| Action Date |
Action |
Description |
DEC Staff |
| 8/31/1990 |
Update or Other Action |
In August 1990, the U.S. Army Corp of Engineers (COE) installed seven soil borings and two
monitoring wells (AP-3602 and AP-3606) at the site. The purpose of the COE investigation was
to determine the potential chemical contamination and to characterize the soil engineering
properties for the new building. |
John Halverson |
| 5/15/1991 |
Update or Other Action |
Delwyn F. Thomas Chief, Geotechnical branch submits a Summary of Fieldwork and Chemical Data Report for Classic OWL CENPA-EN-G-M (200-1c). In February 1991, the COE installed an additional soil boring and two additional monitoring wells (AP-3566 and AP-3567) to assist the 1990 COE investigation. Boring AP-3566 showed jet fuel (3,300 ppm & 4,780 ppm) & kerosene 4,600 ppm both at 10' depth. Jet fuel was found from surface staining near tank (jet fuel 62,800 & 47,900 ppm). |
John Halverson |
| 9/27/1991 |
Update or Other Action |
In September 1991, the COE installed one soil boring, one monitoring well, and one test pit at
the site to investigate a dry well and the extent of contamination downgradient from the dry well, as well as sampling two surface stains noted at the site. High concentrations (up to 1,300
mg/kg) of lead were detected at all sampling locations from the excavation. Volatile compounds
such as chlorobenzene (5,100 ug/kg) and m- and o-Dichlorobenzene were detected at
concentrations of 12,000 and 36,000 ug/kg from the stained soil collected from the surface near
the tank. The dry well at the original building site received drainage from a floor drain in the oil changing pit. |
Louis Howard |
| 10/31/1991 |
Update or Other Action |
CH2MHILL project ANC31026.D6.10 vol. 2 of 2 contract DE-AC06-76RLO 1830 site summary for Environmental Mgt. Operations received by DEC. Recommendations were that a comprehensive sampling plan be made to define the vertical/horizontal extent of contamination. Information obtained will be used to determine risk to human health and the environment & cleanup requirements. |
Louis Howard |
| 12/5/1991 |
Update or Other Action |
Dept. of Army, U.S. Army Engineer District, Alaska sent in supplemental material report for site. Dry well exceeded cleanup level for total petroleum hydrocarbons in soils with 1100 mg/kg & 2000 mg/kg & in water sample 1.2 mg/L |
Louis Howard |
| 7/30/1992 |
Update or Other Action |
Jennifer Roberts sent a letter requesting lab data for Classic Owl site to James Dentry PO Box 898 (US Army Corps of Engineers). It is ADEC's understanding that a sampling program was performed in the vicinity of the heating oil tank at the Classic Owl site. The intent of the program was to characterize and define the extent of lead contamination of soil in the area. ADEC requests the data from the lab analyses pertaining to the area of lead contamination at the Classic Owl site be submitted to the department for review. ADEC requests the data be sent within seven days of receipt of this letter. |
Jennifer Roberts |
| 8/28/1992 |
Enforcement Agreement or Order |
Compliance Advisory sent on the cleanup actions being done during construction of the Classic Owl Operations Building. ADEC has not received the following revised site specific documents which have been requested on a number of previous occasions: comprehensive work plan, quality assurance project plan (QAPP), and disposal/stockpile plan for contaminated soils.
Six different contacts/letters were sent on this matter from 5/8/92 to 7/31/92 regarding a revised site specific work plan, site specific QAPP, and site specific soil disposal/stockpiling plan for actions at the Classic Owl site.
Pursuant to AS 46.04.020(b) Removal of Oil Discharges and 18 AAC 75.327, 18 AAC 75.337 the Corps Of Engineers (COE) site specific work documents are not satisfactory. ADEC demanded that the COE submit a site specific work plan, site specific QAPP, and a site specific soil disposal/stockpile plan to ADEC seven (7) days of receipt of this letter (8/28/92 letter to Colonel John W. Pierce, P.O. Box 898, Anchorage AK 99506-0898). |
Ron Klein |
| 9/15/1992 |
Document, Report, or Work plan Review - other |
Letter to U.S. ACOE Richardson Resident Office Tom Johnson regarding documents submitted to ADEC for review: First field notes of excavation and sampling by Wolverine Supply Inc. dated 8/10/1992 to 9/2/1992. Documentation of maps, sampling points and locations was deemed inadequate and any sample point location would be difficult to replicate. Generic QAPP and SAP submitted contained numerous deficiencies and was rejected by ADEC. |
Vic Vickaryous |
| 9/16/1992 |
Update or Other Action |
USAF letter to Jennifer Roberts regarding "Revisions to Elmendorf Air Force Base (AFB) Federal Facility Agreement (FFA) Scope of Work for Operable Units (OU) 4 and 7." As a result of the 1992 field investigation, the USAF requests to move SS63 from OU4 to OU7. Currently at Classic Owl a building is under construction by the Corps of Engineers. If SS63 remains in OU4, then there could be major conflicts with several contractors working in the area. Also by moving SS63 into OU7, the AF would be able to address all of the sources located north of the Elmendorf Moraine in one remedial investigation.
Delete the requirement of an interim remedial action (IRA) at OU4. Based on the LFI, the remedial project managers identified the dry wells at SD24, SD28, and SD31 as potential IRAs. However, further review of the results of the LFI, indicate only the sludge at the bottom of the dry well at these sources were sampled and no soil samples were obtained. At this time there is no evidence of soil contamination in the immediate vicinity of the dry wells. Without additional investigation of these wells, it does not appear an IRA is warranted. Instead of an IRA, we will pursue funding to remove the sludge in each dry well. ADEC project manager Jennifer Roberts signed document to show its concurrence. |
Jennifer Roberts |
| 9/20/1992 |
Update or Other Action |
EAFB sent in a limited field investigation (LFI) technical bulletin regarding the Classic Owl Building site area sampling results. Preliminary soil sampling conducted in August 1992 by the Corps of Engineers at the site of the proposed Classic Owl Operations Building located adjacent to the former Building 52-140 now on Fairchild Avenue. An LFI (7/20/92) for OU4 was conducted and did not detect any contamination since the building site was not previously sampled.
4,600 mg/kg diesel range organic (DRO) contamination was detected during sampling near the exposed end of a clay outfall pipe at the southwest corner of the building location (sample SGSS63RG4). The sample's chromatograph matched a typical weathered diesel fuel pattern. A total of six subsurface soil samples were taken from the trench area and two samples from the floor of the excavation. The dry well and clay pipe were addressed under OU7 Limited Field Investigation (LFI) conducted for site SS63 also at this location. |
Jennifer Roberts |
| 10/2/1992 |
Enforcement Agreement or Order |
State Elmendorf Environmental Restoration Agreement signed. The agreement is designed to remedy environmental contamination due to past practices at the Base and avoid the expense of formal enforcement proceedings.
The Air Force will perform any necessary assessment, monitoring, remediation, and closure of the sites. The agreement addresses the following program areas: solid waste, underground storage tanks (USTs), and petroleum oil and lubricants (POL) spills. |
Jennifer Roberts |
| 10/6/1992 |
Document, Report, or Work plan Review - other |
Jennifer Roberts sent the USAF a comment letter on the draft OU4 Limited Field Investigation (LFI) report dated September 1992. Groundwater flow direction section 1.4.3.2 adequately addresses the groundwater flow south of the moraine, but neglects groundwater flow in the area of Source Area SS63 (Classic Owl Construction site). SS63 is north of the Elmendorf terminal moraine and will exhibit groundwater characteristics and flow patterns. The Corps of Engineers has some preliminary groundwater information that could be utilized in this report. Recommend expanding exposure pathways section 2.5.2 to include groundwater and exposure pathways specific to SS63. During the Classic Owl construction phase, a clay pipe containing high levels of lead contamination was discovered. CH2MHILL took additional samples under a field memorandum to determine if the lead contamination had impacted SS63 and should be included in OU4. |
Jennifer Roberts |
| 11/1/1992 |
Document, Report, or Work plan Review - other |
Vic Vickaryous sent comments on the Quest QAPP/SAP DACA 85-92-C-0011 dated October 6, 1992 QE Project Number 3991 Revision II in a letter dated November 2, 1992. Staff requested all audit information be reported to the Corps project manager on a daily basis; clarify stockpile volume from 600 cubic yards to 800-1600 cubic yards; refer to actual pages in calibration manual for the PID used at the site; insert decon procedures to be used and filled out sample label, exact date after which stockpiling will be addressed in the plan; and state whether or not the sample containers or quality controlled sample containers will be new or used. Interim approval of the Quest QAPP/SAP and Revision II granted on October 6, 1992. |
Vic Vickaryous |
| 11/2/1992 |
Document, Report, or Work plan Review - other |
Clarence (Vick) Vickaryous provided comments on the Approval of Sampling, Analysis, and QA/QC plan for Classic Owl potential RCRA soil stockpiles Cell #2 and 4 stockpiles on Building 52-140 slab. Staff commented that if the excavation exceeds 4 feet in depth at Cell #2, then it becomes a confined space which requires that precautions be taken to protect the sampler in a confined space. Staff requested clarification on how the sample chain of custody and 4 degrees C cooler temperature will be maintained until shipped to the analyzing laboratory. |
Vic Vickaryous |
| 3/3/1993 |
Update or Other Action |
DOD & ADEC joint Technical Memorandum of understanding signed concerning the Basewide Groundwater (gw) signed by: ADEC Jennifer Roberts remedial project manager(RPM) & USAF Joseph Williamson Chief Environmental Programs & Restoration. Due to the basewide gw study & the FY92 field work that occurred at Operable Units (OUs) 1, 2, & 5 it appears a large portion of the gw flows into OU5 (attach. 1-contour map).
Based on this fact, Elmendorf (EAFB) will move all upgradient gw into the OU5 Feasibility Study, Proposed Plan & Record of Decision (ROD). This means addressing all gw from upgradient sources (CERCLA (ST20, Ous 3&4) & OUs 1 & portions of OU2) & SERA) at OU5 instead of at each individual source area (see attach. 2-Area Map). Sites with free phased product would be looked at to see if there is an available technology to clean them up in a cost effective way. Soil contamination would be addressed at the source areas. NOTE: addressed at the source areas is interpreted by ADEC as removal through excavation and disposal or active treatment systems (e.g. high vacuum extraction, bioventing, etc...).
Also included in the letter is the AF memo: Restricted Use of the Shallow Aquifer on EAFB signed by William R. Hanson P.E. GM-14 Chief Environmental Flight dated October 17, 1996 Memorandum for 3 SPTG/CEC/CEO from 3 SPTG/CEV
1) Due to the contamination & commitments to EPA/DEC the use of the shallow aquifer for any purpose on is not allowed. Attached Facilities Board minutes-03/29/1994 0930 Item 9 has Mr. William Hanson, briefing the Board on the policy to not use the shallow aquifer due to contamination. The Board approved this policy. Minutes approved by Thomas R. Case Brigadier General USAF Commander. The IRP has Record of Decisions (RODs) for OUs 3 & 6 which require, the aquifer remain unused.
2) Personnel in the review process within CES must be aware of these policies & review them on a recurring basis. It is imperative this restriction be recognized & observed during engineer reviews & operations. |
Jennifer Roberts |
| 6/1/1993 |
Cleanup Plan Approved |
Plan approved for bioventing system installation to deal with petroleum contaminants in soil. 1993 field season saw the installation of a bioventing well and two soil multi-depth implants were installed in the vicinity of former UST area. |
John Halverson |
| 6/7/1993 |
Update or Other Action |
Work plan for biopile treatability study to demonstrate the feasibility of biopile technology to remediate petroleum hydrocarbon contaminated soils. The technology will require a relatively small area (approximately 11,250 square feet) and will reduce overall risk associated with the contaminated soils. Using natural bacteria, the biopile will enhance natural biodegradation processes to lower total petroleum hydrocarbon concentrations to levels either below State of Alaska cleanup or risk-based levels. The system will be operated for four months and operational parameters will be varied to optimize bacterial activity while measuring operational parameters. At the end of four months, the results will be evaluated. If this technology is proven successful through this treatability study, Elmendorf may construct other biopiles in the area to treat stockpiled petroleum contaminated soils. As an added benefit of the biopile system design, the equipment will be mobile (in a metal shipping box). The system can be relocated to remediate soils either in-situ (bioventing) or ex-situ (biopile). |
Jennifer Roberts |
| 6/14/1993 |
Document, Report, or Work plan Review - other |
Jennifer Roberts provided comments on the bioventing pilot test work plan(work plan, QAPP, and sampling analysis plan) for ST43/55, ST61 and ST71. Staff requested the work plan be amended to state that Pace Laboratory is approved in Alaska. ADEC does not have an approved QAPP on file for Engineering Science Inc. ADEC requests a file copy of the ES Alaska QAPP. Closure samples collected for certification of remediation shall be collected by a "qualified" person (as defined in 18 AAC 78.995) in accordance with an approved QAPP on file with the department. Please state in the QAPP the qualified person who will be doing the sampling on the EAFB ES bioventing sites. Staff requested amendment of the ES Draft QAPP to include the 8100M and 8015M USEPA SW846 methods.
Staff requested amendment of the draft QAPP to reflect standard QAPP requirement to have a minimum of one (1) field duplicate sample per set of 10 samples taken. Finally, staff requested submittal of the project management plan which describes the site reconnaissance and preparation procedures. |
Jennifer Roberts |
| 9/7/1993 |
Update or Other Action |
September 7, 1993 memo from Rich Howard, Elmendorf AFB, Alaska regarding conversation with Alaska District COE, Concerning Classic OWL (SS63) soils at operable unit (OU)-1 storage area.
1. On this date, I spoke with Tom Reed of the Alaska District
COE Ft. Richardson residence office regarding contamination types and levels at the OU1 soil storage facility.
2. Mr. Reed told me that he had completed tests on materials
from the Classic Owl project that are located in three of the cells
at the location. Cell number 1 is located directly west of
Jacobs' small internal fenced enclosure. This pile showed no
evidence of BTEX or Gasoline Range Organics (GRO). However, it
did show Diesel Range Organics (DRO) at a level of 5,500 PPM and Total Recoverable Petroleum Hydro-carbons (TRPH) at 11,600 PPM.
3. Cell number 2, the southerly of the 2 large cells, tested
negative for BETX and GRO. The material did show DRO at a level
of 120 PPM and TRPH at a level of 320 PPM.
4. MR. Reed stated that the portion of cell number 3 that he
tested was located in a backwards "L" shape along the East and
South sides of the cell. Mr. Reed said that his portion of cell
number 3 also tested negative for BETX and GRO. The material
showed DRO at 3,000 PPM and TRPH at 950 PPM. The other material (located along the West side of the cell) was sampled by Quest Environmental.
5. This information will be provided to Jacobs Eng for their use
in placing the material in the base biopile. |
Jennifer Roberts |
| 12/31/1993 |
Update or Other Action |
Cold Weather Biopile Treatability Study conducted. Objectives: Evaluate efficiency in cold weather regions, evaluate increased efficiency by fertilizer addition, evaluate temperature as a function of biotreatment efficiency, optimize air injection/extraction system to stabilize temperatures greater than 50 degrees Fahrenheit, determine what levels of cleanup can be achieved as a function of time, decision on optimal design and operational specifications for future biopiles. Remedial design was based on Montreal Canada biopiles, designed for 2,000 yards which is the largest cold weather biopile known, and designed for air injection/extraction and nutrient addition.
Lessons learned: Alaska construction market is seasonal and limited availability of equipment, dimensions of pile at 2,000 yards was difficult with conventional loading equipment which required specialized equipment. Future recommendations: reduce size of pile to less than 2,000 yards and change dimensions to allow for easy loading and unloading. |
Jennifer Roberts |
| 2/15/1994 |
Update or Other Action |
USAF IRP SERA Phases 1A and 1B Site Assessment Report (Final) received for 15 SERA Phase 1A and 1B sites: SERA 1A-ST43/55 Hydrant Refueling Area (formerly designated Pumphouse III), SS35 Oil-Stained Soil, Paxson Park, SS61 Navy Construction Site, ST69 76-520 Diesel Leak, SS34 Army Air Force Exchange Services (AAFES) Self-Serve Line Leak, SS62 AAFES Service Station, ST71 Leaking Tank, 31-338, LF01 Landfill, West Overrun
SERA 1B-ST36 Diesel Leak, Vicinity of 62-250, ST47 JP-4 Fuel Leak, Vicinity of 10-875, SS57 Oil-Stained Soil, Vicinity of 32-060, LF02 Landfill/Disposal Site, Vicinity of Boniface Gate, ST64 JP-4 Leak, Vicinity of 42-425, ST65 Diesel Leak, Vicinity of 24-857, ST72 Leaking Tanks, Vicinity of 42-500
SS61: 3 soil borings completed and 2 monitoring wells installed. Soil and groundwater samples were analyzed for DRO and BTEX. The Navy Construction site, SS61*, was built in 1943 as a vehicle maintenance facility. Wastes from the site may have included waste oil, solvents, paints, and fuels. No records for past waste streams were found. The area is included as a part of OU4 under CERCLA. In 1992, the original building was demolished and the naval facility was constructed.
The groundwater sample analyzed from well AP-3566 indicated a benzene concentration of 9.5 ug/l and low levels of total BTEX and DRO compounds. Groundwater monitoring should continue to assess whether off-site migration of contaminants is occurring.
Currently, a pilot bioventing study is being conducted at the site by USAF. The application of
this technology should remediate the contaminated soils to concentrations less than the ADEC
cleanup levels. If cleanup levels are not met using this technique, other approaches should be
considered.
A successful bioventing application may preclude the need to remediate groundwater; however,
remediation alternatives should be assessed if soil contamination is not remediated. If off-site
migration of impacted groundwater is not occurring and the source of contamination is eliminated, natural attenuation could be considered a feasible alternative.
Other potential sources of contamination at this location have been investigated under the LFI
for OU7 and are reported separately. |
John Halverson |
| 3/16/1994 |
Document, Report, or Work plan Review - other |
John Halverson ADEC sent letter to Dept. of Air Force, James Spell, Jr. 3 SPTG/CEVR RE: SERA Phase 1A and 1B; Site Assessment Report Final February 15, 1994. Overall the report is
acceptable as meeting the requirements for site assessments under the SERA. However, there are a few issues and recommendations in the report on which the department does not
concur. Below is a summary of the status of each of the sites. Areas of concern with the report are addressed along with requests for additional work where it was determined
necessary.
Sites Recommended for No Further Action- The final report recommended no further action on several of the sites. The following sites appear be suitable for such a decision: SS35; SS34; and, LF01. If the Air Force would like to pursue closure of these sites, the department requests submittal of a separate letter for each site requesting closure (similar to the August 31, 1992 closure letters used for other SERA sites). This would help clearly document no further action decisions.
Sites Recommended for No Further Action- However, Additional Work Requested. The report recommended closure of additional sites, however, based on the information provided to date, the department can not concur with the recommendations. Sites included in this category are listed below along with a brief discussion of additional work that is necessary and a request for work plans.
Sites with Recommendations for Additional Work-Based on the results of Phase I site assessment work the report recommends additional work at several sites. Each of these sites is listed below with a request for submittal of work plans.
SS61-The report recommends continued bioventing and additional groundwater monitoring at the site. The department concurs with these recommendations and requests submittal of a plan
for the additional groundwater monitoring. In the event the bioventing pilot project does not result in the site meeting acceptable cleanup levels, additional corrective action will be
requested. |
John Halverson |
| 6/27/1994 |
Update or Other Action |
Biopile Treatability Study Data Evaluation Report June 1994. The biopile was constructed during August and September 1994. The biopile measures approximately 75 feet wide by 150 feet long and 6 feet high. Total volume was 2,235 cubic yards. The dimensions of the biopile made it difficult to load with conventional equipment such as loaders and cranes. It is recommended that future biopiles be made smaller to be easily loaded with equipment which has adequate reach. The core temperature ranged from 35 to 40 degrees Fahrenheit for the five months (Oct 93 to Feb 94) it was operated. The mean concentration went from 176 mg/kg DRO to 239 mg/kg DRO. BTEX compounds were not detected in baseline sampling nor at final sampling. GRO went from 2.4 mg/kg to 30.7 mg/kg from final sampling. It is recommended that the biopile treatment be started in the spring and operated over the summer with mechanical addition of oxygen and water (possibly nutrients). It is also recommended that soil with hydrocarbon levels above 5,000 mg/kg be used in future biopiles to provide an adequate food source to sustain biotreatment. Operational remedial costs using this technology would be $118 per cubic yard. Because the majority of these costs are for construction, loading, and unloading of the soil, and are not dependent on the treatment duration, the estimate of $118 per cubic yard will decrease as the biopile is reused over time. |
Jennifer Roberts |
| 9/27/1994 |
Institutional Control Record Established |
No current receptors exist for the groundwater at the Base due to the institutional controls (ICs). As a requirement of previously signed RODs for Operable Units (OUs) at the Base, ICs have been established to restrict the use of the shallow aquifer in the outwash plain on Base for both SERA and CERCLA sites. These restrictions are enforced through the Base Comprehensive Plan (BCP).
Projects and other activities are reviewed during the planning stage to ensure compliance with the BCP. In addition, construction projects and other activities also undergo an environmental review. This review helps ensures compliance with groundwater use restrictions. |
Louis Howard |
| 9/27/1994 |
Long Term Monitoring Established |
Source area SS63 (Navy Facility "Classic Owl") is included in OU7 for purposes of remedial investigation at Elmendorf AFB under CERCLA. The source area is located at the site of former Building 52-140 in the northwest part of Elmendorf AFB, approximately 1.3 miles north of and about midway along the east/west runway just off of Loop Road. Building 52-140 was historically used for a vehicle maintenance shop and was demolished in 1992. The building's floor drains apparently discharged to a dry well located east of the facility and may have received waste from an oil change pit and car wash.
Several investigations have been conducted for different portions of the Classic Owl facility. As part of the preconstruction activities for the new Classic Owl operations building, the U.S. Army Corps of Engineers (USACE) has conducted two investigations (August 1990 and September 1991) to assess the nature and extent of subsurface contamination at the facility. During these investigations, several soil borings were drilled, five of which were converted to monitoring wells. Surface soil samples were also collected and a dry well was uncovered and sampled during the investigation.
As part of the USAF IRP, two LFIs were conducted at source area SS63 as components of both the OU4 and OU7 investigations. The OU4 LFI was conducted in 1992 and focused on locating and evaluating building drain outfalls. Field activities included subsurface soil sampling using hand augers at the dry well location and a ground-penetrating radar (GPR) survey.
The OU7 LFI was conducted in 1993 and focused on locating the outfall of a clay pipe discovered by the USACE in 1992 during construction activities. The LFI was also to assess the magnitude of soil contamination (if any) associated with the outfall. Field activities included a GPR survey, groundwater sampling, and subsurface sampling using hand augers.
As a result of these investigations, the recommended action for the soils in the vicinity of both the dry well and clay pipe at source area SS63 was NFA. NFA was also recommended for the groundwater at SS63. The NFA recommendations for the dry well area was based on OU4 LFI soil analytical results showing no constituents above both risk-based concentrations (RBCs) and Applicable or Relevant and Appropriate Requirements (ARARs) and metals background concentrations. The NFA recommendations for the clay pipe area and groundwater was based on a comparison of OU7 LFI analytical results to RBCs and Applicable or Relevant and Appropriate
Requirements (ARARs), and a qualitative risk assessment and an ecological risk assessment.
Long term monitoring established with the ADEC signature on the SS63 OU7 Building 52-140 Determination of No Further Action document. Groundwater contaminants to be monitored under SERA I Program for source ST61 Classic Owl. |
Jennifer Roberts |
| 9/27/1994 |
Update or Other Action |
The OU7 LFI was conducted in 1993 and focused on locating the outfall of a clay pipe discovered by the USACE in 1992 during construction activities. The LFI was also to assess the magnitude of soil contamination (if any) associated with the outfall. Field
activities included a GPR survey, groundwater sampling, and subsurface sampling using hand augers.
As a result of these investigations, the recommended action for the soils in the vicinity of both the dry well and clay pipe at source area SS63 was NFA. NFA was also recommended for the groundwater at SS63. The NFA recommendations for the dry
well area was based on OU4 LFI soil analytical results showing no constituents above both risk-based concentrations (RBCs) and Applicable or Relevant and Appropriate Requirements (ARARs) and metals background concentrations.
The NFA recommendations for the clay pipe area and groundwater was based on a comparison of OU7 LFI analytical results to RBCs and Applicable or Relevant and Appropriate
Requirements (ARARs), and a qualitative risk assessment and an ecological risk assessment. The NFA document for SS63 was signed on 27 September 1994. Source area SS63 was considered closed with the signing of the NFA document. |
Jennifer Roberts |
| 4/21/1995 |
Update or Other Action |
Air Force AF memo: 18 April 1995 Underground Storage Tank (UST) Meeting. Elmendorf AFB will accomplish the following actions regarding UST Projects. These actions are based upon conversation between, John Mahaffey, Larry Opperman and yourself. EAFB will make every effort to accomplish a clean closure of a UST removal site if possible. UST removal locations requiring cleanup action will be transferred into the State-Elmendorf Environmental Restoration Agreement (SERA).
A list of sites requiring cleanup will be coordinated with your office. The presumptive remedy for contaminated UST sites in the outwash plain only will be bioventing technology. Contaminated soils exceeding cleanup levels may be placed back into the excavation only if the site assessment (SA) indicates a need for further cleanup action. Contaminated UST sites not in the outwash plain will require further investigation to determine appropriate cleanup options. We will make every attempt possible to assure new USTs or new aboveground tanks are not installed in any way that would hamper future access for cleanup. The project will first accomplish removal of all of the USTs. SA information will be used to prioritize sites for cleanup using existing project funds.
Additional funding will be requested to complete cleanup if available. Sites not addressed for cleanup due to exhausted funding will be placed into SERA Phase IV. John Halverson signed on April 21, 1995. Memo was signed by Douglas G. Tarbett, Maj, USAF, Chief, Environmental Compliance. CC: 3 WG/JA and 3 SPTG/CE. |
John Halverson |
| 5/3/1995 |
Document, Report, or Work plan Review - other |
ADEC J. Halverson sent comment letter to USAF J. Williamson & C. Mayer 3 SUG/CEVR RE: Review Comments SERA Phase I Corrective Action Plan April 1995. General Comments-As noted in comments on the draft workplan, the corrective action plan needs to include schedules for conducting field work, monitoring and maintaining equipment, and submittal of interim and/or final corrective action reports. We have previously requested quarterly
reporting of remedial efforts at each site where free product has been identified (ST 43 and ST36).
The Air Force has proposed changes to the several of the tables that outline groundwater monitoring plans. Unless specifically noted below, the department does not object to these changes. The locations of substituted wells need to be shown on figures in the plan, if not already present.
ST61- Navy Construction Site (Classic Owl)-Section 2.2.6 - As noted in our comments on the preliminary draft, the corrective action plan should include evaluation of the current bioventing system, proposed modifications to the system, a schedule for implementing any necessary modifications, plans for
monitoring future performance of the bioventing, and a schedule for submittal of monitoring data. This comment has not been adequately addressed. The plan needs to define who will operate, maintain, and monitor the bioventing system and whether modification of the system is recommended to optimize treatment. My notes from our meeting on March 7 indicate bioventing was to be optimized through adjusting the air flow through the current
system.
Table 2.2-1 - The latest groundwater sample collected from monitoring well AP-3606 showed impacts in excess of the drinking water standards (MCLs) and slightly above the previous sampling results. Therefore, the department requests the well be included in
future groundwater monitoring at least until it is demonstrated the contaminant concentrations are decreasing. |
John Halverson |
| 12/31/1996 |
Document, Report, or Work plan Review - other |
Staff provided comments on the technical memorandum "SOP for Closing Bioventing Systems on the Glacial Outwash Plain at EAFB" dated November 14, 1996. Project managers from ADEC, the EPA, and EAFB agreed that attempting to develop a correlation between monitoring data and closure sampling would be beneficial. If a good correlation is shown to exist, then developing a closure procedure based on monitoring data should be possible. Since there has been extensive site investigation and monitoring work done on EAFB, this appears to be a reasonable alternative. It would reduce sampling costs associated with having to do subsurface soil confirmation sampling at every bioventing site in the outwash plain.
To decide whether this will be a feasible alternative, it will be necessary to identify the number of sites with various types of petroleum contamination; conduct bioventing system monitoring and respiration testing along with confirmation soil sampling at a representative number of the sites; and show a good correlation between the monitoring data and the soil sample results. To do this, ADEC requests a list be prepared showing the number of bioventing sites currently operating or proposed. The site list should be broken down into categories for gasoline range organics (GRO), diesel range organics (DRO), and residual range organics (RRO). ADEC requests 25% of the sites under each category, with a minimum of 10 from each be included in the confirmation soil sampling sites to decide if a good correlation can be developed. If less than 10 sites exist under any category (i.e. RRO) confirmation sampling should be done at each site in that category rather than pursuing an alternative closure process for them.
At Page 3, under "problem definition", it refers to relatively small volumes of contaminated soil commonly treated at the Base through bioventing. It states that once the obviously contaminated soil around an underground storage tank has been removed, the remaining contaminated soil is often in a relatively shallow and even layer. The basis for these statements is not clear. In many cases, when USTs were removed, contaminated soil was placed back into the ground. Since most outwash plain consists of coarse grained soil with a low organic carbon content, most of the releases have resulted in contaminate migration down to the groundwater.
Table #3 Footnote #1 refers to respiration testing between June 15 and September 30. It is likely that some frost may remain in the ground during June. Also, if sufficient biological activity is generated, the soil temperatures would remain elevated later into the year. Therefore, ADEC recommends respiration testing be conducted later in the year (i.e. between July 15 and November 15).
Figure 2 does not include fields for helium injection and monitoring during respiration tests. These should be included to evaluate whether short circuiting may be occurring. Average air flow rates at each venting well should also be reported. This may help indicate whether soil moisture may be a limiting factor due to drying of the soil during bioventing. The depth and screen length of soil implants should be provided on the form to simplify the review process. |
John Halverson |
| 2/11/1997 |
Site Added to Database |
Site added by Shannon and Wilson, Inc. |
S&W-Miner |
| 3/16/1998 |
Document, Report, or Work plan Review - other |
Letter to Air Force (C. Mayer) RE: SERA Phase II Bioventing Remediation Monitoring Annual Report EAFB Feb. 1998. ST61. Recommendations state that bioventing should continue and the groundwater at ST61 be fully characterized. ADEC concurs. |
Louis Howard |
| 7/20/1998 |
Document, Report, or Work plan Review - other |
Letter to Air Force from ADEC RE: Draft work plan SERA phase II (ST36/66, ST74, ST61) Investigation EAFB July 1998. ST61: The text refers to a dry welll that received waste oil and a heating oil UST. It goes on to state that no petroleum constituents were identified in a monitoring well as part of SERA Phase 1A/1B 1994 site assessment. However, since the source area includes a waste oil source, the suite of analytical methods must be expanded to include volatile organic compounds (VOCs). Referring back to the 1994 assessment shows that a later round of groundwater samples were collected and analyzed for VOCs. However, no data was presented in the 1994 document regarding the presence of VOCs.
Appendix A Field Sampling Plan Reference and Appendix B QAPP: Both of these tables list PAHs and metals to be analyzed for in groundwater, but does not list them in the text for each site. Please correct the text to include reference tot he specific methods listed in the tables for each site. Additionally, ADEC requests VOCs be analyzed for at ST61, because the original analyses during the early assessment only included petroleum contaminants and the original source (dry well) receiving waste oil. 18 AAC 78 requires that if a contaminant source is "waste oil" or not identified as a refined petroleum product, then it must be analyzed for the full suite of analytical methods (18 AAC 78.315). |
Louis Howard |
| 8/12/1998 |
Document, Report, or Work plan Review - other |
ADEC letter to C. Mayer Dept. of Air Force 3 CES/CEVR RE: Response to comments Work Plan for SERA Phase II Sites ST36/66, ST74, and ST61 EAFB, July 1998. ADEC disagrees with the contractor's response to comments concerning analytical methods discussed in items 1.i and 1.m. The Underground Storage Tanks and Contaminated Sites regulations (18 AAC 78 and 75, respectively) cleanup levels for diesel and gasoline range organics are based on using AK specific methods and not 8015M or 8100M.
The only exception to this critiria within 18 AAC 78.090(5)(h) is: "If site assessment sampling began before November 3, 1995, and if test results satisfy the water quality criteria and cleanup levels referred to in (i) of this section, the owner or operator may continue to use the analytical methods used before that date to complete the site assessment. If site assessment is begun on or after November 3, 1995, the owner or operator shall use the analytical methods set out in Table G of 18 AAC 78.800(b).
ADEC requests the Air Force cease use of alternative lab methods for DRO/GRO analyses by the end of the calendar year (December 31, 1998) for soil and groundwater analyses or long term monitoring which do not include AK 101 or AK 102. The alternative methods will no longer be acceptable when the new 18 AAC 78 and 75 regulations become final.
It is anticipated that the UST regulations and Contaminated Sites regulations will be finalized by the end of this calendar year. Please make changes to any future contracting or scopes of work to ensure that by March 1, 1999, all analyses for GRO/DRO utilze AK methods for both soil and groundwater. |
Louis Howard |
| 12/14/1999 |
Update or Other Action |
SERA I Round 2 monitoring well results received. Well AP3567 had diesel range organics (DRO) detected at 9.37 mg/L. |
Louis Howard |
| 1/10/2000 |
Update or Other Action |
10/99-12/99 Quarterly report received. Of the 34 wells sampled 11 wells remain above the MCL for benzene. Groundwater cleanup levels for petroleum constituents are estimated to be met in September 2010. |
Louis Howard |
| 1/24/2000 |
Document, Report, or Work plan Review - other |
Draft basewide bioventing system report received. Main comments were: replace missing soil implants to conduct respiration testing and method two or three cleanup criteria require additional analyses that method one does not (i.e. polynuclear aromatic hydrocarbons). |
Louis Howard |
| 2/11/2000 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft Basewide Bioventing System, dated January 2000. The text states that the respiration testing could not be performed at ST61 during 1999 because the
soil implants could not be located. DEC requests the Air Force either locate the "missing" implants or install new ones to conduct respiration testing. In Table 5-1 it recommends negotiating a higher
cleanup due to new 18 AAC 75 regulations. For negotiating cleanup levels beyond the Level A criteria, DEC will consider adopting the cleanup criteria in 18 AAC 75. However, this move to a Method 2 cleanup level will require more analytical work on the Air Force's part to show the site has achieved cleanup levels.
Benzene, toluene, ethylbenzene, and total xylenes (BTEX) and polynuclear aromatic hydrocarbons (PAHs) will need to be analyzed for in addition to GRO, DRO analyses. The
chemical-specific cleanup levels for the polynuclear aromatic hydrocarbons (PAHs):
acenaphthene, anthracene, benzo(a)anthracene, benzo(b)fluoranthene, benzo(k)fluoranthene, benzo(a)pyrene, chrysene, dibenzo(a,h)anthracene, fluorene, indeno(1,2,3-c,d)pyrene,
naphthalene, and pyrene are the main PAHs that must be analyzed if using Method Two. PAHanalysis for soils would be required for all petroleum releases, unless the sum of the applicable soil cleanup standards for individual petroleum hydrocarbon fractions or ranges determined for the site by applying the corresponding Method Two - Four referenced in 18 AAC 75.340 is equal or less than 500 mg/kg. PAH analysis is not required for Method One referenced in 18 AAC 75.340. All of the PAH indicator compounds listed above would be required for all
petroleum products except gasoline and JP-4 fuel spill analysis which would be limited to the naphthalene only.
|
Louis Howard |
| 4/17/2000 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on draft Basewide Bioventing Systems Biweekly monitoring and soil gas respiration testing annual report. For the purposes of final closure sampling, the required minimum number of samples (from a minimum of three borings) will be three per boring-at the area with the highest PID reading, at the highest historical contaminant level and at soil/groundwater interface. ADEC will require analysis of benzene, toluene, ethylbenzene, and total xylenes (BTEX), diesel range organics (DRO) and gasoline range organics (GRO) contaminants of concern (sampling for PAHs will be required if the Air Force chooses to cleanup under Method Two). Laboratory analyses, where applicable, will utilize approved AK lab methods, i.e. AK 101 and 102. |
Louis Howard |
| 7/11/2000 |
Document, Report, or Work plan Review - other |
Staff reviewed work plan for closure confirmation sampling for ST68, ST32, ST61, and ST32 bioventing sites. Plan approved as submitted. |
Louis Howard |
| 1/3/2001 |
Document, Report, or Work plan Review - other |
Staff provided comments on bioventing closure sampling document submitted by the USAF. A review of the data in the main document and the Appendix B data shows that GRO is not a contaminant of concern since the detected value of 31.8 mg/kg is below the Method Two Table B-1 level of 300 mg/kg. ADEC requests that the Air Force excavate and thermally treat or address the soil contamination at 45BH06 in the same manner as contamination being addressed at ST 32 Pipeline.
ADEC concurs with the recommendations that the bioventing system be shut down since it does not appear to be adequately remediating the soils at ST 61. However, before ADEC can concur with monitored natural attenuation at the site for soils or groundwater, it will require the following:
Soils at the site near 45BH05 need to be resampled once every three years (at a minimum) through soil borings for petroleum contaminants to assess the degradation of soil contamination which remains above site closure criterion (currently Table B2 Method Two Cleanup Levels for DRO). If the Air Force elect not to excavate the contamination at 45BH06, then ADEC will require that soil sampling be conducted as close as possible to it as well.
Sampling of groundwater will continue until two years (four events) of groundwater monitoring have shown that all applicable cleanup levels (18 AAC 75 Table C) have been met. Additionally, soil borings will have to be have met cleanup levels in the vicinity of 45BH05 and 49BH06 prior to any no further action consideration by ADEC. |
Louis Howard |
| 3/21/2001 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft 2000 Bioventing Annual Report dated February 28, 2001 received on March 5, 2001. ADEC concurs with the recommendations that the bioventing system be shut down since it does not appear to be adequately remediating the soils at ST 61. However, before ADEC can concur with abandoning the bioventing system at the site and relying on passive remediation (monitored natural attenuation) for soil or groundwater, it will require the following:
ADEC requests the soils at the site near 45BH05 be resampled once every three years (at a minimum) through soil borings for petroleum contaminants to assess the degradation of soil
contamination which remains above site closure criterion. If the Air Force elect not to excavate the contamination at 45BH06, then ADEC will require that soil sampling be conducted as close as possible to it as well.
For the purposes of final closure sampling, the required minimum number of samples (from a minimum of three borings) will be three per boring-at the area with the highest PID reading, at the highest historical contaminant level and at soil/groundwater interface. DEC will require analysis of benzene, toluene, ethylbenzene, and total xylenes (BTEX), diesel range organics (DRO) and gasoline range organics (GRO) contaminants of concern (sampling for PAHs will be required if the Air Force chooses to cleanup under Method Two). Laboratory analyses, where applicable, will utilize approved AK lab methods, i.e. AK 101 and 102.
Sampling of groundwater will continue until two years (four events) of groundwater monitoring have shown that all applicable cleanup levels (18 AAC 75 Table C) have been met. Additionally, soil borings will have to be have met cleanup levels in the vicinity of 45BH05 and 49BH06 prior to any no further action consideration by ADEC. |
Louis Howard |
| 4/3/2001 |
Document, Report, or Work plan Review - other |
Staff commented on response to comments for year 2000 biovent closure effort ST32 and ST 61 and ST68. There are specific regulations which allow ADEC to require the Air Force to conduct sampling (to the contrary of what is stated incorrectly in the text of the document). Staff referred the Air Force to 18 AAC 75.345 (h) and (i). Proposal by staff was to conduct sampling every three years to determine if the soil contamination levels are degrading as anticipated. Sites will not be consider "closed" until the applicable cleanup levels are reached. |
Louis Howard |
| 4/17/2001 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Basewide Groundwater Monitoring report. Overall, ADEC concurs with Elmendorf’s approach to reduce its groundwater monitoring costs while still providing protection to human health, safety, or welfare and the environment. With regards to decreasing the monitoring frequency in Operable Unit (OU) 1 to an annual basis, ADEC concurs. With regards to OU 6, ADEC recommends not discontinuing groundwater monitoring at well 703-WL-02 and to continue to monitor for methyl tert-butyl ether (MTBE). |
Louis Howard |
| 3/7/2002 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the 2001 Basewide bioventing report. General Comments-Decommissioning Bioventing Systems: Where the Air Force is recommending bioventing systems be decommissioned, the Department requests additional clarification if the Air Force has looked at other alternatives to treat the "smear zone" (The smear zone is defined as the range of depths within which the groundwater will fluctuate under normal seasonal conditions, and therefore, in which free product would move and “smear” the soil in response to these seasonal changes in the water level elevation.
The smear zone soils may therefore be saturated or unsaturated with groundwater at any given time.) contamination and found it was not practicable to implement them. The basis for not being practicable can be due to reasons such as: reliability of the alternative, alternative is not cost effective, site location, logistics in light of overall project purposes. If an analysis of alternatives was conducted, then it should be stated it is not practicable due to the incremental cost of implementing an alternative is substantial and disproportionate to the incremental degree of protection provided by the alternative as compared to another lower cost alternative.
Well Log Submittal
The Department also wishes to inform the Air Force of the well log recording requirement by the Alaska Department of Natural Resources (ADNR), Division of Mining, Land and Water. The requirement is referenced in the Underground Storage Tank (UST) Procedure Manual, Section 4.7.1 Installing groundwater monitoring wells. Alaska statutes: 38.05.020, 38.05.035, 41.08.020, 46.15.020 and regulations 11 AAC 93.140 require a log of the well be submitted to the ADNR within 45 days after installing a well.
The text states the Department is currently reviewing the Year 2000 Bioventing report. The Department has reviewed the report and provided comments on the document to the Air Force on March 21, 2001. Based on a review of the data, the Department concurs the bioventing system has reached the end of its usefulness at remediating contamination at ST 61 and the system can be decommissioned and further remedial action for soils above the soil/groundwater interface (smear zone) is not required at this time. The Department will require the Air Force to perform additional containment or cleanup if subsequent information indicates that
(1) the level of contamination that remains does not protect human health, safety, or welfare, or the environment; or
(2) the information the Department relied upon for its decision was invalid, incomplete, or fraudulent.
The Department requests the soils at the site near 45BH05 be resampled once every three years (at a minimum) through soil borings for petroleum contaminants to assess the degradation of soil contamination which remains above site closure criterion. If the Air Force elect not to excavate the contamination at 45BH06, then the Department will require that soil sampling be conducted as close as possible to it as well.
For the purposes of closure sampling, three or more borings will be placed at the site and the required minimum number of samples taken will be three per boring. Soil samples will be obtained from two areas, which have the highest PID readings, and one sample obtained from the area with the highest historical contaminant level. The Department will require analysis of BTEX, DRO and GRO as contaminants of concern (sampling for PAHs will be required if the Air Force chooses to cleanup under Method Two). Laboratory analyses, where applicable, will utilize approved AK lab methods, i.e. AK 101 and 102.
Sampling of groundwater will continue until two years (four events) of groundwater monitoring have shown that all applicable cleanup levels (18 AAC 75 Table C) have been met. Additionally, soil borings will have to be have met cleanup levels in the vicinity of 45BH05 and 45BH06 prior to a no further remedial action determination by the Department. |
Louis Howard |
| 7/23/2002 |
Update or Other Action |
An Aqueous and Mineral Intrinsic Bioremediation Assessment (AMIBA) has been completed at ST-61 at Elmendorf Air Force Base, Alaska. Nine soil borings were installed using a hollow stem auger rig to depths of between 20 to 34 feet. Sediment cores were sampled approximately every 2 feet under anaerobic conditions. These samples were evaluated for mineral Fe Total, Fe2 , FeS, and FeS2 and pore water S042-. Volatile organics and DRO were also sampled over the same interval range.
Several conditions at this site contribute to make the value of measurable natural attenuation lower than probably exists. N03' is apparently being added directly to the ground water near the source area minimizing the observable change in concentration for this electron acceptor. The addition of oxygen from the active bioventing system certainly oxidized Fe2 + and FeS
minerals, which lessened the observable expressed capacity for S042- and Fe2 +. As a result, the measurable magnitude of natural attenuation is probably low for this site making the results conservative.
Fe3+ footprint analyses show that hydrocarbon reached the position of monitoring well 45WL02. The current position of the plume is well upgradient of this point indicating that the plume has contracted significantly.
Approximately 449 Kg sorbed DRO exists on the site today. This is distributed as approximately 53% in the vadose zone (236 Kg) and 47% (211 Kg) in the saturated portions of the aquifer. Less than 1.8 Kg DRO is thought to exist dissolved in ground water, only 0.4% of the total.
Based on AMIBA approximately 2,482 Kg, approximately 756 gallons of fuel, has been destroyed by intrinsic bioremediation processes. This fuel degradation is distributed as 46% S042- reduction, 41% N03' reduction, 12% Fe reduction, and 1% 02. Approximately 84.7% of the original fuel mass has been degraded by intrinsic bioremediation processes. The calculated first order rate constant is 0.17 year'. This value is low (conservative) compared to other sites that have been studied using the AMIBA approach probably for the reasons listed above. The current rate of organic removal is 70 Kg/year. Never the less, it is estimated that intrinsic bioremediation processes can remediate ST-61 to the regulatory limit of 1.5 mg/L within 11 years.
A bioventing test was conducted at the same time as the AMIBA fieldwork. This test showed that the in-situ bioremediation process was still active and that the current rate of fuel removal by bioventing is 67 Kg/year.
It is recommended that the bioventing system be discontinued in favor of an intrinsic bioremediation approach because natural attenuation can remediate the site in a timely manner. Additionally, the rate of organic removal from the bioventing system is comparable to natural attenuation alone. Finally, the operation of the bioventing system is arresting natural attenuation processes.
This conclusion is justified by:
* The fact that intrinsic bioremediation alone can remediate the site in approximately 11 years;
* The rate of fuel degradation for intrinsic bioremediation is approximately the same as the engineered approach;
* About 50% of the existing fuel mass is below the capillary fringe and cannot be effectively treated by bioventing;
* The bioventing process is probably inhibiting natural attenuation.
AMIBA was useful in estimating the natural attenuation potential for ST-61 with only nine soil borings. This approach appears to be practical for smaller sites.
Page |
Louis Howard |
| 10/21/2002 |
Update or Other Action |
J. Roberts (ADEC) sent a letter to Joe Williamson (Air Force) dissolving the State Elmendorf Environmental Restoration Agreement. The Alaska Department of Environmental Conservation (DEC) has reviewed the issue of abolishing the State Elmendorf Environmental Restoration Agreement (SERA) per your recommendation. Elmendorf Air Force Base and DEC entered into the SERA in 1992. The agreement was developed as a tool to bring the Base into compliance with Alaska's regulations addressing underground storage tanks, oil and other hazardous substance releases and solid waste.
Since that time, Elmendorf has made significant progress in investigating and cleaning up historic contamination problems. Many of the sites covered by the SERA have been successfully cleaned up and closed. Cleanup is underway at the remaining sites.
Additionally, Alaska has amended the regulations addressing fuel storage tanks, oil and other hazardous substance spills and solid waste. We concur with you that the SERA is no longer a necessary or beneficial. This letter serves as notice that DEC will end oversight on environmental work at Elmendorf by using the SERA. Instead, it is understood that the sites and programs formerly addressed by SERA: solid waste, underground storage tanks (UST), and oil and other hazardous substance discharges will be addressed in accordance with 18 AAC 60, 18 AAC 78 and 18 AAC 75. |
Jennifer Roberts |
| 11/18/2002 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the basewide institutional controls management plan for the Base. 1.2.2 Environmental Restoration Program Page 1-2
The text states that no ICs are associated with the SERA program. The Department requests the Air Force clarify how it will implement and manage ICs at sites not in the CERCLA program, such as those sites in the environmental restoration and compliance programs, where ICs would normally be required. For example, sites requiring ICs would include those sites where long term groundwater or surface water monitoring is being conducted, or sites where monitored natural attenuation (MNA) is being considered/have been established, or where alternative cleanup levels are being considered or have been established.
The Department is in receipt of a compliance program document which identifies several compliance sites where MNA was identified as a remedy. In order for MNA to be accepted by the Department for any site, it will require that ICs be in place and enforceable on the impacted soils and/or groundwater until cleanup levels have been achieved.
Additionally, preliminary data results for the ST 401 investigation were obtained during a project manager meeting held on November 12, 2002. The data shows that groundwater results from two monitoring wells located upgradient of two groundwater seeps are contaminated with diesel range organics (DRO) above cleanup levels. Specifically, wells 401-WL-03 and 401-WL-04 had 38.6 mg/L and 13.2 mg/L DRO detected in the groundwater. Residual range organics (RRO) results could not be conclusively ruled out for well 401-WL-03 since the detection limit was above the Table C cleanup level. In view of this new data, the Department will require continued monitoring in the OU5 area for DRO and RRO in addition to the other petroleum constituents that are being monitored.
If monitoring for petroleum fuel range constituents will not be conducted under CERCLA as a part of the base wide program, then the Department will require groundwater monitoring be conducted under environmental restoration/compliance programs as required by 18 AAC 75 Contaminated Sites regulations (see 18 AAC 75.335 Site Characterization, 18 AAC 75.345(g-j)) and 18 AAC 78 Underground Storage Tank regulations (see 18 AAC 78.235 Release Investigation and 18 AAC 78.615 Groundwater and Surface Water Sample Number and Location). |
Louis Howard |
| 2/28/2003 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft Basewide Bioventing Technical Report, Elmendorf Air Force Base, AK, Dated February 2003. 3.0 Conclusions and Recommendations Page 3-5
The text mentions the identifying of sites that have achieved closure since the cleanup regulations for contaminated sites have changed since the SERA program was established. The
Department agrees, however, wishes to state the State-Elmendorf Environmental Restoration Agreement (SERA) is no longer applicable since it has been dissolved by the State and Air
Force effective October 21, 2002. Since the SERA has been dissolved, releases to the land and waters of the State which have not been properly characterized and formally closed out will
need to be addressed following the applicable current contaminated sites and underground storage tank regulations (18 AAC 75 and 18 AAC 78, respectively).
3.3 ST61 Page 3-6
The text states the contaminated groundwater is creating a smear zone with overlying soils and that this contamination just above the water table will not be remediated with the bioventing
system. The Department concurs and will require monitoring for DRO and BTEX to continue for groundwater wells associated with this site as a part of the Basewide Monitoring Program.
|
Louis Howard |
| 3/3/2003 |
Update or Other Action |
DRO was the only compound still found above ADEC cleanup levels at 11,000 ug/L in well AP-3567. No contaminants above cleanup levels were found in the downgradient well 45-WL-02 or the upgradient well AP-3606. |
Louis Howard |
| 7/16/2004 |
Update or Other Action |
2003 Annual Technical Report Environmental Monitoring and System Optimization of basewide bioventing systems. Bioventing cleanup standards for ST61: DRO 250 mg/kg, GRO 300 mg/kg, benzene 0.02, toluene 5.4 mg/kg, ethylbenzene 5.5 mg/kg, total xylenes 78 mg/kg.
Historical: Routine operation, maintenance and monitoring activities were performed on the
bioventing systems at ST61 during 2002. Closure sampling was conducted at ST61 during 2000. The results of this closure sampling can be found in the Year 2000 Bioventing Closure Effort Report. Data in this report suggest that contaminated groundwater is creating a “smear zone” (The smear zone is defined as the range of depths within which the groundwater will fluctuate under normal seasonal conditions, and therefore, in which free product would move and “smear” the soil in response to these seasonal changes in the water level elevation. The smear zone soils may therefore be saturated or unsaturated with groundwater at any given time.) with overlying soils and that this contamination just above the water table will not be remediated by the bioventing system currently in place.
Recommendations: Previous recommendations for this site include the decommissioning of the
bioventing system since remaining contamination exists only in the smear zone where bioventing is not effective; and continued groundwater monitoring as part of the Basewide Monitoring program. ADEC concurred with the shutdown of the bioventing system, and that further remediation for soils in the smear zone is not required provided that ongoing monitoring of groundwater for DRO and BTEX is performed as part of the Basewide Monitoring program. |
Louis Howard |
| 3/1/2005 |
Document, Report, or Work plan Review - other |
Staff reviewed the draft annual technical report for basewide bioventing systems. The Department agrees that the bioventing has reached the end of its effectiveness as a treatment and it should be halted at this site. Natural attenuation is an appropriate alternative and it should be monitored under the Basewide Groundwater Monitoring Program. The Department agrees that the bioventing has reached the end of its effectiveness as a treatment and it should be halted at this site. Natural attenuation is an appropriate alternative and it should be monitored under the Basewide Groundwater Monitoring Program. Analyses will consist of: gasoline range organics (GRO), diesel range organics (DRO), and benzene, toluene, ethylbenzene, total xylenes (BTEX). The Department requests the Air Force identify which well(s) would be used to monitor the groundwater at this site. |
Louis Howard |
| 3/10/2005 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the draft report for soil sampling at bioventing systems at ST61. ADEC concurs that the residual contamination present at ST61 is in the smear zone and the bioventing system will not address contamination in this area. The location of the smear zone is at approximately 10 to 17 feet bgs. The bioventing system may be shut down and removed from ST61 and the remediation strategy should be changed to monitored natural attenuation. |
Louis Howard |
| 3/31/2005 |
Update or Other Action |
2004 Phase I Remedial Process Optimization (RPO) annual report received. Three groundwater monitoring wells were sampled and only one well AP-3567 had historically been above cleanup levels for DRO (Spring 2002 11,000 ug/L) but in 2004 it had been sampled in the summer and was found to be below cleanup levels at 630 ug/L for DRO.
MNA monitoring is currently performed at each well that is sampled to ascertain COC levels. MNA samples are also collected at the same frequency at which these COC samples are collected. Although this sample collection approach has created inefficiencies at other Program plumes, the current arrangement is acceptable for the ST61 Plume. Wells AP-3606, AP-3567, and 45WL-02 provide a sufficient MNA sampling network. MNA monitoring at this plume should continue in its current form, with samples being collected every other year during COC monitoring.
Bioventing processes have been ongoing for several years at the ST61 Plume and have been conducted to reduce vadose zone contaminants. COCs within the smear zone have been brought beneath cleanup standards, and it is recommended that this treatment system be shut down. Because limited amounts of groundwater contaminants remain, MNA is recommended as the replacement remedy, with samples collected from wells AP-3567, AP-3606, and 45WL-02 on a biannual basis during COC monitoring.
Currently, ST61 is located in an actively used, paved parking lot that is subject to daily vehicular traffic. The Base General Plan indicates that this is also the anticipated future land use. Based on this land use scenario, that the plume does not appear to be migrating or expanding, and that the contamination is confined to the smear zone, no human or environmental exposure to the contaminated groundwater at ST61 is expected. Remediation workers are adequately protected and follow established health and safety procedures. This remedy is therefore considered protective of human health and the environment. Because this is a State site, this remedy was not evaluated in the 2002 Elmendorf AFB [CERCLA] Five Year Review. |
Louis Howard |
| 3/6/2006 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft 2005 Annual Technical Report Optimization of Basewide Bioventing Systems, Elmendorf AFB, Alaska February 2006. 3.2 ST61 Page 3-3
Site ST61 Recommendations - This section states that diesel range organics (DRO) contamination is limited to the smear zone for ST61. Please correct text to state that a closure document is programmed for ST61 not ST68. Contaminants in groundwater at this site will be monitored under the Basewide Groundwater Monitoring Program. Analyses will consist of: gasoline range organics (GRO), diesel range organics (DRO), and benzene, toluene, ethylbenzene, total xylenes (BTEX). ADEC requests the Air Force identify which well(s) would be used to monitor the groundwater at this site.
3.4 ST32, Tank 2 Page 3-3 - Contaminants at this site remain in the smear zone, therefore, the groundwater will be monitored under the Basewide Groundwater Monitoring Program. Analyses will consist of: gasoline range organics (GRO), diesel range organics (DRO), and benzene, toluene, ethylbenzene, total xylenes (BTEX). ADEC requests the Air Force identify which well(s) would be used to monitor the groundwater at this site.
3.11 ST68 Pages 3-7 and 3-8 - The text states that the contaminated water at this site is known as the Heritage Park 64 Plume which is only being monitored for benzene at Well 62-WL-02 and every 5 years for benzene and natural attenuation parameters from Well 64-WL-01.
Additionally, this section states that the current program will continue until DRO concentrations are below cleanup goals for 2 consecutive sampling rounds. ADEC requests the Air Force begin monitoring for DRO groundwater contamination at Wells 62-WL-02 and 65-WL-01 since the current monitoring cannot determine if DRO is below cleanup goals by analyzing for benzene and natural attenuation parameters. |
Louis Howard |
| 2/27/2007 |
Exposure Tracking Model Ranking |
|
Louis Howard |
| 4/17/2007 |
Update or Other Action |
2006 Annual Phase I RPO report (Draft) received. The groundwater monitoring objectives for the ST61 Plume are as follows: Reduce DRO concentrations in groundwater to ADEC cleanup levels. Verify that plume expansion is not occurring and that the monitoring network is sufficient for this purpose.
Site ST61 was investigated in 1993 as part of the SERA Phase I. The remedy for the site was determined in the Final SERA Phase I Corrective Action Plan, approved by ADEC and the USAF, which identified DRO as the groundwater COC for the site. Currently, Site ST61 is still monitored for DRO. The identified COC and its associated cleanup level are the monitoring components that are tracked to measure progress toward achieving monitoring objectives at Site ST61.
Recommendations: Decrease the monitoring frequency of upgradient sentry well AP-3606 to once every five years and in-plume well AP-3567 and downgradient sentry well 45WL-02 to biennially. Measure groundwater levels in all site wells within a 48-hour period to provide a synoptic view of the water table. |
Louis Howard |
| 5/14/2007 |
Document, Report, or Work plan Review - other |
Draft 2006 Zone 1 Annual Remedial Process Optimization Report, April 2007 received on April 18, 2007. Based on the data presented in the report and any pending U.S. EPA comments, ADEC will approve the document as submitted. |
Louis Howard |
| 11/20/2007 |
Update or Other Action |
2007 Zone 1 Remedial Process Optimization (RPO) Report received for contaminated sites and associated underlying groundwater for the western portion of EAFB. This area, referred to as Zone 1, includes: DP98, ST36/66, ST41, ST61, ST69, LF04 North, PL81, WP14, and LF02. Site ST61 is located in the northern portion of EAFB, approximately 1/3-mile south of Hillberg Lake and east of Fairchild Avenue. A vehicle maintenance facility, constructed onsite in 1943 and demolished in 1992, included a 1,000-gallon heating oil UST and a dry well that received drainage from the oil-changing pit.
Wastes associated with the maintenance facility may have included waste oil, solvents, paints, and fuels. Analytical samples collected during removal of the UST in 1992 indicated petroleum contamination at 10 to 17 feet bgs. The site is presently occupied by a radar facility constructed in 1992. Groundwater beneath the site is contaminated with DRO. One plume, the ST61 Plume, comprises Site ST61.
A bioventing system operated at ST61 from 1993 to 2004. Data collected during 2000 and
2004 site investigations showed that all contamination in the vadose zone was below cleanup
levels but that the smear zone was still contaminated with DRO. Thus, the bioventing system
may have contributed to the successful remediation of the vadose zone but could not treat the
contaminated smear zone at the water table, where gas permeability is presumably much
lower because the pores are filled partially to completely with liquid.
In 2007, DRO concentrations in the in-plume well (AP3567) remained at approximately six
times the cleanup level. The upgradient well (AP-3606), with historically negligible concentrations, was not sampled in 2007. The downgradient well (45WL-02) continued to exhibit a low DRO concentration below the cleanup level (Figure 5-2b) although concentrations have shown a trend of slight increases. Reduced DO levels (0.31 mg/L) and high conductivity (566 µS/cm) in well 45WL-02 suggest that the plume leading edge is close to this sentry well. These data suggest that contamination is generally localized around the inplume well (AP-3567) and that the contaminant plume is not migrating downgradient at a significant rate.
With the exception of the anomalously low value measured in 2004, in-plume DRO concentrations have varied between 2,500 and 11,000 µg/L, with no declining trend. The highest results exceed the probable solubility of DRO and imply the presence of LNAPL droplets or emulsion in the samples. Hence, the contaminated smear zone likely contained significant LNAPL at least as recently as 2002. When the LNAPL has attenuated to the point that it can no longer migrate into the well, DRO concentrations will be much less scattered and will show a declining trend. Continued monitoring will identify this transition and subsequent rate of decline.
In summary, system performance is marginal. The groundwater DRO plume has yet to show
signs of attenuation, geochemical conditions may not favor biodegradation, and the plume
may be migrating slowly downgradient. At this time, no cleanup date can be predicted but the
period of MNA is likely to be protracted. Recommendation: Decommission the bioventing system at ST61. The system at ST61 has served its purpose and has been identified for removal. |
Louis Howard |
| 3/3/2010 |
Update or Other Action |
Zone 1 Field Activities Report received. Zone 1 is one of three zones established on EAFB for management of environmental restoration. Eight sites are managed under Zone 1: LF02, LF04, WP14, ST36/66, ST41, ST61, ST69, and DP98. Groundwater contamination is monitored at 10 plumes in Zone 1, and exposed landfill debris is removed annually at LF04.
Five sites (LF02, LF04, WP14, ST41, and DP98) are administered under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) with U.S. Environmental Protection Agency (EPA) oversight and are governed by Records of Decision (ROD). The three remaining sites (ST36/66, ST61, and ST69) are regulated according to State of Alaska cleanup requirements.
In 2009, one injection well and three soil implants, components of the bioventing treatment system were abandoned. Abandonment proceeded according to ADEC guidelines in Monitoring Well Design and Construction for Investigation of Contaminated Sites (ADEC 2009). The soil implants could not be pulled from the ground and were abandoned in place.
In addition to grouting the well casing and soil implants, flush-mounted access holes for the soil implants located in paved areas were filled with concrete to match the local grade. The location of any piping and wiring left in place was surveyed, and GPS coordinates are provided for placement into Geobase.
In 2004, in-plume DRO concentrations at ST61 varied between 2,300 and 11,000 µg/L except
for low values, and in 2009, values were near 1,000 µg/L. Concentrations in the downgradient monitoring well were always far below the cleanup level. Although DRO increased moderately in 2004 through 2007, it returned to a low level in 2009. These data suggest that contamination is generally localized around the in-plume monitoring well (AP-3567) and that the contaminant plume is not migrating downgradient at a significant rate.
DRO concentrations in the in-plume monitoring well (AP-3567) have exhibited a weakly
declining trend over time, sufficient to support prediction of a cleanup date of 2031 via the statistical geometric regression analysis. Although levels of DRO were below cleanup criteria for the 2009 survey, the data do not indicate that the site is clean. Historic variability of DRO concentrations likely reflect the interaction between the contaminated smear zone and seasonal fluctuations in water levels. In 2009, the water-table elevation was between 0.15 and 1.54 feet, lower than in 2007. Such variations would alter the interaction between groundwater and the contaminated smear zone, with negligible interaction when water levels fall below the base of the contaminated smear zone. This may explain the low DRO concentrations in 2009.
Monitoring will continue until evidence suggests contamination is no longer present at the site. Historic DRO results exceed the probable solubility of DRO and imply the presence of LNAPL droplets or emulsion in the samples at least as recently as 2002. When the LNAPL has attenuated to the point that it can no longer migrate into the well, DRO concentrations will be much less scattered and will show a declining trend. Continued monitoring will identify this transition and subsequent rate of decline. High water levels with low concentrations of DRO may be a result of decreasing amounts of overall presence of contaminants. Further collection of data is needed to verify whether or not this is the case.
Recommendations for future monitoring at ST61 are as follows:
No changes are recommended for groundwater monitoring at ST61, and all three site monitoring wells are scheduled for sampling in 2011. Biennial monitoring will be sufficient to identify the transition from LNAPL droplets in the smear zone to a completely immobile source yielding only dissolved DRO, which would probably decline more consistently and allow a confident prediction of cleanup. |
Louis Howard |
| 3/12/2010 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (ADEC) has received the draft monitoring report for review & comment on March 3, 2010. Below are ADEC’s comments regarding the report which covers eight sites: LF02 (CS DB Hazard ID 2770), LF04 (CS DB Hazard ID 1804), WP14 (CS DB Hazard ID 639), ST36/66 (CS DB Hazard ID 1793), ST41 (CS DB Hazard ID 429), ST61 (CS DB Hazard ID (2747), ST69 (CS DB Hazard ID 1795), DP98 (CS DB Hazard ID 2595) & ten GW plumes in Zone 1.
7.6 Summary and Recommendations for ST61 Page 7-10: ADEC concurs with the summary and recommendations for ST61.
8.6 Summary and Recommendations for ST69 Page 8-7: ADEC concurs with the summary and recommendations for ST69.
Appendix B – Data Quality Assessment and Supporting Documentation
1.0 Introduction Page B-1-1: The text states Pace Analytical Services of Seattle, Washington provided primary analytical support. Please be aware that their certification expires on March 18, 2010 (UST-025).
2.0 Data Quality Summary
Data Quality Assessment 2.1.6 Nonsystematic Data Quality Issues Page B-2-4 states: “Cooler “Can You” arrived at the laboratory with the temperature blank temperature greater than the upper limit of 6 °C. Three measurements were taken using an infrared thermometer: 8.2 °C, 8.1 °C, and 6.3 °C. The cooler contained one sample (LF02SP01-WS090727A [SDG JZ1E06]) for SW8270C and SW6020 analyses. The results associated with this sample were qualified “JTE” (Attachment B-1). The temperature exceedance was the result of too little ice added to the coolers before transport to the laboratory. Analysis for selenium and thallium does not require preservation and storage at 4 ± 2 °C; therefore, these results were not qualified. All SW8270C results for sample LF02SP01-WS090727A were nondetect.”
According to the UST Procedure Manual (amended as of November 7, 2002): 8270C preservation/holding time requirements are as follows: “4 ± 2 oC, Ascorbic acid, dark /7 days to extraction, 40 days to analysis of extract” |
Louis Howard |
| 3/24/2010 |
Document, Report, or Work plan Review - other |
EPA has reviewed the Draft Zone 1 Field Activities Report, February 2010, Elmendorf A.F.B., Alaska and has the following comments:
General: There appear to be several significant issues that need further discussion among the RPMs as a result of interpretations and conclusions made in this Report or practices described in this Report. The proper use of PDBs and the rationale for their use seems to be unclear. There also could be an issue with the consistency of their use. The purpose of a Base-wide Monitoring Program should be to integrate all info on all contaminants and not deal with CERCLA COCs, alone. This Report seems to take" liberties" with the interpretation of the OU6 ESD; EPA agrees with the ADEC clarification of the purpose of the ESD in their comments on the above Report. The QA Lab reports, as an Appendix to this Report outline flagged issues dealing with sample temperature and volatile organic analysis (VOA) collection discrepancies that compromise the data in this Report and cast doubt on adherence to Management Plan SOPs.
Specific:
1.1 2009 Zone 1 Project Objectives Page 1-1 EPA agrees with the comments made by ADEC . The Zone or "Basewide Monitoring Plan" should deal with all programs, otherwise we would have only OU Monitoring Plans.
1.3.1 Ground Water and Surface Water Sampling Page 1-7 Since technique and consistency of sampling appears to be an issue, EPA agrees with ADEC suggestions to include SOPs as an appendix to work plans. This section calls into question the value and use of PDB sampling. This is a topic for FFA discussion and possibly consultant briefing.
7.6 Summary and Recommendations for ST61 Page 8-7: EPA agrees with the recommendations.
Appendix C Sample Summary and Cooler Receipts Pace Analytical Services noted head space non-compliance for VOA samples from cooler AAT240 , cooler AAF842, cooler AAD995, ,AAD783 ,AAT317.
This calls into question data validity and VOA collection technique. Also, coolers "To Where"," 000801 Can You", were beyond temperature controls. Data Validation and QA should be the first step before writing a Report. |
Louis Howard |
| 4/28/2010 |
Update or Other Action |
Memorandum for ADEC. SUBJECT: Response to ADEC Comment on Draft 2009 Zone 1 Field Activities Report (Ref: ADEC Memo, 12.Mar 10)
1. This memorandum is in response to ADEC's concern as to why diesel-range organics (DRO) and gasoline-range organics (GRO) at select groundwater plumes were not sampled in 2009 as
previously agreed in a January 14, 2003 meeting. Specifically, ADEC's comment (Attachment 1) is in reference to Section 3.7.1 Implications of Contaminant and Geochemical Monitoring, Page 3-17 of the draft 2009 Zone 1 Field Activities Report, which stated: "The text states: When these parameters were monitored from 1999 to 2007, GRO concentrations in this monitoring well exceeded cleanup levels while DRO concentrations hovered near the cleanup level. ADEC requests the Air Force provide an explanation or a memorandum to the site file as an appendix to the document on why DRO and GRO were eliminated from the monitoring program as previously agreed to in a January 14, 2003 meeting with ADEC, USAF and EPA."
2. The analytes in question were not included in the Zone 1 groundwater monitoring program
for FY09 due to an administrative oversight. The agreement to monitor for DRO and GRO was
captured in meeting minutes (Attachlnent 2), not in a more formal mechanism such as a decision
document or memorandum to the·site file. In preparation for programming of project
requirements, we reviewed the governing documents for the Zone 1 sites. None of the governing
documents for Zone 1 sites identified GROIDRO as a contaminant ofconcem (COC); therefore,
GRO/DRO sampling was not programmed or conducted in 2009.
3. The U.S Air Force agrees with ADEC's request to continue sampling for diesel-range organics (DRO) and gasoline-range organics (GRO) for CERCLA sites with fuel-related plumes. Minutes of a 14 Jan 03 meeting with EPA, ADEC and DRS, provided with the above referenced ADEC memo, documents that the Air Force agreed to add DRO/GRO into the sampling program under the following conditions:
a. The decision will be documented in the 5-Year Review. The addition of DRO/GRO to the program should be introduced in the 5-Year Review under· mention of new issues affecting protectiveness.
b. The Air Force will NOT add DRO/GRO as a CERCLA ARAR, but will compare DRO/GRO results to ADEC cleanu levels in the annual re orts and will discuss in subsequent 5-Year Reviews. The benefit ofthis is that if CERCLA COCs meet ARARs, the Air Force can achieve a partial delisting.
c. The Air Force will add DRO and GRO to the suite of analyses at monitoring wells associated with fuel plumes starting in 2004.
d. The Air Force will not pursue a decision document with ADEC on DRO/GRO until more data is gathered on the extent of the problem.
e. Until a decision document is signed with ADEC, GRO and DRO concentrations will be compared to ADEC regulations in 18 AAC 75 (Table C, Groundwater Cleanup Levels; 1,500 ug/L for DRO, 1,300 ug/L GRO).
f. Sampling frequency for DRO/GRO will follow the latest Decision Guide for Sampling Frequency (see 2002 Basewide Annual Report). "Immediately up gradient" means within a 2-year warning line, similar to that generated for OU5.
g. ADEC GRO/DRO criteria apply to groundwater, not to seeps which daylight as surface water. Criteria in 18 AAC 70 (TAR, TAqH) apply to surface water.
4. The fact that these analytes were not included in the Zone 1 groundwater monitoring program
for FY09 is attributed to an oversight. The USAF will add DRO/GRO into the suite of analyses
at monitoring wells associated with fuel-related plumes for Zone 1 (LF04 South and WP14) and
will prepare a memo to the site file to prevent this type of oversight from occurring in the future.
The USAF strategy will be to compare DRO/GRO and total aromatic hydrocarbon (TAH)/total
aqueous hydrocarbon (TAqH) sample results as contaminants of interest with current ADEC
regulations in 18 AAC 75 - Table C - Groundwater Cleanup Levels and 18 AAC 70 for surface
water. Should you have any questions, please feel free to contact me at (907) 552-2875.
Signed Gary Fink YF-02 Chief, Environmental Restoration. |
Louis Howard |
| 2/10/2011 |
Update or Other Action |
Zone 1 Draft Field Activities Report received. In 2010, the only site activity for ST61 was a free-product survey at the two wells most likely to contain free product at this site (AP3567 and AP3606). At AP3606, the oil-water interface probe indicated only a very thin layer of product, perhaps 0.005 feet thick, well below the 0.1 foot threshold for product removal. The probe indication was not verified via bailing and could have been a spurious response at the air-water interface (such responses are common). Product was not detected in AP3567.
The 2010 recommendations for future monitoring at ST61 are as follows:
No changes are recommended for groundwater monitoring at ST61. All three site monitoring wells are scheduled for sampling in 2011. Biennial monitoring will identify the transition from product droplets in the smear zone to a completely immobile source yielding only dissolved DRO, which would probably decline more consistently and allow a confident prediction of cleanup.
Evaluate ST61 for in situ chemical oxidation to expedite reduction in DRO. |
Louis Howard |
| 2/24/2011 |
Document, Report, or Work plan Review - other |
Staff reviewed and approved the recommendations in the draft field activities report for this source area in SERA Phase I. |
Louis Howard |
| 5/19/2011 |
Update or Other Action |
Wing Instruction 32-7003 dated May 19, 2011 Land Use Control Management. OPR: 673 CES/CEANR Certified by: 673 CEG/CC (Col Russell R. Hula). This instruction implements AFPD 32-70, Environmental Quality, & is used in conjunction with AFIs 32-7020, The ERP, 32-7066, Environmental Baseline Surveys in Real Estate Transactions, & 673ABWI 32-1007, Safeguarding Utilities From Damage.
It prescribes the processes & responsibilities for the management of & compliance with land use controls on Joint Base Elmendorf-Richardson (JBER) & applies to all military & civilian organizations that occupy facilities, or conduct business, on the installation. This publication does not apply to the USAF Reserve or Air NG units & members. The current land use control areas can be found on the Environmental Restoration map located on the GeoBase webpage.
General:
1.1. Land use controls (LUC), such as limitations on access, water use, excavations, & property transfers, will supplement engineering controls as appropriate for short-term & long-term mgt to prevent or limit human & environmental exposure to hazardous substances, pollutants, or contaminants.
Examples include limitations on the depth & location of excavations, prohibition of or restrictions on well drilling & use of GW, mgt. of excavated soils, & prohibition of certain land uses. LUCs, often used interchangeably with (ICs), are administrative, procedural, engineering, & regulatory measures to control human access to & use of property.
1.2. LUCs were established at JBER to prevent exposure to contaminated soil & water, based on agreements between the military services & the EPA & the 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. They include restrictions on the use of portions of the shallow aquifer south of the Elmendorf Moraine, limitations on the types of buildings allowed in certain areas – primarily occupancy limitations, & land use designations for certain areas as recreational use only.
The LUCs have been implemented at several sites & operable units (OU) as part of the ERP. LUCs were established for DP98 & OUs 1, 2, 4, 5, & 6 on former Elmendorf AFB property in their respective records of decision (ROD), as a component of the selected cleanup remedy. LUCs were also established for restoration & compliance sites formerly part of Fort Richardson in their respective RODs or Decision Documents. LUCs must be in place as long as a property is not available for UU or UE & may include temporary or permanent restrictions or requirements. When all cleanup goals have been achieved for a given site, temporary controls, such as GW use restrictions, may be removed.
2. Responsibilities:
2.1. JBER personnel, tenants, or contractors whose projects or activities require excavation in areas where site-specific LUCs are in effect will comply with all LUCs, 673ABWI 32-1007, & applicable AF instructions. Base contractors & tenant organizations will have LUC compliance requirements incorporated into their contracts & interagency agreements, as will be necessary. Failure to comply with LUCs will be grounds for penalty, in accordance with provisions specified in applicable contract documents. At project completion, the JBER organization or contractor will sign a certification of LUC compliance & return the compliance statement to 673 CES/CEANR.
2.2. The 673d Civil Engineer Squadron (673 CES):
2.2.1. Asset Management Flight (673 CES/CEA):
2.2.1.1. Natural Resources Management (673 CES/CEAN):
2.2.1.1.1. Environmental Restoration (673 CES/CEANR):
2.2.1.1.1.1. Will provide GW & site-specific LUC requirements throughout the installation & identify any known soil contaminated sites & monitoring wells for the area of the proposed project.
2.2.1.1.1.2. Will conduct annual site visits to ensure compliance with LUCs during project implementation.
2.2.1.1.1.3. Will conduct 5-year reviews, at 5-year intervals, or as required by any subsequent RODs.
2.2.1.1.1.4. Will prepare annual LUC compliance reports & submit reports to ADEC & USEPA by 1 February each year.
2.2.1.1.1.5. Will disseminate LUC information to personnel involved in LUC mgt, including real property & 673 CES/CEPT for inclusion into GeoBase.
2.2.1.1.1.6. Will operate an active educational program that includes disseminating updated fact sheets & LUC information, providing notices through the installation intranet & the Arctic Warrior newspaper, & by briefing LUC mgt at project kick-off meetings; Environmental, Safety & Occupational Health Council meetings, & CEB meetings.
2.2.1.1.1.7. Will coordinate any changes in the base general plan (BGP), or real estate transactions, with USEPA & ADEC.
2.2.1.1.1.8. Will maintain copies of signed certificates of compliance, indicating requestor’s adherence to LUCs during project execution.
See site file for additional information. |
Louis Howard |
| 7/15/2011 |
Update or Other Action |
Draft Work Plan Environmental Remedial Action-Operations & LTM & Maintenance received.
The purpose of this project is to perform RA-O & LTM activities for several JBER Programs. These programs include sites distributed across both JBER-Elmendorf & JBER-Richardson. This Work Plan addresses remedial activities in JBER-Elmendorf Zone 1, Zone 2, & Zone 3 Management Areas, JBER-Elmendorf Compliance Restoration Program (CRP) sites, the JBER Elmendorf Operable Unit (OU) 1 Landfill, JBER-Richardson Multiple Installation Restoration Program (IRP) Sites, & JBER-Richardson Poleline Road & OUE Armored Vehicle Maintenance Area (AVMA).
Environmental Restoration Program Zone 1 Management Area covers the comparatively sparsely developed portions of JBER-Elmendorf to the west, north, & east of the airfield & administrative core of the base. Eleven sites are now managed under Zone 1: LF02, LF03, LF04, WP14, ST36/66, ST41, ST61, ST69, SS83, & DP98. LF02 & LF03 are located in the southeastern portion of the base, near the Boniface gate, whereas the remaining nine sites are distributed throughout the northwestern portion of the base, between the airfield & Knik Arm. GW contamination is tracked in nine plumes at these sites, & exposed landfill debris is of concern at LF04.
Six sites (LF02, LF03, LF04, WP14, ST41, & DP98) are administered under the Comprehensive Environmental Response, Compensation, & Liability Act (CERCLA), with USEPA oversight, & are governed by ROD. The five remaining sites (ST36/66, ST61, ST69, & SS83) are regulated according to State of Alaska requirements. GW COCs for most of the sites (WP14, ST36/66, ST41, ST61, & SS83) are fuel constituents (one or more of benzene, toluene, ethylbenzene, xylenes, or diesel-range organics [DRO]).
These sites were contaminated by pipeline & storage tank leaks & past practices. The primary sources have been removed, leaving secondary sources comprised of residual fuel distributed in contaminated smear zones at the water table. Two sites have chlorinated-solvent GW COCs: LF04 (1,2-dichloroethane & methylene chloride, as well as fuel constituents), & DP98 (chlorinated solvents). The chlorinated solvents occur in shallow GW as dissolved contaminants at LF04 & in conjunction with a DRO contaminated smear zone at DP98.
ST61 is located approximately 1/3 mile south of Hillberg Lake, west of Building 21309 and east
of Fairchild Avenue (Figure 2.7). A vehicle maintenance facility, constructed onsite in 1943 and
demolished in 1992, included a 1,000-gallon heating-oil UST and a dry well that received drainage from the oil-changing pit. Wastes associated with the maintenance facility may have
included waste oil, solvents, paints, and fuels. Analytical samples collected during removal of
the UST in 1992 indicated petroleum contamination at 10 to 17 feet bgs. The site consisted of
Building 21309, a radar facility built in 1992. Groundwater beneath the site is contaminated
with DRO. One plume, the ST61 plume, is monitored at this site.
The Zone 1 Management Area sites are located throughout the western, northern, & eastern portions of JBER-Elmendorf. Nine sites on JBER are managed under Zone 1: LF02, LF04, WP14, ST36/66, ST41, ST69, SS83, & DP98. COC are tracked in all nine GW plumes at these sites, & are listed below. LF04 also contains an inactive landfill where debris is monitored & fallen debris removed.
• Site LF02 - 1,1,2,2-tetrachloroethane (PCA)
• Site LF04 - Benzene, ethylbenzene, toluene, methylene chloride, 1,2-dichloroethane
(DCA)
• Site WP14 - Benzene, ethylbenzene, toluene
• Site ST36/66 - diesel range organics (DRO)
• Site ST41 - benzene, toluene, ethylbenzene, & xylenes (BTEX)
• Site ST69 - Benzene
• Site SS83 - DRO
• Site DP98 - tetrachloroethene (PCE), Trichloroethene (TCE), 1,1-dichloroethene, cis-1,2-
dichloroethene, vinyl chloride (VC)
Data quality objectives directly linked to Zone 1 project objectives are defined in the FSP & UFP-QAPP, within the SAP (Appendix A). Additional Zone 1 Management Area project objectives in 2011 include:
Evaluate & maintain the integrity of monitoring wells;
Evaluate GW flow characteristics while continuing to study trends in GW level with the monitoring wells; &
Evaluate erosion rates & characteristics of the LF04 bluff.
The activities to be performed under this TO include:
Collect & analyze GW & surface water samples;
Conduct GW level survey;
Perform maintenance of existing wells, as needed;
Install a maximum of 2 new/replacement GW wells;
Decommission a maximum of 5 damaged/redundant wells; &
Conduct LF04 erosion survey & debris removal.
|
Louis Howard |
| 11/22/2011 |
Update or Other Action |
ST61 Decision Document draft received. This Decision Document (DD) presents the remedy selected by the United States Air Force (USAF) & approved by the Alaska Department of Environmental Conservation (ADEC) for petroleum contamination located at ST61 on Joint Base Elmendorf-Richardson (JBER), Alaska. This DD describes the site history & factors that led to the selection of the remedy at the site.
This DD follows the USAF policy on performance-based records of decision for land use control (LUC) implementation & the State of AK guidance contained within the 18 Alaska Administrative Code (AAC) Chapter 75.380. The site addressed by this DD is ST61, legal description Section 28, Township 14 North, Range 3 West of the Seward Meridian, AK. The physical location is in the northwest portion of JBER approximately 1/3 mile south of Hillberg Lake, east of Fairchild Avenue near Building 21309.
Two soil borings (45BH07 & 45BH08) were advanced during the 2004 site investigation at ST61, & six soil samples were collected & analyzed for DRO. The boreholes were advanced as close as possible to the two boreholes drilled during the 2000 site investigation with elevated DRO levels (45BH05 & 45BH06). A third boring was not required because borehole 45BH04 met soil cleanup levels in 2000.
Soil samples from soil boring 45BH07 were collected at 12 & 14 feet bgs, two of the depths at which DRO concentrations were found at 45BH05 during the 2000 soil sampling event. An obstruction was encountered at approximately 14.5 feet bgs, which did not allow a sample to be collected at 16 feet bgs. A second boring (45BH07B) was drilled several feet away from 45BH07 & advanced to a depth of 16 feet bgs, where a soil sample was collected. Soil samples from soil boring 45BH08 were collected at 10, 12, & 16 feet bgs, the depths at which DRO levels were found at 45BH06 during the 2000 soil sampling event. Depth intervals in each boring were screened with a PID to verify that there were no additional potentially contaminated depths requiring lab analysis.
DRO from the 2004 site investigation ranged from 520 mg/kg to 2,300 mg/kg, all of which exceeded the soil cleanup level. All depth intervals were screened with a PID, which confirmed the depth of contamination to be confined to the smear zone between 10 & 17 feet bgs, just above the GW surface.
Fluctuating levels of hydrocarbon-impacted GW was the predominant cause of the soil contamination within the smear zone. ADEC requires that remaining smear zone contamination be managed as GW contamination; therefore, no further action will be recommended for ST61 soils. Field screening & analytical data indicate that there are no remaining contaminants in the vadose zone soil, demonstrating that the ST61 bioventing system was successful in remediating contamination in the vadose zone soil.
There is a potential that GW at ST61 could be used as a drinking water source in the future. DRO concentrations in the GW are variable & exceed the ADEC Table C cleanup level in the in-plume well during some sampling events. This GW should not be used as drinking water until the contaminant levels have been reduced to below the cleanup level. There are currently no drinking water wells at ST61.
The selected remedy (Alternative 2) will include the following activities:
• The GW at ST61 will be monitored to confirm the natural attenuation of the COC (DRO) that remains above cleanup levels by collecting GW samples from one in source, one upgradient, & one downgradient monitoring well according to the Sampling Frequency Decision Guide.
• Free product will be removed if greater than 0.1 feet thick is observed in an ST61 GW monitoring well during a GW sampling event.
• After results from one analytical GW sampling round show contaminant levels below the GW cleanup level in all wells, one sampling event will take place during each of the following two years to ensure GW samples meet the cleanup level for DRO.
• LUCs will be implemented to prevent exposure to GW & smear zone contaminants as outlined in Section 5.6.
Closure Criteria & Timeframe
GW monitoring & implementation of LUCs will continue at ST61 until GW contamination is no longer a threat to human health & the environment (i.e., one analytical GW sampling round shows contaminant levels below GW cleanup levels). This will be verified by two years of consecutive sampling events where analytical results show that COCs are below the GW cleanup levels.
After the GW cleanup levels have been met, it will be assumed that because the soil contamination in the smear zone is no longer leaching contamination, has reached the soil cleanup level. Trend analysis of long-term monitoring results predicts that the GW will reach the cleanup level by 2031 at the latest.
See site file for additional information. |
Louis Howard |
| 12/1/2011 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the ST61 draft decision document.
2.3 Affected Media
ADEC will consider the contaminated soil in the smear zone as soil which is regulated by Table B1 & B2 of 18 AAC 75 if it is ever excavated by JBER in the future.
Soil excavated during construction activities or any other soil disturbance activities that exhibit contamination levels above migration to GW cleanup levels (i.e. GRO 300 mg/kg, DRO 250 mg/kg, benzene 0.025 mg/kg) must either be removed for off-site disposal, or remediated to levels below target cleanup levels before being placed back into the ground. Prior notification to ADEC will be required prior to transport for off-site disposal or remediation of any contaminated soil. Construction plans on the property must include procedures to screen any excavated soils & provide for soil remediation contingency scenarios. Construction plans within the property must also include procedures to address any contaminated GW that is encountered.
Figure 2-1 If there were a second UST northeast of the original vehicle maintenance facility, it would not be a source of the free product in the upgradient well AP-3606.
4.1 Table 4-1
The correct migration to GW cleanup level for benzene is 0.025 mg/kg. The correct migration to GW for ethylbenzene is 6.9 mg/kg. The correct migration to GW cleanup level for toluene is 6.5 mg/kg. The correct migration to GW cleanup level for total xylenes is 63 mg/kg (18 AAC 75 revised as of October 1, 2011).
4.2.1 See comment #1.
Table 4-2 Please add a column for PAHs or note to table that PAHs were analyzed for in 2000 & not found to exceed applicable cleanup levels.
4.2.2 ADEC requests clarifying text on how an upgradient well (AP-3606) can be considered upgradient if it has had free product found in it during 2007 & 2010. The upgradient extent of the plume boundary would likely need to be extended to include well AP-3606 & text to describe how a downgradient source (the former UST) could cause an upgradient well to contain free product. If it cannot be linked to the former UST, then it appears there may be another source for the free product in AP-3606. “Contamination at ST61 consists of petroleum hydrocarbons, attributed to an UST & an unknown upgradient source.” See Section 2.3 Affected Media.
For this unknown upgradient source, additional wells need to be installed to characterize the extent of contamination associated with AP-3606. ADEC requests clarification on the nature of the product found in AP-3606. The Figure 4-6 in the document does not satisfactorily demonstrate how product being detected in AP-3606 is related to the former heating oil UST.
Figure 4-2 The data for AP-3606 does not reflect what one would expect for a monitoring well that contained free product (2007 0.84 feet & 2010 0.005 feet).
Table 4-3 The correct GW cleanup level for GRO is 2.2 mg/L or 2,200 ug/L. Add AP-3566 to the table & show that it had a benzene exceedance of 9.5 ug/L as part of the 1994 SERA Phase I Site Investigation.
4.4 Conceptual Site Model
See comment #1.
5.4 Benzene was detected above cleanup levels during the SERA Phase I Investigation.
“DRO & benzene were found above cleanup levels at maximum concentrations of 6.4 milligrams per liter (mg/L) (AP-3567) & 0.0095 mg/L (AP-3566), respectively.”
5.5.1 Monitoring wells with free product less than 0.1 feet thick will be sampled during all GW monitoring events. GW samples will be collected after parameters have stabilized, after three casing volumes have been purged if the field parameters have not stabilized, or after the well has recharged sufficiently after going dry.
LNAPL samples should be obtained prior to purging of the well. Purging of the LNAPL from the well prior to sampling may be conceptually desirable to obtain a more representative sample. However, in many cases purging may result in an inability to sample due to slow or no LNAPL recharge & emulsification of the sample. Specific sampling techniques should be evaluated with regard to study objectives & site conditions.
Whenever possible measurements for free product should be taken using either steel tape & paste or an interface probe. The use of bailers can significantly under- or overestimate the thickness of free product in the well & should not be used for determining the elevations of air/free product & free product/water interfaces. The use of bailers should be limited to verification of the presence of free product in a well or collection of a sample of it.
COCs shall include benzene since it was detected at 9.5 ug/L during the 1994 SERA Phase I Site investigation & cannot be dismissed as a COC.
Benzene will be analyzed as part of the final two sampling events since it was present above 5 ug/L in well AP-3566. |
Louis Howard |
| 4/10/2012 |
Update or Other Action |
Draft Annual Report Received for Zones 1, 2, and 3.
DRO in the in-plume monitoring well (AP-3567) exceeded the cleanup level. DRO results for both the upgradient (AP-3606) and downgradient (45WL-02) wells were below the cleanup level. Free product was not detected during sampling in 2011.
Historically, in-plume DRO concentrations at ST61 have varied between 2,300 and 11,000 µg/L, except in 2004 and 2009 when values were below 1,000 µg/L. Although DRO decreased moderately in 2009, it exceeded the cleanup level once again in 2011, as per monitoring well AP-3567 results. Concentrations in the downgradient monitoring well (45WL-02) remain far below the cleanup level. These data suggest that contamination is generally localized around the in-plume monitoring well (AP-3567) and that the contaminant plume is not migrating downgradient at a significant rate.
Prior to 2011, DRO concentrations in the in-plume monitoring well (AP-2497 3567) exhibited a weakly declining trend over time, sufficient to support prediction of a cleanup date of 2031 via the statistical geometric regression analysis (USAF, 2011a). However, the correlation coefficient of only 0.12 indicated that the data poorly fit the regression assumption of first-order decay and that the prediction for the cleanup date was uncertain. In 2011, DRO increased to a concentration exceeding the cleanup level in 2011. Fluctuating concentrations of DRO indicate that additional data are needed to establish a decreasing trend and support prediction of a cleanup date.
Historic variability of DRO concentrations likely reflects the interaction between the contaminated smear zone and seasonal fluctuations in water levels. In 2009, the water table elevation was between 0.15 and 1.54 ft, lower than in 2007 (USAF, 2008b). Such variations would alter the interaction between groundwater and the contaminated smear zone, with negligible interaction when water levels fall below the base of the contaminated smear zone.
This may explain the low DRO concentrations in 2009. Monitoring will continue until evidence suggests that contamination is no longer present at the site. Historic DRO results exceed the solubility of DRO and imply the presence of light non-aqueous phase liquid (LNAPL) droplets or emulsion in the samples at least as recently as 2002.
When the LNAPL has attenuated to the point that it can no longer migrate into the well, DRO
concentrations will be much less scattered and will show a declining trend.
Conditions and trends in the ST61 plume are as follows:
• Upgradient. Historically, results in the upgradient monitoring well (AP-3606) have been below the cleanup level. The concentration of DRO was below the cleanup level in 2011.
• In-plume. DRO concentrations in the core of the plume have been variable since monitoring began in 1995, and do not yet show a downward trend.
• Downgradient. DRO is present at very low levels, below the cleanup level. Over the long term, DRO appears to be stable, indicating that the plume is not migrating.
In summary, the groundwater plume at ST61 has yet to show consistent signs of attenuation and
geochemical conditions do not favor biodegradation, but the plume appears to be remaining in
place.
The 2011 recommendations for future monitoring at ST61 are as follows:
• No changes are recommended for groundwater monitoring at ST61. Biennial (once every 2 years) monitoring will identify the transition from product droplets in the smear zone to a completely immobile source yielding only dissolved DRO, which would probably decline more consistently and allow a confident prediction of cleanup.
• Evaluate ST61 for in-situ chemical oxidation to expedite reduction in DRO.
|
Louis Howard |
| 6/6/2012 |
Update or Other Action |
Draft Project Management Plan received.
Performance Objective: Site closure.
Performance indicators:
· Prepare an approved Site Characterization Workplan by December 2012
· Coordinate, mobilize, and execute Site Characterization by August 2013
· Prepare an approved Site Characterization Report and Site Closure Report by March 2014
· Conduct final site closure requirements and well abandonment to achieve SC by May 2014
Potential Risk
HRC indicates soil contamination is present exceeding risk levels
HRC indicates groundwater contamination is present exceeding risk levels.
Risk Mitigation
Excavation or treatment (biovent) will be completed for vadose zone soils exceeding risk levels to eliminate risk, and evaluation of groundwater impacts will be completed and appropriate treatment (enhanced bioremediation) will be implemented to remediate groundwater.
Summary of performance objectives:
Date of achieving performace objective-3rd Quarter 2014
Planned approach:
Prepare an approved Site Characterization Workplan including an updated CSM. Coordinate, mobilize, and execute Characterization by installing and sampling five soil borings and three existing monitoring wells. Use HRC to evaluate SC based on risk to future residential receptors for all pathways.
Prepare an approved Site Characterization Report with an updated CSM, documented HRC risk evaluation, and include the 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 |
| 6/22/2012 |
Document, Report, or Work plan Review - other |
Staff reviewed & commented on PBR PMP.
Page 2-31
The text states: “The WPs will be submitted in the initial phases of the project for Air Force & regulatory review & concurrence according to the schedule outlined in the IMS. If regulatory agencies elect not to review/approve documents, approval will be sought through the Secretary of the Air Force/Installations & Environment (SAF/IE) to proceed with execution of the plan activities. The WESTON Team understands that a procedure has been established for this situation, & that the Air Force controls this process.”
Failure to obtain work plan approval before implementing site work described above is considered a violation of Alaska regulations & may result in field work not being approved or additional work being required & may subject responsible parties &/or contractors to a Notice of Violation (NOV).
Table 6-3 JBER-Elmendorf
General comments
Risk mitigation: In general, vadose zone soils shall not exceed maximum allowable levels for petroleum contamination for soil from 0 – 15’ bgs (i.e. direct contact for BTEX, PAHs & ingestion for DRO, GRO, RRO) regardless of HRC calculated 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 GW contamination.
In addition, sites with existing GW contamination above Table C cleanup levels will require that migration to GW cleanup levels be used for soil & ICs will be required. Once GW is below Table C for for a period of time (per the latest approved “Basewide Monitoring Program Well Sampling Frequency Decision Guide”), the maximum allowable levels may become the cleanup levels as determined by ADEC on a case by case basis.
7.1.2 Document Preparation & Version Control
Draft & Draft Final Versions of documents
For petroleum sites (aka Two Party sites) overseen by ADEC refer to the following:
ADEC will strive to complete plan reviews & respond to JBER within thirty (30) days after receipt of plans, although this is not always possible nor is it a requirement. At times, JBER requested expedited plan reviews are feasible based on project manager work load, adequate up-front planning, & contractors providing complete, well written plans.
However, if significant work plan revisions are required, additional review & comment resolution time will be needed. To facilitate successful project implementation, it is recommended that DoD project managers & contracting staff:
•Coordinate schedules with ADEC in advance & throughout projects.
•Include ADEC in project planning meetings (DQO meetings, UFP QAPP development meetings, Triad & other Technical Project Planning team meetings, etc.).
• Plan & maintain project schedules that include a minimum of forty-five (45) days for reviewing draft work plans, comment resolution, any necessary revisions to the draft-final version & a final review & approval.
• Review contractor planning documents prior to submission to ADEC to ensure compliance with state & federal regulations consistency with agreements made during project planning meetings.
Independent QA Oversight on Performance Based Contracts
The site cleanup rules require that “collection, interpretation, & reporting of data, & the required sampling & analysis is conducted or supervised by a qualified, impartial third party”. Depending upon the specific terms in a performance based contract, a contractor may no longer be considered an impartial third party with respect to collecting, interpreting & reporting data.
This should be taken into consideration when preparing scopes of work. ADEC strongly recommends the Air Force provide an on-site Quality Assurance Representative or a third party QA oversight contractor to monitor fieldwork for consistency with approved plans & contract requirements.
7.2.1 UFP-QAPP Requirements (Planning)
Any existing approved UFP-QAPPs will be updated to reflect current regulations & guidance that have been updated since they were approved.
Page 7-6
The text states: “Our Technical Site Managers & Project Chemists will ensure that, prior to sampling activities, full service analytical laboratories to be used are, at a minimum, DoD ELAP accredited & in good standing based on standard business information sources (e.g., Dunn & Bradstreet). In addition to DoD ELAP, the Project Chemist will also ensure that the supporting laboratories are approved for work in the State of Alaska, when required. Analytical methods used will be Alaska & EPA standard methods, unless technically impractical.”
ADEC disagrees. The full service analytical laboratories have to be both DoD-ELAP accredited & Alaska approved. Any non-EPA &/or Alaska methods must be approved by the department prior to sample collection.
|
Louis Howard |
| 2/7/2013 |
Update or Other Action |
Draft UFP-QAPP SC work plan received for ST61 Classic Owl Site.
The overall objectives for the site are to meet “unrestricted or residential site use” criteria & achieve a “cleanup complete without institutional controls (ICs)” determination. To meet these objectives soil & GW samples will be collected in order to characterize risk to human health & the environment within the framework of the ADEC site cleanup process 18 AAC 75.325 to 390 & 18 AAC 78.600.
If 18 AAC 75 Method 2 cleanup criteria are exceeded, the HRC approach under Method 3 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 remediation, ICs, or both may be required). If unacceptable risk is indicated by the HRC, then remedial options that address the compounds & exposure routes that contribute most significantly to the cumulative risk will be evaluated.
The DRO GW data from well AP-3576 has exceeded 18 AAC 75 Table C GW Cleanup criteria of 1.5 mg/L for 10 of the last 12 sampling events dating back to 1999. These data indicate that without remedial action, it is likely that the site would only qualify for a cleanup complete with an ICs determination. In order to assess risk & remedial options that would achieve a cleanup complete without ICs determination, it is necessary to collect data for entry into the hydrocarbon risk calculator & it is beneficial to relatively carefully delineate the extent of the source area.
Approximately 10 to 18 LIF probes will be used to help identify the horizontal & vertical extent of petroleum hydrocarbon contamination at the site. The LIF probes will be driven in a loose grid pattern with about a 20' to 30' spacing. Probes will be located in-source, upgradient, cross gradient & downgradient of the former UST location. The first probes will likely be placed next to AP-3566 & AP3567 (which are interpreted to be inside the source area) & then LIF probes will be stepped out until the edge of the source area is identified using the following logic:
1) Complete a boring within a known contaminant source area through the zone of seasonal GW fluctuation, or other established depth, & screen samples to verify contamination.
2) Complete the next boring approximately 20 feet hydrologically upgradient.
3) Screen samples. If contamination is present, complete the next boring an additional 10-20 feet up-gradient.
4) Repeat step 3 as necessary to define extent of contamination.
5) Repeat for hydrologically sidegradient & downgradient directions.
Soil boring locations will be selected based on the LIF results. A minimum of two soil borings will be drilled in the source zone & two or three smear zone samples & one vadose zone sample will be collected from each boring for laboratory analysis. Each of the soil borings will be drilled through the zone of seasonal water fluctuation, & soil samples will be collected from the smear zone & vadose zone that are representative of the highest percent relative emittance (% RE) LIF results.
If the vadose zone appears to be uncontaminated, then vadose zone samples will not be collected. In total, the soil sampling program targets the collection of a minimum of about six new source area soil samples for GRO, DRO, RRO, & BTEX analysis & a minimum of three source area soil samples for PAH, VPH, & EPH analysis. Samples collected for PAH, EPH, & VPH analysis will be from the most heavily impacted soil encountered in the borings (based on LIF, PID, visual & olfactory screening) & will be collected from intervals also analyzed for BTEX, GRO, DRO, & RRO.
If the two source area borings do not produce the target number of soil samples then an additional source area boring may be drilled. One boring will be drilled downgradient of the source area to confirm the LIF results. Continuous soil samples will be collected through the zone of seasonal water table fluctuation & screened using PID, visual & olfactory methods. If the screening indicates that the soil is not contaminated then one sample will be collected & analyzed for BTEX, GRO, DRO, & RRO. If the smear zone appears to be contaminated then another step out boring will be drilled.
GW samples will be collected from wells AP-3606, AP-3567 & 45WL-02. Monitoring well AP-3567 is located within the source area & will be analyzed for DRO, RRO, GRO, BTEX, PAH, EPH, & VPH. Wells AP-3606 & 45WL-02 are located outside the source area so samples will be analyzed for BTEX, GRO, DRO, & RRO. If NAPL is observed in AP-3606, then it will be sampled for DRO, RRO, GRO, BTEX, PAH, EPH, & VPH, & a NAPL sample will be collected & analyzed for BTEX, VPH & EPH.
Observations of odor, turbidity, & color will be recorded on the GW sample collection log. |
Louis Howard |
| 3/1/2013 |
Document, Report, or Work plan Review - other |
Staff provided review comments on the draft UFP-QAPP WP.
General Comments for JBER-E and JBER-R sites
ADEC requests JBER provide the following location information for each site
will be provided for in the Executive Summary text:
Please provide latitude and longitude coordinates for the site location in decimal degree format with a precision of six decimal places (dd.dddddd). Also include the following:
1. Date of collection,
2. Method of collection (i.e. GPS, hardcopy map, air photo),
3. Scale of the map used to acquire coordinates (if applicable),
4. Estimated accuracy and associated unit of measure,
5.Reference point for which the coordinates were established (i.e. center of property, entrance gate),
6.Horizontal datum (NAD 1983 is strongly preferred) and
7. Comments for additional information regarding acquistion of coordinates (if necessary).
This comment applies to all UPF-QAPP submittals for JBER CERCLA and non-CERCLA (e.g. POL) sites.
Executive Summary
ST061 (formerly Classic Owl) is listed as Hazard ID 2747. An additional site associated with Classic Owl is CS DB Hazard ID 1227. Building 52-140 was formerly used as a vehicle maintenance shop and was built in 1943 Building 52-140’s floor drains discharged to a dry well and received waste from an oil-change pit and car wash. A dry well at this source was originally investigated as part of the Operable Unit (OU) 4 Limited Field Investigation (LFI). Discovery of a previously unknown clay pipe during construction activities in 1991 necessitated the further investigation of the clay pipe at Source SS63 under the OU 7 LFI program.
2nd Paragraph
The text states: If 18 AAC 75 Method 2 cleanup criteria are exceeded, the Hydrocarbon Risk Calculator (HRC) approach under Method 3 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 remediation, ICs, or both may be required).”
Please note that a cleanup complete without ICs will not be granted by ADEC to sites with vadose zone soils that exceed maximum allowable levels for petroleum contamination for soil from 0 – 15’ bgs (i.e. direct contact for BTEX, PAHs and/or ingestion for DRO, GRO, and 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.
Institutional controls or Land Use Controls shall be applied when (per July 27, 2012 meeting minutes on the “Use of Hydrocarbon Risk Calculator” with ADEC, JBER, PBR contractors):
• The groundwater under or downgradient of a site was contaminated with POL constituents at concentrations exceeding risk criteria or MCLs; or
• POL contaminants in the soil were above the maximum allowable contaminant concentration given in Table B2 of 18 AAC 75 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 unlimited use/unrestricted exposure (UU/UE) for ADEC to grant a cleanup complete without ICs determination.
• 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.
Vadose zone soils shall not exceed maximum allowable levels 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.
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 annual groundwater monitoring), the maximum allowable levels may become the cleanup levels as determined by ADEC on a case by case basis.
For sites with groundwater contamination above Table C Groundwater Cleanup Levels, During the final round of monitoring, samples will be collected and analyzed for all constituents that exceed MCLs/Table C cleanup levels from previous investigations of ST061 aka “Classic Owl”. These results will be evaluated before a final determination is made that groundwater meets all cleanup requirements.
|
Louis Howard |
| 4/30/2013 |
Update or Other Action |
Draft Annual Monitoring Report received for review and comment.
Historic sampling results for ST061 have indicated fuel constituents present in groundwater above cleanup criteria in 18 AAC 75 Table C and fuel constituents in vadose and smear zone soil above 18 AAC 75 Tables B1 and B2. A bioventing system was operated at ST061 from 1993 to 2007. Data collected during 2000 and 2004 site investigations showed that the bioventing system had successfully remediated the vadose zone and that most of the remaining soil contamination was confined to the water table and smear zone. The bioventing system was shut down in December 2007 and decommissioned in 2009. Current monitoring requirements at ST061 include groundwater sampling for DRO at groundwater monitoring wells 45WL-02 (every 2 years), AP-3567 (every 2 years), and AP-3606 (every 4 or 5 years).
In 2012, monitoring well AP-3567 was sampled for EPH only for future use in calculating risk at the site using the HRC.
Additional investigation in order to define the vertical and horizontal extent of soil contamination will be conducted under the new PBR contract. No changes to the annual monitoring are being proposed for this site. |
Louis Howard |
| 6/13/2013 |
Document, Report, or Work plan Review - other |
ADEC has received the final version of the ST061 UFP-QAPP SC Work Plan on June 10, 2013. ADEC has reviewed the final document and has no further comments on it. The document is approved. |
Louis Howard |
| 3/13/2014 |
Update or Other Action |
Draft 2013 Annual report received for review and comment. The overall project objectives included collecting sufficient data to:
• Monitor concentrations of contaminants of concern (COCs) at each site with sufficient precision and accuracy to evaluate their concentrations with respect to cleanup goals.
• Identify potentially toxic and/or mobile transformation products.
• Verify individual plume characteristics, such as downgradient, lateral, or vertical expansion or retraction.
• Evaluate groundwater flow directions and hydraulic gradients to monitor plume migration and assess contaminant sources.
• Evaluate the effectiveness of land use controls/ institutional controls (LUCs/ICs) to protect human health and the environment.
• Identify and repair damaged monitoring wells to protect groundwater.
• Identify monitoring wells that are no longer needed or are damaged beyond repair.
Historic sampling results for ST061 have indicated fuel constituents present in groundwater
above cleanup criteria in 18 AAC 75 Table C and fuel constituents in vadose and smear zone soil
above 18 AAC 75 Tables B1 and B2. A bioventing system was operated at ST061 from 1993 to
2007. Data collected during 2000 and 2004 site investigations showed that the bioventing system
had successfully remediated the vadose zone and that most of the remaining soil contamination
was confined to the water table and smear zone. The bioventing system was shut down in
December 2007 and decommissioned in 2009. Current monitoring requirements at ST061
include groundwater sampling for DRO at groundwater monitoring wells 45WL-02 (every 2
years), AP-3567 (every 2 years), and AP-3606 (every 4-5 years).
During 2013, monitoring wells 45WL-02, AP-3567, and AP-3606 were sampled for DRO. All DRO results were below 18 AAC 75.345 Table C cleanup criteria.
The ADEC site status for ST061 is “Open.” A bioventing system was operated at ST061 from
1993 to 2007. Data collected during 2000 and 2004 site investigations showed that the
bioventing system had successfully remediated the vadose zone and that most of the remaining
soil contamination was confined to the water table and smear zone. DRO is the only groundwater
COC remaining at this site. DRO concentrations were not above 18 AAC 75 Table C cleanup
criteria in the three site wells sampled in 2013.
Additional investigation to characterize the current nature and extent of soil and groundwater
contamination at ST061 was also performed during 2013 under the JBER PBR contract. A site
characterization report has been prepared under separate cover. Recommendations for the site,
including any changes to the sampling program are provided in the site characterization report. |
Louis Howard |
| 6/13/2014 |
Update or Other Action |
Draft SC report received for review and comment.
Conclusions
The data set for ST061 supports the following conclusions:
• The existing data show that diesel fuel releases have resulted in vadose zone contamination over an area approximately 45 feet long by 30 feet wide.
• The fuel is interpreted to have infiltrated the water table over the vadose zone source area. The NAPL is interpreted to have spread laterally on the water table to a width of approximately 85 feet and migrated approximately 160 feet downgradient. The NAPL has been smeared through the zone of seasonal water table fluctuation over this footprint area.
• The average and 95% UCL DRO concentrations within the NAPL source area are approximately 2,345 and 3,189 mg/kg, respectively.
• Groundwater samples collected from a monitoring well (AP-3567) located in the NAPL-contaminated soil source area and screened across the water table was below 18 AAC 75 Table C cleanup levels during the 2013 sampling event; DRO concentrations in the plume have been variable since monitoring began in 1995. The DRO aliphatics and aromatics meet risk criteria.
• The groundwater data meet 18 AAC 70 TAqH and TAH criteria, which subsequently indicate that the site groundwater cannot cause exceedances of the surface water quality criteria.
• The carcinogenic cumulative risk and non-carcinogenic cumulative risk posed by the individual indicator compounds meet the ADEC risk standard, assuming a residential land use scenario.
• The risk posed by the GRO, DRO, and RRO aromatic and aliphatic surrogate fractions meets the risk standard for each exposure pathway, assuming a residential land use scenario.
• Existing site conditions meet risk-based migration to groundwater criteria.
• The Ecoscoping Form completed for the site does not indicate that more in-depth assessment is necessary. The site meets ADEC qualitative ecological/environmental risk criteria in that there were no observed environmental impacts from soil staining, impacted vegetation, surface water or sediment runoff.
Recommendations
Based on the HRC calculations and compliance with environmental criteria, it is recommended that the ADEC grant Site ST061 at JBER a “Cleanup Complete” determination. Institutional Controls do not appear to be applicable at this site. Following ADEC concurrence with this conclusion, groundwater monitoring of the site should be terminated and the existing monitoring wells at the site should be decommissioned.
|
Louis Howard |
| 6/26/2014 |
Cleanup Complete Determination Issued |
Cleanup complete determination made.
ST061 is the former location of a 1,000-gallon heating oil underground storage tank (UST) that was located east of a former vehicle maintenance facility (Building 52-140). The vehicle maintenance facility was demolished, and the UST and associated piping were decommissioned in 1992. During the removal of the former UST, it was noted that the tank was in poor condition, with corrosion along the bottom. The existing Building 21309 was constructed on the site in 1992.
Contaminants of Concern
Diesel Range Organics (DRO)
Gasoline Range Organics (GRO)
The cleanup level for soils at ST061 containing DRO contamination is 10,250 mg/kg in the Under 40-inch Zone based on the ingestion pathway within the 0 to 15’ interval below ground surface (bgs).
The cleanup level for soils at ST061 containing GRO concentrations is 1,400 mg/kg in the Under 40-inch Zone based on the ingestion pathway within the 0 to 15’ interval below ground surface.
Modeling using the Hydrocarbon Risk Calculator, in accordance with Method 3 under 18 AAC 75.340, demonstrated that residual petroleum contaminants in soil do not pose a migration to groundwater risk/concern.
In 2012 and 2013, additional site characterization work was conducted. The average and 95% UCL DRO concentrations within the NAPL source area are approximately 2,345 and 3,189 mg/kg, respectively. The average and 95% UCL GRO concentrations were determined to be 202.3 and 1,468 mg/kg, based on inclusion of the maximum 1993 result of 1,800 mg/kg GRO in a sample collected 10’ below ground surface.
Although the maximum measured GRO concentration in 1993, and the recently calculated 95% UCL on the mean GRO concentration, exceed the maximum allowable concentration listed in Table B-2 (1,400 mg/kg GRO), ADEC agrees that intrinsic remediation has likely occurred over the past 21 years. This is supported by the facts data from soil borings located in close proximity to the locations of the highest GRO result in 1993 have been non-detect or very low concentrations for GRO and there have not been any groundwater exceedances for GRO at ST061
Groundwater levels are interpreted to vary seasonally between approximately 13 to 18 feet below ground surface (bgs). Groundwater from ST061 is interpreted to flow towards Knik Arm, which is approximately one mile to the northwest
The estimated rounded cumulative cancer risk at ST061 for the current industrial and hypothetical residential exposure scenarios, across all exposure pathways, (4 x 10-7 and 1 x 10-6 respectively) is below the regulatory risk standard of 1 x 10-5 for petroleum hydrocarbons.
The estimated cumulative noncancer HI at ST061 for the current industrial and hypothetical residential exposure scenarios, across all exposure pathways, (0.0 and 0.01 respectively) is below the regulatory risk standard of 1. ST061 meets the ADEC risk criteria [18 AAC 75.325(g)] for petroleum hydrocarbons. The risk posed by the DRO aromatic and aliphatic surrogate fractions meets the risk standard for each exposure pathway, assuming a residential land use scenario.
Based on a review of the environmental records, ADEC has determined that ST061 has been adequately characterized and has achieved the applicable requirements under the site cleanup rules. ADEC is issuing this written determination that cleanup is complete, subject to a future department determination that the cleanup is not protective of human health, safety, welfare, or of the environment [18 AAC 75.380(d)]. A “cleanup complete” designation will be entered for ST061 in the Contaminated Sites Database. |
Louis Howard |
| 6/26/2014 |
Institutional Control Record Removed |
Institutional Controls have been removed. |
Louis Howard |
| 8/19/2014 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 73723 name: Underground tank |
Louis Howard |
