| 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 |
| 11/12/1993 |
Enforcement Agreement or Order |
State-Fort Richardson Underground Storage Tank Compliance Agreement signed by ADEC and U.S. Army. Purpose of the agreement is to bring Fort Richardson into compliance with 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 the Alaska Department of Military and Veterans Affairs and Army National Guard USTs).
Site Assessment or Svstem Tirrhtness 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 78400. 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 Reoorts
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)
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.
See site file for additional information. |
Janice Adair |
| 7/31/1995 |
Update or Other Action |
APVR-RPW-EV 31 July 1995 MEMORANDUM FOR Ellen Klug, Alternate Contracting Officer, JOC
SUBJECT: Drums and Related Contaminated Soils at Building 772 from Sam Swearingen, Environmental Scientist.
1. In discussion with BRSC and with Bernie Miller on Friday, 21 July 1995, it appears that 4
drums of dry cleaning solvent were found buried on top of UST 130 at building 772 during
excavation. Further, one of the drums was crushed during removal contaminating approximately
30 cubic yards of soil, which BRSC had the sub-contractor excavate and stockpile seperately
from the POL contaminated soils.
2. I need BRSC to have their sub-contractor, Oil Spill Consultants, take samples of the
remaining three (3) drums, and have a waste management profile conducted on them, with the
quickest turn-around time possible. I estimate that the analysis will cost approximately $3,000 to $4,000. Further, I need the soil sampled for the same thing. Two to three samples of the soil
should be analyzed. 1 estimate this will cost another $3,000 to $4,000. |
Louis Howard |
| 8/2/1995 |
Update or Other Action |
Letter from the Dept. of The Army, Albert J. Kraus, Colonel, Director of Public Works to ADEC (L. Howard). Attached find soil results for the overburden and excavation created during removal of underground storage tank (UST) 130 at building 772, the backup power plant, on Fort Richardson. The results indicate that diesel range organics (DRO) are all below level C cleanup levels except for samples 95FTR-772-130-181, an overburden sample, and sample 95FTR-772-130-184, a sample from the excavation sidewall. These showed DRO contamination of 1,730mg/kg
and 1,170 mg/kg respectively.
Approximately 350 cubic yards of soil was generated during the excavation. Public Works is requesting approval to use the overburden as backfill, prior to obtaining the site assessment. If the site assessment-requires a release investigation then one Will be initiated, and a corrective action will be developed to address both the contaminated overburden, and the contamation remaining in the excavation. |
Louis Howard |
| 9/14/1995 |
Update or Other Action |
In 1995, Oil Spill Consultants collected soil samples and performed a site assessment during
the removal of Tank 130, a 20,000-gallon UST that supplied fuel to operate diesel-powered
electrical generators situated inside former Building 772. The UST was approximately 2½ feet below ground surface (bgs) and had no surface dispensers. There was no historical documentation regarding spills or releases relating to Tank 130 although visual inspection showed evidence of surface spills prior to tank removal. Soil samples collected during the tank removal were analyzed for DRO, total petroleum hydrocarbons, benzene, toluene, ethylbenzene, and xylenes (BTEX). Petroleum contamination was present at depths between 15 feet and 40 feet below ground surface (bgs).
DRO was detected at a concentration of 1,730 mg/kg in soil, exceeding the ADEC Method Two cleanup level (250 mg/kg). Results from a sample of the tank contents confirmed that the tank was used to store diesel fuel(1995 (August 1995 Site Assessment Report. Facility No. 0-00788/Building 772 Underground Storage Tank 130. Fort Richardson, Alaska). During tank removal activities, two empty, crushed, drums of tetrachloroethene (PCE) were discovered. The surrounding soil was sampled, but no PCE contamination was detected. |
Louis Howard |
| 9/20/1995 |
Document, Report, or Work plan Review - other |
Letter to Army (S. Swearingen) re: Site Assessment Tank 130 Bldg. 772, Fort Richardson, Alaska August 31, 1995. The Alaska Department of Environmental Conservation-Defense Facilities Oversight group (ADEC) has received, on September 14, 1995, a copy of the referenced report for building 772.
ADEC concurs that the level B cleanup criterion was exceeded at tank 130 and will require further investigation to delineate the vertical and horizontal extent of the contamination at the site prior to implementing corrective action. ADEC looks forward to receiving a copy of the workplan for the release investigation with schedules of action for review and comment no later than January 1996. |
Louis Howard |
| 2/10/1997 |
Offsite Soil or Groundwater Disposal Approved |
Comment letter sent to Army (S. Swearingen) re: Soil Stockpile Remediation for 35750, 772, 28008, 45070 and 47022 at Fort Richardson, Alaska.
The Department of Environmental Conservation (DEC) has received the "Post Treatment Sample
Results" for the above piles on February 6, 1997. Based on a review of the data, it appears the soils can be used for any purpose the Post sees fit since they all are below the strictest criteria: Level A. |
Louis Howard |
| 6/25/1997 |
Document, Report, or Work plan Review - other |
Letter sent to Army (S. Swearingen) RE: Draft Work Plan and Site Safety and Health Plan UST RI B1dgs. 772, 35610, 35620,59000 Fort Richardson Contract No. DACAS5-95-D-000S June, 1997.
The Department of Environmental Conservation, has received the above document on June 24,
1997. After reviewing the information provided, the work plan is approved as submitted. DEC
does not review site safety and health plans, but will retain a copy on record for our files. |
Louis Howard |
| 10/1/1997 |
Update or Other Action |
USACE. 1998 (September). Modification No. 0002 Letter Report. UST Remedial Investigation, Buildings 772, 35610, 35620, and 59000, Fort Richardson, Alaska. Prepared by DOWL/Ogden Joint Venture:
Twenty-nine soil samples were collected from four boreholes drilled near the former tank excavation to depths of 30, 35, 40, and 45 feet below ground surface (bgs) in 1997 (USACE 1998). Concentrations of DRO were present in 13 samples collected from the four boreholes at depths ranging from 5 to 40 feet bgs. DRO contamination was detected at concentrations above the ADEC cleanup level in samples collected from depths of 20 and 30 feet bgs (13,700 and 15,000 mg/kg, respectively).
Low levels of toluene, ethylbenzene, xylenes, and various polycyclic aromatic hydrocarbons (PAHs) were identified in several samples but were less than cleanup levels. |
Louis Howard |
| 11/12/1997 |
Document, Report, or Work plan Review - other |
Comment letter sent to Army (S. Swearingen) re: Remedial Investigation Report for Bldgs. 772, 35610, 35620, 59000 Fort Richardson-AK October, 1997.
General Comments-The Environmental Protection Agency risk based concentrations (RBCs) have been updated since the 1995 version that was used during the 1997 release investigation. The newest version that must be used is dated October 22, 1997 which differs from the June 20, 1996 version by only changing the RBCs for PCBs. EPA Region Ill's address where the documents can be found is http://www.epa.gov/reg3hwmd7riskmenu.htm
Bldg. 35610
4.2.3 Groundwater Occurrence-The groundwater flow was assumed to be in a westerly direction, however based on the groundwater elevations listed in Appendix B Soil Boring Logs it appears the flow may be in a northeasterly or northwesterly direction. Well AP-3813 is not in any of the figures in the document nor is the location mentioned in the boring logs. Please locate the well on a map for future reference.
Bldg. 772
5.1.4 Recommendations-The text states that ACLs be evaluated for this site due to soil contamination at depths of 40' and install a monitoring well to determine if groundwater is present onsite. DEC concurs, however it is requested that the well be installed as close as possible to COE Boring# AP-3805 where the highest contamination was detected (15,000 mg/kg DRO).
5.2.4 Recommendations
The recommendations at the site are to excavate to groundwater and dispose/treat the soils properly with groundwater monitoring. DEC concurs, however it is requested that there be at least two monitoring wells installed at the site. Based on the exact location of well AP-3813, one of the two wells may need to be moved. One well would be placed approximately sixty-two feet or half the distance from AP3809 and Ship Creek. The other well would be placed fifty feet perpendicular to AP3812 NW of bldg. 35610. These wells would act as sentinel wells and further characterize the horizontal extent of soil contamination from the site since it appears the soils are contaminated at levels above level "A" at AP3812 and AP3809. Because of the shallow depth of groundwater, proximity of both Ship Creek and the backup standby wellS, DEC requests that the Army excavate all soils above Level "A" criteria or excavation to groundwater whichever is greater.
The text infers that monitoring frequency will be changed after the initial monitoring period. DEC will require the results of monitoring for no less than two years of quarterly monitoring will dictate whether or not subsequent monitoring will increase or decrease in frequency.
Bldg. 35620- See comments above for bldg. 35610 regarding excavation and monitoring frequency.
Bldg. 59000
5.4.4 Recommendations
The text states that ACLs be evaluated for this site due to soil contamination at depths of 40' and install monitoring wells to determine if groundwater is present onsite. DEC concurs, however it is requested that the wells be installed as close as possible to COE Boring# AP-3823 where the highest contamination was detected (3,170 mg/kg DRO) and AP-3824 (2,430 mglkg DRO). |
Louis Howard |
| 11/20/1997 |
Site Added to Database |
Diesel fuel contamination. |
Louis Howard |
| 12/15/1997 |
Update or Other Action |
Installation Restoration Program FY97 Fourth Quarter Update, Underground Storage Tanks
Fort Richardson, Alaska Engineering Manager: Brian West
1. PROJECT DESCRIPTION: This project is to investigate where DERA funded UST’s or leaking tanks were removed in FY88-FY94. The investigations are being conducted in accordance with a two party agreement signed with the State of Alaska. Sites include UST’s located at the following Buildings:
740 762 782 798
956 750 755 756
974 955 975 979
704 712 794 772
8102 2700 1 47662 45590
47811 45080 47203 28008
45580 39600 35610 35620
59000 45070
2. CHEMICALS OF CONCERN: Hydrocarbons, VOCs, and Metals.
3. SUMMARY OF LAST QUARTER ACTIVITIES: The following sites have been considered closed: Buildings 712, 796, 36012. 45726, 47663, 952, 47438, 47641,28004, 955, 975, and 979.
4. CURRENT CONTRACTING ACTIONS: Risk Assessments at Buildings 794, 45-590, 45-580, 39600, 755, 704, and 712 lube rack.
5. CURRENT &/OR FUTURE REMEDIAL ACTIONS: None.
6. EXPECTED DELIVERABLES WITHIN THE NEXT QUARTER: Sampling reports from 762 and 28-008, 772, 35610, 35620: and 59000. Risk Assessment for Building 47203.
7. EXPECTED FIELDWORK TO BE PERFORMED NEXT QUARTER: Sampling at Building 45070. |
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 |
| 9/4/1998 |
Update or Other Action |
An additional borehole was drilled and a 4-inch groundwater monitoring well was installed in
1998 (USACE (US Army Corps of Engineers). 1998 (November). EM 1110-1-4000, Engineering
and Design - Monitoring Well Design, Installation, and Documentation at Hazardous
Toxic, and Radioactive Waste Site). This boring was near the 1997 borehole from which the soil samples with the highest DRO had been collected. Groundwater was observed at 71 feet bgs and the monitoring well was installed to a depth of 78 feet bgs. In 10 of 14 soil samples collected during drilling for monitoring well installation, DRO was detected in 10 of 14 soil samples collected during installation of the well with the highest concentration (5,430 mg/kg) in a sample collected from a depth of 25 feet bgs.
Groundwater samples collected from the well contained DRO at a concentration (3.5 mg/L) exceeding the cleanup level (1.5 mg/L). The well is still located at the site but is not part of an active monitoring program. |
Louis Howard |
| 10/30/1998 |
Document, Report, or Work plan Review - other |
Letter sent to Army (S. Swearingen) re: UST Remedial Investigation Building 772,35610, 35620, and 59000 Fort Richardson, Alaska Contract DACA85-95-D0008 Modification 0002 Letter Report
dated September 4, 1998. The Department of Environmental Conservation (DEC) has received on October 5, 1998 a copy of the above document. After reviewing the data it appears the contamination at the site is above cleanup criteria as defined in 18 AAC 78 and has impacted groundwater at building 59000 and upgradient of building 772.
Building 772
DEC concurs with the recommendation to further delineate contamination in the vicinity of 772.
However, until [the horizontal and vertical] extent of contamination and its source can be characterized, it is premature to select long-term monitoring as a preferred remedial action at 772. DEC requests a workplan be submitted outlining what work will be done to further characterize the contamination at the site.
Building 59000
Per 18 AAC 78.220 Release Notification and Response, an owner/operator in response to a
confirmed release of petroleum from a UST or a suspected release under 18 AAC 78.200, shall
take immediate action to prevent any further release of the petroleum into the environment. This
includes removal of the petroleum from the UST and conducting initial abatement under 18
AAC 78.220;
1) Cease using the system and, if not already performed under 18 AAC 78.220(c)(2), within
seven [7] days remove the petroleum from the UST to prevent further release of the petroleum to
the environment. DEC requests the Army provide documentation that the UST at 59000 has
not been refilled until the system is repaired, replaced, upgraded or shown not to be leaking
(the UST and its associated piping) by a system test (18 AAC 78.210(b)). If the tank has
been removed since this report has been submitted, then please provide documentation
showing that it was removed and disposed of properly.
DEC concurs with the recommendation to begin product recovery at AP-3875. However, DEC
will require the installation, of at [least] a minimum three additional groundwater monitoring wells equidistant AP-3875 to determine local groundwater elevation, gradient, flow direction and
further characterization of the groundwater plume at the site. |
Louis Howard |
| 8/23/2002 |
Update or Other Action |
Email from Mark Prieksat (ARMY) to Louis Howard RE: Transformer Oil Spill at Bldg. 772. We have reported a release of transformer oil to soil on the north side of Bldg 772 on Ft. Rich. About 100 gallons of oil leaked from the transformer onto the concrete pad and surrounding soil. The remaining oil was drained from the transformer and any obvious soil contamination was excavated.
The contaminated soil has been stockpiled on a liner in the Circle Drive area and covered. Samples were collected from the oil and contaminated soil. The oil does contain PCB (aroclor 1260) but at a max concentration of about 10.5 ppm. All the soil sample results for PCB were less than 1 ppm (highest was 0.741 ppm). However, the soil does contain high levels of DRO (35,000 ppm) and RRO (1720 ppm). Because the PCB levels are less than 1 ppm, the soil will be thermally treated.
|
Louis Howard |
| 2/23/2007 |
Exposure Tracking Model Ranking |
|
Louis Howard |
| 8/29/2007 |
GIS Position Updated |
61.2596 N latitude -149.6922 W longitude |
Louis Howard |
| 4/15/2008 |
Update or Other Action |
DOD Supplemental Guidance for Implementing & Operating a Joint Base.
Operational Ranges
2.13.1 The supporting Component will be responsible for overseeing environmental requirements on the operational range (e.g. planning & consultation) when the real property &/or operational range management activities transfer.
2.13.2 The supported Component will identify unique mission requirements (i.e. buffers) to the supporting Component.
2.13.3 The supporting Component in coordination with the supported Component will ensure that the Operational Range Assessments required per reference (p) are conducted in a timely manner. Operational Range Assessments that are currently underway or have been completed by the supported Component will be provided to the supporting Component to fulfill this requirement. Any follow-on Range Assessments or range mitigation measures that are required as a result of the initial Operational Range Assessment will be the responsibility of the supporting Component provided mitigation resources were programmed by the supported component prior to TOA transfer to cover such required mitigation measures stemming from the initial range assessment.
2.17 Environmental Restoration Program (ERP)
2.17.1 The supporting & supported Components should commence negotiations as soon as possible on the Joint Base MOA to ensure all details regarding the timing & logistics associated with site & contract management transfer are identified in a timely manner. The MOA will identify a mutually agreeable date for the transfer of restoration program management responsibilities to the supporting Component.
2.17.2 The supported Component will provide the supporting Component with current site status, phase data, & cost-to-complete estimates & all pertinent site data, including land use controls, & regulatory correspondence & agreements to assist in the transfer of the sites to the supporting Component.
2.17.3 The timing for transfer of POM & budget resources required to support sites being transferred (i.e. , funding through the FYDP, personnel, etc) will be negotiated between supporting & supported Service level Components, consistent with reference (a).
2.17.4 The supporting Component will manage all environmental restoration sites on non-contiguous Joint Base properties in accordance with reference (t), & existing regulatory status or legal authority of the property at the time of site transfer.
The supporting Component may manage contiguous Joint Base sites under the regulatory status or legal authority that best fits the installation-specific circumstances & management approach of the supporting Component subject to prior RCRA permits, orders or other pre-existing agreements.
2.17.5 The supporting Components will honor all existing, previously negotiated Federal Facility Agreements in place at the installations to become the Joint Base at the time of transfer. The Federal Facility Agreement may need to be amended to document that responsibility has been transferred from the supported Component to the supporting Component.
2.17.6 The supporting Component will assume responsibility for environmental restoration data reporting, budgeting, record keeping, & financial liability at the time of transfer.
2.17.7 The supporting Component must work with the supported Component to ensure that the Defense State Memorandum of Agreement (DSMOA) or other State-recovery program is appropriately funded between the start of the current Cooperative Agreement cycle & the date when real property is transferred to the supporting Component.
2.17.8 At the time of property transfer, the supporting Component will assume responsibility for all existing Restoration Advisory Boards (RABs) at the Joint Base. The supporting Component should meet with all RABs associated with the installation to determine if the RABs will remain separate or be merged into a single RAB for the Joint Base. All CERCLA/NCP public participation requirements must also be maintained.
For properties or areas listed on the National Priorities List (NPL), the supporting Component will notify the EPA of any transfer of environmental restoration responsibilities from the supported Component for the property or area on the NPL.
See site file for additional information.
|
Louis Howard |
| 10/9/2009 |
Update or Other Action |
SUBJECT: Installation Support Memorandum of Agreement (MOA) for Joint Base Elmendorf-
Richardson
1. PURPOSE. The purpose of this MOA is to define the installation support relationship
between the supporting Component – the United States Air Force (USAF), hereafter referred to
as the “supporting Component”, and the supported Component(s) – the United States Army
(USA), hereafter referred to as the “supported Component(s)” for fully implementing Base
Realignment and Closure (BRAC) 2005 Joint Base decisions per references (a), (b), (c), and (d)
at Joint Base Elmendorf-Richardson. For the purposes of this MOA, the terms “party” and
“parties” shall be understood to refer exclusively to the supporting Component and the supported
Component(s), either collectively or individually.
This MOA establishes a comprehensive framework for Joint Base Elmendorf-Richardson Implementation, and captures the most practical methods for transferring Installation Support functions while meeting mission requirements. The MOA represents Full Operational Capability (FOC). Initial Operational Capability (IOC) requirements, to include reimbursement arrangements, will be addressed in the Implementation Plan (Attachment 1).
The strategic imperative of Joint Basing is to provide consistent, high quality installation support to the missions. In order to meet this imperative in a dynamic mission environment, the MOA may require refinement as mission requirements evolve, organizational structures mature, and
efficiencies improve product delivery.
The Joint Base Partnership Council (JBPC) shall review the MOA at least once prior to Full
Operational Capability (FOC) for any needed changes, taking into account the experiences of the
Initial Operational Capability (IOC) period. Thereafter, at a minimum, the JBPC shall review
the MOA annually for mission, manpower, and financial impacts and to ensure delivery of
installation support to common output level standards. The annual review will include the
information collected and reported in the Cost and Performance Visibility Framework. The JBPC
shall review the MOA in its entirety triennially. The supported or supporting Component may
propose additional reviews of the MOA at any time.
Any proposed changes to the MOA affecting execution of service delivery or changes of an
administrative nature shall be resolved by the Joint Base Partnership Council. Any significant
proposed changes to the MOA, including those regarding resourcing, manpower, or output
standards will be reviewed and approved through the Joint Management Oversight Structure
(JMOS) as directed by the Senior Installations Management Group (SIMG).
PERIOD OF PERFORMANCE
a. IOC: 31 January 2010 to 30 September 2010.
b. FOC: 1 October 2010 until terminated by the signatories of this MOA.
See site file for additional information. |
Louis Howard |
| 12/10/2009 |
Update or Other Action |
Draft Underground injection Control Class V Closure Plan sent by Army to EPA received. The plan covers the septic tank and wooden cesspool at Fort Richardson-Building 772. Itis the intent to decommission, close, and remove the septic system and wooden cesspool. This Plan will cover the decommissioning, closure, and removal of one septic tank and wooden cesspool at Fort Richardson Building 772. This septic tank and cesspool are being closed in preparation of the demolition of Building 772 later next year.
BUILDING 772
The Fairbanks-Morse (FM) Generator Plant was constructed in 1952 as a temporary generator plant and is located just north of D Street and Fifth Avenue. The plant uses two large diesel-powered generator sets and two smaller diesel-powered generators sets to produce electricity. There is one septic tank and wooden cesspool located approximately 27 feet south of the southern wall of Building 772. Records indicate that the septic tank and cesspool were connected to the sanitary line from the building however it is unclear if any of the floor and trench drains were also connected to this system.
In August 2008 Building 772 was transferred to Doyon Utilities (Doyon), the privatized utility provided for Fort Richardson. While the building and two underground storage tanks (UST) were transferred to Doyon, the UIC remain the Army's responsibility. It is planned that once the UIC is removed and closed that Doyon will demolish the building and remove the USTs on site. All impacted soils associated with the UIC, USTs and building demolition will be addressed by the Army and either state and/or federal regulatory authorities.
Although the septic system was connected to receive sanity waste it is unclear if there
were any additional floor drains or trench drains connected to this system. Therefore all
fluids stored and used within the building must be considered as potential contaminates
of concern. The diesel generators and electrical switching was maintained on site inside
Building 772. Lube oils such as OE-3D and turbine oils were kept inside. Used absorbents, used floor sweep, purged diesel and dielectric fluids were also within the building as well as cleaning solvents.
After the septic tank and cesspool have been emptied, the contractor shall expose all piping and remove them prior to removing the tank and cesspool. Once the tanks and cesspool have been removed from the ground, a total of ten (10) analytical samples along with QA/QC samples shall be collected from under the tank and cesspool and long the side walls as determined by the contractor to assure a complete site characterization. Disposal of the tank, cesspool and piping are the contractor's responsibility and shall be done in accordance with all regulations. A copy of the disposal record shall be provided to the government. All excavated soils generated during the decommissioning process will be returned to the excavation pit. Final determination of any soil disposal associated with this closure will involved discussions between the Army and state/federal regulatory authorities under the Environmental Restoration Program. |
Louis Howard |
| 12/31/2009 |
Update or Other Action |
USAGAK (U.S. Army Garrison, Alaska). 2009. Preconstruction Environmental Survey; Project: FTR 162/PN56914; Preconstruction Environmental Categorization Report. A Preconstruction Environmental Survey (PES) report was developed in 2009 as part of the military construction program (U.S. Army 2009). The report indicated that soil samples had been collected around the sides of a concrete pad on the north side of the building where three electrical transformers had been located.
One of the transformers reportedly leaked and a spill response was conducted to excavate contaminated soil. Confirmation samples were collected and analyzed for PCBs. Six of eight soil samples collected during the 2002 investigation contained the PCB Aroclor-1260 at levels ranging from 0.247 to 0.541 mg/kg. |
Louis Howard |
| 2/25/2010 |
Update or Other Action |
Dept. of Army Installation Management Command, HQ U.S. Army Garrison Fort Richardson, Office of the Garrison Commander sent letter to ADEC.
This letter serves as formal notice under Paragraph XXXII, Transfer of Property, of the Fort Richardson, Alaska (FRA) Federal Facility Agreement (FFA), that the property under the jurisdiction of the U.S. Army will be transferred to the Joint Base Elmendorf-Richardson (JBER) effective October 1, 2010.
This letter also serves as formal notice that effective October 1, 2010, responsibility for the FRA FFA, dated December 15, 1994, will be transferred to the senior official of the JBER Supporting Component, United States Air Force (USAF). This transfer of responsibility is in accordance with the Memorandum of Agreement (MOA) between the USAF and United States Army (USA), and was signed by the Vice Chief of Staff for the USAF and the Vice Chief of Staff for the USA on October 9, 2009.
Based on the MOA and previous discussions with US EPA (reference March 2009 FRA FFA meeting in Seattle with representatives of the EPA Region 10, Elmendorf AFB and Fort Richardson), it is our understanding your agency agrees the management and oversight of the FRA FFA may properly transfer to the JBER Restoration Project Manager (RPM), and such transfer does not constitute a significant change, such as to require formal renegotiation of the Agreement or the preparation of an amendment to the Record of Decision.
If you have any questions or concerns about this matter, please contact Therese Deardorff, Chief, Environmental Division, U.S. Army Garrison Fort Richardson, Alaska 907.384.3074. |
Louis Howard |
| 3/25/2010 |
Update or Other Action |
Letter from Lt. General Dana T. Atkins, Commander, Eleventh Air Force to EPA Region 10 Deb Yamamoto Environmental Cleanup Office and ADEC, Jennifer Roberts Fed. Fac. Environmental Restoration Program.
This letter serves as formal notice to the Environmental Protection Agency Region 10 and the State of Alaska that on 1 October 2010, the U.S. Air Force will assume the U.S. Army's obligations under the 1994 Federal Facility Agreement for Fort Richardson (Docket No. 1093-
05-02-120) and any amendments thereto (hereinafter collectively referred to as "the FFA").
The Air Force assumes these authorities and obligations as the Army's successor at Fort
Richardson in accordance with subsection 2.1(i) of the FFA.
This is a transfer of responsibility for carrying out the terms and responsibilities of the FFA;
it is not a transfer of property covered by Section XXXII of the FFA or Section 120(h) of the
Comprehensive Environmental Response, Compensation and Liability Act (42 U.S.C. §9620(h)). This transfer of responsibility is in accordance with the Base Realignment and Closure Act of 2005 and the Joint Base Elmendorf-Richardson Installation Support Memorandum of Agreement between the Army and the Air Force, dated 9 October 2009.
On and after 1 October 2010, the Air Force and, to the extent necessary, the Department of
Defense will fund all activities required by and subject to the FFA.
The following administrative changes shall be effective 1 October 2010:
1. Para 8.11 - The Air Force representative on the Technical Review Committee (currently
referred to as Community Environmental Board) shall be the Joint Base Elmendorf-Richardson
(JBER) Remedial Project Manager (RPM).
2. Para. 8.13 - The chair of the Technical Review Committee (currently referred to as Community Environmental Board) shall be the Vice Commander, 673rd Air Base Wing.
3. Para 9.1 - The JBER RPM shall be Mr. Gary Fink, who is currently the Chief of the Restoration Section at Elmendorf Air Force Base. Mr. Fink's contact information is:
3 CES/CEANR 6326 Arctic Warrior Drive Elmendorf AFB AK 99506 Phone number is (907) 552-2875
4. Para. 14.2 - The Air Force point of contact shall be Mr. Fink. Please see the preceding
paragraph for his contact information.
5. Para 21.5 - The Air Force's designated member on the Dispute Resolution Committee shall be the Director, Air Force Center for Engineering and the Environment.
6. Para 21.7 - The Air Force's representative on the Senior Executive Committee shall be the Deputy Assistant Secretary of the Air Force (Energy, Environment, Safety, and Occupational Health).
7. Para 27.3 - The source of funds for activities required by the FFA shall be funds authorized and appropriated annually by Congress under the Environmental Restoration, Air Force (ER,AF) appropriation in the Department of Defense Appropriations Act.
8. Attachment 1, Para 3.8: Records of decision shall be signed by the following Air Force designee: Commander, 673rd Air Base Wing.
If you have any questions about this matter, please contact Mr. Gary Fink at (907) 552-2875.
Signed Dana T. Atkins Lieutenant General, USAF, Commander |
Louis Howard |
| 4/1/2010 |
Update or Other Action |
Dept. of Army Office of the Garrison Commander (Colonel Timothy R. Prior) letter to EPA RPM Bill Adams and ADEC L. Howard.
This letter serves as formal notice to the Environmental Protection Agency Region 10 (EPA Region 10) and the State of Alaska Department of Environmental Conservation, (ADEC) that on 1 October 2010 the U.S. Air Force will assume the U.S. Army's obligations under the 1994 Federal Facility Agreement for Fort Richardson (Docket No.1 093-05-02-120) and any amendments thereto (hereinafter collectively referred to as "the FFA"). The Air Force assumes these authorities and obligations as the Army's successor and assignee for the environmental restoration program at Ft. Richardson in accordance with subsection 2.1 (i) of the FFA.
This is a transfer of responsibility between the Military Departments for the purpose of carrying out the terms and responsibilities of the FFA; it is not a transfer of property subject to the requirements of Section 120(h) of the Comprehensive Environmental Response, Compensation and Liability Act (42 U.S.C. §9620(h)). This transfer of responsibility is in accordance with the Base Realignment and Closure Act of 2005 and the Joint Base Elmendorf-Richardson Installation Support Memorandum of Agreement between the Army and the Air Force, dated 9 October 2009.
This letter replaces our earlier letter dated 17 February 2010. If you have any questions about this matter, please contact Mr. Mark Prieksat at (907) 384-2716.
On and after 1 October 2010" the Air Force and, to the extent necessary, the Department of Defense will fund all activities required by and subject to the FFA. |
Louis Howard |
| 9/29/2010 |
Update or Other Action |
USACE. 2011b (March). Preliminary Site Evaluation, FTR271 Maneuver Enhancement Brigade Complex Phase II, JBER, Alaska. Prepared by Jacobs Engineering Group.
Also in September 2010, Jacobs performed a preliminary site evaluation (PSE) at the MEB
complex sites on behalf of JBER. Activities included 15 soil borings and soil sample
collection at the proposed HQ Facility. Soil borings were advanced to 15 feet bgs. Two
analytical samples were collected from each soil boring.
Although concentrations of arsenic, chromium, and methylene chloride exceeded ADEC Method Two cleanup levels, these concentrations were attributed to naturally occurring background conditions or laboratory contamination (USACE 2011b). Concentrations of DRO, TCE, PCB Aroclor 1260, and dieldrin were also found at concentrations that exceeded the ADEC Method Two cleanup
levels in samples collected from 4 to 14 feet bgs. No groundwater was encountered in any of
the borings advanced in 2010. |
Louis Howard |
| 9/30/2010 |
Update or Other Action |
Bristol (Bristol Environmental Remediation Services, LLC). 2010 (December). Class V Underground Injection Control Closure, Building 772, Fort Richardson, Alaska Closure Plan Report.
In September 2010, Bristol Environmental Remediation Services, LLC (Bristol), on behalf of
JBER performed a Class V Underground Injection Control closure at Building 772. Activities
included exposing and characterizing the septic tank, cesspool, and adjacent soil; removal,
transportation, and disposal of the septic tank, cesspool, tank piping, and adjacent soil;
performance of confirmation sampling; and backfilling of the excavation with clean fill.
Confirmation soil samples collected from the sidewalls near the base of the excavation
indicated concentrations of DRO, 1-methylnapthalene, 2-methylnapthalene, arsenic, and
methylene chloride above ADEC Method Two cleanup levels established in Title 18 Alaska
Administrative Code (AAC), Chapter 75 (18 AAC 75) (ADEC 2008). Concentrations of
DRO, 1-methylnapthalene, and 2-methylnapthalene were linked to petroleum contamination
onsite, while arsenic was attributed to naturally occurring background levels, and methylene
chloride was attributed to laboratory contamination |
Louis Howard |
| 11/17/2010 |
Update or Other Action |
November 17, 2010 report which was sent by White Environmental Consultants, Inc. PCB Test Results received on behalf of DOYON Utilities, LLC.
Building 772 is diesel powered electrical generating facility. Based on the age of the facility it is reasonable to assume PCBs were once used in the facility. On October 19, WEC collected 9 wipe samples and one bulk sample. The purpose of this sampling was cursory in nature. Visually stained concrete was targeted for wipe sampling. Not aU visuaUy stained areas were sampled. The wipe samples were collected from various locations with a wipe area of 100 square centimeters. The bulk sample was collected outside the building from an area of visually stained soil.
Results indicate PCBs have been spilled in the past use of this facility. The concentrations
detected by wipe methods exceed the continued use level of 10ug/l00 cm2 (40 CFR 761.30(p).
This facilitv should not be entered or occupied until the facility is decontaminated and post-cleaning sampling confirms PCB concentrations are below reuse or continued use criteria.
Sample ID Location/Surface (Results are in ug/wipe)
11OW-OI East end of building at door/concrete 35.6
l1OW-02 At air compressor SE end of building/concrete 21.9
1l0W-03 North end of generator foundation east end of building/concrete 49.5
11OW-04 North east end of building in conduit trench/concrete 531
1l0W-05 North end of generator foundation center generator/concrete 126
1l0W-06 At back-up generator in conduit trench/concrete 806,000
1l0W-07 Switch gear rack/metal frame 12,500
1l0W-08 South side of main generator #2/concrete 1040
11OW-09 SW blower foundation/concrete 244
110W-IO At south man door entrance/soil 181
110W-11 Field Blank 1.59
Recommendations
The structure currently is scheduled for demolition so cleaning for continued use may not be
appropriate. Further investigation will be required to fully assess contamination of concrete,
equipment and also the wood structure itself.
Significantly more information will be needed to accurately determine the extent of
contamination. Once the extent of the contamination is known, decontamination, demolition and
disposal plans can be developed. |
Louis Howard |
| 1/31/2011 |
Update or Other Action |
USACE. 2011a (April). Memorandum. Report of Chemical Findings and Employee Exposure
Monitoring, FTR271A (PN327741) Maneuver Enhancement Brigade-Phase II Battalion and Brigade Headquarters Facility, Joint Base Elmendorf-Richardson, Alaska. (11-022).
In January 2011, USACE conducted a geotechnical investigation at the site and collected soil
samples from eight soil borings. The chemical data report (FTR271A/PN327741) indicated
that high concentrations of DRO were detected in two borings at concentrations of 780 mg/kg
and 8,800 mg/kg. The PCB Aroclor 1260 was detected, albeit at concentrations below ADEC
cleanup level |
Louis Howard |
| 5/10/2011 |
Update or Other Action |
Draft Sampling & Analysis Plan received for support of Demolition of Building 772. These slabs will be sampled & characterized for PCBs. Slab surfaces (up to ½-inch deep) will be sampled to determine if the slabs are contaminated by PCB-containing oil. Deep samples (greater than ½-inch deep) of the slabs will be completed from the same sample location to determine the extent that PCBs have permeated into deeper parts of the slabs. Analytical results returned from the slab samples will be compared to current EPA standards to determine the need, if any, for special handling & disposal methods during demolition of the structure & foundation.
Specific work tasks
1. Prepare an EPA-compliant “Site-Specific Sampling & Analysis Plan” (Concrete) according to 40 CFR 761.
2. Sample project site, building components, equipment & concrete for PCBs; deliver to the subcontract laboratory, Bureau Veritas for analysis per EPA Method 8082. Sample collection will include a minimum of 10% duplicates for project QA/QC.
3. Prepare a “Final Site Characterization Report”.
4. Provide project management & consulting as needed
The objective is to acquire data of sufficient quantity & quality to accurately assess PCB contamination that may be present in;
a. Surface contamination of soil that will impact access to the site & access around building perimeter.
Composite soil samples will be collected from surface soils located in a path from the main facility entrance along the existing driveway to building 772. Soil sampling will continue around the perimeter of the Building 772. Perimeter samples will extend approximately 10’ from the building.
Each composite sample will be collected from approximately 400 ft2. (20’ x 20’ or 10’ x 40’). Approximately 20 subsamples, each consisting of 1 in3 of material will be collected & homogenized. Sub samples will be placed in Ziploc type bags sealed & the placed in an additional bag for shipping.
b. Painted building structural components scheduled for demolition.
Wipe samples will be collected from walls & structural components to assess surface contamination; additional paint chip samples will be collected to assess PCB concentrations of the paint systems.
Each wipe sample will be collected from 100 cm2 area. Sample area will be wiped with a gauze pad wetted with hexane, & then sealed in an amber glass jar for transport to laboratory.
Paint chip samples will be collected from the same areas as the wipe samples to ensure paint chip samples are contaminated by surface PCB residue. Paint chips will be collected & sealed in 50 ml centrifuge tubes for shipping.
c. Miscellaneous caulking & adhesives.
Bulk samples of caulking & adhesives found throughout the building will be analyzed for PCB concentrations.
Bulk samples will be sealed in 50 ml centrifuged tubes for transport to laboratory.
d. Surface contamination of electrical generation & switching equipment.
Wipe samples will be collected from diesel engines, generators, motors switch gear, etc. to assess surface contamination.
Each wipe samples will be collected from 100 cm2 area. Sample area will be wiped with a gauze pad wetted with hexane, & then sealed in an amber glass jar for transport to laboratory.
e. Oil contamination in diesel engine crankcases & in rotating equipment bearings.
Oil samples will be extracted from engine crankcases & bearing boxes & sealed in 100 ml glass jars for transport to laboratory.
f. Surface & subsurface contamination of concrete equipment pads, trenches & slabs.
A technique published by Region I EPA (New England), “SOP for Sampling Concrete in the Field,” will be closely followed for sampling at the concrete equipment pads and the concrete slab.
Sample Locations and Frequency
a. Composite soil samples – Approximately 18 composite soil samples will be collected to characterize the site entrance route and the exterior perimeter of the structure.
b. Painted building components – 24 wipe and paint chip samples will be collected from the interior and exterior of the building.
c. Miscellaneous caulking and adhesive materials – A representative number of caulking and adhesive samples will be collected to characterize these materials where present.
d. Surface contamination of electrical equipment – A minimum of 24 wipe samples will be collected from electrical generation and switching equipment.
e. Oil samples – Oil samples will be collected from the crankcases of all diesel engines and bearings boxes that are assessable. Equipment that is suspect but not assessable will be noted in the final report.
f. Concrete slabs – Surface and subsurface concrete samples will be collected on a grid approximately spaced 10’ x 10’. Obvious stains within the grid areas will be targeted for sample collection. |
Louis Howard |
| 5/11/2011 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft work plan.
Page 3 Section 1- ADEC requests the Army state when the sampling was conducted & the source of the document. ADEC has just received the document in May of 2011. Sampling had occurred in October 2010 & the report with PCB test results from wipe sampling & a soil sampling was available as of November 17, 2010. Providing documentation six months later is not a timely notification to ADEC of sample results showing a past release of a hazardous substance (e.g. PCBs) had likely occurred in Building 772 & in surface soil.
Page 3 Section 2-The Scope of Work includes characterizing PCB in soil for site access & building perimeter. ADEC will not accept the soil sampling as proposed in the document for Contaminated Site Program site management decisions nor for definitive data required under the Fort Richardson Federal Facility Agreement. One bulk sample from 2010 has shown PCB contamination is present above 1 mg/kg at the building entrance. Whatever protective measures are used they must be able to prevent the soil from being disturbed, tracked, & transferred to previously clean areas during building demolition activities.
Page 4 Section 3.2- ADEC requests a copy be provided for its files & a copy also be provided to EPA Region 10 TSCA Program staff (suggest overnight delivery or same day electronic mail) - Dave Bartus for his review & comment.
Page 6 Section 3.6-ADEC will require completed laboratory data review checklists (January 2010) be completed for all environmental sampling results in accordance with ADEC’s Laboratory Data & Quality Assurance Policy – Technical Memorandum (March 2009). All reports submitted to ADEC containing analytical laboratory sample results shall contain a completed Laboratory Data Review Checklist & a Quality Assurance (QA) Summary.
Page 7 Section 4.2-Soil sampling as proposed will not be used for definitive data in subsequent site management decisions by ADEC when a subsequent remedial investigation is conducted for Building 772. The soil sampling is not acceptable for site characterization of the nature & extent of PCB soil contamination for the site as required by CERCLA or 18 AAC 75. It is outside ADEC’s regulatory authority to state whether or not the proposed soil sampling is adequate for worker safety as this is an OSHA issue.
ADEC suggests using a nine point composites from a 15’ by 15’ grid for the surface soil sampling as described in the EPA guidance for the soil surrounding the perimeter of the building & site entrance route to address the limited area which is not the entire site which will be investigated by the Army at a later date as required by CERCLA & the Federal Facility Agreement.
See site file for additional information.
|
Louis Howard |
| 5/12/2011 |
Document, Report, or Work plan Review - other |
EPA Dave Bartus Region 10 provided comments on the the draft sampling and analysis plan for Bldg. 772.
1 Background Page 3
Based on our teleconference discussions, I’m thinking that a more realistic statement of purpose might be “The purpose of this sampling endeavor is to better characterize the nature and extent of PCB bulk product and PCB remediation waste within the building, contents and concrete slab for purposes of selecting an appropriate regulatory pathway under 40 CFR 761 and for selection of final disposal facilities.” I’m guessing that this sampling will not comprehensively address all data needs for demolition and disposal given that it is currently not clear how much PCB bulk product waste and PCB remediation waste exists and where it may be located.
2 Scope of Work Page 3
Surface wipe samples should be limited to non-porous surfaces (metal, for example). If there are non-porous surfaces, they should be identified and media-specific sampling protocols proposed.
I’d like to see an explicit depth. For purposes of characterization of the depth of PCB penetration into concrete, I’d recommend sample intervals of 0-.5” and .5-1.”
While I’m supportive of sampling to characterization of PCB concentration with depth in concrete, how will this data be used for planning and executing building demolition and subsequent waste management? It may be difficult or un-economic to separate concrete into separate waste streams for disposal.
Most likely, the decision criteria will be a combination of 1) Concrete with as-found concentrations >50 ppm that must be managed in a chemical or hazardous waste landfill; 2) Concrete with intermediate levels (10-49 ppm) which may be managed out-of-state at a Subtitle D landfill, and 3) concrete with <10 ppm that can be disposed of locally. I’m recommend documenting these decision criteria in the plan. As we discussed during our teleconference, the purposes of this sampling exercise is to obtain additional data to figure out what TSCA regulatory authority would be best for PCB remediation waste, including consideration of disposal requirements.
3.1 Work Task Summary Pages 3 and 4
I’m not sure what the reference to 40 CFR 761 really means. For example, 40 CFR 761 Subpart N provides a method for characterization of PCB remediation waste, but not PCB bulk product waste. Also, what is the relationship between this work task and the current sampling and analysis plan? Are there two separate document, or does the current document satisfy this work task?
Will this be per each sample type (soil, building components, equipment and concrete)?
During our conference call, we described the proposed exercise as a “facility assessment.” Should the same phrase be used here?
3.3 Statement of Intended Data Quality and Usage Page 4
I’m curious what role institutional controls are contemplated in this context, given that the stated purpose of the project is building demolition and off-site disposal, with any soil issues to be addressed separately by JBER.
What about corresponding data quality requirements for samples of other than soils? Most likely, it will not be possible to achieve a level this low (in appropriate units, of course) for PCBs in oil.
3.3.1 Definitions of Analytical Levels Pages 4 and 5
Of these levels, which will be required for this specific project
4 Field Sampling Plan Page 7
It would be very helpful to include a diagram of the building indicating the number and location of the various samples to be obtained.
4.3 Sample Locations and Frequency Page 9
(c) What is a “representative number” of samples? I’d recommend at least one sample from each distinct type of caulk or adhesive that can be identified on the basis of visual means
(f) Is the same sampling density to be applied to machinery bases and building slab areas?
4.5.1 Rationale of Analytica Methodology for Samples Page 10
For paint and concrete, EPA recommends Soxhlet or pressurized fluid extraction for sample preparation.
See comments in Section 3.3
The following appears to be specific to concrete sampling. Are there specific sampling procedures for other sampling media (paint, soil, oil, etc.?)
4.5.3 Concrete Sampling Procedures Page 11 Last Bullet
See previous comments on the 10% criteria.
5.7 Internal Quality Control Checks Page 13
Duplicate Sampling
See earlier comments on the 10% criteria.
Given that PCBs are the subject of this work (a specific analyte), concentrations of decision criteria are known and the type of analysis is known, what will be the specific precision, as measured by relative percent difference that is necessary for the data to be acceptable for this project? |
Louis Howard |
| 5/31/2011 |
Update or Other Action |
May 2011 UIC Closure Plan Report received. Confirmation soil samples were collected from
beneath the former septic tank and cesspool from excavation sidewalls. Confirmation soil
sample results also indicated concentrations of arsenic above the site background level of 5.59
mg/kg (E&E, 1996). Arsenic results from the confirmation samples ranged from 4.9 to 7.4
mg/kg; however, results were considered within an acceptable range of background levels.
Because the presence of methylene chloride was detected in the trip blank, it is believed that
the reported concentrations are due to laboratory contamination and are not present at the site
at the reported concentrations. DRO from approximate depth of 21 feet bgs, near the base of the excavation just above the apparent groundwater level. The highest concentration of DRO detected was found in sample 10FRAUIC32SO at a concentration of 8,900 mg/kg. Sample 10FRAUIC32SO was collected from the west sidewall of the cesspool excavation from a depth of 21 feet bgs, within a foot of the soil/groundwater interface. samples were collected from the east sidewall, beneath the former septic tank, at a depth of 21 feet bgs. The DRO in soil samples 10FRAUIC33SO and 10FRAUIC35SO was detected at concentrations of 4,500 and 2,200 mg/kg, respectively.
Concentrations of 1-Methylnaphthalene and 2-Methylnaphthalene were detected in
confirmation sample 10FRAUIC32SO (Lab ID 580-21862-3) taken on 9/17/2010: 6.8 mg/kg and 12 mg/kg respectively.
Methylene chloride was detected in confirmation soil sample 10FRAUIC36SO at a concentration of 17 µg/kg; however, methylene chloride was also detected in the method blank. Due to the presence of method blank contamination, and because methylene chloride is a common laboratory contaminant, professional judgment was used to discount the methylene chloride detection in sample 10FRAUIC36SO.
|
Louis Howard |
| 6/1/2011 |
Update or Other Action |
Report of Chemical Findings & Employee Exposure Monitoring, FTR271B (PN72270) Maneuver Enhancement Brigade-Phase II Tactical Equipment Maintenance Facility (TEMF) Maintenance Facility, Joint Base Elmendorf Richardson, Alaska (11-023).
The northern portion of the proposed site is currently a recreational vehicle storage lot & a fueling point consisting of Bldg 992, while USTs, AST, fuel canopies, tank slabs, & fuel dispensers are located on the southern portion of the site.
According to the historical aerial photographs, the existing Fueling Point (Building 992) site has been a fueling point since at least 1954. The Preconstruction Environmental Survey report also indicates that historically, the subject site had been used for bulk oil storage since 1954 through at least 1984. Prior to that, the site was partially developed & used for parking as far back as 1947 (the earliest aerial photograph available). The Existing Fueling Point is located near a former railroad offloading point where old, historical spills were noted. The existing Fuel Point site contains both UST & AST fuel tanks, thus the possibility of leaking tanks & associated piping exists. The existing fueling point & associated tanks are scheduled to be removed as part of MEB Phase 1, FTR269 (PN55695). While this site has not been comprehensively investigated, evidence of subsurface fuel contamination was noted during a natural gas pipeline installation along Warehouse Street (at the south boundary of the South RV Lot) in 2003.
Workers were forced to evacuate the construction trench when strong fuel hydrocarbon vapors filled the trench. In addition, the Existing Fuel Point is documented as a hazardous waste generator including fluorescent tubes, absorbents, aerosol cans, etc. However, according to the Preconstruction Environmental Survey report, the proposed TEMF Maintenance Facility site has no record of leaking UST/AST’s, Hazardous Waste Generation, or known contamination (DERA). Due to the current & historic use of the land, hazards associated with possible petroleum, lubricants, & oils exist at this site location. Recently, Jacob’s Engineering was contracted by DPW to perform a site investigation at the subject site. Although the final report had not been received to date, preliminary results indicate the following contaminants above state clean up limits are present on site in association with the present fueling area: 1,2,3-trichloropropane & benzene .
Twenty-one borings were completed during the geotechnical investigation on the FTR271B project site. Samples from three of the twenty-one borings were collected & analyzed for contamination. The objectives of the project were to conduct exposure monitoring for evaluation of employee exposure & to collect soil samples for analyses to ensure proper disposal of investigative derived waste.
Arsenic was present in TB-10 (AP-5669 at 7.2 mg/Kg), TB-11 (AP-5670 at 7.4 mg/Kg), & TB-16 (AP-5675 at 6.8 mg/Kg & a duplicate at 5.2 mg/Kg). Chromium was present in TB-10 (AP-5669 at 36 mg/Kg), TB-11 (AP-5670 at 41 mg/Kg), & TB-16 (AP-5675 at 29 mg/Kg & a duplicate at 25 mg/Kg). Arsenic & chromium are above ADEC criteria but are within background levels for the installation (ref. 1.d). In addition, the clean up level for chromium is based on the presence of the more toxic hexavalent chromium. Site history does not indicate the presence of the more toxic hexavalent chromium species. A separate analysis was run for hexavalent chromium & no exceedances were noted.
These results indicate that for the site where the sampling was performed & the task being monitored the employee exposure was less than 1/10th of the TLV & 1/100th the PEL for benzene.
Due to current & historic use of the site, further environmental site investigation is recommended. Based on the employee chemical exposure data, continue utilizing established work practices & established safety protocols. Should site conditions or processes change, additional evaluations should be performed.
|
Louis Howard |
| 7/21/2011 |
Update or Other Action |
Remedial Investigation Work Plan received for Proposed HQ Facility & Proposed Rapid Deployment Facility (June 2011). The goals of this project are to characterize the environmental conditions, define the nature & extent of contamination, & ascertain whether modifications to building design &/or remedial actions are needed to provide for the safety of construction workers & future building occupants at the proposed Headquarters (HQ) Facility (CC-FTRS-17) & the proposed Rapid Deployment Facility (RDF) (CC-FTRS-16).
CC-FTRS-17: The site covered by this Work Plan encompasses the area around existing Building 772 (Figure A-2). This site is the future location of an Army Headquarters (HQ) facility that is part of the Maneuver Enhancement Brigade (MEB) Complex. Building 772 is an industrial facility that houses generators & other electrical equipment including a transformer that provides a backup power source for critical operational elements. The facility is scheduled to be demolished by August 2011 before the Remedial Investigation begins.
CC-FTRS-16: This site is the future location of a Rapid Deployment Facility (RDF) that will be located adjacent to railroad siding. The location is near the south side of JBER-Richardson’s closed solid waste landfill. The area formerly housed warehouse facilities with railroad loading platforms & USTs.
There are several closed sites with l& use controls located near the RDF site: CC-FTRS-70 (former Building 934), CC-FTRS-73 (former Buildings 936 & 944), & CC-FTRS-76 (former Building 946). All of these facilities were warehouses where heating oil tanks leaked, resulting in the l& use controls. All of these facilities were demolished within the past 25 years.
Proposed HQ Facility-Chemical data does exist for the proposed HQ Facility; however, the data is limited & not comprehensive for the site. Data gaps exist for subsurface soils & groundwater. Surface soils may also potentially contain contaminants. The site currently houses a standby generator plant & a UST. The previous UST leaked & the site is surrounded by known contaminated sites. In 2010, a RI identified DRO, PCBs, TCE, & dieldrin as contaminants in subsurface soil. Contaminants are expected in groundwater & possibly in air due to the presence of volatiles in the subsurface soil.
Although groundwater in the area is not used as a drinking water source, this pathway is potentially complete because a formal ADEC evaluation of the groundwater per 18 AAC 75.350 has not yet been performed. Surface water is not present on site. Biota could act as a secondary source by plant or animal uptake through impacted soil. However, this pathway is incomplete because that area is not used for hunting, fishing, or harvesting of wild or farmed foods. Likely future & current receptors are nearby residents, site workers, visitors, trespassers, & recreational users.
Proposed RDF-To date, no chemical data is available at the proposed RDF. Data gaps exist for surface & subsurface soils, soil gas, & groundwater. The area formerly housed warehouse facilities, loading platforms, & USTs which indicates a possibility of surface & subsurface spills & leaks to the soil & underlying groundwater at the site. Petroleum hydrocarbons & their constituents are the most likely contaminants of potential concern for the proposed RDF. In addition, the nearby landfill & known methane plume lends to the possibility for soil gas exposure in the air & volatile organics, pesticides, & PCBs in the soil.
Although groundwater in the area is not used as a drinking water source, this pathway is potentially complete because a formal ADEC evaluation of the groundwater per 18 AAC 75.350 has not yet been performed. Surface water is not present onsite. Biota could act as a secondary source by plant or animal uptake through impacted soil. However, this pathway is incomplete because that area is not used for hunting, fishing, or harvesting of wild or farmed foods. Likely future receptors include residents in the area, workers, visitors, & trespassers. Likely current receptors include recreational users on the trail that cuts through the area.
The primary objective of the RI is to assess the potential presence of contaminants at each location & to define the nature & extent of contaminants. The information obtained from the Remedial Investigation/Feasibility Study will be used to determine whether modifications to building design &/or remedial actions are needed to provide for the safety of construction workers & future building occupants. The decisions regarding treatment of each source area will be made by the 673 CES/CEANR, EPA, & ADEC. |
Louis Howard |
| 7/25/2011 |
Update or Other Action |
Sampling & Analysis Report PCBs in soil, paint, oil, surface wipes & concrete-Bldg. 772 JBER received.
Results indicate;
• Building sidings is cement asbestos board
• Two pipe fittings within the building contain asbestos
• Paint on the interior & exterior of the building & caulking on the exterior of the building contain PCBs at less than 50 ppm with the exception of 2 paint samples collected from the concrete floor.
• Soil samples immediately adjacent to the building structure were found to contain PCBs.
• Concrete core samples show surface contaminated with PCBs & no PCBs detected from mid depth or the bottom of the cores.
• Concrete composite samples from the interior floor slab (slab was divided into 15' x 15' grids with 9 subsamples per grid) show PCBs less than 50 ppm with the exception of one grid.
• Used oils from rotating equipment & sludge from trenching showed some PCBs with concentrations less than 50 ppm.
• Wipe samples from equipment scheduled for recycling show less than 100 ug/100cm2
Remediation of PCBs will be performed under 40 CFR 761.61 (b) "Performance Based Disposal"
Building 772 is currently owned by Doyon Utilities LLC (DU). It is the original diesel powered electrical generation facility for Ft. Rich. It was transferred to DU as part of base wide utilities privatization. The US Army retains title to the land around & under Building 772. After DU demolishes & removes Building 772 the site will be transferred back to the US Army.
The scope of the demo work is limited to building components; no remediation or removal of contaminated soils is part of this work.
Wipe samples were collected from diesel engines, generators, etc. to assess surface contamination. The intent is to clean these items for recycling. Each wipe sample was collected from 100 cm2 area. Sample area was wiped with a gauze pad wetted with hexane, & then sealed in an amber glass jar for transport to lab.
24 wipe samples were submitted for analysis. No duplicates were submitted for this method.
Oil samples were extracted from engine crankcases & bearing boxes & sealed in 100 ml glass jars for transport to lab. 14 oil & 3 oil/sludge samples were submitted for analysis. Oil/sludge samples were collected from the bottom of utility trenches.
7 core samples were collected from the floor slabs within the building. Core samples indicated the majority of the floor slabs were 6 to 8” thick. Subsamples from these cores consisted of the top one half inch, a 1/2" section from the middle of the core & the bottom 1/2" of the core for a total of 21 core samples submitted for analysis. No duplicates from this method were submitted for analysis.
Originally no information was available to determine slab thickness. It was assumed that the slabs were a minimum of 24” thick. Based on this assumption the intent was to take composite surface samples & then follow up with composite sample from deeper within the slab. After determining the slabs were typically less than 8” thick it was decided to profile the slab waste from the surface samples only based on the cost of segregated contaminated from noncontaminated concrete.
The top surface of the floor slabs were sampled utilizing a technique published by Region I EPA (New England), "SOP for Sampling Concrete in the Field". This method uses an impact hammer drill to produce a surface sample from the upper ½” inch of the slab. The drill method generates a fine, uniform powder that is easily processed for analysis by the lab. The bldng foot print was divided into approximately 15' x 15' grids with 9 sub samples collected from each grid. 40 concrete surface composite samples were collected. 10% of these samples were submitted for duplicate analysis.
Concrete Core Samples
Results indicate surface contamination is present throughout the majority of the bldng slabs. No PCBs were detected from the mid or bottom sub samples.
Concrete Surface Composite
Results indicate surface contamination is present throughout the majority of the bldng slabs. 1 sample grid shows PCBs greater than 50ppm. The remainder of the contamination is less than 50 ppm.
Paint & Caulking
Results indicate PCBs are present in all interior paints & in the majority of the exterior paints. 3 of the floor paints from the interior contain PCBs in excess of 50 ppm. All of the remaining paints from the interior & exterior of the structure contain PCBs less than 50 ppm.
Oils & Sludge
Results show all oils & oil/sludge below 500 ppm
Wipe Samples
24 wipe samples from equipment scheduled for recycling indicate no PCBs on 14 samples & less than 100 ug/100cm2 on the remaining 7 samples.
Conclusions
PCBs are present throughout the majority of the floor system & painted bldng components. The demolition waste stream will be profiled & disposed of in regulated landfills located outside AK. Fluids & equipment within the building will be recycled in AK. |
Louis Howard |
| 8/10/2011 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the " Draft Remedial Investigation Work Plan Proposed Headquarters Facility and Proposed Rapid Deployment Facility June 2011."
Table 4-1 Proposed RDF: Field screening with a PID will not serve to identify non-volatile contaminants (e.g. metals, non-chlorinated pesticides, PCBs, and RRO) that may or may not be collocated with volatile contamination that the PID reacts to. ADEC will require at least one of the soil samples be collected from the saturated soils just above the water table or the zone of seasonal water table fluctuation, where contaminants are most likely to migrate, in addition to the sample(s) collected from the area with the highest field screening results. NOTE: this section does not specify the number of samples per boring under Rationale like the Proposed HQ Facility does later on in the table.
Worksheet #15 soil :1,1,1-Tricholoroethane has a migration to groundwater cleanup level (Table B2 Method Two 18 AAC 75) of 0.82 mg/kg. 1,1-Dichloropropene has a migration to cleanup level of 0.033 mg/kg. Endrin has a migration to groundwater cleanup level of 0.29 mg/kg. gamma-Hexachlorocyclohexane (Lindane) has a migration to groundwater cleanup level of 0.0095 mg/kg.
For those contaminants without an ADEC soil cleanup level (e.g. 1,2,3-Trichlorobenzene), ADEC requests that EPA’s risk based Regional Screening Levels for Chemical Contaminants at Superfund Sites be used. For example, 1,2,3-Trichlorobenzene has residential soil screening level of 49 mg/kg and a protection of groundwater soil screening level of 0.087 mg/kg.
Worksheet #15 groundwater: For those contaminants without an ADEC groundwater cleanup level or MCL (e.g. 1,1,1,2-Tetrachloroethane) ADEC requests that EPA risk based Regional Screening levels for Chemical Contaminants at Superfund Sites be used. 1,1,1,2-tetrachloroethane has an EPA carcinogenic target risk ingestion level in tap water of 0.52 mg/L at 1 x 10-6 risk.
Worksheet #19: PCB analyses have no holding times and 40 days to analysis of extract is recommended (ADEC Draft Field Sampling Guide, Appendix D and E May 2010).
Attachment F-1: ADEC Interim Guidance for Non-UST POL Soil has been superseded by ADEC’s UST Procedure Manual (November 2002) and ADEC’s draft Field Sampling Guidance (May 2010). Please cease from using this outdated guidance in this work plan’s SOPs and any future planning, scoping documents. Provide effective dates for the referenced possible applicable, relevant, and appropriate requirements (regulations, guidance, permit) for the State of Alaska.
See site file for additional information.
|
Louis Howard |
| 8/25/2011 |
Update or Other Action |
Letter to Doyon Utilities, Attn: Robert Zacharski, UST Site Manager from Cheryl Paige (ADEC IPP Terminal and Tank Farms Section). Subject: Closure of Underground Storage Tank,ADEC :Facility #3547
The Alaska Department of Environmental Conservation (department) has received your post-closure documentation for permanent removal of the following underground storage tank (UST) system.
Facility Name: Doyon Utilities FRA I ADEC Facility #3547
Address: Building 772,724 Quartermaster Road City: JBER
ADEC Tank 1 (113), Owner 130A, Tank Contents-diesel Volume-20,000 gallons Compliance Tag 0949
I have permanently closed this tank in the department's UST database for both Facility#3547-Doyon Utilities (as Tank:#1) and Facility#788-JBER Fort Richardson (as Tank #113). The Site Assessment and Release Investigation Report is due no later than October 4, 2011, and is also required to satisfy the State UST regulations of Title 18 Alaska Administrative Code (AAC) 78, Underground Storage Tanks, regarding permanent closure.
The department's Contaminated Sites Program has oversight of any further requirements, upon review of your Site Assessment and Release Investigation Report) in accordance with applicable State of Alaska statutes and regulations. Keep a copy of this letter in your UST file for at least ten years (18 AAC 78.276(d)).
If you have any questions please call me at (907) 269-7679 or email cheryl.paige@alaska.gov. |
Cheryl Paige |
| 9/8/2011 |
Update or Other Action |
The Underground Injection Control (UIC) program at the U.S. Environmental Protection Agency,
Region 10, has received the December 2010 Closure Plan Report prepared on your behalf by Bristol
Environmental Remediation Services, LLC (Bristol), along with your letter dated January 25,2011,
regarding the removal of a Class V Injection Well at Building 772 located on Joint Base Elmendorf-Richardson, Alaska.
The Class V injection well was a wooden log cesspool which received fluids from a septic tank
that was connected to the sanitary line of Building 772. The cesspool and septic tank were
installed when the building was constructed in 1952. The septic tank was located approximately
27 feet south of the building and was connected to the building with a 4 inch diameter cast iron
pipe. The cesspool was connected to the septic tank with approximately 10 feet of pipe.
On August 16, 2010, Bristol located and exposed the tops of the outfall pipe, septic tank, and
cesspool, which were encountered at approximately 7 feet below ground surface (bgs). The
wood cribbed lids of both the septic tank and cesspool were found to be collapsed and the inside
of both were full of wood cribbing, debris, and soil.
It was unclear whether any of the floor drains or trench drains located at Building 772 were
connected to the septic system, therefore soil samples were collected from inside and surrounding the septic tank and cesspool in order to characterize the soil for disposal purposes.
The samples were analyzed for the following parameters associated with the fluids stored and
used in the building: gasoline range organics (GRO), diesel range organics (DRO), residual
range organics (RRO), volatile organic compounds (VOCs), semivolatile organic compounds
(SVOCs), RCRA metals, dioxins, furans, polychlorinated biphenyls (PCBs), and pesticides. The
soil had detectable levels of PCBs and concentrations of DRO and RRO above 1,000 mg/kg and
therefore it was determined that the excavated soil and debris were to be transported to the
Columbia Ridge Landfill, a Subtitle D landfill located in Arlington, OR, for disposal.
On September 16, 2010, the septic tank, cesspool, and surrounding soil were excavated.
Visually stained soil with a strong diesel odor was encountered a few feet below the bases of the septic tank (at approximately 18-19 feet bgs) and cesspool (at approximately 20 feet bgs). Soil removal was halted at approximately 22 feet bgs because at this point groundwater began to
accumulate in the excavation pit. In total, 163.86 tons of petroleum contaminated soil and debris were excavated and disposed of accordingly.
Four confirmation soil samples were collected from the sidewalls of the excavation; two from
near the former septic tank at 18 and 21 feet bgs and two from near the former cesspool at 18 and 21 feet bgs. Due to the presence of groundwater, soil samples were not collected from the base of the excavation. The samples were analyzed for GRO, DRO, RRO, VOCs, SVOCs, RCRA
metals, dioxins, furans, PCBs, and pesticides. DRO and SVOCs were detected at concentrations
that exceeded the Alaska Department of Environmental Conservation (ADEC) cleanup levels in
the soil samples that were collected at 21 feet bgs.
Before backfilling the excavation with clean soil, the outfall pipe was cut approximately 8 feet
from the building's south sidewall. The last foot of the remaining pipe was permanently sealed
with a cement grout.
The UIC program file for this facility has been updated to show that the Class V injection well has been permanently removed from the site. The UIC program understands that Joint Base Elmendorf-Richardson is working with ADEC's Contaminated Sites Program and the EPA Office of Environmental Cleanup to address appropriate next steps to respond to the analytical findings. If additional information becomes available indicating that the injection well closure activities at this site were inadequate, Joint Base Elmendorf-Richardson is required to provide the additional information to the EPA and further efforts may be required in the future. You are also advised that Joint Base Elmendorf-Richardson is responsible for compliance with all other federal, state, or local laws and regulations.
Signed, Peter Contreras, Manager, Ground Water Unit |
Louis Howard |
| 10/10/2011 |
Update or Other Action |
Doyon Utilities LLC UST Closure Report ADEC Facility ID 3547 Tank #113 Bldg. 772, JBER, Alaska
September 2011 received. This report presents a summary of soil excavation activities and laboratory sample analytical data for soil samples collected during closure of UST # 113 at ADEC- Facility # 3547, JBER, Alaska. This project was conducted for Doyon Utilities LLC. Sampling and analyses were conducted in accordance with State of Alaska 18 AAC 75 Articles 3 & 9 and Draft Field Sampling Guidance (May 2010).
UST #113 is a 20,000 gallon Diesel tank located at Building 772, JBER (former Ft. Richardson),
Alaska. Building 772 includes the former Power Plant. UST #113 was removed on August 4, 2011. At that time the former Power Plant facility was undergoing demolition and site remediation which included a abatement, and PCB waste removal.
The tank atmosphere was monitored periodically at throughout the removal process using a
calibrated RAE 4-gas meter. All tank atmosphere measurements indicated a 0% LEL. The tank was transported to Emerald Services, Anchorage, Alaska - an ADEC and EPA approved disposal facility - for cleaning and metal recycling.
The scope of work and objectives for this project included the following:
• Removal and decommissioning of Tank #113
• post-removal site assessment, soil sampling and analysis
• complete ADEC SARI and Site Assessment Report
The tank was excavated using an excavator. Excavated soil was stockpiled onto a poly-lined
staging area adjacent to the excavation. Excavated soils were inspected periodically for indications of fuel contamination. No indications of fuel-impacted soils were noted in the excavated soils.
Based on the depth of the excavation and concern for sloughing of excavation walls, all
samples were collected from the excavator bucket. A total of fourteen samples (12 plus 2 duplicates) were collected from soils at the bottomllower sides along the entire length and width of the tank. Each sample was collected from the excavator bucket using clean, disposable sampling spoons at each sampling location. Samples were placed directly into laboratory-supplied
jars and placed into a cooler with frozen gel packs for subsequent transportation and submittal to the laboratory. Samples were transferred under a chain-of-custody.
A review of the sample data report indicates all samples were received intact and properly labeled. Samples were properly preserved and extracted/analyzed within required holding times.
The RPD for Lab Sample 11H0044-MS1 was outside acceptance limits, Precision demonstrated using RPD for lab samples 11G0044 BS1/BSD1. The RPD for Lab Sample 11 H0044-DUP1 was outside acceptance limits, Precision demonstrated using RPD for lab samples 11 G0044 BS1/BSD1. The RPD for Lab Sample 11 H0050-MS 1 was outside acceptance limits, Precision demonstrated using RPD for lab samples 11 G0050 BS 1/BSD1.
The data is determined to be valid and representative.
Tank #113 at ADEC Facility 3547 was removed on August 4, 2011. The tank was used to store diesel fuel and had a capacity of 20,000 gallons. No indications of diesel-contaminated soil were noted during soil excavation and stockpiling. There were no signs of corrosion, punctures, gauges or tears in the tank body.
The tank atmosphere was measured before during and after removal using a calibrated RAE 4-gas meter. All measurements indicated that the tank atmosphere was 0% LEL. The tank was transported to Emerald Services, Anchorage, Alaska for cleaning, and metal recycling.
Fourteen representative soil samples (12 samples plus 2 duplicates) were collected from
the excavation and analyzed for Diesel Range Organics (DRO) and Residual Range Organics (RRO). No RRO compounds were detected in any of the samples. DRO compounds were detetecd at low levels in 2 of the samples and were not detected in 12 of the excavation samples.
Based on site observations and soil analytical data there are no indications that the tank
excavation area has been impacted by DRO/RRO. |
Louis Howard |
| 11/28/2011 |
Document, Report, or Work plan Review - other |
Staff reviewed and approved via email the DOYON revised SAP for Tank 113 on JBER-Richardson at the former bldg. 772. |
Louis Howard |
| 3/6/2012 |
Update or Other Action |
Draft Rapid Deployment Facility RI report received.
A total of 42 subsurface soil boring samples, two surface soil samples, and five soil gas
samples were collected during the 2011 sampling effort and submitted to TestAmerica (Tacoma, WA) for analysis of gasoline-range organics, diesel-range organics (DRO), residual-range organics, volatile organic compounds, semivolatile organic compounds, pesticides, polychlorinated biphenyls, and metals.
One surface soil sample collected near the railroad switches contained DRO at a concentration
of 550 mg/kg, exceeding the ADEC cleanup level (250 mg/kg). No other analytes, other than
those listed above, were detected in soil above the ADEC cleanup levels.
Work Plan Deviations
The five deep soil borings were advanced to 80 feet bgs but did not reach groundwater. The Work Plan stated that soil boring would be advanced to groundwater, which was estimated at 80 feet bgs; however, groundwater at the proposed RDF site appears to be deeper than 80 feet. Since subsurface contamination was not encountered anywhere at the site, the probability of groundwater contamination at the site is low.
Two surface soil samples were collected from underneath railroad switches in response to concerns of possible historic use of polychlorinated biphenyls (PCB) oil in the devices. Samples were collected in accordance with Standard Operating Procedure 2 (Appendix B of the Work Plan), Collection of Analytical Subsurface Samples, modified for surface collection by eliminating the drilling activities. Section 2.3 provides additional detail.
One borehole (RDF16) was extended beyond the original planned depth of 15 feet to 25 feet because historic diesel-range organics (DRO) and benzene, toluene, ethylbenzene, and xylenes contamination at 22 feet bgs was noted on the dig permit.
No wastewater samples were collected from the accumulated decontamination water during the RI. A sample will be collected from the accumulated water in spring 2012 to meet transportation and disposal requirements.
Concentrations of arsenic and chromium were also detected above the ADEC cleanup levels (3.9 mg/kg and 25 mg/kg, respectively). Concentrations of arsenic ranged from 5.1 to 20 mg/kg, and concentrations of chromium ranged from 25 to 48 mg/kg. Although the upper end of both the arsenic and chromium ranges are slightly greater than the background ranges specified in Background Metals Sampling Report, Volume 1 (USAF 1993), these concentrations most likely reflect background concentrations. Concentrations of arsenic and chromium are generally higher in samples collected from within or near the Elmendorf Moraine as documented by the samples collected during the installation of the landfill and Operating Unit E wells (CH2M HILL 2004). Arsenic and chromium are not considered contaminants of potential concern at the proposed RDF site.
Laboratory LOQs were evaluated against the project Work Plan sensitivity requirement of
one-tenth the ADEC cleanup levels. Analytes where the LOQs were greater than the Work
Plan sensitivity requirements due to limitations in the methodology were compared to the
ADEC cleanup level. When the LOQ exceeded the cleanup level, the LOD was evaluated.
Both the LOQ and LOD exceeded the ADEC cleanup levels for the following SW8260 and
SW8270 analytes in multiple samples:
1,2,3-Trichloropropane, 1,2-Dibromoethane, 1,2-Dichloroethane, 2,4-Dinitrotoluene, 2,6-Dinitrotoluene, bis-(2-Chloroethyl)ether, Chloromethane, Methylene chloride, n-Nitrosodimethylamine, n-Nitrosodi-n-propylamine, Pentachlorophenol.
Based on the results of the 2011 RI at the proposed RDF site, it is recommended that a limited
removal action should be conducted at the railroad switch location containing a concentration
of DRO above the ADEC cleanup level. After the contaminated soil has been removed, the
site is recommended for Cleanup Complete Status. |
Louis Howard |
| 4/4/2012 |
Update or Other Action |
Memorandum to the Site File (memo) received. This memo was prepared in accordance with the EPA Guidance & will become part of the administrative record for FfR271A & JBER. The FTR271A Proposed Headquarters (HQ) Facility site is a new site to be added to the Fort Richardson FF A per this memorandum.
Site Description
This site is the future location of an Army HQ Facility that is part of the Maneuver Enhancement Brigade (MEB) Complex. The MEB Complex will include the proposed HQ Facility Building, Company Operations Facility (COF), barracks, & associated facilities. The Site is located near the NW comer of D St & 5th Street on JBER-Richardson & encompasses the area formerly occupied by Bldg 772.
Building 772 was a standby diesel generator plant that was demolished during September 2011 along with the removal of Tank 113, a 20,000-gallon UST. Additional USTs, electrical transformers, & other buildings have also been removed from the Building 772 site during the past 50-plus years.
Contaminants of Potential Concern
COPC in soil at the site include DRO, RRO, PCBs, pentachlorophenol (PCP), benzo(a)pyrene, carbon tetrachloride, TCE, & tetrachloroethene (PCE).
DRO & PCP are the only COPCs that were identified both inside & outside the proposed building footprint above the most stringent ADEC Method Two, under 4O-inch zone cleanup levels.
Other COPCs that were identified above ADEC Method Two cleanup levels were encountered onsite, but outside of the proposed building footprint:
• PCBs were detected in concentrations above the ADEC cleanup level in samples up to 4 feet bgs on the eastern side of the site
• Petroleum, oil, & lubricant (POL) contamination was discovered at the surface to 27 feet bgs
• Carbon tetrachloride was detected above the ADEC cleanup level at 25 feet bgs & at 70 feet bgs, presumably in the smear zone
• A single PCE result was detected at 25 feet bgs
• TCE was detected at 10, 17, 25, & 70 feet bgs
The following list outlines the procedures to be following for construction at this site:
I) A removal action will be conducted to excavate & treat or dispose of POL-related contamination present within the footprint of the proposed building as shown on Figure 1. Contaminated soil will be excavated from within the building footprint. Field screening procedures & analytical sampling will be employed to delineate contamination & confirm that lateral extent of contamination has been excavated. Additionally, surface soil contamination (non-PCB) will be excavated from areas inside & outside the building footprint. The depression created by removal of former Building 772 will be backfilled with clean fill following necessary removal actions. The necessary work plans will be developed & submitted to ADEC for review & approval.
2) A vapor intrusion analysis will be conducted to determine the potential for diesel fuel vapors to migrate into the proposed facility. Mitigation measures will be implemented if necessary.
3) Excavation will not be allowed in areas on the east side of the site where PCB contamination has been detected in near-surface soils. This area will be covered with about 2 feet of classified fill & then covered with asphalt pavement, concrete sidewalk, or vegetation layer. Drainage features will be lined with impermeable liner to ensure proper site drainage & to prevent water infiltration into contaminated areas.
4) If it is necessary to remove vegetation (trees & shrubs) from any area where potential contamination exists, the contractor will ensure that all soil is removed from the debris & left on-site. If the debris contains soil, the contractor will characterize & properly dispose of the materials at an appropriate facility.
5) Additional soil borings will be drilled in the area where sample HQF30 was collected to further delineate PCB contamination at the site. This information will be included in the remedial investigation report.
Completion of RI & Decision Document
Actions outlined in this memo will be undertaken to facilitate construction of the proposed Army HQ Facility. RI activities will be completed in 2012 & presented to ADEC & EPA for review & comment. The new source area (FTR 271A) will meet the general requirements & deadlines as described in Attachment I (Federal Facility Scope of Work) of the Fort Richardson FFA, unless otherwise agreed to by the Air Force, EPA & ADEC.
Development of a risk assessment, PP, & ROD will begin in 2012 & will document the selected remedy for this site. Construction may result in encapsulation of contaminants at this site, but these actions will not preclude selection of a remedy resulting in the eventual removal of contamination from this site.
The risk to the Air Force is that remedial action could require demolition of newly constructed parking structures. |
Louis Howard |
| 5/3/2012 |
Update or Other Action |
Draft JBER Proposed Headquarters Facility Work Plan Addendum dated May 3, 2012 Air Force Center for Engineering and the Environment (AFCEE) Contract No. FA8903-08-8773 Task Order 109 received for review and comment.
This WPA only addresses the soil contamination within the proposed HQ Facility footprint to a depth of 9 feet below ground surface (bgs) and petroleum, oil, and lubricant (POL) contamination in surface soil (0 to 2 feet bgs) throughout the site. The 2012 IRA activities will focus on an estimated 250 cubic yards (cy) of soil at four locations within the footprint of the proposed HQ Facility and two surface locations within the footprint of former Building 772.
Soil will be excavated to a depth of 9 feet below ground surface (bgs) at the locations within the proposed HQ Facility footprint and to about 2 feet bgs where surface samples (SS01 and SS03) identified contamination during the 2011 RI. Excavated soil will be temporarily stored onsite in two segregated stockpiles: one for contaminated soil and another for suspected clean overburden soil, as determined by previous sample results, photoionization detector (PID) field screening, PetroFLAG® field screening, and field observations.
Waste characterization samples will be collected from the stockpiled soil to determine whether the soil should then be thermally treated, disposed of at the Anchorage Regional Landfill (ARL), or re-used onsite (if the soil meets the most stringent ADEC cleanup levels). Excavation confirmation samples will be collected from the floor and sidewalls of each excavation at the frequencies specified in the ADEC Draft Field Sampling Guidance (ADEC 2010).
Excavation confirmation soil samples will be analyzed for DRO, residual-range organics (RRO), PCP, and/or PCBs based on the contaminants identified in the original soil borings and adjacent soil borings during previous investigations. Soil sample results will determine whether remaining soil contains concentrations of contaminants above ADEC cleanup levels. Excavations will continue, as necessary, until contaminated soil likely to be encountered during the building construction activities has been removed. Sample frequencies and analyses for the specific excavation areas are discussed below.
RI activities to be conducted in 2012 will characterize PCB contamination near soil boring HQF30, where PCB contamination was detected at a concentration of 12 mg/kg, well above the ADEC cleanup level of 1 mg/kg. Twenty soil borings will be advanced to a depth of 5 feet bgs and two primary samples will be collected from each boring and analyzed for PCBs. The additional RI activities will include collection of groundwater samples from four onsite wells.
Following the completion of excavation activities, groundwater samples will be collected from each of the four monitoring wells onsite (AP-3874, AP-3914, AP-5689, and AP-5690). To test whether contaminants are present in the groundwater system, one sample will be collected from each of the wells.
Groundwater samples will be analyzed for GRO, DRO, RRO, VOCs, SVOCs, pesticides, PCBs, and RCRA metals. These contaminants were all identified in either soil or groundwater during the 2011 investigation activities. Groundwater sampling procedures are presented in the field SOP JBER-SOP-4 (RI Work Plan, Appendix B [USAF 2011]), including field documentation forms.
The objective of the additional RI sampling is to further characterize and quantify PCB contamination in soils near location HQF30, where PCBs were identified at 12 mg/kg. This
task will be achieved by completing the following:
- Determine the extent of PCB-contaminated soils using direct-push soil borings. A total of
20 soil borings will be advanced to a depth of 5 feet below ground surface (bgs)
surrounding HQF30.
- Collect laboratory analytical composite samples from 0 to 2.5 feet bgs and 2.5 to 5 feet
bgs. These samples will be used to determine the depth of the contamination bgs and the
horizontal extent of the contamination.
- Collect wastewater samples from the decontamination water used to clean the drilling
equipment.
- Plug bore holes with bentonite or grout to 0.5 feet bgs to prevent infiltration of water to
the subsurface soil.
- Survey soil borings to guide future excavation activities. |
Louis Howard |
| 5/4/2012 |
Document, Report, or Work plan Review - other |
Staff reviewed & commented on the draft work plan addendum for the Proposed HQ Facility Work Plan Addendum.
1.0 Introduction
Please direct the reader to the proposed building footprint drawings or diagrams which detail the building footprint limits & depths of the required buried utilities (electrical, water, sewer, stormwater) necessary as part of the proposed Headquarters Facility.
2.0 Site Background
Text states subsurface soil outside the building footprint & onsite groundwater contamination will be addressed in a future FS. ADEC requests clarification on the future feasibility study based on unknown horizontal & vertical extent of contamination in the soil & groundwater if JBER does not conduct the required sampling now to capture these data gaps as part of this remedial investigation.
1994 Federal Facility Agreement Part III PURPOSE paragraph 3.2(c) states:
“Establish requirements for the performance of a Remedial Investigation ("RI”) to determine fully the nature & extent of the threat to the public health or welfare or the environment caused by the release or threatened release of hazardous substances, pollutants, or contaminants at the Site, & to establish requirements for the performance of an FS for the Site to identify, evaluate, & select alternatives for the appropriate remedial action(s) to prevent, mitigate, or abate the release or threatened release of hazardous substances, pollutants, or contaminants at the Site in accordance with CERCLA & applicable state law;”
VIII. Scope of Agreement
EPA Guidance for Conducting Remedial Investigations & Feasibility Studies under CERCLA October 1988 EPA/540/G-89/004
“The objective of the RI/FS process is not the unobtainable goal of removing all uncertainty, but rather to gather information sufficient to support an informed risk management decision regarding which remedy appears to be most appropriate for a given site.”
“Analyses that are important to the subsequent risk assessment & subsequent development of remedial alternatives include the horizontal & vertical extent of contamination in soil, ground water, surface water, sediment, air, biota, & facilities. Spatial & temporal trends in contamination may be important in evaluating transport pathways.”
Stopping excavation, characterization of contaminated media based on the footprint of the future building (vertically & horizontally) & be able to proceed to a feasibility study does not match the FFA & EPA guidance regarding remedial investigations under CERCLA. It is highly likely additional remedial investigation-like activities will be needed to characterize the nature & extent of contamination after this phase of work is completed prior to conducting a feasibility study.
3.0 Project Execution Approach
The text states the soils will be excavated to a depth of 9 feet below ground surface at locations within the proposed HQ Facility footprint. Excavations will continue, as necessary, until contaminated soil likely to be encountered during the building construction activities has been removed. ADEC requests JBER clarify what will be done if contaminated soil remains in the ground below this depth or in a horizontal direction beyond the HQ Facility Building footprint.
5.3 Field Screening
Lack of a positive field screening response from the PID, PetroFLAG or any other field screening device shall not preclude JBER from taking the required number of laboratory soil samples.
5.5 Stockpile Characterization Sampling
See comment on 5.3 above. |
Louis Howard |
| 5/24/2012 |
Document, Report, or Work plan Review - other |
Staff reviewed and approved the JBER's responses to ADEC comments on the HQ Facility Work Plan Addendum. Document may be finalized. |
Louis Howard |
| 5/29/2012 |
Offsite Soil or Groundwater Disposal Approved |
Approval granted to JBER to transport 250 cy of petroleum contaminated soil from FTR271 project (Proposed HQ Facility) to ASR. |
Louis Howard |
| 1/30/2013 |
Update or Other Action |
Remedial Investigation/Interim Removal Action draft report received.
The goals of this project were to characterize the environmental conditions, to define the nature & extent of contamination, & to conduct an interim removal of contaminated soil necessary to protect the safety of workers during construction activities.
Surface soil samples 11HQF-SS01 & 11HQF-SS03 contained DRO at 6,900 mg/kg & 350 mg/kg, respectively; both of which exceeded the ADEC cleanup level of 250 mg/kg. Soil sample 11HQF-SS01 also exhibited RRO (36,000 mg/kg) that exceeded the ADEC cleanup level of 10,000 mg/kg. Concentrations of PCP, dieldrin, & mercury were exhibited by Sample 11HQF-SS02 at 0.22 mg/kg, 0.009 mg/kg, & 2.4 mg/kg, respectively; all of which exceeded their respective ADEC cleanup levels.
In addition, levels of benzo(a)pyrene, exceeding or equal to the EPA screening level (0.21 mg/kg), were exhibited by soil samples 11HQF-SS02 & 11HQF-SS04 at 0.31 mg/kg & 0.21 mg/kg, respectively. It is noted that the levels of benzo(a)pyrene exhibited by soil samples 11HQF-SS02 & 11HQF-SS04 were below the most conservative ADEC cleanup level (0.40 mg/kg) .
GW samples from AP-3874 (11HQFAP-3874 & duplicate 11HQFAP-3874.9) exhibited DRO & carbon tetrachloride exceeding the ADEC Table C cleanup levels of 1.5 mg/L & 0.005 mg/L, respectively. DRO was detected at 2.5 mg/L & carbon tetrachloride was detected at 0.0096 mg/L; the highest levels from the duplicate pair are listed. Additionally, chromium was detected at 0.14 mg/L in AP-3874 & at 0.16 mg/L in AP-3914, exceeding the ADEC cleanup level of 0.1 mg/L. Arsenic (0.075 mg/L), lead (0.052 mg/L), chromium (3.5 mg/L), & carbon tetrachloride (0.008 mg/L) detected in sample 11HQFMW01-GW (AP-5689) exceeded respective ADEC cleanup levels
PCBs exceeded the ADEC cleanup level of 1 mg/kg were exhibited by 25 of the 44 primary & duplicate samples collected during drilling activities. 17 of these 25 samples were collected from 0 to 2.5 feet bgs & had levels from 1.3 to 9.3 mg/kg. The remaining 8 exceedances were collected from 2.5 to 5 feet bgs, with PCBs ranging from 1.5 to 26 mg/kg.
Based on sample exceedances, the lateral extent of PCB contamination in the vicinity of HQF30 has NOT been defined. Although the precise lateral extent of PCB contamination was not defined in close proximity to HQF30, numerous soil samples collected in the general vicinity of the HQF30 investigation area did NOT exhibit concentrations of PCBs exceeding the ADEC cleanup level of 1 mg/kg.
Summary & Recommendations
Field activities in 2012 focused on the removal of the contaminated soil at the locations described above. During the IRA, approximately 1,464 tons of contaminated soil was excavated & transported to ASR for thermal remediation; additionally approximately 4.5 tons of contaminated soil was transported to CWMNW for disposal. Confirmation soil samples collected from the final HQF34 excavation boundaries exhibited elevated DRO exceeding the ADEC cleanup level indicating that the vertical & lateral (easterly) extent of contamination has yet to be defined.
As described above, the contaminated soil previously identified within the proposed HQ Facility building footprint was removed up to a depth of 9' bgs. Subsurface contaminated soil does remain at the site in areas that will not be impacted by the proposed construction activities.
Both the LOQ and LOD exceeded the ADEC cleanup levels for the following SW8260 and SW8270 analytes in multiple samples.
1,2,3-Trichloropropane
2,6-Dinitrotoluene
Chloromethane
Methylene chloride
1,2-Dibromoethane
4-Chloroaniline
Dieldrin
Nitrobenzene
1,2-Dichloroethane
alpha-BHC
gamma-BHC (Lindane)
n-Nitrosodimethylamine
2,4-Dinitrophenol
beta-BHC
Heptachlor epoxide
n-Nitrosodi-n-propylamine
2,4-Dinitrotoluene
bis-(2-Chloroethyl)ether
Hexachlorobenzene
Pentachlorophenol
The complete list of sample results with LODs greater than the ADEC cleanup level is
presented in Table C-1-1 (Attachment C-1). Future investigations at the site should include
low-level volatile organic compound (VOC) analysis of soil samples to determine whether the
analytes with LODs greater than the ADEC cleanup level are chemicals of potential concern. |
Louis Howard |
| 1/30/2013 |
Update or Other Action |
Draft HHRA work plan received.
The risk assessment will be conducted in accordance with EPA Risk Assessment Procedures. The purpose of the risk assessment is to estimate & quantify any potential risks that site contamination could pose to human health following EPA risk assessment guidance established under the Comprehensive Environmental Response, Compensation, & Liability Act (CERCLA). This process includes sufficiently characterizing the contaminants, potential exposure routes, & potentially exposed human populations to determine whether unacceptable risks exist at the site. The results of the risk assessment are intended to guide risk-management decisions at the JBER-Richardson HQ Facility.
An ecological risk assessment is not being performed due to the current & future industrial nature of the site & the absence of ecological receptors.
Risk-based screening for human health focuses the assessment on the chemicals that may contribute significantly to overall risk & to remove from quantification those chemicals whose contribution is clearly inconsequential. In this screening, the maximum detected concentration (MDC) is compared to the appropriate risk-based screening concentration (RBSC). The units of the MDC & RBSC are the same for each chemical in a given medium.
The maximum reporting limit for analytes with no reported detections will be compared to the RBSC. If the maximum reporting limit exceeds the screening level, the analyte will be retained for qualitative evaluation in the HHRA. If the MDC of a chemical is less than or equal to its RBSC, then the chemical in this medium is not considered further in the HHRA because it is unlikely that chemical levels at or below the RBSC would contribute significantly to risk. An analyte is identified as a COPC if its MDC exceeds its RBSC. RBSCs used in this HHRA will be derived from EPA Regional Screening Levels (RSL) (EPA 2012) & ADEC Method Two cleanup levels. Contaminants that are considered to be related to past activities at the site may be retained as COPCs based on best professional judgment regardless of the results of screening.
For cancer risk, the RSL values will be used directly as RBSCs in the HHRA because they are based on an ILCR of 1E-6; acceptable exposure levels are generally levels that represent an excess upper bound lifetime cancer risk to an individual of 1E-6 to 1E-4 (EPA 1990), referred to as the “risk-management range.” The ADEC “risk-management range” of 1E-5 will also be considered. Cancer risks associated with RBSC values represent the lower end of this range. For this HHRA, the RBSC for a chemical that elicits both cancer & noncancer health effects will be selected based on either a cancer risk of 1E-6 or an HQ of 0.1, whichever associated concentration is lower.
Contaminants will be screened out as CO PCs if they are not detected in any sample, are detected only at levels less than the RBSC, or are detected only at levels below background levels. Although the ingestion of GW exposure pathway is technically complete, JBER does not allow the use of GW at this site nor is GW a current or likely future drinking water source. JBER controls GW use administratively through 673d Air Base Wing Instruction 32-7003. However, ADEC has not formally evaluated the GW per 18 AAC 75.350.
To address direct contact through incidental soil ingestion, dermal absorption of contaminants from soil, inhalation of contaminants in fugitive dust, & inhalation of volatile contaminants in soil, soil data collected from 2010, 2011 & 2012 will be evaluated. Data for these years are presented in detail in the JBER Proposed Headquarters Facility RI/IRA Report (USAF 2013). Soil analysis results was compared to the cleanup levels provided in 18 AAC 341, Tables B1 & B2, Method Two, under 40-inch zone most stringent cleanup levels (ADEC 2012).
To address vapor intrusion/inhalation of indoor air for workers within the future HQ Facility, GW data from AP-5690, AP-3874, AP-3914, & AP-5689 will be evaluated. Only volatile compounds identified in Appendix D of ADEC Policy Guidance for Developing Conceptual Site Models will be addressed (ADEC 2010). GW data addressing indoor VI will be initially compared to ADEC Target Levels for GW published in Appendix G of ADEC’s Draft VI Guidance for Contaminated Sites (ADEC 2012a).
The EPA VI Screening Level Model will also be used to address volatile compounds in GW & subsurface soil (EPA 2012). The EPA model is based on the analytical solutions of the 1991 Johnson & Ettinger model for contaminant partitioning & subsurface vapor transport into buildings. Since that time (1991), revisions have been made & a series of new models have been added. Data for any chemical may be edited, new chemicals added, or existing chemicals deleted from the Lookup Table within the VLOOKUP worksheet. |
Louis Howard |
| 2/28/2013 |
Document, Report, or Work plan Review - other |
Staff provided review comments on the RI/IRA report for the proposed Headquarters Facility.
Executive Summary
ADEC requests JBER state that the purpose of the remedial investigation & interim removal action activities were not to fully characterize the site as required by CERCLA (e.g. OSWER Directive 9355.3-01) & the Fort Richardson Federal Facility Agreement (e.g. VIII. Scope of Agreement), but it was conducted to support the construction of a new building (Proposed Headquarters Facility).
Proposed HQ Fac. & Proposed Rapid Deployment RI WP states: “The goals of this project are to characterize the environmental conditions, define the nature & extent of contamination, & ascertain whether modifications to building design &/or remedial actions are needed to provide for the safety of construction workers & future building occupants at the proposed Headquarters (HQ) Facility (CC-FTRS-17) & the proposed Rapid Deployment Facility (RDF) (CC-FTRS-16).”
Site Description & History
There is conflicting information in the work plan which states two crushed drums of PCE were discovered during tank removal & four drums found on top of the UST during excavation noted in the Public Works Memo below.
APVR-RPW-EV 31-July 1995
MEMORANDUM FOR Ellen Klug, Alternate Contracting Officer, JOC
SUBJECT: Drums & Related Contaminated Soils at Building 772
Samuel P. Swearingen
ADEC has no records of the analysis of the stockpiled soil, confirmation samples taken for chlorinated solvents, disposition of the remaining drums. Please state that there were four drums with chlorinated solvents uncovered at the site & one drum was crushed during UST removal activities.
Please state that during the 1997 DOWL/Ogden JV RI detected DRO from samples collected at depths of 20 & 30 feet bgs (13,700 mg/kg & 15,000 mg/kg boring AP-3805).
Also missing from this section is discussion of the July 22, 2011 WEC report “Sampling & Analysis Report PCBs in Soil, Paint, Oil, Surface Wipes & Concrete Building 772” The purpose of the sampling endeavor described in this report was to obtain information to adequately address worker protection during the demolition actives, develop demolition strategies based on the findings & to profile the demolition waste stream.
The scope of the demolition work was limited to building components; no remediation or removal of contaminated soils was part of this work. PCBs were detected above the 1 mg/kg cleanup level in seven composite soil samples ranging from 1.40 mg/kg (Sample ID 060-CPS) to 57 mg/kg (sample ID 059-CPS).
The 4 composite soil samples with the highest PCB exceedances collected on May 26, 2011 (WEC) are in the vicinity of the one sample collected by Jacobs in 2010 (HQ15).
3.2.1 HQF34 Borehole Location
The text states: “Contaminated soil identified on the east side of this excavation was left in place because that area was outside the footprint of the proposed HQ Facility building.” This appears to the reader to be an area requiring further investigation or excavation & confirmation sampling.
3.2.1.1 Excavation Analytical Results
The text states: “Soil samples 12HQF34-C50-05, 12HQF34-C51-05 (a duplicate of 12HQF34-C50-05), & 12HQF34-C54-05 collected from the eastern sidewall of the excavation exhibited concentrations of DRO ranging from 308 to 404 mg/kg; all of which slightly exceed the ADEC cleanup level of 250 mg/kg. Because the eastern edge of the HQF34 excavation was at the boundary of the proposed HQ building footprint the excavation activities did not continue east.”
Last Paragraph
The text states: “Soil sample 12HQF34-C56-05 (collected from the northeastern sidewall of the excavation) exhibited concentrations of DRO & PCBs at 422 mg/kg & 4.21 mg/kg, respectively; both of which exceed their applicable ADEC cleanup criteria. Similarly this location was at the edge of the proposed HQ building footprint & additional excavation activities were not conducted.”
This appears to the reader that these two areas require additional investigation, excavation activities & confirmation sampling.
HQFSS01 Borehole Location
The text states: “The identified contaminated soil was discovered within the former building’s footprint at approximately 7 feet below grade; therefore, the potentially contaminated soil was only removed to approximately 2 feet bgs.”
ADEC requests clarification on which confirmation samples were taken after the 17 cy was removed from the location. Table 3-2 does not indicate which samples are sidewall samples and which samples are from the base of the excavation.
This area appears to the reader to be an area that requires additional investigation, excavation and confirmation sampling. Or if already covered by the construction of the new building, an area that will need to be addressed as part of the selected remedy. |
Louis Howard |
| 2/28/2013 |
Document, Report, or Work plan Review - other |
Staff provided comments on the HHRA work plan.
4.5 Quantification of Exposure Points
The maximum detected concentration in groundwater shall be used as the EPC for the assessment of risk posed due to exposure to groundwater (i.e., ingestion, dermal contact, inhalation of volatiles from water). Considering the dynamic nature of groundwater, it is not deemed appropriate to average concentrations over an aquifer. This is recognized in 18AAC75.345 (e). This is also consistent with compliance determination in 18AAC75.380(c)(2) requiring the use of the maximum concentration in groundwater.
As discussed in previous comments above, all groundwater is considered drinking water source on JBER & should not be eliminated as a pathway for purposes of a baseline risk assessment.
The NCP establishes general expectations for purposes of groundwater restoration as follows:
(F) EPA expects to return usable ground waters to their beneficial uses wherever practicable, within a timefrarne that is reasonable given the particular circumstances of the site. When restoration of ground water to beneficial uses is not practicable, EPA expects to prevent further migration of the plume, prevent exposure to the contaminated ground water, & evaluate further risk reduction.”
Principles/or Groundwater Remediation
“As discussed in the NCP & in various associated guidance, there are in general, five key principles that stem from the overarching expectations for groundwater restoration. These are as follows:
1) If groundwater that is a current or potential source ofdrinking water is contaminated above protective levels (e.g., for drinking water aquifers, contamination exceeds Federal or State MCLs or non-zero MCLGs), a remedial action under CERCLA should seek to restore that aquifer to beneficial use (e.g., drinking water standards) wherever practicable.
2) Groundwater contamination should not be allowed to migrate & further contaminate the aquifer or other media (e.g., vapor intrusion into buildings; sediment; surface water; or wetland).
3) Technical impracticability waivers & other waivers may be considered, & under appropriate circumstances granted if the statutory criteria are met, when groundwater clean up is impracticable; the waiver decision should be scientifically supported & clearly documented.
4) Early actions (such as source removal, plume containment, or provision of an alternative water supply) should be considered as soon as possible. ICs related to groundwater use or even surface use, may be useful to protect the public in the short-term, as well as in the long-term.
5) ICs should not be relied upon as the only response to contaminated groundwater or as a justification for not taking action under CERCLA.9 To ensure protective remedies, CERCLA response action cleanup levels for contaminated groundwater should generally address all pathways of exposure that pose an actual or potential risk to human health & the environment.”
(EPA OSWER Directive 9283.1-33 “Summary of Key Existing EPA CERCLA Policies for Groundwater Restoration” June 26, 2009).
See site file for additional information.
|
Louis Howard |
| 3/21/2013 |
Document, Report, or Work plan Review - other |
EPA comments on the HHRA Work Plan.
Sec 1.0,
p. 1-1 The introductory sentence describes the HHRA as addressing potential risks based on results of the 2010-2012 field sampling activities. In the accompanying draft RI/IRA, the goal of the 2011-2012 sampling effort was to protect worker safety during construction activities (draft Proposed HQ Facility RI/IRA report, January 2013, Section 1.1, page 1-1). The 2011-2012 sampling has not adequately characterized site conditions for risk to future workers or residents, particularly in regard to the source and extent of carbon tetrachloride contamination in soils and groundwater.
Please clarify how the HHRA will assess risk to future workers (in the building) and residents based on samples collected for the specific purpose of protecting workers during construction activities.
Sec 1.2,
p. 1-5
Please update EPA 1997a Exposure Factors Handbook with the 2011 version of the Exposure Factors Handbook, which supersedes the 1997 edition.
EPA Exposure Factors Handbook (2011) under Downloads on this page
Please add the followingEPA guidance to the list of reference guidance documents.
Risk Assessment Guidance for Superfund (RAGS), Volume I: Human Health Evaluation Manual (Part F, Supplemental Guidance for Inhalation Risk Assessment), 2009
EPA Risk Assessment Guidance Part F (2009 Inhalation Risk Assessment)
Sec 3.1.2
Fig 3-1
Please delete reference to the use of Frequency of Detection as a means of evaluating data inclusion in the HHRA. Given the small numbers of samples and the use of Risk Based Screening as outlined in section 3.2.1, the frequency of detection in less than 5% of samples as a data screening tool should be eliminated from the narrative and the flow chart in Figure 3-1.
Sec 3.2.3 Screening of metals against background is not consistent with EPA’s 2002 guidance (EPA 540-R-01-003, Appendix B), which says to include them and then discuss the contribution of background to the overall risk estimate.
From APPENDIX B POLICY CONSIDERATIONS FOR THE APPLICATION OF BACKGROUND DATA IN RISK ASSESSMENT AND REMEDY SELECTION Summary points on page B-5 to B-6:
The COPCs retained in the quantitative risk assessment should include those hazardous substances, pollutants, and contaminants with concentrations that exceed risk-based screening levels. The Risk Characterization should include a discussion of elevated background concentrations of COPCs and their contribution to site risks. Naturally occurring elements that are not CERCLA hazardous substances, pollutants, and contaminants, but exceed risk-based screening levels should be discussed in the risk characterization
|
Louis Howard |
| 3/21/2013 |
Document, Report, or Work plan Review - other |
EPA (Sandra Halstead) provided comments on the RI/IRA Report.
Sec. 1.1 & 2.0
The project goals and objectives narrative states the RI/IRA was performed to ensure worker safety during construction activities. This may not provide representative data for a remedial investigation for future industrial or residential scenarios. Please repeat the objective of this RI for worker safety during construction in the opening sentence of section 2.0.
Figure 2-1
Please explain the tan contour lines in the legend of Figure 2-1. Surface topography?
There appears to be an error in reporting the cleanup level for soil boring at AP-5690. 0.023 is reported as both the cleanup level and the sample result. Cleanup level should be consistent with 0.005 mg/kg for carbon tetrachloride.
Figure 2- 1 and Figure 2-2
Note: Carbon Tetrachloride was found at depth (to ~70 fbgs in the gw smear zone) in all well borings and groundwater samples with the exception of AP-3914, which is about 30 ft deeper than the other groundwater wells at ~103 fbgs. Additoinal characterization to determine the source of the carbon tetrachloride is recommended.
Excavation Analytical Results (numerous sections including 3.2.1.1; 3.2.6; 3.3.2)
In numerous locations, confirmation samples exceeded cleanup levels for contaminants but excavation was not advanced and contaminants were left in place. (HQF 34, SS02). “Capping” with clean material and/or construction of a building over the contaminated soil cannot be determined as the final remedy as a part of this interim removal action.
EPA strongly recommends further evaluation of the contaminated soils and groundwater, especially in regard to compounds that may contribute to the indoor air exposure pathway via volatilization.
3.3.2 This section summarizes PCB contamination near sample location HQF30 which has not been defined over a lateral extent within the 3600 ft2 sampling area. Please clarify the sentence “Although the precise lateral extent of PCB contamination was not defined in close proximity to HQF30, numerous soil samples collected in the general vicinity of the HQF30 investigation area did not exhibit concentrations of PCBs exceeding the ADEC cleanup level of 1 mg/kg.” |
Louis Howard |
| 5/31/2013 |
Document, Report, or Work plan Review - other |
ADEC has received the final version of the Remedial Investigation/Interim Removal Report for TU117 Brigade HQ Facility (FTR-271A) CS DB Hazard ID 2766 on JBER-Richardson on May 28, 2013. ADEC has reviewed the document and has no further comments on it. The document is approved. |
Louis Howard |
| 8/9/2013 |
Update or Other Action |
Draft Human Health Risk Assessment report received.
Uncertainties arise from limits on the number of locations that can be sampled. The sampling protocol used at TU117, however, was designed to optimize efficiency of the sampling effort & reduce uncertainty by focusing on areas around former process bldgs., storage structures, & potential transfer piping. Sampling appears to be sufficient to show that the contamination is largely limited to soil & GW. Surface water & sediments are not present in the vicinity of the TU117 site. Soil vapor data for VOCs are not available, which introduces uncertainty regarding concentrations & potential for migration to indoor air within the HQ facility. Indoor air data from within the HQ facility are also not available.
A further source of uncertainty for noncancer effects arises from use of an effect level in the estimation of an RfD or RfC, because this estimation is predicated on the assumption of a threshold below which adverse effects are not expected. Therefore, an additional uncertainty factor is usually applied to estimate a no-effect level. Additional uncertainty arises from estimating RfD values for chronic exposure from less-than-chronic data.
Unless empirical data indicate effects do not worsen with increasing duration of exposure, an additional uncertainty factor is applied to the no-effect level in the less-than-chronic study. In summary, the EPA methodology for both cancer & noncancer toxicity evaluation is intentionally designed to be protective. However, the extent to which toxicity values may overestimate toxic potency is not clear, & it is possible that the toxicity values for some compounds may not be adequately protective.
Total HI estimates for the indoor/outdoor onsite worker for soil & GW are 0.02 & 0.1, respectively. The COPCs for the soil HI were dioxins/furans, metals, VOCs, & SVOCs. The COPCs for the GW HI were bis(2-ethylhexl) phthalate (BEHP), carbon tetrachloride, chloroform, & TCE. The total HI for all soil & GW for the indoor/outdoor onsite worker is 0.2. The total ILCR estimate summed across all media for the indoor/outdoor onsite worker receptor was 2E-5.
The ILCR for soil & GW were 1E-6 & 2E-6, respectively. The COPCs for the ILCR were dioxins/furans, PCBs (Aroclor 1260 only), metals (arsenic only), VOCs, & SVOCs in soils & BEHP, carbon tetrachloride, chloroform, & TCE in GW. Exposure to carbon tetrachloride via vapor intrusion (VI) into bldgs. from GW resulted in an HQ of 2.8E-07 & ILCR of 7.2E-11.
The current & future construction worker was evaluated for exposure to soils (ingestion, dermal contact, & inhalation of fugitive dust). Total HI for soils for the construction worker is 0.1. The COPCs for soils are dioxins/furans, metals, VOCs, & SVOCs. The total ILCR for the construction worker is 4E-6. The COPCs for the ILCR in soil are dioxins/furans, Aroclor 1260, metals (arsenic only), VOCs, & SVOCs.
Total HI estimates for the future resident for soil & GW were 0.03, & 0.4, respectively. The COPCs for the soil HI were dioxins/furans, metals, VOCs, & SVOCs. The COPCs for the GW HI were BEHP, carbon tetrachloride, chloroform, & TCE. The total HI for soil & GW for the resident was 0.4.
The total ILCR estimate summed across all media for the resident was 1E-4. The COPCs for the ILCR were BEHP, carbon tetrachloride, chloroform, & TCE in GW, & dioxins/furans, Aroclor 1260, metals (arsenic only), VOCs, & SVOCs for soil & air. Exposure to carbon tetrachloride via VI into bldgs. from GW resulted in an HQ of 2.8E-07 & ILCR of 7.2E-11.
Total HIs for contaminants in soil & GW are less than 1 for the current/future indoor/outdoor onsite worker, current/future construction worker, & hypothetical future resident. Total cancer risk to soil & GW for a current/future indoor/outdoor onsite worker are within the acceptable EPA cancer risk range of 1E-6 to 1E-4 but exceed the acceptable ADEC risk range of 1E-6 to 1E-5.
Total cancer risk to soil for a current/future construction worker are within the acceptable EPA cancer risk range of 1E-6 to 1E-4 & the acceptable ADEC risk range of 1E-6 to 1E-5. Total cancer risk to soil & GW for the future resident are within the acceptable EPA cancer risk range of 1E-6 to 1E-4 but exceed the acceptable ADEC risk range of 1E-6 to 1E-5.
The primary contributor to the elevated GW cancer risk for the resident is the ingestion of carbon tetrachloride. VI HIs & ILCRs for the indoor bldg. air scenario are below the acceptable EPA & ADEC risk management ranges. |
Louis Howard |
| 9/24/2013 |
Document, Report, or Work plan Review - other |
EPA comments on the 1st draft of the HHRA received on August 8, 2013. Document received for review on August 8, 2013. An extension to review the report was requested & received with a deadline for regulator comments on September 30, 2013. The Vapor Intrusion model spreadsheet was absent from the original draft report & was received for review on September 9, 2013. The following comments include review of the Vapor Intrusion model spreadsheet.
Sec 6.0
p. 6-1 In the Uncertainties Analysis, Sampling & Analytical Limitations section, suggests the sampling effort conducted under the Interim Removal Action at the Brigade HQ facility is sufficient to conduct a risk assessment. However, the introduction both the Human Health Risk Assessment & of the RI/IRA report, page 1-1, states “goals were to characterize the environmental conditions, to define the nature & extent of contamination, & to conduct an interim removal of contaminated soil necessary to protect the safety of workers during construction activities.” The Response to Comments in the Interim Removal Action Report agrees
Section 2.1.1, Evaluation of Data Quality, p. 2-7: Please provide a specific justification from the QAPP indicating why various sample results were considered valid when specified quality control procedures were not met, as the designation of less than twice the specified holding time seems arbitrary. P.2-7
Secondly, the treatment of contamination in method blanks appears inconsistent with EPA guidance. According to the CLP National Functional Guidelines (EPA 2010), when a blank sample contains detectable levels of organic or inorganic chemicals not considered to be common laboratory contaminants, the result in the primary sample should be positively detected only when the concentration in the sample exceeds 5 times the maximum amount detected in any blank. Samples containing less than 5 times the amount in any blank should considered non-detect, with the blank-related concentration set as the quantitation limit for the sample. If needed, the results of the associated primary samples should be re-qualified & subsequent evaluations adjusted as necessary.
EPA 2010. National Functional Guidelines for Organic Superfund Data Review. EPA-540-R-08-01
http://www.epa.gov/superfund/programs/clp/download/somnfg.pdf
Sec 2.2 Process of Identification of Chemicals of Potential Concern, p. 2-9 to 2-11
The use of a separate screening process to assess the vapor intrusion pathway for contaminants detected in groundwater fails to account for the potential of cumulative exposure, as the initial screening levels do not account for the vapor intrusion pathway. Thus, while VOCs may not pose an unacceptable risk/hazard due to vapor intrusion alone, the cumulative exposure may be unacceptable when combined with additional pathways. Accordingly, all VOCs selected as COPCs in groundwater should be evaluated in the vapor intrusion assessment. In addition, where the screening levels are presented in Appendix B, “risk-based” values should clarify whether they were selected from EPA’s Regional Screening Level tables or the ADEC tables of cleanup values.
Section 2.3, Derivation of Exposure Point Concentrations, p. 2-11 As a clarification, EPA considers the 95 percent UCL on the arithmetic mean as a central tendency estimate of exposure concentration, & recommends it be used in estimates of both central tendency & reasonable maximum exposure, & the text here should be revised accordingly to clarify that use of the UCL is not limited to a RME evaluation.
Section 3.2.3, Receptors and Exposure Routes, p. 3-4 The discussion in this section lists inhalation of fugitive dust as a complete exposure pathway for residential, onsite workers, and construction workers. However, the subsequent discussion in Section 3.3 presents no further information on the quantification of the inhalation pathway, and it does not appear to have been evaluated. The discussion in Section 3.2.3 should either provide acceptable justification why this isn’t considered a complete exposure pathway, or is considered insignificant, or exposure via inhalation of fugitive dust should be quantitatively evaluated in the subsequent sections.
Table 5-1 p. 5-6
Table 5-1 is titled as the Summary of Noncancer Hazards and Cancer Risks for Current/Future Indoor/Outdoor onsite workers. However the last line of the table provides a summary calculation risk for Total HI and ILCR for Resident. Please clarify the Total HI and ILCR risks to workers. This issue is repeated on Table 7-1. |
Louis Howard |
| 1/27/2014 |
Update or Other Action |
ADEC received the Headquarters Facility 2012-2013 PCB-Contaminated Soil Removal
and Well Decommissioning (Draft) for review and comment.
This removal action was conducted to ensure worker safety by removing PCB-contaminated
soil, which would otherwise have been excavated by the construction contractor. These
efforts significantly reduced potential worker exposure by either removing the contaminated
soil or covering the contaminated soil that was left in place. In the HQF30 area, where PCB-contaminated soil has been left in place; concentrations range from 1.3 to 26 mg/kg. In the
HQF17 area, all of the excavation confirmation samples were less than 1 mg/kg, indicating
that all of the PCB-contaminated soil was removed from this location.
In addition, HQ03 (2.1 mg/kg), HQ14 (2.6 mg/kg), HQ15 (1.9 mg/kg), and HQF34-C56 (4.21 mg/kg) all have PCB concentrations greater than 1 mg/kg. Other contaminants of concern have also been identified at the site and are summarized in the TU117 Brigade Headquarters Facility (FTR271A) Remedial Investigation/Interim Removal Action Report (USAF 2013). This report details the recommendations for the site, which include the preparation of a human health risk assessment and feasibility study for both soil and groundwater contamination. |
Louis Howard |
| 2/6/2014 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft HQ Fac. PCB-Contaminated Soil Removal.
Introduction
The text states: “This removal action was conducted to remove PCB-contaminated soil that would present a health risk to workers during the placement and compaction of structural fill to support parking lot construction.”
The removal action appears to be equivalent to an interim action under the Fort Richardson Federal Facility Agreement. Interim actions shall neither be inconsistent with nor preclude implementation of the final expected Site remedy and shall be undertaken in accordance with the NCP, 40 CFR Part 300, as amended, and with the requirements of CERCLA.
Soil Removal Activities
The text states: “To prevent exposure of the construction workers to the contaminated soil, USAF and USACE requested that Jacobs complete the removal activities using properly trained and qualified personnel to package, transport, and dispose of the contaminated soil in accordance with all applicable regulations.”
ADEC could not locate the resumes and work experience of all the “qualified persons ” that were involved in this project. While this is a technical memorandum, the information regarding “qualified persons” must be included. In accordance with 18 AAC 75.355(b), the Air Force must ensure that the collection, interpretation, and reporting of data, and the required sampling and analysis at TU117 was conducted or were directly supervised by a qualified, impartial third party. Please provide to ADEC for its review, the names of the staff and their qualifications in the technical memorandum as an appendix that shows that they meet the educational and work experience requirements of 18 AAC 75.990(100) if they were the “qualified person” on site for field work at TU117 Headquarters Facility.
|
Louis Howard |
| 2/10/2014 |
Document, Report, or Work plan Review - other |
EPA comments on the 1st draft final redline HHRA.
HHRA Report Comment: The Final Human Health Risk Assessment Report, TU117 HQ Facility indicates that the potential for current & future receptors to be exposed to contaminants through direct contact, dermal absorption, inhalation of volatile contaminants, & inhalation of fugitive dust is likely overestimated due to the presence of the TU117 HQ building & 2 to 3' of clean fill covering a majority of the site; however, unless the site includes LUCs/ICs which keep the building & fill intact, there is no assurance that the area will remain undisturbed. Please revise the HHRA Report to clarify that ICs are not considered in the risk assessment in regard to the potential for current & future receptors to be exposed to contaminants through direct contact, dermal absorption, inhalation of volatile contaminants, & inhalation of fugitive dust.
HHRA Report Comment: Insufficient data are available to sufficiently evaluate the potential for vapor intrusion/inhalation of indoor air. Section 2.2 states, “To address vapor intrusion/inhalation of indoor air for workers within the TU117 Brigade HQ Facility, groundwater data from monitoring wells AP-5690, AP-3874, AP-3914, & AP-5689 were evaluated.” Section 2.2 indicates that GW data from four monitoring wells (i.e., AP-5690, AP-3874, AP-3914, & AP-5689) were used to evaluate VI/inhalation of indoor air for workers within the TU117 HQ Facility & Section 6.0 indicates that no soil vapor data for volatile organic compounds (VOCs) were available. As such, the VI/inhalation of indoor air for workers within the TU117 HQ Facility is based on only four sampling locations, three of which no longer exist (decommissioned or buried) according to Figure 1-4. Please revise the HHRA Report to clarify how 4 sampling locations are sufficient to characterize VI/inhalation of indoor air for workers within the TU117 Brigade Headquarters Facility.
HHRA Report Comment: Section 3.2.3 indicates that the two to three feet of clean fill which covers the majority of the site will reduce the potential for current & future receptors to be exposed to contaminants through inhalation of volatile contaminants. While the clean fill will reduce the potential for current receptors to be exposed to contaminants through inhalation of volatile contaminants, the potential for future receptors to be exposed to contaminants through inhalation of volatile contaminants will likely not be reduced as contaminants in the subsurface &/or GW could volatize & contaminate the clean fill, potentially collecting under the TU117 HQ Facility. Please revise the HHRA Report to clarify that the clean fill cover does not reduce the potential for future receptors to be exposed to contaminants through inhalation of volatile contaminants.
HHRA Report The text indicates that EPA’s GW_ADV spreadsheet model was used in the evaluation of the vapor intrusion pathway. The GW_ADV model is based on the Johnson & Ettinger model.
While the ADEC guidance for vapor intrusion indicates that ADEC will accept the results of models based on the Johnson & Ettinger model, the guidance also recommends that a thorough uncertainty analysis be provided for the model application. An analysis of the uncertainties associated with the application of the GW_ADV model has not been provided. In addition, due to the uncertainties associated with the J&E Model, EPA does not support its use to contraindicate the presence of or the significance of vapor intrusion when detections in environmental media exceed the most relevant health-based screening criteria.
In cases where environmental concentrations of subsurface vapor sources exceed the screening criteria obtained from the Vapor Intrusion Screening Level (VISL) calculator, EPA recommends that VI generally be assessed using multiple lines of evidence. This assessment should address, but may not limited to:
• Characterization of the subsurface vapor source(s);
• Characterization of vapor migration & attenuation in the Vadose zone;
• Characterization of the building foundation, including the susceptibility to soil gas entry;
• Characterization of the building interior; &
• Characterization of outdoor & indoor sources of vapor-forming chemicals.
The characterizations should be based on appropriate sampling results; however, site-specific modeling (e.g., site-specific modeling using the GW_ADV) can be considered as one component of the building interior characterization. |
Louis Howard |
| 4/29/2014 |
Document, Report, or Work plan Review - other |
ADEC has reviewed JBER's responses to ADEC's comments and finds them acceptable and concurs with the responses. |
Louis Howard |
| 6/12/2014 |
Enforcement Agreement or Order |
Federal Facility Agreement (FFA) Document Schedule for TUl 17 -Brigade Headquarters Facility, JBER-Richardson.
Attached for your review and acceptance is the proposed document schedule for TUl17 - Brigade Headquarters Facility on Joint Base Elmendorf-Richardson, Richardson (JBER-R), Alaska. If approved, the schedule will be attached to the current JBER-R FFA (5 December 1994).
If you concur with the proposed schedule, please sign in the block provided on the attached signature page and return the original signature page to me. Should you have questions or comments, please feel free to contact me at (907) 384-1824.
Document type: Draft Feasibility Study, date due for agency review: 22 December 2014
Document type: Draft Record of Decision, date due for agency review: 15 October 2015.
Upon approval, this document will be attached to the current FF A (effective 5 Dec 1994). The
document schedule may be updated or modified to include additional primary or secondary
documents as necessary to meet FF A requirements. Changes will require approval of FF A
Project Managers.
Signed by G. Fink USAF, S. Halstead EPA, L. Howard ADEC. |
Louis Howard |
| 4/4/2016 |
Update or Other Action |
Supplemental RI/FS Mgt. Plan received for review & comment. The following activities will be performed at TU117:
• Mobilize & Prepare for Site Work – Obtain all necessary materials, equipment, & personal protective equipment (PPE), as well as a dig permit.
• Soil Boring Advancement – Advance 10 soil borings to groundwater & record visual & olfactory observations & field screening values.
• Groundwater Well Installation – Four of the 10 soil borings will be completed as groundwater monitoring wells according to the procedures listed in JBER-SOP-1200 Monitoring Well Installation & Development (Appendix C) to a depth of approximately 70 to 85 feet bgs based on an approximate depth to groundwater of 65 to 80 feet bgs.
• Soil Boring Sampling – Collect field screening soil samples 1 from borings every 5 to 40 feet bgs, followed by every 10 feet to the groundwater interface, & collect five analytical soil samples per boring. Soil samples will be analyzed for GRO, DRO, RRO, VOCs, SVOCs, pesticides, PCBs, & RCRA metals plus nickel & vanadium. Samples collected from the soil-groundwater interface will be analyzed on a 7-day turnaround time to help determine the proper monitoring well locations.
• Surface Soil Sampling – Collect surface soil samples from surface locations (not borings) from 0 to 2 feet bgs. Soil samples will be analyzed for GRO, DRO, RRO, VOCs, SVOCs, pesticides, PCBs, & RCRA metals plus nickel & vanadium. Locations for the surface samples will be evaluated following the soil boring activities.
• Well Development – Develop groundwater monitoring wells at least 24 hours after installation using EPA & ADEC low-flow guidelines (EPA 2009; ADEC 2016b).
• Groundwater Sampling – Collect one analytical groundwater sample at least 24 hours after development from each of the four newly installed wells & from existing wells AP-5000 (deep upgradient), AT035-MW02 (shallow downgradient), & AP-3914 (deep downgradient), twice & approximately 6 months apart. Groundwater samples will be analyzed for GRO, DRO, RRO, VOCs, SVOCs, pesticides, PCBs, & RCRA metals plus nickel & vanadium.
• Vapor Intrusion Evaluation – Collect four indoor air, four outdoor air, & four near slab soil gas samples & indoor air handling system readings quarterly, from up to 10 buildings. Samples will be analyzed for VOCs. Buildings that will be sampled for vapor intrusion will be selected after the soil & groundwater results have been reviewed.
• Site Survey – Record positions of site features, soil borings, & monitoring well tops of casings using global positioning system (GPS) positioning methods &/or differential level-loop measurement methods.
• Investigation-Derived Waste Disposal – Manage all investigation-derived waste (IDW) (i.e., used PPE & sampling equipment, soil cuttings, & decontamination/purge water) & ensure proper disposal.
See site file for additional information. |
Louis Howard |
| 4/18/2016 |
Update or Other Action |
Staff provided comments on the draft Mgt. plan for TU117. Main comments were regarding definition of a "Murphy Plant" listed in the text for a notation on as-builts for the facility, requesting 1,4-dioxane analysis in groundwater since chlorinated solvents are also present and VI pathway evaluation for PCBs since the Henry's law constant is exceeded by what EPA considers a substance to be volatile.
Lastly, staff requested that the migration to groundwater cleanup levels are also promulgated cleanup levels which need to be considered during the RI/FS investigation in addition to screening levels based on 1/10th of ingestion, outdoor inhalation, direct contact levels which in many cases are higher than migration to groundwater cleanup levels in soil.
See site file for additional information. |
Louis Howard |
| 5/16/2016 |
Meeting or Teleconference Held |
Conf. call with JBER, EPA, DOYON UTILITIES, ADEC staff. Basically the Air Force and Doyon met May 6, 2016 and decided to proceed with full demolition of the 772 Central heating power plant instead of temporarily encapsulating the 30-45% of the siding which has flaking paint. Funding is an issue, it will be sought for this fiscal year and if by October 1, 2016, no funding can be made available to demolish the building to 12' below grade to 1 ppm PCBs, a new approach will be sought in the interim. This will likely involve encapsulation of the siding as originally proposed. 12' bgs is the depth of the first floor to the top of the 2nd floor below the ground and that is what is being proposed as the demolition depth for concrete. Asbestos in all of the structure (3 floors above grade, 3 floors below grade).
The sediment basin(s) on site will be looked and sampled for PCBs/Lead to determine whether or not the decades of peeling paint has reached these areas. |
Louis Howard |
| 7/26/2016 |
Document, Report, or Work plan Review - other |
Staff provided comments on the RI/FS mgt. Plan.
Main comments were regarding the need to ensure the contractor drills to groundwater and not limit drilling to an arbitrary contract limit of 80 feet bgs and to ensure that surface soil sampling at a site where fill material was placed occurs at the original surface soil interface and not in clean fill material.
See site file for additional information. |
Louis Howard |
| 9/11/2019 |
Document, Report, or Work plan Review - other |
Staff commented on the Draft TU117 – Building 772 Supplemental Remedial Investigation/Risk Assessment Report JBER-Richardson, Alaska Contract No. FA3002-08-D-0001 / Task Order No. 0001. Dated August 2019.
Staff commented on the migration to groundwater cleanup level exceedances are to be used for site delineation and potential fate and transport of contaminants to groundwater. Diesel range organics (DRO), chloroform, and trichloroethylene (TCE) all exceeded the migration to groundwater cleanup levels in soil and were detected in groundwater above Table C groundwater cleanup levels. Migration to groundwater exceedances are to be used for site delineation, consistent with other CERCLA investigations on JBER . If these contaminants in soil and groundwater are not addressed by CERCLA for further consideration in the feasibility study (FS) , then ADEC will require them to be addressed under State regulations (18 AAC 75) and associated guidance documents.
See site file for additional information. |
Louis Howard |
| 12/3/2019 |
Update or Other Action |
December 3, 2019 FFA Schedule revision signed by USAF, EPA and ADEC includes source area TU117.
Draft Supplemental Management Plan Draft to agencies: January 15, 2021
Draft Supplemental RI Report Draft to agencies: September 30, 2021
Draft FS Report Draft to agencies: January 31, 2022
Draft Proposed Plan* Draft to agencies: June 15, 2022
Draft Record of Decision* Draft to agencies: March 25, 2023.
* AT035, SS013, and TUI 17 will be on one PP and ROD as the 3 sites are physically contiguous.
This document will be attached to the current FFA (effective 5 Dec 1994). The document schedule may be updated or modified to include additional primary or secondary documents as necessary to meet FF A requirements. Changes will require approval of [all three] FFA Project Managers. |
Louis Howard |
| 4/12/2021 |
Document, Report, or Work plan Review - other |
DEC submitted comments on Draft JBER Basewide UFP-QAPP dated February 2021. |
William Schmaltz |
| 5/19/2021 |
Document, Report, or Work plan Review - other |
DEC Reviewed and approved of Basewide Uniform Federal Policy - Quality Assurance Project Plan. QAPP summarizes general activities for a 5 year period on JBER. |
William Schmaltz |
| 4/25/2023 |
Document, Report, or Work plan Review - other |
DEC submitted comments regarding the TU117 – Former Building 772 Supplemental Remedial Investigation/Feasibility Study Management Plan, Draft, Dated March 2023. The work plan describes the investigation methods to identify a source area for carbon tetrachloride and chloroform in groundwater, address data gaps in plume delineation, and to re-evaluate the contaminants of potential concern at TU117 located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. Soil, groundwater, and soil gas samples will be collected. The work plan proposes to compare sample results to the Environmental Protection Agency’s (EPA) regional screening levels (RSLs) for residential soil or 1/10th of the most stringent of DEC’s Method Two Table B1 Under 40-Inch Zone Human Health cleanup levels, commercial soil gas vapor intrusion screening levels, and EPA’s RSLs for tap water. To evaluate the potential for contaminants to migrate to groundwater the EPA site-specific protection of groundwater soil screening level calculator will be used. The work plan also describes the procedures for conducting a baseline risk assessment once all the data is gathered at the site. |
Ginna Quesada |
| 4/26/2024 |
Document, Report, or Work plan Review - other |
DEC provided responses to comments regarding the TU117 – Former Building 772 Supplemental Remedial Investigation/Feasibility Study Management Plan, Revised Draft Final, dated April 2024. The work plan describes the investigation methods to identify a source area for carbon tetrachloride and chloroform in groundwater, address data gaps in plume delineation, and to re-evaluate the contaminants of potential concern at TU117 located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. Soil, groundwater, and soil gas samples will be collected. The work plan proposes to compare sample results to the Environmental Protection Agency’s (EPA) regional screening levels (RSLs) for residential soil or 1/10th of the most stringent of DEC’s Method Two Table B1 Under 40-Inch Zone Human Health cleanup levels, commercial soil gas vapor intrusion screening levels, and EPA’s RSLs for tap water. To evaluate the potential for contaminants to migrate to groundwater the EPA site-specific protection of groundwater soil screening level calculator will be used. The work plan also describes the procedures for conducting a baseline risk assessment once all the data is gathered at the site. |
Ginna Quesada |
| 5/9/2024 |
Document, Report, or Work plan Review - other |
DEC approved the TU117 – Former Building 772 Supplemental Remedial Investigation/Feasibility Study Management Plan, Final, dated May 2024. The work plan describes the investigation methods to identify a source area for carbon tetrachloride and chloroform in groundwater, address data gaps in plume delineation, and to re-evaluate the contaminants of potential concern at TU117 located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. Soil, groundwater, and soil gas samples will be collected. The work plan proposes to compare sample results to the Environmental Protection Agency’s (EPA) regional screening levels (RSLs) for residential soil or 1/10th of the most stringent of DEC’s Method Two Table B1 Under 40-Inch Zone Human Health cleanup levels, commercial soil gas vapor intrusion screening levels, and EPA’s RSLs for tap water. To evaluate the potential for contaminants to migrate to groundwater the EPA site-specific protection of groundwater soil screening level calculator will be used. The work plan also describes the procedures for conducting a baseline risk assessment once all the data is gathered at the site. |
Ginna Quesada |
