| Action Date |
Action |
Description |
DEC Staff |
| 4/1/2015 |
CERCLA PA |
Preliminary Assessment received for multiple U.S. Air Force (Air Force or USAF) and Air National Guard (ANG) Fire Training Areas (FTAs) to determine probable environmental release of perfluorinated compounds (PFCs). Specifically, HGL is completing PA activities consistent with the U.S. Environmental Protection Agency (USEPA) Guidance for Preparing Preliminary Assessments under the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA) (USEPA, 1991) to determine potential releases of PFCs at 82 Air Force and ANG installations from FTAs and other known and suspected PFCs or aqueous film-forming foam (AFFF) usage or storage areas.
At Fire Station 7 (Building 14431), the only storage of AFFF is in the fire engine, totaling
approximately 210 gallons of concentrate. After a response that requires the application of AFFF, the worker primarily flushes the nozzle at the scene; however, small-scale AFFF testing may also have been performed at the station, which may have been released to nearby grassy areas. Vehicle cleaning is conducted inside Fire Station 7 (Building 14431), where runoff is captured by drains connected to the sanitary sewer system. Refilling of the fire engine’s AFFF tank occurs from stock supply stored at Building 6210 (Bakker, 2014b, personal communication; Appendix C).
Recommendation is to initiate a site inspection. A SI is defined as an investigation to collect and analyze waste and environmental samples to support an evaluation (USEPA, 1992). |
Louis Howard |
| 4/28/2015 |
CERCLA PA |
Final Preliminary Assessment received. Under authority of CERCLA and the Superfund Amendments and Reauthorization Act of 1986, CH2M HILL conducted a PA visit at Joint Base Elmendorf-Richardson (JBER) during the week of December 15, 2014, with a follow-up visit on January 12 and 13, 2015, to secure additional information.
Based on background research and visits to JBER, a total of four FTAs, seven fire stations, seven hangars, five crash locations, four areas where AFFF spray testing has occurred, and three
additional “miscellaneous” locations have been identified as being active during the timeframe
when AFFF has been used by the USAF for fire suppression.
Recommendation: initiate a site inspection as an investigation to collect and analyze waste and environmental samples to support an evaluation.
Since the draft was not provided to EPA or ADEC prior to the FINAL version of the PA being submitted, it was decided that no comments or approval letter would be granted on the preliminary assessment for PFCs on JBER. |
Louis Howard |
| 4/11/2016 |
Document, Report, or Work plan Review - other |
Staff commented on the draft site inspection work plan for PFCs. The most stringent values should be used for screening criteria. Correction, the 3.04 mg/kg and 2.03 mg/kg are proposed human health values not migration from soil to groundwater. These values are based on cleanup values for dermal contact with soil, ingestion, of soil using a childhood age-adjusted to account for varying levels of soil ingestion depending on age, and exposure to soil through inhalation of both volatiles and particulates. Values for the three pathways are then totaled to produce a single, cumulative risk-based value (i.e. human health value).
The proposed migration to groundwater cleanup values, which are also to be considered “relevant” for this PFC Site Inspection, are even more stringent: PFOS (0.571 mg/kg) and PFOA (0.142 mg/kg). The PFOS and PFOA cleanup values are expected to be promulgated in the winter of 2016.
For determining presence or absence of PFOS and PFOA using solely risk based screening levels is not acceptable to ADEC. If the migration to groundwater cleanup level is adopted by ADEC and it exceeds for PFOS or PFOA, a release is confirmed and it is deemed to be contaminated by ADEC. 18 AAC 75.990 Definitions. (23) “contaminated soil” means soil containing a concentration of a hazardous substance that exceeds the applicable cleanup level determined under the site cleanup rules.
If AFCEC chooses to proceed with risk based values (as it is apparent upon review of Table 10-2 Steps 2, 4, & 5), then ADEC reserves the right to require further investigation/cleanup under 18 AAC 75 for all areas of concern/source areas where AFCEC determined no addition action was necessary at an area of concern/source area, but the PFC levels detected exceed migration to groundwater cleanup levels for PFCs.
See site file for additional information. |
Louis Howard |
| 6/1/2017 |
Update or Other Action |
Draft site inspection (SI) at aqueous film forming foam (AFFF) areas on JBER-E and JBER-R waa received for review and comment. The purpose of the SI was to determine the presence or absence of perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS) in the environment. These compounds are a class of synthetic fluorinated chemicals used in industrial and consumer products, including defense-related applications. This class of compounds is also referred to as per- and polyfluorinated alkyl substances (PFAS).
One soil sample from ground surface to 15 feet bgs was collected. PFBS was not detected in soil at Fire Station 7. PFOA was detected at concentrations below the EPA RBSL and ADEC cleanup levels. PFOS was detected at concentrations below the EPA RBSL and ADEC human health cleanup level but above the ADEC MTGW cleanup level.
One groundwater sample was collected from 30.6 to 40.6 feet bgs in new monitoring well FS7-1.
PFBS was detected at a concentration below the EPA RSL. PFOA and PFOS were detected concentrations above the EPA HA and ADEC cleanup level.
See site file for additional information. |
Louis Howard |
| 6/13/2017 |
Document, Report, or Work plan Review - other |
Staff commented on the draft SI for JBER-E and JBER-R sites which included this site. It appears there are documented releases of PFOS and/or PFOA at these areas which require additional investigation through a remedial investigation/feasibility study under CERCLA or as required by 18 AAC 75.335 Site Characterization.
The 1991 Elmendorf Federal Facility Agreement Part II Definitions. Paragraph 2.1 states: “(y) "Site” shall mean the areal extent of contamination and shall include sources of contamination subject to this Agreement at the Elmendorf (Elmendorf AFB), which occupies approximately thirteen thousand one hundred and thirty (13,130) acres, bordered by the Municipality of Anchorage,- Alaska, to the south. The Site includes ANY OFF-BASE area(s) contaminated by the MIGRATION of hazardous substances, pollutants, or contaminants FROM Elmendorf AFB;”
See site file for additional information. |
Louis Howard |
| 7/17/2017 |
Document, Report, or Work plan Review - other |
EPA received the Draft Site Inspection Report for Aqueous Film Forming Foam Areas, Joint Base Elmendorf-Richardson, Alaska, May 2017 for review the week of June 2, however Appendix B2 (App B2) laboratory data was not included. EPA received App B2 for review the week of June 20. EPA preliminary comments were sent to the Air Force on July 17, 2017.
EPA Office of Research and Development staff, as well as EPA Region 5 Laboratory chemists, reviewed App B2. EPA has asked the Air Force for clarification regarding what level of report and data review was done by the government prior to submittal of the report to EPA and have not received a clear response. EPA’s initial review has identified a number of data quality issues and that the government data review should be completed and submitted to EPA before we are asked to finalize our comments. The comments submitted reflect only those requiring clarification on the narrative or figures and are not inclusive of review of the laboratory data, and therefore cannot substantiate any conclusions drawn on the presence/absence of PFAS at the 26 AOCs.
EPA review of the laboratory data packages has raised a number of concerns with deviations from workplan approved standard operating procedures, laboratory methods, and data validation.
EPA requests the Air Force clarify the level of governmental data review conducted on the JBER Site Inspection laboratory packages, and provide a copy of the Air Force data review to EPA.
Additional EPA comments on the laboratory data are pending receipt of the Air Force data review.
See site file for additional information. |
Louis Howard |
| 8/15/2017 |
Update or Other Action |
AFCEC will have the U.S. Army Corps of Engineers conduct a level IV data review for the JBER PFAS data. Guestimates are it will be at least 4-6 weeks. The review may also include Eielson and Clear AFB since they were on the same contract/ same labs.
Level IV data validation
These data undergo full review and evaluation of a complete Data Validation Package (DVP) according to DQO/QAPP specific criteria, and National Functional Guidelines. This level of review includes all summaries, and raw data associated with the data package, and ensures the highest level of defensibility. |
Louis Howard |
| 8/31/2017 |
Site Added to Database |
A new site has been added to the database |
Mitzi Read |
| 8/31/2017 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 80124 name: AFFF Area #15 Fire Station 7 Bldg 14431 |
Louis Howard |
| 11/21/2017 |
Update or Other Action |
Per AFCEC email: A memo from the USACE summarizing issues found in their review should be in hand on the 4th of December. |
Louis Howard |
| 2/8/2018 |
CERCLA SI |
SI responses to ADEC's comments are satisfactory and may be incorporated into the final report. with the exception of lack of clarity in the response on which program the PFAS contamination will be investigated under at JBER: RI/FS in accordance with CERCLA as new source areas under the Federal Facility Agreements OR as new sites under State Authority (i.e. 18 AAC 75).
ADEC is requesting specific responses as to which path the investigation will occur (RI/FS per the FFA or Site Characterization per 18 AAC 75..335). Please respond. Additionally, ADEC is reviewing the Data Quality Evaluation Report AND the Technical Memorandum for Data Quality Findings Perfluorinated Compound Site Inspection for Joint Base Elmendorf-Richardson |
Louis Howard |
| 1/15/2019 |
CERCLA ROD Periodic Review |
Fifth draft five-year review received which does not directly address sites with AFFF contamination (PFOS/PFOA). Site Interviews: Generally, comments regarding the overall remediation process at JBER-E were positive, with the following comments applicable to JBER-E CERCLA sites as a whole: Reporting of groundwater (GW) monitoring results is often delayed by 1 or 2 years following a sampling event, which could result in missed opportunities to react or change procedures in subsequent monitoring events. Perfluorooctane sulfonate (PFOS)/ perfluorooctanoic acid (PFOA) contamination was recently detected in soil & GW above ADEC cleanup levels & GW contamination above EPA Health Advisory levels. *Note: PFOS/PFOA sampling was conducted at JBER in 2016. These activities are briefly noted in this FYR (Section 6.5.3); however, results were not available at the time of the report, & results will be addressed in the next FYR (March 2024).
In 2014, a Preliminary Assessment (PA) was performed at FT023 and, in 2016, a follow-up site
inspection was conducted into the presence of PFOS/PFOA at JBER locations where aqueous
firefighting foams (AFFFs) were historically used (ADEC, 2018a). Final results from the site
inspection were not available at the time of this FYR and will be addressed in the next FYR (March 2024).
See Site file for additional information. |
Louis Howard |
| 2/14/2019 |
Document, Report, or Work plan Review - other |
Staff provided comments on the Five Year-Review. General Comments: ADEC requests AFCEC to add the following new contaminants as part of the long-term monitoring program (as soon as possible): per- & polyfluorinated alkyl substances (PFAS) which include (but not limited to) perfluorooctanoic acid (PFOA) & perfluorooctane sulfonate (PFOS). ADEC has promulgated cleanup levels (18 AAC 75 Table C groundwater and Table B1 Method Two since November 6, 2016) for PFOS & PFOA that have been detected in various locations during 2016 sampling efforts at JBER-E & JBER-R. These locations include State sites, CERCLA source areas, compliance program sites or previously unknown sites which are either active, closed, cleanup complete, or cleanup complete with institutional controls & areas which have never been investigated before. At CERCLA source areas where PFAS has been detected above promulgated standards, the original remedy selections may not be valid for new contaminants such as PFAS.
As of now, no long-term groundwater, surface water/seep monitoring is occurring for PFAS contamination at the locations where it was detected or downgradient of the PFAS exceedance on JBER. Rather, AFCEC is choosing to characterize investigation-derived wastes (IDW) for PFAS contamination on a site by site basis until 2020. In 2020 [now more likely 2021], it is anticipated that AFCEC will evaluate the nature & extent of the new PFAS contaminant sources on JBER-E & JBER-R as part of the target analyte list of contaminants of concern in accordance with CERCLA or as part of State oversight in accordance with 18 AAC 75 (most current version) & guidance documents adopted by reference.
See site file for additional information.
|
Louis Howard |
| 10/23/2022 |
Document, Report, or Work plan Review - other |
DEC approved the Site Inspection Report For Aqueous Film Forming Foam Areas Final, dated May 2018. PFOS and/or PFOA were detected in soil at concentrations above the ADEC MTGW cleanup levels. PFAS were detected in groundwater at concentrations above the EPA’s human health levels and PFOA and PFAS were above DEC’s Table C cleanup levels. |
Ginna Quesada |
| 10/23/2022 |
Document, Report, or Work plan Review - other |
DEC approved the Site Inspection Report For Aqueous Film Forming Foam Areas Final, dated May 2018. PFOS and/or PFOA were detected in soil at concentrations above the ADEC MTGW cleanup levels. PFAS were detected in groundwater at concentrations above the EPA’s human health levels and PFOA and PFAS were above DEC’s Table C cleanup levels. |
Ginna Quesada |
| 3/17/2025 |
Exposure Tracking Model Ranking |
A new updated ranking with ETM has been completed for source area 80124 AFFF Area #15 Fire Station 7 Bldg 14431. |
Ginna Quesada |
