| Action Date |
Action |
Description |
DEC Staff |
| 4/28/2015 |
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.
In addition to the regular system testing described in Section 3.1.2, several accidental activations of the system have occurred around 2005, including at least one instance when all four cannons activated simultaneously, and a number of other instances where one or both cannons in the east or west end activated. The estimated maximum volume for each of these discharges is 1,000 gallons of AFFF concentrate. AFFF was collected in floor drains and was allowed to flow out the door at the south side of the west bay of the hangar (Ellis, 2014, personal communication; Appendix C). The area immediately outside the door is paved, but grassy areas to the southeast and farther southwest may receive runoff. The volume of AFFF that may have escaped from the hangar door is unknown (Ellis, 2014, 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).
Since the draft was not provided to EPA or ADEC prior to the FINAL version 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 was 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.
PFOA was detected at concentrations below the EPA RBSL and ADEC cleanup levels. PFOS was detected at concentrations below EPA RBSL and ADEC human health cleanup level but above the ADEC MTGW cleanup level.
One groundwater sample was collected from 36 to 46 feet bgs in new monitoring well H18-1. PFBS was detected at a concentration below the EPA RSL. PFOA was detected at a concentration above the EPA HA but below the ADEC cleanup level. PFOS was detected at a concentration above the EPA HA and the 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 |
| 8/31/2017 |
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: 80129 name: AFFF Area #24 Hangar 18 Bldg 17470 |
Louis Howard |
| 11/21/2017 |
Update or Other Action |
Per AFCEC email: A memo from the USACE summarizing issues found in their Level IV data review should be in hand on the 4th of December.
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 |
| 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 |
| 3/30/2020 |
Update or Other Action |
JBER sent list of sites that have been validated for future funding to investigate PFAS contamination at both JBER-E and JBER-R. They may be included in an end-of-year centrally-funded investigation. Right now, the scope is for a “PFAS General RI,” with an option of adding any installation-specific requirements later. Additionally, there may be end-of-year Expanded Site Investigations, and some of the other [JBER PFAS] sites that haven’t yet been validated may be included there.
JBER-E
SS135P C17 Debris Yard [AFFF Area #06]
SS136P Current AFFF Test Area [AFFF Area #07]
SS137P Corrosion Control [AFFF Area #08]
SS138P Current Fire Training Facility [AFFF Area #09]
SS139P Former AFFF Test Area [AFFF Area #12]
SS144P Hangar 5 Test Area [AFFF Area #18]
SS145P Hangar 6 [AFFF Area #19]
SS146P Hangar 10 [AFFF Area 21]
SS147P Hangar 16 [AFFF Area #22]
SS148P Hangar 17 [AFFF Area #23]
SS150P Cesna Crash Site [AFFF Area #26]
SS155P Hangar 18 [AFFF Area #24]
SS156P Hangar 8 [AFFF Area #20]
JBER-R
SS044P FTRS-044 [AFFF Area #05]
SS149P Ruff Road [AFFF Area #01] |
Louis Howard |
| 7/2/2021 |
Document, Report, or Work plan Review - other |
Reviewed and provided comments on the Draft Phase I Remedial Investigation Management Plan/UFP-QAPP, dated May 2021. The document provides the Work Plan, Field Sampling Plan, and the Quality Assurance Project Plan for the Phase I Remedial Investigation (RI) for PFAS at JBER. |
William Schmaltz |
