| Action Date |
Action |
Description |
DEC Staff |
| 8/1/1983 |
Update or Other Action |
On August 1, 1983, EPA issued a RCRA Permit to Elmendorf Air Force Base to operate a hazardous waste container storage facility in building 22-009. The permit for this storage facility is effective until August 1, 1993, and requires the Facility to comply with all its terms and
conditions. |
Jennifer Roberts |
| 10/1/1984 |
Update or Other Action |
Site ST75 is located at Building 22-009, which is to the west of Maple Street on the southern portion of Elmendorf AFB. Building 22-009 was built in 1944 and is currently in use as a hazardous waste storage facility. A 2,600-gallon heating oil UST (tank 229) was located immediately adjacent to the south wall of Building 22-009.
Tank 229 was oriented to the east and west, with supply and return lines coming from both ends of the tank. The west end of the tank was within 3 feet of Building 22-009. Based on the excessive quantity of fuel drawn by Building 22-009, the UST was believed to be leaking and was removed from service sometime in the 1983-1984 time period. |
John Halverson |
| 8/1/1988 |
Update or Other Action |
Elmendorf Air Force Base (EAFB) ID NUMBER AK8570028649 RCRA FACILITY ASSESSMENT (RFA)
I. INTRODUCTION
The primary objective of the RCRA corrective action program is to clean up releases of hazardous waste or hazardous constituents that threaten human health or the environment. This program applies to all operating, closed or closing RCRA facilities. EAFB has applied for a permit to continue to operate a hazardous waste storage unit at their facility. Section 3004(u) of the Resource Conservation and Recovery Act (RCRA) requires that permits issued to RCRA facilities address past and continuing releases of hazardous waste or constituents from all solid waste management units (SWMU's) at the facility. The RFA is conducted to identify releases or potential releases requiring further investigation, by evaluating SWMU's and other areas of concern, for releases to all media, prior to permitting.
The RFA consists of a preliminary review (PR) and a visual site inspection (VSI). The PR focuses on evaluating existing information to determine the presence of the solid waste management units (SWMU's) at EAFB. Both Environmental Protection Agency (EPA) and Alaska Department of Environmental Conservation (DEC) facility files were reviewed. Such facility files included Part A and Part B applications, hazardous waste notifications, hazardous waste manifests, inspection reports prepared by EPA and/or DEC, in addition to all correspondence with EAFB.
Documents were also submitted by EAFB which detailed facility background and various SWMU's on-site; this information has been used throughout the RFA report for the identification of SWMU's and for research of past waste management practices at the facility.
S-4, Hazardous Waste Storage Area
a. Location: Building 22-009, see photographs #1-#7 of Attachment 2.
b. Operation: This is the present hazardous waste storage area, permitted on August 1, 1983.
c. Contamination Potential: No releases have been reported from this site. Any releases which occur from any specific drum inside the storage building must be cleaned up, pursuant to the present storage permit.
d. Recommended Action: No action is presently warranted for this unit, any required action will be addressed in the closure plan. |
Louis Howard |
| 2/24/1989 |
Update or Other Action |
Telephone Memorandum for the file by Black & Veatch Project: 13833 at 10:15 a.m. with Jim Hayden ADEC. Call to Jim to find out if he could recommend any soil cleanup levels. He said that the "most likely set of standards or guidelines to be used were the California Leaking Underground Fuel Tank (LUFT) manual tables. He also said that a meeting would be held in about three (3) weeks to go over the proposed cleanup levels for the State. Black & Veatch asked if his office would be overseeing operations at Elmendorf and he replied "that they most likely would." |
Jim Hayden |
| 10/3/1989 |
Update or Other Action |
USAF Letter received from Patrick M. Coullahan, Lt. Col, Commander to ADEC Subj: Requirements for Temporary Storage of Petroleum Contaminated Soil.
1. The USAF has several sites which are contaminated with petroleum products (POL) and require remedial action. Temporary storage and stockpile of contaminated soil is needed while remedial action is performed.
2. Request guidance from your office on regulatory requirements and ADEC policy for storage and stockpiling POL contaminated soil. Point of contact for the 5099th Civil Engineering Operations Squadron is Capt Gerken or Mr Cords at 552-4854. |
Bill Lamoreaux |
| 10/20/1989 |
Document, Report, or Work plan Review - other |
ADEC Ron Klein, Supervisor, Contaminated Site Investigations, sent letter to Captain Brad Gerken, Dept. of Air Force, 5099th Civil Engineering Operations Squadron (AAC) Subject: Response to September 27, 1989 Letter; Requirements for Temporary Storage of Petroleum Contaminated Soil. Enclosed is a copy of the Southcentral Region Office's interim policy for storage and disposal of waste oil contaminated soil.
The guidance also applies to storage of soils contaminated with clean fuels if they are to be stored off the site where they were generated or stored on-site longer than thirty (30) days. The
guidance document will be revised shortly to make that explicit. Petroleum contaminated soils generated on-site and stockpiled onsite for less than thirty (30) days must be placed on a bermed
liner and covered. The liner and cover must be at least 6 mil reinforced polyethylene.
Alaska Department of Environmetal Conservation Southcentral Region Office - Interim Policy For Storage and Disposal of Waste Oil Contaminated Soil
The Southcentral Regional Office solid waste program has been working on an interim policy for storage and disposal of waste oil contaminated soil. Currently the Region has approved the removal
of waste oil contaminated soil to a facility permitted to properly handle the contamination. With the exception of the Municipality of Anchorage (MOA) Landfill and Alaska Pollution Control Palmer
Facility (pre-treatment for landfill disposal) all of these facilities are located in the contiguous United States.
Currently, if the waste oil contaminated soil does not meet MOA Landfill criteria the only disposal option is to send the contaminated soil out of Alaska. Soil disposal under this method is costly due to handling, shipping, and facility fees. In discussions with Responsible Parties (RP) there appears to be a strong move to develop other local disposal methods that would meet with agency approval. Therefore the Regional solid waste program has developed interim storage guidelines for waste oil contaminated soils.
These guidelines include the following:
1. An approved design for a low-maintenance or maintenance free storage liner and cover that will be able to withstand winter conditions and is petroleum resistant. This will include a schedule to monitor the storage facility to verify that the integrity of the liner and cover is maintained through out the storage period.
2. Obtain a solid waste storage plan approval for onsite storage of waste oil contaminated soil from ADEC prior to storage construction.
3. The Responsible Party may propose to remove the waste oil contaminated soil to an off-site storage location if long term on-site storage is not practical. This location must be approved of by the Department prior to any transfer of the soils. The storage site must meet, ADEC design criteria and the RP must obtain an off-site; solid waste storage plan approval prior to transfer of the soil. All transfer of soil off-site must be done under a Bill of Lading and copies provided to ADEC.
4. The maximum allowable storage time is one (1) year. |
Ron Klein |
| 11/2/1989 |
Document, Report, or Work plan Review - other |
ADEC AWDO Ron Klein, Supervisor, Contaminated Site Investigations, sent USAF Colonel Everett L. Mabry, HQ 21st Combat Support Group (AAC) letter RE: Elmendorf Air Force Base Petroleum Contaminated Soil. Thank you for your 17 October, 1989 response to my September 1989 letter. The following are answers to the questions detailed in your letter:
1. What State of Alaska regulations cover the treatment of soil contaminated with petroleum product?
The State has no detailed regulations on petroleum contaminated soil treatment. According to the oil pollution regulations (18 AAC 75.140, Cleanup), Immediately upon becoming aware of a discharge of a hazardous substance to the water or land of the state, persons responsible for that discharge shall clean up and dispose of the material collected using methods for which prior approval, oral or written, has been given by the regional supervisor or his designee.
Under this section the Department reviews soil treatment plans to insure that the treatment method proposed is effective and will not result in the contamination of other sites.
Petroleum contaminated soil is also classified a solid waste under State solid waste management regulations. See 18 AAC 60.910 (53) for the definition of solid waste. According to the solid waste regulations a permit is required for solid waste facilities. The solid waste regulations also provide guidance in 18 AAC 60.075 for landspreading operations.
Depending upon the petroleum contaminated soil treatment method selected other regulations may apply such as our Air Quality Control (18 AAC 50) and Wastewater Disposal (18 AAC 72)
regulations.
2. What are the State of Alaska cleanup standards for soil contaminated with petroleum products?
According to 18 AAC 75.130 (Disposal of Hazardous Substances) prior approval by the Department is required for the ultimate disposal of a hazardous substance, and soil, cleanup materials, or other substances contaminated with a hazardous substance. Chapter 75 classifies oil as a hazardous substance (see 18 AAC 75.900 (05)).
Ultimate cleanup levels depend upon what the proposed disposal alternative is. At a minimum soil needs to be cleaned up to a level which will not pose a risk to the lands and waters of the disposal site. The beneficial use of petroleum contaminated soils is encouraged. For example, processing petroleum contaminated soil through a hot mix asphalt plant for use as non-spec asphalt base. |
Ron Klein |
| 8/6/1991 |
Enforcement Agreement or Order |
USEPA sent EAFB a Federal Facility Compliance Agreement pursuant to RCRA and Executive Order 12088. On September 20-22, 1989 ("1989 inspection") and August 14-15, 1990 ("1990 inspection"), representatives of EPA and DEC conducted inspections at the Facility.
Building #22-009 - Permitted Hazardous Waste Storage Facility
The 1990 inspection revealed that manifests received from off-site did not include notification of the appropriate treatment standard for the waste as set forth in 40 C.F.R. Part 268 Subpart D as required by 40 C.F.R. § 268.7(a) (2) (i) (B). The 1989 inspection revealed many manifests without required notifications of restricted waste. These omissions are violations of 40 C.F.R. §§ 264.73(b)(15) and 270.4 which require storage facilities to maintain copies of notices provided by generators in accordance with 40 C.F.R. §§ 268.7 or 268.8.
The 1990 inspection revealed less than eight (8) feet of aisle space in the center corridor of the building, and inadequate aisle space, for the purposes of conducting an inspection, around the following pallets of drums:
1) Yellow overpack drums labeled "Hazardous Waste" in the outside covered storage yard;
2) Drums labeled "Hazardous Waste" stored on aluminum aircraft cargo pallets in the storage yard west of the building; 3) Containers labeled "Hazardous Waste" in the storage yard north of the building.
These conditions are violations or Permit Condition B.7.(d) which requires the Facility to maintain a minimum of twelve (12) feet of aisle space in the center aisles, and two feet of aisle space between each row of palletized containers.
The 1990 inspection revealed that containers received from off-site were stored in the following areas:
1) Yellow overpack drums labeled "Hazardous Waste" were stored in the outside covered storage yard ;
2) Drums labeled "Hazardous Waste" were stored on aluminum aircraft cargo pallets in the storage yard west of the building;
3) Containers labeled "Hazardous Waste" were stored in the storage yard north of the building. These storage practices are in violation of Permit Condition C.1., which prohibits hazardous waste storage outside Building 22-009, and of Sections 3005 and 3010 of RCRA, 42 U.S.C. §§ 6925, 6930, which require facilities to obtain permits for hazardous waste storage.
The 1989 inspection revealed that the Facility waste analysis plan had not been updated to include analysis of restricted waste generated at the Facility. This failing is a violation of 40 C.F.R. S 268.7 which requires generators to test their waste to determine whether it is restricted from land disposal, and to notify the treatment or storage facility in writing of the appropriate treatment standards set forth in 49 C.F.R. Part 268, Subpart D. |
Jennifer Roberts |
| 3/26/1993 |
Update or Other Action |
Department of Defense and ADEC joint Technical Memorandum of understanding signed concerning the Basewide Groundwater. Signatories: ADEC SCRO-Jennifer Roberts Remedial Project Manager and USAF Joseph Williamson Chief Environmental Programs and Restoration.
As a result of the basewide groundwater study and the FY92 field work that occurred at Operable Units (OUs) 1, 2, and 5 it appears that a large portion of the groundwater flows into OU5 (attachment 1-contour map). based on this information Elmendorf would like to move all upgradient groundwater into the OU5 Feasibility Study, Proposed Plan and Record of Decision. This means we would address all groundwater from upgradient sources (CERCLA (ST20, OU3, and OU4) and OUs 1 and portions of OU2) and SERA) at OU5 instead of at each individual source area (see attachment 2-Area Map). Those sites which have 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 still be addressed at the source areas. NOTE: addressed at the source areas is interpreted by ADEC as removal through excavation or active treatment systems (e.g. high vacuum extraction, bioventing, etc...). |
Jennifer Roberts |
| 6/30/1993 |
Update or Other Action |
In June 1993, Tank 229 was excavated and removed. All lines were removed from the ground and capped where they entered the building. At the time of the closure, the tank contained approximately 1,700 gallons of fuel, which was pumped into 55-gallon drums. Soil from grade to the tank bottom, a depth of 9 feet, was a homogeneous mixture of fines and gravel. Depth to the shallow aquifer from the tank bottom was calculated to be approximately 29 feet. The groundwater gradient, based on basewide information, is to the south in the area of this site
No obvious soil staining or hydrocarbon odors were present at the time of UST removal. Three soil samples were collected and analyzed for hydrocarbon contamination. One sample taken 3 feet from the west end of the excavation, under the tank, indicated 5,900 mg/Kg for total petroleum hydrocarbon (TPH) as diesel. The sample 3 feet from the east of the tank was non-detect for TPH as diesel.
A sample from the spoils pile showed 100 mg/Kg TPH as diesel. A sample collected midway along the south side of the base of the tank was field tested using a photoionization detector (PID) to measure ambient head space. The field test indicated hydrocarbon contamination of 3,000 ppm. All excavated soil was placed back in the excavation hole, and approximately 100 tons of clean soil was brought in to bring the excavation back up to grade. |
John Halverson |
| 1/20/1994 |
Enforcement Agreement or Order |
Janice Adair Regional Administrator Southcentral Regional Office signs the November 29, 1993 Underground Storage Tank Agreement. The Parties enter this Agreement to perform necessary inventory, registration, upgrading or closure, and tightness testing associated with USTs at Elmendorf. All draft final work plans for field work must be submitted to ADEC a minimum of 30 days prior to the start of field work or construction.
Site Assessment draft reports for closures must be submitted to ADEC within 60 days after completion of field work. All reports of confirmed leaking USTs, or the need for further investigation, will be forwarded to 3 SPTG/CEVR (or its) successor organization) for possible inclusion into the SERA*. Initial abatement activities required under 18 AAC 78.230 will be conducted by the Air Force prior to transfer of any site to the SERA.
*SERA=Environmental Restoration Agreement between ADEC and the Air Force dated October 1992.
Discovered USTs-All USTs discovered during the life of this Agreement will be addressed under this Agreement and will be added to Attachment A. The Air Force will notify ADEC by next day mail of any discoverv within five days of the discovery of an UST, unless release notification is required under 18 AAC 78 220, in which case those provisions will control.
Installation: Any new USTs installed by the Air Force shall be installed in accordance with 40 CFR 280 and 18 AAC 78.022 through 18 AAC 78.090 and will have leak detection, corrosion protectlon, overfill protectIon, and spill protection. The Air Force will notify ADEC at least 30 days prior to initiating installation of an UST. UST installation work will be conducted by a certified UST worker as required by 18 AAC 78.030 and 18 AAC 78.400.
Release Detection: The Air Force shall install and perform release detection in accordance with the schedules outlined in Attachment A. If release detection is not installed or the tank not previously permanently closed by the date in Attachment A, the Air Force will close the tank in accordance with the closure requirements in 18 AAC 78. All tightness testing performed to satisfy these requirements will be conducted bv a certified UST worker as required bv 18 AAC 78.030 and 78.400
Operation and Maintenance of Corrosion Protection: The Air Force shall meet the requirements of 18 AAC 78.045 and 40 CFR 280.31 for any steel USTs, that have corrosion protection systems The testing of the corrosion protection systems shall be done by a certified UST worker as required by 18 AAC 78.400.
Site Assessment or System Tig:htness Test: The Air Force shall either conduct a system tightness test on all regulated USTs located at the Base or permanently close the USTs in accordance with Attachment A. If site assessments or system tests have been conducted, the Air Force shall submit proof of compliance by the deadlines set in Attachment A. All tightness testing work will be conducted by a certified UST worker as required by 18 AAC 78.400.
Release Investigation and Corrective Action: Release investigations, interim corrective action and corrective action on petroleum contamination identified in work conducted pursuant to this Agreement is not within the scope of this Agreement. These activities will be conducted pursuant to the Environmental Restoration Agreement between ADEC and the Air Force dated October 1992. |
Janice Adair |
| 3/2/1994 |
Underground Storage Tank Site Characterization or Assessment |
UST Site Assessment for SOA UST Register Number 229 near building 22-009. This is a report of the excavation, sampling and analysis associated with the closure by removal of a 2,600 gallon underground storage tank. Tank 229 was an unregulated heating oil UST. According to Base Fuels Management personnel, it had been out of service for approximately ten years (1983-1993). At the time of closure the tank contained approximately 1,700 gallons of fuel. As part of the closure process, thirty-one 55 gaUon barrels of fuel were pumped out of the tank. This fuel was tested and was found to be clean with no visible discoloration or sediment content. This fuel was used by Base Fuels personnel. AU subsurface tank fuel lines were removed. The lines were capped at the point where they extended into building 22-009 Excavation began on June 24th, 1993 and the tank was removed on July 14th, 1993.
Soil sampling and testing were done in accordance with ADEC approved Quality Assurance
Program Plan (QAPP) prepared by EA Remediation Technologies, Inc. Site history available
indicated only the storage and dispensal of diesel fuel. Therefore, laboratory analysis only
included screening for diesel and related hydrocarbon contaminants. Field tests indicated a
very low level of hydrocarbon contamination.
As per the agreement between ADEC and the U. S. Air Force, no attempt was made to cleanup contaminated soil in the vicinity of this tank. Additional investigative measures should be taken at this site to determine whether the shallow aquifer water shows any contamination in the vicinity of this site. Installation of monitoring wells are recommended to this end. According to ADEC's matrix score sheet for clean-ups, level B is the indicated priority (ref. appendix E).
Field sample # F-4 midway along south side, base of tank 3,000 ppm. Sample XXX-2 RP22-009 3' from west end of excavation under tank DRO at 5,900 mg/kg (lab file ID# 012R0101.D Project 11206.47 EA Laboratories Sparks MD.). |
John Halverson |
| 8/31/1994 |
Update or Other Action |
Another potential pathway for fuel to reach the subsurface in the vicinity of Tank 229 is from a used oil UST located approximately 100 feet to the east. In the summer of 1994, the UST was removed and replaced with an oil/water separator and associated waste oil UST. In August 1994, a 300-gallon spill occurred from a fill pipe on the newly installed waste oil UST. Most of the spill appeared to be under Building 22-009, as the damaged pipe causing the leak was within the building foundation. |
John Halverson |
| 11/18/1994 |
Enforcement Action |
Notice of Violation (NOV) letter sent to Lieutenant General Lawrence E. Boese for findings from the July 6-8, 1994 RCRA compliance evaluation. Violations covered: Drum marked with DAW September 93 and DM0728 labeled waste environmentally hazardous substance D003. Accumulation start date on drum was dated 7/1/1992. The Base is not permitted to store D003 reactive hazardous waste anywhere in 22-009 and it is not compatible with the hazardous waste stored in the West Area of 002 of Building 22-009. Lead painted doors were not stored properly (containerized) but instead were strapped to pallets. |
Janice Adair |
| 12/29/1994 |
Enforcement Agreement or Order |
NOV/Compliance advisory letter sent to Air Force regarding improperly permanently closed USTs without submitting proper registration and post closure notices.
Paragraph 22 of the Agreement states that the AF will complete registration of all known USTs in accordance with the schedule outlined in Attachment A and shall thereafter maintain and update those records as required by 18 AAC 78 and 40 CFR 280. Attachment A states, "Elmendorf shall comply with the registration requirements of 18 AAC 78 for all USTs installed subsequent to the signing of this agreement." The Agreement was signed on January 20, 1994. The UST regulations, 18 AAC 78.01 5 - Registration and Fees, require a person who intends to install an UST, register it at least 30 days before installation. The department has interpreted and implemented this by allowing submittal of registration forms for up to thirty (30) days after installation. However, it has come to our attention that the Air Force has not registered several USTs installed at Elmendorf during the summer of 1994. This is a violation of the Agreement and the state and federal regulations.
According to EA Engineering Science and Technology, several UST systems replaced at Elmendorf this summer were connected to oil water separators located below grade inside buildings. Reportedly, EA and the AF agreed that responsibility for installation of new UST systems ends at the point where the existing piping goes through or under a building. Based on these statements, it appears the alleged violations noted above are not limited to building 22-009. This is a significant issue that must be addressed by the AF. Through the NOV referenced above, the department requests the AF provide additional information documenting how USTs associated with oil water separator systems were replaced at Elmendorf AFB.
Site Assessment Reports Paragraph nine of the Agreement states draft site assessment reports for UST closures must be submitted to the department within 60 days after completion of field work. Paragraph 45 states the Parties to the Agreement shall provide quality assured results of sampling within sixty (60) days of submittal of data (samples) to the laboratory. Closure of regulated USTs at Elmendorf this summer started in April and continued through November. As of December 19, no site assessment reports (draft or final) had been submitted for the closures. No extension of submittal dates has been requested or approved. This is a violation of the existing Agreement and 18 AAC 78.100(e), which require submittal of a site assessment report within sixty (60) and thirty (30) days after closure of an UST, respectively. The Agreement was written to provide some flexibility to the AF to work with in its contracting mechanism, however, failure to comply with the Agreement also constitutes a failure to comply with the more stringent regulation.
One of the intentions behind the requirement to submit reports in a timely manner was to ensure that any problems with the field work or reporting were identified and resolved early in the process. This would prevent problems from being carried through an entire field season. Failure to identify and resolve problems with work done under a contract early in the process results in a much larger cost in terms of time, work effort and money for all parties involved. As we discussed, the AF will provide copies of all the draft site assessment reports it has received for work conducted during 1994 along with any AF comments on them.
Release Detection Paragraph 26 of the Agreement states the AF shall install and perform release detection on each UST in accordance with the schedules outlined in Attachment A. Attachment A
states all USTs shall meet the release detection requirements by December 31, 1994 or the USTs shall be closed out, either temporarily or permanently, in accordance with 18 AAC 78.080-18 AAC 78.090.
See site file for additional information. |
John Halverson |
| 1/5/1995 |
Update or Other Action |
ADEC letter to Dept. Of Air Force (J. Williamson and C. Mayer) from J. Halverson RE: SERA Phase III Site Assessment Work Plans, Preliminary Draft Dec. 1994. Field Screening: The plan contains little information on field screening. Section 2 contains subsections for each site with informaiton on soil borings and sampling. It refers to section 3.3.5 for sampling procedures. Section 3.3.5.2 refers back to section 2 for selection of samples for laboratory analysis.
The process and rationale for selecting samples for laboratory analysis is not clear. The proposed sample summaries for each site indicate a predetermined number of soil samples will be collected and analyzed at a laboratory, for example table 2.1-1 shows seven borings will be installed at ST75 and seventy soil samples will be collected and analyzed for DRO, BTEX, TOC, moisture and bulk density. This appears to be excessive. The department recommends conducting a significant amount of field screening to guide field work. Samples for lab analysis should be selected based on field screening and field observations. In many cases, samples from shallow depths in soil borings will NOT need to be analyzed at a laboratory, because they may be from imported clean backfill material used to fill in a tank void, or from areas where horizontal contaminant migration through soilis not likely.
Section 1.6: The site visit at ST75 showed the former UST is located within one-hundred feet of a recent release at the same building. Since both releases occurred at the same building and are close together, if at all possible, the assessment should be expanded to evaluate contamination around the building rather than just one tank.
Section 2.1.2: The last paragraph refers to a sample from the UST closure site assessment which contained 5,900 mg/kg DRO and another sample which contained non-detectable concentrations of DRO. The text infers only one sample from soil remaining at the site contained contaminant concentrations above the cleanup levels. However, another sample collected at the base of the excavation on the south side of the tank contained 3,000 mg/kg DRO.
Figure 2.1-2-The figure shows a proposed soil boring and monitoring well (MW) locations. The rationale for placing 3 MW in a line perpendicular to the former tank location is not clear. The department recommends converting one soil boring immediately downgradient of the former tank into a MW. Based on analytical results of the samples from on eMW upgradient and one immediately downgradient of the former tank, a decision could be made on the need for additional MWs.
The site assesment map showed supply and return lines from the former tank. A two inch line extended beyond the edge of the diagram. It is not clear how far the line extended, but it appears it may have been connected to the southeast wing of the building. The assessment should include evaluation of any releases from the lines. Additional investigation into the configuration of the former system may be necessary and a boring should be placed near the point where the piping went into the building. |
John Halverson |
| 1/19/1995 |
Update or Other Action |
Janice Adair Regional administrator sends a letter to the Air Force regarding the two NOVs for violations under RCRA. 1/14/94 and 11/18/94 NOVs issued under RCRA for violations observed by hazardous waste inspection. ADEC has reviewed responses (2/11/94 and 5/24/94 and 12/19/94) from the Air Force on these NOVs and finds them adequate in addressing all the violations stated in the subject NOVs. Therefore, ADEC considers the subject NOVs "closed."
However, ADEC has a comment on the management of unknown waste which is later found to be hazardous waste and that waste is not managed properly between the time it is "generated" and when it was characterized. ADEC suggests the Air Force further address the "unknown" waste issue by either expanding their present plan or re-notify your current policy to all affected individuals within the TSDfs, BEE, managers of accumulation points, etc. to ensure such violations do not recur. |
Janice Adair |
| 3/1/1995 |
Update or Other Action |
Air Force requests NOV be closed out for the tank at Building 22-009. They have made arrangements to have the tank piping tightness tested and corrosion protected. If adequate corrosion protection can not be designed, the existing piping will be removed and replaced with a non-corrosive alternative. They have included a project for site assessment and remediation of this UST spill in their programmed SERA Phase III management plan. The Phase III work also included a remediation project for cleanup of a fuel UST situated next to Building 22-009. |
John Halverson |
| 3/15/1995 |
Update or Other Action |
ADEC (J. Halverson) sent the Dept. Of Air Force (J. Williamson & C. Mayer 3 SUG/CEVR) a letter RE: SERA Phase III Site Assessment Work Plans, Draft February 1995. Section 2.1.4-The last paragraph states: "It is expected that the 300 gallon spill will be included as part of this investigation." However, no details are provided on how this will be done. The location of the recent release should be identified on the site diagram along with proposed soil boring and monitoring well locations. Details on proposed sampling and analysis associated with the recent release should be included in the plan.
Section 2.1.4.2-In the preliminary draft, the last paragraph of this section stated that the locations of pre-existing wells were not consistent with the observations made during visits to the former UST site. It also stated snow may have covered some wells and that others were not located accurately. In the current draft these statements were simply deleted. The plan should state monitoring well locations will be verified and and that if the well locations are not accurately reflected in other documents, the information will be forwarded to the appropriate Air Force and ADEC project managers, or at a minimum, the information should be clearly described in the report.
Section 2.1.5-This section, or a new section that should be added, should include a description of air permeability and respiration testing and any other field testing that will be done as part of the remedial design efforts that are to be included in this project. |
John Halverson |
| 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 |
| 7/2/1995 |
Update or Other Action |
UST Site Assessment final report for SOA UST Register Number 209 near building 22-009. This is a report of the excavation, sampling, and analysis of soils associated with permanent removal of a 500 gallon used oil underground storage tank. The single-walled carbon steel UST stored used oil from an oil water separator located in the southeast corner of the adjacent building.
Excavation and removal of tank 209 began on 16 June 1994. Base personnel emptied tank
fluids prior to excavation and transported the fluids to the EAFB treatment, storage, and
disposal (TSD) facility.
Soil analytical results for RRO ranged from not detected (ND) to 57 mg/Kg, with the highest result at the center of the tank excavation. DRO results ranged from 18 mg/Kg to 52 mg/Kg, with the highest result at the center of the excavation. Toluene was detected at 0.05 mg/Kg in the sample from the western portion of the stockpile. Total Xylenes results ranged from 0.08 mg/Kg to 0.12 mg/Kg, with the highest result in the center of the tank pit. Methylene chloride results ranged from 17 ug/Kg to 22 ug/Kg with the highest result in the sample from the eastern portion of the stockpile. The methylene chloride is believed to be a lab contaminant. No other compounds were detected. No further delineation of the extent of hydrocarbon impact is recommended at this site. |
John Halverson |
| 8/11/1995 |
Enforcement Agreement or Order |
ADEC (J. Halverson) sent letter to Air Force (L. Opperman) RE: Disposition of petroleum contaminated soil generated during underground storage tank (UST) Closures at Elmendorf AFB. I met with you and Mr. John Mahaffey on April 18, 1995, to discuss UST closures planned at Elmendorf this summer and the issue of how contaminated soil would be handled. We agreed that if "clean closure" could be reached through excavation, all contaminated soil should be removed and taken to an off-site treatment facility.
We also agreed that petroleum contaminated soil could be placed back in the ground, on the condition bioventing systems would be installed starting this year, if clean closure was not feasible. However, it has become apparent the Air Force has not been able to implement corrective action at leaking underground storage tank sites in a timely manner.
Therefore, our April 21, 1995 agreement on soil management must be revoked. Starting immediately, the department requests that all contaminated soil removed from the ground during closure or upgrade of USTs be completely contained in accordance with our petroleum contaminated soil stockpiling guidelines referenced in the UST regulations.
Please notify your project managers, the Army Corps of Engineers project manager and all of your UST contractors of this change. The rationale behind the need to contain all excavated petroleum contaminated soil is provided below.
Failure to implement Corrective Action-Tank #805, at building 24-805, failed a tightness test in 1994 and was removed from the ground. Tanks #96-104 were also removed from the ground in 1994. Petroleum contaminated soil was excavated during removal of the tanks. The Air Force requested approval to place contaminated soil back in the ground at both sites. Department approval was granted on the condition corrective action be started at each site no later than June 30, 1995.
The Air Force had committed to doing this work under Phase IV of the SERA. However, we have been informed that contracts for SERA Phase IV have not yet been awarded, work plans have not been developed, and it does not appear the field work will be started this year. This is a violation of the corrective action requirements outlined in the UST regulations and our prior agreements.
Management Action Plan (MAP) for transfer of LUST sites into the SERA-On several occasions the department has requested a formalized process for transfer of leaking UST sites from the UST agreement into the SERA. The January 3 1, 1995 annual UST report states that a MAP was being prepared to formalize such a process and that a copy would be forwarded to us as soon as it was completed.
We have not received a copy of the MAP. Numerous LUST sites have been identified during the past two years and transfer of sites between the UST and SERA compliance agreements has not been working. It appears the UST agreement needs to be amended to address release investigation and corrective action requirements. Based on the above and the fact that funding for DoD environmental cleanups is being reduced, we are no longer in a position to allow contaminated soil to be placed back in the ground with the hope it will be remediated in a timely manner. |
John Halverson |
| 8/14/1995 |
Update or Other Action |
On February 21, 1995, staff sent the Air Force a letter with comments on site assessment reports prepared by EA Engineering for USTs it closed or upgraded during 1994. The reports were not complete and ADEC requested they be amended to provide the necessary information. Without the complete site asessment reports ADEC is unable to make determinations on site closure or the neeed for additional investigation or corrective action. Until information is submitted, the Air Force has not met its site assessment obligations and may be in violation of release investigation and corrective action requirements.
On March 28, 1995, ADEC sent the Air Force another letter providing comments on site assessment reports prepared by Haliburton NUS and Harding Lawson. Several of the sites may be appropriate for no further action decisions after additional information is provided. However, until it is submitted, ADEC cannot make such determinations.
Elmendorf's annual report dated January 31, 1995, stated the floor of the building would be cut out to conduct a site assessment beneath the piping. It also stated the release investigation and corrective action would be conducted concurrently with work being done at the site under Phase III of the SERA.
ADEC was verbally informed the floor of the building had been opened, the piping replaced, some soil was removed, and additional samples were collected. However, to date, ADEC has not received the site assessment results from teh area beneath the piping. The release investigation and corrective action have not been implemented. SERA Phase III was not initiated this year (1995) due to funding problems and work at the site was added back into SERA Phase IV. However, ADEC also understands field work under Phase IV has not started. A notice of violation (NOV) was previously issued in response to the release at this site. It was closed out May 17, on the condition corrective action would be initiated this summer. Failure to conduct the requiredd release investigation and corrective action is an apparent on-going violation of the UST regulations and our agreements. |
John Halverson |
| 11/21/1995 |
Enforcement Agreement or Order |
ADEC Industrial Operations Section Chief Michael A. Conway sent a Notice of Violation - USAF Elmendorf Air Force Base EPA ID# AK8570028649 to Captain Jeffrey Liddle, Chief, Environmental Compliance 3 SPTG/CE. This Notice of Violation (Notice) is being issued to USAF Elmendorf Air Force Base (Elmendorf) based on findings from the hazardous waste inspection conducted at the installation on September 20-21, 1995.
This inspection was conducted by representatives of the Alaska Department of Environmental Conservation (Department), pursuant to Sections 3007(a) and 3007(c) of the Resource Conservation and Recovery Act (RCRA) and Alaska Statutes Title 46, Chapter 03, Section 020 [AS 46.03.020].
The purpose of the inspection was to determine whether the hazardous waste and used oil management activities at E!mendorf were bsir?g conducted ir? ccrnpliance with your Hazardous Waste Management Facility Permit (Permit) effective April 1, 1993 as modified, your Federal Facility Compliance Agreement (FFCA) pursuant to RCRA and Executive Order 12088 between Elmendorf and EPA effective August 6, 1991, and with applicable State and Federal regulations, The applicable regulations are found in Title 18 of the Alaska Administration Code, Chapter 62 (18 AAC 62) and Title 40 of the Code of Federal Regulations Parts 260 through 279 (40 CFR
260-279).
At the time of the inspection, Elmendorf was observed to be a large quantity generator of hazardous waste, a used oil generator, operating a container storage facility, and attempting to demonstrate "clean closure" at five RCRA regulated units. The following violations of your Permit, your FFCA, and State and Federal hazardous waste and used oil Management regulations were observed at the time of the inspection:
Violation #5 Modification of Approved Closure Plan: Paragraph 57 of the FFCA requires Elmendorf to submit closure plans meeting the requirements of 40 CFR 265 Subpart G or 40 CFR 264 Subpart X for the following areas at the Facility: 1) Building 22-009 - outside covered storage area; 2) Building 22-009 - storage yard outside north door; 3) Building 22-023 - Storage Shed; 4) Building 22-023 - Parts Cleaning Room floor and floor drain; 5) Explosive Ordnance Disposal Range and burn kettle; and 7) Power Plant hazardous waste accumulation areas. Up on approval by EPA, Respondent shall implement these plans.40 CFR 265.1 12(c)(3) [as adopted by 18 AAC 62.41 0 and authorized by AS 46.03.020(10)(1), AS 46.03.296(b), AS 46.03.299, AS 46.03.302(a), AS 46.03.305, and AS 46.03.31 I ] requires that the facility owner or operator submit a modification to an approved closure plan within 60 days after an unexpected event has occurred which has affected the closure plan.
On October 19, 1995, one of the inspectors (Mr. Geoffrey Kany) spoke with Mr. John Mahaffey of Elmendorf on the telephone regarding the closure plans. Mr. Mahaffey provided a status update on the closure plans. Mr. Mahaffey stated that closure has been delayed because Elmendorf intends to demonstrate clean closure by going to "background" levels. However, Elmendorf has received several results of analysis done for Total Chromium which have exceeded background levels, and apparently now Elmendorf has decided to distinguish between Total Chromium and Chromium-VI in a modified demonstration of clean closure. If this is the case, Elmendorf needs to amend the closure plans. EPA must then again public notice the closure plans to allow the public the opportunity to comment on the substantive revision to the closure plans, pursuant to 40 CFR 265.1 13(c)(3).
The Department is concerned that these closure plans, which were due by August 15, 1991, public noticed July 7, 1993 and approved March 23, 1994, have yet to be certified as "clean closed." When the FFCA was being negotiated, the Department had the expectation that these units would be certified as "clean closed" by October 1992. If you have not already done so, please submit your requested modifications to your previously approved subject closure plans to both EPA and the Department and submit notification to EPA and the Department pursuant to Paragraph 77 of the FFCA.
The violations described above are serious violations which may subject you to legal action and can result in either civil or criminal actions as provided for under RCRA or Alaska Statutes [AS 46.03.760 and 46.03.7901. This written informal enforcement action is being taken by the State of Alaska simply to identify violations which were observed during the inspection; in effect, to put you on notice.
Issuance of this Notice does not preclude formal State or Federal enforcement action or citizen suits pursuant to RCRA Section 7002(a). Nor does the Department consider its issuance of this Notice to necessarily trigger the dispute resolution process in Paragraph 73 of the FFCA, as the Department is not a party to the FFCA. |
Mike Conway |
| 10/17/1996 |
Institutional Control Record Established |
Air Force 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 and 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 RODs for OUs 3 and 6 which require, the aquifer remain unused. 2) Personnel in the review process within CES must be aware of these policies and review them on a recurring basis. It is imperative this restriction be recognized and observed during engineer reviews and operations |
Jennifer Roberts |
| 2/11/1997 |
Site Added to Database |
Site added by Shannon and Wilson, Inc. |
S&W-Miner |
| 2/11/1997 |
Update or Other Action |
(Old R:Base Action Code = RI - Remedial Investigation). RI action added by Shannon and Wilson, Inc. on 02/11/1997. Air Force Relative Risk Evaluation Worksheet dated 8/18/95 indicated RI is the current phase. |
S&W-Miner |
| 3/21/1997 |
Update or Other Action |
Letter sent to Larry Underbakke in response to phone call on 3/19/1997 regarding the disposition of excavated contaminated soils encountered during upcoming summer's PL81 (inactive 10-inch) pipeline project in the vicinity of the Port of Anchorage but on the northern portion of PL81. All contaminated soils removed from the ground during the closure or decommissioning of the PL81 project must be done in accordance with 18 AAC 78.311 Soil Storage and Disposal.
The rationale for the need to excavate all excavated petroleum contaminated soil is based on previous experience with EAFB at sites where followup work was not conducted.
Specifically, Tank #805 at building 24-805, UST failed a tightness test in 1994 and was removed from the ground. Tanks 96-104 associated with building 22-013 were also removed from the ground in 1994. Petroleum contaminated soil was excavated during removal of the tanks. The Air Force requested approval to place contaminated soil back in the ground for both of these sites and subsequently numerous others. DEC approval was granted on the condition corrective action would be started at each site soon thereafter. The Air Force had committed to doing this work under Phase IV of the SERA. However, DEC has been informed that work plans for risk assessment or corrective action at each site had not been developed. This is a violation of the corrective action requirements outlined in the UST regulations and our prior agreements with the Air Force.
Based on the above example, and the fact that funding for DOD environmental cleanups is being reduced, DEC is no longer in a position to allow contaminated soil to be placed back in the ground with the hope it will be remediated in a timely manner. |
Louis Howard |
| 11/11/1998 |
Update or Other Action |
Site transferred to compliance UST program SERA IV ST403 LUST EVENT ID 2826 reckey # 1994210015201 due to UST 209. Technical Document to support no further action ST75 at 22-009. Administratively close site ST75 from SERA Phase III program and move it under the SERA Phase IV program as site ST403. Soil contamination is being addressed under SERA Phase IV as ST403. Monitoring well 403-WL-01 is included in the SERA Phase IV groundwater contaminants of concern effort. Groundwater contamination will continue to be monitored under the Basewide effort until the water meets standards. The document was signed by L. Howard ADEC and J. Williamson Elmendorf AFB on 11/25/98 and 11/13/98 respectively. Administratively closed out. |
Louis Howard |
| 10/9/2000 |
Document, Report, or Work plan Review - other |
Staff sent letter on 10/09/2000 certified mail number 388 516 845 and Air Force received it on 10/25/2000. 21 day deadline for response to corrective action request for SERA Phase IV Sites Letter dated June 9, 1998 is on November 8, 2000 at 5:00 PM. On June 9, 1998 the Alaska Department of Environmental Conservation (ADEC) sent EAFB a letter requesting a release investigation workplan for the groundwater contamination since soil contamination reaches groundwater for all of the sites listed below.
ADEC requests EAFB provide any information that a release investigation workplan has been submitted for the sites listed below or that an investigation has been conducted to characterize the full extent of groundwater contamination associated with these sites. If no workplan was ever submitted, then ADEC requests EAFB submit a release investigation workplan for its review and comment. ADEC also requested in the June 1998 letter that EAFB begin corrective action on contaminated soils at the following sites:
ST 401 AFIDs 96-104 associated with Building 22-013, ST 402 AFID 150 associated with Building 32-127, ST 403 AFIDs 209 and 229 associated with Building 22-009, ST 422 AFID 471 associated with Building 41-701, ST 424 AFID 189 associated with Building 32-189, ST 405 AFID 335 associated with Building 42-335, ST 419 AFIDs 51 and 52 associated with Building 41-659, ST 407 AFIDs 575, 576, 578 associated with Building 43-575, ST 410 AFID 165 associated with Building Hush House, ST 421 AFID 425A, B, C, D associated with Building 42-425, ST 428 AFID 130 associated with Building 1-836.
EAFB is awaiting finalization of the Spill Response Presumptive Remedy Memorandum of Understanding (MOU) prior to taking any action at the sites discussed above in anticipation of requesting that they be included in the MOU. ADEC does not concur with this delay and requests EAFB take prompt corrective action and characterization of the groundwater contamination at these sites. Past failure to adequately address this compliance issue prevents ADEC from considering these sites under the draft MOU and closing out the SERA Agreement. |
Louis Howard |
| 10/21/2002 |
Update or Other Action |
Letter sent to Joe Williamson 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 |
| 7/23/2004 |
Conditional Closure Approved |
On April 26, 2004, the Alaska Department of Environmental Conservation (the Department) received several decision document packets. After reviewing the data and reports submitted for ST403, the Department agrees that no additional remediation or investigation is required (for the soil) at ST403 LUST Event ID 2826. The selected remedy for this site is monitored natural attenuation. DRO concentrations in soil exceed the ADEC 18 AAC 75 Method Two (January 2003) cleanup levels at this site. Based on SERA IV investigation results, contamination is present in the smear zone at UST AFID 209 and from 7 feet to 21 feet bgs at UST AFID 229. Contamination may also be present in the smear zone at AFID 229. Based on previous investigations, contamination may also be present in shallow soil under the building foundation and immediately adjacent to the building. Excavation of this contaminated soil is not practical and may undermine the building foundation. However, groundwater monitoring will be required until cleanup levels are achieved.
The Department reserves its rights, under: 18 AAC 75 Contaminated Site regulations, 18 AAC 78 Underground Storage Tank regulations, and AS 46.03 to require additional investigation, cleanup, containment, and/or other necessary actions, if subsequent information indicates: additional contamination remains at the site which was previously undiscovered and presents an unacceptable risk to human health, safety, or welfare, or the environment. |
Louis Howard |
| 7/26/2004 |
Long Term Monitoring Established |
The Elmendorf AFB Basewide Groundwater Monitoring Program will be utilized to monitor groundwater during implementation of the remedy. The nearest downgradient monitoring well currently in the Basewide Groundwater Monitoring Program is 403-MW-01, located approximately 150 feet south of ST403. Trichloroethylene (TCE) was detected in this well in 2002; however, DRO was not detected.
The Elmendorf AFB Basewide Groundwater Monitoring Program will no longer exist after this year. Please confirm that your contractor will be monitoring the wells specified in the closure document submitted for this site and that the zone project manager is aware that the monitoring requirements for the compliance wells may be different than what is being required for under the CERCLA program.
For the compliance site known as ST403, the Department will require monitoring for: diesel range organics (DRO) and polynuclear aromatic hydrocarbons (PAHs) as required in Table 2A of the UST Procedure Manual section 10.1.2 “Determination of Sampling and Laboratory Analysis for Soil(s) and Groundwater (GW). PAHs were never analyzed for in the previous investigations.
|
Louis Howard |
| 2/15/2007 |
GIS Position Updated |
TOPOZONE (NAD83/WGS84), 2004 Environmental Atlas Page I42, and EAFB UST Site Assessment Final Report, SOA UST No. 209 near Building 22-009 dated July 2, 1995 Appendix A Vicinity Map |
Louis Howard |
| 6/10/2013 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 73725 name: auto-generated pm edit Elmendorf ST75 Bldg 4314 |
Louis Howard |
| 7/31/2015 |
Update or Other Action |
Staff received a draft work plan for vapor intrusion monitoring covering several sites on JBER-E and JBER-4 which includes building 4314 (Industrial HazMat Storage) for trichloroethylene groundwater contamination that may potentially be a completed pathway for vapor intrusion at the building. This work plan is intended to describe the overall project implementation plan and
methodologies to be used to complete the initial screening and building survey tasks. Field
data collection activities associated with soil vapor and ambient air will be addressed in a
separate Uniform Federal Policy - Quality Assurance Project Plan (UFP-QAPP) that will be
developed prior to the start of field sampling.
See site file for additional information. |
Louis Howard |
| 8/13/2015 |
Document, Report, or Work plan Review - other |
Staff provided comments on the letter work plan (draft). Main comments were regarding specifying in the document what exactly is being screened for during this project and whether the screening effort will be done in accordance with the current EPA and ADEC vapor intrusion guidance. Staff also commented on the need to conduct a building survey on the buildings before a priority building of interest list is created.
See site file for additional information. |
Louis Howard |
| 9/1/2015 |
Document, Report, or Work plan Review - other |
EPA Comments on the Vapor Intrusion Letter Work Plan
GENERAL
The Five Year Reviews for both Fort Richardson (2013) and Elmendorf (2014) question if the groundwater plume boundaries have been fully defined, especially for chlorinated solvent plumes associated with ST037. Additionally, there are sites currently under investigation which were not covered in the Five Year Reviews that include chlorinated solvent plumes. It is unclear if buildings around these sites still early in the CERCLA investigative process will be included in the VI building survey. Some of these sites include SS22, SS109, CG703, AT035, SS013, and TU117
Please clarify if sites with VOC contaminated groundwater plumes which have not completed the CERCLA process to a ROD are included in the buildings of interest list.
Building Use Evaluation. Consider a second prioritization tier in addition to residential/ industrial for screening buildings based on occupancy of women of childbearing age. These buildings should be prioritized so an office or industrial workplace with women of childbearing age would be a higher priority than an office or workplace occupied solely by men.
Please define which age class is included in women of childbearing age (?12 to 50 years old?)
The ADEC building inventory and air sampling questionnaire does not include a question on occupancy of women of childbearing age. This question should be added to the questionnaire.
For plumes that have not been well defined in extent, it is suggested to error on the conservative side and include more buildings that might possibly be within the edge of a plume.
|
Louis Howard |
| 4/13/2016 |
Update or Other Action |
Draft UFP-QAPP for vapor intrusion studies received for review and comment. The VI Studies will evaluate the potential for one or more complete VI pathways associated with volatile organic or fuel-related contaminants in groundwater or soil at approximately 136 potential buildings of interest (PBOI) at JBER-Elmendorf (JBER-E) and JBER-Richardson (JBER-R). The overall project scope of work includes the completion of an initial screening, on-site building surveys, field data collection, and human health risk assessment. The overall project objectives are to determine the potential risk to human health associated with VI and to provide recommendations for additional work at the 30 highest priority buildings of interest (BOI).
This UFP-QAPP also addresses the collection and analysis of groundwater samples from 33 existing
monitoring wells at JBER, as part of a separate task on this Task Order. The groundwater samples will be analyzed for 1,4-dioxane. Their collection and analysis are not associated with the VI Study. The results of the groundwater task will be presented in a separate letter report.
See site file for additional information. |
Louis Howard |
| 5/4/2016 |
Document, Report, or Work plan Review - other |
Staff commented on the draft VI Studies WP.
ADEC and EPA will be the judge of the significance of any changes to the approved UFP-QAPP not JBER and whether or not they require agency approval prior to being implemented
ADEC highly recommends a plan of action be developed beyond what is presented here for indoor air sampling results identifying an unacceptable risk to human health. The EPA Region 9 memorandum “EPA Region 9 Response Action Levels and Recommendations to address Near-Term Inhalation Exposures to TCE in Air from Subsurface Vapor Intrusion” (July 9, 2014) is a good place to start in developing accelerated and urgent response actions. Additionally, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP) and Superfund guidance provide for early or interim actions where warranted by the hazards posed by site-related contamination.
A pre-sampling building walk-through should be completed at least 24 hours before collecting indoor air samples. During the walk-through, indoor vapor sources that could interfere with detecting COCs intruding into the building from subsurface sources should be removed if possible.
When conducting leak tests at sub-slab, or near slab soil sample ports, the helium utilized should be research grade with 99.9% purity.
ADEC recommends that ancillary data be collected during sampling events. Ancillary data includes temperature, barometric pressure, indoor/outdoor pressure differential, recent rainfall patterns, and the potential operation of an HVAC system. The ancillary data can be used as additional lines of evidence for assessing the potential vapor intrusion risk.
See site file for additional information. |
Louis Howard |
| 6/28/2016 |
Document, Report, or Work plan Review - other |
Approval of the UFP-QAPP VI Studies Work Plan.
ADEC’s comments on the work plan have been incorporated into the document. Research on vapor intrusion has shown large variability in soil gas and indoor air concentrations for a given site over time in response to changes in many variables including climatic conditions, HVAC system operations, groundwater table flux, preferential pathways, etc.
This investigation will assess vapor intrusion for a subset of potentially impacted buildings (e.g. buildings of interest) using Summa canisters deployed for a 24 hour time period over two sample events for indoor air and a “summer-only” sample event for sub-slab gas. The Air Force will inform ADEC immediately of any preliminary sample results that exceed the interim response action levels agreed to in the approved work plan.
The Air Force will implement a response plan as necessary to notify and protect residents or workers exposed to vapor concentrations exceeding screening levels as established in this work plan. Additional indoor air/sub-slab sampling will be required for demonstrating the success of any mitigation efforts for vapor intrusion and assessing vapor intrusion in the winter season at the buildings of interest.
The work plan is approved by ADEC. ADEC’s review and approval of this work plan is to ensure that the work is done in accordance with State of Alaska environmental conservation laws and regulations. While ADEC may have commented on other state and federal laws and regulations, our review and approval on the work plan does not relieve AFCEC from the need to comply with other applicable laws and regulations. Significant organizational or project goal changes must be documented in a QAPP Amendment or Addendum requiring the approval of USEPA and ADEC prior to implementation. |
Louis Howard |
| 12/20/2018 |
Update or Other Action |
Site Assessment & Release Investigation Report UST Removal of Tank #386 received for comment. Naphthalene was found to be above ADEC cleanup levels via 8260C but below cleanup levels via 8270D SIM; this is a common occurrence & is most often determined non-actionable. Benzene, ethylbenzene, & naphthalene were determined to be above cleanup levels in pre & post stockpile samples; although further investigation may be warranted for those areas, pre-stockpile samples indicate that it is a pre-existing contaminant associated with Restoration Site S0550/CG551 & as a result from leakage of a previous tank in the same location.
No direct evidence of a waste oil release from the fill lines, vents, or tank body was encountered during the course of investigation & UST removal. Due to the relative low and isolated levels of Benzene, ethylbenzene, & naphthalene detected in soils surrounding the UST and piping, further excavation & removal of associated soils is not recommended. This recommendation is in conjunction with and supported by a previous implementation of Institutional Controls and Conditional Closure of Restoration Site S0550/CG551.
See site file for additional information. |
Louis Howard |
| 2/7/2023 |
Document, Report, or Work plan Review - other |
DEC reviewed the 2023 Letter Work Plan Remedial Action Operations and Long-Term Management, Draft, dated January 2023. The work plan describes the site inspections, maintenance activities, and groundwater, seep, and surface water monitoring, at multiple sites located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. The scope of work briefly summarizes the site locations, sampling/monitoring schedules, and activities such as free-product removal from monitoring wells and monitoring/maintenance activities at the Operable Unit 5 wetlands. The details regarding the procedures for the remedial action operations and long-term management activities will remain consistent with the 2021 Uniform Federal Policy Quality Assurance Project Plan (UFP-QAPP). |
Ginna Quesada |
| 4/25/2023 |
Document, Report, or Work plan Review - other |
DEC approved the 2023 Letter Work Plan Remedial Action Operations and Long-Term Management, Final, Dated April 2023. The work plan describes the site inspections, maintenance activities, and groundwater, seep, and surface water monitoring, at multiple sites located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. The scope of work briefly summarizes the site locations, sampling/monitoring schedules, and activities such as free-product removal from monitoring wells and monitoring/maintenance activities at the Operable Unit 5 wetlands. The details regarding the procedures for the remedial action operations and long-term management activities will remain consistent with the 2021 Uniform Federal Policy Quality Assurance Project Plan (UFP-QAPP). |
Ginna Quesada |
| 1/30/2025 |
Document, Report, or Work plan Review - other |
DEC approved the 2025 Remedial Action–Operations and Long-term Monitoring Work Plan Addendum Final, dated January 2024.The work plan describes the site inspections, maintenance activities, and groundwater, seep, and surface water monitoring, activities that will be conducted at multiple sites located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. The scope of work briefly summarizes the site locations, sampling/monitoring activities and schedules. This workplan will remain consistent with the procedures outlined in the 2023 Letter Work Plan Remedial Action-Operations and Long-Term Management. |
Ginna Quesada |
