| Action Date |
Action |
Description |
DEC Staff |
| 9/20/1939 |
Update or Other Action |
EO 8102 (one of five for Richardson) 1939 withdrew 36,570 acres for military use. It was later amended by EO 9526 Feb. 28, 1945, which states that the area will revert back to Dept. of Interior six months after termination of national emergency. PLO 2698 in 1962 specifically withdraws 90 acres for use to protect Nike Site.
Three off-post Nike-Hercules missile sites were built in 1959. That December, one of the missiles atop Site Summit (Mount Gordon Lyon) was test fired, marking the first time a Nike Hercules had been fired from an actual operational location. Two Nike Hercules air defense artillery battalions replaced anti-aircraft artillery guns during the late 1950s in providing point defense for the Anchorage-Elmendorf-Fort Richardson and Fairbanks-Eielson-Fort Wainwright areas. Nike Hercules missiles were assigned to Alaska in 1959. Three batteries were established on or near Fort Richardson at Site Summit, Site Point, and Site Bay.
Alaska had eight NIKE sites with five in Fairbanks and three in Anchorage. The five northern batteries became operational during 1959-1960 and were closed during 1970-1971. The three batteries in the Anchorage area became operational in 1959 and were closed in July 1979. The 1964 Good Friday earthquake caused extensive damage to the Site Point Nike Hercules battery. It is possible that the resulting debris and rubble from the Site Point battery was disposed of in the sanitary landfill.
(The remnants of Site Summit can be seen overlooking Eagle River on Fort Richardson property. Site Bay at Goose Bay was turned over to state and now sits abandoned. Site Point was turned into Kincaid Park. The Tony Knowles Coastal Trail ends near there.) |
Louis Howard |
| 10/3/1955 |
Update or Other Action |
Concurrent with the deployment of Nike Ajax, limitations in the system’s range and kill capabilities were identified. This led to creation of Nike Hercules, the second generation Nike weapon. Unlike its predecessor, Nike Hercules could be armed with nuclear weapons or high yield explosives, and its firing range was increased from twenty-five miles to over seventy-five miles. Nike Hercules began replacing Ajax sites across the country in 1958. Fewer Hercules sites were needed since the missile range was significantly increased.
When Alaska was scheduled for Nike Hercules defenses in 1955, the Army originally planned to station three Nike battalions in Alaska, with eight sites in Fairbanks and three in Anchorage. The areas identified for protection were Eielson AFB and Ladd AFB in Fairbanks, and Elmendorf AFB in Anchorage.
Site Summit, at the top of the Chugach Range 4,000-feet above sea level, was the most difficult Alaskan battery to construct. Sixty vertical feet were blasted off the mountaintop to raze a platform for the battery control building and radars. Blast holes were located at 5-foot intervals with a depth ranging from 16 inches to 24 feet. The holes were loaded with 1½ cartridges of Atlas dynamite. Over 25,000 cubic yards of rock were removed from the site. Usable material blasted from the peak was recycled for road and area fill.
Excess rubble was bulldozed off the mountainside. The mountaintop weather hindered construction crews somewhat. Visibility was often so poor that, “driving to the day’s work through a sunny summer day, they would be engulfed in fog layers so thick ‘you could put out your hand and move it.” The battery’s unique location added approximately twenty percent to the average battery construction costs.
Site Summit (4th Missile Battalion, 43d Artillery, Battery "B") was subject to very extreme weather conditions due to its location at the top of the Chugach Mountains. Snow, fog, and high winds frequently socked in the site. The Integrated Fire Control (IFC) building was anchored to the ground by six feet square four feet thick concrete pads with encased steel rods. |
Louis Howard |
| 11/20/1960 |
Update or Other Action |
The live fire exercises generally occurred in winter to test the system’s cold weather capabilities, and to ensure that fewer people would inadvertantly be in the firing fans. and to ensure that fewer people would inadvertently be in the firing fans. Even so, some outlying homesteaders in the Anchorage area were potentially in harm’s way. The Army invited homestead families to be guests of the military as a safety precaution. Citizens were bussed to Fort Richardson and provided Army housing on days when the missiles were fired. The inconvenience was offset by the opportunity to witness the live fire exercises with the VIP post.
The live Nike missile firings did leave some physical impacts upon the landscape. S.E. Thomas, an Anchorage AADCP officer, said missile debris from a live fire exercise in the 1960’s broke through the roof on his parents’ home in Eagle River. |
Louis Howard |
| 8/18/1981 |
Update or Other Action |
The live Nike missile firings did leave some physical impacts upon the landscape. Also in 1981, many years after the live fiexercises at Site Summit had ceased, a cluster of rocket boosters from a missle launch was discovered near Hiland Drive in Eagle River. Thirteen year old Doug Liebold located the boosters through a spotting scope on Fort Richardson. The Army sent ordnance disposal experts to investigate the debris and determined the boosters were inert and presented no danger (Missile Remains 'Dangerous as a Tree'" ADN 18 Aug, 1981. |
Louis Howard |
| 2/15/1990 |
Update or Other Action |
Sampling, analysis, & QA/QC Plan for groundwater monitoring at Fort Richardson - Prepared by the AK District Army CORPS of Engineers Materials and Instrumentation Section February 1990.
1.3.4.6 Other Wells
Arctic Valley Ski Area Well and Nike Site Well: These supply wells are located on the eastern boundary of the installation in the Chugach Mountain Range. The CORPS does not plan on sampling these two wells at this time. |
Louis Howard |
| 1/15/1992 |
Update or Other Action |
Installation Action Plan For Fort Richardson
Three Nike missiles sites were in the 172nd Infantry brigade. The 1964 Good Friday earthquake caused $17 million in damages to Fort Richardson. Most damage was incurred at the Site Point Nike hercules battery. |
Louis Howard |
| 4/9/1992 |
Update or Other Action |
EPA Memorandum April 9, 1992 Reply to the ATTN of ES-098. Subject Toxicity of Fuels. From Carol Sweeney, Toxicologist Health & Environmental Assessment Section. To Wayne Pierre Federal Facilities Superfund Branch (HW-124).
Toxicity Reference Vaules for Fuel Mixtures EPA Region 10 4/9/1992 Non-cancer effects-Gasoline (unleaded) RfD (mg/kg-day) Oral: 2.0E-1, Uncertainty Factor-Oral:1000, Level of Confidence-Oral: Low. Toxicity Data Source-Oral RfD: Memo 3/92. Carcinogenicity-Cancer Potency/(mg/kg/day): Oral 1.7E-3, Unit Risk (/ug/m3) 4.8E-7, Cancer Weight Of Evidence-C, Toxicity Data Source-Oral SF & Inhal. SF: Memo 3/1992.
Kerosene/JP-5 RfD2.0E-2, UF Oral: 10,000, LOC Oral: low, TDS Oral RfD: Memo 3/92, JP-4 RfD 8.0E-2, UF Oral: 10,000, LOC Oral: low, TDS Oral RfD: memo 3/92, Screening Values for Water RBCs based on Ingestion, Residential: Gasoline-Risk = 10-6 (ug/L) 50, 10-4=5000 HI=1 (ug/L) 7000, JP-5 Kerosene Risk 10-6 10-4=NA HI = 1 (ug/L) 700, JP-4 Risk 10-6 10-4 = NA, HI = 1 (ug/L) = 3,000
Screening Values for Soils- RBCs Based on Soil Ingestion Residential: Gasoline-Risk = 10-6 (mg/kg) 400, 10-4 (mg/kg) 40,000, HQ = 1 (mg/kg) 50,000, JP-5 Kerosene Risk 10-6 10-4 NA, HQ =1 5,000, JP-4 Risk 10-6 10-4 NA, HQ = 20,000
USEPA Office of Research & Development, Environmental Criteria & Assessment Office Cincinnati, OH Subj: Oral Reference Doses & Oral Slope Factors for JP-4, JP-5; similar to Kerosene (CAS no. 8008-20-6), Diesel Fuel (CAS No. 68334-30-5), & Gasoline (CAS No. 8006-61-9) (AVGAS) [McChord AFB (Wash Rack/Treatment)/Tacoma, WA]. From Joan S. Dollarhide Associate Director, Superfund Health Risk Techncial Support Center, Chemical Mixtures Assessment Branch TO Carol Sweeney USEPA Region X.
This memorandum is in response to your request for oral systemic & carcinogenic toxicity values for JP-4, JP-5, diesel fuel, & gasoline (AVGAS) found to contaminate soil & groundwater at McChord AFB (Wash Rack/Treatment), Tacoma, WA. We have attempted to derive RfDs & slope factors for the above fuel mixtures. We have derived provisional RfDs for gasoline, JP-4, JP-5 & diesel fuel; provisional cancer weight-of-evidence classifications of C for gasoline & D for JP-4, JP- 5 & diesel fuel; & a provisional slope factor (adapted from an interim Agency value) for gasoline.
Based on the available evidence, unleaded gasoline can be assigned to U.S. EPA (1986) weight-of-evidence Group C: possible human carcinogen. An earlier U.S. EPA document assigned unleaded gasoline to Group B2 as a probable human carcinogen (EPA, 1987a), but that document predates the U.S. EPA (1991d) conclusion that the male rat kidney tumors produced by gasoline are not predictive for humans, & therefore should not contribute to the weight-of-evidence or dose-response assessment of carcinogenicity. IARC concluded that marine diesel fuel is possibly carcinogenic to humans (Group 2B), but light diesel fuels & jet fuels are not classifiable as to their carcinogenicity in humans (Group 3). |
Jennifer Roberts |
| 5/15/1992 |
Update or Other Action |
Waterfowl Mortality In Eagle River Flats, AK The Role Of Munitions Residues, Charles H. Racine, Marianne E. Walsh, Charles M. Collins, Darryl J. Calkins, Bill D. Roebuck and Leonard Reitsma May 1992 (92-5) CRREL Report.
Explosive craters and associated features Page 13: Along the eastern edge of ERF is a large gravel pad that has been used as an explosive ordnance disposal (EOD) site (Fig. 10). The gravel pad is approximately 2 m thick and was placed as fill into the edge of the marsh. Aerial photos from 1956 show the edge of the pad in approximately the same location as at present.
The surface of the EOD pad is marked withmany craters and is littered with the remains of surplus and outdated munitions that have been blown up over the years. Along the bottom edge of the pad, numerous NIKE rocket motor casings, junk cars and scrap metal can be found. |
Louis Howard |
| 6/14/1993 |
Update or Other Action |
Letter to EPA Region 10 Doug Smith RE: Ft. Richardson Multimedia underground storage tank/leaking underground storage tank (UST/LUST) inspection report. The UST/LUST compliance inspection was conducted as part of the multi-media inspection at Fort Richardson by Kent Patrick-Riley and myself on June 16-17, 1993. A review of department records indicates the Army has operated at least 150 regulated USTs at Fort Richardson.
In 1987, the Army initiated UST testing (associated lines were not tested) at its Alaska facilities, including Fort Richardson. Eight of the tanks at Fort Richardson were identified as leaking. At that time, the product was removed from all tanks which failed a tank tightness test. In 1988, an underground storage tank (UST) removal and replacement program was initiated. According to available records, between 1988 and 1993, the Army permanently closed 46 regulated USTs and at least 5 non-regulated heating oil tanks at Fort Richardson by removing them from the ground. Petroleum contaminated soils was identified during closure of nearly all of the tanks. Since 1988, 25 new USTs have been installed at Fort Richardson.
Inspection of the slope to the west of Building 457 at the former NIKE site revealed dark staining from petroleum which appears to have been dumped on the hillside. The department has no records of the release. Failure to report a release and take necessary corrective actions may constitute a violation of State Oil Pollution regulations (18 AAC 75). |
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 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 |
| 12/15/1993 |
Update or Other Action |
Demolition Area Number One Closure Guidelines Fort Richardson Alaska, Prepared by the Dept. Of Army, U.S. Army Engineer District AK. December 1993. Prepared by EMCON AK INC.
2.3 Current Conditions Page 8
At this time, limited quantities of discarded material litter the pad. Racine et al. (1992:p. 13) reported that. “Along the bottom edge of the pad. numerous Nike rocket motor casings, junk cars and scrap metal can be found,” and that “Propellant grains. _ _ were found scattered on the EOD pad... ” A reconnaissance visit to the site on October 14. 1992. following a light snowfall, revealed no obvious hazardous materials. Three junked automobiles were found near the southeastern section of the pad at the berm. Larger numbers of discarded items, including automobile bodies, metal screens, 55-gallon steel drums, and smaller unidentified objects protrude from the bluff. On the upper surface of the pad lie occasional smaller pieces of metal and wooden crates.
Several detonation craters. four feet deep, line the edge of the bluff. The remainder of the pad’s surface appears free of craters.
The pad slopes toward the southwest. from the surrounding upland forest to the edge of Eagle River Flats. The surface soils consist of poorly sorted sandy gravels, with a mix of pebbles. cobbles. and clayey soils. The surface has been repeatedly graded. The most recent grading is apparent in the southwest corner, the same area EOD personnel said the most recent OB/OD activities were conducted. The pad supports a sparse vegetative cover in the form of woody
shrubs, with some grasses and broad-leaved herbaceous plants. |
Louis Howard |
| 11/3/1994 |
Enforcement Agreement or Order |
Janice Adair, Regional Administrator Southcentral Regional Office (ADEC) signs the Fort Richardson-State Environmental Restoration Agreement. After completion of all required actions, the source area(s) addressed in this Agreement will be included in a Record of Decision in the companion FFA.
ADEC finds that releases of petroleum products & oil within the meaning of AS 46.03.826, AS 46.03.740 & 19 AAC 75.990(35) have occurred at the source areas identified in Attachment A, & have contaminated the land & waters of the State of Alaska.
The petroleum contamination source areas will be remediated pursuant to the levels set forth in 18 AAC 75 (non-UST petroleum); the interim soil guidance for non-UST soil cleanup levels, dated July 17, 1991; the guidance for storage, remediation & disposal of non-UST petroleum contaminated soils, dated July 29, 1991; & for water, the applicable water standards set out in 18 AAC 70; & the applicable federal regulatory requirements for Maximum Contaminant Levels for drinking water; & interim guidance for surface & groundwater cleanups, dated September 26, 1990.
If the Army wishes to reduce water contamination concentrations to levels which exceed levels specified above, the Army may prepare a risk assessment which sets forth the justification for the proposed elevated clean-up levels. The risk assessment shall include an exposure assessment. toxicity assessment & risk characterization.
Free product recovery & soil remediation plans shall contain the following information: a schedule for implementation, support for choice of remedial technology, engineered system plans (where applicable), available equipment & skilled personnel, efficiency, reliability (life & difficulty of maintenance, costs & other associated impacts), compatibility of proposed actions with other reasonably foreseeable requirements, need for an on-site pilot scale study, third-party field supervision of remedial actions, procedures for equipment monitoring during remediation, contaminant media analysis to ensure remediation is progressing, & provisions for work documentation. Each plan shall reference the QAPP that will be followed & shall address any source area specific modifications necessary to conduct field work.
Remedial Action Plans for each source area with groundwater contamination shall contain the following information: a schedule for implementation, support for choice of remedial technology, engineered system plans (where applicable, available equipment & skilled personnel, efficiency, reliability (life & difficulty of maintenance, costs & other associated impacts), compatibility of proposed actions with other reasonably foreseeable requirements, need for an on-site pilot scale study, qualified 3rd-party field supervision of remedial actions in accordance with 18 AAC 75.995(70), procedures for equipment monitoring during remediation, contaminant media analysis to ensure remediation is progressing, & provisions for work documentation. Each plan shall reference a QA/QC plan addressing all reasonably foreseeable planned activities & shall address any source area specific modifications necessary to conduct field work.
Modifications, extensions, &/or actions taken pursuant to paragraphs 8(Schedule of Actions); 9-16 (Review & Comment on Documents); 17 (Subsequent modification); 37 (Progress Reports); 54-57 (Sampling & Data Document Availability); 63-65 (Extensions/Force Majeure) & Attachment B may be effected by the agreement of the Project Managers. Any modification approved orally under this paragraph must be reduced to writing within 10 days.
Sites covered by Attachment A at time of signing: Bldg. 755 Auto & Craft Shop: waste paints, grease mineral spirits, & oil, Status: RCRA Closure 1990 RFA SWMU: 27 & 72. Bldg. 794 Cannibalization Yard, Bldg. 45590 Motor Pool: waste oil, lubricants, antifreeze, acid, & solvents. Status: RCRA Closure 1990 RFA SWMU 83. Bldg. 47431 Aircraft Maintenance Facility: drycleaning solvents, grease, hydraulic fluid, methyl ethyl ketone, naptha & waste fuels/oil. 1990 RFA SWMU 87. Bldg. 39800 (Upper Site Summit) & Lower Site Summit Former Nike Missile Site: water with residual solvents, fuels, radioactive material, asbestos. |
Janice Adair |
| 11/17/1994 |
Update or Other Action |
Federal Facility Agreement (FFA) under CERCLA 120 Administrative Docket # 1093-05-02-120 signed by U.S. Army, U.S. EPA, & ADEC (John Sandor). The agreement ensures that the environmental impacts associated with past & present activities at the Post are thoroughly investigated & that appropriate removal &/or remedial action(s) is/are taken as necessary to protect the public health, welfare, & the environment.
Major sources of contamination at Fort Richardson (referred to collectively here as the Fort) include areas of white phosphorus at Eagle River Flats, PCB contamination at the Roosevelt Road transmitter site, volatile organic compounds at the Poleline Road disposal area, & the fire training pits.
"Agreement" shall mean this document & shall include all Attachments to this document. All such Attachments shall be incorporated by reference & are an integral & enforceable part of this agreement.
The Project Mgrs may decide to address a source area identified in Attachment I within the scope of a Two Party Agreement (TPA) between the ADEC & the Army. In such a case, & upon unanimous written agreement of the Army, US EPA, & ADEC Project Mgrs, the agreed upon activities at the source area may commence pursuant to the TPA, Such source areas will remain within the scope of this Agreement to the extent established in Part 3.5 of Attachment I.
An outline of the planned activities for the upcoming quarter & a revised depiction of the timeline for Attachment I using the CPM process. Any revisions to the primary milestones to this timeline shall be made pursuant to the procedures specified in Part XXXIII of this Agreement.
Enforceable deadlines (subject to extension pursuant to Parts XXV & XXXIII) for the draft primary documents are established in Attachment. The Army will propose secondary document target dates not otherwise established in Attachment. Unless the Parties agree on another disposition, new source areas will be addressed under the last scheduled OU as described in Attachment I.
The purpose of Attachment 1 is to set forth the elements of work required to be performed in responding to hazardous substance/waste releases, or the threat of such releases, at or from source areas at the Fort which pose an actual or potential threat to human health or the environment.
This document provides the site management approach to implement the remedial response process under the FFA entered into by the Army, the ADEC, & the US EPA. The source areas at the Fort have been divided into 4 manageable OUs. A critical path schedule has been developed for performing the general remedial activities at each OU, & an optimal sequence has been established for addressing each OU.
See site file for additional information. |
Louis Howard |
| 2/1/1995 |
Update or Other Action |
ATSDR site summary and site ranking for Fort Richardson. ATSDR issued Fort Richardson an lrE1' ranking because we did not identify any immediate health hazards nor any current human exposures. Rankings for facilities are "A" through "E", with "A" being highest priority in terms of threat to public health. Although the "E" ranking means that this site has received a low priority for receiving a full public health assessment within the next fiscal year, the attached site summary includes three issues would like the Army to consider.
In each case it appears that maintenance of institutional controls limiting public access to the areas in question will eliminate potential threat to public health. We are requesting that our staffs maintain contact on at least a semi-annual basis on the status of the base remedial
activities. If you have any questions, please contact Jeff Kellam at (404)639-6070.
Phvsical Hazards
Physical hazards include derelict structures, open pits, etc. that present the possibility of physical injury. Institutional controls are in place at Fort Richardson, effectively limiting access by the public. Additionally, many of the facilities in question, such as the abandoned Nike emplacements on Summit Mountain are in extremely isolated locations. For these reasons opportunities for exposure of the general public to physical hazards are very limited. Potential exposure is confined to trespassers who ignore posted warnings. However, if institutional controls are enforced, with fencing and signs regularly maintained, the potential for exposure is low.
Asbestos
The Fort Richardson environmental programs, as well as regulators, have recognized the potential hazard presented by asbestos in old and abandoned structures, such as the former Nike site. Asbestos occurrence appears to be limited to the interior of these old and abandoned structures. Institutional controls are in place, controlling access, and exposure to the public is limited to trespassers. Again, as long as institutional controls are maintained, potential for exposure to non-remediation workers and the public is insignificant. ATSDR will to work with Fort Richardson on the issues described above or to address other issues as warranted. |
Louis Howard |
| 8/1/1995 |
Update or Other Action |
During the excavation of underground storage tank (UST) 129 at Lower Site Summit extensive soil contamination was encountered. Preliminary verbal results from Brown and Root Service Corporation indicated levels of diesel range organic (DRO) compounds Oat upto 22, 000 mg/kg. Upon a visit to the site Major Kevin Gardner and Mr. Sam Swearingen found water with free product in the excavation.
Approximately 300 cubic yards of ORO contaminated soils were removed from the excavation. Based upon labor and transportation costs to haul the contaminated soil from Lower Site Summit, and stockpile it at the Circle Loop Road stockpile area, USARAK would like to backfill the excavation with the contaminated soils rather than contaminate the 300 cubic yards of clean fill it would take to fill the excavation.
Further, USARAK is requesting that both Upper and Lower Site Summit be removed from Fort Richardson-State of Alaska Environmental Restoration Agreement for UST, and be address under the Non-UST Petroleum, Oil and Lubricant Agreement. The entire site is currently undergoing a PSE 2 investigation being conducted by Ogden Environmental/Dowl Engineering, Inc.
Based upon the visual inspection Ogden has conducted there are many other concerns at the site, other than the USTs, that will need to be investigated. Any alternative clean-up levels, or remedial actions will be established for the entire site.
|
Louis Howard |
| 8/8/1995 |
Document, Report, or Work plan Review - other |
The Department of Environmental Conservation (DEC) has received on August 1, 1995,a request for transferring the Upper and Lower Site Summit sites from the Underground Storage Tank (USTCA) agreement to the non-UST agreement (SFRERA) for follow up and remediation. ADEC concurs with the Army's view that there are many more concerns at these two sites that need to be addressed as well. ADEC prefers to include the sites in the agreement that results in an expedited investigation and cleanup.
Please provide information which will show the agreement that will provide the framework for a timely cleanup. Without such information ADEC cannot agree to transfer the sites out of the USTMP agreement to the SFRERA agreement. When the information is received and reviewed, then ADEC will make a final determination of this matter. |
Louis Howard |
| 8/8/1995 |
Preliminary Assessment Approved |
Now includes Lower site summit UST 129 from Building 39225. Soil samples for DRO contamination ranged from 252 mg/kg to 5,630 mg/kg. |
Louis Howard |
| 10/3/1995 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Site Assessment Bldg. 39225 Tank 129, Fort Richardson, Alaska September 5, 1995.
The Alaska Department of Environmental Conservation-Defense Facilities Oversight group (ADEC) has received, on September 27, 1995, a copy of the above referenced report for building 39225. ADEC concurs that the level B cleanup criteria was exceeded at tank 129 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 February 1996. If there is enough information from the site assessment to undertake corrective action, then the Army may submit a workplan outlining the proposed remedial action without conducting a release investigation. |
Louis Howard |
| 7/23/1996 |
Update or Other Action |
ATSDR Public Health Assessment for Fort Richardson (U.S. Army) CERCLIS No. AK 621452257 July 23, 1996.
Abandoned and Derelict Structures
A group of facilities that require particular attention are the abandoned structures throughout the post. These include buildings within the main cantonment, and facilities in more remote areas, such as the former Nike installations on Summit Mountain. A number of these structures have been found to contain asbestos in addition to the expected physical hazards of an
abandoned building. During the 1994 site visit fencing at the remote Nike fortification was observed to be in a state of disrepair. Although public access to these areas is unlikely due to the remote lot ation within the interior of Fort Richardson, these structures require continued attention in the maintenance of institutional controls.
Physical Hazard Summary
As long as continued attention is given to the maintenance of institutional controls, physical hazards at Fort Richardson do not represent public health threats. |
Louis Howard |
| 7/31/1996 |
Update or Other Action |
Environmental Restoration News Vol 2 No 3 July 1996. Two Party Agreement at Fort Richardson. ADEC and the Army signed an agreement on November 3, 1994, requiring the Army to perform necessary site assessments to monitor, remediate, and "close" specific source areas on Fort Richardson. Sites included in the Agreement: Wooded area adjacent to the Black Spruce Travel Camp, Sewer line excavation area near the new Army Reserve Center, Former vehicle cannibilization yard at Building 794, Upper and Lower Site Summit (the former NIKE Missile Site), Building 755-the Auto and Craft Shop (surface soil sampling), Bryant Army Air Field (National Guard investigations underway), and OUD Source areas (PSE conducted under CERCLA), potential contamination: petroleum contaminants.
The contamination or potential contamination at the Two-Party sites mainly consists of petroleum products and oil. Site assessments involving surface and subsurface soil sampling have been conducted at most of the Two-Party Sites. The site assessment at Upper and Lower Site Summits included sampling of surface soil and surface water and sampling to determine the presence of explosives and radiological contamination. |
Louis Howard |
| 7/31/1996 |
Update or Other Action |
Site Assessment Report Two-Party Non-UST POL Preliminary Assessment/Site Investigation Contract# DACA85-95-D-0008 Delivery Order No. 0003. 2.0 Installation Background Information. 2.2 Installation History: The launch area at Lower Site Summit was where the missiles and warheads were stored. The Nike-Hercules missiles consisted of two solid fuel stages, a booster and sustainer. The warhead was nuclear. The Lower Site Summit facility contained the equipment and resources required to assemble, test, and maintain the missiles and associated launchers.
Upper Site Summit: 6 surface soil samples with diesel range organics (DRO) ranging from 16 mg/kg to 5,790 mg/kg. Gasoline range organics was detected only once at 320 mg/kg collocated with the 5,790 mg/kg DRO sample.
Lower Site Summit: 8 Surface soil samples with DRO from 9.6 mg/kg to 12,700 mg/kg (4 over 200 mg/kg and 2 over 1,000 mg/kg). PAHs ranged from 0.38 mg/kg to 40.7 mg/kg.
Site A, "Opportunity Strikes" Radio Installation: 27 surface soil samples taken. DRO ranged from 2,720 mg/kg to 17,400 mg/kg. TPH was detected at 77,900 mg/kg at RISS31 soil sample location. |
Louis Howard |
| 2/17/1997 |
Site Added to Database |
Site added by Shannon and Wilson, Inc. |
S&W-Miner |
| 7/9/1997 |
Update or Other Action |
Addendum 2 for Field Sampling Plan received. The objective of this document is to provide the information necessary to fill data gaps to complete the postwide risk assessments. Data gaps have been identified at the following four locations (see Figure l-l):
- Bryant Airfield Complex (BAC);
- Moose Run Golf Course;
- Alaska Department of Fish and Game Fish Hatchery (Fish Hatchery); and
- [NIKE] Site Summit.
The document is intended to supplement the existing Management Plan and will utilize the appended plans -- FSP, Quality Assurance Project Plan (QAPP), and Site-Specific Safety and Health Plan (SSHP) - as much as is practical and relevant.
A review of existing file information indicated the possibility of a fuming red nitric acid (FRNA) UST buried at Lower Site Summit. Previous investigations had not been successful in positively confirming or denying this information. Also of concern at both Upper Site Summit and Lower Site Summit are surface water drainages where elevated levels of methylene chloride have been detected during previous sampling programs.
A geophysical survey was intended at Site Summit in the presumed area of the UST. In addition, a visual investigation of French drain outfalls at both Upper and Lower Site Summits will be performed.
See site file for additional information. |
Louis Howard |
| 8/18/1997 |
Document, Report, or Work plan Review - other |
OU D Field Sampling Plan Draft Addendum 2, Fort Richardson, Alaska
DACAS5-94-D-0010: The Department of Environmental Conservation (DEC) has received the document on August 5, 1997. DEC has reviewed the document and has no comments regarding the sampling plan for Moose Run Golf Course work that was planned for Lower and Upper Site Summit. The plan is approved as submitted. |
Louis Howard |
| 8/29/1997 |
Document, Report, or Work plan Review - other |
Matt Wilkening-EPA comments on the FSP Addendum # 2 OUD Fort Richardson. Page 2-6 Section 2.1.3: Indicate if replicate samples will be co-located samples or will be subsampled from a homogenized sample. In either case, results may not provide the desired statistical power since samples will not be independent unless samples are collected during different field events.
Page 2-7 Table 2-2: Include a footnote specifysing the total, dissolved, and simultaneously extracted metals to be analyzed. Include analysis of herbicides and possibly fungicides since these compounds are widely used on golf courses.
Page 2-8 Section 2.5.1.1: The particle size should be considerably less than 3 inches in diameter. Three millimeters would be more appropriate. Otherwise, an extremely large sample volume would be required to obtain a representative sample (i.e., to eliminate heterogeneity errors) and laboratory subsampling would be problematic.
It is stated that sediment samples will be collected in plastic jars. While plastic is appropriate for metals, samples for pesticides/PCBs and total organic carbon must be collected and shipped in glass containers.
Page 2-9 Section 2.1.5.2: The use of polyethylene materials is not appropriate for collection of water samples for PCP analysis. PCBs would adsorb into the HDPE and membrane material resulting in loss from the porewater.
Provide evidence that 7 days is sufficient time for equilibration of powewater metal concentrations.
Page 2-9 Section 2.1.5.3: Water samples for pesticides/PCB analysis cannot be homogenized or mixed and then subsampled since these compounds also adsorb to glass surfaces resulting in a loss of anatytes. Laboratories overcome this problem by solvent rinsing the glass sample bottle during sample extraction.
Page 2-12 Section 2.2: E&nch Drains al Upper and Lower Summit. Sample and analyze drains and outfalls for nitrate as an indicator of nitric acid to verify that the material was not stored and/or released.
General comments: Revise sampling plan for Ship Creek to a phased approach that includes sample collection of sediments, porewater, surface water, macrophyte tissue, and benthic macroinvertibrates during the initial phase of sampling. Fish tissue sampling would be conducted during a second phase of sampling if .problems were identified as a result of the earlier phase of sampling. Remove all references to fish tissue sampling throughout the document. |
Louis Howard |
| 9/30/1997 |
Update or Other Action |
OUD Field Sampling Plan Addendum 2 Final DACA85-94-D-D-0010 Deliv Order No. 022: Data gaps have been identified at the following four locations: Bryant Airfield Complex (BAC); Moose Run Golf Course; Alaska Department of Fish & Game Fish Hatchery (Fish Hatchery); & Site Summit.
2.2.1. Underground Storage Tank at Lower Site Summit: A review of existing file information had indicated the possibility that there may have been a fuming red nitric acid (FRNA) UST buried at Lower Site Summit. Previous investigations had not been successful in positively confirming or denying this information. However, recently reviewed publications (Army 1954, DNR 1996? Bender 1997, Thelen 1997) coupled with discussions with former commanding officers of similar sites (Halsey pers. corn. 1997; Loving pers. corn. 1997) has led to the conclusion that this tank does not exist. FRNA was only used in conjunction with the earliest Nike Ajax rockets. Ajax rockets were never used at any of the Anchorage Nike facilities. The later model of Nike rocket (Hercules) employed a solid fueling system rather than the liquid system of FRNA & undiluted dimethylhydrazine (UDMH). Furthermore, FRNA & UDMH, when used, were stored above ground in small (7.7 cu. ft.) pure aluminum containers, not in large USTs.
A closer analysis of the as-built plans revealed a likely scenario that would account for the initial concern over the presence of the UST. On the plans for the Acid Storage Building, there is a cross section showing a buried 20,000-gallon tank. Due to the layout of the page, it appears that this tank is associated with the acid storage building. However, closer analysis clearly shows that the tank is located adjacent to the Control building & is intended for the storage of fuel oil, not FRNA.
Detailed description of the fueling operations from Milton B. Halsey, Jr., Colonel USA (Ret.), Site Manager, Nike Site SF GGNRA (pers. corn. 1997) clearly identifies the storage practices for FRNA associated with the Nike rocket sites. No underground storage of these fuels was performed, & only a “specially designed aluminum (99 percent pure) drum” that “closely resembled a beer keg” was used for storage of FRNA. FRNA or UDMH “was not stored in underground tanks. Most likely it was a diesel fuel storage tank for a generator or heater.”
As a result of this analysis, no additional work will be performed in the area of the Acid Storage Building at Lower Site Summit. Although a geophysical investigation had originally been proposed, based on recently developed information as presented above, no further investigation will be performed.
French Drains at Upper & Lower Site Summit: Previous investigations (DOWUOgden 1996) have identified several French drains as having potential for release of contaminants. ENSR will perform a visual investigation of the French drains & out-falls at both Upper & Lower Site Summit to determine whether additional investigation is feasible. As mentioned above, it has been determined that FRNA was never stored or used at Site Summit. Accordingly, there is no plan to sample to determine whether any nitric acid has been released at this site. |
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 |
| 11/1/1999 |
Update or Other Action |
To: Dr. Mollie TeVrucht. CEPOA-PM. United States Army Engineer District, Alaska (USAED Alaska)
From: Ecology & Environment. Inc. (E & E)
Date: November 1, 1999
Re: Contract No. DACA8599-D-0003. Delivery Order No. 0009; Site Summit Risk Assessment: Fort Richardson. Alaska
E & E conducted a records search at the Army's Directorate of Public Works at Fort Richardson USAED Alaska at Elmendorf Air Force Base (EAFB), the National Archives & United States Air Force History at EAFB. E & E also interviewed Mr. Jeff Green former sergeant stationed at Site Summit in the 1970s, & contacted seven people who once served at the Nike Hercules Missile sites, including Site Summit. via electronic mail. E & E gathered blueprints & as-builts of the site & six site assessment reports addressing the closure & removal of underground storage tanks (USTs) & aboveground storage tanks (ASTs) at Site Summit. Additionally, E & E conducted an Internet search for informaton about the Nike Hercules Missile sites.
Site Summit & Opportunity Strikes are located on Fort Richardson, The Opportunity Strikes location is on Opportunity Strikes Road, approximately 2 miles from Arctic Valley Road & 0.75 mile from Alpenglow Ski Area. Lower Site Summit is approximately;0.5 mile from the Opportunity Strikes location, & Upper Site Summit (USS) is 2 miles from Lower Site Summit (LSS). Two magazine bunkers are between LSS & USS (Dowl/Ogden 1998).
Interviewees indicated that carbon tetrachloride was used throughout Site Summit as a general cleaning solvent. Ethylene-glycol-based antifreezes also were used extensively. Radioactive vacuum tubes were used & possibly discarded on site. Other chemicals reportedly used at this site included linseed oils, paraffin, kerosene (for heating fuel), gasoline (for vehicle fuel). & Cosmoline (a petroleum-based preservative used in weapons storage).
Upper Site Summit
Buildings at the USS area include high-power acquisition radar (HIPAR), battery control, target tracking radar, target ranging radar. & missile tracking radar buildings. There are also an electrical substation & helicopter landing pad. In 199-t & 1995. two USTs (Tanks 57 & 112) & one AST (Tank 58), located on the west side of the battery control building, were removed (Oil Spill Consultants 1995; Nessco Environmental 1994). One AST remains outside the HIPAR building, but its size is unknown. There are discrepancies in information concerning the volumes of the two USTs.
As-builts indicate that the larger UST’s (Tank 112) capacity was 30,000 gallons; however. the tank was identified as containing 33,000 gallons of diesel in the 1995 site assessment report by Oil Spill Consultants. Diesel range organic (DRO) concentrations in soils after the tank removal were found to exceed Alaska Department of Environmental Conservation (ADEC) Level B cleanup levels. Whether the distribution lines were removed when the tanks were removed is unknown.
As-builts indicate that the smaller UST (Tank 57) had a capacity of 5.000 gallons & was used for mogas; however, in its 1994 site assessment report. Nessco Environmental reported that the tank had a capacity of 2,000 gallons. In June 1994 DRO concentrations found in soils after the tank removal exceeded ADEC’s Level C cleanup levels. The AST (Tank 58) was a 130-gallon tank located within a concrete vault. During tank removal activities in July 1995, soils were analyzed for gasoline range organics (GRO); benzene; & benzene. toluene, ethylbenzene, & total xylenes (BTEX). No contamination above applicable cleanup levels was observed, & nofurther- action (NFA) status was recommended.
In 1995. Dowl/Ogden collected six surface soil samples at USS in addition to the samples collected in conjunction with the tank removals. All samples were analyzed for DRO. GRO. metals. total petroleum hydrocarbons (TPHs), & volatile organic compounds (VOCs). GRO. DRO. & TPHs were detected at levels of potential concern. E & E’s research indicated that ten areas warrant further investigation.
Lower Site Summit
LSS includes the launch control building, two missile launch areas, & a missile warhead magazine, in addition to canine kennels, a vehicle shop & storage building, two gate houses, & a water storage tank. Two ASTs (Tanks T-l 13 & T-39125) & one UST Tank 129) have been removed from the launching control building (Building 39225). No other tanks are known. |
Louis Howard |
| 2/29/2000 |
Update or Other Action |
Environmental Restoration News Vol 6 No 1 February 2000. Two Party Petroleum Sites Page 3: Former Mike Hercules Missile Site
The Army plans to complete a Risk Assessment for contamination at the former Nike Site located near Arctic Valley in the Chugach Mountains, 12 air miles northeast of downtown Anchorage. The Army and ADEC have agreed on a conceptual model for the site and a general approach to the Risk Assessment.
The Army is preparing a Sampling and Analysis Plan (SAP) to gather more information at the site and outline the sampling strategy. The draft SAP will be released for review in late February 2000, with field work planned for early summer 2000.
The former Nike Missile Site was placed on the National Park Service’s National Register of Historic Places in July 1996. The Army and the State Historic Preservation Office has organized a task force to evaluate the management options for opening the former Cold War Site to the public in the interest of heritage tourism. The Nike Site Summit Task Force includes representatives from community organizations with interest in the Chugach State Park, preservation non-profits, the Army, and the Alaska Division of Parks and Outdoor Recreation. The site was built 40 years ago in response to a potential aerial bomber threat by the former Soviet Union on the local military bases (Fort Richardson and Elmendorf) and Anchorage.
|
Louis Howard |
| 2/20/2003 |
CERCLA ROD Periodic Review |
Jennifer Roberts (ADEC) signs the First Five-Year Reviews. ADEC’s concurrence with the findings of this review is based on the information presented in the accompanying Five-Year review Report, First Five-Year Review Report for Fort Richardson, Alaska. This statutory review is required by the Comprehensive Environmental Response, Compensation, & Liability Act (CERCLA) since all of the RODs for this site were signed after the effective date of the Superfund Amendments & Reauthorization Act of 1986 (SARA) & some of the remedial actions result in hazardous substances, pollutants, or contaminants remaining at the site above levels that allow for unlimited use & unrestricted exposure. OUD is the fourth OU to reach a final-action ROD & was signed June 30, 2000. This ROD documented a NFA Decision in accordance with EPA Guidance. OUD was originally established to be the final OU to be investigated at Fort Richardson. Consequently, this ROD was intended to integrate the remaining evaluations at the Post & include the potential cumulative human health & ecological risks that may become evident from the aggregate of source areas & areas not otherwise resolved in previous OUs. Additional background details & general site information is documented in the OUD ROD & in the Administrative Record for each source area listed in this Section.
OUD originally consisted 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), & where warranted, limited field investigations, called PSE2s, were conducted. Based on the PSE2, petroleum contamination at Building 955 qualified to be investigated under the Two-Party agreement & 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, & the Building 45-590 Auto Hobby Shop. Based on the PSE & RI information, the Army, ADEC, & EPA determined in the OUD ROD that 6 source areas required NFA under CERCLA, 3 source areas should be referred to the Non-UST Two-Party Agreement, 2 source areas be recommended for NFA under CERCLA following additional limited monitoring, & the 2 remaining source areas were referred to a newly created OU, OUE, for investigation & further evaluation.
The NFA decision was recommended for source areas if: no visible sign of contamination was observed during the source area inspection; a removal action eliminated existing & potential risks to human health & the environment; or environmental sampling results showed contamination, if present, is at levels below the protective human health-based levels for unrestricted use. The NFA decisions for 7 sites identified in the ROD are intended to document that the risk to human health & the environment associated with contamination from past activities at the Post is not present at these sites. Two of these source areas, the landfill fire training area & the grease pits, are being monitored in accordance with the requirements of the Fort Richardson Landfill Closure Plan. The NFA decision under CERCLA was made in the OUD ROD for the following source areas: Building 726 Laundry Facility, Storm water Outfall to Ship Creek Dust Palliative Locations (4 separate areas), Landfill Fire Training Area, Grease Pits, Building 45-590, & Circle Road Drum Site.
Three source areas were referred to the Two-Party Agreement because the only contaminants of concern were petroleum. This agreement is part of the FFA and officially referred to as the State-Fort Richardson Environmental Restoration Agreement. It presents the petroleum cleanup strategy & documents all known historical petroleum sources on Post & their current cleanup status. It also confirms the Army’s commitment to adequately address these petroleum source areas in a manner consistent with state regulations. The source areas that were referred to the Two-Party agreement & do not require any additional action under the OUD ROD include: Building 700/718, Building 704 & Building 955 petroleum contaminated soils. The ROD determined 2 source areas, Building 796 (Battery Shop) & Building 955 (DDT contaminated soils), should undergo further monitoring. These source areas are subject to Five-Year Review for evaluation of post-ROD monitoring data to determine if levels of chemicals of concern at these sites are below MCLs or EPA risk based criteria & do not pose a threat to human health or the environment. |
Jennifer Roberts |
| 9/30/2005 |
Update or Other Action |
Perchlorate: Overview of Issues, Status, and Remedial Options Prepared by The Interstate Technology & Regulatory Council Perchlorate Team September 2005.
Highly soluble and mobile in water, perchlorate is also very stable. Most of the attention focused
on perchlorate contamination concerns groundwater and surface water contamination. However,
perchlorate can also contaminate soil and vegetation. The potential for perchlorate contamination
in drinking water and food supplies is a human health concern because it can interfere with
iodide uptake by the thyroid gland and, through this mode of action, result in decreased thyroid
hormone production.
NOTE 18 AAC 75 (January 2016) lists perchlorate cleanup level for under 40 Inch Zone Direct Contact 71 mg/kg and Migration to GW value of 0.067 mg/kg. Table C Groundwater cleanup level is 0.026 mg/L. EPA RSL THQ=1 lists ammonium/lithium/potassium/sodium perchlorate RSLs of 55 mg/kg residential 820 mg/kg commercial tapwater 14 ug/L.
Of the four main manufactured perchlorate compounds, ammonium perchlorate as used for solid
propellant rockets and missiles makes up the largest proportion by volume of U.S. production. However, the earliest use of perchlorate as a solid propellant was in the form of potassium perchlorate. The Guggenheim Aeronautical Laboratory at the California Institute of Technology developed a formulation that combined asphalt as a binder and fuel with the oxidizer potassium perchlorate for use in jet-assisted take-off units (Hunley 1999).
In the middle to late 1940s and early 1950s, perchlorate-based rocket motors that used potassium perchlorate were developed for smaller tactical missiles. In the early to middle 1950s, ammonium perchlorate began replacing potassium perchlorate as the preferred oxidizer for solid propellants in large rocket motors.
By 1958, the NIKE Hercules missile, which replaced the NIKE Ajax missile, used a solid propellant motor of polysulfide–ammonium perchlorate. In the 1960s, solid propellant mixtures of ammonium perchlorate and powdered aluminum replaced liquid propellant systems in intercontinental ballistic missile systems. |
Louis Howard |
| 2/23/2007 |
Exposure Tracking Model Ranking |
|
Louis Howard |
| 5/31/2007 |
CERCLA PA |
Abbreviated Preliminary Assessment for Site Summit NIKE site. Site Summit Nike site is divided into five locations- 1)Opportunity Strikes: includes the adjacent landfill to the southeast and the borrow pit to the north; 2) Lower Site Summit: including the landfill that is due west; 3) Explosive and Missile Magazine Area; 4) Upper Site Summit; and 5) Off-site Areas.
Waste fluids were reported to have been disposed of directly to the surface soil on occasion, rather than being transported to official dumps. Dumping of various wastes was reported as common at Nike sites. The primary factor affecting the incidence of dumping was convenience. Rural sites, such as Nike 07, were particularly prone to “unofficial” dumping.
Potential sources of contamination may be present at the site and may be migrating offsite to downgradient targets such as groundwater wells, wetlands, and Ship Creek. Further investigation of the site under the Comprehensive Environmental Response, Compensation, and Liability Act is recommended. |
Louis Howard |
| 8/3/2007 |
Update or Other Action |
E&E for EPA under Contract Number: EP·S7-06-02 Technical Direction Document Number: 07-05-0021
provided a Draft Nike Site Summit Site-Specific Sampling Plan.
Sample locations have been selected to determine if contamination generally associated with operations at former Nike sites are present in off-site targets. Samples will be submitted for off-site fixed laboratory andlor on-site field laboratory analysis for 1,4-Dioxane (EPA Method 625!8270C), diesel range organics (DRO; Alaska Department of Environmental Conservation [ADEC] Methods 102), gasoline range organics (GRO; ADEC Method 101), NDMA (EPA Method 521). perchlorate (EPA SW-846 metbod 6860), SVOCs including PBDE (EPA CLP SOW SOM01.l andlor EPA SW-846 method 8270). TAL metals (EPA CLP SOW SOM01.l and/or EPA SW-846 6000 and 7000 series methods), UDMH (laboratory SOP), and VOCs (EPA CLP SOW SOMOI.1 andlor EPA SW-846 method 8260).
Groundwater Well Sampling. Groundwater samples will be collected by purging the water from the wells for 10 to 14 minutes prior to samples collection, groundwater monitoring parameters (pH, conductivity, turbidity, dissolved oxygen, temperature, and salinity) will be measured until all readings stabilize within 10% of each other for three consecutive readings. The samples will be collected directly from the spigot nearest the wellhead into dedicated pre-labeled sample containers. Samples requiring preservation, will be preserved immediately after sample collection or placed into pre-preserved sample containers.
• Surface Water Sampling. Surface water samples will be collected by hand-dipping the sample container into the water, if possible, or by creating a funnel with a dedicated 1-liter polyethylene sample bottle with the bottom of the bottle removed. If required, a chemical preservative will be added to the sample after collection. Water quality parameters (dissolved oxygen, pH, temperature, salinity, conductivity, and turbidity) will be determined using a field instrument prior to sample collection or placed into pre-preserved sample containers.
A mnnicipal drinking water intake for the City of Anchorage is present on Ship Creek approximately 1.5 miles from the site. The target distance limit (TDL) for the groundwater migration pathway is a 4-mile radius that extends from the sources at the site. Drinking water is known to be used as an ingredient in commercial food preparation at the nearby Alpenglow Ski Area.
Upper Site Summit flows overland approximately 0.5 mile to an Unnamed Tributary (PPEl) north of the site. PPEI flows to the end of the urmamed tributary approximately 2.5 miles downstream. The Connector Road flows overland approximately I mile to the same Unnamed Tributary (PPE 2), and again the TDL is wholly contained within the unnamed tributary. Lower Site Summit flows overland approximately 0.5 mile to an Unnamed Tributary (PPE 3). The Unnamed Tributary flows approximately 1.5 miles to the confluence with Ship Creek. The TDL concludes approximately 13.5
miles downstream in Ship Creek.
See site file for additional information. |
Louis Howard |
| 8/23/2007 |
Document, Report, or Work plan Review - other |
Army (K. Gardner) sent EPA (K. Marcy) Request for Clarification on EPA’S Proposed Draft Nike Site Summit Site-Specific Sampling Plan at Fort Richardson, Alaska (FRA).
On August 7, 2007 you had telephoned our office and requested permission to enter Fort Richardson’s property to sample our drinking water system for perchlorate. At that time, detailed information about why this site was being selected for the study and how the data would be used was not made available to our Compliance Program. This letter is to acknowledge that the U.S. Army Garrison, Alaska (USAG-AK) has since received a copy of your Draft Nike Site Summit Site-Specific Sampling Plan, July 2007. This report was forwarded by Ecology and Environmental, Inc. (EPA’s Superfund Technical Assessment and Response Team (START) -3 contractor) to Fort Richardson and received on August 16, 2007.
After reviewing the above mentioned report we still have several unanswered questions that concern us regarding this sampling request. It is unclear to us what regulatory program or jurisdictional driver this sampling activity is governed under (CERCLA / RCRA or Clean Water/ Safe Drinking Water Program). Understanding this will enable us to ensure that the correct compliance individuals are involved in reviewing the material and communicating with you.
Additionally, it is unclear in the report how scientifically and legally defensible data would be generated from the collection of a single grab sample at the intake of the Fort Richardson Water Treatment Plant. If the decision to collect a single sample is part of a targeted sampling program, then the scientific hypothesis and supporting documentation outlining this rational is missing from the report. Without detailed information in the report regarding site specific operations and source characteristics it is also difficult to follow the methodology used to identify any chemicals of potential concern (COPC) at the Fort Richardson Site Summit Nike site. Furthermore, a discussion outlining any potential exposure pathways that might exist from any identified POCs and the selection of a 4-mile radius in evaluating groundwater is lacking.
Given our inability to clearly understand the purpose, scope, and objective for this draft plan we are hesitant to allow the sampling at this point. We are willing to discuss our concerns with you regarding this project and as always are will to continue working with the EPA to help ensure the overall protection of human health and the environment. If you have any questions please contact Don Haas, Colorado State University IPA, Environmental Compliance Specialist – Water Program, at (907) 384-0208. |
Louis Howard |
| 9/4/2007 |
Update or Other Action |
EPA finished sampling in August 2007. Sampling limited to off-site well at Alpenglow Ski Area and the Municipality of Anchorage surface water intake. EPA did not find any contaminants of concern over the detection limits.
Samples were submitted for off-site fixed laboratory analysis for 1,4-Dioxane (EPA Method 625 8270C), diesel range organics (DRO; Alaska Department of Environmental Conservation [ADEC] Methods 102), gasoline range organics (GRO; ADEC Method 101), NDMA (EPA Method 521) and PERCHLORATE (EPA SW-846 method 6860),
SVOCs including PBDE (EPA CLP SOW SOM01.l and/or EPA SW-846 method 8270). TAL metals (EPA CLP SOW SOM01.l and/or EPA SW-846 6000 and 7000 series methods), UDMH (laboratory Standard Operating Procedure [SOP]), and VOCs (EPA CLP SOW SOMOI.1 and/or EPA SW-846 method 8260).
|
Louis Howard |
| 9/22/2009 |
Meeting or Teleconference Held |
Nike Site Summit PRE-RI/FS TRIAD meeting to discuss the way forward for the investigation of the NIKE Site Summit and a site visit in the afternoon of 9/22/2009. |
Louis Howard |
| 10/9/2009 |
Update or Other Action |
Memorandum of Agreement between US Air Force & US Army for Joint Base Elmendorf-Richardson. 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”, & the supported Component(s) – the United States Army (USA), hereafter referred to as the “supported Component(s)” for fully implementing Base Realignment & Closure (BRAC) 2005 Joint Base decisions per references (a), (b), (c), & (d) at Joint Base Elmendorf-Richardson. For the purposes of this MOA, the terms “party” & “parties” shall be understood to refer exclusively to the supporting Component & the supported Component(s), either collectively or individually.
This MOA establishes a comprehensive framework for Joint Base Elmendorf-Richardson implementation, & 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. 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.
Major milestones & transfer date for each annex to successfully achieve FOC which area applicable to environmental issues.
#15 Annex G: Review existing environmental contracts/determine optimum methods to complete the JB mission Activation or completion date: 01/31/2010,
#16: Develop JB Environmental Quality organizational structure 01/31/2010
#17: Merge JB tank inventories into a single, common data base (DB) 03/01/2010
#18: Work with external regulatory agencies to optimize the merger of all air permits 06/01/2010
#19: Begin Merger of JB air emission inventories into a single, common DB 09/01/2010
#20: Determine additional air regulatory requirements due to JB merger 06/01/2010
#21: Begin Merger of JB drinking water (DW) programs 06/01/2010
#22: Determine DW regulatory requirements due to JB merger 06/01/2010
#23: Merge JB environmental management system (EMS) programs 08/01/2010
#25: Complete new JB compliance inventory & risk analysis 08/01/2010
#27: Establish JB Environmental, Safety, & Occupational Health Council (ESOHC) 08/01/2010
#33: Merge JB hazardous waste (HW) programs 10/01/2010
#34: Work with external regulatory agencies to optimize incorporating Fort Richardson into Elmendorf Air Force Base Part B permit 03/01/2010
#35: Develop JB OPLAN for HW/toxic waste operations 06/01/2010
#36: Merge JB HW inventories/accumulation points into common DBs 10/01/2010
#37: Merge JB Land Use Controls (LUC) programs 10/01/2010
#42: Merge JB contaminated sites (CS) program 10/01/2010
#43: Merge JB CS inventories into a single, common DB 10/01/2010
#44: Convert Fort Richardson CS to meet Air Force protocols 10/01/2010
#45: Begin Merger of JB spill prevention & reporting programs 01/31/2010
#46: Develop JB spill contingency plan 03/01/2011 Note: this is when current plans expire. EPA says we can use existing plans until then.
#58: Review existing Agreements & Plans 09/01/2010
#88: Transfer all environmental files from Fort Richardson to JBER 09/01/2010
#90: Merge Fort Richardson & Elmendorf Air Force Base Geographic Information System (GIS) into AF-approved GIS 09/01/2010
#96: Review Comprehensive Environmental Response, Compensation, & Liability Act (CERCLA) activities to ensure compliance with the Federal Facility Agreement (FFA) 03/01/2010
#97: Draft notification of responsibility change for FFA 09/01/2010
#98: Negotiate revisions/amendment to Two party Agreement 10/01/2010
#99: Prepare annual update of the status of all two-party sites 09/01/2010
#103: Prepare/update JB instruction for management of LUCs 09/01/2010
#104: Update maps/GEOBASE depicting LUC boundaries 10/01/2010
#105: Prepare/submit annual LUC report to EPA & ADEC 10/01/2010
#106: Update Air Force base general plan 10/01/2010
#107: Merge JB CERCLA administrative record 09/01/2010
#108: Merge project & contract files into common formats & DBs, libraries 10/01/2010
#109: Prepare & update the Community Relations Plan 10/01/2010
#110: Develop 1- & 2- year work plans for the (Defense-State Memorandum Of Agreement) DSMOA cooperative agreement 10/01/2010
#111: Merge JB CS programs 09/01/2010
#112: Merge JB CS inventories into a single, common DB 10/01/2010
#113: Convert Fort Richardson CS to meet Air Force protocols 10/01/2010
#114: Merge JB Military Munitions Response Program (MMRP) sites programs 10/01/2010
#115: Merge JB MMRP site inventories into a single, common DB 10/01/2010
#116: Convert Fort Richardson MMRP sites to meet AF protocols 10/01/2010
#120 I-1.3 Transfer Records Mgt. Functions to the Joint Base 06/30/2010
|
Louis Howard |
| 3/25/2010 |
Enforcement Agreement or Order |
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 |
| 5/4/2010 |
Meeting or Teleconference Held |
NIKE Site Summit TRIAD Systemic Planning Meeting held at Fort Richardson with: Rafael E. Vazquez-AFCEE/ERC, John C Marshall-MWH, Lenny Wright-FRA Range Control, Mike Bryers-FRA Range Control, Bill Adams-EPA/Region 10 RPM, Louis Howard-ADEC-CSP RPM, Gary Fink-3 CES/CEANR, Earl Crapps-ADEC/CSP, Marty Brewer-ADEC/CSP, Ron Porter-NOBLIS, Rick Girouard-MWH, Heather Williams-MWH, Bruce Narloch-MWH, Alex Hanson-MWH, Lisa Graham-DPW-FRW-ENV, David Fitz-Enz-FRA Range Control, Doug Quist-MWH, Mark Prieksat-DPW-FRW-ENV RPM, Todd Fickel-AFCEE/EXE, and Dick Nenahlo-DPW-FRW-ENV.
Field Investigation Process
Do initial proposed sampling set based on previous data, as-built research and on-site field screening
- Rush samples in areas of known contamination at former USTs and any sources located by field screening to minimize length/cost of drill rig mobilization
- Disseminate results graphically to TRIAD participants as they become available for real-time group decision-making
• If on-pad surface or sub-surface samples come back hot, delineate vertical and horizontal extent with additional borings or test pits
• If off-pad surface soil samples come back hot, attempt hand borings to 3' or point of refusal at initial sampling location and additional locations to delineate vertical and horizontal extent
Scope of Work Assumptions
All sampling to take place outside building footprints
• Limited entry into buildings for visual inspection to help determine and/or verify appropriate outside sampling locations
• No sampling of daytank, drain, pit, utilidor, etc. locations within and/or underneath building foundations
- No hazardous building material sampling
- No sampling near tanks that were pulled and determined NFA by ADEC
- No radioactive survey work
Sampling Assumptions
Subsurface soil will be sampled from:
• excavated test pits
• split spoons driven by a hollow-stem auger drill rig (not into bedrock)
• hand excavations
- Borings that encounter water will be completed as Monitoring Wells and sampled if recharge rate allows
See site file for additional information. |
Louis Howard |
| 5/21/2010 |
Update or Other Action |
Army submits a work plan for the former NIKE Site Summit. Upper Site Summit. Investigate areas of potential & known contamination associated with aboveground storage tanks (ASTs), former USTs, floor drain outlets, & the septic system. Samples are planned to be collected from surface soil (0 to 2 feet below ground surface [bgs]), subsurface soil (utilizing test pits or boreholes), groundwater (if present) from monitoring wells (to be installed), & collocated ephemeral surface water & sediment samples representing primary runoff from the site.
Lower Site Summit. Investigate areas of potential & known contamination associated with ASTs, USTs, floor drain outlets, & the septic system. Samples are planned to be collected from surface soil, subsurface soil (utilizing test pits or boreholes), groundwater (if present) from monitoring wells (to be installed), & collocated ephemeral surface water & sediment samples representing primary runoff from the site.
Area A – Former Opportunity Strikes Radio Relay Station. Investigate areas of potential surface soil & subsurface soil contamination in the vicinity of the three remaining concrete foundations.
Area A – Suspected Disposal Area. This area was referred to as a former landfill in the 1996 PA/SI. However, there is no record of a formal landfill being established for either Nike Site Summit or the former Opportunity Strikes Radio Relay Station. However, based on site observations noting surface debris, there may also be buried debris at this location. The objectives for this area are to determine, through a magnetometer survey, if buried ferrous metallic debris is present &, if so, to conduct an invasive investigation of some areas with the highest potential for metallic debris. Additional investigation will be made to determine whether there is any contamination emanating from within the suspected disposal area by sampling at what appears to be the toe of the slope of the disturbed or mounded area.
Area A – Former Borrow Area. A site walk of this area will be conducted during the RI to confirm there is no evidence of surface staining or otherwise notable visible contamination. However, no additional sampling is planned for the borrow area within Area A based on the data presented in the 1996 PA/SI.
Area B – High Explosive & Guided Missile Magazines. A site walk of this area will be conducted during the RI to confirm there is no evidence of surface staining or otherwise notable visible contamination. No additional sampling is planned for this area based on the data presented in the 1996 PA/SI.
Area C – Pump House. Surface soil, surface water, & sediment samples will be collected & analyzed at the Pump House during the RI to establish presence or absence of COPECs associated with the fuel system & pump.
Area D – Former Borrow Area. A site walk of this area will be conducted during the RI to confirm there is no evidence of surface staining or otherwise notable visible contamination. However, no additional sampling is planned for Area D based on the data presented in the 1996 PA/SI.
See site file for additional information. |
Louis Howard |
| 6/21/2010 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Preliminary Draft RI/FS and Baseline Risk Assessment Work Plan. The text states: “The RI will entail sampling surface and subsurface soil, sediment, surface water, sludge, and groundwater to determine if there are any contaminants of potential environmental concern (COPECs) on-site in concentrations at or above regulatory cleanup levels and, if so, to determine what affect they might have through development of a baseline HHERA.”
The reference to regulatory cleanup levels has the same definition as “ARARs or “Applicable or Relevant and Appropriate Requirements" and shall mean any standard, requirement, criterion, or limitation as provided in Section 121(d) (2) of CERCLA, 42 U.S.C. § 9621 (d) (2), and the NCP. ARAR identification is necessarily an iterative process and that potential ARARs must be re-examined throughout the RI/FS process until a ROD is issued.
With respect to releases of hazardous waste or hazardous constituents, Resource Conservation and Recovery Act (RCRA) shall be considered an ARAR pursuant to Section 121 of CERCLA, 42 U.S.C.§ 9621. ADEC is not a RCRA authorized state and shall defer to the U.S. EPA regarding RCRA corrective action obligations that relate to the release(s) of hazardous substances, hazardous wastes, hazardous constituents, pollutants, or contaminants.
The text states: “This project is being conducted under the guidelines of the Comprehensive Environmental Response and Liability Act (CERCLA) of 1980 with the participation of the U.S. Environmental Protection Agency, Region 10, and the Alaska Department of Environmental Conservation (ADEC).” ADEC requests the Army move this paragraph to a new subsection.
The text states: “A total of seven borings and five surface soil samples are planned to investigate fuel operations at the Battery Control and Barracks Building. If water is encountered in any of the borings, they will be converted to monitoring wells per MWH standard operating procedures provided in Appendix B.”
ADEC recommends the Army use the more updated ADEC Monitoring Well Design and Construction for Investigation of Contaminated Sites (February 2009).
The text states: “The test pit will extend to the base of the tank. If no evidence of contamination is evident, the pit will be extended 1-foot and a subsurface soil sample collected. If contamination is evident, based on visual or photoionization detector (PID) screening, the test pit will be extended downward until the extent of the contamination is reached or the excavator is met with refusal.”
ADEC will require the Army to take a subsurface soil sample at the bottom of the test pit or when the excavator is met with refusal. For an excavated pit area up to equal to 50 square feet, at least two samples must be collected from the pit area. One additional sample must be collected for 51-250 square feet of pit area. For an excavated pit area of more than 250 square feet collect 2 samples, plus one sample for each additional 250 square feet, or portion thereof over the initial 250 square feet, at points where contamination is most likely to be present, as determined by field screening or presence of staining. For excavation sidewalls, a minimum 1 per 20 linear feet, or portion thereof at the highest field screening reading in all soil horizons (i.e. a 20’x20’ excavation [80 linear feet total] would require 4 laboratory side wall samples. A 4’x4’ excavation [16 linear feet total] would require 1 laboratory side wall sample).
Field screening samples and laboratory samples are to be collected within a soil horizon at the area most likely to be contaminated, such as on top of confining layers, at the base of more porous layers, at the groundwater interface, or along any other preferential pathways identified in the field. The number of field screening samples will, at a minimum, be dictated by Table 2B – Surface/Excavation Soil Sample Collection Guide, based on square feet of surface area (ADEC Draft Field Sampling Guidance Table 2B – Surface/Excavation Soil Sample Collection Guide May 2010).
In no case shall the Army not collect the minimum number of samples from an excavation (test pit) due to lack of positive field screening results (i.e. PID/FID response below an arbitrary response level). In this case, best professional judgment by the sampling technician will be used to collect the mandatory number of samples. A PID measures the change of signal as the analytes are ionized by an ultraviolet lamp. It can be used alone to give a general idea of levels of soil contamination, but cannot identify the individual constituents that are present. There are contaminants which cannot be detected by the PID (e.g. metals, and PCBs). The reading of ppm with the PID does not always correlate with laboratory analytical results.
|
Louis Howard |
| 8/4/2010 |
Document, Report, or Work plan Review - other |
Staff reviewed & commented on the Draft Post Wide Work Plan, Fort Richardson, AK dated July 2010.
4.4.4 Confirmation Sampling Page 4-6: ADEC will require the Army to comply with the UST Procedure Manual Section 6.3 Determination of Analyses for Petroleum Hydrocarbons: “Unless approval to deviate from these specifications is obtained in advance from ADEC, selection & use of all laboratory analyses must conform to the provisions of Table 2A & appropriate sections of this chapter.
Table 2A indicates which product is to be tested for each petroleum range using Alaska Series Methods & for the various indicator compounds listed in Table 2B, using methods from EPA's Test Methods for Evaluating Solid Waste, Physical/Chemical Methods, SW-846, adopted by reference in 18 AAC 78.090(d).” The identity of a released refined petroleum product is assumed to be unknown unless a laboratory analysis shows that a contaminant is only a gasoline or only a non-gasoline refined product, unless this requirement is waived by ADEC.
4.5 Test Pit Investigations, Excavations, & Waste Characterization Pages 4-6 & 4-8: ADEC treats test pits the same as an excavation & will require sampling to comply with the UST Procedure Manual (i.e. 2 samples from the first 250 sq. ft. of excavated area & 1 soil sample for every 250 sq. ft. thereafter).
ADEC will require the Army to take soil samples at all test pits since it is not acceptable to use field screening results, olfactory results, visual observations, best professional judgment to determine if contamination is known, absent or present in soil at a source area.
Page 4-8: ADEC will require the Army to obtain laboratory confirmation prior to reuse of the overburden to determine if the overburden from the excavation meets cleanup levels. ADEC will not accept a determination that the overburden is “clean” based solely on field screening results, visual or olfactory observations, or best professional judgment of the contractor on site.
4.10 Backfilling Page 4-9: The text states: “In the event that excavation is required, clean soil (including overburden removed during the excavation) will be used as backfill.”
See ADEC’s comment above regarding the need to ensure that contamination is not present in “clean” overburden through laboratory analysis prior to backfilling activities. Field screening results, visual observations, olfactory results or best professional judgment will not substitute for laboratory confirmation results. If there is an absolute human welfare or safety issue or building foundation integrity being compromised by leaving the excavation open until laboratory results are in, then backfilling excavation is appropriate with the understanding that the Army may have to excavate the soil again if results are above cleanup levels.
ADEC requests the Army correct all the TBC designations for those Federal/State Acts or Regulations which are in fact ARARs (i.e. cleanup standards, standards of control, & other substantive environmental protection requirements, criteria, or limitations promulgated under Federal environmental or State environmental or facility citing law). See attached list of Potential universe of ARARs (Federal Citation & companion State Citation where applicable).
See site file for additional information. |
Louis Howard |
| 8/17/2010 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (ADEC) has received the above document for review and comment on August 16, 2010. ADEC has reviewed the response to comments and the modifications to sampling test pits at the Nike Site Summit (CS DB # 2775). The response is satisfactory as well as the number of subsurface soil samples collected from the test pits. The work plan is approved.
ADEC’s review and approval on the work plan is to ensure the work is done in accordance with State of Alaska Environmental Conservation laws and regulations. While ADEC may comment on other state and federal laws and regulations, our comments on the plan do not relieve the Army, its contractors, subcontractors or agents acting on its behalf, from the need to comply with other applicable laws and regulations.
|
Louis Howard |
| 11/17/2010 |
Meeting or Teleconference Held |
A meeting of the remedial project managers (RPMs) convened at 0900 on 17 November 10 at the Joint Base Elmendorf-Richardson (JBER)-Richardson Conference Room in Building 658. Attendees included: Mr. Bill Adams - Environmental Protection Agency (EPA); Mr. Louis Howard - Alaska Department of Environmental Conservation (ADEC); Mr. Robert Shirley - Air Force Center for Engineering and Environment (AFCEE) Western Region Environmental Office; Mr. Nick Muszynski - AFCEE Restoration - Program Management Office (R-PMO); Mr. Rafael Vazquez - AFCEE R-PMO; Mr. Jim Klasen - lith Air Force Environmental Attorney; Ms. Renee Wright - Environmental Restoration Community Relations Coordinator; and CEANR personnel - Mr. Gary Fink, Mr. Mark Prieksat, Ms. Donna Bawnler, Mr. Don Aide, Mr. Tim Plucinski, Mr. Dick Nenahlo, and Ms. Cynthia Tomlinson.
NIKE Site Summit - Mr. Nenahlo provided an update on progress of the RIfFS project and field work that was conducted in Summer 2010. This FYIO project was awarded through the Air Force Center for Engineering and the Environment (AFCEE). Field work included the collection of soil, groundwater and background samples, which was completed in mid-Oct. A total of209 soil samples and 17 groundwater samples were evaluated. Preliminary data indicates no polychlorinated biphenyls (PCBs) were detected; trichloroethylene (TCE) hits were fairly low; arsenic was high but comparable to 1996 data; lead detections were all high and are associated with fuel sites; and DRO and GRO were identified in Area A of Upper Site Summit. Data validation is expected at the end of Nov 10. The RI Report is expected in Apr 11 and the FS Report is anticipated next summer. |
Louis Howard |
| 3/31/2011 |
Update or Other Action |
JBER-Richardson Nike Site Summit Analytical Data Report received. The number of samples collected by media and area included: Approximately 90 surface soil samples – USS, LSS, Area A, Area C, and Background Sampling Area, Approximately 89 subsurface soil samples – USS, LSS, Area A, Approximately 13 groundwater samples – USS and LSS, and One primary surface water/sediment sample – Area C.
The bulk of the sampling and investigation, including all of the groundwater sampling, was focused on the Launch Control Building and Vehicle Maintenance Shop, which are adjacent to one another. The Launch Control Building is the site of a former diesel UST (UST-129), and a former diesel aboveground storage tank of unknown quantity or designation.
Additionally: PCB samples were analyzed in areas associated with the electrical substation. EDB (low level) samples were analyzed in select areas of the former UST. Perchlorate samples were analyzed in areas associated with the missile launch pads and potential runoff drainages. Hexavalent Chromium. Surface soil samples exhibiting chromium concentrations greater than 38 mg/Kg were resampled and analyzed for hexavalent chromium. All surface soil samples from in front of the Vehicle Maintenance Shop and its drain outfall were also analyzed for hexavalent chromium.
These data will be analyzed in detail in a forthcoming human health and ecological risk assessment (HHERA) and a remedial investigation (RI) report. SGS Environmental Services Inc. (SGS) of Anchorage, Alaska, provided analytical services for this investigation. MWH performed the data verification and validation presented in this Analytical Data Report.
DATA VERIFICATION/VALIDATION SUMMARY
Precision. Based on the results of the MS/MSD, LCS/LCD, laboratory replicate and field duplicate/replicate sample analyses, the data are precise as qualified.
Accuracy. Based on the tune standard, ICAL, ICV, CVS, IS, surrogate, MS/MSD, LCS, LCD, labeled standard, and ion ratio results, the data are accurate as qualified.
Representativeness. Based on the results of the holding time evaluation, method trip and source water blank sample analysis, the field duplicate/replicate sample evaluation, and the RL evaluation the data are considered representative as qualified.
Completeness. Based on the results of the data verification and validation, all data are considered usable.
Based on the results of the data validation, the data collected for this sampling round were of sufficient quantity and quality to meet the project objectives.
Location ID: 10NSS001GW04USS Field Sample ID: 10NSS001GW04USS Sample Date: 09/01/10 Water E504.1 1,2-Dibromoethane (EDB) 0.047 µg/l HT 15 Days 14 Days J- (Holding Time exceeded by one day cleanup level is 0.05 ug/l). J- Data are estimated, potentially biased low due to associated quality control data. Lead (total) 653 ug/L lead (dissolved): 43.5 ug/L Field Sample ID: 10NSS001GW04USS taken 9/1/2010.
See site file for additional information. |
Louis Howard |
| 6/1/2011 |
Update or Other Action |
Incorporation of Nike Site Summit into the JBER-Richardson (JBER-R) Federal Facility Agreement (FFA) memorandum signed (and all concurred) by EPA, AF and ADEC remedial project managers. Nike Site Summit was listed in the 1994 Fort Richardson FFA as a Non-UST Two-Party Site. The Army conducted a preliminary assessment/site investigation (PA/SI) for Nike Site Summit in 1996 and determined that further investigation was warranted. Data collected during the PA/SI indicated that fuel and volatile organic contaminants were present at the site. In 2010, the Army initiated a Remedial Investigation and Feasibility Study (RI/FS) to characterize the nature and extent of contamination. Based on initial data results, fuel contaminants and solvents (TCE) have been confirmed to be present at the site. The RI/FS is on-going and a draft report is expected to be completed in mid 2011.
In accordance with Section 24.3 ofthe Federal Facility Agreement (FFA), a new site can be addressed under the last, scheduled Operable Unit or other mechanism as agreed upon by the Parties to the FFA. As described in Section 9 of the FFA, the Project Managers have the authority to determine how to address source areas within the scope of the FFA. The FFA requires unanimous written agreement between the Project Managers concerning disposition of individual source areas.
The Project Managers are asked to review the proposed document schedule for Nike Site Summit that is enclosed with this memorandum. Please indicated if you concur/non-concur with this request to incorporate Nike Site Summit into the FF A and sign the enclosed agreement.
Gary Fink, Chief Restoration Section.
Based on site-specific information indicating that CERCLA contaminants are present in soil and groundwater, the Project Manager~ agree that Nike Site Summit will be incorporated into the FFA as a new site subject to the stipulations listed in the FFA and Attachment 1.
Document Type, Document, Date Due for Agency Review
Primary Draft RI/FS Work Plan May 19, 2010
Primary Final RI/FS Work Plan August 16, 2010
Secondary Draft RI Report June 27, 2011
Primary Final RI Report August 19, 2011
Secondary Draft FS Report August 30, 2011
Primary Final FS Report October 24, 2011
Secondary Proposed Plan June 15, 2012
Primary Record Of Decision September 30, 2010
This schedule may be updated or modified to include additional primary or secondary documents as necessary to meet FFA requirements. |
Louis Howard |
| 7/1/2011 |
Update or Other Action |
Staff received the draft remedial investigation. Surface runoff at USS is thought to be minimal, except in times of extreme precipitation. A May 2010 site visit during snowpack melt showed no signs of runoff. Several heavy rainfall events occurred during the 2010 RFI from August through October 2010, & no surficial runoff resulted. All the melt water & rainwater appeared to be absorbed through percolation.
5 surface soil samples were collected from the vicinity of the former Diesel UST location (SS13USS & SS14USS), the former gasoline UST (SS15USS & SS16USS), & the drain outfall for the Barracks Bldg (SS07USS). SVOCs were detected in surface soil samples above action limits for benzo(a)anthracene (8.61 mg/Kg), benzo(a)pyrene (2.0 to 5.75 mg/Kg), & benzo(b)fluoranthene (6.93 mg/Kg). [MTG cleanup level: benzo(a)anthracene 3.6 mg/kg & benzo(a)pyrene 2.1 mg/kg]. Subsuface soil samples: DRO concentrations in subsurface soil ranged from non-detect (ND) to 3,690 mg/Kg. (MTG cleanup level 250 mg/kg].
TCE was detected in subsurface soils above action limits at BH01, BH/MW04, BH06, BH06, BH10, & BH/MW12 – ranging from 23.4 to 79.0 µg/Kg. [MTG cleanup level TCE 0.020 mg/kg]. Benzo(a)pyrene was detected at 2.47 & 3.71 mg/Kg, [MTG cleanup level 2.1 mg/kg] above the action level of 0.49 mg/Kg. Dibenz(a,h)anthracene was detected at 0.653 & 0.846 mg/Kg, above the action level of 0.49 mg/Kg. [Direct Contact Dibenzo(a,h)anthracene 0.49 mg/kg]
GW at USS is limited to perched water collecting within fill material placed on top of bedrock in the vicinity of the former USTs. Subsequently, GW volume at USS was not sufficient to develop or purge any of the three wells, but rather was collected directly utilizing disposable Teflon bailers, as the use of peristaltic pumps was unsuccessful due to high viscosity. GW samples above action limits for the following compounds & ranges, singular results indicate one (two) detection(s) only above action limits:
GRO (0.941 mg/L) , DRO (9.43 & 32.3 mg/L) [Table C 1.5 mg/L] & RRO (4.41 & 31 mg/L) [Table C 1.1 mg/L].
Total metals were detected in 2 GW samples above action limits for the following compounds & ranges, singular results indicate 1 detection only above action limits: Arsenic, Total (73 & 156 µg/L) [Table C 6 ug/L], Barium, Total (11,600 & 16,200) µg/L [Table C 2,000 ug/L], Cadmium, Total (6.88 µg/L) [Table C 5 ug/L], Chromium, Total (694 & 1,790 µg/L) [Table C 100 ug/L], Lead, Total (189 to 653 µg/L) [Table C 15 ug/L], Nickel, Total (531 & 916 µg/L) [Table C 10 ug/L], Vanadium, Total (1,610 & 2,450 µg/L). [Table C 260 ug/L].
Dissolved metals were detected, but below action limits, except for lead at MW04USS (43.5 µg/L). [Table C 15 ug/L]
SVOCs were detected in one GW sample (MW04USS) above action limits for the following compounds & ranges: 2-Methylnaphthalene (0.0552 mg/L), Benzo(a)anthracene (0.0168 mg/L) [Table C 0.0002 mg/L], Benzo(b)pyrene (0.0131 mg/L), Benzo(b)fluoranthene (0.0142 mg/L) [Table C 0.0012 mg/L], bis(2-ethylhexyl)Phthalate (0.0115 mg/L) [Table C 0.006 mg/L], Chrysene (0.0177 mg/L) Fluoranthene (0.0296 mg/L), Phenanthrene (0.0116 mg/L), and Pyrene (0.0329 mg/L).
HIPAR Bldg. & Foundation: All of the surface soil samples were analyzed for GRO, DRO, RRO, VOCs, & SVOCs. There were no detections above action limits.
Surface soil: Arsenic was detected in all 3 samples between 4.59 & 5.54 mg/Kg. These detections are above the action limit of 3.9 mg/Kg but below the 95% UPL of 12.5 mg/Kg for background arsenic levels at NSS. Total chromium was detected above the action limit of 25 mg/Kg in Samples SS27USS & SS31USS at 25.1 & 29.9 mg/Kg, respectively. However, all chromium detections were below the 95% UPL of 38.3 mg/Kg for background chromium concentrations at NSS.
2 primary samples were collected at approximately 3 feet bgs, where the excavator met with refusal due to the presence of bedrock. Both samples were analyzed for GRO, DRO, RRO, VOCs, SVOCs, RCRA 8 metals, nickel, vanadium, & PCBs. Total Chromium was detected above the action limit 25 mg/Kg in both samples (31.1 & 31.8 mg/Kg), but was below the 95% UPL of 38.3 mg/Kg for background chromium levels at NSS.
No other analytes were detected above action limits in subsurface soil samples collected from Electrical Sbstn C.
See site file for additional information. |
Louis Howard |
| 7/28/2011 |
Document, Report, or Work plan Review - other |
Staff provided comments on the Nike Site Summit Remedial Field Investigation Contract No. FA8903-08-D-8777, Task Order 0083 June 2011 JBER-Ft. Richardson.
ES-1 2nd para. Executive Summary: ADEC requests JBER add text to the paragraph describing the purposed of the Remedial Investigation (RI) Report. “The objective of the Rl/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. The RI continues to serve as the mechanism for collecting data to characterize site conditions; determine the nature of the waste; assess risk to human health & the environment; & conduct treatability testing as necessary to evaluate the potential performance & cost of the treatment technologies that are being considered.” (Guidance for Conducting Remedial Investigations & Feasibility Studies Under CERCLA OSWER Directive 9355.3-01 October 1988)
1-2 1.0: The text makes reference to a separate Analytical Data Report which presented the complete 2010 analytical data set & data validation. The report did not have an explanation for methylene chloride detections, nor did the QA/QC summary provide any additional detail. There was no technical memorandum provided with the Analytical Data Report (ADR) & it was merely data presented in tables with flagged data for the EPA & ADEC remedial project managers to review. There was no required discussion on data usability in the QA/QC summary as required by ADEC’s Technical Memorandum “Environmental Laboratory Data & Quality Assurance Requirements” March 2009.
All laboratory results, including laboratory quality control (QC) sample results, must be reviewed & evaluated for quality, validity & usability. The text must include any effects on data validity &/or usability due to field sampling & laboratory quality control discrepancies. The QA Summary, at a minimum, will describe the following six (6) parameters for all analytical results with respect to the impact that any discrepancies have on the quality & usability of the data.
Plus, it appears that the additional verification flags are not present in the Remedial Investigation Report, only the laboratory provided flags. ADEC noted during a review of the ADR at section 2.2.5 Field Duplicate/replicate Evaluation, the field duplicate RPD criteria for water is incorrect. It should be thirty (30) percent, not fifty (50) percent. ADEC requests JBER concur with a request to incorporate additional comments on the ADR when ADEC conducts an additional review of the referenced Analytical Data Report with the draft Human Health/Ecological Risk Assessment Report & comments provided on both documents. This will give the ADEC & EPA extra time to look at them together. The ADR is a secondary document under the Federal Facility Agreement & may be finalized in the context of the corresponding primary documents [i.e. Remedial Investigation/Feasibility study (RI/FS), including RI, Baseline Risk Assessment, FS per para. 20.5 (d) pages 35 & 36).
|
Louis Howard |
| 8/31/2011 |
Update or Other Action |
Baseline risk assessment received.
USS-Current & Future Site Worker: Cumulative carcinogenic risk & noncarcinogenic HI for a current & future site worker exposed to USS surface soil were 2 x 10-5 & 0.07, respectively, for non-PHC COPCs. The primary contributors to risk were arsenic (Ar) (EPC = 9.84 mg/Kg) & benzo(a)pyrene (BaP) (EPC = 1.37 mg/Kg). The HI estimate for surface soil is below ADEC’s acceptable HI criterion of 1. Cumulative carcinogenic risk & noncarcinogenic HI estimates for a current & future site worker and visitors exposed to subsurface soil at USS were less than ADEC’s acceptable risk & HI criteria.
Hypothetical Future Resident: Cumulative carcinogenic risk & noncarcinogenic HI estimates for a hypothetical future resident exposed to surface soil at USS were 5 x 10-5 & 0.7, respectively, for non-PHC COPCs. The primary contributors to risk were Ar & BaP. The noncarcinogenic HI estimate is below ADEC’s acceptable HI criterion of 1. Cumulative carcinogenic risk & noncarcinogenic HI estimates for a hypothetical future resident exposed to subsurface soil at USS were 2 x 10-5 & 0.2, respectively, for non-PHC COPCs. The primary contributors to risk were BaP (EPC = 0.632 mg/Kg) & dibenz(a,h)anthracene (EPC = 0.335 mg/Kg). The noncarcinogenic HI estimate is below ADEC’s acceptable HI criterion of 1.
LSS- Current & Future Site Worker: Cumulative carcinogenic risk & noncarcinogenic HI estimates for a current & future site worker exposed to soil & indoor air at LSS were 3 x 10-4 & 0.9, respectively, for non-PHC COPCs. The primary contributors to risk in surface soil were BaP (EPC = 7.74 mg/Kg) & PCP (EPC = 46.5 mg/Kg). The primary contributors to risk in subsurface soil were 1,2,3-trichloropropane (EPC = 0.491 mg/Kg) & 1,2-dibromo-3-chloropropane (EPC = 3.04 mg/Kg). The primary contributor to risk in indoor air was TCE (EPC = 0.00843 mg/L).
The cumulative site media noncarcinogenic HI for non-PHC-related COPCs was less than ADEC’s acceptable HI criterion of 1. The cumulative noncarcinogenic HI estimate for current & future site workers exposed to PHC-related COPCs at LSS was 0.05. This noncarcinogenic HI estimate is less than ADEC’s acceptable HI criterion of 1.
Current & Future Site Visitor: Cumulative carcinogenic risk & noncarcinogenic HI estimates for a current & future site visitor exposed to subsurface soil at LSS were 2 x 10-5 & 0.05, respectively, for non-PHC COPCs. The primary contributor to risk in subsurface soil was 1,2-dibromo-3-chloropropane. The noncarcinogenic HI estimate is less than ADEC’s acceptable HI criterion of 1. PHCs were not selected as COPCs in subsurface soil at LSS. Cumulative carcinogenic risk & noncarcinogenic HI estimates for a current & future site visitor exposed to surface soil at LSS were less than ADEC’s acceptable risk & HI criteria of 1 x 10-5 & 1, respectively. The cumulative noncarcinogenic HI estimate for a current & future site visitor exposed to PHC-related COPCs in subsurface soil at LSS was less than ADEC’s acceptable HI criterion of 1.
See site file for additional information. |
Louis Howard |
| 11/30/2011 |
Update or Other Action |
MEMORANDUM FOR DISTRIBUTION FROM: 673 CES/CEANR 6326 Arctic Warrior Drive JBER, AK 99506-3240 dated 30 November 2011 received.
SUBJECT: Revision of the Federal Facility Agreement Document Schedule for Nike Site Summit, JBER-Richardson
1. Nike Site Summit was incorporated into the Joint Base Elmendorf-Richardson, Richardson (JBER-R) Federal Facilities Agreement (FFA) on 1 June 2011. At that time Federal and State FFA Project Managers, along with the U.S. Air Force (USAF) FFA Project Manager, established a schedule for primary and secondary documents under the FFA. However, delays with recent document submittals, reviews and revisions have resulted in a failure to meet the schedule as delineated.
2. Schedule updates and/or modifications to the schedule require unanimous written agreement between the Project Managers. As such, the Project Managers are asked to review the attached revised document schedule for Nike Site Summit. Please indicate if you concur/non-concur with this request to modify the FFA document schedule for Nike Site Summit and sign the enclosed
agreement.
Project Managers agree to the proposed revision of the Nike Site Summit document schedule.
3. The revised document schedule will be included as an attachment to the FFA:
Document Type Document Date Due for Agency Review
Primary Final RI 6 February 2012
Primary Draft FS Report 26 March 2012
Secondary Draft Proposed Plan 10 December 2012
Primary Draft Record of Decision 3 June 2013
4. This schedule may be updated or modified to include additional primary or secondary documents as necessary to meet FFA requirements. |
Louis Howard |
| 12/2/2011 |
Document, Report, or Work plan Review - other |
EPA (Bill Adams) sent in review comments for the NIKE Site Summit Draft HHERA.
The Human Health & Ecological Risk Assessment (HHERA) requires reorganization to ensure that the HHER components are presented in a logical progression. For example, Section 3.0 CSM includes a discussion of both the HHRA & ERA although the potential receptors & exposure pathways are distinctly different for each evaluation. To ensure the ERA addresses the appropriate indicator species, exposure media, & chemicals, the conceptual site model (CSM) should be described as part of the Problem Formulation step in the Tier I ERA progress, followed by the selection of chemicals of potential ecological concern (COPECs).
It is recommended that the relevant portions of Sections 3.0 Conceptual Site Model, 6.0 Uncertainty Analysis, & 7.0 Risk Based Cleanup Levels be reorganized & presented as separate HHRA & ERA sections in the HHERA. The HHRA should be presented in accordance with Alaska Department of Environmental Conservation (ADEC) (2010; 2011b) & Environmental Protection Agency (EPA) (1989) HHRA guidance; the Tier I & Tier II ERA should be presented in a manner consistent with ADEC (1999; 2010; 2011b) & EPA (1997; 1998) ERA guidance.
The calculation of exposure point levels (EPCs) for use in the baseline HHRA & Tier II ERA using EPA’s ProUCL software, Version 4.1.00 dated May 2010 should be re evaluated & revised. It appears that an insufficient number of detected results (high number of non-detects) were used in the calculation of the 95 percent Upper Confidence Limit (95UCL) for some of the analytes, resulting in erroneous EPCs used in the estimates of cancer risk, non-cancer hazard, & Tier II dose calculations. There also appears to be inconsistencies in the use of the erroneous EPCs when maximum levels should have been used as the EPC. Consequently, the calculated risks presented for the HHERA may not be accurate & the results, conclusions, & risk-based cleanup levels should be revised based on the maximum level as the EPC when there are an insufficient number of detected results for an analyte.
The risk assessment was conducted using an insufficient number of samples for GW (2 samples; Table 2-3) at the Upper Site Summit. At Area C there were an insufficient number of samples used in the risk assessment for surface soil (3 samples; Table 2-9), surface water (2 samples; Table 2-10), & sediment (1 sample; Table 2-11). Additional sample collection is warranted prior to performing the HHERA for these areas.
The HHERA does not include figures of the four sites that depict sample locations, historic site features/release areas, & surface cover (vegetated, paved, surface drainage) resulting in the lack of clarity in the CSM. A fundamental description of the site history & environmental setting should supplement the CSM to support the selection of human health & ecological receptors, contaminant fate & transport pathways, exposure media & exposure pathways to be further evaluated in the HHERA.
The overall approach for the ERA is based on a tiered approach but the steps for conducting the ERA require clarification in order to justify the use of specific exposure level methodologies & exposure factors (e.g., species-specific home ranges) at the Step 3, Screening Level ERA phase. For example, Section 5.2.2.2 states. “Methods used in the statistical derivation of soil & surface water EPCs during the Phase II ERA are the same as those previously described for human health (refer to Section 4.2.1).” It is not clear what the Phase II ERA refers to & whether it is conducted as part of the Tier II ERA. Further, please indicate the basis for the EPC (e.g., maximum level, 95UCL for the dose calculations) since use of the 95UCL limit typically occurs in the Baseline Ecological Risk Assessment & not at the Step 3, Screening Ecological Risk Assessment. Additionally, please provide a flowchart to describe the steps of the ERA to supplement the text in Section 5.0.
The document lacks certain basic components of a complete Tier I Screening ERA, which are further described as follows:
a. The Problem Formulation step does not include several components to establish the exposure setting used as the basis for the exposure analysis & risk characterization.
A detailed description of the site history & environmental setting at each of the four sites & figures are not provided. This information should include, but is not limited to: the size of the site, physical description of site features (e.g., location of above & underground storage tanks [USTs], transformers, landfills, etc.) relative to sample locations, & types of aquatic & terrestrial habitats. This information is the basic foundation upon which to develop the CSM; without this information, the CSM is unclear. |
Louis Howard |
| 1/3/2012 |
Update or Other Action |
Air Force discussion topics for 01/04/2012 meeting on agency comments on the HHERA.
1. EPA General Comment 3: “Additional sample collection is warranted [at Upper Site Summit and Area C] prior to performing the HHERA ...”.
USAF Response: Groundwater was extremely limited at USS and therefore it is not feasible to collect additional groundwater samples. Furthermore, the location and the number of samples collected at Area C is consistent with the approved Work Plan based upon what was agreed to during prior Triad meetings. (Additional responses/explanations as required.)
2. EPA General Comment 7: “Additional data may be needed to fully evaluate potential exposure to PCBs at the four sites.” For example, “… none of the samples collected at Area C even though Section 5.2.1 Exposure Analysis indicates that transformers were present at the four NSS Areas.”
USAF Response: Field observations made at Area C indicate that no transformer was found at the Pump House. Furthermore, analytical results of samples collected across NSS demonstrated that PCB-containing transformer fluids were not used at NSS.
3. EPA Specific Comment 3: Use of a hierarchy of screening values vs. more the conservative of RSLs and ADEC values.
USAF Response: ADEC accepted (i.e. did not comment on) the hierarchy as provided in the draft HHERA, and EPA accepted the hierarchy as provided in the approved Work Plan. As such, the USAF will follow the hierarchy presented in the Work Plan.
4. EPA Specific Comment 10: Figure 3-3 - Ecological CSM.
USAF Response: EPA has requested separate Eco CSM figures for each area of concern. Both ADEC and EPA previously agreed with the single Eco CSM figure that was included in the approved HHERA Work Plan. The USAF does not believe separate Eco CSMs are necessary.
5. EPA Specific Comment 11: Sections 4 and 5 regarding EPCs
USAF Response: EPA does not acknowledge having received, reviewed, or approved revised EPCs in their comments although this is assuming the TechLaw Inc was aware of the revised EPCs.
6. EPA Specific Comment 12: Table 4-2: Human Health Toxicity Values.
USAF Response: ADEC previously requested that we use the conservative end of the range of inhalation toxicity values for TCE cited in EPA’s 2002 Toxicity Reassessment for TCE, whereas EPA requests that we use new inhalation toxicity values for TCE published by the EPA on September 28, 2011. Please provide guidance on which value to use.
7. EPA Specific Comment 18: Section 7 - RBSLs for carcinogenic risk drivers:
USAF Response: ADEC did not comment on our target risk of 1x10-5; EPA has requested we use a target risk of 1x10-6. Please provide guidance on which value to use.
|
Louis Howard |
| 1/3/2012 |
Update or Other Action |
JBER response to EPA comments on the HHERA.
Section 6.0, Uncertainty Analysis, is similarly intended to discuss sources of uncertainty that are related to components of the HHERA that are common to both the HHRA & ERA, such as chemical characterization & site characteristics, together. However, we agree that review of uncertainties specific to the HHRA or ERA would be facilitated by highlighting the uncertainty components that apply to the human health or ecological risk assessments. Text will be modified to place uncertainty discussions specific to the HHRA or ERA under separate subsection headings.
Risk-based Cleanup Levels (RBCLs) are presented separately for human & ecological receptors as described in Sections 7.2.1 & 7.2.2. However, additional subsection headings will be added to Section 7.1 to differentiate the specific methods used to calculate RBCLs for human & ecological receptors. Please also note that we will consider the potential for different organization of this information in future risk assessments.
In response to ADEC comments on the EPCs included in the Draft HHERA Report, the AF prepared & submitted revised EPC tables to the EPA & ADEC for their review. In e-mail correspondence from ADEC & EPA to Mr. Tim Plucinski (AF), ADEC & EPA approved the EPC revisions & directed the AF to revise the HHERA Report accordingly. The revised EPCs, & updated risk estimates based on the revised EPCs, will be presented in the final version of the HHERA Report.
Please also note that RBCLs are not dependent on the EPC values used for calculation of hazard estimates, & therefore, revision of EPCs will not change the calculated RBCLs for any chemical already identified as a risk driver.
GW was found to be extremely limited at Upper Site Summit (USS). Most boreholes were dry. It is not feasible to take additional GW samples at USS. The location & number of surface soil samples that were collected at Area C conform to what was agreed to during the Triad mtngs detailing the proposed sampling regime across all of the NSS sub areas & as stated in the approved Work Plan. Given that there was no evidence of release from the pump house at Area C, & no other potential sources of contamination, the necessity for broad sampling was confirmed to be unwarranted. The locations of the three surface soil samples were such to capture any contamination running off from the Pump House to the ponded area & followed the natural drainage. The surface soil samples were within 10-feet of each adjacent location & coverage is considered sufficient to demonstrate that no release has occurred.
The singular collocated surface water & sediment sample was collected from the area of lowest flow & greatest deposition, & is therefore indicative of the worst case. Also, the ponded area is a concrete lined structure with minimal sediment accumulation & likely seasonal flushing. Additional surface water samples collected in July 2011 upstream & downstream of the pond demonstrated similar concentrations to those detected in the pond, suggesting that the single 2010 sample was representative of contamination within the pond.
Based on these factors, the AF believes that no further sampling is required. A figure showing the general layout of the four Nike Site Summit areas will be added to the HHERA for ease of reference.
See site file for additional information. |
Louis Howard |
| 1/3/2012 |
Update or Other Action |
JBER response to ADEC comments on the draft HHERA.
We agree that ADEC regulates based upon total contaminant concentrations in water. We also agree that the baseline HHRA should evaluate risks in the absence of remediation or institutional controls. Therefore, risk estimates were calculated for a hypothetical future resident consuming unfiltered GW as described in the HHERA Report. Please also note that a balanced baseline HHRA should provide risk estimates based upon all reasonably anticipated future land uses. As noted below, it is reasonable to assume that GW at the NSS would be filtered prior to consumption. Thus, human health risk estimates were also provided using results from filtered GW samples. The additional risk estimates based upon filtered GW sampling results were provided to give risk managers additional perspective regarding the range of potential risks associated with the Site.
GW samples for metals were collected & analyzed for both total & dissolved phase, with dissolved samples field filtered with a 0.45 micron in-line filter. Both total We agree that ADEC regulates based upon total contaminant concentrations in water. We also agree that the baseline HHRA should evaluate risks in the absence of remediation or institutional controls. Therefore, risk estimates were calculated for a hypothetical future resident consuming unfiltered GW as described in the HHERA Report. Please also note that a balanced baseline HHRA should provide risk estimates based upon all reasonably anticipated future land uses. As noted below, it is reasonable to assume that GW at the NSS would be filtered prior to consumption. Thus, human health risk estimates were also provided using results from filtered GW samples. The additional risk estimates based upon filtered GW sampling results were provided to give risk managers additional perspective regarding the range of potential risks associated with the Site.
GW samples for metals were collected & analyzed for both total & dissolved phase, with dissolved samples field filtered with a 0.45 micron in-line filter. Both total & dissolved phased metals were compared in the risk assessment as it is reasonable to assume given the limited availability & poor quality of GW available across NSS, that if any water were ever to be used for human consumption, it would be at a minimum treated through filtration, leaving only dissolved phase metals.
Background Data
Please note that background sample data were provided in the March 2011 Draft RFI Analytical Data Report previously submitted to ADEC. A reference to this draft report will be added to the text. ProUCL output files for UPL calculations will be provided in an appendix to the HHERA Report.
3.1 Page 3-1 Please note that the HHERA Report was submitted to ADEC in August, 2011. However, we will edit text to indicate that 18 AAC 75 was revised on October 1, 2011. Text will also be revised to indicate that 18 AAC 70 was revised as of May 26, 2011.
3.1.1. Page 3-2 Please note that EPA published revised Regional Screening Levels (RSLs) table as of November, 2011. The November 2011 RSL Table will be used in preference to the June Table. Text will be revised to cite the November 2011 update to the RSLs, & screening levels will be revised to reflect the updated RSLs, as appropriate.
The first source in the surface water hierarchy will be clarified in text & in Table 3-2 to indicate that surface water screening values were derived from the Alaska Water Quality Criteria Manual for Toxic & Other Deleterious Organic & Inorganic Substances, dated December 12, 2008.
3.2 Page 3-5 Please note that the pond freezes completely or almost completely during the winter & does not provide sufficient refuge for aquatic receptors to overwinter, with the possible exception of some benthic invertebrates. No fish or aquatic invertebrates have been observed in the pond. Temporary use of the pond for fish spawning is unlikely given the weir that is present, the steep incline & shallow depth of the downgradient drainage, & man-made barriers including culverts with significant drop-offs. Finally, observations during field investigations over multiple seasons indicate that the Area C Pond is not productive enough to support foraging by higher trophic level receptors on a regular basis.
Additional text reflecting the above field biologist observations will be added to text in Section 3.2.
3.4.1.4 Page 3-11 In February 2011, a determination of non-viable GW under 18 AAC 75.350 was requested for the Upper Site Summit, only, based on the extremely limited amount of GW present. Of the thirteen boreholes that were advanced to auger refusal at USS, only three encountered water. |
Louis Howard |
| 5/23/2012 |
Update or Other Action |
JBER Memorandum for Distribution signed by EPA, ADEC and JBER. RE: Revision of the Federal Facility Agreement Document Schedule for Nike Site Summit, lBER-Richardson.
1. Nike Site Summit was incorporated into the Joint Base Elmendorf-Richardson, Richardson
(JBER-R) Federal Facilities Agreement (FFA) on 1 June II. At that that time Federal and State FFA Project Managers, along with the U.S. Air Force (USAF) FFA Project Manager, established a schedule for primary and secondary documents under the FFA. However, delays with
document submittals, reviews, revisions and changes in personnel have resulted in a failure to
meet the original and revised schedules.
2. Schedule updates and/or modifications to the schedule require unanimous written agreement between the Project Managers. As such, the Project Managers are asked to review the attached revised document schedule for Nike Site Summit. Please indicate if you concur or non-concur with this request to modify the FF A document schedule for Nike Site Summit and sign the
enclosed agreement.
I. Project Managers agree to the proposed revision of the Nike Site Summit document schedule.
2. The revised document schedule will he included as an attachment to the FFA:
Document Type
Primary Draft FS 30, June 2012
Secondary Draft Proposed Plan 10 April 2013
Primary Draft Record of Decision 3 September 2013
3. This schedule may be updated or modified to include additional primary or secondary documents as necessary to meet FFA requirements.
Concur: Gary Fink JBER Alaska, Sandra Halstead US EPA, Louis Howard ADEC. |
Louis Howard |
| 5/29/2012 |
Update or Other Action |
Draft Feasibility Study received for NIKE Site Summit. Two of the six NSS areas (Area B & Area D) are recommended for No Further Action. GW, surface soil, &/or subsurface soil are impacted at one or more of the 4 impacted NSS areas. Based on the RAOs & PCLs developed for specific media at each area, General Response Actions (GRAs) were developed. For each GRA, remedial technologies & associated technology process options were developed & formulated into remedial alternatives. In summary, for some media & areas of NSS, PCLs differing from the PALs established for the RI were selected, for one of the following reasons:
• In cases where ERBCLs are more conservative (i.e., lower) than the cleanup levels from 18 AAC 75 (e.g., RRO & some PAHs), the ERBCLs were selected as PCLs for surface soil & used to develop remedial approaches that will protect ecological receptors.
• For the NSS areas that do not have GW resources (Area A & USS), the ADEC cleanup levels for migration to GW do not apply. The ADEC cleanup levels based on direct contact or outdoor inhalation were used for these areas. If these cleanup levels are not specified in 18 AAC 75, EPA RSLs or RBCLs were used.
• For metals in soil, background concentration will take precedence over other cleanup levels (ADEC concentrations, RSLs, & RBCLs/ERBCLs). Metals will not be proposed for cleanup to concentrations below background concentrations.
• For contaminants where laboratory LOQs are known to be higher than the corresponding regulatory value, RBCL, or ERBCL, the laboratory LOQ was selected as the PCL. This criterion may need to be revisited during future project phases, because laboratory LOQs can change as laboratory methods evolve.
Although GW is present at USS, it is only present in bedrock depressions that were created when USTs were installed. Because of its very limited extent, it is not considered a viable drinking water source and no PCLs are proposed for USS GW. ADEC has stated that human health exposure pathways for GW do not need to be assessed for USS. However, ADEC is concerned that subsurface contamination at USS may migrate and potentially impact surface water. These concerns were factored into development of PCLs and action areas for soil at USS.
However, PCLs for several constituents are lower and are based on more conservative exposure assumptions. For example, the PAL for RRO in soil was established as 10,000 mg/Kg, based on the ADEC cleanup level provided in Table B2 of 18 AAC 75, for an ingestion exposure pathway. The PCL for RRO in surface soil, however, is 120 mg/Kg, based on the calculated ERBCL for RRO in surface soil (USAF, 2012a). This lower PCL for RRO will protect ecological receptors potentially exposed to RRO in surface soil, while the PCL for RRO in subsurface soil will remain as 10,000 mg/Kg.
For areas of surface soil with metals, PHCs, or PAHs exceeding their respective PCLs (and background concentrations for metals), contamination was assumed to have a maximum vertical depth of 1 foot bgs due to the typically limited vertical mobility of these types of contaminants and the thin soil cover present over bedrock at USS. For areas with subsurface soil contamination exceeding PCLs, the depth was assumed to be the maximum depth to which PCLs were exceeded, and an area of 10 feet by 10 feet, centered on the soil sample location.
Before any remedial action is implemented at USS, additional lateral and vertical delineation should be completed to more precisely define the action areas. Additionally, post-remediation confirmation sampling would be completed to verify that contaminated soil has been adequately addressed.
See site file for additional information.
|
Louis Howard |
| 7/12/2012 |
Document, Report, or Work plan Review - other |
EPA Sandra Halstead reviewed & commented on the NIKE Site Summit Feasibility Study (FS). The FS does not include a figure that identifies the JBER boundaries in relation to Nike Site Summit (NSS) & the surrounding area. Section 1.2.2.1, Current & Future Site Use, states that the boundary of JBER in the vicinity of NSS is adjacent to that of Chugach State Park, a recreational area, which should also be shown on Figures 1-1 & 1-2. To support discussions of current site use at NSS & the surrounding area, please revise the FS to include a figure that delineates the JBER site boundaries. In addition, please include the boundaries of Chugach State Park on Figures 1-1 & 1-2.
It is acknowledged in several sections of the FS report (e.g., Section 5.3.3, Evaluation of LSS [Lower Site Summit] Soil & GW Action Areas, Section 6.3.2, Evaluation of Area A Action Areas, & Section 7.3.2, Evaluation of Area C Action Area) that the lateral & vertical extents of contamination are not well defined at several of the evaluation areas. In some cases, “Action Areas,” defined as areas that are targeted for remediation, were identified based on results from just 1 or 2 samples (Areas G, H, & K on Figure 4-1, Overview of USS Sample Locations & Action Areas).
This approach introduces considerable uncertainty in the determination of area & volume of site media that require remediation, as significant assumptions were used to define these areas for purposes of the FS. For example, Section 4.3.2, Evaluation of USS Action Areas, states, “For purposes of estimating the volume of contaminated media, areas with surface soil contamination were assumed to encompass an area of 10’ by 10’, centered on the surface soil sample location [which reported an exceedance of a proposed cleanup level (PCL)].”
The FS also states, in Section 5.3.3, in regards to the LSS, “Because of the uncertainties in delineation, the resulting area & volume estimates provided in Table 5-5 are uncertain, which will result in a similar degree of uncertainty in the cost estimates that are included for LSS remedial alternatives. Because these uncertainties apply to all evaluated remedial alternatives, the uncertain volumes of contaminated media should not adversely affect the conclusions of the FS.” This statement is unsupported as the volume estimates could significantly alter conclusions of the FS.
Containment was eliminated as a remedial alternative in the preliminary screening of alternatives (Table 3-3 Technology Screening Analysis for Soil); however, if the extent of contamination is significantly greater than is currently known, this alternative may require further consideration. Excavation & off-site disposal/treatment of soil may also become cost prohibitive should the volume of soil requiring remediation increase significantly. Prior to finalizing the FS, please consider collecting additional samples to further delineate the lateral & vertical extent of contamination at NSS so that volume estimates presented in the FS are supported by site data, & remedial alternatives which may be based on the volume or area of contamination can be properly evaluated in the FS.
Table 3-5, Contaminated Media by Area, indicates that GW at the USS is not considered for remediation since only “small quantities of groundwater [are] present in bedrock depressions. Table 3-6, Remedial Alternatives by Area, selects GW remedial alternatives to be evaluated at the USS. If GW will not be remediated, remedial alternatives need not be selected & evaluated for the USS. Please clarify the discrepancy between Table 3-5 & Table 3-6.
Monitored Natural Attenuation (MNA) is a component of several of the remedial alternatives evaluated in detail in this FS (Alternatives USS-2, USS-3, LSS-2, LSS-3, & ARA-2) yet the FS lacks any evaluation of the efficacy of this remedial alternative at reducing contaminant concentrations in soil & GW to acceptable levels. EPA’s MNA Directive clearly states, “Decisions to employ MNA as a remedy or remedy component should be thoroughly & adequately supported with site-specific characterization data & analysis.
In general, the level of site characterization necessary to support a comprehensive evaluation of MNA is more detailed than that needed to support active remediation.” The FS could provide evidence that MNA would be effective using the protocol outlined in USEPA’s Technical Protocol for Evaluating Natural Attenuation of Chlorinated Solvents in GW (September 1998, EPA/600/R-98/128) (MNA Guidance). Please revise the FS to include a thoroughly documented evaluation of the efficacy of MNA at the NSS in support of the detailed analysis of remedial alternatives. Please refer to the MNA Directive as well as the MNA Guidance & USEPA’s Monitored Natural Attenuation of Inorganic Contaminants in GW (October 2007, EPA/600/R-07/139) for additional information concerning evaluation of MNA. |
Louis Howard |
| 1/3/2013 |
Document, Report, or Work plan Review - other |
Staff reviewed and approved the Draft Final Feasibility Study Nike Site Summit JBER, Alaska Contract No. FA8903-08-D-8777, Task Order 0083 December 2012.
The Alaska Department of Environmental Conservation (ADEC) has received the document for review and comment on December 20, 2012. In accordance with 1994 Federal Facility Agreement, ADEC is approving the draft final version of the Feasibility Study for Nike Site Summit. ADEC has not identified any issues or comments concerning incorporation of JBER’s incorporation of responses to ADEC’s comments on the draft document. Pending any other comments by EPA, the document may be finalized.
|
Louis Howard |
| 1/10/2013 |
Document, Report, or Work plan Review - other |
EPA provided additional comments on the Final Nike Site Summit Feasibility Study.
EPA's comments have been addressed, including the additional items that were covered in our Response to comments discussion and at least clarifies some outstanding questions.
The Sparrevohn MNA discussion in the FS didn't provide any data, so I dug around and this is all I could find (with Louis' help in navigating the ADEC and Adminrec databases) and I've attached the only GW TCE monitoring graph I could find for that site. For comparison, the max conc. of TCE in GW at LSS was 0.017 mg/kg so about 2x the highest level seen at Sparrevohn.
(See attached file: sparrevohn MNA TCE graph.pdf)
I'm likely to send you the note early next week that we've approved the final but just need to confirm a couple of last questions in our Seattle office. I'm already thinking to the within EPA technical peer review that has to happen prior to the draft proposed plan (tentatively scheduled for mid-March) and how to respond to questions I know are coming about perchlorate in gw (it was not sampled for in GW - see table 2.1) and MNA efficacy. |
Louis Howard |
| 1/10/2013 |
Document, Report, or Work plan Review - other |
EPA comments on the draft final JBER responses to comments.
1) G4 Thank you for addressing the comparative remedy question. For consistency, please add a comparison table and discussion for Area C Pump House. This would be Table 7-5.
2) G8 please clarify if data from Sparrevohn LRRS will be discussed to represent MNA under similar latitude/altitude/geologic conditions
3) G15 please consider amending the sentence to read “State Acceptance. … State acceptance will be assessed after agency comments have been received on the Proposed plan." It currently states after agency "comments have been received on the FS".
4) S2/M8 first bullet. In the discussion on Nov 1, I recall MWH staff spoke of a cross section hydrologic groundwater divide diagram that could be produced to show the relative locations of Nike Site Area C and the Arctic Valley drinking water well. The text description provided does not provide confidence that there is no risk from drinking from a 20 ft deep well adjacent to a CERCLA site.
In the meeting minutes, I responded that I was unable to verify the statement by MWH that perchlorate had been analyzed in groundwater in LSS Missile Launch pad areas. I have been unable to find any data in the final RI, final Analytical Data Report, or this draft FS that perchlorate GW samples were analyzed.
• Perchlorate soil/subsoil sample results are presented in the final RI in Figure 6-10 Missile Launch Pad & Control Building but no results or discussion around perchlorate in GW.
• In the final ADR, perchlorate is listed in Table 1-5 Water Sample Data Summary, Remedial Field Investigation, pdf pages 381-396 for both groundwater and surface water samples as NA - not analyzed.
It will be important going into the proposed plan to clarify if perchlorate was sampled in groundwater, and if so, the analytical results. I predict it will be one of the first questions raised by the EPA review team in looking at the proposed plan for a former missile launching site. I was not involved in review of the earlier RI or ADR, but request that the perchlorate groundwater sampling and results be clarified in the FS before its finalized.
|
Louis Howard |
| 1/23/2013 |
Document, Report, or Work plan Review - other |
EPA provided comments and approval of the Draft Final Feasibility Study for Nike Site Summit, JBER, AK, December 2012.
EPA Region 10 has reviewed the draft final Nike Site Summit Feasibility Study, Joint Base Elmendorf-Richardson, Alaska, December 2012 which was received on 20 December 2012.
EPA approves the draft final version of the Feasibility Study but recommends additional lines of evidence for monitored natural attenuation (MNA) of TCE be provided in the narrative. In the draft final FS, Sparrevohn LRRS is presented as a site where MNA of TCE is under evaluation. An expanded discussion of the geochemical properties and TCE degradation in relation to conditions at Nike Site Summit would suffice to indirectly show the types of natural attenuation process likely to be active at the sites.
From OSWER Directive 9200.4-17 (1997)
In general, more supporting information may be required to demonstrate the efficacy of monitored natural attenuation at those sites with contaminants which do not readily degrade through biological processes (e.g., most non-petroleum compounds, inorganics), at sites with contaminants that transform into more toxic and/or mobile forms than the parent contaminant, or at sites where monitoring has been performed for a relatively short period of time.
The amount and type of information needed for such a demonstration will depend upon a number of site-specific factors, such as the size and nature of the contamination problem, the proximity of receptors and the potential risk to those receptors, and other physical characteristics of the environmental setting (e.g., hydrogeology, ground cover, or climatic conditions).
To address a data gap, perchlorate (using method 6860) and NDMA (N-Nitrosodimethylamine using method 521) must be analyzed in groundwater monitoring at Lower Site Summit until the Air Force, ADEC, and EPA project managers agree to remove it from the sampling regime. |
Louis Howard |
| 4/10/2013 |
Update or Other Action |
Draft Proposed Plan (PP) received for review & comment.
There are six areas at SS047 addressed within this PP:
Upper Site Summit (USS) – former battery control area, located at an elevation of 3,900’ above mean sea level (amsl), currently housing several commercial antenna installations.
Lower Site Summit (LSS) – former missile launch area, located at an elevation of about 3,100’ amsl.
Area A – Former Opportunity Strikes Radio Relay Station (RRS), a Former Borrow Area, & a Suspected Disposal Area are located at a slightly lower elevation (2,950’ amsl) than LSS.
Area B – High Explosive & Guided Missile Magazines, located about midway between LSS & USS, along the east side of the gravel road at an elevation of 3,200’ amsl.
Area C – Pump House, is the lowest elevation area of SS047 at 2,500’ amsl, off of Arctic Valley Road.
Area D – Former Borrow Area, at 3,200 feet above mean sea level, adjacent to LSS.
USS RAOs:
Prevent contact with soil with contaminant concentrations that exceed cleanup levels. The primary contaminants that exceeded these levels & contributed to human health (HH) risks were:
- Surface & subsurface soil: Benzo(a)pyrene, dibenz(a,h)anthracene, & arsenic.
Prevent exposure of ecological receptors to surface soil contaminants. The primary contaminants that exceeded cleanup levels & contributed to ecological receptor health risks were:
- Surface soil: RRO, cadmium, lead, benzo(b)fluoranthene, & pyrene.
Prevent soil contaminants that exceed migration-to-GW cleanup levels from impacting GW through leaching. The primary contaminants that exceed these levels were:
- DRO, barium, total chromium, silver, 4-chloroaniline, benzo(a)anthracene, benzene, & trichloroethylene (TCE).
LSS RAOs:
Prevent use of surface soil, subsurface soil, & GW with contaminant concentrations that exceed cleanup levels. The primary contaminants that exceeded these levels & contributed to HH risks were:
- Surface soil: Arsenic, pentachlorophenol, benzo(a)pyrene, & benzo(b)fluoranthene.
- Subsurface soil: 1,1,2-Trichloroethane, 1,2,3-trichloropropane, & 1,2-dibromo-3-chloropropane.
- GW: DRO, arsenic, vanadium, 2-methylnaphthalene, naphthalene, & TCE.
Prevent exposure of ecological receptors to surface soil contaminants. The primary contaminants that exceeded these levels & contributed to ecological receptor health risks were:
- Surface soil: RRO, cadmium, bis(2-ethylhexyl)phthalate, pentachlorophenol, benzo(a)pyrene,
benzo(b)fluoranthene,chrysene, & pyrene.
Prevent soil contamination that exceed migration-to-GW cleanup levels from impacting GW through leaching. The primary contaminants that exceeded these levels were:
- DRO, chromium, nickel, mercury, TCE, pentachlorophenol, 1,1,2,2-tetrachloroethane, 1,1,2 trichloroethane, 1,2,3-trichlorobenzene, 1,2,3-trichloropropane, 1,2-dibromo-3-chloropropane, 2-hexanone, benzene, benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, & dibenz(a,h)anthracene.
Area A RAOs:
Prevent contact of soil with contaminant concentrations that exceed cleanup levels. The primary contaminants that exceeded these levels & contributed to HH risks were:
- Surface & subsurface soil: DRO.
- Surface soil: RRO.
Prevent exposure of ecological receptors to Area A surface soil contaminants that exceed cleanup levels. The primary contaminant that exceeded these levels & contributed to ecological receptor health risks was:
- Surface soil: RRO.
Area C HH RAOs:
Prevent contact of soil with contaminant concentrations that exceed cleanup levels. The primary contaminant that exceeded these levels & contributed to HH risks was:
- Surface soil: Benzo(a)pyrene.
There were no potential ecological receptors at Area C; therefore, ecological RAOs are not necessary.
Preferred alternatives
USS – Alternative 3, Excavation & off-site treatment of surface soil & subsurface soil.
LSS – Alternative 2, Excavation & off-site treatment of surface soil, MNA for subsurface soil & GW along with LUCs.
Area A – Alternative 3, Excavation & off-site treatment of surface & subsurface soil.
Area B – No Action.
Area C – Alternative 2, Excavation & off-site treatment of surface soil.
Area D – No Action.
Based on the information currently available, the Air Force (AF), ADEC, and EPA believe the Preferred Alternatives meet the threshold criteria (Criteria 1 and 2) and provide the best balance of tradeoffs among the other alternatives with respect to the balancing and modifying criteria. |
Louis Howard |
| 5/9/2013 |
Document, Report, or Work plan Review - other |
EPA comments on the draft NSS Proposed Plan.
1. GW: it is unclear there is sufficient information about the GW pathway to support the conclusions of the FS & proposed plan, specifically:
a. Lack of data from the one existing water supply well at Arctic Valley or its immediate vicinity leave questions about whether the well or the source of water to it are contaminated or affected by contaminated soils at the higher-elevation USS & LSS areas of contamination. Reviewers recommended sampling the existing well at Arctic Valley & development of some Wells in the vicinity of Area C to address this question. In addition to the suite of compounds analyzed in the RI, perchlorate (using method SW6860) & NDMA (N-Nitrosodimethylamine ( using method SW521) should be analyzed in GW monitoring at LSS & Area C/Arctic Valley.
b. There is no evidence of NA at NSS given there are no detectable daughter products from releases that occurred 50+ years ago. The use of MNA at LSS should be fully evaluated. EPA believes it makes sense to require a soil & subsoil action, with no action for GW, & conduct GW monitoring to ensure the soil/subsoil removal was protective. Excavation of surface & subsurface soils as outlined in Alternative 3 directly reduces TMV & reduces the uncertainty of MNA for subsoil & GW remediation
2. The need for CERCLA-based action appears to be triggered for the LSS area based on human health & ecological risk from exposure to soils contaminated with hazardous substances, pollutants or contaminants & commingled petroleum products. The need for action also appears to be triggered for the USS area based on ecological risk from exposure to soils contaminated with hazardous substances, pollutants or contaminants & commingled petroleum products. Given the need for action under CERCLA, the preferred alternative & ultimately the selected remedy must be protective & comply with ARARs that pertain to the site, including promulgated State requirements that are more stringent. Some questions remain about whether site conditions & the current or reasonably anticipated future land use(s) support cleanup to the levels required for protection of GW for residential use.
3. No Action under CERCLA appears warranted for Areas A & C & thus ARARs are not triggered. However the State may have grounds to require non-CERCLA action(s) in one or both areas under State law (18 AAC 75) as discussed below:
a. the risks identified for Area A are within or below the CERCLA acceptable risk range for carcinogens & do not pose unacceptable noncarcinogenic risks from exposure to hazardous substances, pollutants, or contaminants except for petroleum products excluded from CERCLA authority except where they are commingled with CERCLA hazardous substances, pollutants or contaminants, or unless there are sensitive sub-populations or other reasons why a risk within the CERCLA 10-4 to 10-6 range is warranted. No such circumstances are readily apparent for Area A. Given the lack of basis for CERCLA action, the requirement for CERCLA remedial actions to comply with ARARs is not triggered, either.
b. the risks identified for Area C are also within or below the CERCLA acceptable risk range for carcinogens & do not pose unacceptable noncarcinogenic risks from exposure to hazardous substances, pollutants, or contaminants even for petroleum products excluded from CERCLA authority. Unless there are sensitive sub-populations or other reasons why action to address risks within the CERCLA 10-4 to 10-6 range would be warranted, no CERCLA action is warranted for Area C.
1. Pg. 2 of pdf, first paragraph: The date of the final FS is incorrect. Please change to February 2013.
2. In the narratives following the map, CSM, & Table for each area, the description concentrates on GW, even at areas where GW isn’t an issue. These narrative descriptions do not add much useful information to the accompanying tables. Consider adding narrative that describes the map, CSM, or contaminant table.
3. Page 5 of pdf, the USS narrative. Consider changing the term GW to saturated soils. If the term GW is maintained, consider adding a line in Table 1 with the media GW but signify no cleanup is required or recommended for this media.
4. Under the Battery Building photo, consider adding a caption that the Battery Building & Barracks were removed in 20xx (2012?)
5. Pgs 6 & 7 of the pdf: It would be more consistent if the paragraph & photo for LSS on page 8 could be moved to the bottom of page 6. It would require shrinking down the map & CSM for LSS.
6. Pg 8. If the LSS paragraph & photo move to pg 6, this would allow for Area A paragraph to accompany Figure 5 & Table 3 on page 8. See comment #5 regarding the content of the paragraph. |
Louis Howard |
| 6/5/2013 |
Document, Report, or Work plan Review - other |
ADEC has reviewed the RTCs for its comments and accepts the comment responses on the Nike Site Summit Proposed Plan |
Louis Howard |
| 6/6/2013 |
Update or Other Action |
Proposed Plan Remedial Action Objectives:
Upper Site Summit RAOs:
Prevent contact with soil with contaminant concentrations that exceed cleanup levels. The primary contaminants that exceeded these levels and contributed to USS human health risks were:
- Surface and subsurface soil: Benzo(a)pyrene, dibenz(a,h)anthracene, and arsenic.
Prevent exposure of ecological receptors to USS surface soil contaminants. The primary contaminants that exceeded cleanup levels and contributed to USS ecological receptor health risks were:
- Surface soil: RRO, cadmium, lead, benzo(b)fluoranthene, and pyrene.
Prevent soil contaminants that exceed migration-to-groundwater cleanup levels from impacting groundwater through leaching. The primary contaminants that exceed these levels were:
- DRO, barium, total chromium, silver, 4-chloroaniline, benzo(a)anthracene, benzene, and trichloroethylene (TCE).
Lower Site Summit RAOs:
Prevent use of surface soil, subsurface soil, and groundwater with contaminant concentrations that exceed cleanup levels. The primary contaminants that exceeded these levels and contributed to LSS human health risks were:
- Surface soil: Arsenic, pentachlorophenol, benzo(a)pyrene, and benzo(b)fluoranthene.
- Subsurface soil: 1,1,2-Trichloroethane, 1,2,3-trichloropropane, and 1,2-dibromo-3-chloropropane.
- Groundwater: DRO, arsenic, vanadium, 2-methylnaphthalene, naphthalene, and TCE.
Prevent exposure of ecological receptors to LSS surface soil contaminants. The primary contaminants that exceeded these levels and contributed to LSS ecological receptor health risks were:
- Surface soil: RRO, cadmium, bis(2-ethylhexyl)phthalate, pentachlorophenol, benzo(a)pyrene,
benzo(b)fluoranthene,chrysene, and pyrene.
Prevent soil contamination that exceed migration-to-groundwater cleanup levels from impacting groundwater through leaching. The primary contaminants that exceeded these levels were:
- DRO, chromium, nickel, mercury, TCE, pentachlorophenol, 1,1,2,2-tetrachloroethane, 1,1,2 trichloroethane, 1,2,3-trichlorobenzene, 1,2,3-trichloropropane, 1,2-dibromo-3-chloropropane, 2-hexanone, benzene, benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, and dibenz(a,h)anthracene.
Area A RAOs:
Prevent contact of soil with contaminant concentrations that exceed cleanup levels. The primary contaminants that exceeded these levels and contributed to Area A human health risks were:
- Surface and subsurface soil: DRO.
- Surface soil: RRO.
Prevent exposure of ecological receptors to Area A surface soil contaminants that exceed cleanup levels. The primary contaminant that exceeded these levels and contributed to Area A ecological receptor health risks was:
- Surface soil: RRO.
Area C Human Health RAOs:
Prevent contact of soil with contaminant concentrations that exceed cleanup levels. The primary contaminant that exceeded these levels and contributed to Area C human health risks was:
- Surface soil: Benzo(a)pyrene.
There were no potential ecological receptors at Area C; therefore, ecological RAOs are not necessary.
|
Louis Howard |
| 6/27/2013 |
Cleanup Level(s) Approved |
JBER Memorandum signed by JBER, EPA and ADEC project managers.
Proposed Cleanup Levels Set To Limit of Quantitation for Select Analytes at SS047 (Nike Site Summit)
1. The Air Force formally requests concurrence from the State of Alaska Department of Environmental Conservation (ADEC) and United States Environmental Protection Agency (USEPA) in establishing proposed cleanup levels (PCLs) in the Nike Site Summit (NSS) Feasibility Study (FS), Joint Base Elmendorf-Richardson (JBER), Alaska. As agreed to at the December 7, 2012 Remedial Project Manager's (RPM) meeting, we propose setting the PCL equal to the laboratory-achievable limit of quantitation (LOQ) for select analytes where they exceed the initial project action limit (PAL).
2. P ALs for soil were initially based on Title 18 Alaska Administrative Code (AAC) Chapter 75, Table B 1, Method Two, Soil Cleanup Levels. When no soil cleanup value existed under ADEC, USEPA Region 9 Soil Screening Levels (SSLs) for Migration to Groundwater, Dilution Attenuation Factor (OAF) 20 (Region 9 Preliminary Remediation Goals (PRG) Table, October 2004) were used. For soil, a total of 15 volatile organic compounds (VOCs) and 18 semi-volatile organic compounds (SVOCs) had L0Qs greater than their respective PAL.
3. PALs for groundwater were based OD 18 AAC 75, Table C, Groundwater Cleanup Levels. When DO groundwater cleanup value existed under ADEC, USEPA Region 9 PRGs for Tap Water (Region 9 PRG Table, October 2004) were used. For groundwater, a total of 4 VOCs and 19 SVOCs had L0Qs greater than their respective PALs.
4. The Triad-approved Uniform Federal Policy (UFP) Quality Assurance Project Plan (QAPP), for the NSS Remedial Investigation and Feasibility Study (RllFS), addressed and highlighted the analytes where the L0Q achievable by the standard laboratory methods were above the PAL. Those analytes were presented in Worksheet #1 S of the UFP-QAPP as either bold text and/or shaded cells.
5. For soil, the use of methanol as a field preservative for VOCs (Method SW8260), as prescribed by ADEC-approved laboratory methodology, limits the achievable detection limit thus the subsequent L0Q is greater than the PAL in several instances. Also, Method SW8260 for VOCs in groundwater and Method SW8270 for SVOCs in both soil and groundwater results in L0Qs greater than their respective P ALs in several occurrences. The project laboratory (SGS Laboratory Services) LOQs were vetted against similar ADEC-approved laboratories and found to be consistent in their relative LOQs versus the PALs.
6. ADEC has the authority, under 18 AAC 75.340(h)(2), to establish a less stringent soil cleanup level if the practical quantitation limit (i.e., LOQ) for the hazardous substance exceeds the applicable cleanup level set out in 18 AAC 75.341 for that substance.
7. During the Baseline Risk Assessment, conducted as a part of the RI, only 2 VOCs and 2 SVOCs in the soils at Nike Site Summit were found to have concentrations above the P ALs. These analytes have WQs greater than their respective PAL and are considered contaminants of concern (CoCs). None of the analytes in groundwater were found to exceed ADEC's risk criteria; therefore, they were not identified as CoCs.
8. The Air Force requests ADEC and USEPA's conCUJTCDce to set the laboratory-achievable LOQ, at the time of the 2010 Rl/FS, as the PCL for the CoCs listed in Table 1.
Lower Site Summit VOCs
1,2,3-Trichloropropane 96-18-4 LOQ 0.001 mg/kg, ADEC MGW 0.00053 mg/kg, USEPA Reg 9 2004 SSL MGW N/A, USEPA Reg 9 SSL Protection of GW 0.00000028 mg/kg.
1,2-Dibromo-3-chloropropane 96-12-8 LOQ 0.002 mg/kg, ADEC MGW N/A, USEPA Reg 9 2004 SSL MGW N/A, USEPA Reg 9 SSL Protection of GW 0.00000014 mg/kg
SVOCs
Upper Site Summit
4-Chloroaniline 106-47-8 LOQ 0.25 mg/kg, ADEC MGW 0.057 mg/kg, USEPA Reg 9 2004 SSL MGW 0.7 mg/kg, USEPA Reg 9 SSL Protection of GW 0.00013 mg/kg
Lower Site Summit
Pentachlorophenol 87-86-5 LOQ 2 mg/kg, ADEC MGW 0.047 mg/kg, USEPA Reg 9 2004 SSL MGW 0.03 mg/kg, USEPA Reg 9 SSL Protection of GW 0.00036 mg/kg.
Signed by Gary Fink Chief, Environmental Restoration, Sandra Halstead, Fed. Fac. Project Mgr. USEPA, and Louis Howard CS Project Mgr. ADEC on June 27, 2013. |
Louis Howard |
| 8/30/2013 |
Update or Other Action |
Email message from JBER Gary Fink: I am requesting a revision to the FFA schedule for Nike Site due to contract delays in the submission of the draft ROD. I am proposing a date of 13 Nov 2013, however, I do anticipate a deliverable before then. If this is acceptable to you please let me know and I will submit a formal schedule for your signature.
ADEC response: ADEC concurs with the proposed extension (November 13, 2013) to the schedule for Nike Site Summit submission of the draft Record of Decision (ROD), a primary document as found in the 1994 Federal Facility Agreement |
Louis Howard |
| 9/4/2013 |
Update or Other Action |
ADEC, AFEC & EPA signed off on revised schedule for documents under the FFA. See site file for additional information. |
Louis Howard |
| 11/6/2013 |
Update or Other Action |
Nike Site Summit Draft ROD received for review & comment.
CERCLA hazardous substances have been identified as contaminants of concern (COCs) in three areas of SS047: soil at Upper Site Summit (USS), soil & groundwater at Lower Site Summit (LSS), & surface soil at Area C. Areas within LSS at SS047 cannot support unlimited use & unrestricted exposure due to hazardous substances & contaminants remaining in place above cleanup levels after implementation of the selected remedies.
Land use restrictions are required as part of this response action & will be achieved through imposition of land use controls (LUCs) that limit the use &/or exposure to those areas of the property, including water resources, that are contaminated. The response actions selected in this decision document for USS, LSS, Area A, & Area C are necessary to protect public health or welfare & the environment from releases of hazardous substances into the environment. USS & LSS have mixed CERCLA & petroleum constituents, so these sites will be addressed under CERCLA, which will integrate the Alaska State Regulations into the Air Force’s CERCLA response so that all COCs are cleaned up under the CERCLA response action.
DESCRIPTION OF SELECTED REMEDY
Remedial alternatives for SS047 were developed & evaluated through a Feasibility Study (FS). Based on the results of the FS, the Air Force selected:
USS. Excavation & off-site treatment & disposal of surface & subsurface soil at USS. All surface & subsurface soil with contamination exceeding cleanup levels will be excavated. As groundwater at USS is limited to pockets on top of subsurface bedrock depressions, any groundwater present in the excavations would be removed through dewatering at the time of excavation. Approximately 1,062.3 cubic yards of soil would be removed from the site & treated at an off-site treatment facility.
The RAOs for USS are:
Prevent unrestricted contact with and use of surface and subsurface soil with contaminant
concentrations that exceed cleanup.
Prevent exposure of ecological receptors to USS surface soil contaminants.
Prevent soil concentrations that remain in place from posing a threat to groundwater
through soil (surface and/or subsurface) leachability, by exceeding cleanup levels.
These RAOs were developed based on the currently and reasonably anticipated future
commercial/industrial land use.
LSS. Excavation & off-site treatment & disposal of surface soil with LUCs for subsurface soil & groundwater monitoring (GWM) at LSS. Surface soil with contamination exceeding cleanup levels will be excavated. Subsurface soil & groundwater contamination will remain in place & be addressed by monitored natural attenuation (MNA). A monitoring program will be implemented to verify & document changes in COC concentrations. LUCs will be implemented to prevent potential human exposures to contaminants in the subsurface.
A total of 220 cubic yards of impacted soil would be excavated & treated at an off-site treatment facility. LUCs. Excavation of soil is restricted at this site. Soil use restrictions will be maintained at LSS until RAOs are met. Soil remains on-site at concentrations greater than allowed for unrestricted use. The use of groundwater at this site, for any reason, is prohibited. Groundwater use restrictions will also be maintained at LSS until RAOs are met.
Pursuant to Air Force & ADEC policy, because the selected remedy, which at completion will retain onsite hazardous substance levels that will not allow for unlimited use & unrestricted exposure, will not attain this result within 5 years of the remedy construction complete, a policy review will be required within 5 years after initiation of the remedial action to verify that the remedy is, or will be, protective of human health & the environment at LSS. The approval & signature of this ROD will signify the initiation of remedial action. Five-Year Reviews will be conducted until concentrations of hazardous substances, pollutants, or contaminants remaining onsite are reduced to levels that allow for unlimited use & unrestricted exposure.
Area A. Excavation & off-site treatment & disposal of surface & subsurface soil at Area A. All surface & subsurface soil with contamination exceeding cleanup levels will be excavated down to bedrock. The estimated volume is about 500 cubic yards, which will be hauled to an off-site treatment facility.
Area B. No Action at Area B.
Area C. Excavation & off-site treatment & disposal of surface soil at Area C. Surface soil with contamination exceeding cleanup levels will be excavated. An estimated 4 cubic yards will be removed & hauled to an off-site treatment facility.
Area D. No Action at Area D. |
Louis Howard |
| 1/6/2014 |
Document, Report, or Work plan Review - other |
EPA comments on draft ROD for NIKE Site Summit.
Petroleum-only contaminated areas (Area A) &/ or those areas that do not trigger CERCLA risk (Areas A & C) mimic & reference CERCLA decision document format. The Air Force has stated it would like to retain these subareas in the ROD document. Please delete all references to CERCLA & clarify cleanup at Area A & Area C are based on state regulations. Make sure this part of the document, if retained in the ROD, satisfies the decision document components for ADEC petroleum-based cleanups.
Suggested language for the introductory & selected remedy portions of Areas A & C:
1) The no action alternative IS protective at such sites that already meet the CERCLA/NCP risk limits/range. [Currently, no action for each site is described as not protective.]
2) Under CERCLA we are selecting no action. The selected remedy is no action under CERCLA but alternative xxx was chosen to satisfy the AK state regulations.
Similar issues exist for any of the petroleum-only action areas at USS & LSS (example, LSS action areas C & M) where petroleum is not commingled with CERCLA contaminants. If the requirements to delineate the petroleum actions under state authority are not met (ie… declaring the petroleum areas are not part of the CERCLA action), then offsite disposal rule for CERCLA response actions will apply.
EPA Off-Site Rule Fact Sheet
The signature pages will also need to be modified to reflect this also. EPA will be cosigning on the CERCLA remedies at USS & LSS & the No Further Action decisions at Area B & D only. ADEC will concur on the CERCLA decisions at USS & LSS & jointly? selecting the remedies at Areas A & C under state regulations.
From EPA comments on the draft Proposed Plan, submitted April 2013
No Action under CERCLA appears warranted for Areas A & C & thus ARARs are not triggered. However the State may have grounds to require non-CERCLA action(s) in one or both areas under State law (18 AAC 75) as discussed below:
a. the risks identified for Area A are within or below the CERCLA acceptable risk range for carcinogens & do not pose unacceptable noncarcinogenic risks from exposure to hazardous substances, pollutants, or contaminants except for petroleum products excluded from CERCLA authority except where they are commingled with CERCLA hazardous substances, pollutants or contaminants, or unless there are sensitive sub-populations or other reasons why a risk within the CERCLA 10-4 to 10-6 range is warranted. No such circumstances are readily apparent for Area A. Given the lack of basis for CERCLA action, the requirement for CERCLA remedial actions to comply with ARARs is not triggered, either.
b. the risks identified for Area C are also within or below the CERCLA acceptable risk range for carcinogens & do not pose unacceptable noncarcinogenic risks from exposure to hazardous substances, pollutants, or contaminants even for petroleum products excluded from CERCLA authority. Unless there are sensitive sub-populations or other reasons why action to address risks within the CERCLA 10-4 to 10-6 range would be warranted, no CERCLA action is warranted for Area C
Five Year Reviews are treated for each of the 6 subareas separately. The draft ROD suggests a Five Year Review will be necessary only at LSS, where hazardous substances remain in subsoils & GW. All other areas will be remediated below cleanup standards (USS, Area A, Area C) or are no further action (Area B & D). Five Year reviews are done on an OU level, & so it subjects USS to review along with LSS.
Please establish timelines for RD/RA for USS & LSS. The FFA spells out deadlines for submitting target dates for RD/RA documents in Section 24.2
EPA requested the AF drop the term MNA for GW remediation & refer to this portion of the remedies as GW monitoring. The final proposed plan reflects this change. The draft ROD reverts back to the use of MNA in subsoils & GW. No evidence for MNA in subsoils or GW was presented in the RI/FS or the ROD.
Metals are a known challenge for MNA. Organics are likely to be a challenge due to the setting & climate of the site.
Please change the remedy from MNA to GW monitoring as was done in the final Proposed Plan.
The term Project Action Levels is used throughout the document & this does not follow CERCLA terminology.
RODs have Cleanup Levels & Remedial Action Objectives. The document references both of these terms, but additionally uses terms like Project Action Levels, cleanup goals (see example on §2.6.3). |
Louis Howard |
| 4/15/2014 |
Meeting or Teleconference Held |
Informal dispute meeting held at EPA. Deb Yamamota confirms to Kevin Thomas (AFCEC CFPA) that EPA, the Air Force and the State of Alaska agreed during the (4/15/2014) meeting to toll the date for declaring formal dispute from April 21, 2014 (the date at which formal dispute would otherwise be declared), until June 20, 2014 so that we can continue to work through the issues and reach agreement on final language for the ROD. The parties have agreed to hold the next informal dispute resolution meeting on April 23, 2014 starting at 9:30 am. |
Louis Howard |
| 4/23/2014 |
Meeting or Teleconference Held |
Meeting notes from informal dispute meeting at EPA for SS047.
1. PARTICIPATION: Participants in attendance over the telephone included the following:
• Donna Baumler, JBER/Air Force Civil Engineer Center (AFCEC)
• Chris Cora, U.S. Environmental Protection Agency (USEPA)
• Jennifer Currie, Alaska Department of Environmental Conservation (ADEC)
• Gary Fink, JBER/AFCEC
• Sandy Halstead, USEPA
• John Halverson, ADEC
• Louis Howard, ADEC
• Steve Lufkin, AFLOA/JACE
• Neil Robertson, MWH
• Tim Sueltenfuss, SMITH/Associates
• Kevin Thomas, AFCEC
• Kristen Villarreal, SMITH/Associates
• Ted Yaculuk, USEPA
• Deb Yamamoto, USEPA
• Michael Zidek, MWH
2. MEETING PURPOSE
a. Follow-up to the initial Response to Comments (RTC) meeting on 15 April 2014.
3. ACTION ITEMS
a. The group determined five new action items.
• Action Item No. 1 is to obtain clarification from USEPA HQ concerning the manner by which ground water should be classified at Lower Site Summit (LSS) to determine which cleanup levels apply. This item is assigned to USEPA (C. Cora) with a due date of 7 May 2014.
• Action Item No. 2 is to document an agreement in principle on the remedy for SS047. This item is assigned to all parties with a due date of 21 June 2014.
• Action Item No. 3 is to seek guidance from USEPA HQ on potential latitude concerning LUC language for interim (vice final) RODs. This item was assigned to US EPA (S. Halstead) with a due date of 2 May 2014.
• Action Item No. 4 is to seek guidance from USAF concerning USEPA’s proposed LUC language and determine potential latitude concerning LUC language employed in interim (vice final) RODs. This item is assigned to the USAF (S. Lufkin) with a due date of 15 May 2014.
• Action Item No. 5 is to propose a revised FFA schedule for document deliveries. This item was assigned to USAF (G. Fink) with a due date to be determined.
4. DECISION POINTS
a. The group approved two new decision points.
• USAF will prepare a draft interim ROD for SS047. USAF will conduct final action for soils consisting of source removal. USAF will conduct interim action for GW consisting of ICs and monitoring.
• USAF will develop a State decision document for petroleum-only sites at SS047. Sites A and C will be listed as No Action Remedy under CERCLA within the ROD.
|
Louis Howard |
| 4/25/2014 |
Update or Other Action |
EPA (S. Halstead) email to AFCEC/AF (S. Lufkin). Attached is language from a Travis AFB ROD on which the EPA & the AF have agreed, as of yesterday's negotiations, for checklist items 14 & 17..
Hopefully this is easily modifiable for the Nike ROD & JBER internal procedures to ensure LUCs are implemented.
The question on how LUCs might be modified based on an interim ROD was referred to some folks in HQ & I expect to hear an answer sometime next week, however the resolution on these two may have made that a moot point.
If there are additional questions, I can send them up the chain to Jyl et. al. in EPA HQ.
14. Travis Air Force Base (AFB) shall not modify or terminate LUCs, implementation actions, or land use that are associated with the selected remedy without the approval of EPA & the opportunity for concurrence by the State. Travis AFB shall seek prior concurrence of EPA & the State before any anticipated action that may disrupt the effectiveness of the LUCs or any action that may alter or negate the need for LUCs.
17. The internal procedures that Travis Air Force Base will use to implement the LUCs include but are not limited to the following:
A. Base General Plan (BGP) & Geographical Information System (GIS): The BGP is the Travis Air Force Base comprehensive plan for developing & using all available base land & water resources, & classifying allowable uses of those resources as well as constraints to uses such as environmental ones. Travis AFB shall record environmental contamination locations & environmental resource use constraints in this plan. The GIS is an integrated system designed to capture, store, manipulate, analyze, manage, & present all types of spatial data for informing decision-making on base resource uses. Resource use constraints occasioned by environmental contamination will similarly be recorded in this system.
B. Base Environmental Impact Analysis Process (EIAP): The EIAP is used to assess the potential environmental impacts of proposed actions & projects at Travis AFB in accordance with the National Environmental Policy Act. The EIAP includes ensuring consideration of & compliance with environmental use & exposure constraints on the property.
C. Base construction review & siting process: An Air Force Form 332, Base Civil Engineering Work Request, must be submitted & approved before the start of any construction project at Travis AFB. Approval of this form requires the comparison of the proposed construction site with the constraints of the BGP & GIS, to include use & exposure restraints due to environmental contamination. This ensures the proposed action is compatible with the current & future land use for the project area & ensures steps are taken to address potential contaminant exposure.
D. Base dig permit system: An Air Force Test Center Form 5926, Travis AFB Work Clearance Request, is required for any project that involves mechanical soil excavation or drilling. Approval of this form again requires comparison of the proposed site location with the environmental use & exposure constraints in the BGP & GIS. This ensures the proposed action is compatible with the current & future land use for the project area & ensures steps are taken to address potential contaminant exposure.
E. Base well permitting system: A Travis AFB Work Clearance Request is required for GW wells, to include monitoring & extraction wells. See requirements listed under D, above.
The Air Force will notify EPA in advance of any changes to internal procedures associated with the selected remedy that might affect the LUCs.
|
Louis Howard |
| 5/20/2014 |
Meeting or Teleconference Held |
Meeting minutes from May 20, 2014 SS047 informal dispute meeting at EPA.
1. PARTICIPATION: The meeting was conducted via audio conference and Adobe Connect. Participants in attendance included the following:
• Donna Baumler – JBER/Air Force Civil Engineer Center (AFCEC)
• Laura Christ – SMITH/Associates
• Jennifer Currie – Alaska Department of Environmental Conservation (ADEC)
• Gary Fink – AFCEC
• Eric Grill – SMITH/Associates
• John Halverson – ADEC
• Sandy Halstead – U.S. Environmental Protection Agency, Region 10 (US EPA Region 10)
• Louis Howard – ADEC
• Steve Lufkin – Air Force Legal Operations Agency (AFLOA)
• Doug Quist – MWH Global
• Neil Robertson – MWH Global
• Tim Sueltenfuss – SMITH/Associates
• Kevin Thomas – AFCEC
• Ted Yakulic – US EPA Region 10
• Deb Yamamoto – US EPA Region 10
2. ADMINISTRATIVE (Action Items):
a. OLD Action Items (Mr. Sueltenfuss/Ms. Christ): The attendees reviewed action items from the 23 April 2014 Decision Tracker.
• Action Items No. 1, 3 and 4 were closed.
• Action Item No. 2 remains open with a new due date of 21 June 2014.
• Action Item No. 5 remains open with a new due date to be determined.
b. NEW Action Items (Mr. Sueltenfuss/Ms. Christ): The attendees agreed to add new action items No. 6, 7 and 8 to the Open Action Items list.
• Action Item No. 6 was subsequentially closed.
3. DECISION POINTS: The attendees reviewed Pending, New and Approved Decision
Points.
• Pending Decision Point No. 1 was withdrawn.
• Pending Decision Point No. 2 was approved.
• New Decision Points No. 3, 4, 5 and 6 were approved.
4. 1100: Meeting Concluded.
5. The most recent version of the Action and Decision Tracker is included as Attachment 1 of this document.
|
Louis Howard |
| 5/27/2014 |
Update or Other Action |
SS047 USS and Areas A and C CoCs and cleanup levels For SS047 Upper Site Summit and Areas A and C, the CoCs and cleanup levels proposed by USAF in the 20 May 2014 conference call are acceptable. The CoCs and cleanup levels for the Lower Site Summit are still pending a drinking water determination. 20-May-14 JBER Teleconference on Nike Site Pending Team Review
Interim ROD for SS047 USAF will prepare an interim ROD to document the final remedy for soils at Upper Site Summit and Lower Site Summit and the interim remedy for groundwater at Lower Site Summit. 20-May-14 JBER Teleconference on Nike Site Pending Team Review
A Proposed Plan will be issued before the final ROD and the public will have the opportunity to comment on this Proposed Plan. 20-May-14 JBER Teleconference on Nike Site Pending Team Review
Final ROD for SS047 USAF will prepare a final ROD once the final remedy for groundwater has been selected for SS047 (Nike Site Summit). 20-May-14 JBER Teleconference on Nike Site Pending Team Review
|
Louis Howard |
| 5/28/2014 |
Update or Other Action |
Air Force submits NSS Tech Memo for review.
As agreed to at the 20 May 14 Nike Site Summit meeting, I am submitting documentation to support the Air Force's position that the groundwater at Lower Site Summit (LSS) be classified as Class IIIA under the EPA Groundwater Classification System. The data demonstrate a discontinuous groundwater source limited to the southeast corner of the gravel pad at LSS. Based on well
development at the site, it is unlikely that the groundwater entrained within the gravel pad area has sufficient yield to be classified as a drinking water source as defined in EPA classification.
Request your review of the attached technical memorandum and a response on the final determination of the classification of groundwater at LSS.
This submittal closes out action item #6 per the JBER decision tracker.
Thanks,
Gary
GARY FINK, GS-13
Chief, JBER Environmental Restoration
DSN 317 384-1824
Comm 907 384-1824
|
Louis Howard |
| 6/16/2014 |
Update or Other Action |
EPA Region 10 Hydrogeologist (M. Knadle) letter to EPA RPM for JBER (S. Halstead): Support for GW insufficiency determination at Lower Site Summit (Nike Site Summit) JBER.
On June 5, 2014, fellow OEA hydrogeologist Kwasi Boateng & I visited the area of the Nike Site Summit as part of a larger tour of Joint Base Elmendorf-Richardson (JBER). We were accompanied by EPA RPM Sandra Halstead, ADEC RPM Louis Howard, & several JBER environmental staff, including Gary Fink.
Because of an issue with keys, we were unable to visit the actual summit, but we were able to drive up to the end of the road along Unnamed Creek & could look up the slope to the Lower Site Summit. Thus, we could see the slope where groundwater would either discharge through seeps or flow in the shallow subsurface toward Unnamed Creek.
We have also reviewed the May 23, 2014 Technical Memorandum to Gary Fink from MWH "Groundwater Determination at Lower Site Summit, Joint Base Elmendorf-Richardson, Alaska Site SS047, Nike Site Summit (NSS)." This tech memo provides information about seven monitoring wells that were installed at the site in August/September 2010. Only one of the wells encountered groundwater before encountering bedrock materials. MWH interprets the results to indicate that groundwater at the site is limited in volume & mainly within the small gravel pad that was placed over the native terrain.
Both Kwasi Boateng & I have concluded that there is insufficient water for year-round use at the site for several reasons:
• The site is situated on a hillside just below a mountain hilltop, so any water downgradient of the gravel pad would be restricted to a thin zone of fractured bedrock above more competent (less fractured) bedrock.
• The water table is shallow & the water column is thin (not much thicker than the gravel pad), so the volume of water in the aquifer is very limited.
• The wells installed at the site produced at most 0.28 gallons per minute during sampling, which is 408 gallons per day (gpd). However, it's unlikely this flow rate could have been sustained since few of the other wells came close to this production rate & several wells purged dry, reinforcing the conclusion that the aquifer is of very limited extent.
• The aquifer is too limited to support year-round use at a rate of 150 gpd (EPA's definition of sufficient groundwater for use as a drinking water source) before becoming drained, since storage is mostly limited to the gravel pad recharge is limited to snowmelt & precipitation in the very small summit area catchment.
Discharge from the aquifer follows a very steep slope extending down to Unnamed Creek, where any groundwater that didn’t discharge from seeps along the slope would mostly or entirely discharge to Unnamed Creek. If there are any impacts, they should show up in Unnamed Creek below the slope. Concentrations at LSS were low enough that we would not expect elevated concentrations to be detected anywhere in Unnamed Creek.
We conclude that the aquifer is not usable as a drinking water source because it would not produce enough water year round. We also conclude that any contamination migrating from the site would be at a slow enough rate that it would not impact Unnamed Creek or any aquifer below the creek.
NOTE to file: EPA's decision is equivalent to ADEC 18 AAC 75.350 determination regarding groundwater not being suitable for drinking water. |
Louis Howard |
| 6/26/2014 |
Update or Other Action |
Draft informal dispute memo sent by AF to EPA.
Purpose: Document agreements reached during informal dispute resolution for SS047 Nike Site Summit, Joint Base Elmendorf-Richardson (JBER), AK.
Background: US EPA Region 10 (EPA) and the Alaska Department of Environmental Conservation (ADEC) invoked informal dispute regarding the Draft Final Record of Decision (DF ROD) for SS047 (19 Mar 2014). Informal dispute was invoked during a 15 April 2014 meeting between the Air Force (AF) (represented by Kevin Thomas, Gary Fink, Donna Baumler and Steven Lufkin), EPA (represented by Deb Yamamoto, Sandra Halstead and Ted Yackulik) and ADEC (represented by John Halverson, Louis Howard and Jennifer Currie) in accordance with Part XXI of the Fort Richardson Federal Facilities Agreement (FFA) dated 5 Dec 1994. Issues in dispute were:
1) Upper Site Summit (USS) Groundwater Remedy. EPA and ADEC do not believe the proposed remedy complies with the Applicable or Relevant and Appropriate Requirements (ARARs). Specifically, the agencies are concerned the AF is not adequately addressing groundwater at USS.
2) Lower Site Summit (LSS) Groundwater Remedy. EPA and ADEC do not believe the proposed remedy complies with the Applicable or Relevant and Appropriate Requirements (ARARs). Specifically, the agencies are concerned that the AF is not adequately addressing groundwater at LSS. The AF proposed monitoring of metals in groundwater, but monitoring isn’t a remedy and will not lead to groundwater meeting cleanup standards.
3) Land Use Controls (LUCs). The DF ROD does not incorporate complete language from EPA’s Federal Facility Land Use Control ROD Checklist with Suggested Language (LUC Checklist) per OSWER Directive 9355.6-12.
4) Petroleum Only Areas. The DF ROD includes remedies for petroleum only areas A and C.
Resolution: The agencies met on 15 April, 23 April, 20 May and 18 June to resolve the dispute. The decision points below hereby document the agreements between the agencies and resolve the informal dispute.
1) The agencies agree that the groundwater pathway is not complete at USS. Subsurface water at USS will not be classified as groundwater and will be referred to as “pit” water. Cleanup levels for soils at USS will be based on 18 AAC 75, Table B1 and B2 Method Two-direct contact (under 40” zone).
2) The AF will develop a groundwater basin transport model at LSS utilizing the existing well at Arctic Valley as a baseline condition. Information from the MWH Technical Memorandum dated 23 May 2014 and the groundwater basin transport model, as well as evaluation of new alternatives, will be incorporated into a Supplemental Feasibility Study (SFS).
3) Following review and approval of the SFS by EPA and ADEC, the cleanup levels for soils at LSS will be based on 18 AAC 75, Table B1 and B2 Method Two-direct contact (under 40” zone).
4) The AF and EPA agree to use the LUC language contained in the 24 April 2014 e-mail from Mr Gerald Pease (SAF/IEE) to Mr Reggie Cheatham, Director, FFRRO.
5) The Air Force agrees to remove the petroleum only areas from the ROD for SS047. This will be done by listing a No Action Remedy under CERCLA for Areas A and C. The AF will prepare a petroleum-only decision document under the ADEC contaminated sites program for these areas.
6) The remedy for Subaction Area Q (LSS) and Subaction Area K (USS) will be evaluated in the SFS and submitted for public review and comment during the proposed plan phase.
7) The AF will prepare a new Proposed Plan and ROD.
8) The FFA schedule will be updated following the AF’s award of a contract to prepare the SFS, PP and ROD. The updated schedule will be coordinated with EPA and ADEC as required by the FFA.
|
Louis Howard |
| 6/26/2014 |
Meeting or Teleconference Held |
Meeting summary from Air Force to EPA.
We (see attached list) met with AWWU and the Municipality of Anchorage Watershed Management to discuss our remedial actions at Nike site. We presented background information on the contaminants, the affected media and the hydro geologic conditions at the site. We explained our intent to perform fate and transport modeling to evaluate Nike's hydraulic connectivity to the Ship Creek watershed. Based on the site parameters it is highly unlikely to have any effect but we need to demonstrate that conclusion and document the results in the administrative record.
AWWU does not model groundwater in the area so the notion of inputting our site conditions into their existing model is not an option. However, MOA Watershed Management does have a watershed model that includes the Ship Creek drainage area. We discussed the model and concluded that using the model's site boundary conditions and input parameters from the Alpenglow well we could potentially determine Nike's contribution based on standard mass balance. Again, it is expected to negligible if it can be quantified at all. The model is available for our use and MWH will look at it to see if it will suit our needs.
Thanks for hooking us up with these folks and we'll keep you posted on developments.
Have a great weekend,
Gary
GARY FINK, GS-13
Chief, JBER Environmental Restoration
DSN 317 384-1824
Comm 907 384-1824
|
Louis Howard |
| 7/29/2014 |
Update or Other Action |
Part I of II
Final signed informal dispute resolution memo for Nike Site Summit.
Purpose: This document records the agreements reached during informal dispute resolution under the Federal Facility Agreement (FFA) on the draft final ROD (19 Mar 2014) for SS047 Nike Site Summit, JBER, AK.
Background: The United States Environmental Protection Agency Region 10 (EPA) & the ADEC submitted comments on the draft Nike ROD in December 2013/early January 2014. The Air Force (AF) Response to Comments (RTCs) & the draft final ROD were provided for review in mid-March 2014. After consideration of the RTCs & draft final ROD, EPA provided a list of primary issues to be discussed at the RTC meeting in mid-April 2014. Since a draft final ROD was provided before comments on the draft ROD were resolved, dispute was invoked according to the procedures outlined in the Fort Richardson FFA, dated 5 Dec 1994, Section 20.21 to delay finalization of the draft final document until consensus was reached.
Informal dispute was invoked during a 15 April 2014 meeting between the AF (represented by Kevin Thomas, Gary Fink, Donna Baumler & Steven Lufkin), EPA (represented by Deb Yamamoto, Sandra Halstead & Ted Yackulic) & ADEC (represented by John Halverson, Louis Howard & Jennifer Currie). Primary issues in dispute were:
1) Upper Site Summit (USS) GW. The draft final ROD uses inconsistent terms for the subsurface water found in isolated pockets. The term GW is used, however it is not treated as a media of concern or exposure pathway. The draft final ROD includes a table with 14 contaminants found in GW that exceed Project Action Limits without a remedy to reduce volume, mobility, or toxicity.
2) Lower Site Summit (LSS) GW Remedy. EPA & ADEC believe the draft final ROD fails to require action to satisfy the migration to GW soil cleanup levels in 18 Alaska Administrative Code (AAC) 75.340 & 341 which are listed as Applicable or Relevant & Appropriate Requirements (ARARs ). The Comprehensive Environmental Response, Compensation & Liability Act (CERCLA) requires that ARARs must be met at the completion of remedial action or waived. The draft final ROD acknowledges that residual subsoil & GW contamination at LSS exceed proposed cleanup levels (PCLs), which are primarily based on ADEC's most stringent soil migration to GW cleanup levels. The selected remedy of excavation & offsite treatment of surface soils with Land Use Controls (LUCs) for subsurface soil & GW will not satisfy the soil migration to GW ARAR requirement.
3) Land Use Controls. The draft final ROD does not incorporate complete language from EPA's Federal Facility Land Use Control ROD Checklist with Suggested Language (LUC Checklist) per the Office of Solid Waste & Emergency Response (OSWER) Directive 9355.6-12.
4) Petroleum Only Areas. The draft final ROD includes remedies for petroleum only Area A & Area C & subareas at USS & LSS.
|
Louis Howard |
| 7/29/2014 |
Update or Other Action |
Part II of II Final signed informal dispute resolution memo for Nike Site Summit.
Purpose: This document records the agreements reached during informal dispute resolution under the Federal Facility Agreement (FFA) on the draft final ROD (19 Mar 2014) for SS047 Nike Site Summit, JBER, AK.
Resolution: The agencies met on 15 April, 23 April, 20 May & 18 June 2014 to resolve the dispute. The decision points below hereby document the agreements between the agencies & resolve the informal dispute.
1) USS GW: The agencies agree GW does not exist at USS & that very limited subsurface water is held in bedrock depressions in areas of the former underground storage tanks (USTs). Subsurface water at USS will not be classified as GW & will be referred to as "pit" water. Cleanup levels for soils at USS will be based on 18 AAC 75.341, Method Two Table Bl (CERCLA compounds) direct contact (under 40" zone) & Table B2 (petroleum hydrocarbons) ingestion (under 40" zone).
2) LSS GW: GW at Lower Site Summit will be classified as IHA, Insufficient Yield pending regulatory agency approval of a Supplemental Feasibility Study (SFS) that includes a technical description of LSS GW volume & any impacts to the watershed from contamination at LSS. Towards this goal, the AF will develop a GW basin transport model at LSS utilizing the existing well at Arctic Valley as a baseline condition as evidence that contamination that may migrate from LSS only results in de minimis impact to the watershed. The GW volume & basin transport model, as well as evaluation of expanded alternatives & costs, will be incorporated into a SFS. Following review & approval of the SFS by EPA & ADEC, the cleanup levels for soils at LSS will be based on 18 AAC 75.341, Method Two Table Bl (CERCLA compounds) direct contact (under 40" zone) & Table B2 (petroleum hydrocarbons) ingestion (under 40" zone).
3) Land Use Controls: The AF & EPA agree to use the LUC language contained in EPA's Federal Facility LUC ROD Checklist with Suggested Language (LUC Checklist) per OSWER Directive 9355.6-12, as modified to incorporate checklist items #14 & #17 in the 24 April 2014 e-mail from Mr. Gerald Pease, Secretary of the AF/Installations, Environment & Logistics (SAF/IEE) office to Mr. Reggie Cheatham, Director, Federal Facilities Restoration & Reuse Office (FFRRO).
4) Petroleum Only Areas: The AF agrees to remove the petroleum only areas from the ROD for SS047. This will be done by listing a No Action Remedy under CERCLA for Areas A & C & subareas at USS & LSS where petroleum compounds are not collocated with CERCLA contaminants. The AF will prepare a petroleum-only decision document under the ADEC contaminated sites program for these areas. The remedy for Subaction Area Q (LSS) & Subaction Area K (USS) will be evaluated in the SFS & submitted for public review & comment during the proposed plan phase.
5) The AF will prepare a new Proposed Plan & ROD for regulatory review & approval. A 30 day public comment period will be provided following issuance of the Proposed Plan.
6) The FFA schedule will be updated following the AF's award of a contract to prepare the SFS, Proposed Plan & ROD. The updated schedule will be coordinated with EPA & ADEC as required by the FFA. |
Louis Howard |
| 11/20/2014 |
Update or Other Action |
ADEC, AFCEC, EPA signed off on revised document schedule under the FFA.
See site file for additional information. |
Louis Howard |
| 2/5/2015 |
CERCLA FS |
Draft Supplemental Feasibility Study received for review and comment. It was produced as part of the agreement reached between the U.S. Air Force (Air Force), U.S. Environmental Protection Agency (EPA), and Alaska Department of Environmental and Conservation (ADEC) after the Informal Dispute Resolution Agreement (IDRA) (July 2014).
Following the IDRA, one of the requirements was to develop a SFS to re-evaluate remedial alternatives for addressing contamination of environmental media incorporating the agreement in the IDRA memo. The site is being assessed under the provisions of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA). Any Areas or Action Areas identified as being contaminated by petroleum will be listed as No Action Remedy and a separate State Decision document will be prepared for those areas.
The document develops and evaluates remedial alternatives that are appropriate to site specific conditions, are protective of human health and the environment, and comply with CERCLA. JBER, ADEC, and the EPA will use the results of the previous studies of SS047, including this SFS Report, to develop a Proposed Plan and Record of Decision regarding the cleanup and/ or resolution of the status of SS047.
Following review of the action areas at SS047, four of the six areas (Area A, Area B, Area C,
and Area D) are recommended for No Further Action under this CERCLA Action. Contaminant types that were determined to be of concern at one or more of the other two remaining areas (USS and LSS) were:
• Volatile Organic Compounds (VOCs)
• Metals – Arsenic, Cadmium, and Lead
Subsurface water at USS has been classified as ‘pit water’ and no longer presents a pathway to ground water. The revised pathway will be utilized in Section 2 to identify chemicals of concern (COCs).
A ground water determination has been conducted to evaluate the quantity and potential impact of ground water at LSS (Appendix A). Ground water at LSS does not support a drinking water source, due to limited recharge volumes and low permeability of the ground water-bearing strata at LSS, which results in low yield. This low yield does not meet EPA’s classification of a drinking water source, which must produce a minimum of 150 gallons per day for a family of four. Table 1 of Appendix A demonstrates the low yield (0.14 to 0.30 gallons per minute) of ground water from the seven monitoring wells that were installed at LSS.
Several of these wells were pumped dry during the purge process that is conducted prior to collecting a ground water sample. Additionally, the ground water determination demonstrated that any contamination from LSS would pose a minimal risk to a downgradient ground water source within the catchment basin area evaluated in Arctic Valley, due to low solubility and concentrations of COCs.
The EPA confirmed that the classification as Class IIIA due to insufficient yield of the ground
water is appropriate for LSS, which no longer presents a pathway to ground water (Appendix B). The revised pathways will be utilized in Section 2 to identify COCs.
LUCs language will be rewritten, combining the EPA and Air Force LUC checklist as
documented in the IDRA.
It was agreed that areas contaminated by petroleum, or petroleum by-products only, would be
identified and removed from the CERCLA process. This will be achieved by identifying the
source of contamination and, if fuel-related, marking it as No Further Action under this
CERCLA process. A remedy for petroleum-only areas will be selected and documented using
the State of Alaska cleanup regulations.
See site file for additional information. |
Louis Howard |
| 3/4/2015 |
Update or Other Action |
EPA comments on SFS (draft).
1.0 The statement that the EPA identified areas in the draft ROD that were potentially disputed is accurate, but for clarity, EPA provided input on removing POL only areas (Area A and C) from the ROD and the question on the status of groundwater during both the EPA remedy review phase (March 2013) and draft proposed plan stage (May 2013). However, no change is needed to the document to reflect these earlier comments.
1.3.1 The site history describes the use of integrated fire control functions at the Nike site. Does the JBER PFOA/PFOS Preliminary Assessment include whether Aqueous Fire Fighting/Film Forming Foams (AFFF) were present at the Nike Site and their potential for release?
1.3.1
Reference Figure 1-1, US Army 2007 The last sentence describes the acreage of the Nike Site Summit included in the National Registry of Historical Places, but the referenced map of Fig 1-1 from the 2007 Army report is not provided. As the NRHP is considered as a location-specific ARAR, it would be good to provide a map showing where these location-specific regulations apply at the site. This comment requesting the NRHP map was made previously by EPA.
A final 2008 Nike Summit EA report is available on-line at the link below and Figure 2 appears to provide a good level of detail of the area included in the Historic Register.
US Army. 2008. Final Finding of No Significant Impact and Environmental Assessment, Management of Nike Site Summit, Fort Richardson, Alaska. February.
http://www.jber.af.mil/shared/media/document/AFD-111121-043.pdf
Please provide a map showing where the NRHP location-specific ARARs would apply at Nike Site Summit.
1.4.2.3 and Table 1-4 The discussion of Arsenic recalculation could use additional information, and it appears Arsenic should be included in Table 1-4 as the maximum detected As concentration of 19.1 mg/kg still exceeds the 95th PCL recalculated background value of 16.5 mg/kg and the RBCL calculated cleanup level of 4.7 mg/kg.
Please explain why arsenic has not been included as a COPC for SS047.
Typo: Table 1-4 has an errant footnote ‘a’ which has a definition but does not appear in the table.
2.5.1.1 Please clarify why TCE is discussed in the Lower Site Summit soil contamination at the Launch Control Building.
Section 2.5.1.1 identifies bis(2-ethylhexyl)phthalate as a chemical of concern (COC) detected in subsurface soil above proposed cleanup levels (PCLs) at Action Area Q; however, Table 2-2 does not list bis(2-ethylhexyl)phthalate for Action Area Q. Please resolve this discrepancy.
|
Louis Howard |
| 3/4/2015 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft supplemental feasibility study.
Executive Summary
1st Paragraph
The text should state: “This SFS Report develops & evaluates remedial alternatives that are appropriate to site specific conditions, are protective of human health & the environment, & comply with CERCLA. JBER will use the results of the previous studies of SS047, including this SFS Report, to develop a Proposed Plan & Record of Decision regarding the cleanup &/or resolution of the status of SS047.”
The Air Force as the “lead agency” develops the Nike Site Summit’s Proposed Plan & Record of Decision for review & comment, not the EPA or ADEC.
2nd Paragraph
The text states: “Any Areas or Action Areas identified as being contaminated by petroleum will be listed as No Action Remedy & a separate State Decision document will be prepared for those areas.”
Add text: “This decision document will be consistent with applicable State of Alaska environmental laws & regulations, including but not limited to Title 46 of the Alaska Statutes & regulations promulgated thereunder (e.g. Title 18 Alaska Administrative Code Chapter 75).”
Last Paragraph
After the first sentence add the following text: “GRAs describe those actions that will satisfy the remedial action objectives. GRAs may include treatment, containment, excavation, extraction, disposal, institutional actions, or a combination of these. Volumes or areas of media to which GRAs may apply shall be identified, taking into account requirements for protectiveness as identified in the remedial action objectives & the chemical & physical characteristics of the site.”
Introduction
Actually the FFA refers to the sections as paragraphs in the actual agreement under Part II DEFINITIONS. Please change text accordingly to refer to Paragraph 20.21.
Informal Dispute Resolution
4 Petroleum Exclusion Rule
Add a footnote the Petroleum Exclusion Rule with a citation or source for the “rule”. Some readers may not know the origin of the Petroleum Exclusion Rule.
Subsurface Water at USS
The text states: “The revised pathway will be utilized in Section 2 to identify chemicals of concern (COCs).”
ADEC requests the Air Force elaborate in the text which pathway will be utilized in Section 2 (direct contact or outdoor inhalation).
See site file for additional information. |
Louis Howard |
| 3/24/2015 |
Update or Other Action |
Distance to Surface water right location: ADL 45838, Customer Name: R and E Lab, AN USDOD US ARMY COE COLD REGIONS, is 3,864 feet (http://dec.alaska.gov/eh/dw/DWP/protection_areas_map.html).
260,000 GALLONS PER DAY FOR GOLF COURSE IRRIGATION FROM THE
SHIP CREEK RESERVOIR WITHIN THE NW1/4NE1/4 SECTION 16, TOWNSHIP
13 NORTH, RANGE 2 WEST, SEWARD MERIDIAN.
THE LOCATION TO WHICH THIS WATER RIGHT APPERTAINS IS:
THE MOOSE RUN GOLF COURSE WITHIN SECTIONS 5, 7, 8, AND 9, TOWNSHIP
13 NORTH, RANGE 2 WEST, SEWARD MERIDIAN, ANCHORAGE RECORDING
DISTRICT, THIRD JUDICIAL DISTRICT, STATE OF ALASKA |
Louis Howard |
| 4/27/2015 |
Document, Report, or Work plan Review - other |
ADEC has reviewed the response to ADEC's comments, incorporation of ADEC's comments into the NIKE SFS by the Air Force and finds the responses and incorporation of ADEC's comments into the SFS acceptable. Finalize the document pending any EPA changes or concerns being addressed by the Air Force. |
Louis Howard |
| 7/2/2015 |
Update or Other Action |
Draft Proposed Plan received for review & comment. The COCs at SS047 are CERCLA hazardous substances: volatile organic compounds (VOCs), semi-volatile organic compounds (SVOCs), & metals. Areas A & C were excluded from further CERCLA evaluation since they consist of petroleum contamination only. This contamination will be handled under ADEC cleanup regulations. Areas B & D were recommended for no action after the RI/FS as no contamination remains in these two areas that poses an “unacceptable risk”.
Upper Site Summit RAOs: Prevent contact with surface soil which has contaminant concentrations that exceed cleanup levels. Surface soil: benzo(a)pyrene & benzo(b)fluoranthene.
Prevent exposure of ecological receptors to USS surface soil with contaminant concentrations that exceed cleanup levels. Surface Soil cadmium & lead.
Lower Site Summit RAOs: Prevent contact with surface & subsurface soil which has contaminant concentrations that exceed cleanup levels. Surface soil: benzo(a)pyrene, & benzo(b)fluoranthene. Subsurface soil: benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, dibenzo(a,h)anthracene, & indeno (1,2,3-c,d)pyrene
Prevent exposure of ecological receptors to LSS surface soil with contaminant concentrations that exceed cleanup levels. Surface soil: cadmium, bis(2-ethylhexyl)phthalate & pentachlorophenol.
Preferred alternatives
USS: Excavation & off-site disposal of surface soil. Surface soil contamination is limited primarily to specific points of release & are relatively small in area; action area USS-F & USS-K. Therefore, excavation & off-site disposal of surface soil is the preferred alternative
LSS: Excavation & off-site disposal of surface & subsurface soil. Surface soil contamination at LSS is associated primarily with localized releases. Subsurface contamination is present over a broader area in the vicinity of action areas LSS-B, LSS-H, & LSS-U, & the launch control building LSS-Q. Removal of surface & subsurface soil & off-site is the preferred alternative.
For additional information see site file. |
Louis Howard |
| 8/5/2015 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft Proposed Plan. Main comments were regarding the lack of VOCs not being included as contaminants of concern despite being listed in the document as exceeding cleanup levels and requesting clarification on the use of terms "treatment" vs. disposal in one of the alternatives. Other comments were on the inclusion of natural attenuation for cleanup even though the three alternatives do not include natural attenuation. See site file for additional information. |
Louis Howard |
| 10/29/2015 |
Update or Other Action |
ADEC, AFEC & EPA signed off on revised schedule for documents under the FFA. See site file for additional information. |
Louis Howard |
| 11/10/2015 |
Update or Other Action |
Air Force provides responses to comments for ADEC, revised calculated risk ranges (10-4 instead of 10-5 as previously agreed to in prior documents) which were not mentioned in the RI/FS, Supplemental Feasibility Study, first and second Proposed Plans and an Air Force 2010 memo mentioned in the Air Force's explanation of the approach used to recalculate risk.
See site file for additional information. |
Louis Howard |
| 4/29/2016 |
Update or Other Action |
ADEC, AFEC & EPA signed off on revised schedule for documents under the FFA.
See site file for additional information. |
Louis Howard |
| 5/25/2016 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft Proposed Plan.
Main comments were regarding the bolding of exceedances of risk for 1 x 10-5 risk, requesting what land use controls are being proposed for Alternative LSS-3, and reranking of alternatives that do not include treatment as part of the alternative.
See site file for additional information. |
Louis Howard |
| 3/30/2017 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft ROD.
USS and LSS
Please adjust the cubic yards for each source area based on the more stringent Human Health cleanup levels as found in 18 AAC 75 Table B1 Method Two, Under 40 Inch Zone Human Health cleanup level (November 6, 2016) [March 23, 2017 is the most CURRENT regulations].
Direct contact (dc) cleanup levels have been superseded by 18 AAC 75 Table B1 Method Two Human Health levels (November 6, 2016). The “Human Health” exposure pathway is the cumulative exposure pathway through dermal contact, ingestion, and inhalation of volatile and particulate compounds from hazardous substances in the soil but excludes the vapor intrusion pathway of indoor air inhalation.
See site file for additional information. |
Louis Howard |
| 5/22/2017 |
Document, Report, or Work plan Review - other |
Staff commented on the Interim Data Report. Main comment was to provide text regarding sampling was conducted by a qualified environmental professional or qualified sampler.
See site file for additional information. |
Louis Howard |
| 8/9/2017 |
Update or Other Action |
Draft Decision Document received for review and comment. Upper Site Summit- Groundwater is "pit water" and not considered a drinking water source, therefore no groundwater is present at USS. Lower Site Summit - Using the EPA Guidelines for Ground-Water Classification, LSS groundwater is a Class IIIA, insufficient yield water source. Additionally, the groundwater determination demonstrated that any contamination from LSS would pose a minimal risk to a downgradient groundwater source within the catchment basin area evaluated in Arctic Valley, due to low solubility and concentrations of contaminants.
This Decision Document addresses the four areas within SS047 where non-CERCLA
contaminants have been identified. A summary of the non-CERCLA contaminants of concern
(COCs) and the affected media at these four areas is:
• USS: Polynuclear aromatic hydrocarbons (PAHs) are present at concentrations above
cleanup levels in surface and subsurface soil.
• LSS: PAHs and residual range organics (RRO) are present at concentrations above cleanup
levels in surface and subsurface soil.
• Area A: Diesel range organics (DRO) and RRO are present at concentrations above cleanup
levels in surface and subsurface soil.
• Area C: Benzo(a)pyrene is present at concentrations above cleanup levels in surface soil
only.
The remedies selected by the USAF for each area at SS047 in accordance with Alaska State law are as follows:
• USS, LSS, and Area A – Surface and Subsurface Soil Excavation with Offsite Treatment/Disposal.
• Area C – Surface Soil Excavation with Offsite Treatment/Disposal.
These remedies do not include LUCs as a component.
See site file for additional information. |
Louis Howard |
| 8/15/2017 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 73751 name: Spills |
Louis Howard |
| 9/13/2017 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft decision document for non-CERCLA contaminants. Main comments were to update the reference to current 18 AAC 75 regulations in the document (July 1, 2017) and signature page to state: "By signing this declaration, the Alaska Department of Environmental Conservation agrees that proper implementation of the selected remedy for SS047 will comply with state environmental laws. These decisions will be reviewed and may be modified in the future if information becomes available that indicates the presence of contaminants or potential exposures that present unacceptable risk to human health or the environment."
See site file for additional information. |
Louis Howard |
| 1/9/2018 |
350 Determination |
The signed record of decision memorializes the decision that groundwater is used for drinking water at SS047. The agencies agree groundwater (GW) does not exist at Upper Site Sumitt (USS) & that very limited subsurface water is held in bedrock depressions in areas of the former underground storage tanks (USTs). Subsurface water at USS will not be classified as GW & will be referred to as "pit" water.
GW at Lower Site Summit (LSS) does not support a drinking water source, due to limited recharge volumes & low permeability of the GW-bearing strata at LSS, which results in low yield. This low yield does not meet EPA’s classification of a drinking water source, which must produce a minimum of 150 gallons per day for a family of four. Several of these wells were pumped dry during the purge process that is conducted prior to collecting a GW sample. Additionally, the 18 AAC 75.350 GW determination demonstrated that any contamination from LSS would pose a minimal risk to a downgradient GW source within the catchment basin area evaluated in Arctic Valley, due to low solubility & concentrations of contaminants. The EPA supports the classification of GW at LSS as Class IIIA due to insufficient yield, and that it does not present an exposure pathway to GW.
See site file for additional information. |
Kim DeRuyter |
| 1/9/2018 |
CERCLA ROD Approved |
ROD signed by ADEC. ADEC agrees that, if properly implemented, the selected remedies for SS047 will comply with State law. This decision will be reviewed and may be modified in the future if information becomes available that indicates the presence of contaminants or exposures that may cause unacceptable risk to human health or the environment. The selected remedy for USS (Alternative USS-2) involves excavation and off-site disposal of surface soil with CERCLA contaminants at concentrations above cleanup levels. The selected remedy for LSS (Alternative LSS-2) includes surface and subsurface soil excavation and off-site disposal.
See site file for additional information. |
Louis Howard |
| 4/23/2018 |
Update or Other Action |
Draft work plan for remedial action - construction received for review and comment. The plan will implement the record of decision selected remedies. Upper Site Summit (USS): Approximately 44 cubic yards of CERCLA-contaminated soil will be removed from Action Areas USS-F and USS-K and transported offsite to an EPA-approved disposal facility.
Lower Site Summit (LSS): Approximately 263 cubic yards of CERCLA-contaminated soil will be excavated from these four action areas and transported offsite to an EPA-approved disposal facility.
The State source areas with non-CERCLA substances (i.e. petroleum constituents associated with fuels). USS: 267 cubic yards of contaminated soil will be excavated from these six action areas and transported offsite to a soil disposal facility for thermal 487 treatment. LSS: 356 cubic yards of PHC contaminated soil will be excavated from these six areas and transported offsite to a location soil disposal facility for treatment by thermal desorption. Area A: 465 cubic yards of contaminated soil will be excavated from these two areas and transported offsite to a location soil disposal facility for treatment by thermal desorption. Area C: 7.4 cubic yards of POL contaminated soil will be excavated from the one area and transported offsite to a soil disposal facility for thermal treatment.
See site file for additional information. |
Louis Howard |
| 4/30/2018 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft RA-Construction Work Plan. Main comments were regarding notification by AFCEC to EPA & ADEC project managers regarding significant corrective actions that need to be implemented during field activities. Other comments were to remind AFCEC to involve ADEC and EPA when remedial action/cleanup is being designed/planned for future source areas. Finally, staff made AFCEC aware of FFA requirements for a draft-final after the draft work plan (a primary document) be provided to ADEC and EPA for review and comment.
See site file for additional information. |
Louis Howard |
| 8/13/2019 |
Offsite Soil or Groundwater Disposal Approved |
Staff approved disposal of soil at a Lower 48 disposal facility.
See site file for additional information. |
Louis Howard |
| 2/2/2021 |
Update or Other Action |
DEC reviewed and approved disposal summary report. A total of 733 supersacks containing CERCLA-contaminated soil were transferred from the site during September 2020 and transported to an EPA-approved disposal facility in Arlington, Oregon. The bags arrived at the disposal facility by rail on November 20, 2020. |
William Schmaltz |
| 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 |
