| 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 |
| 8/15/1997 |
Site Added to Database |
Site added to database by staff. Heating oil contaminated soils. |
Louis Howard |
| 11/15/1997 |
Site Characterization Report Approved |
Release Investigation received and reviewed by staff. Soil contamination is present at 15' 2000 mg/kg DRO. Level C requires 1000 mg/kg DRO at the site. SESOIL/AT123D modeling shows that groundwater at 135' will not be impacted from contamination at the site. Army requests ADEC approval of ACL (2000 mg/kg) for this site. |
Louis Howard |
| 11/24/1997 |
Update or Other Action |
Army draft decision document received.
ALTERNATIVE CLEANUP LEVEL APPROVAL FOR PETROLEUM CONTAMINATED SOILS BLDG 47-022 November 24, 1997
BACKGROUND-Building 47022 is located in the southeast quadrant of the intersection of Randall Road and the Davis Highway. The building was demolished in 1991 and a 1,000 gallon UST was removed in 1997. Cleanup levels using soil matrix would have been level “C” 1000 mg/kg DRO, 500 mg/kg GRO, 50 mg/kg BTEX.
SITE HISTORY-Only one sample for DRO exceeds level C at a maximum detected value of 2,000 mg/kg at 15'. All other samples collected at the site were below level “C” criteria. There are no current human or ecological receptors in the area. The depth to groundwater is estimated to be approximately 135 feet below ground surface.
ISSUE-Army wishes to pursue ACLs for the site based on available information without conducting a leaching assesssment or risk assessment. Analyses were conducted for DRO for the aromatic and aliphatic fractions and the levels detected did not exceed any levels found in table B for either fraction. Maximum values for levels found at 20-25' for aliphatic and aromatic fractions were 43 mg/kg and 12 mg/kg respectively versus the values listed in the table of 20000 mg/kg and 100 mg/kg for the same fractions.
CURRENT STATUS-The surface soils meet cleanup criteria and there are no current or future plans to expose the subsurface soils at the site.
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. Analysis of aliphatic and aromatic fractions show no exceedances of either when compared to values found in table B for Migration to Groundwater in an “under 40 zone”.
RECOMMENDATION-Approve levels as an “alternative cleanup level”.
|
Louis Howard |
| 4/15/1998 |
Conditional Closure Approved |
Soil contamination is present at 15' 2000 mg/kg DRO. Level C requires 1000 mg/kg DRO at the site. SESOIL/AT123D modeling shows that groundwater at 135' will not be impacted from contamination at the site. Army requests ADEC approval of ACL (2000 mg/kg) for this site. Site was briefed to management on 4/10/98 (Roberts and L. Kent) for approval. Concurrence received and all closed out LUSTs to be referenced in final OU D ROD that sites were addressed adequately in the USTMP two party agreement. Soil contamination is to be institutionally controlled in place by Post. |
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 |
Institutional Control Record Established |
Institutional controls (ICs) report received for several sites which include this building. Diesel range organics (DRO) was detected at 2,000 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 closed underground storage tank system sites will need to be referenced in the final Record of Decision (ROD) for the Post (currently OU E). |
Louis Howard |
| 6/6/2012 |
Update or Other Action |
Draft Project Management Plan received for review and comment.
Performance Objective: Site Closure (CRP).
Performance Indicators:
· Complete an approved Characterization/Cleanup Plan by May 2013
· Coordinate, mobilize, and execute characterization/cleanup by September 2013
· Complete an approved Characterization/Cleanup Report by March 2014
· 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 soil as needed (estimate 250 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 Period of Performance.
Date of achieving performance objective: 2nd Quarter 2014.
Planned Approach
Prepare an approved Characterization Workplan. Coordinate, mobilize, and execute Characterization Workplan by installing and sampling two soil borings and collect one hydropunch groundwater sample.
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 reviewed and commented on the draft Project mgt. plan.
2.3
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).
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.
However, if significant work plan revisions are required, additional review and comment resolution time will be needed. To facilitate successful project implementation, it is recommended that DoD project managers and contracting staff:
•Coordinate schedules with ADEC in advance and throughout projects.
•Include ADEC in project planning meetings (DQO meetings, UFP QAPP development meetings, Triad and other Technical Project Planning team meetings, etc.).
• Plan and maintain project schedules that include a minimum of forty-five (45) days for reviewing draft work plans, comment resolution, any necessary revisions to the draft-final version and a final review and approval.
See also the Fort Richardson 1994 Environmental Restoration Agreement “Review and Comment on Documents” which states at Section 9. “All draft final work plans for field work, site assessments or remedial actions (both interim and final) must be submitted to ADEC a minimum of 45 days prior to the start of field work or construction. Site Assessment and Remedial Action draft reports must be submitted to ADEC within 120 days after completion of field work.”
• Review contractor planning documents prior to submission to ADEC to ensure compliance with state and federal regulations consistency with agreements made during project planning meetings.
Independent QA Oversight on Performance Based Contracts
The site cleanup rules require that “collection, interpretation, 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 |
| 2/12/2013 |
Update or Other Action |
Draft UFP-QAPP SC work plan received.
One boring will be drilled near former boring AP-3799 to investigate the nature of residual
contamination at the location of the former UST. The proposed new boring is located where the
vadose zone is interpreted to be contaminated. The soil boring will be advanced using a direct-push technology drill rig to depths up to 25 feet bgs (contamination is expected at 15 feet bgs). Soil samples will be collected at 5-foot intervals to the total depth of the boring. Soil cores will be examined for evidence of hydrocarbons (e.g., staining or odor) and will be screened for organic vapors using a PID.
For this boring, if the maximum vertical extent of the soil contamination (approximately 15 to
20 feet bgs) is reached (based on PID field-screening and visual/olfactory evidence), then two
soil samples will be collected beyond the last evidence of contamination, and the boring will be
terminated. If the boring is advanced to groundwater (not expected at this site), a HydroPunch
groundwater sample will be collected at the water table. However, if visual observations indicate the presence of potential contamination at or near the water table, then monitoring wells may be installed in the soil borings.
Based on field observations and the results of the PID screening, soil samples within each
planned sampling interval throughout the boring will be selected for laboratory analyses. All soil samples (up to five primary samples) will be analyzed for GRO, DRO, RRO, and petroleum-related VOCs.
One boring will be drilled east of former boring AP-3799 to assess the lateral extent of
contamination northeast of the tank.
The soil boring will be advanced using a direct-push technology drill rig to depths up to 25 feet bgs. Soil samples will be collected at 5-foot intervals to the total depth of the boring. Soil cores will be examined for evidence of hydrocarbons (e.g., staining or odor) and will be screened for organic vapors using a PID. Lithologic descriptions, observations of staining or odor, and the results of field screening with the PID will be recorded on borehole log forms.
For this boring, if the soil boring has reached a total depth of 15 feet bgs and soil contamination has not been encountered (based on PID field-screening and visual/olfactory evidence), then two soil samples will be collected beyond the last evidence of contamination.
|
Louis Howard |
| 3/4/2013 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft UFP-QAPP
WS #6 Communication Pathways
Project Scope Changes
The text states: “JBER/AFCEE will inform the WESTON Team Project Manager of any project scope changes.”
ADEC expects JBER project manager or WESTON Team Project Manager to notify ADEC of any project scope changes after the site-specific UFP-QAPP is approved.
Approval of QAPP Amendments
The text states: “Approval of any/all QAPP amendments by AFCEE is required prior to the implementation of any modifications to the QAPP.”
ADEC will review and approve any/all QAPP amendments. This approval by ADEC is required prior to the implementation of any modification to the final ADEC approved site-specific UFP-QAPP.
Recommendations to stop work and initiation of CAs
The text states: “The WESTON Team and AFCEE all have authority to stop work and initiate CAs should any one person believe there is a reason to do so. Whoever stops work or initiates CAs will inform all other interested parties immediately.”
ADEC requests WESTON Team and/or AFCEE or JBER notify ADEC as soon as possible, but not later than 24 hours after such stoppage of work. This notification requirement will apply to activities undertaken in furtherance of this site-specific UFP-QAPP or any other circumstances or activities at the Site are creating an imminent and substantial endangerment to the health or welfare of the people on the Site or in the surrounding area or to the environment. JBER, WESTON Team and/or AFCEE shall provide ADEC with documentation of its analysis in reaching this work stoppage determination within five (5) days of any such stoppage.
Distribution of analytical data
The text states: “The WESTON Team will receive all deliverables from the subcontracted laboratory, review/verify the data, and distribute data to JBER/AFCEE and any other interested parties.”
Per the State/Fort-Richardson Environmental Restoration Agreement-Sampling and Data/Document Availability: 54.
The parties (WESTON/JBER) shall make available to each other (ADEC), quality-assured results of sampling, tests, or other data generated by or on behalf of any party (JBER) under this agreement (site-specific UFP-QAPP) within sixty (60) days of the submittal of samples 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 and twenty (120) days after the submittal of samples to the laboratory. These periods can be extended upon mutual agreement among the project managers (WESTON Team, JBER/AFCEC and ADEC).
WS #10 Conceptual Site Model
Potential Receptors and Exposure Pathways
Page 14
See comment #2 above regarding ADEC’s requirements for ICs.
2nd Paragraph
The text states: “In addition, the site must (1) meet the “migration to groundwater” criteria, which indicate that the dissolution (leaching) of chemicals from soil will not cause groundwater to exceed 18 Alaska Administrative Code (AAC) 75 Table C groundwater criteria for ingestion risk, and (2) concentrations in soil must not exceed the maximum allowable concentrations.”
ADEC also wishes to inform JBER that the vadose zone soils shall not exceed maximum allowable concentrations (MAC) for petroleum contamination for soil from 0 – 15’ bgs (i.e. direct contact for BTEX, PAHs and ingestion for DRO, GRO, RRO) regardless of HRC calculated risk levels. Treatment or excavations deeper than 15’ bgs may be warranted on a site-specific basis to prevent the soil from acting as a continuing source of groundwater contamination above Table C cleanup levels. This comment applies to all future UFP-QAPPs submitted by JBER for review by ADEC.
Last Paragraph
The text states: “There are no drinking water wells in the shallow groundwater at this time.”
ADEC requests JBER provide information (e.g. location and well construction) on the nearest (within ½ mile of Building 47022 site) drinking water [Base] well or standby drinking water well that may be used on a temporary, intermittent or permanent basis. This comment applies to all future UFP-QAPPs submitted by JBER for review by ADEC.
|
Louis Howard |
| 5/3/2013 |
Document, Report, or Work plan Review - other |
ADEC has received the final version of the UFP-QAPP SC Work Plan for Building 47022 TU036 ADEC CS DB Hazard ID 2763 on JBER-Richardson on April 18, 2013. ADEC has reviewed the document and has no further comments on it. The document is approved. |
Louis Howard |
| 6/10/2013 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 73739 name: auto-generated pm edit Ft. Rich Bldg. 47022 UST |
Louis Howard |
| 2/24/2014 |
Update or Other Action |
Site Characterization report (draft) received for review and comment. In June, July, and September 2013, additional activities were conducted to fully characterize the nature and extent of contaminants of potential concern (COPCs) in soil at TU036 and to evaluate potential risks to human health and the environment.
DRO was detected above screening levels and identified as the primary COPC at the site. Although historical source boring location AP-3799 was not specifically replicated in 2013, the results from TU036-SB01 and TU036-SB02 (within 10 feet of AP-3799) suggest that the historical DRO concentrations in the former UST area have a very limited lateral extent to the south, west, north, and northeast. The highest concentration of DRO detected at the site (5,777 mg/kg) was in 1996 from soils beneath the edge of the UST. In 2013, the highest concentration of DRO (3,000 mg/kg) was detected directly east of the location of the former UST, at boring TU036-SB03. DRO was not detected above screening levels in lateral extent borings TU036-SB04 or TU036-SB05.
Based on the results from borings surrounding TU036-SB03, the DRO contamination does not cover a large area, and for purposes of assessing risk from the site, the lateral and vertical extent of DRO in soil has been delineated. The soil source area (defined as the three-dimensional soil
volume with DRO concentrations greater than 250 mg/kg) begins at approximately 10 feet bgs,
extends vertically to approximately 20 feet bgs, and covers an area approximately 54 by 10 feet
(for an approximate volume of 5,400 cubic feet, or 200 cubic yards).
In 1996 and 1997, DRO was detected beneath the former UST at concentrations of
5,777 mg/kg and 2,000 mg/kg, respectively.
• In 2013, DRO was detected in soil at concentrations above project screening levels in one boring to the east of the former UST excavation (TU036-SB03).
• DRO in soil at concentrations above the screening level (250 mg/kg) covers an area approximately 54 by 10 feet and extends from approximately 10 to 20 feet bgs (or an approximate volume of 5,400 cubic feet, or 200 cubic yards). The maximum vertical extent of DRO at the site (20 feet bgs) is approximately 130 feet above the water table.
• Groundwater was not encountered during the investigation.
• The estimated rounded cumulative cancer risk for the current industrial and hypothetical
residential exposure scenarios is below the regulatory risk standard of 1E-05.
• The estimated cumulative noncancer HI for the current industrial and hypothetical residential
exposure scenarios is below the regulatory risk standard of 1. The site meets the ADEC risk
criteria for bulk hydrocarbons.
• No potential risks to the environment/ecological receptors were observed, and petroleum
hydrocarbon contamination in soil is considered insignificant (less than 0.5 acre).
Recommendations for TU036 are as follows:
• No further investigation or cleanup of soil or groundwater.
• ADEC to document an unlimited use and unrestricted exposure or “Cleanup Complete without ICs” designation because the site meets the criteria established for site closure.
Performance-based |
Louis Howard |
| 3/18/2014 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft Site Characterization Report.
Summary of 2013 Site Characterization Activities
The text states: “Five soil borings were drilled by GeoTek Alaska, Inc. to depths ranging from 25 to 35 feet bgs. Twenty-two primary soil samples were collected and submitted to Applied Science Laboratories for analysis of gasoline range organics (GRO), DRO/RRO, petroleum-related VOCs, extractable petroleum hydrocarbon (EPH), volatile petroleum hydrocarbon (VPH), and PAHs.”
Please state here and elsewhere as applicable that Applied Sciences Laboratory (ASL) is the CH2M Hill-Corvalis laboratory, UST-079.
Nature and Extent
The text states: “DRO was detected above screening levels and identified as the primary COPC at the site.”
Please state in the text what screening levels were used (i.e. migration to groundwater cleanup level listed in Table B1). The reader may not know what the basis of the project screening levels are and if they are either the migration to groundwater, direct contact, or the outdoor inhalation cleanup levels.
Risk Evaluation
The text states: “Potential risks to human health and the environment were evaluated within the framework of ADEC’s site cleanup rules.”
The text shall state: “Potential risks to human health and the environment were evaluated within the framework of ADEC’s site cleanup rules under Method Three.”
Environmental/Ecological Risk Evaluation
The text states: “In accordance with ADEC 18 AAC 75.325 and ADEC ecological risk guidance, the site is considered protective of the environment based on the following criteria:…”
Please provide the results of the completed ecological scoping evaluation (Appendix C Ecoscoping Form from ADEC’s January 2012 Ecoscoping Guidance) with preliminary screening which shows that exposure pathways and routes for ecological receptors are incomplete. ADEC has developed a scoping document designed to quickly eliminate sites that are unlikely to pose a risk to the environment. Such sites would exit the ERA process without further evaluation and the evaluation would be in accordance with ADEC ecological guidance.
NOTE: This needs to be done for every site on JBER not under the Fort Richardson Federal Facility Agreement or the Elmendorf Federal Facility Agreement. The results from the Ecoscoping form may be added as an appendix to the document/report.
Soil Sampling
The text states: “Table 3-1 presents a summary of the soil samples collected during the 2013 investigation and submitted to Applied Sciences Laboratory (ASL)...”
Please state here and elsewhere as applicable that Applied Sciences Laboratory (ASL) is the CH2M Hill-Corvalis laboratory, UST-079.
The text states: “Four types of field quality control (QC) samples were also collected to meet data quality standards: three FDs, one matrix spike/matrix spike duplicate (MS/MSD), two equipment blanks (EBs), and three trip blanks (TBs) were submitted for analysis. While the field QC samples for TU036 alone do not meet the required frequency for FDs according to the data quality evaluation (DQE), the work at this site was performed as part of a larger program, and overall the program meets the QC requirements outlined in the Basewide QAPP (USAF, 2013a).”
ADEC disagrees. The site specific UFP-QAPP field quality controls as agreed to in the final work plan UFP-QAPP for each site shall be applicable. The fact that the work is being performed as part of a larger program has no bearing on complying with QC requirements for a specific site’s QA requirements. |
Louis Howard |
| 6/4/2014 |
Cleanup Complete Determination Issued |
Cleanup complete determination given for the site by ADEC.
The cleanup level for the site containing DRO contamination in the Under 40-Inch Zone for the ingestion pathway is 10,250 mg/kg for soil. Migration to groundwater soil cleanup levels are not applicable in this circumstance, because groundwater is not likely to be impacted by petroleum contamination, based on the depth to groundwater (150 feet below ground surface) and maximum depth of contamination (20 feet below ground surface).
Based on a review of the environmental records, ADEC has determined that TU036 has been adequately characterized and has achieved the applicable requirements under the site cleanup rules. ADEC is issuing this written determination that cleanup is complete, subject to a future department determination that the cleanup is not protective of human health, safety, welfare, or of the environment [18 AAC 75.380(d)]. A “Closed” designation will be entered for TU036 in the Contaminated Sites Database, subject to the following standard conditions. |
Louis Howard |
| 6/9/2014 |
Institutional Control Record Removed |
Institutional Controls have been removed. |
Louis Howard |
