| Action Date |
Action |
Description |
DEC Staff |
| 9/12/1994 |
Update or Other Action |
Site assesment for Bldg. 962 UST tank 105 received. Under Work Release R30213/550 issued by Brown & Root Service Corporation, Oil Spill Consultants collected samples and performed a site assessment during the removal of a 1,000-gallon underground storage tank (UST) at Building 962 at Ft. Richardson, Alaska. The UST (Tank 105) was removed by Nessco Environmental on June 14, 1994. It was taken to a storage area behind Building 955 for cutting and cleaning. Following this, the tank was given to the Defense Reutilization and Marketing organization for disposal.
Five (5) project samples and one (1) quality control sample were collected to determine if the soil over and around the UST was contaminated with petroleum hydrocarbons. Additionally, the tank contents were sampled to assess which contaminants would likely be in the soil if a release
occurred. Samples were taken to Analytical Technologies, Inc., in Anchorage, Alaska for
analysis.
HNU PID 2 ppm Lab result DRO 1,200 mg/kg, HNU PID 2 ppm Lab result DRO 1,300 mg/kg, HNU 1 ppm Lab result DRO 880 mg/kg, HNU 4 ppm Lab result DRO 1,000 mg/kg, HNU 8 ppm Lab Result DRO 3,600 mg/kg. NOTE TO FILE: 2 ppm is TOO HIGH for field screening at DRO UST sites, use 1 ppm or ANY positive deflection as an indication that the site is contaminated.
Laboratory results show that the maximum detected level of diesel range organics (DRO) in the
project soil was 3,600 ppm. These results suggest that petroleum hydrocarbons may have been
released to the environment from Tank 105 at Building 962.
Based on guidelines provided in 18 MC 78.315 and environmental conditions at Ft. Richardson,
Alaska, the soil at Building 962 qualifies for Level C cleanup which sets the maximum DRO
concentration at 1,000 ppm. Since the detected levels for DRO at Building 962 exceeds this level, further action is required for site closure.
As required by the State of Alaska, a remedial site investigation is required to quantify the area affected by the tank release. The report containing this investigation must include
recommendations for site cleanup. Soil excavated during tank removal cannot be used for backfill. |
Louis Howard |
| 9/28/1994 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation-Defense Facilities Oversight group (ADEC)
has received, on September 12, 1994 a copy of the above referenced report. Below are ADEC's
comments.
5.3 Conclusion and Recommendations page 11
The text states levels detected in the soil under the tank indicated tank 105 has leaked and the
maximum detected level of DRO is 3.600 ppm. This level is in excess of level C cleanup criteria.
Further action is still required by the Army to delineate the vertical and horizontal level and extent of petroleum hydrocarbon contamination in soil and groundwater at each site. ADEC looks forward to receiving the draft release investigation work plan with schedules of action for review and comment by January 1995. |
Louis Howard |
| 11/9/1994 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the October 21, 1994 Site Work Plan, Sampling Analysis Plan, QC/QA Plan, and Health and Safety Plan, Circle Rd. Heating Oil Tanks Project# DACA8594DOOO9
The Alaska Department of Environmental Conservation (ADEC) has received, on November 4, 1994, a copy of the above documents. Here are our comments regarding the documents.
Task 3 Implement Release Investigation Plan Soil Borings page 5 last para.
The text states after receipt of lab data one soil boring will be completed as a monitoring
well in the area where the highest concentrations and deepest contaminant impact occur. ADEC requests two monitoring wells be installed instead of one to characterize the potential impacts to groundwater at the 12 different project sites. One well will be placed at each of the two project sites that have the highest concentrations and deepest impacts to soil.
Health and Safety Plan
ADEC does not review health and safety plans, but will keep a copy on fIle in its records. |
Louis Howard |
| 3/22/1996 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Release Investigation for bldgs: 914UST 37, 920UST.95,926 UST96, 932 UST 97, 934 UST 98, 936 UST 99, 944.UST 100,946 UST 101,950 UST102, 962 UST105,
968 UST 34 at Fort Richardson, Alaska, February 21, 1996.
The Department of Environmental Conservation (DEC) has received the above documents on March
6,1996.
Based upon a review of the information submitted no further assessment or remediation of the sites is requested at this time, These closures do not preclude future remediation or site investigation if new information indicates there is previously undiscovered contamination or exposures which cause unacceptable risk to human health or the environment.
Future investigation and/or remedial actions may be required if contamination exceeding these risks are detected or if the contamination is excavated; DEC reserves all of its rights under Title 46 of Alaska Statutes and 18 AAC 78 to request additional activities in the future if necessary to address these risks. DEC requests any monitoring wells installed as a part of these investigations be added to the Postwide monitoring network established under the CERCLA FFA. |
Louis Howard |
| 2/28/1999 |
Update or Other Action |
This decision document describes the rationale forNo Further Remedial Action Planned (NFRAP) at the Circle Loop Road Warehouses, Fort Richardson, Alaska. This action has been chosen in accordance with the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) as amended by the Superfund Amendments and Reauthorization Act (SARA), the National Contingency Plan (NCP), the Resource Conservation and Recovery Act (RCRA) and Army Regulation 200-1, as applicable.
The sites addressed by this document include Bldg 914 underground storage tank (UST) 137, Bldg 926 UST 96, Bldg 932UST 97, Bldg 934 UST 98, Bldg 936 UST 99, Bldg 944 UST 100, Bldg 946 UST 101, Bldg 950 UST 102, Bldg 962 UST 105, and Bldg 968 UST 34. These USTs were removed during the summer 1994 to meet the requirements of the Fort Richardson-State of Alaska, Department of
Environmental Conservation (ADEC) UST Compliance Agreement. During removal, soil contamination was found at each site at levels exceeding the State of Alaska level clean-up standards, 2000 parts per million (ppm) Diesel Range Organics (DRO) and 2000 ppm residual range organics (RRO), specified in 18 Alaska Administrative Code (AAC) 78.
A release investigation was conducted which averaged 4 soil borings per site. The borings were drilled to approximately 50 feet below ground surface (bgs), and found DRO concentrations ranging from 3,010 ppm to 16,000 ppm.
Circle Loop Road warehoused isan industrial complex. Due to limited acess it is not expected to pose a risk to the general public or other pathways. Contamination is not expected to impact groundwater, based up on a soil leaching potential assessment conducted during the release investigation. Therefore, contamination poses no risk to the potential drinking water supply in the area.
Because this remedy will result in hazardous substances remaining on-site above levels that allow for unlimited use and unrestricted exposure, a review will be conducted within five years to ensure that there is adequate protection of human health and the environment. |
Louis Howard |
| 6/6/2012 |
Update or Other Action |
Draft Project Management Plan received for review and comment.
Performance Objective
Site Closure
Potential Risk
The nature and extent of soil contamination in the upper 25 feet is greater than anticipated.
Groundwater impacts are discovered during site characterization.
Risk Mitigation
Excavate soil as needed (estimate 250 yd3) to achieve SC. Monitoring wells will be installed,
and groundwater contamination will be addressed with a technology that is appropriate to the
nature and extent of the plume to achieve SC within the POP.
Date of Achieving Performance Objective
2nd quarter FY2014
Planned Approach
Prepare an approved Characterization Workplan. Coordinate, mobilize, and execute characterization Workplan by installing and sampling two soil borings and collect one hydropunch groundwater sample.
Use HRC to evaluate SC based on risk to future residential receptors for all pathways.
Prepare an approved Site Characterization Report documenting HRC risk evaluation.
Prepare an approved Site Closure Report requesting Cleanup Complete without ICs.
Receive concurrence from ADEC that site has achieved Cleanup Complete without ICs and provide documentation to AFCEE. |
Louis Howard |
| 2/11/2013 |
Site Added to Database |
A new site has been added to the database |
Mitzi Read |
| 4/22/2013 |
Update or Other Action |
Draft UFP-QAPP work plan received for review and comment.
The overall objective for the site is to meet “unrestricted or residential site use” criteria and achieve a “cleanup complete without institutional controls (ICs)” determination. To meet this objective, soil and groundwater samples will be collected to characterize risk to human health and the environment within the framework of the ADEC site cleanup process (Title 18, Chapter 75 of the Alaska Administrative Code [18 AAC 75], Sections 325 to 390 and 18 AAC 78 Section 600) (ADEC, 2012a; ADEC, 2012b).
If ADEC 18 AAC 75 Method Two criteria are exceeded, the Hydrocarbon Risk Calculator (HRC) approach under Method Three will be used to assess whether site conditions meet ADEC risk criteria (in which case, a “cleanup complete without ICs” determination will be requested) or whether the site poses unacceptable risk (in which case, further remediation may be required). If unacceptable risk is indicated by the HRC or if vadose zone soils exceed maximum allowable concentrations, then remedial options will be evaluated that address the contaminants of concern and associated exposure routes that contribute enough risk to cause the cumulative risk estimate to exceed the risk standard.
Two borings will be drilled near the location of former UST 105 to investigate residual contamination in the source area and to collect soil samples for volatile petroleum hydrocarbons (VPH) and extractable petroleum hydrocarbons (EPH) analysis.
Up to approximately 30 primary soil samples will be collected and analyzed for gasoline-range organics (GRO), DRO, residual-range organics (RRO), volatile organic compounds (VOCs) (petroleum-related), and polycyclic aromatic hydrocarbons (PAHs). Three of those soil samples will also be analyzed for EPH and VPH. One of the soil samples will be analyzed for soil bulk density, grain size distribution, specific gravity, and soil moisture content.
All the samples analyzed for VOCs (petroleum-related), GRO, DRO, RRO, PAHs, EPH, VPH, and other soil properties will be from the interpreted extent of the nonaqueous phase liquid (NAPL) contaminated soil source. One of the soil samples will be collected from below the contaminated soil source and analyzed for fraction of organic carbon (foc).
If groundwater is encountered before the interpreted extent of the NAPL-contaminated soil is
reached at these locations, source area groundwater samples will be collected and analyzed
for DRO, GRO, RRO, VOCs (petroleum-related), PAHs, EPH, and VPH.
Four borings will be drilled around the former tank location to delineate the extent of residual
contamination. Up to approximately 20 primary samples will be collected and analyzed for
GRO, DRO, RRO, VOCs (petroleum-related), and PAHs.
If groundwater monitoring well AP-3591 is still serviceable, a groundwater sample will be
collected and analyzed for DRO, GRO, RRO, VOCs (petroleum-related), PAHs, EPH, and
VPH. |
Louis Howard |
| 4/23/2013 |
Update or Other Action |
UFP-QAPP SC Work Plan
The overall objective for the site is to meet “unrestricted or residential site use” criteria and achieve a “cleanup complete without institutional controls (ICs)” determination. To meet this objective, soil and groundwater samples will be collected to characterize risk to human health and the environment within the framework of the ADEC site cleanup process (Title 18, Chapter 75 of the Alaska Administrative Code [18 AAC 75], Sections 325 to 390 and 18 AAC 78 Section 600).
If ADEC 18 AAC 75 Method Two criteria are exceeded, the Hydrocarbon Risk Calculator (HRC) approach under Method Three will be used to assess whether site conditions meet ADEC risk criteria (in which case, a “cleanup complete without ICs” determination will be requested) or whether the site poses unacceptable risk (in which case, further remediation may be required). If unacceptable risk is indicated by the HRC or if vadose zone soils exceed maximum allowable concentrations, then remedial options will be evaluated that address the contaminants of concern and associated exposure routes that contribute enough risk to cause the cumulative risk estimate to exceed the risk standard.
At TU071, up to six new soil borings will be drilled as shown on Figure 2 and discussed below:
Two borings will be drilled near the location of former UST 105 to investigate residual
contamination in the source area and to collect soil samples for volatile petroleum
hydrocarbons (VPH) and extractable petroleum hydrocarbons (EPH) analysis.
Up to approximately 30 primary soil samples will be collected and analyzed for
gasoline-range organics (GRO), DRO, residual-range organics (RRO), the volatile organic
compounds (VOCs) benzene, toluene, ethylbenzene, xylenes, and naphthalene (BTEXN),
and polycyclic aromatic hydrocarbons (PAHs). Three of those soil samples will also be
analyzed for EPH and VPH. One of the soil samples will be analyzed for soil bulk density,
grain size distribution, specific gravity, and soil moisture content. All the samples analyzed
for VOCs (BTEXN), GRO, DRO, RRO, PAHs, EPH, VPH, and other soil properties will be
from the interpreted extent of the nonaqueous phase liquid (NAPL) contaminated soil source
One of the soil samples will be collected from below the contaminated soil source and
analyzed for fraction of organic carbon (foc).
If groundwater is encountered before the interpreted extent of the NAPL-contaminated soil is
reached at these locations, source area groundwater samples will be collected and analyzed
for DRO, GRO, RRO, VOCs (BTEXN), PAHs, EPH, and VPH.
Four borings will be drilled around the former tank location to delineate the extent of residual
contamination. Up to approximately 20 primary samples will be collected and analyzed for
GRO, DRO, RRO, VOCs (BTEXN), and PAHs.
If groundwater monitoring well AP-3591 is still serviceable, a groundwater sample will be
collected and analyzed for DRO, GRO, RRO, VOCs (BTEXN), PAHs, EPH, and VPH. |
Louis Howard |
| 5/6/2013 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 79398 name: Heating Oil Tank 105 |
Louis Howard |
| 5/17/2013 |
Document, Report, or Work plan Review - other |
ADEC reviewed and commented on the draft UFP-QAPP work plan for Bldg. 962.
It is ADEC’s position that ICs would be applied at JBER sites when:
• The groundwater under a site or downgradient of a site is contaminated with POL constituents at concentrations exceeding or MCLs or Table C; or
• POL contaminants in the soil were above the maximum allowable concentrations (MAC ) in Table B2 of 18 AAC 75 are left in place after evaluation or at concentrations exceeding risk criteria.
• ICs also needed if direct contact or inhalation risks exceed residential land use risk-based levels. Sites should be suitable for UU/UL for cleanup complete without ICs.
If soil that was above MAC were excavated, the excavation confirmation sample concentrations could be used to replace the higher concentration in the removed soil and the statistics for the site could be rerun. The ProUCL checks for outliers and the Q-Q plot should be submitted with the 95% UCL calculations.
Vadose zone soils shall not exceed MAC for petroleum contamination for soil from 0 – 15’ bgs (i.e. direct contact for BTEX, PAHs and ingestion for DRO , GRO , RRO ) regardless of HRC calculated risk levels. Treatment or excavations deeper than 15’ bgs may be warranted on a site-specific basis to prevent the soil from acting as a continuing source of groundwater contamination (i.e. exceeding MCLs or Table C cleanup levels).
In addition, sites with existing groundwater contamination above Table C cleanup levels will require that migration to groundwater cleanup levels be used for soil and ICs will be required. Once groundwater is below Table C for a period of time (per the latest approved “Basewide Monitoring Program Well Sampling Frequency Decision Guide (Attachment 1 Memo to the Site File for OUs 4, 5, and 6 September 2003)” two rounds of annual groundwater monitoring), MAC may become the cleanup levels as determined by ADEC on a case by case basis.
Page ES-3
The text states: “If groundwater is encountered before the interpreted extent of the NAPL-contaminated soil is reached at these locations, source area groundwater samples will be collected and analyzed for DRO, GRO, RRO, VOCs (petroleum-related), PAHs, EPH, and VPH.”
The Site Cleanup Rules for Method Three do not allow for changes to Table C groundwater cleanup levels or calculation of risk-based groundwater cleanup levels. ADEC will not recognize the use of HRC for calculation of risk of groundwater contamination at TU071 or any site on JBER-E or JBER-R, except through the use of Method Four [risk assessment as allowed by 18 AAC 75.325(h)]. Therefore, Table C Groundwater Cleanup levels will apply at all JBER sites with no allowance for alternative or “risk-based” groundwater cleanup levels allowed via Method Three (e.g. HRC). Where the HRC guidance and user manual conflict with existing promulgated regulations regarding the regulations will be applicable and supersede or override any guidance, manuals or technical memoranda.
|
Louis Howard |
| 7/23/2013 |
Document, Report, or Work plan Review - other |
ADEC has reviewed the responses to its comments on the UFP-QAPP for Bldg. 962 (TU071) and finds the responses acceptable. Please finalize the document. |
Louis Howard |
| 3/28/2014 |
Update or Other Action |
Draft Site Characterization Report received for review and comment.
A soil sample collected in 2013 just southwest of the former UST 105 at 15 to 20 feet bgs detected DRO at an estimated concentration of 4,890J mg/kg. The DRO-contaminated soil is limited vertically to approximately 32 feet bgs. DRO was reported in the groundwater at a concentration of 28.7 B µg/L (Figure 4-2), which is well below the screening level of 150 µg/L. The DRO result was qualified (B flagged) because of contamination reported within the laboratory blank.
Conclusions
The following conclusions were made regarding TU071:
• Based on previous investigations and the 2013 site characterization field investigation, DRO
was the only contaminant detected in soil at concentrations above project screening levels.
• DRO in soil at concentrations above the screening level (250 mg/kg) covers an area approximately 120 feet long and 40 feet wide centered on the former UST’s location and extending to a depth of up to 32 feet bgs.
• No buildings are present within 30 feet, and all analyte concentrations were below their
respective 18 AAC 75.345 Method Two, Table B1 and Table C cleanup levels. Therefore, the vapor intrusion pathway is considered incomplete for current industrial and potential future residential exposure scenarios.
• The cumulative carcinogenic risk and noncarcinogenic HI estimates for each source area at
TU071 (using the HRC) based on both industrial and hypothetical residential exposure
scenarios were calculated to be below the regulatory risk standards.
• Using the HRC for contaminated soil, the source area at the site meets the ADEC risk criteria for bulk hydrocarbons.
• GRO, DRO, and RRO were not detected above project screening levels in groundwater samples collected from the site in 1995 and 2013.
• No potential risks to ecological receptors were observed, and potentially complete ecological
exposure pathways are considered insignificant.
Recommendations
The following are recommended for TU071:
• No further investigation or cleanup of soil and groundwater.
• “Cleanup Complete without ICs” designation because TU071 meets the criteria established for site closure (ADEC, 2012a).
• Abandonment of monitoring well AP-3591 following ADEC’s Monitoring Well Guidance (ADEC, 2013). |
Louis Howard |
| 4/15/2014 |
Cleanup Complete Determination Issued |
Staff provided a cleanup complete determination for TU071.
Contaminants of Concern
During the 2013 site characterization at this site, the maximum DRO of 4,890 mg/kg was detected at13Q3TU071-SB0104-SO-1 at 15 to 20’ bgs and 4,200 mg/kg at 10 to 15’ bgs. ADEC does not recognize the Table 5-6a and 5-6b 2013 Site Characterization’s modeled concentrations for aromatics and aliphatics as groundwater cleanup levels under Method Three for TU071. Current regulations do not list aromatic and aliphatic cleanup levels for groundwater in Table C. However, since groundwater is not contaminated above Table C levels at this site, it is not an issue at TU071.
Cleanup Levels
In accordance with 18 AAC 75.341(d), Table B2, the cleanup level for DRO at TU071 is based on the ingestion pathway for the under 40” Zone which is 10,250 mg/kg.
In accordance with 18 AAC 75.380(d)(1), after reviewing the site characterization report submitted under this section, ADEC has determined TU071 has been adequately characterized under 18 AAC 75.335 and has achieved the applicable requirements under the site cleanup rules for a “cleanup complete” designation. The designation shall be noted in the CS Database.
This written determination does not preclude ADEC from requiring additional assessment, investigation, monitoring, and cleanup if future information, site conditions, or new data indicates that action is necessary to protect human health, welfare, safety, or of the environment.
In accordance with 18 AAC 75.325(i) and 18 AAC 75.370(b): the Air Force shall obtain ADEC approval before moving or disposing of soil from TU071. Movement or use of contaminated material in a manner that results in a violation of 18 AAC 70 water quality standards is prohibited. Notations of these requirements shall be made on the Environmental Restoration map/Base General Plan which will show up during a dig permit review/work clearance request process for TU071.
Any person who disagrees with this decision may request an adjudicatory hearing in accordance with 18 AAC 15.195 -18 AAC 15.340 or an informal review by the Division Director in accordance with 18 AAC 15.185. Informal review requests must be delivered to the Division Director, 410 Willoughby Avenue, Suite 303, Juneau, Alaska 99801, within 15 days after receiving ADEC’s decision reviewable under this section. Adjudicatory hearing requests must be delivered to the Commissioner of the Department of Environmental Conservation, 410 Willoughby Avenue, Suite 303, Juneau, Alaska 99801, within 30 days after the date of issuance of this letter, or within 30 days after ADEC issues a final decision under 18 AAC 15.185. If a hearing is not requested within 30 days, the right to appeal is waived.
|
Louis Howard |
