| Action Date |
Action |
Description |
DEC Staff |
| 8/24/2012 |
Update or Other Action |
Draft UFP-QAPP for PA/SIs at Sites SA034, SA033, AT035, and AT032 Site Characterization/Cleanup at Sites TA008, TU948, TU110, TU111, TU112, TU949, and SS001 August 2012 received.
Site SA033 – Otter Lake Road Drum Site consists of approximately 20 to 50 drums and assorted metallic debris. The site is located within Joint Base Elmendorf-Richardson (JBER)-Richardson
(JBER-R) (the former Fort Richardson Army Post) in Anchorage, Alaska. The site has not been
previously investigated. The Preliminary Assessment/Site Inspection (PA/SI) activities proposed
in this Uniform Federal Policy Quality Assurance Project Plan (UFP-QAPP) for Site SA033 are
being conducted to determine whether a release has occurred and, if so, whether soil or
groundwater have been impacted.
Site SA033 – Otter Lake Road Drum Site was first discovered in 2002. This remote site consists of approximately 20 to 50 drums piled along with other metal debris in one general area located approximately 100 to 300 feet west of Otter Lake Road. The contents of the drums are unknown.
No previous investigations have been completed at the site, so little is known about the site-specific geology and hydrogeology.
This site is currently uncharacterized. It is not known if a contaminant release has occurred or if soil or groundwater contamination is present. The majority of the visible drums are open or punctured; therefore, surface spills could have occurred in the vicinity of the pile.
Site SA033 is located in a remote wooded area. There are currently no institutional controls in place that restrict the use of soil or groundwater.
No environmental data have been collected at SiteSA033. Data will be collected in this investigation to determine whether a release has occurred and if soil or groundwater has been impacted.
The sampling and analytical approach will occur in two phases. Phase I consists of drum removal, content sampling, and disposal; and Phase II consists of surface soil sampling at approximately 15 locations after drums and metal debris are removed. Soil analyses will follow Alaska Department of Environmental Conservation (ADEC) requirements (ADEC, 2010).
The Phase I sampling and analytical approach includes the following:
- Collect samples of drum contents (as needed) from drums containing enough liquid to sample.
- Samples will be analyzed for toxicity characteristic leaching procedure (TCLP) volatile organic compounds (VOCs), TCLP semivolatile organic compounds (SVOCs), TCLP polychlorinated biphenyls (PCBs), gasoline-range organics (GRO), diesel-range organics (DRO), residual-range organics (RRO), TCLP pesticides, TCLP herbicides, and TCLP metals.
The Phase II sampling and analytical approach includes the following:
- Following drum removal and sampling, approximately 15 surface discrete soil samples will be collected. The actual number of samples will be based on the sample collection frequency per the surface area of the drum pile, as defined in Table 2B of the ADEC Draft Field Sampling Guidance (2010). Since the approximate area of the drum pile is 100 by 50 feet (5,000 square feet), Table 2B indicates that the following samples should be collected: 10 screening samples for the first 250 square feet plus one per additional 100 square feet (approximately 31 screening samples total); and two laboratory samples for the first 250 square feet, plus one
for each additional 250 square feet (approximately 15 laboratory samples total).
- Sample locations will be based on observations of the ground surface beneath the drums. These observations include photoionization detector (PID) readings, soil staining, sheens, unusual discolorations, and odors.
- Soil type, moisture, visual observations of staining, PID readings, and other observations will be recorded for each sample location. |
Louis Howard |
| 8/29/2012 |
Site Added to Database |
A new site has been added to the database |
Mitzi Read |
| 9/21/2012 |
Document, Report, or Work plan Review - other |
Staff reviewed the draft UFP-QAPP for priority sites on JBER-Richardson.
WS #10 CSM
General CSM
The text states “At Sites SA034, TU949, SS001, SA033, TA008, TU948, TU110, TU111, TU112, AT035, & AT032, the primary COPCs are petroleum hydrocarbons.” In the same paragraph, it states: “Sites SA034 & SA033 are drum disposal sites; it is unknown whether a release has occurred & whether soil or GW have been impacted.”
At SA034 & SA033, previous text in the document states in various places that there have not been any previous investigations at SA034 & SA033.
“No previous investigations have occurred at Sites SA034 & SA033, & it is not known whether a release has occurred. Therefore, PA/SIs are being conducted at Sites SA034 & SA033 to determine whether a release has occurred.”
Please correct text & delete SA034 & SA033 from the statement about petroleum hydrocarbons being the primary COPC.
Land Use Considerations
The text states: “ICs include soil use restrictions based on agreements between the military services, EPA, & ADEC.”
The Army’s 2008 SOPs state “Institutional controls are established when contamination remains in soil or GW & a decision is made to restrict land use & access. Institutional controls include dig permits, signage, fences, & monitoring. IC areas are designated on the installation master plan & are regularly updated.”
JBER’s LUCs (May 2011) states: “LUCs were established at JBER to prevent exposure to contaminated soil & water, based on agreements between the military services & the US Environmental Protection Agency (USEPA) & the Alaska Department of Environmental Conservation (ADEC). LUCs are used to reduce the potential for exposure to hazardous substances or to enhance the protectiveness of a soil &/or water cleanup remedy.”
Please state that ICs include both soil & GW use restrictions.
Table 15-1 Comparison of Laboratory DLs & LOQs non-TPH Analytes in Soil
If a COC at any of the sites, please note perchlorate has a direct contact cleanup level of 71 mg/kg & a migration to GW cleanup level of 0.067 mg/kg.
General Comment: For all the tables in section 15:
a. Please correct all headers, as they all reference Direct Contact.
b. The 1/10th screening criteria does not apply to Migration to GW.
c. Please clarify in the text why the EPA RSLs are included. These levels are only referenced if State cleanup levels are not present for specific contaminants. In most cases, the COCs are primarily petroleum or chlorinated solvents. The two sites where no cleanup level exists in 18 AAC 75 & then the EPA RSLs may be appropriate, are the two drum sites: SA034 & SA033.
WS #17 Sampling Design & Rationale
WS #17 & all appendices
General Comment
The sampling design should specify that soil samples will be collected at the highest PID reading & where visual/olfactory evidence indicates contamination. The text seems to indicate that only the two clean intervals below contamination will be sampled regardless of field screening or visual observations. The contractor shall not limit sampling to two planned intervals below the last evidence of contamination, even though the boring logs may document contamination in other intervals within the borings. This will result in an increased number of samples per boring.
The text states: “Soil Excavation. If soil contamination is found to pose unacceptable risk using the HRC model under Method 3, & excavation is the selected remedial approach, the following decision rules will be used to guide the excavation:
– Soil contamination in the upper 15 feet bgs that creates unacceptable direct contact risk (the 95 UCL ~10,250 milligrams per kilogram [mg/kg]) will be excavated.
– Soil contamination creating unacceptable vapor intrusion or migration-to-GW risk down to 25 feet bgs will be excavated, if soil contamination below 25 feet bgs does not create unacceptable risk.”
Delete reference to 95 UCL.
a. Soil – A 95% UCL may be proposed for department review & approval in accordance with 18 AAC 75.380(c). If it is not approved, the maximum concentration will be used for site determination. It does not appear that sufficient data will be collected to calculate a valid 95% UCL.
b. Water – 95% UCL is not acceptable for GW. The maximum GW site concentrations shall be used.
Last bullet
Vapor Intrusion (VI)
ADEC requests JBER elaborate on the term “significant” with regards to HRC & VI. ADEC’s October 2010 CSM guidance (see Appendix D) contains a list of volatile compounds & discusses (see 3.3.2) when a building is close enough to contamination to prompt additional evaluation (30 feet from a petroleum source & 100 feet from a non-petroleum source). |
Louis Howard |
| 1/2/2013 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 79324 name: SA033 Otter Lake Road Drum Site |
Louis Howard |
| 4/1/2013 |
Update or Other Action |
Draft PA/SI received for review & comment.
Four munitions & explosives of concern (MEC) items were unearthed during drum removal & were promptly cleared & removed by JBER Explosives Ordnance Disposal (EOD) personnel.
CH2MHILL Daily Reports
11/02/2012
1322- While excavator removed metal debris, an UXO was found. We retreated and I notified Range Control as well as Rich Horn and Mike Whitney.
1345- Range Control onsite evaluated UXO and called EOD.
1455- EOD onsite.
1535- After going through proper procedures EOD team verified UXO was benign, removed it and gave us the OK to proceed.
11/03/2012
1435- Found UXO 25ft northeast of grid stake #120.
1450- Marked location and called Range Control. Also notified PM.
1515- Range Control onsite, made assessment and notified EOD.
As per Range Control, EOD is understaffed on Saturdays and their ETA cannot be determined.
We decided to shutdown for the day and begun securing the site.
11/05/2012
1545- Found UXO. Notified Range control.
1642- EOD onsite, removed UXO and gave us the OK to go back to work.
Detected GRO concentrations ranged from 0.715 to 21.8 mg/kg; DRO concentrations ranged from 7.25 to 130 mg/kg; & RRO concentrations ranged from 30.5 to 643 mg/kg.
1,2,3-Trichloropropane was detected in only one soil sample at location SA033-SS06, & it exceeded the ADEC Method Two migration-to-groundwater SL (0.00053 mg/kg) with a concentration of 0.00905 mg/kg. The result for 1,2,3-trichloropropane was “J” flagged because the analytical holding time was exceeded.
The 1,2,3-trichloropropane exceedance was significantly less than the ADEC Method Two direct contact cleanup level (1.2 mg/kg) or outdoor inhalation cleanup level (0.17 mg/kg).
No PCBs were detected in the surface soil samples collected from SA033.
MCPA exceeded the EPA Protection of Groundwater RSL (0.0015 mg/kg) at soil sample locations SA033-SS04, SA033-SS12, & SA033-SS14 at a maximum concentration of 7.89 mg/kg.
The site reconnaissance & drum inventory located 63 drums on the surface & one half barrel cut open, standing vertical with liquid & debris inside. During the reconnaissance, it was discovered that the drum site was adjacent to, & partially encroached onto the toe of, the inactive landfill.
The drum inventory included only drums that were visible on the surface; some of the drums were stacked on piles of metal debris, which was a significantly larger quantity when compared to the drums. One of the debris piles was about half covered with soil, & large cottonwood trees were growing on top of the debris pile, indicating that the debris had been deposited & partially covered at approximately the same time that landfill closure activities were performed. Available site information was reviewed, & onsite personnel were interviewed to obtain site-specific background information.
Civil Survey: A civil survey of the location & elevation of SA033 was conducted on November 14, 2012. Survey locations & elevations were recorded for the grid layout, select perimeter drums, surface soil sample locations, & crest & toe of the existing JBER-Richardson (JBER-R) landfill.
Electromagnetic Induction (EMI) Geophysical Survey: After completing drum removal, an EMI geophysical survey was conducted across the site on December 4, 2012. The EMI survey indicated a large volume of metal debris within the toe of the landfill slope & two anomalies adjacent to the toe of slope. The large volume & widespread distribution of metal indicates that drums likely remain at the site
Based on the findings from the drum removal activities, surface soil & bulk drum sampling, civil survey, & geophysical EMI survey, the following recommendations are presented for SA033:
- Complete repair to the inactive Fort Richardson Landfill cover within the SA033 site boundary, by applying cover material where metal debris is currently exposed as shown in Appendix A, Photograph 11.
- Install signs along the landfill boundary west of Otter Lake Road to inform people of the boundary & the LUCs that are in place.
- Revise the landfill boundary to include SA033 & the area where obvious landfill debris is present.
- Update the JBER GIS database with the revised landfill boundary.
- Designate SA033 as “no further remedial action planned” (NFRAP) under the JBER IRP.
- Restore the site to natural conditions after cover material has been placed:
- Fill in the locations where surface soil samples were collected, & remove all lath & pin flags marking sample locations, grid, & drum locations.
- Spread piled vegetation & trees placed at the perimeter of the site across the cleared area, & allow nature to reestablish itself. |
Louis Howard |
| 4/23/2013 |
Document, Report, or Work plan Review - other |
Staff provided review comments on the Draft PA/SI Report for SA034. Main comment was regarding transferring SA033 and include it with the inactive Fort Richardson Landfill for Solid Waste Program Oversight. See site file for additional information. |
Louis Howard |
| 6/25/2015 |
Cleanup Complete Determination Issued |
Site closed out and handled as part of the inactive Fort Richardson Landfill overseen by the Solid Waste Program. |
Louis Howard |
