| Action Date |
Action |
Description |
DEC Staff |
| 9/21/1993 |
Update or Other Action |
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 |
| 9/12/1994 |
Update or Other Action |
Building 47-203 is located near Randall Road. Building 47-203 was previously used as an aviation motor pool.
A 1,000-gallon fuel oil UST (Tank 93) was installed on the northwest side of Building 47-203. Tank 93 was nine feet one-inch long and three feet 10 inches in diameter. It had a two-inch vent pipe and a four-inch fill pipe. Both pipes extended three feet above the ground. This UST was installed approximately five feet below ground and had no surface dispensers.
This UST (Tank 93) was removed in June 1994. In conjunction with the removal, five soil samples and Quality Assurance (QA) Quality Control (QC) soil samples were collected to determine if the soil was contaminated with petroleum hydrocarbons. Up to 12,000 mg/Kg diesel range organics (DRO) were found in the soil surrounding the tank. |
Louis Howard |
| 9/28/1994 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Site Assessment report, Bldg 47203, Former UST 93 Facility No. 0-00788 July 13, 1994
The Alaska Department of Environmental Conservation-Defense Facilities Oversight group (ADEC) has received, on September 12, 1994 a copy of the above referenced report. Below are ADEC's comments.
5.2 Discussion page 11
The text states the cleanup criteria is level C, however the factor used for mean annual
precipitation appears to be incorrect. Based on information from other consultants' reports at Fort Richardson the annual precipitation has been calculated to be approximately 13 to 20 inches per year (Univ. of AK, Anchorage, Environmental Atlas ... 1972). This correction would result in a reclassifying of the cleanup score to 20 or a level "D" cleanup. Even with this correction the results from the laboratory analysis indicate contamination to be well above this level.
5.3 Conclusion and Recommendations page 11
The text states levels detected in the soil under the tank indicated tank 93 has leaked and
the maximum detected level of DRO is 12,000 ppm. This level is in excess of level D cleanup criteria. Further action is still required by the Army to delineate the vertical and horizontal level and extent of petroleum hydrocarbon contamination in soil and groundwater at each site. ADEC looks forward to receiving the draft release investigation work plan with schedules of action for review and comment by January 1995. |
Louis Howard |
| 12/15/1995 |
Document, Report, or Work plan Review - other |
ADEC (Tim Stevens) sent a letter Sent to Sam Swearingen (Army) Waiver No. #A 001 RE: Waiver From Requirement to Use AK 101, AK 102, or AK 103 Analytical Procedures For Hydrocarbon Analyses
This waiver is issued to allow the above named person or firm to avoid the requirement to analyze soil samples in accordance with analytical methods AK 101, AK 102 and AK 103 for the specific project listed below. The waiver further specifies that analytical methods specified below shall be used for the project, with slight modifications in integration ranges.
This letter, when signed with an original signature by the appropriate Department official, will serve as a waiver solely from the portion of the following regulations that refer to use of analytical methods AK 101, AK 102, and AK 103: 18 AAC 78.090(e), 18 AAC 78.235(b), 18 AAC 78.300(c), and 18 AAC 78.312(f)(2) requiring the use of analytical methods AK 101, AK 102, and AK 103 for analysis of hydrocarbons in soils, and from 18 AAC 78.315(d)(3) specifying the integration range for analysis of residual range organics, and only for the specific project listed as follows:
Underground storage tank release investigation, in association with buildings 47-203, 955, 979, 45-070 and 28-008 at Fort Richardson Alaska.
Note that all other portions of these regulations cited must be adhered to, including the requirements to take samples for petroleum hydrocarbons and for data collection and interpretation by a qualified, impartial third party in accordance with the UST Procedures Manual.
The conditions for issuance of this waiver are:
1. During the waiver period, laboratory analyses performed in support of activities regulated by 18 AAC 78, ADEC Underground Storage Tank Regulations, must be performed by a laboratory that is approved by the Department. Further, the analytical methods used for soil and water analyses for gasoline range, diesel range, and residual range petroleum hydrocarbons must be:
a) for gasoline range hydrocarbons, EPA method 8015 Modified, and integrated from the beginning of C6 to the beginning of C10 and a boiling point range between approximately 60oC and 170oC;
b) for diesel range hydrocarbons, EPA method 8100 Modified, and integrated from the beginning of C10 to the beginning of C25 and a boiling point range between approximately 170oC and 400oC;
c) for residual range hydrocarbons, the analytical measurement for the total concentration of petroleum hydrocarbons as derived by using EPA method 418.1, minus the concentration quantified in the gasoline range and diesel range (the ranges listed in a) and b) above).
2. Subject to Condition 3, this waiver becomes void on the effective date of Underground Storage Tank Regulations containing updated procedures for AK 101, AK 102, and AK 103 hydrocarbon analyses revised after November 3, 1995. Thereafter, or beginning August 1, 1996, whichever occurs first, the recipient of this waiver must conform to the requirements of those updated procedures or to the analytical procedures promulgated in the November 3, 1995 version of the regulations, whichever is applicable.
3. This waiver becomes void if the Department, in its discretion, issues a 30 day notice of its intent to revoke this waiver.
4. Because use of the new analytical methods may increase yields from analyses, the person or firm receiving this waiver is advised to plan for the transition to the new methods when considering actions involving the specific project listed above.
cc: Marliyn Plitnik DOWL Engineers. |
Tim Stevens |
| 10/31/1996 |
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.
All work performed under this contract complied with the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) and the Federal Facility Agreement (FF A) entered into in 1994 by the Army, the EPA and ADEC. A waiver has been issued by ADEC exempting all work conducted during the Remedial Investigations from the analytical requirements specified in 18 AAC 78.090(e), 18 AAC 78.235(b), 18 AAC 78.300(c), 18 AAC 78.312(f)(2), and 18 AAC 78.315(d)(3).
The purpose of the RI was to define the nature and extent of petroleum hydrocarbon releases at 47-203.
Five soil borings were drilled from March 13, 1996 to March 15, 1996, using a hollow-stem auger drill rig. Four were to a depth of 35' bgs and one boring was to 40' bgs. A total of 36 soil samples and five QNQC soil samples were collected and sent to the laboratory for analysis. One ground water monitoring well, AP-3696, was drilled to 160' bgs and installed on April 11 and 12, 1996. The boring was backfilled to 140 feet and then completed as a well. AP-3696 was located downgradient of the site. One ground water sample was collected and sent to the laboratory for analysis. No analytes were detected above the detection limit.
A fuel oil UST was removed in June 1994. Sampling results from the soil surrounding the tank. during removal determined the soil was contaminated with petroleum hydrocarbons. Based on this information, soil and water samples collected were analyzed for BTEX, GRO, and DRO. Four soil samples were analyzed for semi-volatile organic compounds (SVOCs) and two samples were analyzed for total organic carbon (TOCs).
SOIL Results
AP-3664: 20' bgs DRO 820 mg/kg
AP-3666 15' bgs DRO 4,600 mg/kg, 20' bgs 2,800 mg/kg, 25' bgs 3,800 mg/kg, 30' bgs 7,400 mg/kg (DRO concentrations are increasing with depth)
AP-3667 1' bgs 480 mg/kg, 20' bgs 3,400 mg/kg, 25' bgs 4,700 mg/kg, 30' bgs 960 mg/kg
AP-3668 30' bgs 350 mg/kg
Groundwater was encountered at approximately 135 feet bgs. No detections were found in monitoring well AP-3696 drilled just north of AP-3666.
The sampling results for Building 47-203 indicate soil contaminated with DRO primarily around AP-3666 and AP-3667. The actual extent of the contamination was not determined since levels near or in excess of 100 mg/Kg of DRO were found in all borings. The contaminant levels decrease in the direction of AP-3665 from AP-3666 and also in the direction of AP-3668 from AP-3666.
Levels of metals detected in the samples are within the background range for Fort Richardson. Review of the sampling results indicate the highest concentrations of contaminated soil occur between 15 to 30 feet bgs. Approximately 30 to 35 feet bgs a more silty interval was encountered. This siltier interval may be acting to slow diesel migration in the vertical direction and allowing it to spread horizontally. Surface contamination (0-12 inches) was encountered in borings AP-3667 and AP-3668, but this could be due to the use of the lot for parking and vehicle storage.
The matrix score for Building 47-203 is 26, or Category C. This requires the following soil clean-up levels:
DRO 1,000 mg/Kg
GRO 500 mg/Kg
RRO/TPH (TRPH) 2,000 mg/Kg
Benzene 0.5 mg/Kg
BTEX 50 mg/Kg
Recommendations
Contaminated soils were found to a depth of 30 feet; therefore, excavation does not appear to be a cost effective option. Contamination levels in excess of clean-up criteria were not found below 30 feet. ADEC allows for the establishment of alternative clean-up levels based on the results of a leachability assessment, provided no ground water is contaminated, or a risk assessment if ground water is contaminated or has the potential to become contaminated at levels in excess of acceptable vales.
The depth to ground water and the soil characteristics which suggest a "tighter", siltier soil interval at approximately 30 to 35 feet support the performance of a Leachability Analysis (as outlined in 18 AAC 78.310 and 78.350) for the vadose zone to establish whether or not the ground water will be impacted as a result of the present contamination. Based on the results of the leachability analysis, alternative clean-up levels can be established. |
Louis Howard |
| 2/17/1997 |
Site Added to Database |
Heating oil contaminated soils. |
Louis Howard |
| 11/15/1997 |
Site Characterization Report Approved |
Release investigation received and reviewed by staff. Soil diesel range organics (DRO) contamination present at site, maximum concentration 7,400 mg/kg DRO (BTEX, PAHs, RRO, GRO, VOCs analyzed also ND or below Reg. III RBCs). SESOIL fate and tranport modeling conducted using conservative parameters 100 year runs no impacts to groundwater above maximum contaminant levels (MCLs) for any constituents or not reach it at all. Army requests closure and approve alternative cleanup levels (ACLs) for site. |
Louis Howard |
| 11/24/1997 |
Update or Other Action |
Army draft decision document received. ALTERNATIVE CLEANUP LEVEL APPROVAL FOR PETROLEUM CONTAMINATED SOILS BLDG 47-203 November 24, 1997
BACKGROUND-Building 47-203 is currently not in use. The Alaska Army National Guard plans to have the building razed in the near future and return the location to a natural state. Cleanup levels using soil matrix would have been level “C” 1000 mg/kg DRO, 500 mg/kg GRO, 50 mg/kg BTEX.
SITE HISTORY-The soil was a former UST used for heating fuel (diesel) storage which was removed in 1994. Only DRO exceeds level C at a maximum detected value of 7,400 mg/kg at 30'. The extent of contamination which exceeds 1,000 mg/kg DRO is found from 15' to 30' at depth. Surface contamination at the site is well below level “A” criteria. There are no current human or ecological receptors in the area. Groundwater monitoring well on site has not detected any contamination from the site. The depth to groundwater is 135 feet below ground surface.
ISSUE-Modeling to determine if contamination at the site could potentially impact groundwater. Benzene, napthalene, and flourene were selected for use in SESOIL and AT123D because they represent the most mobile of the aromatic additives associated with arctic diesel. Results from the modeling show that using the highest sample results for DRO at the site, no significant groundwater contamination will occur.
CURRENT STATUS-The surface soils meet cleanup criteria and there are no current or future plans to expose the subsurface soils at the site. This leaves pathways associated with groundwater contamination. A modeling effort has shown that contaminants associated with DRO by means of a surrogate review do not pose a threat to groundwater.
ALTERNATIVES CONSIDERED-None. Propose closeout via ACLs.
ALTERNATIVE SELECTED/BASIS-No further action close out site. Levels of contaminants are below levels that are proposed in the 18 AAC 75 draft regs for maximum allowable concentrations 12,500 mg/kg total C10-C25 and Benzene or total BTEX does not come close to exceeding level “A” criteria.
RECOMMENDATION-Approve levels as an “alternative cleanup level”. |
Louis Howard |
| 4/15/1998 |
Update or Other Action |
Institutional controls established in the form of a dig permit reviewed by Public Works Environmental staff on Post for any work in this area. Mapped out site on Post general management plan as a site with institutional controls. |
Louis Howard |
| 4/15/1998 |
Cleanup Complete Determination Issued |
Maximum diesel range organics (DRO) soil concentration 7,400 mg/kg DRO (BTEX, PAHs, RRO, GRO, VOCs analyzed also ND or below Reg. III RBCs). Sesoil modeling conducted using conservative parameters 100 year runs no impacts to groundwater above MCLs for any constituents or not reach it at all. Army requests closure and ACLs for site. Site was briefed to management for ACL closure on 4/10/1998. Concurrence received and site approved for closure. Site must be wrapped up in final OUD ROD for Post along with all closed LUST sites by reference that they were addressed by USTMP two party agreement. Soil contamination at site must have institutional controls placed on it and if excavated in future will be remediated to appropriate cleanup levels.
The following policy applies for soil regulated under 18 AAC 75 and 18 AAC 78 that is proposed for disposal off site from where it was generated. If the following criteria is met, ADEC approval and/or an institutional control(s) are not required: 1. The soil meets the most stringent Method Two, Migration to Groundwater, Table B2 cleanup level, and the most stringent standards for those chemicals under Table B1; 2. The soil may only be disposed of at any non-environmentally sensitive location in the Under 40" or Over 40" annual precipitation zone;
3. The soil is not placed within 100 feet of water wells, surface waters, and drainage ditches; and 4.The written approval from the landowner of the off-site location is required.
The off site disposal of all other soil subject to the site cleanup rules that does not meet the criteria above shall be reviewed by the ADEC project manager in order to determine if the off-site disposal action poses a current or future risk to human health or the environment. The final approval to dispose of soil off site that does not meet the criteria shall be made by ADEC.
Terms used in this document have the meaning given in 18 AAC 75.990 including: “environmentally sensitive area” means a geographic area that, in the department's determination, is especially sensitive to change or alteration, including:
(A) an area of unique, scarce, fragile, or vulnerable natural habitat;
(B) an area of high natural productivity or essential habitat for living organisms;
(C) an area of unique geologic or topographic significance that is susceptible to a discharge;
(D) an area needed to protect, maintain, or replenish land or resources, including floodplains, aquifer recharge areas, beaches, and offshore sand deposits;
(E) a state or federal critical habitat, refuge, park, wilderness area, or other designated park, refuge, or preserve; and
(F) an area that merits special attention as defined at 6 AAC 80.170 (Repealed see AS 46.40.210(1))
“area which merits special attention” means a delineated geographic area within the coastal area which is sensitive to change or alteration and which, because of plans or commitments or because a claim on the resources within the area delineated would preclude subsequent use of the resources to a conflicting or incompatible use, warrants special management attention, or which, because of its value to the general public, should be identified for current or future planning, protection, or acquisition; these areas, subject to council definition of criteria for their identification, include:
(A) areas of unique, scarce, fragile or vulnerable natural habitat, cultural value, historical significance, or scenic importance;
(B) areas of high natural productivity or essential habitat for living resources;
(C) areas of substantial recreational value or opportunity;
(D) areas where development of facilities is dependent upon the utilization of, or access to, coastal water;
(E) areas of unique geologic or topographic significance which are susceptible to industrial or commercial development;
(F) areas of significant hazard due to storms, slides, floods, erosion, or settlement; and
(G) areas needed to protect, maintain, or replenish coastal land or resources, including coastal flood plains, aquifer recharge areas, beaches, and offshore sand deposits. |
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 |
| 7/2/1998 |
Update or Other Action |
Updated USARAK institutional control policies and procedures received. The draft USARAK Command Policy Memorandum, ICs standard operating procedure and revised excavation clearance request have been finalized. To ensure the effectiveness of institutional controls, all organizational units and tenant activities will be informed on an annual basis of the institutional controls on contaminated soils and groundwater in effect on USARAK property. Where institutional controls are applicable to any organization, tenant, or activity, land use restrictions shall be incorporated into either a lease or Memorandum of Agreement, as appropriate. Costs for any and all remedial actions and fines and/or stipulated penalties levied as a result of a violation of an established institutional control shall be funded by the violating activity or organization. |
Louis Howard |
| 9/14/2001 |
Update or Other Action |
Institutional controls report received for several sites which include this building. DRO was detected up to 7,400 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).
This site as well as all other UST sites will need to be referenced in the final Record of Decision (ROD) for the Post (currently at OU E). |
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 |
| 7/24/2004 |
Update or Other Action |
Institutional controls established in the form of a dig permit reviewed by Public Works Environmental staff on Post for any work in this area. Mapped out site on Post general management plan as a site with institutional controls. |
Louis Howard |
| 6/6/2012 |
Update or Other Action |
Draft Project Management Plan received for review and comment.
Performance objective
Site Closure
Performance Indicators
• Complete an approved Site Characterization WP/Cleanup Plan in 2013
• Complete characterization/cleanup in 2013
• Complete an approved Site Characterization/Cleanup Report in 2013
• Achieve SC in 2014
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 additional soil as needed (estimate an additional 250 yd3) to achieve SC. Additional
monitoring wells will be installed, as necessary, 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.
2nd Quarter FY 2014
Prepare an approved Characterization Workplan. Coordinate, mobilize, and execute characterization Workplan by installing and sampling two soil borings 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 Cleanup Report including 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 |
| 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, Alaska Administrative Code Chapter 75 [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, then 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 boring AP-3666 to resample the soil at the location and depth where previous sampling showed exceedances of the migration to groundwater criteria for diesel-range organics (DRO) and to collect source area soil samples for volatile petroleum hydrocarbons (VPH) and extractable petroleum hydrocarbons (EPH) analysis.
Four borings will be drilled around the former tank to assess the lateral extent of soil
contamination.
Up to approximately 37 new primary soil samples will be collected and analyzed for gasoline-range organics (GRO), DRO, residual-range organics (RRO), volatile organic compounds (VOCs) (petroleum-related), and polycyclic aromatic hydrocarbons (PAHs). Three of those soil samples will also be analyzed for EPH and VPH. One of the soil samples will be analyzed for soil bulk density, grain size distribution, specific gravity, and soil moisture content. All the samples analyzed for VOCs (petroleum-related), GRO, DRO, RRO, PAHs, EPH, VPH, and other soil properties will be from the interpreted extent of the nonaqueous phase liquid (NAPL) contaminated soil source. One of the soil samples will be collected from below the contaminated soil source and analyzed for fraction of organic carbon (foc). |
Louis Howard |
| 5/15/2013 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the draft UFP-QAPP for TU069.
Conceptual Site Model
Page 18
Potential Receptors and Exposure Pathways
The text states: “In addition, the HRC can calculate risk for the pathways that are complete at the present time for residential, industrial/commercial, and site visitor scenarios. The risks calculated for the “currently complete pathways” and for industrial and site visitor scenarios are for risk management purposes.”
Results of the HRC calculations for petroleum hydrocarbons are applicable only for those alternative cleanup levels allowed by regulation for Method Three - 18 AAC 75.340(e):
Under method three, a responsible person may propose a site-specific alternative cleanup level that modifies
(1) the migration to groundwater or inhalation levels in Table B1 of 18 AAC 75.341(c) or Table B2 of 18 AAC 75.341(d), based on the use of approved site-specific soil data, and the equations set out in the department’s Cleanup Levels Guidance, dated June 9, 2008, adopted by reference; the alternative cleanup level that then applies at the site for a hazardous substance is the most stringent of the Table B1 direct contact or Table B2 ingestion level and the site-specific calculated levels for inhalation or migration to groundwater;
(2) the migration to groundwater levels in Table B1 or Table B2 based on approved site-specific soil data and an approved fate and transport model that demonstrates that alternative soil cleanup levels are protective of the applicable groundwater cleanup levels under 18 AAC 75.345 if the alternative migration to groundwater cleanup level does not exceed
(A) the direct contact level in Table B1 or the ingestion level in Table B2;
(B) the inhalation level in Table B1 or Table B2; or
(C) a site-specific inhalation level calculated under (1) of this subsection; the level that applies at the site is the most stringent level; or
(3) the direct contact level or the inhalation level in Table B1 or the ingestion level or the inhalation level in Table B2 based on use of commercial or industrial exposure parameters listed in Appendix B of the Cleanup Levels Guidance, adopted by reference in (1) of this subsection, if the department determines that the site serves a commercial or industrial land use, and if the alternative direct contact level or inhalation level does not exceed the migration to groundwater cleanup level in Table B1, the alternative ingestion level or inhalation level does not exceed the migration to groundwater cleanup level in Table B2 or the alternative level does not exceed a site-specific migration to groundwater level calculated under (2) of this subsection.
The Site Cleanup Rules for Method Three do not allow for changes to Table C groundwater cleanup levels or calculation of risk based groundwater cleanup levels. ADEC will not recognize the use of HRC for calculation of risk of groundwater contamination at TU069 or any site on JBER-E or JBER-R, except through the use of Method Four [risk assessment as allowed by 18 AAC 75.325(h)]. Therefore, Table C Groundwater Cleanup levels will apply at all JBER sites with no alternative or “risk-based” groundwater cleanup levels allowed via Method Three (e.g. HRC). Where the HRC guidance and user manual conflict with existing promulgated regulations, the regulations will be applicable and supersede or override any guidance, manuals or technical memoranda.
The text states: “There are no drinking water wells located within a half mile of TU069”
ADEC assumes that there is not any groundwater well(s) within a ½ mile radius of TU069 used to supply water including, but not limited to: irrigation, fire control, dust control, or any other activity on a temporary, intermittent or permanent basis.
The text states: “… if impacts cover less than a half acre, ecological impacts are considered negligible and do not require assessment.”
The ADEC Ecoscoping Guidance for “Scoping Factor 4: Contaminant Quantity states:
“This off-ramp does not apply to potentially impacted aquatic media. Nor does it apply if endangered-, threatened-, or species of special concern are present.”
ADEC assumes that there is no potential for impacted aquatic media or any endangered, threatened species, species of greatest conservation need (FYI: ADF&G no longer maintains a list of “species of special concern” instead see the 2006 Wildlife Action Plan, specifically, Appendix 7 at http://www.adfg.alaska.gov/index.cfm?adfg=species.wapview), or any non-petroleum contaminants present at TU069. If the answer is “yes” for any of these, then JBER needs to proceed to toxicity determination step (Scoping Factor 5) in the guidance.
|
Louis Howard |
| 6/10/2013 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 73732 name: auto-generated pm edit Ft. Rich Bldg. 47203 UST 93 |
Louis Howard |
| 7/22/2013 |
Document, Report, or Work plan Review - other |
The responses to ADEC's comments on the draft UFP-QAPP for TU069 are acceptable. Please finalize the document. |
Louis Howard |
| 4/24/2014 |
Update or Other Action |
SC report (draft) received for review and comment.
In 2013, DRO was measured in concentrations up to 11,400 mg/kg at source area boring TU069-SB01 (adjacent AP-3666) at a depth of 10 to 15 feet bgs.
Conclusions
The following conclusions were made regarding TU069:
• There appears to be two sources of contamination at the site: (1) subsurface leaks and spills
associated with the former UST, and (2) a TCE source south of the former UST.
• Based on previous investigations and the 2013 site characterization field investigation at the
former UST, DRO, GRO, PAHs, petroleum-related VOCs, and TCE were detected in soil at concentrations above project screening levels. DRO was the most frequently detected COPC with the highest concentrations and the largest lateral and vertical extent.
• DRO in soil at concentrations above the screening level (250 mg/kg) at the former UST, covers an area approximately 90 feet long by 60 feet wide, reaching a depth of approximately 30 feet bgs, for an estimated volume of 162,000 cubic feet (6,000 cubic yards).
• GRO, several PAHs (1-methylnaphthalene, 2-methylnaphthalene, and dibenz(a,h)anthracene), and several petroleum-related VOCs (1,2,4-trimethylbenzene, 1,3,5-trimethylbenzene, n-butylbenzene, naphthalene, and total xylenes) were detected in source area boring TU069-SB01 above their respective screening levels.
Dibenz(a,h)anthracene was detected above its screening level in TU069-SB01 at the same depth interval as the second highest detected concentration of DRO/GRO at TU069-SB01. GRO and the remaining PAHs and VOCs mentioned above were detected above screening levels at a slightly deeper interval at TU069-SB01 reported to contain the third highest detected DRO concentration. Although these compounds were only detected in two samples and appear to be related to the high DRO concentrations detected at the site, these COPCs are also laterally and vertically contained within the area of the highest concentration of DRO.
• Two low-level detections of TCE in TU069-SB05 (0.0634 mg/kg from 5 to 10 feet bgs and 0.0613 mg/kg from 10 to 15 feet bgs) were reported above its screening level (0.020 mg/kg). TCE was not detected in any other site samples and was not associated with DRO at these sample locations approximately 55 feet away from the former UST location, indicating the likelihood of a small separate source not related to leaks from the UST.
• The potential future indoor air exposure pathway for the former UST source area is considered incomplete because even though dibenz(a,h)anthracene was detected above its the most stringent 18 AAC 75.341, Method Two, Table B1 cleanup level (direct contact) (WESTON, 2013), dibenz(a,h)anthracene is not considered a COPC for indoor air (ADEC, 2012a). All remaining VOC concentrations detected in soil above the most stringent 18 AAC 75.341, Method Two, Table B1 cleanup levels are located greater than 7 feet below a hypothetical basement foundation where biodegradation would act as a sufficient barrier to eliminate petroleum vapor intrusion risk.
• Using the HRC for petroleum-contaminated soil with the former UST source area, the cumulative carcinogenic risk and noncarcinogenic HI estimates, based on both industrial and hypothetical residential exposure scenarios, are below the regulatory risk standards.
• Using the HRC for petroleum-contaminated soil with the former UST source area, the ADEC risk criteria for bulk hydrocarbons are met.
• The sitewide exposure risk for TCE under current conditions is below the ADEC risk criteria
based on ADEC’s Method Three online calculator. However, under the potential future exposure scenario, the indoor air pathway (vapor intrusion) still needs to be evaluated because the TCE concentration in soil is above its most stringent 18 AAC 75.341, Method Two, Table B1 cleanup level.
• No potential risks to ecological receptors were observed for TU069, and potentially complete
ecological exposure pathways at TU069 are considered insignificant.
Recommendations
The following are recommended for TU069.
Former UST
• No further investigation or cleanup of soil and groundwater associated with the former UST.
• “Cleanup Complete” designation because TU069 meets the criteria established for site closure (ADEC, 2012c).
Area Outside Former UST
• Designation of a new site to further characterize the nature and extent of TCE in soil. |
Louis Howard |
| 4/29/2014 |
Cleanup Complete Determination Issued |
Staff provided a cleanup complete determination for the petroleum contamination associated with TU069. However, the TCE contamination needs to be addressed by JBER.
Contaminants of Concern
During the 2013 investigations at TU069 which had a former fuel/heating oil tank. The highest detected concentrations of DRO was 11,400 mg/kg (boring TU069-SB01 from 10 to 15 feet bgs) GRO at 355 mg/kg 15 to 20’ bgs in the same boring. Groundwater was not found to contain levels of contamination above Table C. Groundwater occurs at approximately 126 feet bgs. Low-level concentrations of trichloroethene (TCE) (0.0634 and 0.0613 mg/kg) were detected in soil from 5 to 15 feet bgs in lateral extent boring TU069-SB05. ADEC concurs that the TCE is likely not associated with the former UST and is a new source that needs to be addressed separately.
Cleanup Levels
In accordance with 18 AAC 75.341(d), Table B2, the cleanup level for DRO at TU069 is based on the ingestion pathway for the under 40” Zone at 10,250 mg/kg and for GRO based on the ingestion, outdoor inhalation pathways and maximum allowable concentration of 1,400 mg/kg. TCE contamination located approximately 55’ to the south of the former UST shall be investigated and addressed as a separate issue than the petroleum release associated with UST 93.
In accordance with 18 AAC 75.380(d)(1), after reviewing the final cleanup report submitted under this section, ADEC has determined the petroleum release associated with TU069 has been adequately characterized under 18 AAC 75.335 and has achieved the applicable requirements under the site cleanup rules for a “cleanup complete” designation for the petroleum release associated with UST 93.
This written determination for the petroleum release associated with UST 93 at TU069 does not preclude ADEC from requiring additional assessment, investigation, monitoring, and cleanup if future information, site conditions, or new data indicates that action is necessary to protect human health, welfare, safety, or of the environment. The TCE contamination will need to be addressed under a new site number designation besides TU069. Until such time, TU069 shall remain open due to the unresolved TCE contamination.
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 (TU069)
(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 results 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 TU069.
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 Avenue, 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 |
| 12/3/2019 |
Update or Other Action |
Incorporation of SS 125 - East Randall Road Former Building 47203 into the JBER-Richardson
(JBER-R) Federal Facility Agreement (FFA) SS125 - East Randall Road Former Building 47203 is located on the east side ofE Randall Road about one quarter mile south of Davis Highway. During investigation for site close-out in 2013, trichloroethene (TCE) was identified (up to 0.0634 mg/kg at a depth of 5 to 15 ft bgs) above the screening level of 0.020 mg/kg in soil in an located 55 feet south of the TU069 former UST location and within the footprint of former Building 47203.
The TCE contamination was determined to not be associated with TU069 site and therefore was not investigated further at the time. In 2014 the ADEC approved cleanup complete for the petroleum release associated with the UST (TU069) but requested a new site ID (SS 125) be opened to address the TCE contamination.
Based on site-specific information indicating that CERCLA contaminants are present in the soil [Trichlorethylene], the Project Managers agree that SS 125 - East Randall Road Former Building 47203 will be incorporated into the JBER-R FF A as a new site [SS125] subject to the stipulations listed in the FFA, including Attachment 1.
FFA Doc Type, Document & Due date for agency reviews:
Primary Draft RI/FS Management Plan 8/30/2021,
Secondary Draft RI Report 8/30/2022,
Secondary Draft FS Report 8/30/2023,
Secondary Draft Proposed Plan 2/28/2024.
Primary Draft Record of Decision 2/28/2025 |
Louis Howard |
| 12/4/2019 |
Site Reopened |
Site conditions changed since cleanup complete action: TCE found in soil above cleanup levels. |
Louis Howard |
| 4/2/2020 |
Meeting or Teleconference Held |
Conference call scoping meeting held with EPA, ADEC, JBER and contractor. 3 soil borings to be advanced within suspected source areas to fully characterize subsurface soil contamination and delineate vertical extent of contamination. 1 near previous detection within center of vehicle bay at former Building 47203, possible location of dry well (no documentation of dry well found). 1 outside man-door exiting vehicle bay. 1 outside vehicle bay door.
8 soil borings will be advanced beyond suspected source areas to delineate lateral extent of subsurface contamination. 3 upgradient of suspected source areas. 2 downgradient of suspected source areas. 3 cross-gradient of suspected source areas. 3 of the 11 soil borings completed as flush-mount monitoring wells to be sampled in the summer and in the fall (~90 days apart).
One well located upgradient of suspected source areas. One new well within suspected source area to characterize nature of groundwater contamination. One new well cross-gradient of suspected source areas to delineate extent of contamination. Existing well (AP-3696) downgradient of suspected source areas to delineate extent of contamination. |
Louis Howard |
| 12/1/2021 |
Document, Report, or Work plan Review - other |
DEC provided comments on SS125 Draft RI Report |
William Schmaltz |
| 6/23/2022 |
Document, Report, or Work plan Review - other |
DEC completed review of USAF response to comments on RI Report. |
William Schmaltz |
