| Action Date |
Action |
Description |
DEC Staff |
| 4/5/1991 |
Enforcement Agreement or Order |
Resource Conservation and Recovery Act (RCRA) Federal Facility Compliance Agreement signed. It was based on initiated by a Notice of Non-compliance (NON) dated June 19, 1990. Also the Army failed to mark containers of hazardous waste which has accumulated at Building 975 with the words "hazardous waste (HW)" during an 4/19/88 inspection resulted in a NON. Also the Army failed to mark containers of HW accumulated at 975 with an accumulation date. |
Louis Howard |
| 9/21/1993 |
Enforcement Agreement or Order |
A.G. letter (Breck Tostevin) to Tamela J. Tobia OS Judge Advocate for the Army. Letter states that a separate petroleum site compliance agreement should be separate from the CERCLA federal facility agreement. The petroleum site restoration agreement would function as a "two-party agreement" under the FFA. It would track the basic provisions of the UST Agreement but be tailored to the State's contaminated site regulations and would interface with the FFA. All petroleum sites addressed under the Two Party agreement would be reviewed in the final operable unit of the FFA and actions taken would be memorialized in a Record of Decision (ROD) under the FFA. |
Louis Howard |
| 11/12/1993 |
Enforcement Agreement or Order |
State-Fort Richardson Underground Storage Tank Compliance Agreement signed by ADEC (Janice Adair Regional Administrator-Southcentral Office) and U.S. Army. The purpose of the agreement is to bring Fort Richardson into compliance with the Underground Storage Tank (UST) regulations and avoid the expense of formal enforcement proceedings. The Army agrees to perform the necessary inventory, record keeping, registration, upgrading or closure, tightness testing, site assessment, release reporting, release investigation, and corrective action (remediation) associated with USTs at Fort Richardson (excluding Alaska Department of Military and Veterans Affairs and Army National Guard USTs).
All petroleum sites addressed under the Two Party agreement would be reviewed in the final operable unit of the FFA and actions taken would be memorialized in a Record of Decision (ROD) under the FFA.
Site Assessment or Svstem Tightness Test
29. The Army shall conduct a site assessment* or a system tightness test, as required by AS 46.03.380(b) and 18 AAC 78.01S(i)(3), on all USTs located at Ft. Richardson, or permanently close the USTs in accordance with 40 CFR 280 and 18 AAC 78. If site assessments or system tests have been conducted, the Army shall submit proof of compliance by the deadlines set forth in the USTMP. Site Assessments or System Tightness Tests shall be conducted under the schedules in 18 AAC 78.015(i)(3) or, in order to come into compliance, as scheduled in the USTMP.
All tightness testing work will be conducted by a certified UST worker as required by 18 AAC 78.400. Site Assessment work will be conducted pursuant to 18 AAC 78 and an ADEC-approved Quality Assurance Program Plan (QAPP). With respect to UST recordkeeping requirements, the Army shall compile all required records by the date set forth in the USTMP and shall thereafter maintain and update those records as required by 18 AAC 78 and 40 CFR 280.
Release Investigation Reports
31. The Army shall submit to ADEC a Release Investigation* report for each UST site having a documented release* of petroleum products or hazardous substances. These reports will be submitted by the deadlines in the USTMP. The Release Investigation report shall contain all information required by 18 AAC 78.230(b), 18 AAC 78.240(c) and the following:
1) a detailed written or, if applicable, visual description of all work performed and summary of all pertinent data prepared by the Army and its consultants,
2) monitoring well construction data and
3) soil boring logs;
4) site maps detailing existing improvements and (if known)
5) the location of former fuel dispensing equipment,
6) water table elevation maps,
7) petroleum-product level and thickness (isoplot) maps,
8) organic-contaminant concentration maps,
9) aquifer interpretations,
10) other potential source areas within 1/4 mile,
11) data deliverables as outlined in 18 AAC 78,
12) interpretations of field observations and analytical data,
13) a completed Site Assessment/Release Investigation Summary Form, and
14) recommendations for any follow up work.
32. If upon review of a Release Investigation report the ADEC reasonably determines additional contamination assessment is required, ADEC shall notify the Army in writing. This writing will set forth the reason(s) the ADEC concluded that additional assessment is required.
111. "Site" shall mean a distinct area of contamination or potential contamination.
112. "Site assessment" shall mean the investigation of suspected contamination resulting from an unpermitted release of oil or hazardous substance as further defined in 18 AAC 78.090 (Site characterization and assessment).
110. "Release" shall have the meaning in AS 46.03.826 [(9) "release" means any spilling, leaking, pumping, pouring, emitting, emptying, discharging, injecting, escaping, leaching, dumping, or disposing into the environment, including the abandonment or discarding of barrels, containers, and other closed receptacles containing any hazardous substance.]
Listed on Attachment D as either requiring an upgrade or closure for UST 38. |
Janice Adair |
| 4/19/1994 |
Update or Other Action |
A sample of the tank contents was collected by Oil Spill Consultants on April 19, 1994. Laboratory analysis indicated this tank contained water with trace quantities of benzene, toluene, ethylbenzene, xylene, (BTEX). No PCBs or halogenated hydrocarbons were detected. The flash point was greater than 200°F. |
Louis Howard |
| 7/26/1994 |
Preliminary Assessment Approved |
Site assessment performed. Soil samples found to be above Level D criteria. The 1,000-gallon UST was removed from Building 975 in May 1994. Five soil samples were collected to determine if the soil was contaminated with petroleum hydrocarbons.
Laboratory results indicated the maximum detected level of DRO in the soil was 2,430 mg/Kg and GRO and benzene were detected at 0.585 mg/Kg and 0.02 mg/Kg, respectively. BTEX was detected at 0.22 mg/Kg. |
Louis Howard |
| 8/18/1996 |
Update or Other Action |
Final Remedial Investigation Report for Buildings: 47-203, 955, 975, 979, 45-070, 28-008 received (DOWL/Ogden Joint Venture) for the USACE. Building 975 is located near the intersection of the Davis Highway and Fifth Street. Vehicle maintenance is performed in Building 975. A 1,000-gallon UST (Tank 38) was placed on the North side of Building 975 to store water which accumulated from vehicle washing. Tank 38 was six feet two inches long and five feet two inches in diameter. It had a two-inch vent pipe and a four-inch fill pipe. Both pipes extended two feet above the ground. This UST was installed approximately four feet below
ground and had no surface dispensers.
Information provided by Brown & Root Services Corporation stated Tank 38 contained oily
water from equipment washing.
Soil samples collected during the removal detennined the soil surrounding the tank was contaminated with petroleum hydrocarbons. Therefore, soil samples collected during the RI were analyzed for VOCs, TRPH, GRO, DRO, metals, and PCBs.
DRO was detected in one sample borehole AP-3675 at a concentration of 960 mg/Kg at the
surface. TRPH was detected in two soil samples at concentrations of 1,378 mg/Kg at the surface and 55.26 mg/Kg at 10 feet.
DRO was detected in one sample in borehole AP-3676 at a concentration of 1,400 mg/Kg at the surface. TRPH was detected in one soil sample at a concentration of 8,524 mg/Kg at the surface. TRPH was detected in two soil samples at concentrations of 5,135 mg/Kg at the surface and 95.74 mg/Kg at five feet.
The sampling results for Building 975 indicate soil contaminated with diesel range organics in
excess of 100 mglKg at all five sample locations. The results greater than 100 mglKg for DRO
were only from the surface samples. The DRO and TRPH sampling results in excess of the clean-up criteria are most likely the result of sampling just below the asphalt.
This soil could be
contaminated with residue from the hot asphalt during paving. Also, in order to cut through the
asphalt it was necessary to heat the asphalt first, heating the asphalt would further
"contaminate" the soil just below it. GRO levels were detected in five samples, all were less than 5 mg/Kg. The metals sampling results were near established background levels.
The matrix score for Building 975 is 24, or Category C. This requires the following soil clean-up levels:
DRO 1,000 mg/kg
GRO 500 mg/kg
TPH (TRPH) RRO: 2,000
Benzene 0.5 mg/kg
BTEX 50 mg/kg
No ground water was encountered at this site.
The contaminated soil present at this site is most likely due to the asphalt paving above it. It is recommended a letter be submitted to the ADEC requesting alternative clean-up levels and no further action at this site, since contaminant levels in access of clean-up criteria are only found immediately below the asphalt paving.
|
Louis Howard |
| 9/9/1996 |
Conditional Closure Approved |
No further remedial action required since leaching assessment shows that petroleum will not migrate to groundwater and impact it. Based on a review of the information provided, ADEC agrees that buildings: 955, 975, 979 do not require further investigation or remedial action.
Institutional controls on contaminated soils requires dig permits monitored by the Public Works department on Post. This action does not preclude ADEC from requesting future remediation or site investigation at a later date. If new information indicates that previously undiscovered contamination or exposures lead to groundwater contamination above the applicable water quality criteria (18 AAC 70) or exposures which cause and unacceptable risk to human health, welfare or the environment, then future investigation and/or remedial actions will be required by ADEC. |
Louis Howard |
| 9/9/1996 |
Institutional Control Record Established |
ICs are required since level of soil contaminated with petroleum is above those levels which would allow for unrestricted use. Dig permit required for any soil activity in area managed by Public Works Environmental staff. Area noted on Post Management plans and maps as an area requiring ICs and waste management and disposal at a permitted facility if soil were to be excavated at any time in the future. |
Louis Howard |
| 2/17/1997 |
Site Added to Database |
Diesel. |
Louis Howard |
| 4/21/1998 |
Site Ranked Using the AHRM |
Ranking action added now because it was not added when the site was originally ranked. |
Bill Petrik |
| 9/14/2001 |
Update or Other Action |
Institutional controls report received for several sites which include this building. DRO was detected up to 1,400 mg/kg and TRPH at 8,500 mg/kg, a leachability study was used to obtain site closure (NFA actually). This closure does not preclude future remediation or site investigation if new information indicates there is previously undiscovered contamination or exposures which cause an unacceptable risk to human health or the environment. ADEC requests any monitoring wells installed as a part of the investigation be added to the Post-wide monitoring network established under the CERCLA Federal Facility Agreement. ICs tracked under Fort Richardson Master Plan (GIS). |
Louis Howard |
| 12/12/2001 |
Update or Other Action |
1. All organizations conducting activities on United States Army Alaska (USARAK) controlled land are responsible for complying with established institutional controls (ICs). ICs are administrative, procedural, and regulatory measures to control human access to and usage of property. They are applicable to all known or suspected contaminated sites where contamination has been left in place.
2. These controls have been established to implement the selected remedial actions agreed upon by the U.S. Army (Army), the U.S. Environmental Protection Agency (USEPA), and the Alaska Department of Environmental Conservation (ADEC) in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) as amended by the Superfund Amendment Reauthorization Act (SARA). These controls also apply to remedial actions agreed upon under Two-Party Compliance Agreements. These agreements are concluded between USARAK and ADEC and apply to petroleum/oil/lubricants- (POL) contaminated sites.
3. ICs such as limitations on access, water use, excavations, and property transfers will supplement engineering controls as appropriate for short-term and long-term management to prevent or limit human and environmental exposure to hazardous substances, pollutants, or contaminants. Specific ICs include, among other things: limitations on the depth and location of excavations, prohibition of or restrictions on well drilling and use of ground water, requirements for worker use of personal protective equipment, site monitoring, and prohibition of certain land uses, types of vehicles, etc.
4. Organizational units, tenants, and support/contractor organizations must obtain an Excavation Clearance Request (ECR) for all soil disturbing activities impacting soils six inches or more below the ground surface. The review process for approval of an ECR begins with the identification of the current status (known or suspected hazardous waste site or “clean” site) of a work location. ECR’s for work in known or suspected hazardous waste sites:
a. will include specific limitations and controls on such work;
b. will include specific IC procedures, and notification, monitoring, reporting, and stop work requirements;
c. may include procedures for management, characterization, and disposal of any soil or groundwater encountered or removed;
d. will identify “project managers” for both the unit/contractor requesting the work and DPW Environment Resources.
5. The DPW project manager will conduct on-site inspections of each work site (at which ICs apply) to determine continued compliance with the terms and conditions of the approved ECR. DPW has the authority to revoke ECR approval if the specified terms and conditions are not being met. ECR forms are available at the Customer Service Desks at: a. Building 730 at Fort Richardson; b. Building 3015 at Fort Wainwright; c. Building 605 at Fort Greely.
6. USARAK has negotiated (with USEPA and/or ADEC) decision documents and/or Records of Decision (RODs) that mandate the implementation of ICs USARAK Directorate of Public Works, Environmental Resources Department (PWE), maintains copies of all decision documents and RODs requiring ICs in its real property files. PWE provides regularly updated post maps showing all areas affected by ICs. These maps can easily be accessed by using an approved intranet mapping interface application. Copies of these maps will be available to each directorate, activity, and tenant organization. To ensure the effectiveness of ICs, all organizational units and tenant activities will be informed on an annual basis of ICs on contaminated soils and groundwater in effect near their facilities.
7. ICs are enforceable by the U.S. Environmental Protection Agency (USEPA) and the Alaska Department of Environmental Conservation (ADEC). Failure to comply with an IC mandated in a decision document or ROD will violate the USARAK Federal Facility Agreement and may result in stipulated fines and penalties. This does not include the costs of corrective actions required due to violation of an established IC.
|
Louis Howard |
| 8/30/2007 |
GIS Position Updated |
61.265 N latitude -149.6931 W longitude |
Louis Howard |
| 11/5/2009 |
Document, Report, or Work plan Review - other |
EPA Letter to Colonel Timothy Prior. RE: Closures of Five Class V Injection Wells, Reclassification of One Motor Vehicle Waste Disposal Well, and Long-Term Monitoring of Moose Run Golf Course Stormwater Drainage Injection Wells, Fort Richardson, Alaska (UIC ID# AK020F5-12-13347, AK020F5-12-13398, AK020F5-17-13406, and AK020F5-12-13346)
Four Class V injection wells used for disposal of stormwater existed about 250 feet northeast of Building 975. The four injection wells were constructed as a cluster of drywells, each consisting ofwelded-together sections ofperforated 55-gallon drums that were buried underground. The drywells were approximately ten feet deep.
On June 5, 2008, the drywells were excavated. Soil samples were collected from beneath the excavation, at approximately 11 feet below ground surface, and analyzed for gasoline range organics by Alaska Method 101, diesel range organics by Alaska Method 102, residual range organics by Alaska Method 103, metals by EPA Method. 6020, and mercury by EPA Method 7471 B.
Analyses detected diesel range organics, arsenic, and chromium above State ofAlaska cleanup levels. The drywells were located approximately 100 feet southwest ofa petroleum contaminated site that is the subject of a cleanup action under a Two Party Agreement between the Alaska Department ofEnvironmental Conservation (ADEC) and the U.S. Army. Fort Richardson is working with ADEC to determine appropriate next steps to respond to these analytical findings. The excavation was backfilled with rock imported from an offsite source.
The UIC Program files for Fort Richardson have been updated to show that one stormwater injection well at Building 45-125 and four stormwater injection wells at Building 975 have been permanently removed. EPA understands that Fort Richardson is continuing to work with ADEC to address the diesel range organics, arsenic, and chromium found in samples collected at the Building 975 drywell excavation.
If additional information becomes available indicating that the injection well closure activities at these sites were inadequate, Fort Richardson is required to provide the additional information to EPA, and further efforts may be required in the future. You are also advised that Fort Richardson is responsible for compliance with all other federal, state, or local laws and regulations. |
Louis Howard |
| 6/6/2012 |
Update or Other Action |
Draft Project Management Plan received for review and comment.
Performance Objective
Site Closure
Potential Risk
The nature and extent of soil contamination in the upper 25 feet is greater than anticipated.
Groundwater impacts are discovered during site characterization.
Risk Mitigation
Excavate soil as needed (estimate 500 yd3) to achieve SC. Monitoring wells will be installed,
and groundwater contamination will be addressed with a technology that is appropriate to the
nature and extent of the plume to achieve SC within the POP.
Date of Achieving Performance Objective
2nd Quarter FY 2014
Planned Approach
Prepare an approved Characterization Workplan.
Coordinate, mobilize, and execute Characterization Workplan by installing and sampling four soil borings, collect one hydropunch groundwater sample and collect groundwater sample from one existing monitoring well.
Use HRC to evaluate SC based on risk to future residential receptors for all pathways.
Prepare an approved Site Characterization Report documenting HRC risk evaluation.
Prepare an approved Site Closure Report requesting Cleanup Complete without ICs.
Receive concurrence from ADEC that site has achieved Cleanup Complete without ICs and provide documentation to AFCEE. |
Louis Howard |
| 6/22/2012 |
Document, Report, or Work plan Review - other |
Staff commented on the draft PMP.
2.3 Quality Control Documents
Please be aware that the federal facility agreements and Ft. Richardson Environmental Restoration Agreement require submittal of laboratory data to the agencies for review as follows:
The Parties shall make available to each other quality-assured results of sampling, tests, or other data generated by or on behalf of any Party under this Agreement within sixty (60) days of field testing or the submittal of data to the laboratory.
If quality assurance is not completed within sixty (60) days, preliminary data or results shall be made available within the sixty (60) day period and quality assured data or results shall be submitted as they become available but in no event later than one hundred (100) days after testing or the submittal of data to the laboratory. These periods can be extended upon mutual agreement among the Project Managers.
Page 2-31
The text states: “The WPs will be submitted in the initial phases of the project for Air Force and regulatory review and 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 and Environment (SAF/IE) to proceed with execution of the plan activities. The WESTON Team understands that a procedure has been established for this situation, and 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 and may result in field work not being approved or additional work being required and may subject responsible parties and/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 and 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 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 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 and Version Control
Draft and Draft Final Versions of documents
Agency review of draft/draft-final version of documents are subject to those review time frames for primary and secondary documents and conditions as specifically identified in the respective Federal Facility Agreements for JBER or a mutually agreed upon schedule agreed to in writing by the three agencies’ remedial project managers.
For petroleum sites (aka Two Party sites) overseen by ADEC refer to the following:
ADEC will strive to complete plan reviews and 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, and contractors providing complete, well written plans.
Independent QA Oversight on Performance Based Contracts
The site cleanup rules require that “collection, interpretation, and reporting of data, and the required sampling and 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 and 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 and contract requirements.
|
Louis Howard |
| 4/22/2013 |
Update or Other Action |
Draft UFP-QAPP work plan received for review and comment.
The overall objective for the site is to meet “unrestricted or residential site use” criteria and
achieve a “cleanup complete without institutional controls (ICs)” determination. To meet this
objective, soil and groundwater samples will be collected to characterize risk to human health
and the environment within the framework of the ADEC site cleanup process (Title 18
Chapter 75 of the Alaska Administrative Code [18 AAC 75] Sections 325 to 390 and 18 AAC 78
Section 600) (ADEC, 2012a; ADEC, 2012b). If ADEC Method Two cleanup criteria as
established under 18 AAC 75 are exceeded, the Hydrocarbon Risk Calculator (HRC) approach
under Method Three will be used to assess whether site conditions meet ADEC risk criteria (in
which case, a “cleanup complete without ICs” determination will be requested) or whether the
site poses unacceptable risk (in which case, further remediation may be required).
If unacceptable risk is indicated by the HRC or if vadose zone soils exceed maximum allowable
concentrations, remedial options will be evaluated that address the contaminants of concern and
associated exposure routes that contribute enough risk to cause the cumulative risk estimate to
exceed the risk standard.
One boring will be drilled near former sample 94-975-BE to resample the soil at the location
and depth where previous sampling showed exceedances of the “migration to groundwater”
criteria for DRO and to collect source area soil samples for polycyclic aromatic hydrocarbons
(PAHs), volatile petroleum hydrocarbons (VPH), and extractable petroleum hydrocarbons (EPH) analysis. The proposed boring is located where historical data indicate the vadose zone is the most contaminated.
One soil boring will be drilled east of former sample 94-975-BE to assess the lateral extent of residual contamination.
Two soil borings will be drilled to assess current DRO concentrations at historical borings
AP-3675 and AP-3676 where previous sampling showed exceedances of the “migration to
groundwater” criteria for DRO in surface soil.
Up to approximately 26 new primary soil samples will be collected and analyzed for gasolinerange
organics (GRO), DRO, residual-range organics (RRO), and volatile organic compounds
(VOCs) (petroleum-related). Three of those soil samples will also be analyzed for PAHs, EPH,
and VPH.
One of the soil samples will be analyzed for soil bulk density, grain size distribution, specific gravity, and soil moisture content. One of the soil samples will be collected from below the contaminated soil source and analyzed for fraction of organic carbon (foc). |
Louis Howard |
| 5/14/2013 |
Document, Report, or Work plan Review - other |
Sampling Design & Rationale
Page 33
The text states: “If Method One & Method Two criteria are exceeded, the HRC approach under Method Three will be used to assess whether site conditions meet ADEC risk criteria (in which case, a “cleanup complete without ICs” determination will be requested) or whether the site poses unacceptable risk (in which case, remediation, ICs, or both may be required).”
Please note that vadose zone soils shall not exceed MAC 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 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 GW contamination exceeding Table C criteria.
See comment #1 above regarding ADEC’s position on when ICs would be applied at JBER sites.
2nd Bullet
The text states: “The soil exposure point concentrations used as input to the HRC will be either the 95 percent upper confidence limit (UCL) of the samples collected from the contaminated soil source area, or the maximum value of samples collected from the contaminated soil source area.”
Section 5.1 Page 4 of ADEC's " Implementing Guidance for the Method 3 Hydrocarbon Risk Calculator" February 25, 2011 states:
“ADEC recommends a minimum of 10 data points be used to calculate the 95 UCL.
However, responsible parties should bear in mind that even 10 data points may not yield a stable UCL if there is higher than normal heterogeneity in contaminant levels."
Be aware that EPA's ProUCL Version 4.1.00 Technical Guide, Chapter 1 "Use of Statistical Methods as Incorporated in ProUCL 4.0 & Associated Minimum Sample Size Requirements" states:
"Decisions based upon statistics obtained using data sets of small sizes (e.g., 4 to 6 detected observations) cannot be considered reliable enough to make a remediation decision that affects human health & the environment."
Also see 1.7.4 Minimum Sample Sizes for Hypothesis Testing.
Page 35
2nd Bullet
The text states: “Approximately one sample from uncontaminated soils that are representative of the source zone will be analyzed for fraction of organic carbon (foc).”
JBER may collect one foc soil sample for whatever purpose it desires, however, the results for the foc may not be used to derive any cleanup level under the Site Cleanup Rules (Method Three or Method Four). WS #15 states that the foc samples will be collected & analyzed in accordance with ADEC Technical Memorandum 08-002, Guidelines for Total Organic Carbon (TOC) Sample Collection & Data Reduction for Method Three & Method Four.
If JBER is proposing using the foc data for Method Three or Method Four, then the 2008 Technical Memorandum 08-002 Guidelines for Total Organic Carbon (TOC) Sample Collection & Data Reduction for Method Three & Method Four states:
"TOC samples must be collected from a minimum of four (4) borings or test pits adjacent to but outside of the zone of contamination. Soil type(s) analyzed for TOC must be representative of the impacted soil type(s).
It is recommended that the sampling locations be selected at points surrounding (on each side of) the contaminated zone to ensure adequate characterization of the soil TOC variability. If the zone of contamination extends over a significant area, additional samples may need to be collected from the soil horizon below the impacted soils."
TU066-SB03
The text states: “In the event underground utilities or structures cannot be definitively identified, an air knife & vacuum truck may be used to clear the upper 6 feet of the proposed drilling location prior to drilling or conducting other invasive activities. Once clearance activities have been completed in the upper 6 feet of the soil column, soil removed during utility clearance will be placed back into the hole from which it was removed. Drilling or other invasive activities.”
Please note that the 6 ft. interval that has been proposed in other UFP-QAPPs for the air knife shall not be excluded from field screening & sampling requirements due to it being previously removed & replaced during utility investigation activities. ADEC expects in most cases that the U.S. Air Force can definitively identify & locate the utilities at most of the PBR sites for the contractor & the use of the air knife & vacuum truck will be used very infrequent.
|
Louis Howard |
| 6/13/2013 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 73731 name: auto-generated pm edit Ft. Rich Bldg. 975 UST 38 |
Louis Howard |
| 7/22/2013 |
Document, Report, or Work plan Review - other |
ADEC has reviewed the responses to its comments for the UFP-QAPP SC WP and finds the responses acceptable. Please finalize the document. |
Louis Howard |
| 4/24/2014 |
Update or Other Action |
Site Characterization report (draft) received for review and comment.
Conclusions
The following conclusions were made regarding TU066:
• DRO is present in soil above the project screening level at the former wastewater UST source
area and has been adequately characterized to delineate the nature and extent of soil
contamination.
• Groundwater was not encountered during the investigation.
• Concentrations of all detected non-hydrocarbon analytes were below their most stringent 18 AAC 75.341 Method Two, Table B1 cleanup levels; therefore, the site meets the vapor intrusion guidance, and the indoor air pathway is considered incomplete.
• The estimated carcinogenic cumulative risks, assuming industrial and hypothetical residential
land use scenarios are below the ADEC risk standard of 1E-05.
• The cumulative noncancer HI estimates for the future industrial and hypothetical residential
exposure scenarios are below the regulatory risk standard of 1.
• The ADEC risk criteria for bulk hydrocarbons are met.
• Estimated total GRO, DRO, and RRO concentrations in groundwater beneath TU066 are predicted to be below their respective 18 AAC 75.345 Table C cleanup levels.
• No potential risks to ecological receptors were observed for TU066, and potentially complete
ecological exposure pathways at TU066 are considered insignificant.
Recommendations
The following are recommended for TU066:
• No further investigation and/or cleanup of soil and groundwater.
• “Cleanup Complete” designation because TU066 meets the criteria established for site closure (ADEC, 2012a). |
Louis Howard |
| 4/30/2014 |
Cleanup Complete Determination Issued |
Staff assigned a cleanup complete designation for TU066.
Contaminants of Concern
During the 2013 investigation at TU066, the maximum detected levels of diesel range organics (DRO) was 429 (J) mg/kg at 10' to 15' bgs from boring TU066-SB01. This was collected from within the footprint of the former tank excavation at 10 to 15 feet bgs. Groundwater was not encountered and therefore not sampled as part of this investigation. Groundwater occurs at approximately 120 feet bgs.
Cleanup Levels
In accordance with 18 AAC 75.341 (d), Table B2, the cleanup level for DRO at TU066 is based on the ingestion pathway for the under 40" Zone at 10,250 mg/kg.
In accordance with 18 AAC 75.380(d), after reviewing the final cleanup report submitted under this section, ADEC has determined TU066 has been adequately characterized under 18 AAC 75.335 and has achieved the applicable requirements under the site cleanup rules3 for a "cleanup complete" designation. The designation shall be noted in the CS Database.
This written determination does not preclude ADEC from requiring additional assessment, investigation, monitoring, and cleanup4 if future information, site conditions, or new data indicates that action is necessary to protect human health, welfare, safety, or of the environment.
In accordance with 18 AAC 75.325(i) and 18 AAC 75.370(b): A responsible person (the Air Force) shall obtain approval before disposing of soil from a site (TU066)
(1) that is subject to the site cleanup rules, or
(2) for which the responsible person has received a written determination from the department under 18 AAC 75.380(d)(1).
Movement or use of contaminated material in a manner that res11lls in a violation of 18 AAC 70 water quality standards is prohibited. Notations of these requirements shall be made on the Environmental Restoration map/Base General Plan which will show up during a dig permit review /work clearance request process for TU066.
Any person who disagrees with this decision may request an adjudicatory hearing in accordance with 18 AAC 15.195 -18 AAC 15.340 or an informal review by the Division Director in accordance with 18 AAC 15.185, informal review requests must be delivered to the Division Director, 410 Willoughby Avenue, Suite 303, Juneau, Alaska 99801, within 15 days after receiving ADEC's decision reviewable under this section. Adjudicatory hearing requests must be delivered to the Commissioner of the Department of Environmental Conservation, 410 Willoughby A venue, Suite 303, Juneau, Alaska 99801, within 30 days after the date of issuance of this letter, or within 30 days after ADEC issues a final decision under 18 AAC 15. 185. If a hearing is not requested within 30 days, the right to appeal is waived
|
Louis Howard |
| 5/1/2014 |
Institutional Control Record Removed |
Institutional Controls have been removed. |
Louis Howard |
