/20/2013

Update or Other Action

Draft Tech memo received. Equipment was mobilized to the RV parking lot site on 16 October 2012, & warning barricades & signs were placed around the work area prior to beginning excavation activities. Anomaly investigation activities began on 17 October 2012 at Debris Area 1, where Ancor encountered the buried drums. Soon after beginning the excavation, 55-gallon drums, metallic debris, & empty & crushed 2-gallon fuel cans were encountered. Metallic debris was segregated for recycling & the 55-gallon drums were initially left in place until a containment area could be prepared. An area with potential fuel contamination was identified by odor, & soil from the area was excavated & placed on a liner adjacent to the excavation area. Figure 2 displays the drum & debris removal excavation areas & corresponding geophysical anomalies. On 18 October 2012, investigative excavation activities continued north into the Anomaly 4 area. An exclusion zone was established surrounding the area of buried drums & workers entering the exclusion zone were required to wear Level C personal protective equipment. The field crew began removing drums from Debris Area 1, placing drums with contents into a containment area for characterization & crushing empty drums for recycling. Table 1 presents a summary of the drums with contents. Excavation activities progressed north through the Anomaly 4 area & into Debris Area 3. The drums & metallic debris were found in what appeared to be a disposal trench approximately 15 feet wide by 100 feet long & 8 to 10 feet deep. The soil used to cover the trench was a brown loamy soil, while the native subsurface soil observed at the site was grey sandy gravel with cobbles. Excavation activities continued 3 to 5 feet into the native soil to confirm that no additional debris was located outside the trench area. Metallic debris found in the disposal trench included vehicle tracks, demilitarized rifle barrels, a bus or travel trailer, & other miscellaneous scrap metal. Excavation at the Debris Area 1/Anomaly 4/Debris Area 3 disposal trench was completed on 20 October 2012. Jacobs removed 31 drums from this area in addition to the more than 20 drums previously removed by Ancor. Concentrations of DRO & solvent soil contamination greater than the ADEC migration to groundwater cleanup levels remain at the site. Concentrations of DRO exceeding the cleanup level are present at the east wall, north wall, & excavation floor, ranging from 858 to 1,370 mg/kg. Concentrations of the solvents 1,2-dichloroethane (0.0590 mg/kg) & 1,2,3- trichloropropane (0.109 mg/kg) are present at the excavation floor. Table 5 summarizes the soil contamination remaining onsite. The depth to groundwater at the site is unknown, but is assumed to be 70 to 120 feet bgs based on nearby monitoring well depths. Based on the contaminant concentrations remaining at the site & the depth to groundwater, it is unlikely that these contaminants have migrated to groundwater. The contaminant concentrations remaining at the site do not present a risk to site workers via direct contact or outdoor inhalation. Recommendations Due to the contamination remaining at the site, it is recommended that a site investigation be conducted to further assess the nature & extent of contamination. The investigation should consist of soil borings & sample collection from the soil surrounding & below the disposal trench. Installation of groundwater monitoring well(s) may be necessary if the soil samples indicate the potential for groundwater contamination.

Louis Howard

3/20/2013

Document, Report, or Work plan Review - other

EPA comments on the tech memo EPA received the Draft Recreation Vehicle Parking Lot Drum and Debris Removal Technical Memo for review on February 14, 2013. Figure 1 does not provide enough detail to cite the location of the RV Parking Lot Drum within the JBER installation. Figure 4-2, provided in an appendix of figures but not referenced in the technical memo, does a much better job at identifying street names to better place the physical location of the investigation. It is recommended to add building numbers to Figure 4-2, and reference Fig. 4-2 in the introductory paragraph with Figure 1, the large overview of the vicinity of the site. EPA agrees with the recommendation for additional site characterization . Please note, any future VOC soil analysis should not use a methanol preservative to obtain detection limits that meet EPA CERCLA cleanup levels. It is acknowledged that ADEC sampling guidance requires MeOH preservative for soil VOCs analysis. This may require samples analyzed in both matrices.

Louis Howard

3/20/2013

Document, Report, or Work plan Review - other

The Alaska Department of Environmental Conservation has received the removal after action report on March 15, 2013 for review and comment. ADEC concurs with the recommendations of the report and requests a formal work plan be submitted for review and comment prior to field work commencing. ADEC requires methanol preservation for VOC analysis of soils and EPA requires the detection limits for CERCLA cleanup levels be met that methanol preservation cannot meet. Future analysis of soil samples should have both methanol preserved analysis and “low-level” analysis performed if VOCs are to be analyzed.

Louis Howard

11/4/2013

Document, Report, or Work plan Review - other

Staff reviewed and approved the responses to comments on the technical memorandum.

Louis Howard

4/4/2014

Update or Other Action

PSE II work plan received for review and comment. The objectives of the 2014 PSE II are to determine and document the nature and extent of contamination in soil and groundwater, and determine whether any potential actions are necessary to protect human health and the environment. These objectives will be achieved by advancing and sampling soil borings as well as installing and sampling groundwater monitoring wells. The data gathered from the PSE II should provide the necessary information to determine the cleanup approach for the site, which will be included with the PSE II Report. The following activities will be performed at the site: • Mobilize and prepare for site work. • Advance 16 soil borings to groundwater (approximately 90 feet bgs) or until vertical extent of contamination is delineated. If no evidence of soil contamination (field screening and observations) is identified in the first 30 feet of the soil boring, drilling will cease and an analytical sample will be collected from the bottom of the soil boring and the two highest PID field screening result locations. If the analytical result determines that contamination is present, then the location will be re-drilled to greater depths to determine the lower limit of contamination. • Collect field screening readings using PID every 5 feet for the first 20 feet and every 10 feet thereafter. • Record visual and olfactory observations. • Collect analytical samples from three locations within each boring. • Submit soil samples for offsite laboratory analysis of the following analytes: - GRO by AK101 - DRO by AK102 - RRO by AK103 - VOCs by SW8260 - SVOCs by SW8270 - PCBs by SW8082 - RCRA Metals by SW6020/7471 • Install four groundwater monitoring wells according to the procedures listed in JBERSOP-1200 Monitoring Well Installation and Development; the depth to groundwater is approximately 90 feet bgs. • Develop groundwater wells and collect analytical groundwater samples from the newly installed wells. Groundwater samples will be submitted for the following analytes: - GRO by AK101 - DRO by AK102 - RRO by AK103 - VOCs by SW8260 - SVOCs by SW8270 - PCBs by SW8082 - RCRA Metals by SW6020/7471 • Collect survey data from soil borings and newly installed groundwater monitoring wells using real-time kinematic global positioning survey (GPS) and conventional level loop surveying equipment. • Manage all IDW generated during the field activities. • Restore the site and demobilize

Louis Howard

4/28/2014

Document, Report, or Work plan Review - other

Staff provided comments on the draft PSE II work plan. Project Overview Page 1-1 Please state what authority this work is being conducted under. For example: “These activities were conducted in accordance with the Alaska Department of Environmental Conservation (ADEC) site cleanup rules (18 Alaska Administrative Code [AAC] 75 Sections 325 to 390).” Page 1-2 Please state that the work plan has been also drafted in accordance with: “The Final Basewide Uniform Federal Policy-Quality Assurance Project Plan (Basewide UFP-QAPP), which was approved by the United States Environmental Protection Agency (EPA) and ADEC on April 1, 2013.” Base Description 2rd Paragraph Add text with discusses NPL listing and other Two-Party Agreements, for example: “Fort Richardson was proposed for placement on the CERCLA National Priorities List (NPL) on June 18, 1993 and listed on June 1, 1994. The EPA (Region 10), the Alaska Department of Environmental Conservation (ADEC), and the United States Department of the Army signed a Federal Facility Agreement (FFA) for Fort Richardson on December 5, 1994. Fort Richardson also negotiated the State-Fort Richardson Environmental Restoration Agreement (Two-Party Agreement) for Non-UST source areas with ADEC for petroleum contaminated source areas not associated with USTs on November 3, 1994.” Preliminary Source Evaluation Tasks Add as part of data QA/QC or data interpretation the report will include completed ADEC Laboratory Data Review Checklists. WS #11 Data Quality Objectives QAPP-17 Analytical Approach Soil samples will be taken from the highest PID field screening result or based on best professional judgment if PID results are negative and two intervals (5’ apart) below the highest field screening result. Collecting from the upper and lower limit of contamination and highest PID reading location will not determine the full vertical extent of contamination if the highest PID or lower limit of contamination (based on PID results) is at the bottom of the boring and no additional samples are taken below this location. RCRA Metals analyses is stated as being analyzed by SW6020/SW7471. Be aware that this is for all metals except mercury. Mercury analysis must be conducted by analytical method 7471B and preserved 4 degrees C plus/minus 2 degrees C with a holding time of 28 days (ADEC Draft Field Sampling Guidance Appendix D May 2010). See site file for additional information.

Louis Howard

5/15/2014

Document, Report, or Work plan Review - other

EPA provided comments on the Draft PSE2 WP. 1.0 Project Overview In an effort to be clear about work conducted at the military bases, please clarify if this is action is taken pursuant to any CERCLA legal authority. The reference to an AFCEC contract does not define the authority. Please update the references & corresponding information throughout the document from DoD QSM v4.2 to DoD QSM v5.0, which was released in July 2013. Work plan Rationale 4.0 , p. 4-1 The PSE II report should provide information if contaminants exist above project screening or action levels, but does not include a risk assessment or feasibility study to evaluate remedial actions. This workplan does not include either of these components. Please revise the sentence to be more reflective of the CERCLA process: “the data gathered from the PSEII should provide the necessary information to determine if the site warrants inclusion in the Fort Richardson FFA & follow the cleanup process as established under CERCLA” PS Evaluation Tasks 4.1, p. 4-1 As this is a PSE II workplan & contaminants at the site are unknown, the list of target analyte categories/ method in both soils & GW should be expanded to include: VOCs / SW8260 low level Pesticides / SW8081 Herbicides / SW8151 Explosives / SW8095 Dioxins/Furans / SW8290 for any charred layers encountered in soils or soil borings. Please make these revisions throughout the document or provide rationale as to why these analyte categories should not be investigated. Depending what type of waste is generated & if this work is conducted under CERCLA authority, the listed waste subcontractors are not approved to accept CERLCA wastes (off-site rule interpretation) W#10 CSM Please revise the graphic in Appendix A to include: • for surface soils, under the receptor category Farmers or subsistence harvesters, add C/F to the three exposure routes. Section 1.0 of the ADEC form, as well as the CSM narrative, mentions this pathway. • ECO as a receptor category. The narrative of the CSM on page 12-14 support the inclusion of wildlife as potential receptors. W#12 VOCs p. QAPP-24 EPA approved the JBER Basewide UFP-QAPP in April 2013 & an example of a VOC-SW8260 W#12 is provided as an attachment as an example. Most of the criteria to evaluate PARCCS were included on the approved QAPP W#12 & are recommended to be included in this workplan. Similar comments pertain to W#12 SVOCs, PCBs & Metals. W#14/16 The row with perform fieldwork is very general, & W#17, p. QAPP-65, mentions that GW wells will be located based on the results of the contaminant concentrations in the soil borings. It seems the order of fieldwork & appropriate timelines should include: • Submit soil samples/ obtain laboratory results • Install MW/ submit GW samples/ obtain GW results W#15 For all the W#15 tables, please use a bold font, italic typeface, or shading to represent LODs &/or LOQs that are greater than Project Action Limits. For the SW8260 VOC-low soils; 1,2,3-TCP, EDB, both LODs & LOQs > PAL. For methylene chloride, the LOQ>PAL. How will a determination be made for methylene chloride as a contaminant verses a common laboratory contaminant in the blank? The LOD or LOQ> PAL for SW8260-med (MeOH preserved) for ~15 compounds; for SVOCs, ~10 compounds including munition constituents (NMDA, 2,4-DNT) Please define if there is a difference between Project Action Limits & Project Cleanup Limits. W#15 Metals soils p. QAPP-52 Lead PAL should be footnoted to specify this is based on soil direct contact. The JBER background metal concentrations vary across the installation, but would provide a more realistic project cleanup value than the Migration to GW value. For example, the draft Feb 2013 RI/FS for SS22 (page 4-149) provides for a range of values depending on soil profile depth for these metals in soils. In the SS22 document, arsenic background levels ranged from 9.0 to 6 mg/kg from surface to deep profile. W#15 Metals GW p. QAPP-52 The values for the Project Action Limits are not 18 AAC75 Table C but appear to be 1/10th of the Migration to GW. For example, the Table C GW cleanup level (mg/L) is 0.010; barium is 2.0; cadmium is 0.005, etc… Please revise the table to use the correct Project Action Levels. W#17 Chemical & Non-chemical analysis: please expand on this section to describe the non-chemical techniques (magnetometer, XRF,) that will be employed at the site prior to soil boring & sampling. As the extent of remaining contamination is unknown & the 1957 photos showing this as a debris disposal area, an expanded list of analyte categories is justified (see comment #3)

Louis Howard

6/11/2014

Document, Report, or Work plan Review - other

ADEC agrees with responses to ADEC's comments as long as comment #9 response for VOC analysis complies with the attached 2012 memorandum from the ADEC Laboratory Certification Officer.

Louis Howard

6/12/2014

Document, Report, or Work plan Review - other

Response to ADEC Comments DA090 Preliminary Source Evaluation II Work Plan Upon review of the responses by the Air Force, ADEC has no objection to the responses and the Air Force may finalize the document, pending incorporation of EPA comments on 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 do not relieve responsible persons from the need to comply with other applicable laws and regulations. The Air Force is responsible for the actions of contractors, agents, or other persons who perform work to implement the approved work plan. For any activity that significantly deviates from the approved plan, the Air Force shall notify the ADEC and EPA to obtain written approval in the form of a work plan amendment before beginning the activity.

Louis Howard

6/12/2014

Enforcement Agreement or Order

Federal Facility Agreement (FF A) Document Schedule for DA090 - RV Lot, JBER-Richardson. Attached for your review and acceptance is the proposed document schedule for DA090 - RV Lot on Joint Base Elmendorf-Richardson, Richardson (JBER-R), Alaska. If approved, the schedule will be attached to the current JBER-R FFA (5 December 1994). If you concur with the proposed schedule, please sign in the block provided on the attached signature page and return the original signature page to me. Should you have questions or comments, please feel free to contact me at (907) 384-1824. Primary Document: Draft Preliminary Source Evaluation 2 Report, date due for agency review: 15 May 2015. Signed by G. Fink USAF, S Halstead EPA, L Howard ADEC.

Louis Howard

5/11/2015

Update or Other Action

Draft PSE 2 Evaluation report received for review and comment. Benzene exceeded the PAL for soil in SB05 & detected in borings SB03 & SB16, immediately south & north of SB05. Surface soil sample results from a distressed vegetation area identified near SB06 exceeded PALs for arsenic, lead, cadmium, & TCE, which are all known carcinogens. Surface debris was also observed, but appeared localized. Chromium & arsenic are presumed naturally occurring as the levels detected were consistent with background levels. However, arsenic at the area of distressed vegetation & SB08 had concentrations that slightly exceeded background levels. Benzo(a)pyrene is the only contaminant to exceed the EPA RSL without also exceeding one-tenth the PAL. TCE was above 1/10th the PAL in three of the four monitoring wells, & detected in all four wells, indicating that migration to GW has occurred. The source of TCE is currently unknown. Although benzene results were nondetect in all four wells, additional soil borings & monitoring wells are needed to fully characterize the extent of benzene contamination. There is currently no evidence for benzene migration to GW, but no wells are positioned immediately adjacent to SB05, & the only well downgradient from SB05 (MW03) is located more than 1,200’ to the NW. Future Remedial Investigation (RI) site work should include geophysical surveying, excavation of test pits, GW well installation, soil boring installation, & soil & GW sampling. A minimum of four geophysical transects are recommended to identify potential source areas. Any anomalies identified during the survey should be investigated through test pits, field screening, & analytical sampling. Soil borings should be advanced to GW to further characterize & more fully delineate the lateral & vertical extents contamination identified in this PSE II investigation. In addition, benzo(a)pyrene should be retained for analysis & results compared to the more stringent EPA RSL based on 2014 levels that exceed this more stringent criterion in two surface soil locations. A follow-up RI Report would then be prepared to document the information collected, characterize the environmental conditions, define the nature & extent of contamination, quantitatively estimate the risk to human health & to the environment, & update the conceptual site model. A subsequent Feasibility Study will synthesize RI data to develop & evaluate remedial alternatives where identified risks to human health &/or the environment exceed acceptable levels

Louis Howard

5/12/2015

Document, Report, or Work plan Review - other

Staff provided comments on the draft PSE II Report. Main comment was that staff agreed a remedial investigation (RI) will need to be conducted. The RI will be conducted pursuant to CERCLA, the NCP, applicable state law, pertinent written national guidance, U.S. EPA national policy, and the 1994 Fort Richardson Federal Facility Agreement. Prior to the development of either a Statement of Work, Management Plan, the Project Managers [U.S. EPA, ADEC and JBER] shall meet to develop a Scope of Work to be used when preparing a Management Plan for a RI.

Louis Howard

6/5/2015

Document, Report, or Work plan Review - other

EPA S. Halstead provides comments on the PSE 2 draft report. 1. Sec 1.4, p. 1-7 contains a description of this site relative to the 2 party agreement. That seems a bit out of context and it would be better to cite the NPL and FFA since this isn’t a 2 party site. 2. P. 1-13 references areas of permafrost. Is that true? I’m unaware of any permafrost in SC AK with the exception of a funky block out by Birchwood. 3. Sec 2.3 soil results provide the results for explosives and dioxins. I didn’t catch that at the time of the workplan, but we probably should have used incremental soil sampling for these categories of potential contaminants. Doesn’t need to be changed now, just an FYI for future investigations with these contaminant categories.

Louis Howard

6/29/2015

Document, Report, or Work plan Review - other

Staff reviewed and approved the final version of the Preliminary Source Evaluation II report.

Louis Howard

10/2/2015

Update or Other Action

Staff received the draft RI/FS work plan for review & comment. The following activities will be performed: • Geophysical survey – Complete a minimum of 4 geophysical transects (approximately east to west) to identify the potential for additional buried debris at the site (Figure A-4 in Appendix A). • Test pit excavation – Excavate up to 5 test pits to investigate anomalies identified by the geophysical survey. • Test pit sampling – Collect field screening samples & analyze using a PID & collect up to 5 analytical characterization samples for GRO, DRO, RRO, VOCs, SVOCs/PAHs, PCBs, & RCRA metals. Samples may be analyzed for dioxin/furan (SW8290) if evidence of charring is found, & explosives analysis (SW8330B) may be conducted if warranted based on field observations. • Soil boring advancement – Advance 12 soil borings to GW (approximately 70 to 80 feet bgs). Record visual & olfactory observations & field screening values. • GW well advancement & installation – Install 6 GW monitoring wells according to the procedures listed in JBER-SOP-1200 Monitoring Well Installation & Development (Appendix B) to a depth of approximately 90' bgs based on an approximate depth to GW of 70 to 80' bgs. • Soil sampling – Collect field screening soil samples every 5' to 40' bgs, followed by every 20' to the GW interface, & collect three analytical soil samples per boring/monitoring well location. Soil samples will be analyzed as specified for the test pits. • Well Development – Develop GW wells at least 24 hours after installation using EPA & ADEC low-flow guidelines (EPA 2009b; ADEC 2010). • GW sampling – Collect 1 analytical GW sample at least 24 hours after development from each of the 6 newly installed (2015) wells & from the 4 existing 2014 wells. GW samples will be analyzed for GRO, DRO, RRO, VOCs, SVOCs, PAHs, PCBs, RCRA metals, & ethylene dibromide (EDB)/1,2,3-TCP. • Site Survey – Collect survey data using real-time kinematic GPS equipment to document the locations of the soil borings & newly installed wells. Top of casing elevations for the newly installed wells will be surveyed using differential level-loop methods. • IDW Disposal – Manage all IDW (i.e., used PPE & sampling equipment, soil cuttings, & decontamination/purge water) & ensure proper disposal. The proposed soil boring & GW monitoring well locations presented in Figure A-5 (Appendix A) are based on the areas where soil contamination was previously identified, disturbed areas observed in a 1957 aerial photograph, & the GW flow direction. The soil boring & monitoring well locations may be modified based on site conditions, field observations, & analytical results during the field effort with the overall intent of determining the nature & extent of contaminated soil & GW. Any modifications to soil boring & monitoring well locations will be coordinated with USAF, EPA, & ADEC.

Louis Howard

10/26/2015

Document, Report, or Work plan Review - other

Staff provided comments on the draft RI/FS work plan. Main comments were requesting clarification on the data being used for the risk assessment and how it will be screened out and still represent current and potential future exposures to contamination at DA090. Staff requested TCE contamination at the site be looked at in light of the EPA December 2012 TCE memo regarding TCE contamination and risk assessments. Finally, staff requested that ecological risk assessment be discussed further in the document since the ecoscoping form did not list any "off-ramps" to justify not looking at ecological risk assessment at DA090. See site file for additional information.

Louis Howard

1/4/2016

Document, Report, or Work plan Review - other

Technical memorandum for geophysical investigation at DA090 received. Staff concurred with AFCEC’s recommendations that Anomalies A1 – A5 be characterized by test pit excavation, observation, and soil sampling. The work will be done in accordance with the 1994 Fort Richardson Federal Facility Agreement (FFA). The geophysical results will be incorporated in a future remedial investigation at DA090 to determine fully the nature and extent of the threat to the public health or welfare or the environment caused by the release or threatened release of hazardous substances, pollutants, or contaminants at the Site , and to establish requirements for the performance of an FS for the Site to identify, evaluate, and select alternatives for the appropriate remedial action(s) to prevent, mitigate, or abate the release or threatened release of hazardous substances, pollutants, or contaminants at the Site in accordance with CERCLA and applicable state law . ADEC will approve the technical memorandum as a final version, pending incorporation of EPA’s comments/concerns.

Louis Howard

1/27/2016

Meeting or Teleconference Held

Conference call held with JBER, contractor (Jacobs), EPA and ADEC staff. Decision was made to move three soil borings - on the downgradient portion of MW-04 and one in the "distressed vegetation" area.

Louis Howard

2/21/2018

Update or Other Action

Draft DA090 Remedial Investigation Report received for review and comment. The following COCs have been retained for each media: Surface soil: Lead (future child resident). Subsurface soil: Dioxin/furan compounds (current/future industrial/commercial worker). Combined surface and subsurface soil: 1,2,3-TCP (future adult resident), Dioxin/furan compounds (future adult resident, future child resident), PCBs (future child resident) and Vanadium (future child resident). Groundwater: TCE (future adult resident, future child resident), PCE (future adult resident, future child resident) and Lead (future child resident). Arsenic, in soil and groundwater, was at concentrations similar to background and, therefore, is not retained as a COC. There were no COCs for soil or groundwater retained for the future site employee, current/future construction worker, current/future adult recreator, or current/future child recreator. TCE is bounded downgradient and crossgradient. Although there is a slight exceedance on the upgradient edge, it is at a concentration where attenuation will occur relatively rapidly. PCE is unbounded but is associated with upgradient and crossgradient sources located southeast and west of DA090, which do not overlap with the TCE plume emanating from DA090. Chloroform is widespread and likely associated with an upgradient source. Although it is unbounded, concentrations are not high enough to significantly contribute to human health or ecological risk at DA090. It is recommended that a FS be completed to determine which remedial actions, if any, should be performed at DA090. See site file for additional information.

Louis Howard

4/16/2018

Document, Report, or Work plan Review - other

Staff reviewed and commented on the draft remedial investigation report. Main comments were to state that the source of PCE in the groundwater at DA090 is from DA090 since it is the only logical upgradient source of contamination for well MW-08. Also staff commented on the fact that if you don't know the source of contamination, the persistence of the contaminant is unknown and not known whether the source is a current ongoing release or historical contamination, then you can't say that natural attenuation is expected. See site file for additional information.

Louis Howard

12/18/2018

CERCLA FS

Staff reviewed responses to ADECs comments on the Feasibility Study and approved the responses and redline version of the document incorporating the changes which will proceed to a final version of the document.

Louis Howard

12/18/2018

CERCLA RI Report Approved

Staff reviewed the revised responses to its comments made on the draft-final remedial investigation report and approved the responses and redline version of the document to go to a final version.

Louis Howard

3/26/2020

Update or Other Action

DA090 supplemental RI/FS Management Plan received for review and comment. The objective of this Supplemental RI/FS is to: Determine the nature and extent of hazardous substances, pollutants, or contaminants at the site, and to establish requirements for the performance of an updated FS. The supplemental FS shall update the prior FS and identify, evaluate and select alternatives for the appropriate remedial action(s) that prevent, mitigate or abate those hazardous substances that could pose a potential environmental risk to human health and the environment in accordance with CERCLA, the existing Fort Richardson FFA and the requirements established in 18 AAC 75 and 78. See site file for additional information.

Louis Howard

4/20/2020

Document, Report, or Work plan Review - other

Staff commented on the Draft Supplemental RI/FS Mgt Plan for DA090 – RV Parking Lot Drum Site. Main comments were regrading to-be-considered requirements & referenced in record of decisions. Chemical-specific to-be-considered TBC values such as health advisories & reference doses will be used in the absence of ARARs or where ARARs are not sufficiently protective to develop cleanup goals. After the risk assessment has been conducted, if no ARARs address a particular situation, or if existing ARARs do not ensure protectiveness, to-be-considered advisories, criteria, or guidelines should be used to set cleanup targets. Once a TBC is selected in a Record of Decision as a requirement, it becomes a binding performance standard with which the chosen remedy must comply. All soil results from the supplemental Remedial Investigation will be compared to the more stringent of 1/10th of the Method Two Human Health level & the ADEC migration to groundwater cleanup levels for further action under State authority per 18 AAC 75. Results to be included in a table in the draft & final document. See site file for additional information.

Louis Howard

4/12/2021

Document, Report, or Work plan Review - other

DEC submitted comments on Draft JBER Basewide UFP-QAPP dated February 2021.

William Schmaltz

5/19/2021

Document, Report, or Work plan Review - other

DEC Reviewed and approved of Basewide Uniform Federal Policy - Quality Assurance Project Plan. QAPP summarizes general activities for a 5 year period on JBER.

William Schmaltz

11/3/2021

Document, Report, or Work plan Review - other

DEC Reviewed and approved Addendum #1 to the Final 2020 Field Sampling Plan and UFP-QAPP. Work Plan describes steps and processes to be conducted to perform an additional round of groundwater monitoring, monitoring well gauging, slug testing, and a geophysical survey at Site DA090 – RV Parking Lot Drum Site, Joint Base Elmendorf-Richardson, Alaska

William Schmaltz

4/25/2022

Document, Report, or Work plan Review - other

DEC reviewed and approved Final Data Gap Technical Memorandum Supplemental Remedial Investigation/Feasibility Study, DA090 – RV Parking Lot Drum Site, Joint Base Elmendorf-Richardson, Alaska, March 2022. The Technical Memorandum (Tech Memo) addresses data gaps identified as part of the 2021 investigation activities for the Supplemental RI/FS being conducted at DA090.

William Schmaltz

5/26/2022

Document, Report, or Work plan Review - other

DEC reviewed Draft-Final Quality Assurance Project Plan Addendum #2 to the Final 2020 Field Sampling Plan and UPF-QAPP, Supplemental Remedial Investigation/Feasibility Study Site DA090 – RV Parking Lot Drum Site, Joint Base Elmendorf-Richardson, Alaska. Disagreements about DEC’s comment #1 in regards to projects screening levels remain. DEC recognizes the importance of the intended field sampling, and the USAF’s commitment to ensure analytical methods have limits of detection that are able to achieve the DEC migration to groundwater cleanup levels. DEC approves this document with the exception of QAPP WS# 11 and 15. DEC will evaluate the results of this field effort as presented in the draft report, to include whether the nature and extent of the contamination has been delineated, and whether the sufficient information has been gathered to determine the fate and transport of contamination over time.

William Schmaltz

9/14/2022

Offsite Soil or Groundwater Disposal Approved

ADEC approved the Contaminated Media Transport and Treatment or Disposal Approval Form for 41 tons of soil contaminated with TCE, PCE, and SVOCs to be transported to Chemical Waste Management of the Northwest in Oregon. Soil cuttings were generated from 7 test pits, 8 soil borings, and installation of 5 monitoring wells. Soil samples were analyzed for GRO, DRO, RRO, VOCs, SVOCs, PAHs, pesticides, herbicides, PCBs, and metals. Analytical results reported contaminants at concentrations less than the regulatory limit and waste is considered non-hazardous. TCE was detected at concentrations greater than EPA RSL and ADEC MTGW cleanup level. Soil cuttings are located in 23 55-gallon drums and 35 1-CY supersacks.

Ginna Quesada

3/9/2023

Document, Report, or Work plan Review - other

DEC reviewed Draft Site Inspection Report for DA090. Report summarized field activities that were conducted over multiple field season at the site. Additional soil and groundwater characterization activities are proposed for the site. DEC recommends additional characterization of PFAS to investigate PFAS detected in IDW water.

William Schmaltz

5/11/2023

Site Characterization Report Approved

DEC received and approved Final DA090 Site Characterization Report.

William Schmaltz

Contaminant Information

Name

Level Description

Media

Comments

Control Type

Type

Details

Requirements

Description

Details

1996 Background Data Analysis Report

1994 Federal Facility Agreement

2019 FFA Document Schedule for FFA Attachment

2016 DA090 Geophysical Investigation Technical Memorandum

2015 Preliminary Source Evaluation II Report DA090 RV Lot

2013 DA090 - RV Lot Drum & Debris Removal Technical Memorandum

2012 Preliminary Source Evaluation FTR271 MEB Complex Phase II

No associated sites were found.

Missing Location Data

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Site Report: JBER-Ft. Rich DA090 RV Parking Lot Drum Site

Site Chronology

IC / Closure Details

Documents

Associated Sites

Problems/Comments

Action Information

Contaminant Information

Control Type

Requirements

1996 Background Data Analysis Report

1994 Federal Facility Agreement

2019 FFA Document Schedule for FFA Attachment

2016 DA090 Geophysical Investigation Technical Memorandum

2015 Preliminary Source Evaluation II Report DA090 RV Lot

2013 DA090 - RV Lot Drum & Debris Removal Technical Memorandum

2012 Preliminary Source Evaluation FTR271 MEB Complex Phase II

Missing Location Data

State of Alaska Department of Environmental Conservation