| Action Date |
Action |
Description |
DEC Staff |
| 10/28/1983 |
Update or Other Action |
US Army Environmental Hygiene Agency GW Quality Survey No. 38-26-K986-91 Evaluation of Solid Waste Management Units Fort Richardson AK 24 June to 2 July 1991. This survey was performed to evaluate and update the Solid Waste Management Unit (SWMU) information contained in Fort Richardson's RCRA Facility Assessment (RFA); to determine which SWMU's require further sampling, investigation, or corrective action; and to identify and evaluate any SWMU's not previously documented.
SMWU's Not Previouslv Identified in the RFA. The following SWMU was not in existence or were not discovered during the RFA. This site should be formally added to the SWMU list, and supporting documentation regarding ongoing work or justification for no further action should be provided to the regulator prior to issuance of the permit.
TABLE 4. SWMU'S Requiring Addtional Investigation: Former Soil Aeration Area/UST at Building 726. Building 726 is the post laundry/drycleaning facility, which has operated since the 1950's. The UST containing petroleum solvents (e.g. *PD680 or Stoddard Solvent) was removed in the mid-1980's (the plant uses perchloroethylene solvent; this is assumed to be the tank contents).
Soils from the excavation, apparently contaminated with solvent, were placed on the ground at the UST site for aeration. An HNU detector did not indicate the presence of organic vapors at the time of tank excavation. The soil pile was present for several months until the soil was disposed of. The quantity of soil, condition of the ground (soil or paved), and extent of contamination are unknown. Due to the relative mobility of solvents in ground water and the unknown length of time that the UST was leaking, this site requires investigation into potential soil and ground-water contamination. It is recommended that Fort Richardson proactively pursue this site investigation rather than delaying action until the corrective action negotiations.
*NOTE: Each item the Govt. orders must have an N.S.N, a National Stock Number, unless the Agency gets special permission to local purchase the item. Each N.S.N. item goes out for bid and has an
associated minimum specification. The specification for PD680, aka. Stoddard Solvent, back in the 1980's and before was for a petroleum based degreaser with a specified flashpoint. No
requirement for non-halogenated existed. Besides that, because Alaska was so far from venders that supplied the Govt., many federal agencies in Alaska purchased solvents locally. There were no qualifications on those solvents and most often halogenated solvents worked with less effort than pure petroleum distillates, so they were preferred.
NSNs ordered through the PD680 specs had some batches with TCE, Methylene chloride, etc; it depended on who the supplier to the Govt.was at the time. So as a result between 1980 and 1983,
some PD680 batches were in fact halogenated. For historical releases it pays to be aware that chlorinated solvents may be associated with releases from PD680 or Stoddard Solvent. |
Jennifer Roberts |
| 4/5/1991 |
Enforcement Agreement or Order |
Resource Conservation and Recovery Act (RCRA) Federal Facility Compliance Agreement signed. Section V Required Compliance Action 20(K) states that the Post shall cease taking hazardous waste at 45590 (Old Auto Craft Shop) for greater than 90 days without a permit and comply with 40 CFR 262.34(b). The Post shall determine if their waste located at 45590 is a hazardous waste and comply with 40 CFR 262.11. The Post shall obtain a detailed chemical and physical analysis of a representative sample of waste or use knowledge of the waste to determine if the wastes are hazardous wastes, as required by 40 CFR 2w62.11 and comply with 40 CFR 265.13(a)(1) and 40 CFR 268.
Fort Richardson had failed to prepare a hazardous waste manifest for hazardous waste shipped off-site as required by 40 C.F.R. §262, Subparts (A-D) for wastes generated at building 726. Hazardous waste tetrachloroethylene (F002) generated at Fort Richardson's dry cleaners operations was disposed of at the Hiland Road Municipal Sanitary Landfill.
See site file for additional information. |
Louis Howard |
| 6/12/1991 |
Update or Other Action |
June 12, 1991 Resource Conservation & Recovery Act (RCRA) HW Management Compliance Evaluation Inspection Report documents Tim Law, Daniel Hartung, Vic Vickaryous, Geoffrey Kany, of ADEC's RCRA program inspection the Post for compliance with the provisions of the compliance agreement (FFCA) on April 29, April 30, 1991.
Buildinq 45590 - AAFES Auto Center
The nine 55-gallon drums and the two white 5-gallon containers that were observed along the southern side of the building in May 1990 have been removed. One container that formerly contained used oil was lacerated. See photo #55. The container in the background contains antifreeze. Although the containers have been removed from the concrete pad, some residue remains, which appears to possibly be the release of hazardous constituents.
The above ground used oil tank was sampled and the analysis confirmed that it was used oil and not hazardous waste, according to Ms. Scott. The 'tank bung hole was open. An empty 55-gallon container was abandoned behind Building 45590 next to a smashed manhole.
It appeared as though the facility had satisfied Paragraph 21.K. of the FFCA. |
Louis Howard |
| 7/2/1991 |
Update or Other Action |
US ARMY Environmental Hygiene Agency: Groundwater Quality Survey No. 38-26-K986-91 Evaluation of Solid Waste Management Units, Ft. Richardson AK 24-June - 2 July-1991.
This survey was performed to evaluate and update the Solid Waste Management Unit (SWMU) information contained in Fort Richardson's RCRA Facility Assessment (RFA); to determine which SWMU's require further sampling, investigation, or corrective action; and to identify and evaluate any SWMU's not previously documented.
CONCLUSIONS. Four of the 120 previously-identified SWMU's require sampling and analysis to verify environmental release, and 14 sites are being investigated under separate programs.
Thirty-one SWMU's are Waste Accumulation Areas (WAA's), some of which require improvements to identify, prevent, or control environmental releases. Eighteen underground storage tanks
(UST's) require no actions other than continued documentation of efforts. The two SWMU's located at Camp Carroll should not be addressed under Fort Richardson's corrective action requirements. Based on a low potential for release and/or a lack of a susceptible migration pathway, 51 SWMU's require no further action. Six new SWMU's were identified, five of which have ongoing or planned investigations. The remaining new SWMU requires no further action.
3. RECOMMENDATIONS. Provide the information contained in this report, along with supporting documentation for all SWMU's, to the permitting agency when issuance of the Part B RCRA permit
becomes imminent. Initiate investigative actions recommended at SWMU's 15/120, 37, and 41 to determine whether environmental releases have occurred. Implement the improvements recommended
for specific WAA's to identify, prevent, or control environmental releases.
Maintain complete documentation of all sampling and analysis, remedial action, construction/removal, or investigation work associated with every SWMU. Continue with ongoing or planned investigations -at 14 original SWMU's and five new SWHU's.
Former Soil Aeration Area/UST at Building 726.
Building 726 is the post laundry/drycleaning facility, which has operated since the 1950's. The UST containing petroleum solvents was removed in the mid-1980's (the plant uses perchloroethylene solvent; this is assumed to be the tank contents). Soils from the excavation, apparently contaminated with solvent, were placed on the ground at the UST site for aeration. An HNU detector did not indicate the presence of organic vapors at the time of tank excavation. The soil pile was present for several months until the soil was disposed of. The quantity of soil, condition of the ground (soil or paved),and extent of contamination are unknown.
TABLE 4. SWMU'S REQUIRING ADDITIONAL INVESTIGATION
SWMU NO. SWMU NAME ACTIONS
15,120 Former Soil Aeration Area/UST at Bldg 726. Soil/ground-water sampling
Due to the relative mobility of solvents in ground water and the unknown length of time that the UST was leaking, this site requires investigation into potential soil and ground-water
contamination. It is recommended that Fort Richardson proactively pursue this site investigation rather than delaying action until the corrective action negotiations. |
Louis Howard |
| 4/5/1993 |
Update or Other Action |
A Plan Prepared for U.S. Army Corps of Engineers, Alaska o;strict Project Support Section
Post Office Box 898 Anchorage, Alaska 99506-0898 Contract No. DACA85-91-0-0008 Delivery Order No. 0008 RELEASE INVESTIGATION PIAN/QUALlTY ASSURANCE PROJECT PLAN UNDERGROUND STORAGE TANK SITES FORT RICHARDSON, ALASKA HLA Project No. 21844 received for review and comment. Sites include the following Buildings: 45590 Old Auto Hobby Shop, 750 Motor Pool, 755 Auto and Crafts Center, 756 Motor Pool, 974 Special Purpose Equipment Repair Shop, 796 Vehicle and Weapons Repair Shop, 47811 Veterinary Clinic, 47438 Bryant Army Airfield Fuel Facilty Tanks 65, 67 and 68, 47438 Bryant Army Airfield Fuel Faiclity Tank 69, 47641 Former Aero Club, and 28004 Chlorination Facility. |
John Halverson |
| 8/30/1993 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation-Defense Facilities Oversight group (ADEC)
has received on November 15, 1993 a copy of the DRAFT Interim Site Assessment/Remedial
Investigation Site 4, building 35752 High Frequency Transmitter Site, HLA Project No. 24212. Here are ADEC’s comments regarding this document.
3.1.1 Deviations from the Release Investigation Plan pages 13 & 14
The text states that the two inch standpipe near monitoring well AP-3232 was investigated through geophysics by Harding Lawson Associates. A conclusion was reached that an underground storage tank was not associated with this standpipe. Although the standpipe was not considered for further investigation by HLA, ADEC requests that the Army further investigate and/or remove it from the site to prevent it from becoming a conduit of contamination to the subsurface soils.
5.2.2 Soil Boring Sampling Results page 36 2nd paragraph
The text sites that Diesel Range Organics (DRO) and Gasoline Range Organics (GRO) concentrations
were in excess of ADEC Level A cleanup levels mainly in borings AP-3227 and AP-3228. ADEC is concerned that the presence of petroleum contaminants in the subsurface soils: in particular, at the fifteen foot depth interval along with Polychlorinated BiphenyIs (PCBs) may pose a signiticant risk to the environment through increased mobilization. ADEC requwts that any corrective action plans or interim removal actions for this site incorporate an appropriate method of dealing with PCB contaminated soils (i.e. TSD facility).
The document also states that a qualitative risk assessmen for risk based concentrations (RBCs) and potential receptors at the site be conducted to determine actions levels for PCBs. ADEC requests that the risk assessment cover: the potential multiple pathways and contaminants present at the site, potential migration to groundwater since it appears that the some of the contaminants are at the soil/groundwater interface, and an ecological assessment.
5.2.3 Groundwater Sample Results page 38 third paragraph
The text states that the significant decrease of contaminant concentrations in wells AP-2982 and AP-2987 and lack of detected contaminants in other nearby downgradient wells suggests that the contaminants detected during the 1990 USACE investigation are dissipating. This assumption cannot be substantiated with the current data set given the qualifications listed in 4.2.1 on page 25.
The text states that no duplicates or MS recoveries for Volatile Organic Compounds (VOCs) were submitted for several of the aqueous samples so the data precision and accuracy could not be assessed.Subsequently, the data is suspect and should be viewed with caution. ADEC requests that additional sampling be conducted to verify the absence or presence of VOCs in all of the monitoring wells at the site.
5.2.4 Surface-Water and Sediment Sampling Results Page 39 first paragraph
The text states that cleanup levels are not established for sediment, however there are sediment quality criteria (SQC) available that the U.S. EPA recommends be considered in establishing remediation goals for contaminated sediments. The SQC were designed to be protective of aquatic life and animals that consume aquatic life.
The PCB SQC is not a fixed value; rather, it is dependent on the total organic carbon (TOC) concentration in the sediment. In order for the appropriate SQC level to be determined, the TOC will have to be calculated from another round of sediment sampling. ADEC requests that a sampling plan be submitted outlining specifictily what sediment sampling will be done and exactly how the sample will be collected.
Appendix F Chemical Quality Assurance Report
Use of the detection limits for PCBs water samples of 0.5 to 1.0 ug/L (ppb) is not low enough to
determine if the National Ambient Water Quality Criteria of 0.014 ug/L was exceeded. ADEC
requests that additional water sampling of all monitoring wells at the site for PCBs (in addition to the VOCs mentioned in section 5.2.3) be performed with methods that are able to detect this level of concern. |
Louis Howard |
| 9/2/1993 |
Update or Other Action |
Preliminary Release Investigation Report Underground Storage Tank Sites Fort Richardson, Alaska, dated July 6, 1993 received by ADEC for review and comment. The report covers the following sites:
Plate 3 Site A, Building 45590, Old Auto Hobby Shop
Plate 4 Site B, Building 750, Motor Pool
Plate 5 Site C, Building 755, Auto and Crafts Center
Plate 6 Site D, Building 756, Motor Pool
Plate 7 Site E, Building 974, Special Purpose Equipment Repair Shop
Plate 8 Site F, Building 796, Vehicle and Weapons Repair Shop
Plate 9 Site G, Building 47811, Veterinary Clinic
Plate 10 Site H, Building 47438, Bryant Anny Airfield Fuel Facility
Plate 11 Site I, Building 47641, Former Aero Club
Plate 12 Site J, Buildi ng 28004, Chlorination Facility
Plate 13 Site K, Building 955, Used POL Holding Facility |
John Halverson |
| 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 Comprehensive Environmental Response, Compensation, and Liability Act (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 |
| 11/15/1993 |
Document, Report, or Work plan Review - other |
The Department of Environmental Conservation (ADEC) staff has reviewed the Corps of
Engineers Scope of Work for the upcoming investigation at Bldg. 726 on Fort Richardson.
These comments are based on the July 14, 1993 Draft Sampling and Analysis Plan. Here are
our comments regarding this document.
Field Sampling Plan
3. Sampling Strategy 4th paragraph page 2
The text states that an air rotary rig will be used to install seven borings, four of which will
be developed into monitoring wells. ADEC requests that the Corps utilize the “ADEC
Recommended practices for Monitoring Well Design, Installation, and Decommissioning”
final version dated April 1992 when installing these monitoring wells. ADEC recommends
when an air-rotary drilling method is utilized in monitoring well development to identify
organic compounds, that the following should be taken into consideration:
1) The air must be filtered to insure that oil from the air compressor is not introduced to
the formation to be monitored. If it is necessary to add water to the borehole during
drilling, only potable water should be used, and the source of the water should be identified.
2) The use of air rotary drilling methods in highly contaminated areas is difficult to
control since the water and cuttings (which may be contaminated) are blown out of the hole posing a hazard to the drill crew & obsemers. If it is necessary to add drilling mud to the borehole during drilling to stabilize the hole or control downhole fluid losses, only high yield sodium bentonite clay free of all organic polymer additives should be used.
3) In areas where volatile compounds are of interest, air-rotary can volatilize those
compounds & cause water samples withdrawn from the hole to be unrepresentative of
in-situ conditions. The sampling regime and well development must reflect and
recognize these conditions.
4) If foam additives are used to aid cuttings removal, then this may present an
opportunity for organic contamination of the monitoring well that may not have been
present in the first place.
3. Sampling Strategy
ADEC requests that one sample per boring have a full hazardous waste determination (i.e.
ignitability, corrosivity, reactivity) and TCLP (Toxicity Characteristic Leaching Procedure)
analysis performed in addition to the eight RCRA metals that have been proposed in Table 1
(one) of the plan.
7. References
Please include as a reference the ADEC “Recommend Practices for Monitoring Well Design,
Installation, and Decommissioning” dated April 1992. |
Louis Howard |
| 9/12/1994 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft Release Investigation Report and Corrective Action Plan Bldg. 45590 Contract No. DACA85-93-D-0013
The Alaska Department of Environmental Conservation (ADEC) has received the above document on
August 31, 1994. Based on our meeting with you on September 12, 1994 and the data presented,
bioventing is the preferred alternative for remediating the contaminated soils. ADEC concurs with the recommendation. ADEC requests the site be added to the NON-UST State Fort Richardson 2 Party Agreement for followup. |
Louis Howard |
| 3/15/1995 |
Update or Other Action |
Building 45590 was originally constructed in 1943 and was used as an auto hobby shop.
The building was refurbished and an annex added in 1956. Additional annexes were
added in 1966 and 1972.
Based on data collected during the bioventing feasibility test, bioventing was determined
to be an appropriate technology to remediate the impacted soils. The system consists of
a 0.5 HP Rotron DR 303 regenerative blower, one vertical air injection vent well, and
three soil gas monitoring points. The bioventing system was started in November 1994.
The COE authorized EMCON to conduct quarterly groundwater sampling through July
1995. The groundwater sampling includes measurements of groundwater elevation for
determining groundwater flow direction and collection of groundwater quality samples.
The first quarterly groundwater monitoring event occurred from November 29 to
December 11, 1994. The findings of the monitoring event are summarized in the report
entitled Quarterly Monitoring Report December 1994 Sampling Event Building 45590 Fort
Richardson, Alaska. This groundwater monitoring report details the methodology and
findings of the second quarterly monitoring event conducted from March 13 to March
14, 1995.
Analytical results from EMCON’s 1994 release investigation and the November/December 1994 monitoring event indicate that groundwater collected from monitoring well AP3387 (MW-l), installed in the vicinity of the former suspected dry well, contained diesel-range organics (DRO) and gasoline-range organics (GRO) at concentrations exceeding Alaska Department of Environmental Conservation (ADEC) Water Quality Criteria. In the previous sampling efforts, tetrachloroethane (PCE) was detected at concentrations, marginally above the ADEC Drinking Water Regulations maximum contaminant level (MCL) in Al?3387 (MW-I), AP3439 (MW-2), and AP3440
(MW-3). Analytical results also indicated that sampled groundwater did not contain metals above appropriate ADEC and federal cleanup levels. Other contaminants of concern did not exceed ADEC Water Quality Criteria or MCLs.
PCE was detected above the MCL (5 micrograms per liter [ug/L]) in 5 water samples: 95FRU567WG, 95FRU563WG, (and associated duplicate and split samples 95FRU564WG and 95FRU565WG) and 95FRU566WG. The PCE concentrations ranged from 9 ug/L in sample 95FRU563WG to 14 ug/L in sample
95FRU567WG. Chloroform was detected at a concentration of 3 ug/L in sample 95FRU562WG. Toluene was detected at a concentration of 1.6 ug/L in 95FRU569WG and 1.7 ug/L in 95FRU571WG. No additional VOCs were detected above the MRL in the water samples submitted.
EMCON submitted eight water samples for GRO and DRO analysis from the groundwater monitoring wells. submitted. GRO not detected above the MRL. DRO detected in one sample at 0.20 mg/L.
The analytical results indicate that minor groundwater impact related to the use of the
former dry well appears to be confined to an area directly beneath the site and slightly
downgradient (to AP3441). The uniform distribution of PCE in groundwater collected
from AP3387 (MW-l), AP3439 (MW-2) and AP3441 (MW-3), coupled with the absence of VOC in subsurface soils indicates that the dry well is not the source of the PCE contamination as noted in the final release investigation report for this site. The elevated concentrations of metals in groundwater collected from AP3441 (MW-4) can be attributed to the high silt content in the sample.
Based on a review of the historic groundwater flow elevation data, the groundwater flow
regime across the site is relatively constant with only minor variations in the direction
of groundwater flow and magnitude of the hydraulic gradient. Based on a review of analytical results and observations recorded during the water sampling field effort, the groundwater exhibits elevated concentrations of PCE. The PCE contamination is apparently reIated to an off-site source. The elevated metals concentration in AP3441 (MW-4) is apparently related to the high silt content in the groundwater samples collected from that monitoring well.
The COE has authorized EMCON to conduct one additional groundwater sampling event. The next event is scheduled for August 1995. |
Louis Howard |
| 6/1/1995 |
Document, Report, or Work plan Review - other |
Staff reviewed the Operable Unit D Preliminary Source Evaluation 2 Bldg. 726 dated April 1995.
Alaska Departmento f EnvironmentalC onservation-DefensFea cilities Oversight group (ADEC) received on April 28,1995 a copy of the above referenced document. Listed below are ADEC’s comments.
5.2 Contaminant Fate and Transport 2nd para. page 46 and 1st para.: ADEC does not concur with the rationale that a more appropriate soil type of “fine-grained” soils. The guidance manual lists the determination of soil type as the predominant Unified Soil Classification soil type between the fist sign of contamination and the groundwater table. A more appropriates oil type would be cLcoarse-grainesdo ils with fmes” (8). As for the potential receptors, ADEC concurs that a lower scoring for “Potential Receptors” is appropriate. The score of 4 for “no known well within 1 mile” combined with the rest of the factors results in a score of 26 or Level C.
5.4 Contaminant Fate and Transport page 50 1st para.: ADEC has inspected the site and the asphalt pavement is not intact as stated in the text. It has visible cracks that will allow infiltration of precipitation and runoff. It is highly recommended that a new overlayment of asphalt be applied to prevent any mobilization of contaminants from infiltration. ADEC concurs that natural bioremediation will be a likely mechanism for contaminant reduction at the site.
ADEC will request long term monitoring of the groundwater using the existing wells to ensure
the deep aquifer is not impacted by stoddard solvent (e.g. PD680), especially in the area of AP-3465 and AP- 3466 where the contamination is highest. It is ADEC's understanding that the investigation at bldg. 45590 will try to determine the source of the PCE contarr).ination in the groundwater since there is no data at this time showing bldg. 726 as a source.
Bldg. 726 will be considered as requiring no further action with the exception groundwater monitoring in conjunction with the postwide effort. The groundwater analyses for PCE and Stoddard Solvent will be capable of detecting levels equal to the risk based concentration levels (i.e. 10-4 to 10-6 range). The determination of no further action does not preclude ADEC from requiring remediation or site investigation if new infonnation indicates there is previously undiscovered contamination or exposures that may cause risk to human health (exceeding RBCs or HI of 1) or the environment.
|
Louis Howard |
| 6/13/1995 |
Document, Report, or Work plan Review - other |
EPA Review comments on PSE 2 OUD. Background sampling was performed in order to determine natural background levels of targeted compounds for comparative purposes. Samples were collected from "undisturbed & non-contaminated soils". A significance test was performed for metals to determine whether the metals data for each site can be distinguished from the background sample population. References to this significance test are made throughout the document. The significance test is not provided for review, & could not be evaluated for statistical validity. Also, organic compounds were detected in the background samples, indicating the samples were not from undisturbed, non-contaminated soils. Therefore, elimination of target compounds should not be eliminated from consideration on this basis until the background levels are determined with certainty.
A comparison should be made between detection limits (i.e., MRLs) for nondetected chemicals & risk-based screening concentrations. This comparison is particularly important for the stormwater Outfall to Ship Creek, where "NFA" was recommended based on nondetections at MRLs.
Explain why SVOC analysis was only performed at samples taken at Buildings 35-752, 796, & 955. Based on the contaminants of potential concern, it would have been appropriate to conduct this analysis at other sites as well.
Explain why cancer risk due to soil ingestion was compared to an "acceptable risk level promulgated in AK water quality standards." In addition to the comparison to AK standards, estimated cancer risk should be compared to the recommended risk range of 10-6 to 10-4 as stated in the NCP. At sites where GW was not investigated, the rationale for this exclusion should be presented.
Future land use should be evaluated with respect to ecological receptors & habitat. Specifically, site habitat characteristics may change over time, therefore the potential for future use should be evaluated. Please clarify how the list of chemicals to be analyzed at each site was determined. There is no justification provided for changes in the analyte list.
Page 3-2, 3.1.2, Sediment samples. The sediment sampling techniques used in this investigation are inappropriate. Sediment samples must be collected with an approved sediment sampling device that allows no loss of percent fines (i.e., silts & clays). Appropriate sediment sampling devices are described in ASTM e 1391-90. In addition, a number of steps must be completed to ensure a representative sample is collected. These steps are outlined in the Puget Sound Estuary Program (PSEP), 1991 document "Recommended Protocols for Sediment Sampling". For future sediment sampling in addition to following PSEP procedures, efforts should be made to ensure that sediment sampling locations are in depositional areas (i.e., characterized by fine grained sediments), water is decanted off of the sediment surface using appropriate techniques. The appropriate procedures are required to ensure that the data is of sufficient quality for interpretive purposes.
Bldg. 726: EPA does not agree with the no further action (NFA) decision for this site. The NFA decision appears to be based on the fact that the site is paved, allowing no infiltration of precipitation to drive the contamination toward the aquifer, & the occurrence of natural biodegradation to remediate the source. Following the inspection of the site EPA notice numerous cracks & breaks in the asphalt cover. Also, it appears that the cover had been built up over period of time & thus may not served have served as cap since the tanks were remove. In addition given the low percentage of fines & organic content of the soils in this area the likelihood of natural biodegradation occurring does not appear promising. Additional action appears warranted at this site, for example possibly passive venting, & should be carried forward into the RI.
The document should present a table comparing maximum detected levels in soil & GW to the associated risk-based screening criteria. Also, where contaminants were "undetected", a comparison of detection limits to risk-based screening criteria should be made. This is the way to ensure that the analytical methods used were sensitive enough to show that a potential health risk did not exist.
Page 7, 2.3 Land use. While no disposal of PCE in the facility is known, the floor drains & any stained areas should be investigated. How is the residual sludge from the dry cleaning operation disposed of?
Page 30, 4.2 Analytical Results. The results of the VOC analysis for the soil samples near the UST excavation must be interpreted with care. With the high dilution required due to the high levels of Stoddard Solution, the detection limits were extremely high (660, 690, 6500 ug/l, for-example) & may have masked lower yet significant levels of PCE. Therefore, the UST should not automatically be discounted as a potential PCE source. |
Louis Howard |
| 6/13/1995 |
Document, Report, or Work plan Review - other |
EPA (M. Wilkening) Submits comments on the PSE 2 OU-D. This is a formal version of the comments EPA submitted to Fort Richardson on May 23rd. Most concerns were discussed and addressed during the project managers' meeting held that week. EPA concurs with the proposed evaluation for most all the sites discussed in the PSE2. The outstanding issue is the Laundry, Building 726. EPA does not agree that the Laundry is a candidate for no further action
GENERAL COMMENTS
1. EPA does not agree with the no further action (NFA) decision for this site. The NFA decision appears to be based on the fact that the site is paved, allowing no infiltration of precipitation to drive the contamination toward the aquifer, and the occurrence of natural biodegradation to remediate the source. Following the inspection of the site EPA notice numerous cracks and breaks in the asphalt cover. Also, it appears that the cover had been built up over period of time and thus may not served have served as cap since the tanks were remove. In addition given the low percentage of fines and organic content of the soils in this area the likelihood of natural biodegradation occurring does not appear promising. Additional action appears warranted at this site, for example possibly passive venting, and should be carried forward into the remedial investigation.
2. The document should present a table comparing maximum detected concentrations in soil and groundwater to the associated risk-based screening criteria. Also, where contaminants were "undetected", a comparison of detection limits to risk-based screening criteria should be made. This is the way to ensure that 'the analytical methods used were sensitive enough to show that a potential health risk did not exist.
specific Comments
1. Page 7, 2.3 Land use. While no disposal of PCE in the facility is known, the floor drains and any stained areas should be investigated. How is the residual sludge from the dry cleaning operation disposed of?
2.· Page 30, 4.2 Analytical Results. The results of the VOC analysis for the soil samples near the UST excavation must be interpreted with care. With the high dilution required due to the high levels of Stoddard Solution, the detection limits were extremely high (660, 690, 6500 ug/l, for -example) and may have masked lower yet significant concentrations of peE. Therefore, the UST should not automatically be discounted as a potential PCE source.
3. Page 52, section 5.4: Please provide documentation justifying the lack of migration pathways. Has extent of contamination been determined? The potential ecological risk associated with this site needs to be thoroughly evaluated. In addition, see the general comment section for more guidance.
The ecological risk for this site has not been thoroughly evaluated, therefore conclusions relating to potential ecological risks can not be draWn at this time~ .It is recommended that additional investigation be conducted at this site to further evaluate potential ecological risk, following the approach outlined in the general comment section.
4. Page 54, Recommendations
1) The presence of PCE in soil and ground water in the vicinity of the laundry requires additional investigation to evaluate the source and risk of PCE to the environmental and human health.
2) At least four additional wells downgradient wells should be installed and sampled to evaluate ground water conditions. The wells should be completed in the same zone as the wells at Building 45-590.
3) In situ remediation of the Stoddard Solvent contaminated |
Louis Howard |
| 6/19/1995 |
Document, Report, or Work plan Review - other |
Bldg. 45590 Draft Preliminary Source Evaluation Two contract: DACASS-93-D-0013
project 5210-008.00 Task 17, Fort Richardson, Alaska. The Alaska Department of Environmental Conservation(ADEC), hasr eceivedt he above document on May 23,1995. Below are our comments regarding the document.
4.1.3 Site Investigation and Data Evaluation page 23
The text states arsenic was detected in high concentrations in soil and groundwater. These high
levels were stated as being from naturally occurring conditions. Please elaborate further in this section on exactly what the range of “naturally” occurring arsenic was detected in the various media during Elmendorf Air Force Base’s (EAFB) background sampling efforts. Additional information is needed on why the specific soil types found at EAFB are comparable to the soil types found at Fort Richardson with regards to background levels of arsenic.
5 Conclusions and Recommendations page 32
The conclusion stating that gasoline range organics (GRO) impacted soil is related to an abandoned sewer line should be followed up with text describing what other programs are investigating the contamination. For example, the text should state that the GRO impacted soils are being investigated as a NON-UST source under the State Fort Richardson Environmental Restoration Agreement( SFERA). ADEC concursw ith recommendationtso extendt he soil bioventing from 40 feet below ground surface (bgs) to 15 feet bgs in impacted areas. ADEC agrees with the
recommendationth at the source of the tetrachloroethylene(PCE) contamination in the groundwater
requires further investigation under CERCLA. |
Louis Howard |
| 6/20/1995 |
Document, Report, or Work plan Review - other |
EPA (M Wilkening) reviewed the PSE 2 Bldg. 45590 OUD. EPA agrees with the conclusion that the source for the PCE in the groundwater at this site is probably not the dry well and that the upgradient source(s) need to be identified. While this report contains no recommendation for further action EPA recommends that this site be included in the remedial investigation/feasibility study for OU-D. The lack of any recommendation is the main item lacking in this report.
GENERAL CONMENTS
1. Water elevations should be measured in the four monitoring wells during the quarterly groundwater sampling events. Groundwater elevations contour maps from the water elevation
data should be included in this report and future reports. These data should have been included in this report in order to evaluate the groundwater pathway.
2. Include all laboratory data as an appendix to the document.
3. Include a discussion of laboratory detection limits compared to risk and regulatory criteria used for evaluation.
4. Include the rationale as to why ecological receptors were not evaluated. If there were no migration or exposure pathways or the habitat was not suitable for ecological receptors, please indicate this in the text.
SPECIFIC COMMENTS.
1. Page 6, Figure 2. This figure should show the location of the suspected dry well, and the renorted location of the . abandoned sewer line.
2. Page 20, Section 3.2.1.i. Suspected Former Dry Well. A figure should be included identifying the surface area of DRO impacted soil as described in the first paragraph of this page.
3. Section 4.1.3, second paragraph. In the absehce of data for surface soil, explain why it is conservative to assume concentrations at 5 feet bgs are the same.as concentrations at the surface. If there was a surface spill, this would not be a conservative assumption. However, if the source of contamination at this location is an UST, this would be an appropriate conservative assumption.
4. Section 4.1.3, third paragraph. Provide a statistical comparison of arsenic levels measured at the site to those ,reported for the area by CH2M Hill.
5. Section 4.3.1. For chemicals which were not detected in any samples, provide a statement relating how detection limits compared to the respective PRGs for these chemicals (i.e.,
were detection limits below PRGs?).
6. Table 4, page 27. Provide more explanation, in the footnote at the end of this table and in Section 4.3.2.3, regarding the derivation of PRGs for "GRO" and "DRO". Specifically,
state which toxicity factors were applied for calculation of the PRGs (i.e., JP-4, JP-5, diesel fuel, or gasoline?), and explain why the toxicity factor chosen-was appropriate.
7. Section 4.3.2.3, fifth paragraph. The statement that there is more uncertainty extrapolating toxicological data for carcinogens (as opposed to noncarcindgens) is not necessarily true, and should be removed. It is hard to and is sufficient to simply state that there is considerable uncertainty involved with both approaches.
8. section 4.4, second paragiaph. The text should be changed to state "hexavalent chromium can be rapidly reduced in the presence of orqanics or iron (+21 to the trivalent form.
9. Page 32, Section 5, Conclusions and Recommendations. Under item 1 those compounds which were elevated above risk-based concentrations in groundwater should be added for completeness.
10. Page 32, Section 5, Conclusions and Recommendations. There are no conclusions or recommendations made to address the courses of action outlined on page 1, the goals of the PSE
process. One of-the four recommendations outlined on page 1 should be included in this section. |
Louis Howard |
| 7/31/1995 |
Update or Other Action |
Preliminary Source Evaluation Fort Richardson Laundry Facility Bldg. 726 Final Report (USACE) received. A Preliminary Source Evaluation was conducted at the Fort Richardson Laundry Facility (Building 726). The laundry’s former underground s;lolvent tanks were suspected of releasing solvents of unknown composition and volume into the environment. In the assumed downgradient groundwater flow direction from the laundry at Building 45-590 monitoring wells were found to contain low levels of perchloroethylene (PCE). The PCE source may have originated from the laundry’s former solvent tanks which had been removed in 1987.
To investigate the site and identify possible release locations and volumes, three shallow soil borings were drilled inside the former tank excavation pit where contamination would most likely be present. Following these borings, three monitoring wells were installed in both upgradient and downgradient flow directions. In addition, a fourth monitoring well was installed to the west of the site but was funded as part of another project. The monitoring wells were completed within the confining silt layer and below the silt within the confined aquifer. Soil samples were collected and analyzed throughout the drilling operations.
Analysis of the soil samples reported petroleum contaminatilon of the soil below the former tank locations. The chromatographic pattern of the petroleum solvent matched that of Stoddard solvent, which is a common cleaning solw?nt used in dry cleaning and degreasing operations. No PCE or its breakdown products were detected in soil or groundwater samples with insignificant exceptions.
The zone of petroleum contamination was found to be present within gravel soils commonly encountered at Fort Richardson and is limited in size vertically, but has an unknown horizontal limit. Below uncontaminated gravels, a thick silt layer was found with a confined aquifer below it. The confined aquifer is within a second gravel strata and flows in a westerly direction. A possible perched water table was present on top of the silt layer and flows in a northern direction.
Evaluation of data generated during the PSE operations lecl to the conclusion that the
contamination was not migrating and is not a threat to humran health and the environment. No further action is recommended for the site based on the information presented in this report.
The only soil sample collected during drilling of the monitoring wells that contained
detectable quantities of PCE was taken at a depth of 52 feet from AP - 3469. All soil samples collected above and below this depth contained non-detectable levels of all VOCs as analyzed by EPA Method 8010. The monitoring well was installed northwest of the laundry just beyond the adjacent asphalt paved parking lots.
Gravel and, sand extended from the surface to a depth of 69 ‘feet bgs, below which the
confining silt layer was encountered. The source of the PCE at this single depth is
unknown. One possible source is a past release of new or used PCE at the ground surface at a distance from the location of AP - 3469 in which PCE may have migrated downward laterally from the spill area. Such migration behavior may explain the PCE existance at only one depth in the und,isturbed gravel soils in the area. The source of the PCE found in the AP - 3469 soil is not likely to be from the laundry’s former UST area. Prior to 1990 sludge from the PCE distillation units inside the laundry was placed into the nearby dumpster at the laundry and disposed of in the Fort Richardson landfill. Spillage associated with the dumpster may have contributed to PCE soil contamination.
The source of PCE detected in Building 45-590’s monitoring wells is also unknown. Possible sources based on groundwater flow direction include Building 45-590, Building 733, and Building 726 (Laundry). A PCE release near any of these buildings may be detected in the monitoring wells at 45-590 that are completed in the unconfined aquifer (directly above the silt confining layer), The three monitoring wells south of 45-590 consistently contain detectable levels, while the fourth monitoring well north of the the building has not contained any PCE from any sampling events. This indicates the groundwater contaminated with PCE is not widespread or that the PCE may be channelled along the building’s south side. |
Louis Howard |
| 8/15/1995 |
Document, Report, or Work plan Review - other |
EPA (M. Wilkening) reviewed the final report for PSE Bldg. 726 OUD. EPA has completed a cursory review of the "final" report for the Preliminary Source Evaluation of Building 726. In a letter
dated June 13, 1995, EPA stated that it disagreed with the listing of this site for no further action. Among the reasons for this was the fractured nature of the asphalt cover, the
presence of staining on the concrete at the drum storage site, and the action taken to remediate a similar site, the Veterinary Clinic. Although EPA did not receive any response to these comments, we noted that in the "final draft" Building 726 is still recommended for no further action. EPA still disagrees with this conclusion until additional information is provided in response to the earlier comments. |
Louis Howard |
| 10/31/1995 |
Update or Other Action |
Quarterly groundwater monitoring report received.
PCE ranged from 4 ug/L (95FRU572WG) to 10 ug/L (95FRU574WG). Lead detected at 0.032 mg/L (94FRU577WG). The project laboratory noted the presence of bubbles in one of six vials for samples 95FRU572WG, -576WG and 577WG and in three of six vials of sample - 57SWG.
Based on a review of analytical results and observations recorded during the water sampling field effort, the groundwater exhibits elevated concentrations of PCE. The PCE contamination is apparently related. to an off-site source. The elevated metals concentration in AP3441 (MW-4) is apparently related to the high silt content in the groundwater samples collected from that monitoring well. Additionally, minor concentrations of DRO are present in the groundwater directly beneath the site and slightly upgradient. |
Louis Howard |
| 11/29/1995 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Bldg. 45590 Pilot Bioventing Remediation System Final Six Month Shutdown Test Summary November 1995, Fort Richardson, Alaska
The Department of Environmental Conservation (DEC), has received the above document on November 27,1995. Below are our comments regarding the document.
4 Conclusions and Recommendations pages 6-7
The text states that the radius of influence of the vent well is large enough to elevate oxygen levels at the margin of the impacted soil volume. Without some type of diagram or figure to refer to it is hard to visualize the radius of influence in relation to the contamination present at the site. Please include figures placing all of the vent wells' radius of influence and monitoring points at the site in relation to the petroleum contamination. |
Louis Howard |
| 1/29/1996 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft CSMs, DQOs, ARARs OUD December 1995. 3.1.2 Past Practices page 3.1.3 fourth and fifth paragraphs
The text states the cooling ponds currently receive discharge water from building 35-750. Please
provide information on whether or not the discharge is currently covered by a wastewater discharge permit from DEC. The text states that it was hooked up to the post sewer system by 1972 and thus that would negate the need for a cooling pond for discharge if it is still being used for this purpose. A clarification is needed whether or not the building is connected to the Post’s sewer system.
3.1.3.2 Remediation Sampling page 3.1-5 1st paragraph
Note that rotating bioZogicaZfactor.s should be “Risk Based Concentrations (RBCs)“.
3.1.7 Summary of Data Gaps and Proposed Actions page 3.1-14 and 3.1-15
Cooling Ponds
The text states there will be an evaluation of ecological toxicity of the sediments present. DEC
requests the Army, in consultation with the other project managers, consider not using the cooling pond for discharge purposes and filling in the manmade cooling pond in with material (gravel, clean fill, asphalt) to eliminate a pathway to potential ecological receptors. This action would save time and money that would not be spent on evaluating ecological risk from the sediments in the pond (but not the drainpipe from the pond), or effects from contaminants in the surface water in the pond.
Groundwater
The text references the most likely remedial action for the groundwater at the site as natural
attenuation. Please elaborate on how PCBs will naturally attenuate in the groundwater at this site (i.e., at MW AP-2986). As a part of any proposed intrinsic remediation scenarios that the Army wishes to consider, there must be a description of what type of institutional controls, deed restrictions and land use controls placed on groundwater use.
3.2.7 Building 45-590 Summary of Data Gaps and Propose Actions page 3.2-9
The text states there are no risk values for DRO and thus the extent of DRO does not need to .be
further evaluated. DEC does not concur. Section 3.2.3 on page 3.2-5 states that the “DRO was
consistently detected in the groundwater from two of the wells and exceeded ADEC Water Quality
Criteria in one well.” If the groundwater contamination is not to be pursued by the FFA, then it
should be addressed by either the USTMP or the SFRERA. Regardless of which agreement it is
covered by, analysis of total PAHs in the groundwater will have to be conducted to determine if the PAHs have leached from the soils into the groundwater and what levels are being detected.
Building 726
See comment above regarding DRO detected in the groundwater.
Appendix ARARS
The chemical specific analysis does not appear to address PCBs in sediments or PCBs in soil. The
AIV&s should mention TSCA standards and EPA’s PCB cleanup guidance and new proposed PCB
cleanup regulations. Table 3-1 should have a footnote acknowledging that ADEC has adopted EPA
RCRA standards by reference in 18 AAC 62.
Section 4.0, proposed location-specific ARARs, does not note the parallel state statutes involving wetlands, historic preservation or endangered species. The section should incorporate the Alaska Coastal Management Program standards in 6 AAC 80. Given the preliminary nature of the
investigation and lack of remedial alternative, DEC’s review of the ARARs section is preliminary
at this point. The ARARs analysis in the management plan is very general and will need to be
greatly expanded in the future. Identification of ARARs I an iterative process and additional
analysis will be needed when remedial alternatives are proposed and analyzed. |
Louis Howard |
| 3/22/1996 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Drafi Management Plan OU D February 1996, Fort Richardson, Alaska.
4.3 Potential Remedial Technologies Applicable to Soil and Water page 4-13
The text references a remedial alternative for the groundwater at OU D as natural attenuation
(intrinsic remediation.) As a part of any proposed intrinsic remediation scenarios that the Army
wishes to consider, there must be a description of what type of institutional controls the Army is considering, deed restrictions for the OU and land use controls placed on groundwater use until the groundwater meets drinking water standards.
7.0 References
Please note the DEC has new Underground Storage Tank (UST) regulations (18 AAC 7X November
3, 1995) and an accompanying UST Procedures Manual (September 22, 1995) that supersedes the
1993 reference listed on page 7-l.
Appendix C AR4RS
DEC has included many of the same comments that were made on the December draft in a previous
letter to the Army:
1) The chemical specific analysis does not appear to address PCBs in sediments or PCBs in soil.
The ARARs should mention TSCA standards and EPA PCB cleanup guidance and new proposed PCB cleanup regulations.
2) Table 3-l should have a footnote acknowledging that DEC has adopted EPA RCRA standards by reference in 18 AAC 62.
3) Section 4.0, proposed location-specific ARARs, does not note the parallel state statutes involving wetlands, historic preservation or endangered species (although the notification list does not some of these state agencies involvement). The section should incorporate the Alaska Coastal Management Program standards in 6 AAC 80.
DEC has also noted an incorrect citation form in table 3-l on pages 3-11 and 3-13. 46 AS 14 should be cited as AS 46.14. greatly expanded in the future. Identification of ARARs is an iterative process and additional analysis will be needed when remedial alternatives are proposed and analyzed. |
Louis Howard |
| 3/28/1996 |
Document, Report, or Work plan Review - other |
EPA (M. Wilkening) provided comments on the OUD Management Plan.
Groundwater Data Gaps at the Buildings 726 and 45-590.
It is very likely that the source of PCE in groundwater in the vicinity of Building 45-590 is Building 726. PCE solvent was stored in drums and possibly in USTs at Building 726. PCE is a
common dry-cleaning solvent. The direction of groundwater flow either in the unconfined and confined aquifer is not well documented in this report but apparently is towards the west and
northwest. This is in the direction of Building 45-590. The closest monitoring well (AP-3469) to Building 726 was installed at least 300 feet from the tank site, screened in the confined
aquifer and located cross-gradient from the site.
Another well (AP-3467A) provides little useful information because it is upgradient of the. site. Since contamination was detected in soil beneath the UST, it is possible that contamination could have reached the water table. Because the existing monitoring well network is inadequate to evaluate potential releases from this site, EPA recommends that at least two to three additional monitoring wells should be installed within 50 feet and downgradient of the tank site to monitor groundwater conditions. Wells should be completed in both the unconfined and confined aquifers.
Unless monitoring wells are installed in the unconfined aquifer, it cannot be concluded whether significant groundwater is present or not. Because of the critical importance of determining if
this site is a source of PCE it is not enough to argue that significant unconfined groundwater is not present based simply on field observations or experience. Field observations indicate
that some unconfined groundwater is present. The-presence or absence of significant quantities of groundwater can only be verified using properly constructed monitoring wells.
Groundwater flow in the confined and unconfined aquifer in the area needs to be better defined. The proposed studies should be designed such that the groundwater flow system in the area will
be adequately defined.
2. Field Sampling Plan. The draft field sampling plan is a very general document with little project specific inforination provided. A field sampling plan (FSP) provides guidance for all
fieldwork by defining in detail the sampling and data-gathering methods to be used on a project. The FSP should be written so that a field sampling team unfamiliar with the site would be able to gather the samples and field information required" (EPA 1988, Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA, page 2-16). An experienced individual with this FSP could not complete the sampling activities with the
information provided. The FSP is specifically missing a section detailing sample location and frequency.
Table l-l. Building 45-590 is not included in this list.
Page 3.1-2, Section 3.1.2 Past Practices. Another explanation for the difference in PCBs is that
identification of PCBs is somewhat subjective, particularly for older, weathered Aroclors. Since the chromatographic patterns for Aroclor 1260 and 1254 are very similar, it is
quite easy for an inexperienced analyst to misidentify these two Aroclors. Generally, even with misidentification, total concentrations are accurate to within IO-15 percent of the true value.
Page 3.3-4, Section‘3.3.4, last sentence. EPA disagrees, based on the placement of existing monitoring wells, that groundwater has been properly evaluated at this location.
Page 3.3-3, Section 3.315. Based on significant groundwater gaps discussed below, EPA disagrees that groundwater leaching and transport can be ruled out at this site.
Page 4-15, top of the page. Potassium, chloride, redox potential and total dissolved solids (TDS) should be added to the list of general water quality parameters. Potassium and chloride are important anions which are necessary to calculate ion balance and construct Piper diagrams important in interpreting water quality. |
Louis Howard |
| 2/17/1997 |
Site Added to Database |
Stoddard solvent. Site added by Shannon and Wilson, Inc. |
S&W-Miner |
| 4/29/1997 |
Document, Report, or Work plan Review - other |
Staff reviewed and provided comments on the Draft Approach Document Risk Assessment, Fort Richardson, Alaska. 2.1.5 Risk-Based Screening pages 2-4 and 2-5 The text states the chemicals will be compared to EPA Region 9 PRGs to further identify those chemicals that warrant inclusion in the baseline HHRA. DEC is concerned that the PRGs in some cases will not adequately address those chemicals which may have been included in a baseline risk assessment using RBCs from EPA Region III. For example, the following chemicals have been found to have higher soil screening levels for protection of groundwater than those levels which are found in the EPA Region III RBCS: Trichloroethylene, 1,2-Dichloroethane, 1, 1-Dichloroethane, 1, 1,l -Trichloroethane, and benzo(b)fluoranthene.
lf the Army wishes to use Region 9 PRGs it must use a dilution attenuation factor of 1 for protection of groundwater. This is based on data gathered from the Poleline Road Disposal Area which shows little to no dilution or attenuation from natural processes. If this approach is not one the Army wishes to use, then it may be more appropriate to use the latest EPA Region ill RBCs for screening purposes since the State’s draft 18 AAC 75 regulations and risk assessment guidance are based on these RBCs. |
Louis Howard |
| 5/6/1997 |
Document, Report, or Work plan Review - other |
EPA reviewed & commented on the OUD risk assessment approach document.
Page l-l, third para. Of the 7 OUD sites previously proposed for NFA status, have any had this status confirmed or finalized? If so, please note in which document. If not, has a consensus been established that it is reasonable to omit these sites from the OUD risk assessment? Please confirm this up front.
Page l-7, last para, last sentence. It seems a strong statement to say that there is no connection between the site & adjacent waterways, particularly when considering the possibility of GW transport or airborne carriage of soil particles, both of which are acknowledged as effected by secondary release mechanisms in the CSM . Is this statement necessary? The intent of this statement is unclear.
Pages l-8,9. Please clarify in this table that these are preliminary COPCs, & are not based on validated data.
Page 1-8, Bldg. 35752. Should there be a horizontal line between soil & GW, or will all 4 contaminant classes be examined for both media? Please clarify on diagram
Page l-10, fourth para, last sentence. Please clarify which RBCs were not exceeded.
Page 2-1, Section 2.1, third bullet. It may be helpful to indicate that the natural background concentrations for comparison are site-specific.
Page 2-1, Section 2.1, fifth bullet. It may be helpful to note that the PRGs are RBCs (as opposed to ARARs or other regulatory types of criteria)
Page 2-2, Figure 2-l. Contaminants that are screened out for ND reasons should be summarized & discussed in the uncertainty analysis &/or risk characterization sections.
Page 2-2, Figure 2-1. How will it be ensured that the frequency of detection screening step will not eliminate potential hotspots from further consideration & evaluation?
Page 2-2, Figure 2-l. Since metals that naturally exist above RBCs may be screened out of the risk assessment, the total estimated risk may underestimate the total risk to which an individual at the site may be exposed. While this screening step is reasonable, it is still important to acknowledge, somewhere in the risk characterization &/or uncertainty analysis, such potential risks from any metals that are screened out.
Page 2-2, Figure 2-1. The “NO” & “YES” coming from the nutrient decision diamond should be switched.
Page 2-2, Figure 2-1. Contaminants screened out because they did not exceed risk-based criteria should be summarized in the risk characterization section.
Page 2-3, third para. This statement is very general. Please specify what is meant by “appropriate for risk assessment purposes.
Page 2-3, last para. The extra effort on behalf of contaminants whose MRLKQL exceed the PRG is a sound idea. Please specify what criteria will be used in this evaluation to determine if the contaminant will be included as a COPC.
Pages 2-4 & 5, Section 2.1.5. In the past, Region 10 has advocated using a hazard index of 0.1 for screening purposes. If 1.0 is to be used, an explanation to justify this deviation should be added to the text & the standard default parameters should be examined to insure the screening process is adequately conservative with respect to receptors at the site.
Page 2-5, last par. Please be sure that the acronyms GRO & DRO are introduced somewhere in the document.
Page 2-6, second para. In Section 2.1.2 it was indicated that contaminants with MRLs/SQLs in excess of the PRG would be considered for possible inclusion as COPCs. This para seems to indicate that no such consideration will occur. Please clarify.
Page 2-2, Section 2.2. It is not clear why exposures are being considered on a site-by-site basis rather than an overall OU basis, particularly for the -site visitor”. Please provide some discussion in the text as to why this site-by-site approach was taken.
Pages 2-7 - 2-10, CSM. Please define blank spaces: it is not clear if these indicate incomplete pathways, uninvestigated pathways, pathways without adequate information or precedent for evaluation, or something else. Also, in cases where a dashed line is used to indicate a ‘probably not significant n pathway, please include some discussion of this assumption in the text.
Page 2-7, surface water. Why are site workers & area residents assumed to have insignificant exposure to sediment but no exposure to surface water? Generally, these figures represent exposure pathways. If this figure also represents the likelihood of the media to contain COPCs that should be stated in the text.
Page 2-11, second para. If the residential exposure scenario is determined a reasonable one (either as a current or potential future scenario), then risks to that residential receptors should not be viewed as insignificant. However, it is certainly reasonable to examine the uncertainties associated with the estimated residential risks & discuss the risks in light of these uncertainties.
|
Louis Howard |
| 5/28/1997 |
Document, Report, or Work plan Review - other |
EPA (M. Wilkening) reviewed and commented on the Operable Unit D, Draft Field Sampling Plan, Addendum 1.
GENERAL COMMENT
1. For the analyses to be performed, provide the bottle type to be used, the preservatives required (if any), and the holding times required for each analysis by matrix (l-e.,
soil, sediment, groundwater).
SPECIFIC COMMENTS
2. Section 2.1, Page 2-3. Explain why equipment rinsate blanks will not be collected from the Bryant Airfield Complex. 3. Section 2.1, Page 2-1. When collecting soil sampies at the
Bryant Airfield Complex, it is not in keeping with health and safety procedures to use olfactory observations to determine whether samples are additionally contaminated with
svocs , PCB/pesticides, and/or petroleum hydrocarbons.
Please comment on this. |
Louis Howard |
| 5/29/1997 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Field Sampling Plan Addendum 1, Fort Richardson, Alaska which includes the Fish Hatchery site.
1.2.3 Fish Hatchery page 1-3
The text states that only a review of existing data will be done for this site. There was a report of diesel range organics being detected in a monitoring well near the site. It is DEC’s understanding that the site will be investigated this field season under one of the two POL agreements the Army has with the State (USTMP or SFRERA). If that is not the case, then the site will need to be included for investigation under the OU D sampling plan. |
Louis Howard |
| 8/15/1997 |
Update or Other Action |
OUD RI Report (draft) received. Four sites under investigation for OUD have known or suspected contamination as indicated by results of previous investigations. The purpose of the RI is to confirm the presence and evaluate the extent of contamination, and to provide enough information so that risk assessments and feasibility studies can be performed at each site. The four sites are:
Building 35-752 - High Frequency Transmitter Site;
Building 45-590 - Auto Hobby Shop;
Building 726 - Laundry Facility; and
Building 796 - Battery Shop.
Sump at Building 45-590
At the time of the Remedial Investigation, the building and the sump had been demolished.
The boring was placed in close proximity to where the sump had been located. DRO and GRO
were detected in samples collected at 10 feet and 15 feet bgs in concentrations ranging from 4
to 308 mg/Kg. PCE and 1,2-dichloroethane (1,2-DCA) were detected at 20 J ug/Kg and 10 J
ug/Kg in the sample collected at 10 feet.
The total estimated AVO concentration detected at this location was 190 J ug/Kg. VOCs were not detected in any other samples. Arsenic was detected at 6 mg/Kg to 7 mg/Kg in the three samples collected. Although these concentrations exceed the screening criteria of 2.3 mg/Kg (one-tenth the Region Ill RBC), they do not exceed Post background levels.
Sump at Concrete Wash Pad
Sediment samples were collected from the bottom of the sump; results are shown on Table
4.2-4. Substantial concentrations of DRO and VOCs were detected, including concentrations
of PCE ranging from 87 ug/Kg to 600 ug/Kg. However, a soil boring advanced adjacent to the
sump, to a total depth of 35 feet bgs, indicated that the materials in the sump have not
impacted adjacent soils.
Low concentrations (< 25 mg/Kg) of DRO were detected in the subsurface soils adjacent to the sump. Arsenic was detected at concentrations of 6 mg/Kg in the 15 and 35 foot samples, and 18 mgJKg in the 10 foot sample. The detection of 18 mg/Kg exceeds Post background levels for this metal (9.2 mg/Kg).
Groundwater Sampling
In September 1996, five monitoring wells were installed in the vicinity of Building 45-590. Soil
samples were not collected for contaminant analysis; lithologic logging was based, in general,
on discharge cuttings from the air rotary drill rig. Three of the wells were located potentially
hydraulically upgradient of the site. Two wells, AP-3772 and AP-3773, were screened below a
- confining unit as no water was encountered above this unit.
The three other wells (AP-3774, AP-3775, and AP-3776) were completed in the unconfined aquifer. The wells were sampled for VOCs on a quick turnaround basis to determine if additional upgradient wells needed to be installed to further evaluate the upgradient source of PCE contamination. PCE was detected in the newly installed upgradient well (AP-3775). During the site-wide groundwater sampling event, PCE was also detected in upgradient wells AP-3468 and AP-3534.
In February 1997, two additional wells were installed hydraulically upgradient from this site in
an attempt to further delineate the extent of PCE in groundwater and possibly identify the
source. One well (AP-3789) located adjacent to Building 732 was screened below a confining
unit as no water was encountered above this unit.
AP-3790, located downgradient of Building 704, was screened above a confining unit in what is presumed to be a perched aquifer. Groundwater results collected during the Remedial Investigation are included in Table 4.2-5 and Figure 4.2-l. The concentrations of PCE detected were highest in wells AP-3468 (unconfined) and AP-3534 (confined). Concentrations detected in these wells were 100 ug/L and 34 ug/L, respectively.
PCE had not previously been detected in either of these wells. PCE was detected in on-site wells AP-3439 and AP-3440, as it had been previously. Carbon tetrachloride was also detected in both wells, although it had not been detected in previous investigations. PCE had been detected in AP-3387 during previous investigations; this well was not sampled during the Remedial Investigation as it was believed to be inaccessible due to ongoing remedial activities.
PCE was not detected in AP-3441, although it is unclear if this well is screened in the unconfined aquifer or not. Of the five new wells installed in September, PCE was detected in the three installed in the unconfined aquifer. PCE was not detected in the two wells screened below the confining unit (south of Building 45590). PCE was detected in both wells installed in February 1997, upgradient of the site. |
Louis Howard |
| 10/7/1997 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the OU D Draft Remedial Investigation, Fort Richardson, Alaska dated August 26, 1997. General Comments- Add a list of acronyms to table of contents to help the reader quickly find the meaning of each acronym as needed.
Specific Comments
4.1.4 page 4-20
The text references contaminants of potential concern (COPCs) in table 4.1-2, but offers no
reasoning on why they should be retained as COPCs. DEC requests a footnote be added either in
the text or table 4.1-2 referring the reader to Appendix G “Analytical Data”. DEC also requests that language be explaining the raticnaie why a ccntaminant is not considered a CQPC if the REC falls within the range of non-detects or when the range of non-detects exceed the RFK for that
contaminant. This comment mainly applies to the semivolatile organic compounds and in some cases
volatile organic compounds.
4.1.4.5 Groundwater page 4-44 4th para.
The text refers the reader to the DAR (data assessment report) for a more detailed explanation of this section. Please spell out DAR and add text which will aid the reader to Appendix F of the RI where the Data Assessment Report is located.
The tables presented in this appendix list COPC determinations for bldg. 35752. DEC requests
adding the remaining sites to this section list the determination of chemicals of potential concern. |
Louis Howard |
| 10/31/1997 |
Document, Report, or Work plan Review - other |
EPA (Matt Wilkening) sent a comment letter to the Army. OUD Draft Remedial Investigation (RI) and baseline risk assessment. The primary concerns EPA has with these documents are: the need for additional supporting information for statements made and for site specific conditions and is need for additional supporting information for the statements put forth. In the BRA, there appears to be deviations from the Risk Approach Document.
A table which summarizes the various media-specific cleanup or screening levels and concentrations should be included in the report. Without some reference concentrations for comparison, mere is no way that the reader can determine if the investigation has been performed adequately to characterize the nature and extent of contamination. There arc numerous references in the report made to one or more of the following screening levels: EPA soil cleanup level, MCLs, RBCs, Alaska Water Quality Criteria, EPA cleanup criteria or residential soil, background, EPA Region 3 RBCs, etc. These screening concentrations should be summarized and defined in a table as a reference for the reader.
For example, it is not possible to determine whether additional soil sampling is required in the former drum accumulation area or the cooling pond (Building 35752) because PCBs were detected in most of the soil samples. Without developing some screening criteria, it is not possible to evaluate whether or not additional sample is req$red at this location. One of the goals of the Federal Facility Agreement is to thoroughly investigate the environmental impacts associated with past and present activities. Developing media-specific screening concentrations is important in determining if this goal has been achieved.
Data Gaps, Building 45-590 Source Area:
a) The vertical and horizontal extent of diesel-range contamination in the vicinity of the drywell/abandoned sewer hue has not been established.
b) The source, nature, and extent of VOC contamination in groundwater has not been fully characterized. Additional sampling and monitoring wells are required.
c) A map showing the extent and concentrations of PCE should be included in the report.
Data Gaps, Building 726 Source Area: The horizontal and vertical extent of soil contamination has not been determined for this area.
Appendix F, page 3-2: The second bullet under Building 35-752 interprets n-C 8 to n-C,, range petroleum hydrocarbons as gasoline, while the same range material is interpreted as Stoddard solvent in the third bullet under Building 45-590. |
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. Suspected S&W oversight. |
Bill Petrik |
| 3/29/1999 |
CERCLA Proposed Plan |
Final Proposed Plan received. OUD consists of 12 source areas: Building 35-752 – High Frequency Transmitter Site; Building 45-590 – Auto Hobby Shop; Building 726 – Laundry Facility; Building 796 – Battery Shop; Stormwater Outfall to Ship Creek; Dust Palliative Locations (four separate
areas); Landfill Fire Training Area; Grease Pits; Circle Road Drum Site; Building 700/
718; Building 704; and Building 955.
Source Areas Requiring Further Action Under CERCLA
- Building 35-752 – High Frequency Transmitter Site
- Building 45-590 – Auto Hobby Shop
- Building 796 – Battery Shop
Source Areas Recommended for No Further Action Under CERCLA
- Stormwater Outfall to Ship Creek
- Dust Palliative Locations (four separate areas)
- Landfill Fire Training Area
- Grease Pits
- Circle Road Drum Site
- Building 955*
- Building 726 – Laundry Facility
Source Areas Referred to Two-Party Agreement
- Building 700/718
- Building 704
- Building 955*
* A removal of DDT-contaminated soil occurred in 1998; however, confirmatory samples indicate that a second removal action at Building 955 is required prior to its status as a No Further Action CERCLA source area. Petroleum contamination in soil at Building 955 will be addressed under the Two-Party Agreement.
The remedial action objectives for the three source areas covered in this Proposed Plan are to:
- Restore groundwater at Buildings 35-752, 45-590, and 796 to drinking water quality for protection of human health.
- Prevent further migration of sorbed contaminants (primarily PCBs and chlorinated pesticides) to Ship Creek from the cooling pond sediment and surface soil at Building 35-752.
- Minimize the potential off-site migration of contaminated groundwater (primarily benzene) from Building 35-752.
- Reduce risk associated with PCB-contaminated soil and sediment at Building 35-752 consistent with industrial land use.
The preferred alternative for PCB-contaminated soil at Building 35-752 is Alternative 3 – Phytoremediation. Phytoremediation is cost-effective, and the treatment of soil is expected to remove the contamination and provide long-term effectiveness. In this case, long-term monitoring would not be required because the contamination would be remediated. However, if phytoremediation proves through treatability studies to be ineffective, thermal desorption (Alternative 5) will be implemented. Following treatment, institutional controls will ensure treated soils remain at the source area.
The preferred alternative for benzene- and metals-contaminated groundwater at Building 35-752, carbon tetrachloride- and PCE-contaminated groundwater at Building 45-590, and benzo(a)pyrene- and 1,2-dibromoethane-contaminated groundwater at Building 796 is Alternative 2 – Institutional Controls with Monitored Natural Attenuation. Although Alternative 3 would achieve cleanup more rapidly than Alternative 2, the Army, EPA, and ADEC believe Alternative 2 is the best choice because groundwater at these source areas is not currently used as a source of drinking water; therefore, a less aggressive schedule is acceptable, considering the significant difference in cost between the two alternatives. Alternative 2, the preferred alternative, is expected to achieve overall protection of human health and the environment and to meet ARARs.
Additionally, this alternative is a cost-effective and permanent solution at Buildings 35-752, 796, and 45-590. Table 11 shows a comparison of all alternatives evaluated for groundwater remediation at Buildings 35-752, 796, and 45-490. As with any remedial action under CERCLA, as long as contamination remains on site, the effectiveness of the selected remedy is subject to periodic reviews, not to exceed 5 years. If the selected treatment technology is determined to be ineffective, the Army, EPA, and ADEC will propose another alternative. |
Louis Howard |
| 3/8/2000 |
Meeting or Teleconference Held |
J. Roberts attended conference call between ADEC, EPA and Army staff. New information caused buildings 45-590 and 35-752 to be withdrawn from ROD and become Operable Unit "E". Transformers were opened and oil disposed of in a pit dug in 1983 then lit on fire at corner of 35-752. Transformers were operated and used until 1980 at 35-750. Air photos from 1966 shows open pit with trenches and solid waste disposal along with historical information that tanks and armored vehicles were washed down with carbon tetrachloride. This carbon tetrachloride is more than likely the source for the contaminant in groundwater associated with 45-590. OU D ROD will consist of 796, the NFA sites and two party sites. New site-wide risk assessment to be done with OU E. Draft ROD for OU D will be delivered at end of March 2000 for agency review. Building 45-590 will be declared as requiring no further action and a new site: Armored Vehicle Maintenance Facility will be created to continue as a source area contributing to the groundwater contamination detected at 45-590 for OU E along with Building 35-752. |
Louis Howard |
| 9/28/2000 |
Institutional Control Record Established |
Fort Richardson instituted a post wide IC policy for all known or suspected contaminated source areas. IC policies include the following:
• No unauthorized intrusive actions take place at source areas,
• No potable water wells are installed on source areas, and
• No soil excavation can take place without prior briefings on potential concerns at the source area, knowledge of the procedures for handling contaminated soils on Fort Richardson, and possession of a valid site-specific Fort Richardson Excavation Permit.
USARAK DPW maintains the GIS database with information on all of the contaminated source areas on Post. The DPW is responsible for ensuring ICs on Fort Richardson are enforced. ICs will remain in place as long as hazardous substances remain on site at levels that preclude unrestricted use.
|
Louis Howard |
| 9/28/2000 |
Record of Decision |
ADEC signed the OUD ROD. Air photos from 1957, 1960 and 1966 show a large disturbed area east of Building 45-590 with trenches, large cylinders, stained areas and burial of debris. Interviews with former employees indicated that this area was used as for field maintenance on armored vehicles (tanks) with disposal of oil and other waste material such as chlorinated solvents. With the new additional information, it has been determined that Building 45-590 is not the source and is considered no further action under CERCLA. The new upgradient source, now be referred to as the Armored Vehicle Maintenance Facility, will be investigated and become part of OUE. |
Louis Howard |
| 9/28/2000 |
Conditional Closure Approved |
OUD ROD signed by ADEC, U.S. Army and U.S. EPA. Building 45-590 is not the source of groundwater contamination from chlorinated solvents. The soils meet ADEC most stringent criteria for cleanup. Groundwater contamination is from an upgradient source now called the Armored Vehicle Maintenance Facility and is being investigated as a new operable unit "E". After 2001 Remedial Investigation of upgradient source, most likely will involve institutional controls being placed on the groundwater use at this site and long-term monitoring until cleanup goals are met. |
Louis Howard |
| 9/28/2000 |
Long Term Monitoring Established |
Long-term monitoring required for upgradient source of groundwater contamination not associated directly with building 45-590 as noted in the Record of Decision for Operable Unit D which includes building 45-590. See Operable Unit E Armored Vehicle Maintenance Area for further information at database Reckey number 200021X904701. |
Louis Howard |
| 2/22/2001 |
Update or Other Action |
EPA sent comment letter regarding the RCRA Closure under 1991 FFCA. 1990 AEHA study documented that hazardous waste had been improperly stored at this unit. In June 1994, USARAK conducted surface and subsurface soil sampling at the unit and confirmed that contamination was not detected above regulatory levels and therefore remedial action was not required. Groundwater contamination was discovered during a UST release investigation and OU D remedial investigation determined that 45-590 was not the source of the contamination. Groundwater contamination has been referred to OU E for further characterization and remedial action under CERCLA. Additional work conducted under the FFCA is not required for Building 45-590. |
Louis Howard |
| 2/20/2003 |
CERCLA ROD Periodic Review |
Jennifer Roberts signed the five year review document for the Post. The objectives of the Five-Year Review are to answer the following questions:Are the remedies functioning as intended by the decision document? Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives (RAOs) used at the time of the remedy still valid? Has any other information come to light that could call into question the protectiveness of the remedy?
OUD originally consisted of the following 12 potential source areas: Building 35-752 - High Frequency Transmitter Site, Building 45-590 - Auto Hobby Shop, Building 726 - Laundry Facility, Building 796 - Battery Shop, Storm water Outfall to Ship Creek, Dust Palliative Locations (four separate areas), Landfill Fire Training Area, Grease Pits, Circle Road Drum Site, Building 700/718, Building 704, Building 955.
Each source area was evaluated through the PSE process (Pre-RI), and where warranted, limited field investigations, called PSE2s, were conducted. Based on the PSE2, petroleum contamination at Building 955 qualified the site to be investigated under the Two-Party agreement and DDT contamination at the Building 955 site was evaluated as part of OUD. Four of the original source areas were carried through an RI/FS: the Building 726 Laundry Facility, the Building 796 Battery Shop, the Building 35-752 High Frequency Transmitter Site, and the Building 45-590 Auto Hobby Shop. Based on the PSE and RI information, the Army, ADEC, and EPA determined in the OUD ROD that six source areas required NFA under CERCLA, three source areas should be referred to the Non-UST Two-Party Agreement, two source areas be recommended for NFA under CERCLA following additional limited monitoring, and the two remaining source areas were referred to a newly created OU, OUE, for investigation and further evaluation.
Building 45-590 was determined not to be a source for groundwater contamination and was considered NFA under CERCLA in the OUD ROD. Groundwater contamination was attributed to an up gradient source area referred to as the Armored Vehicle Maintenance Area (AVMA). This newly identified potential source area is being investigated as part of the OUE RI/FS. |
Jennifer Roberts |
| 8/31/2007 |
GIS Position Updated |
61.2588 N latitude -149.7205 W longitude |
Louis Howard |
| 12/18/2012 |
Document, Report, or Work plan Review - other |
EPA comments on the draft 3rd 5 Year Review.
The last paragraph on page 3-35 is unclear. This section indicates both Buildings 45-590 and 726 have been designated as no further action (NFA) under CERCLA, but then later indicates an area east of Building 45-590 was identified as a potential source of PCE groundwater contamination. Please revise the text to clarify if these former OUD sites are still designated as NFA or if one or both of these sites are now considered part of the PCE impacted area. Please identify Building 45-590 and Building 732 on Figure 3-5.
Further, please note that any occupied or potentially occupied building located within 100 feet of groundwater VI exceedances should be retained in any future VI evaluation. Please revise Section 3.4 to clarify if these former OUD sites are still designated as NFA. Please specify the distance of these buildings to the volatile organic compound (VOC) groundwater plume.
Groundwater RAOs are MCLs for all COCs except for 1,1,2,2-PCA, which has an EPA Region 3 risk-based concentration (RBC) of 0.0053 micrograms per liter (µg/L) (according to the footnotes of Table 4-1). However, Section 4.0 does not clarify if groundwater RAOs are protective of the VI to indoor air pathway. For completeness, please demonstrate that groundwater RAOs are also protective of the VI to indoor air pathway.
Soil RAOs are based on protection of groundwater from leaching of contaminants. However, it is noted that the current EPA risk-based soil screening levels (SSLs) for migration-to-groundwater are three orders of magnitude less than the COC-specific RAOs. For completeness, please clarify why the selected RAOs are considered protective.
The PostWide Human Health Assessment conducted in 1996 was 15 years prior to this review, however the statement is written to suggest the initial assessment can be used to evaluate that “selected remedies continue to remain protective at JBER-R.” Please clarify the timeframe to which the Human Health Assessment pertains.
|
Louis Howard |
| 6/11/2013 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 73750 name: Vehicle Maintenance |
Louis Howard |
