| Action Date |
Action |
Description |
DEC Staff |
| 9/30/1986 |
Update or Other Action |
From US Army Environmental Hygiene Agency Phase I Hazardous Waste Study No. 37-26-0725-87, Evaluation of Fire Training Pits, Fort Richardson, Alaska 8-26 September 1986.
FTP2 (aka Ruff Road Fire Training Area), Specific Findings.
(1) The FTP was a 50-foot diameter, unlined pit located near a gravel borrow area as shown in Figure 4. This FTP was in operation PRIOR TO 1985.
In 1986, AEHA drilled three soil borings and collected 20 subsurface soil samples at
the site. Two soil borings met refusal at 20 feet BGS, and one met refusal at 26 feet BGS. Eight samples were analyzed for VOCs, but VOCs were not detected at concentrations
exceeding detection limits. The remaining 12 samples were not analyzed for VOCs because
holding times were exceeded. |
Louis Howard |
| 10/10/1989 |
Update or Other Action |
In 1989, as part of the Installation Restoration Program (IRP), 15 soil-gas probes were installed in the area to a depth of 9 feet. Benzene, toluene, and xylenes were identified in the soil-gas sample with maximum concentrations of 250 ppm, 2,500 ppm, and 1,200 ppm, respectively. Other hydrocarbons were detected. |
Louis Howard |
| 12/31/1989 |
Update or Other Action |
DERP Program Review, Army IRP, WN-D-007, FTW-D-006 & GR-D-001, Fire Burn Pits. Project Phase SI/RD/RA. Fort Richardson has 2 fire pits. The fire training pits were used for fire training and disposal of combustible waste since the 1940's. Investigations performed in 1988 revealed contamination, but little or no migration.
Major contaminants: BTX and other volatile organics and heavy metals. One additional "site" has been identified at FTR. |
Louis Howard |
| 2/28/1990 |
Update or Other Action |
The U.S. Air Force contracted Woodward-Clyde Consultants (WCC) to conduct Stage 1 investigations under the Installation Restoration Program for the U.S. Army, Directorate of Engineering & Housing (DEH), at three Army bases in Alaska. Volume 4, IRP Stage 1 Joint Resources Project Fort Richardson, Fort Wainwright, & Fort Greely. Site 4, Fire Training Pits (WCC). FTP-1 & FTP-2 are on Fort Richardson. The sites include: the Anchorage Fuel Terminal near Fort Richardson; the Roosevelt Road Transmitter site on Fort Richardson; the Fort Wainwright L&fill on Fort Wainwright; & four Fire Training Pits, two at Fort Richardson, one at Fort Wainwright, & one at Fort Greely. This volume addresses the results of the investigations at the fire training pits.
All of the samples retrieved were analyzed for volatile organic EP toxic metals, explosives, acid extractable organics, base/neutral extractable organic& & pesticides. It was reported that EPA-recommended holding times were exceeded on some analyses for volatile organics. One surface sample contained 0.511 ppm of leachable lead. No other contaminants were quantified as being present at FTP-2.
The area with petroleum hydrocarbons greater than 30 ppmv is delineated by probes 1, 2, 5, 6, 11, 12, 14, & 15. This area extends roughly east & west of the pit. A pile of burned debris several feet high remains within the pit. The debris included several burned out drums & cans that had contained paint & paint thinner.
Contaminant concentrations decrease outward from the pit area. Concentrations less than 30 ppmv extend around the outside perimeter of the pit. The southwest extent of the concentration plume is not completely delineated. Sufficient probe locations were not included in this area to firmly establish the extent of detectable contaminant concentrations. The contaminant concentrations decrease radially outward from the pit area. The topographical gradient descends towards the north where surface spills would probably be expected to migrate. The soil gas survey has delineated the concentrations of detectable contaminants to the north of the pit.
In general, the results of the soil gas survey indicated that in most directions the extent of detectable contamination was delineated. It appears from these results that the contamination at FTP-2 is reasonably localized. The localized nature of contamination at the site is probably due to incomplete combustion of fuels during training exercises.
Based on the qualitative risk screening, FTP-2 at Fort Richardson is designated a Category 2 site, requiring additional IRP investigation. Levels of contamination indicated by the soil gas survey and previous investigations are not sufficient to pose an immediate or new threat to human health and it is not situated near human receptors. Fire training exercises have not been conducted at FTP-2 since 1985. However, the data base is incomplete in terms of groundwater quality, gradient, and hydraulic conductivity.
At the time of closure, the area was reportedly cleaned and covered over. However, a significant amount of burned debris, including burned out barrels and cans, was noted during the 1988 WCC investigation. The entire area should be cleaned of debris, the top several feet of surface soil at the pit removed to prevent the tracking of potential contaminants off site. and the area covered with clean material.
If an overall environmental restoration program is conducted at Fort Richardson, the fire training pit should be included as a site. The investigation should include an evaluation of the groundwater. At least three monitoring wells should be installed. Soil samples and groundwater samples should be taken and analyzed. Analyses should include priority pollutants and normal fuel and combustion products. The risk screening should be repeated and, if necessary, alternative remedial actions should be re-evaluated. |
Louis Howard |
| 11/11/1991 |
Update or Other Action |
In 1991, as part of a two-phase investigation, E & E collected surface and subsurface soil samples at the fire training area. A composite surface soil sample was collected in triplicate from stained soil near the center of the area.
The sample contained lead (80.8 mg/kg to 543 mg/kg), diesel and other fuels in the diesel range (10,000 mg/kg to 20,000 mg/kg), pyrene (not detected to 750 J ug/kg), tetrachloroethene (PCE; 48 ug/kg to 485 ug/kg), toluene (not detected to 732 ug/kg), xylenes (not detected to 1,116 ug/kg), bis(2-ethy hexyl-phthalate (not detected to 4,100 ug/kg), and dioxins (0.0022 ug/kg toxicity equivalent factor [TEfl). Neither pesticide nor PCBs were detected.
Subsurface soil samples were also collected during the 1991 Phase I effort. Samples were collected from two soil borings at 5-foot intervals from to a depth of 20 feet BGS; one boring was located at the center of the fire training area and one was located in a background location south of the fire training area. The highest VOC concentrations detected in these samples were acetone (283 ug/kg), trichloroethene (TCE; 46 ug/kg), toluene (56 ug/kg), and xylenes (42 ug/kg). |
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 and Environmental Assessment Section. To Wayne Pierre Federal Facilities Superfuend Branch (HW-124). A response has been provided to the frequently-asked question of whether a reference dose or other toxicity information can be provided for fuel mixtures so that these mixtures can be addressed quantitatively in Superfund risk assessments. The memo from ECAO Cincinnati is attached (last attachment). They have developed reference doses for gasoline, JP-5/kerosene, and JP-4, and a cancer potency factor for gasoline. The memo emphasizes that these are provisional numbers and that considerable uncertainty is involved in this quantitative assessment, because of data limitations, and because inhalation studies were used to calculate oral reference doses.
I typed up a summary table showing the numbers (first attachment) and calculated some risk-based concentrations (second attachment). On the risk-based concentration table, I also
included ordnance compounds, because I hadn't made a table of those before that I can remember. The risk-based concentrations were calculated the same way as table II-1 and II-2 of the Region
10 Supplemental guidance; for soil, the same limitations apply, that the numbers presented do not consider pathways other than soil ingestion.
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 and 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
IARC concluded that gasoline is possibly carcinogenic to humans (Group 2B). IARC concluded that marine diesel fuel is possibly carcinogenic to humans (Group 2B), but light diesel fuels and jet fuels are not classifiable as to their carcinogenicity in humans (Group 3). |
Louis Howard |
| 12/12/1992 |
Update or Other Action |
E & E conducted the second phase of the investigation in 1992. Twenty-five surface soil samples and approximately 100 subsurface soil samples were collected. No groundwater samples were collected because groundwater was estimated to occur at a depth of 140 feet.
Soil samples AP-3204 sample ID 92RFTP379SL from 19.5-21.0' bgs taken on 10/26/1992 had trichloroethene (TCE) at 2.3 mg/kg and Sample ID 92RFTP380SL taken from same boring but at 24.5-26.0' bgs on 10/26/1992 had TCE at 73 mg/kg. Though VOCs were detected frequently in subsurface soils, the concentrations were generally well below the RBCs. Trichloroethene was found in sample
92RFTP380SL at 73 mg/kg, which slightly exceeds the RBC; however, this sample was collected from a depth of 22 to 24 feet BGS, where exposure cannot occur. EPA Region 10 TCE RBC 10-6 = 50 mg/kg, 10-4 = 5,000 mg/kg and HQ of 1 = 2,000 mg/kg.
ADEC 2009 cleanup levels for TCE in Under 40 Inch Zone: Direct Contact (10-5 risk) 21 mg/kg, Outdoor Inhalation (10-5) risk 0.57 mg/kg and Migration to Groundwater = 0.020 mg/kg. 2012 EPA Region 10 noncancer risk to women of child bearing age residential: 3.4 ug/L 4.7 mg/kg and 2.0 ug/m3. Chronic Noncancer adjusted HQ 0.1 0.26 ug/L, 0.44 mg/kg, 0.21 ug/m3. Cancer risk 1x10-6 EPA RSLs 0.44 ug/L, 0.91 mg/kg, 0.43 ug/m3. Commercial industrial: soil 1 x 10-6 6.4 mg/kg and Air at 3.0 ug/m3. Chronic Noncancer HQ 0.1 soil 2.0 mg/kg and air at 0.88 ug/m3. Short term noncancer for NTE 21 day exposure women of reproductive age 19.2 mg/kg and 8.4 ug/m3.
The concentrations of chemicals detected in soils at the FTPs were compared to existing risk-based concentrations from EPA Region 10 (EPA 1991) to determine which chemicals are present at levels that may potentially pose significant health risks. The Region 10 risk-based concentrations (RBCs) are calculated for target risk levels (a hazard quotient [HQ] of 1 for noncarcinogens and a cancer risk of lo6 for carcinogens) using EPA-derived toxicity indices and standard default exposure factors for ingestion of soil by residential receptors.
POL contamination was detected in both subsurface and surface soil samples. Significant levels of dioxins/furans were also encountered in surface soil samples at concentrations up to 45.4 pglkg. Analytical results exceed ADEC matrix cleanup levels for non-UST petroleum contaminated sites or EPA Region 10 RBCs. All 1992 surface and subsurface samples contained total lead, with concentrations ranging from 3.6 to 400 mg/kg.
Samples were subsequently analyzed for TCLP lead, but none of the samples contained TCLP lead at concentrations exceeding the toxicity characteristic limit that would require treatment under Title 40, Code of Federal Regulations (CFR) Part 261.24 as a characteristic waste.
Select & subsurface samples were analyzed for pesticides and PCBs using EPA Method 8080, but PCBs were not detected in the samples. Surface samples were not analyzed for pesticides or PCBs. Analytical results from the 1992 investigation confirmed the presence of petroleum contamination in soils at concentrations exceeding ADEC cleanup levels.
Contaminants previously identified at levels requiring remediation at the site included benzene, toluene, ethylbenzene, and total xylenes, DRO, and TRPH. In addition, several samples showed dioxin TEFs that exceed EPA Region 10 RBCs. Based on the results of this investigation, the areal extent of contamination was estimated to be 25,000 square feet, with approximately 35,000 cubic yards of contaminated soil. |
Louis Howard |
| 9/21/1993 |
Update or Other Action |
A.G. letter (Breck Tostevin) to Tamela J. Tobia OS Judge Advocate for the Army. Letter states that a separate petroleum site compliance agreement should be separate from the CERCLA federal facility agreement. The petroleum site restoration agreement would function as a "two-party agreement" under the FFA. It would track the basic provisions of the UST Agreement but be tailored to the State's contaminated site regulations and would interface with the FFA. All petroleum sites addressed under the Two Party agreement would be reviewed in the final operable unit of the FFA and actions taken would be memorialized in a Record of Decision (ROD) under the FFA. |
Louis Howard |
| 9/26/1994 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the RI/FS Management Plan for OU A. Text states that depth to groundwater is the reason why contamination of the groundwater is assumed to be unlikely. Based on the unknown depth to groundwater, the quantity of waste fuel/oil burned annually at the site, and the length of time the site was used, this assumption may be incorrect.
ARARs will be addressed for OUA under a separate cover letter pending Attorney General's review by 9/30/1994. |
Louis Howard |
| 10/3/1994 |
Update or Other Action |
The fire training pit was filled with clean soil and the site regraded. |
Louis Howard |
| 12/5/1994 |
Update or Other Action |
Federal Facility Agreement under Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) 120 Administrative Docket # 1093-05-02-120 signed by U.S. Army, U.S. EPA, and ADEC. The agreement ensures that the environmental impacts associated with past and present activities at the Post are thoroughly investigated and that appropriate removal and/or remedial action(s) is/are taken as necessary to protect the public health, welfare, and the environment.
Major sources of contamination at Fort Richardson 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, and the fire training pits.
Proposed listing on NPL was 06/23/1993 and Final listing on NPL was on 05/31/1994. |
Louis Howard |
| 3/2/1995 |
Site Characterization Workplan Approved |
Staff reviewed and approved the Management Plan for Operable Unit A. Data Gaps:
Lateral extent of surface contamination: Proposed actions-Grid Sampling, Data Types-Type, concentration, and extent of contaminants, Data Uses-Define perimeter of surface contamination.
Lateral and vertical extent of deep suburface contamination: Proposed Actions-Drill boreholes around the known sources and collected soil samples until no more contamination is encountered, Data Types-Type, concentration and extent of contaminants, Data Uses-Define extent of subsurface soil contamination, evaluate remedial alternatives.
Areal extent and thickness of perched water table: Proposed Actions-Drill boreholes to the perched aquifer and install wells screened across the perched water zone, collect water level data. Data Types-Groundwater elevations. Data Uses-Define potential groundwater migration pathway, evaluate potential risks associated with exposures to groundwater.
Depth to main aquifer and groundwater flow direction: Proposed Actions-Drill wells to main aquifer and collect groundwater flow data. Data Types-Groundwater flow direction. Data Uses-Define groundwater migration pathways, evaluate potential risks associated with exposures to groundwater.
Presence and extent of contaminants in groundwater: Proposed Actions-Collection of groundwater samples from monitoring wells in the vicinity. Data Types-Type, concentration of contaminants, and extent of contamination. Data Uses-Evaluate remedial alternatives, evaluate potential risks associated with exposures to groundwater.
Determine physical and chemical characteristics of site soil: Proposed Actions-Collection of soil for grain size, Atterburg limits, specific gravity, moisture content, total Kjeldahl nitrogen, total organic carbon, potassium, and phosphorus, Data Types-Physical and chemical parameters of soil, Data Uses-Evaluate remedial alternatives. |
Louis Howard |
| 2/6/1996 |
Update or Other Action |
Reports of analytical data for the OUA (Phase II) Ft. Richardson project by E&E, Inc. from Aug. 14, through Oct. 1, 1995.
VOC soil sample 95RRSTL-1155SB in ARDL report 9211 was analyzed outside the method specified 12 hour calibration window. Per method criteria, the original VOC results are not valid. The re-analysis of VOC soil sample 95RRSTL-1155SB was past the required holding rime. The VOC data of this particular analysis should be considered as estimates. .%t the request of YPDL the laboratory; submitted the re-analyzed VOC results for this sample on 9 Feb 96.
The laboratory noted sample foaming during purging as a problem in the low level analysis of selected VOC soil samples. A major-iv of these samples were either analyzed by direct purge-n-trap at a 1:5 dilution (low level method) or they were extracted in methanol then analyzed (medium level method). The following samples were analyzed at a 15 dilution:
95POLLDW-3123SB. -3124SB, -31OSB. -3132SB, -3137SB (ARDL report 9178). These samples were analyzed by the medium level method: 95POLLDW3096SB, -3098SB, -31OOSB.
ARDL report 9189: BNA soil sample had a cracked lid upon receipt. TLI report numbers 3007A and B were submitted under ARDL report 9189. TLI recorded a cooler temperature of 12.0 degrees Celsius (“C) which is outside the EPA requirements of 4 + or - 2 C. Rinsate sample 9XRFTX-2002GW and soil samples 95RRPTA-2173SB, -2174SB, and -2 182SB were in the shipment.
The initial VOC result, for soil sample 95RRSTL-1155SB are not valid as the sample was analyzed outside the 12 hour calibration window. The re-analysis of the soil sample was past the required holding time and the data are estimates Because of sample foaming during purging 15 selected VOC soil samples were either reanalyzed by direct purge-n-trap at a 1:5 dilution or were methanol extracted prior to analysis. The soil and/or water volatiles data of methylene chloride. acetone. and/or 2-butanone throughout most ARDL reports, were qualified by the laboratory with a “B” flag: should be considered due to laboratory contamination. |
Louis Howard |
| 7/30/1996 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Technical Memorandum Task 2 OUA July 1996. Pending receipt and analysis of the most recent groundwater samples for dioxins at Ruff Road Fire Training Area (RRFIA), it appears the site is a good candidate for transfer to another companion agreement for cleanup.
The State Fort Richardson Environmental Restoration Agreement is appropriate for the RRFTA since the main contaminant of concern is petroleum The Army may wish to consider either vapor extraction a viable treatment to meet soil cleanup level “C”. |
Louis Howard |
| 9/16/1996 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Feasibility Study OU A RuffRd. Fire Training Area August 1996 contract #DACA85-93-DO009 at Fort Richardson, Alaska.
1.5 Nature and Extent of Contamination and 1.5.1 Surface SoiI Contamination page l-5
The text does not specify the maximum contaminant concentrations detected for total recoverable petroleum hydrocarbons (TRPH) in the surface soil even though it is mentioned as a contaminant of concern in section 1.5.
Please add to the text the maximum concentrations detected for TRPH in the present fill and former ground-surface soil. Same comment applies to section l-5.2. TRPH and RRO (residual range organics) are mentioned throughout the document, please use RRO instead of TRPH unless there is a reason to do so.
1.5.5 Contaminant Fate and Transport page l-8
The text references transport modeling of petroleum constituents in the subsurface soils without identifying which model it is. Please include a brief description of the model in this section (i.e., particular model used, whether or not maximum concentrations detected at the site were used, and if a sensitivity analysis was conducted on the various input parameters).
Figure 2-1 Approximate Areas of Soil Contamination
The figure is not clear on what soil contamination is present at the site from past investigations. It does not indicate whether this is contamination that exceeds a particular cleanup level (i.e. soil cleanup matrix “C” or an EPA RBC) or is indicative for all contaminants detected. Please clarify in the figure with additional language or appropriate text in section 2.
3 Development and Detailed Analysis of Remedial Alternatives pages 3-2 and 3-3
Alternatives 2 and 3 state natural attenuation as being considered for the soil contamination present at the site. In addition to collecting soil samples for DRO, GRO, and RR0 under these two alternatives, the groundwater will need to be monitored (using on site wells where possible) for contaminants of concern as long as there are levels present that exceed the soil cleanup matrix. |
Louis Howard |
| 11/30/1996 |
Site Characterization Report Approved |
Remedial investigation/feasibility study approved. The SESOIL contaminant transport model was used to calculate a preliminary, conservative order-of-magnitude estimate of the leachability of petroleum constituents in subsurface soils at the RRFTA. SESOIL is a seasonal soil compartment model that estimates the rate of vertical chemical transport and transformation in the soil column in terms of mass and concentration distributions among the soil, water, and air phase in the unsaturated soil zone (Bonazountas and Wagner 1984).
Calibration of the SESOIL model involves adjusting various input parameters (soil disconnectedness, intrinsic permeability, and porosity) so that output parameters, such as soil moisture and recharge, reflect reasonable site-specific conditions.
Analytical data for DRO were the most consistently available data for subsurface soils at the RRITA. Because the SESOIL model requires compound-specific information, naphthalene was chosen as a representative and persistent component of the arctic-grade diesel that is believed to be a likely source of the DRO contamination at OU-A.
The concentrations of naphthalene used for the model were derived as a fraction of the average DRO concentration detected at the RRlTA. The fraction of naphthalene in DRO was determined from the average percent constituents of diesel fuels reported by Mapco Alaska Petroleum, Inc. (1993).
The area, thickness, and average concentration of contamination were determined conservatively based on the depths and locations of soil boring samples containing DRO at concentrations greater than 100 mg/kg.
The model predicted that petroleum contaminants will migrate approximately 10 feet vertically from their present location over a 90-year period and that groundwater would not likely be impacted.
Since the RI findings did not indicate the presence of either benzene and/or BTEX contamination nor did the HHRA identify any site-related risk with benzene and/or BTEX, cleanup objectives for these constituents are not proposed. The cleanup objectives for petroleum hydrocarbon contamination in the soil will be: GRO-500 mg/kg; DRO-1,000 mg/kg; and RRO-2,000 mg/kg.
The RI did determine the presence of dioxin contamination in the surface and subsurface soils. The maximum dioxin TEF concentration in surface soils and subsurface soils was 2.39 x 10-5 mg/kg and 1.91 x 10-5 mg/kg, respectively. The HHRA determined that for each of the four risk scenarios evaluated for the RRFTA, the risk associated with dioxin contaminated soils is below EPA’s risk criterion of 10-6.
Additionally, there are no ARARs which mandate specific cleanup levels for dioxin contaminated soil. Since the risk associated with dioxin contamination is below EPA’s acceptable risk range and due to the lack of specific soil cleanup levels, no cleanup objective for dioxin contaminated soil is proposed.
Based on the findings of the FS and review of the ARARs/TBCs, it has been determined that the establishment of cleanup objectives for groundwater is not warranted. Therefore, groundwater remedial options will no longer be addressed by this FS. |
Louis Howard |
| 2/17/1997 |
Site Added to Database |
DRO and GRO. |
Louis Howard |
| 4/2/1997 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft ROD for OUA and OUB. Hydrogeology and Groundwater Use pages 2 and 3: This section is too vague and does not give the reader the impression that it applies specifically to OU A source areas.
The description needs to mirror or be more like section 1.2.2 for OU B or incorporate information from previous investigations concerning hydrogeology and groundwater usage. |
Louis Howard |
| 1/14/1998 |
Institutional Control Record Established |
As a part of a presumptive remedy for the landfill at the Post which includes this site, a cap of soil was completed in the summer of 1997 as a part of the RCRA subtitle D of solid waste landfill regulations. Groundwater sampling has been conducted since 1989 and no contaminants of concern have been identified. Monitoring to continue for thirty years and ICs to be maintained on the cap. |
Louis Howard |
| 4/21/1998 |
Site Ranked Using the AHRM |
Ranking action added now because it was not added when the site was originally ranked. |
Bill Petrik |
| 7/31/1998 |
Cleanup Plan Approved |
Cleanup plan approved to biovent soils found at depth for the petroleum constituents. |
Louis Howard |
| 8/31/1998 |
Update or Other Action |
A treatment system demonstration project was implemented to determine the viability of using SVE at this site. Three horizontal wells were installed to a depth of about 5 feet below ground surface (bgs). Four passive air infiltration galleries were installed parallel to and on both sides of the 3 horizontal wells. The entire site was covered with a 30-mil geomembrane and overlain by 1 foot of silty sand. |
Louis Howard |
| 2/14/2000 |
Update or Other Action |
Staff received final copy of year-end progress report for 1998 activities of the treatment system. Contaminants in soil include: diesel, trichloroethylene, toluene, benzene and volatile organic components of gasoline. Full operation of system was achieved on 9/15/98 until 11/3/98 when it was shutdown and winterized. Soil sampling was recommended for start and end of 1999 season to determine if system should be continued in 2000. |
Louis Howard |
| 2/15/2000 |
Document, Report, or Work plan Review - other |
Staff received and reviewed draft copy of progress report for 1999 activities. Staff concurred with recommendations for soil sampling at beginning and end of season to determine if continued operation in 2001 is necessary. Staff also requested polynuclear aromatic hydrocarbons (PAHs) be sampled for since method one may not be the final cleanup method of choice for the Army. |
Louis Howard |
| 2/5/2001 |
Update or Other Action |
Institutional controls required due to the presence of soil contamination that would otherwise allow for unrestricted use at the site.
NOTE TO FILE: § 300.430 Remedial investigation/feasibility study and selection of remedy.(a) General—(1) Introduction. The purpose of the remedy selection process is to implement remedies that eliminate, reduce, or control risks to human health and the environment. Remedial actions are to be implemented as soon as site data and information make it possible to do so.
Accordingly, EPA has established the following program goal, expectations, and program management principles to assist in the identification and implementation of appropriate remedial actions.
(iii) Expectations. EPA generally shall consider the following expectations in developing appropriate remedial alternatives:
(D) EPA expects to use institutional controls such as water use and deed restrictions to supplement engineering controls as appropriate for short- and long-term management to prevent or limit exposure to hazardous substances, pollutants, or contaminants. Institutional controls may be used during the conduct of the remedial investigation/feasibility study (RI/FS) and implementation of the remedial action and, where necessary, as a component of the completed remedy. The use of institutional controls shall not substitute for active response measures (e.g., treatment and/or containment of source material, restoration of ground waters to their beneficial uses) as the sole remedy unless such active measures are determined not to be practicable, based on the balancing of trade-offs among alternatives that is conducted during the selection of remedy.
|
Louis Howard |
| 2/5/2001 |
Conditional Closure Approved |
Based on ADEC’s review of the data presented in the document, the Ruff Road Fire Training Area ADEC concurs no further remedial or investigative action is required at this time. Pending receipt of the land-use planning map detailed below, ADEC will grant a no further remedial action designation for this site. Institutional controls (ICs) are required by ADEC since levels of petroleum contamination are above those, which allow for unrestricted use. To eliminate the ICs, the Army may consider performing a “hotspot” removal at AP-4076 at 4.5’ and 9.5’ and AP-4077 at 4.5’.
These ICs will consist of a land use-planning map delineating the area of contaminated soil at the site. Any excavation at within this area by: Army personnel, contractors, utility companies, leaseholders, shall be coordinated with the Fort Richardson Environmental Coordinator. The contaminated soils shall be properly disposed of in accordance with 18 AAC 75. If in the future, additional contamination is discovered at this site or the soil is excavated or disturbed for any reason, further investigation and/or remedial actions will be requested of the Army by ADEC. ADEC reserves its rights, under 18 AAC 75 Oil and Hazardous Substances Pollution Control and AS 46.03 to require the Army to conduct additional assessment and/or corrective actions in the future if information indicates the site conditions pose a risk to public health or the environment. |
Louis Howard |
| 12/12/2001 |
Update or Other Action |
1. All organizations conducting activities on United States Army Alaska (USARAK) controlled land are responsible for complying with established institutional controls (ICs). ICs are administrative, procedural, and regulatory measures to control human access to and usage of property. They are applicable to all known or suspected contaminated sites where contamination has been left in place.
2. These controls have been established to implement the selected remedial actions agreed upon by the U.S. Army (Army), the U.S. Environmental Protection Agency (USEPA), and the Alaska Department of Environmental Conservation (ADEC) in accordance with the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) as amended by the Superfund Amendment Reauthorization Act (SARA). These controls also apply to remedial actions agreed upon under Two-Party Compliance Agreements. These agreements are concluded between USARAK and ADEC and apply to petroleum/oil/lubricants- (POL) contaminated sites.
3. ICs such as limitations on access, water use, excavations, and property transfers will supplement engineering controls as appropriate for short-term and long-term management to prevent or limit human and environmental exposure to hazardous substances, pollutants, or contaminants. Specific ICs include, among other things: limitations on the depth and location of excavations, prohibition of or restrictions on well drilling and use of ground water, requirements for worker use of personal protective equipment, site monitoring, and prohibition of certain land uses, types of vehicles, etc.
4. Organizational units, tenants, and support/contractor organizations must obtain an Excavation Clearance Request (ECR) for all soil disturbing activities impacting soils six inches or more below the ground surface. The review process for approval of an ECR begins with the identification of the current status (known or suspected hazardous waste site or “clean” site) of a work location. ECR’s for work in known or suspected hazardous waste sites:
a. will include specific limitations and controls on such work;
b. will include specific IC procedures, and notification, monitoring, reporting, and stop work requirements;
c. may include procedures for management, characterization, and disposal of any soil or groundwater encountered or removed;
d. will identify “project managers” for both the unit/contractor requesting the work and DPW Environment Resources.
5. The DPW project manager will conduct on-site inspections of each work site (at which ICs apply) to determine continued compliance with the terms and conditions of the approved ECR. DPW has the authority to revoke ECR approval if the specified terms and conditions are not being met. ECR forms are available at the Customer Service Desks at: a. Building 730 at Fort Richardson; b. Building 3015 at Fort Wainwright; c. Building 605 at Fort Greely.
6. USARAK has negotiated (with USEPA and/or ADEC) decision documents and/or Records of Decision (RODs) that mandate the implementation of ICs USARAK Directorate of Public Works, Environmental Resources Department (PWE), maintains copies of all decision documents and RODs requiring ICs in its real property files. PWE provides regularly updated post maps showing all areas affected by ICs. These maps can easily be accessed by using an approved intranet mapping interface application. Copies of these maps will be available to each directorate, activity, and tenant organization. To ensure the effectiveness of ICs, all organizational units and tenant activities will be informed on an annual basis of ICs on contaminated soils and groundwater in effect near their facilities.
7. ICs are enforceable by the U.S. Environmental Protection Agency (USEPA) and the Alaska Department of Environmental Conservation (ADEC). Failure to comply with an IC mandated in a decision document or ROD will violate the USARAK Federal Facility Agreement and may result in stipulated fines and penalties. This does not include the costs of corrective actions required due to violation of an established IC.
|
Louis Howard |
| 2/20/2003 |
CERCLA ROD Periodic Review |
Jennifer Roberts signed the five year review document for the Post. The purpose of this review is to ensure that remedial actions selected in the Records of Decision (RODs) for the Fort Richardson Operable Units (OUs) are being implemented, that they continue to be protective of human health and the environment, and are functioning as designed. To achieve this purpose, this review evaluates the status of implementation of the selected remedies, identifies any significant variances from the RODs, and makes recommendations for reconciling variances and/or for improving performance of remedial actions. In addition, the review identifies any new information that becomes evident, documents that no new contaminant sources or exposure pathways were discovered, confirms that no new OUs were established, and verifies that no additional work was performed that was not identified in the RODs.
The objectives of the Five-Year Review are to answer the following questions: Are the remedies functioning as intended by the decision document? Are the exposure assumptions, toxicity data, cleanup levels, and remedial action objectives (RAOs) used at the time of the remedy still valid? Has any other information come to light that could call into question the protectiveness of the remedy?
The OUA ROD included the following three source areas: Roosevelt Road Transmitter Site Leachfield, Ruff Road Fire Training Area and Building 986 Petroleum Oil and Lubricant (POL) Laboratory Dry Well. The Army, EPA, and ADEC determined that the source areas included within OU-A did not represent unacceptable risk to human health or the environment, based on EPA criteria for residential use. Thus, no remedial action was necessary to ensure protection of human health and the environment under CERCLA.
However, the levels of petroleum contamination in the soil did exceed the ADEC soil cleanup criteria. Accordingly, the sites were transferred to the Non-UST POL Environmental Restoration Agreement (Two-Party Agreement) between the Army and ADEC. Two of the sites, Roosevelt Road Transmitter Site Leachfield and Ruff Road Fire Training Area, have undergone remedial action and have been closed under the Two-Party Agreement. The Building 986 POL Laboratory Dry Well site was undergoing active remediation at the time of this review. |
Louis Howard |
| 5/27/2005 |
Update or Other Action |
Report lists section, township and range data for site. |
Louis Howard |
| 8/31/2007 |
GIS Position Updated |
61.2704 N latitude -149.6451 W longitude |
Louis Howard |
| 2/22/2008 |
CERCLA ROD Periodic Review |
ADEC signed the second Five Year Review for the Post. The purpose of this review is to ensure that remedial actions selected in the Records of Decisions (RODs) for the Fort Richardson Operable Units (OUs) are being implemented and that they continue to be protective of human health and the environment. To achieve this purpose, this review evaluates the status of implementation of the selected remedies, identifies significant variances from the RODs, and makes recommendations for reconciling variances and/or for improving performance of remedial actions. This statutory review is required by the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) since all of the RODs for this site were signed after the effective date of the Superfund Amendments and Reauthorization Act of 1986 (SARA) and some of the remedial actions result in hazardous substances, pollutants, or contaminants remaining at the site above levels that allow for unlimited use and unrestricted exposure.
The Fort Richardson NPL site is comprised of five OUs: OUA, OUB, OUC, OUD, and OUE. Records of Decision (RODs) have been written and signed for all five of these OUs, although it should be noted that the OUE ROD was signed in 2005, following the first Five-Year Review. The Five-Year Review found that the remedies for all Fort Richardson OUs are expected to be protective of human health and the environment upon completion, and in the interim, exposure pathways that could result in unacceptable risk are being controlled. It should be noted that because the sites in OUA and OUD sites have all been previously recommended for NFA or deferred to other regulatory authorities, no protectiveness determination was necessary for these OUs.
The OUA ROD included the following three source areas: Roosevelt Road Transmitter Site Leach field, Ruff Road Fire Training Area and Building 986 Petroleum Oil and Lubricant (POL) Laboratory Dry Well. The Army, EPA, and ADEC determined that the source areas included within OUA did not represent unacceptable risk to human health or the environment, based on EPA criteria for residential use. Thus, no remedial action was necessary to ensure protection of human health and the environment under CERCLA.
However, the levels of petroleum contamination in the soil did exceed the ADEC soil cleanup
criteria. Accordingly, the sites were transferred to the Non-UST POL Environmental Restoration
Agreement (Two-Party Agreement) between the Army and ADEC. Two of the sites, Roosevelt
Road Transmitter Site Leachfield and Ruff Road Fire Training Area, have undergone remedial
action and have been closed under the Two-Party Agreement. The Building 986 POL
Laboratory Dry Well site is still an active site but is not currently undergoing active remediation at the time of this review.
A description of these sites and NFA decisions can be found in the OUA/OUB ROD. During the
Five-Year Review process, the remedies conducted under the Two Party Agreement were reviewed and determined to be protective. A summary of remedial actions at the OU source areas can be found in the Administrative Record and are presented on Table 3-1 of this review. In addition, Table 3-1 contains updated information for all sites listed in the FFA. Because the OUA POL source areas are addressed through the Two-Party Agreement, they are not discussed further in this Five-Year Review. |
Jennifer Roberts |
| 2/25/2010 |
Update or Other Action |
Dept. of Army Installation Management Command, HQ U.S. Army Garrison Fort Richardson, Office of the Garrison Commander sent letter to ADEC. This letter serves as formal notice under Paragraph XXXII, Transfer of Property, of the Fort Richardson, Alaska (FRA) Federal Facility Agreement (FFA), that the property under the jurisdiction of the U.S. Army will be transferred to the Joint Base Elmendorf-Richardson (JBER) effective October 1, 2010. This letter also serves as formal notice that effective October 1, 2010, responsibility for the FRA FFA, dated December 15, 1994, will be transferred to the senior official of the JBER Supporting Component, United States Air Force (USAF). This transfer of responsibility is in accordance with the Memorandum of Agreement (MOA) between the USAF and United States Army (USA), and was signed by the Vice Chief of Staff for the USAF and the Vice Chief of Staff for the USA on October 9, 2009.
Based on the MOA and previous discussions with US EPA (reference March 2009 FRA FFA meeting in Seattle with representatives of the EPA Region 10, Elmendorf AFB and Fort Richardson), it is our understanding your agency agrees the management and oversight of the FRA FFA may properly transfer to the JBER Restoration Project Manager (RPM), and such transfer does not constitute a significant change, such as to require formal renegotiation of the Agreement or the preparation of an amendment to the Record of Decision. If you have any questions or concerns about this matter, please contact Therese Deardorff, Chief, Environmental Division, U.S. Army Garrison Fort Richardson, Alaska 907.384.3074. |
Louis Howard |
| 1/31/2013 |
Update or Other Action |
UFP-QAPP Draft work plan received.
Two borings will be drilled at or near historical sample location AP-4076 & AP-4077 to investigate the area of residual soil contamination. The proposed new borings are located where the vadose zone is interpreted to be contaminated.
Soil boring AT029-SB01 will be advanced to a depth up to 150 feet bgs (the water table) at historical sample location AP-4076 to define the nature of contamination & vertical extent & collect source area data. Soil samples will be collected every 5 feet from ground surface to 25 feet bgs & every 10 feet from 25 to boring termination. If the boring is advanced to GW, HydroPunch GW samples will be collected at the water table to confirm contamination has not migrated to GW. However, if visual observations indicate the presence of potential contamination at or near the water table, a monitoring well will be installed in the soil boring. AT029-SB02 will be advanced to a depth of up to 50 feet bgs at historical location AP-4077 to further characterize the nature of contamination & collect additional source area data. Soil samples will be collected every 5 feet from ground surface to boring termination.
If, based on photoionization detector (PID) field screening & visual/olfactory evidence, the boring reaches the maximum vertical extent of the soil contamination, two samples will be collected beyond the last evidence of contamination, & the boring will be terminated. Both borings will be drilled to at least 25 feet bgs.
AT029-SB03 through AT029-SB06
Soil borings AT029-SB03 through AT029-SB06 will be advanced to a depth to 25 feet bgs to define the lateral extent contamination at location AP-4076. Samples will be collected every 5 feet from ground surface to boring termination.
For all borings, based on field observations & the results of the PID screening, soil samples within each 5-foot interval throughout the boring will be selected for laboratory analyses. All soil samples (up to 48 primary samples) will be analyzed for GRO, DRO, RRO, petroleum-related VOCs (& PCE at AT029-SB01 only). To facilitate HRC calculations, a subset of soil samples will be collected & analyzed as follows:
Approximately three samples (including quality control [QC]) from more heavily contaminated soils (as observed at the time of sampling based on PID readings & visual/olfactory evidence of contamination) will be analyzed for PAHs, VPH, & EPH.
Approximately one sample from uncontaminated soils that are representative of the source zone will be analyzed for foc.
Approximately one sample representative of the site subsurface conditions will be analyzed for bulk density, grain size distribution, specific gravity, & moisture content.
Prior to drilling, utility locates will be performed in accordance with SOP-04 to identify potential underground hazards. In the event underground utilities or structures cannot be definitively identified, an air knife & vacuum truck may be used to clear the upper 6 feet of the proposed drilling location prior to drilling or conducting other invasive activities. Once clearance activities have been completed in the upper 6 feet of the soil column, soil removed during utility clearance will be placed back into the hole from which it was removed. Drilling or other invasive activities will be conducted after utility clearance has been completed & the soil has been replaced.
If borings are advanced to GW, HydroPunch GW samples will be collected from a few feet below the water table from each boring to confirm contamination has not migrated to GW. However, if visual observations indicate the presence of potential contamination at or near the water table, monitoring wells may be installed in the soil borings. GW samples will be analyzed for GRO, DRO, RRO, VOCs, PAHs, VPH, & EPH. Observations of odor, turbidity, & color will be recorded on the GW sample collection log.
AP-3655 & AP-3657
GW samples will be collected from two existing onsite wells, AP-3655 & AP-3657, shown on Figure 3, to confirm that no contamination has migrated to GW. Samples will be analyzed for GRO, DRO, RRO, petroleum-related VOCs, PAHs, VPH, EPH, & will be collected using low-flow sampling techniques, as described in SOP-08. Observations of odor, turbidity, & color will be recorded on the GW sample collection log.
Specific laboratory methods, bottle requirements, field preservation requirements, & sample volumes for these analyses are provided in Worksheet #19 of this Work Plan. Quality assurance (QA)/QC samples will be collected as specified in Worksheet #20. Sample handling will follow procedures listed in SOP-02. |
Louis Howard |
| 2/20/2013 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft UFP-QAPP work plan.
Executive Summary
2nd Paragraph
Please note that a cleanup complete without ICs will not be granted by ADEC to sites with vadose zone soils that exceed maximum allowable levels for petroleum contamination for soil from 0 – 15’ bgs (i.e. direct contact for BTEX, PAHs &/or ingestion for DRO, GRO, & RRO) regardless of HRC calculated risk levels. Treatment or excavations deeper than 15’ bgs may be warranted on a site-specific basis to prevent the soil from acting as a continuing source of GW contamination.
ICs or LUCs shall be applied when (per July 27, 2012 meeting minutes on the “Use of Hydrocarbon Risk Calculator” with ADEC, JBER, PBR contractors):
• The GW under or downgradient of a site was contaminated with POL constituents at concentrations exceeding risk criteria or MCLs; or
• POL contaminants in the soil were above the MAC given in Table B2 of 18 AAC 75 or at concentrations exceeding risk criteria.
• ICs also needed if direct contact or inhalation risks exceed residential land use risk-based levels. Sites should be suitable for unlimited use/unrestricted exposure (UU/UE) for ADEC to grant a cleanup complete without ICs determination.
• In addition, sites with existing GW contamination above Table C cleanup levels will require that migration to GW cleanup levels be used for soil & ICs will be required.
Once GW contamination is below Table C for a period of time [per the latest approved “Basewide Monitoring Program Well Sampling Frequency Decision Guide (See Attachment 1 Memo to the Site File for OUs 4, 5, & 6 September 2003)” e.g. two rounds of annual GW monitoring], the MAC may become the soil cleanup levels as determined by ADEC on a case by case basis.
See comment #3 below regarding perfluorocarbons (PFCs) data requirements at historical fire training pits such as Ruff Road Fire Training Area. This data gap will prevent the site from achieving “cleanup complete without ICs”.
WS #10 Conceptual Site Model
Potential Receptors & Exposure Pathways
To receive a “cleanup complete” without ICs/LUCs:
GW under or downgradient of a site cannot be contaminated with POL contaminants at levels exceeding risk criteria or MCLs; or
POL contaminants in the soil (0-15’ bgs) cannot be above MAC given in Table B2 of 18 AAC 75 or at concentrations which exceed risk criteria; or
POL contaminants’ direct contact or inhalation risks cannot exceed residential land use risk-based levels. Sites should be suitable for UU/UE for an ADEC cleanup complete determination without ICs/LUCs.
Soils greater than 15 feet below the ground surface have to meet the migration to GW standards. The direct contact pathway only needed to be considered within 15 feet of the ground surface at a site (i.e. direct contact for BTEX, PAHs &/or ingestion for DRO, GRO, & RRO).
Page 16
3rd Paragraph
ADEC requests JBER provide information (e.g. location & well construction) on the nearest (within ½ mile of RRFTA) drinking water [Base] well or standby drinking water well that may be used on a temporary, intermittent or permanent basis. This comment applies to all future UFP-QAPPs submitted by JBER for review by ADEC.
Page 17
Data Gaps
Concerns are being raised nationally over perfluorocarbons (PFCs) as contaminants. Initial concerns arose over perfluorooctane sulfonate (PFOS) & perfluorooctoanoic acid (PFOA) in fire fighting foams used between 1970 & 2000* (RRFTA fire training operations covered a portion of this time period). Investigation into PFOS/PFOA has led to finding other PFCs of concern.
PFOS & PFOA are extremely persistent in the environment & resistant to typical environmental degradation processes. As a result, they are widely distributed across the higher trophic levels & are found in soil, air, & GW at sites across the United States. The toxicity & bioaccumulation potential of PFOS & PFOA indicate a cause of concern for the environment & human health.
Below are the cleanup values using the numerical factors presented in EPA’s Office of Water which established a provisional health advisory for PFOS & PFOA to protect against the potential risk from exposure of these chemical through drinking water provisional health advisory. A subchronic RfDs was extrapolated & subsequently used in the current EPA Regional Screening Levels (RSLs) equations for calculating an Alaska site-specific risk based cleanup levels in soil & GW in accordance with 18 AAC 75.340(g). Cleanup levels for PFOS & PFOA may be updated as more current & relevant toxicity information are presented & reviewed by ADEC.
Risk Based Soil Cleanup Levels
PFOS Under 40-Inch Zone 6.3 mg/kg & migration to GW 1.2 mg/kg
PFOA Under 40-Inch Zone 16 mg/kg & migration to GW 1.1 mg/kg
Risk Based GW Cleanup Levels
PFOS 0.0013 mg/L
PFOA 0.0031 mg/L |
Louis Howard |
| 6/11/2013 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 73753 name: Fire Training Pit |
Louis Howard |
| 2/18/2014 |
Update or Other Action |
Site Characterization Report received for review & comment.
The vertical & lateral extent of DRO contamination is delineated. DRO in soil was detected at concentrations above 250 mg/kg across an area approximately 45’ long by 105’ wide from the surface to 25’ bgs. GRO contamination is delineated vertically & laterally. GRO in soil was detected at concentrations above project screening level of 300 mg/kg across an area 30’ wide by 45’ long from the surface to approximately 25’ bgs.
TCE contamination in soil above 0.02 mg/kg has been delineated both laterally & vertically at AT029. TCE-contaminated soil covers an area of approximately 145’ wide by 180’ long from the surface to a depth of 55’ bgs. The concentrations of TCE observed within the soil at AT029 are consistently small, indicative of a mixed product (waste oil) release & not a pure solvent spill. The TCE concentrations in soil remain well under direct contact or inhalation cleanup levels.
While a concentration of DRO was detected in GW (0.448 milligram per liter [mg/L]) above 0.15 mg/L, the DRO concentration was well below ADEC’s cleanup level of 1.5 mg/L. GRO was detected within the GW, but at a concentration below the project screening level. TCE was not detected in the GW sample.
Based on previous investigations & the 2013 site characterization field investigation, DRO, GRO, benzene, toluene, xylenes, 1,2,4-trimethylbenzne, 1,3,5-trimethylbenzene, n-butyl-benzene, n-hexane, naphthalene, TCE, benzo(a)pyrene, 1-methylnaphthalene, & 2-methyl-naphthalene were detected in the soil at concentrations exceeding project screening levels.
• DRO in soil was detected at concentrations above the project screening level of 250 mg/kg across an area approximately 45’ long by 105’ wide from the surface to 25’ bgs, which is 127’ above the water table of 152’ bgs.
• GRO in soil was detected at concentrations above project screening level of 300 mg/kg across an area 30’ wide by 45’ long from the surface to approximately 25’ bgs.
• TCE contamination in soil above the project screening level of 0.02 mg/kg covers an area of approximately 145’ wide by 180’ long from the surface to a depth of 55’ bgs, which is approximately 97 feet above the water table. The concentrations of TCE observed within the soil at AT029 are consistently small, indicative of a mixed product (waste oil) release & not a pure solvent spill. The TCE concentrations in soil remain well under direct contact or inhalation cleanup levels.
• The remaining soil COPCs (benzene, toluene, xylenes, 1,2,4-trimethylbenzne, 1,3,5-trimethylbenzene, n-butylbenzene, n-hexane, & naphthalene) are all co-located with the GRO & DRO contamination which has been laterally & vertically defined.
• A GW sample was collected from existing monitoring well AP-3657. DRO was detected in the GW sample above the project screening level, but well below the ADEC Table C cleanup level.
• The rounded cumulative carcinogenic risks for the current commercial/industrial (2E-05) & hypothetical residential exposure scenarios (9E-05) are above the regulatory risk standard of 1E-05. The primary contributors to carcinogenic risk are TCE, ethylbenzene, xylenes, naphthalene, & 1,2,4-trimethylbenzene in indoor air & benzo(a)pyrene from direct contact/ingestion of soil.
• The cumulative noncarcinogenic HI estimates for the current industrial & hypothetical residential exposure scenarios (0.3 & 1) are below or meet the regulatory risk standard of 1.
• The site meets the ADEC risk criteria for bulk hydrocarbons.
No potential risks to the environment/ecological receptors were observed, and petroleum hydrocarbon contamination in soil is considered insignificant (less than 0.5 acre).
Recommendations for AT029 are as follows:
• Investigation of the vapor intrusion pathway is warranted as follows before decisions about potential remedial actions can be made:
- Soil gas samples should be collected for comparison to ADEC shallow soil gas target concentrations to determine whether remedial efforts are required & where those efforts would be focused.
- Three soil gas probes should be installed in the source area to a depth of approximately 7 to 8 feet bgs to collect samples that are representative of the soil gas at the bottom of a potential future building with a basement.
- One soil gas probe should be installed at the location of the highest known VOC contamination (AP-4076/AP029-SB01), & two additional probes should be installed laterally approximately 30 feet to the northwest (near AP-4077/AT029-SB02) & to the southwest (near AT029-SB06).
- Soil gas sample collection will follow the standard operating procedures (SOPs) provided within the Basewide UFP-QAPP.
- Soil gas samples should be collected & analyzed for petroleum-related VOCs & TCE.
|
Louis Howard |
| 3/11/2014 |
Document, Report, or Work plan Review - other |
Staff commented on the draft report.
Page ES-2
Summary of 2013 Site Characterization Activities
Please state here & elsewhere as applicable that Applied Sciences Laboratory (ASL) is the CH2M Hill-Corvalis laboratory, UST-079.
Please direct the reader to “Deviations from the Work Plan” at 3.5 for explanation on why the full suite of VOCs were analyzed for reported instead of PCE & petroleum related VOCs as originally planned.
Page ES-3
ADEC partially disagrees. The lateral extent soil boring AT029-SB06 encountered shallow contamination prior to termination at 25 feet bgs. Because of a misunderstanding of the field crew, only soil samples from 0 to 5 feet bgs & 5 to 10 feet bgs were submitted for laboratory analysis. Field screening measurements (PID) were obtained from the deeper subsurface soil samples (but no laboratory analysis was performed so the total vertical extent of contamination in this boring is unknown.)
DRO contamination could conceivably be higher as was indicated in boring AT029-SB01 where DRO went from 918 mg/kg at the 5-10’ interval. To 3,140 mg/kg in the next interval at 10-15’ bgs. Maximum vertical extent of contamination could go as deep as 25’ bgs at AT029-SB06 or more. However, it is unlikely in ADEC’s opinion that the DRO/GRO went to GW at 140’ bgs at this boring or elsewhere.
ADEC is requesting any follow up work (i.e. soil gas sampling) include the location of BH-11 (aka AP-3204) from the 1993 Ecology & Environment Inc. Site Investigation Project Report for Fire Training Pits at Fort Richardson & Fort Greely, Alaska:
Page 6-6
Section 6.4.1 Fort Richardson RTFTP-2
“Tables 6-1 & 6-2 summarize the organic chemicals & metals, respectively, detected in soil at RFTP-2. Though VOCs were detected frequently in subsurface soils, the concentrations were generally well below the RBCs. Trichloroethene was found in sample 92RFTP38OSL at 73 mg/kg, which slightly exceeds the RBC; however, this sample was collected from a depth of 22 to 24 feet BGS, where exposure cannot occur.”
Evaluation of Risk
Page ES-3
Without any analyses for perfluorooctane sulfonate (PFOS) & perfluorooctoanoic acid (PFOA) in soil & GW, the RRFTA will not receive a “Cleanup Complete without ICs” from ADEC & its current status will remain as “Cleanup Complete with ICs” in the CS database until such time the data gaps are resolved, other contaminants have been properly investigated & the site conditions allow for “unlimited use & unrestricted exposure” (UU/UE).
The PBR contract does not include any analyses for these constituents & the Air Force’s own interim guidance (Dept. of Air Force, HQ USAF, Mark Correll September 17, 2012 & attachment dated August 27, 2012) states that it is not appropriate for the PBR to address these contaminants. ADEC recognizes this as Air Force guidance & required use of AFCEE/TDV approved toxicity values, coordination with other Air Force entities (Bioenvironmental Engineering) which ADEC will not be held to in its regulatory reviews & comments regarding Air Force characterization of PFCs (PFOS/PFOA). The data gaps regarding PFCs (PFOS/PFOA) remains at RRFTA & any investigation & response actions are the responsibility of the Air Force & shall be conducted in accordance with 18 AAC 75.300 - 18 AAC 75.396.
Conclusions & Recommendations
The text shall state: “TCE contamination in soil above the migration to GW cleanup level (0.02 mg/kg) covers an area of approximately 145 feet wide by 180 feet long from the surface to a depth of 55 feet bgs …The concentrations of TCE observed during the 2013 investigation within the soil at AT029 are consistently small, indicative of a mixed product (waste oil) release & not a pure solvent spill.
However, further investigation will also occur as part of the soil gas investigation for AT029 at the sampling location AP-3204 as part of the 1993 E&E investigation which found TCE at 73 mg/kg at 22-24’ bgs which is consistent with a larger release of solvents mixed with fuels & waste oil associated with fire training activities.”
Page ES-6
ADEC will require additional soil gas probes in the vicinity of BH-11 (AP-3204) from the 1993 E&E Site Investigation Project Report. The number of probes stated here conflicts with the number of probes stated in the Conclusions at Section 6.2 Recommendations Sections which needs to be consistent with statements made on Page ES-6. The details of the soil gas investigation shall be provided in a site-specific UFP-QAPP work plan addendum since these are general recommendations in this report. |
Louis Howard |
| 5/8/2014 |
Document, Report, or Work plan Review - other |
ADEC comments on the AT029 document.
Comment 7:
While the field quality control (QC) samples for AT029 alone do not meet the required frequency for EBs and MS/MSDs according to the data quality evaluation (DQE), the work at this site was performed as part of a larger program, and overall the program meets the QC requirements outlined in the Basewide UFP-QAPP (USAF, 2013a).”
The site specific UFP-QAPP field quality controls as agreed to in the final work plan UFP-QAPP for each site shall be applicable. The fact that the work is being performed as part of a larger program has no bearing on complying with QC requirements.
Restate text as follows: “The field quality control (QC) samples for AT029 alone do not meet the required frequency for EBs and MS/MSDs according to the data quality evaluation (DQE).”
AF RTC: Disagree. Worksheet #20 of the approved Site Characterization Work Plan states that a lower number of duplicates and MS/MSD samples may be collected if the AT029 samples are collected as part of a (basewide) program and submitted with samples from other sites.
-----------------------------------------------------------------------------------------------------------------------------------------------------------
ADEC response to RTC and BIGGER PICTURE for JBER:
As discussed earlier this a.m. for 3 other sites on JBER-Richardson QC requirements for soil gas sampling, the need for field duplicates on a "site" specific basis as required by ADEC in the UST Procedure Manual - which is adopted by reference by 18 AAC 75 requires compliance with site-specific QC requirements. The work at AT029 has been done already, therefore from this point forward, site-specific duplicates and MS/MSD samples will be collected and not rely on the larger program effort by the PBR contractor on JBER to "fulfill the QC requirements" in the Basewide UFP-QAPP.
The lastest Draft Basewide UFP-QAPP out for agency review will need to be changed to reflect these regulatory requirements. In the interim, finalize the document for AT029 and direct all JBER (WESTON/CH2MHILL) contractors that site-specific duplicates, MS/MSD samples, etc.. are required (see UST Manual Section 9.1.1 Minimum Field QC Sample Requirements-Table 4 and also May 2010 Draft Field Sampling Guidance: Minimum Quality Control Requirements Table 3).
Where the Basewide UFP-QAPP (last final approved version) and site specific UFP-QAPP WPs' QC (field quality controls) conflict with ADEC regulatory requirements, the regulatory QC requirements shall prevail. Revise all future UFP-QAPP work plans/WP Addendums accordingly if in the draft stage and not approved by ADEC to reflect these QC requirments.
|
Louis Howard |
| 11/20/2014 |
Update or Other Action |
Draft AT029 - Ruff Road FTA SC Report received for review and comment.
A single concentration of GRO was detected at 654 mg/kg (above its project screening level of 300 mg/kg) in soil collected from 20 to 25 feet bgs. DRO was detected above its project screening level of 250 mg/kg in two soil samples collected: at 341 mg/kg from the soil sample from 20 to 25 feet bgs, and at 1,210 mg/kg in the soil sample from 25 to 30 feet bgs. These results are slightly less than the reported DRO concentrations from AP-3240 in 1992 of 2,200 mg/kg in the soil sample collected from 19.5 to 21 feet bgs and 1,800 mg/kg in the soil sample collected from 24.5 to 26.5 feet bgs.
In soil sampled from 20 to 25 feet, the following VOCs were detected above their respective
screening levels:
• 1,2,4-TMB at a concentration of 32.6 mg/kg (screening level: 4.9 mg/kg)
• 1,3,5-trimethylbenzene (1,3,5-TMB) at a concentration of 9.81 mg/kg (screening level: 4.2 mg/kg)
• Naphthalene at a concentration of 4.96 mg/kg (screening level: 2.8 mg/kg)
• Total xylenes at a concentration of 32.4 mg/kg (screening level: 6.3 mg/kg).
In soil from 25 to 30 feet bgs, 1,2-dichloroethane (1,2-DCA) was detected above its screening level (0.016 mg/kg) at a concentration of 0.0167 mg/kg. In soil from 25 to 60 feet bgs, benzene
was detected above its project screening level at concentrations ranging from 0.0263(J) mg/kg at
25 to 30 feet bgs to 0.0667 mg/kg at 55 to 57.5 feet bgs.
The following conclusions were made regarding AT029:
• Concentrations of DRO, GRO, 1,2,4-TMB, 1,3,5-TMB, 1,2-DCA, naphthalene, total xylenes, and benzene were detected in soil from AT035-SB09 (former location AP-3204) above their respective project screening levels at depths of 20 feet or greater bgs
• Concentrations of TCE in soil from AT035-SB09 were either nondetect or slightly above
detection limits (well below its project screening level). These soil results indicate that the
previously reported TCE concentration of 73 mg/kg in soil from AP-3204 (E & E, 1993) was likely reported incorrectly and in fact was 73 µg/kg. Low oxygen, high carbon dioxide and methane, and the presence of VC detected in soil gas at AT035-SB09/SV01 suggests that biological degradation of TCE may be occurring naturally in the vadose zone at this specific location.
• The risk evaluation completed in 2013 indicated that the vapor intrusion pathway was complete
for potential future residents at AT029 and based on modeling of soil concentrations there was
potential risk to future residents from exposure to TCE, ethylbenzene, total xylenes, and
1,2,4-TMB concentrations within indoor air. Laboratory results for soil gas samples collected
in 2014 indicate that concentrations of TCE, ethylbenzene, total xylenes, and 1,2,4-TMB are above ADEC’s residential shallow soil gas target levels. In addition, laboratory results for soil gas collected in 2014 also indicate concentrations of 1,3,5-TMB, PCE, VC, and benzenes were above ADEC’s residential shallow soil gas target levels. Concentrations of 1,2,4-TMB, 1,3,5-TMB, and TCE were also above ADEC’s commercial shallow soil gas target levels.
The following are recommended for AT029:
• Based on concentrations of VOCs detected in soil and soil gas in 2013 and 2014, further action
under CERCLA is necessary.
• Further investigation of soil may be necessary if laboratory detection limits for historic soil
data are not considered adequate to define the lateral and vertical extent of VOCs in soil and to evaluate potential site risk.
• Further investigation of soil gas may also be necessary to support the evaluation of potential
future site risk and risk management decisions. |
Louis Howard |
| 12/2/2014 |
Document, Report, or Work plan Review - other |
Staff provided comments on the SC report addendum.
General Comments
Concerns are being raised nationally over perfluorocarbons (PFCs) as contaminants. Initial concerns arose over PFOS & PFOA in fire fighting foams used between 1970 & 2000 (RRFTA fire training operations covered a portion of this time period). Investigation into PFOS/PFOA has led to finding other PFCs of concern.
The PBR contract does not include any analyses for these constituents & the Air Force’s own interim guidance (Dept. of Air Force, HQ USAF, Mark Correll September 17, 2012 & attachment dated August 27, 2012) states that it is not appropriate for the PBR to address these contaminants, required use of the AFCEE/TDV approved toxicity values & coordinate with other Air Force entities (Bioenvironmental Engineering). ADEC does not consider these issues relevant in conducting its own regulatory review & providing comments regarding Air Force characterization of PFCs (PFOS/PFOA) on JBER-E & JBER-R.
The data gaps (in soil & GW) regarding PFCs (PFOS/PFOA) remains an outstanding issue at RRFTA (& JBER-E/JBER-R) & any investigation & response actions are the responsibility of the Air Force & shall be conducted in accordance with 18 AAC 75.300 - 18 AAC 75.396.
Soil Gas Sampling
Soil gas sample AT029-SV01 failed helium leak check in the field which was attributed to high methane concentrations. The sample was subsequently analyzed for helium by the laboratory. ADEC requests the Air Force elaborate on whether there was a calculation performed to confirm helium leak check passed. If so, ADEC requests the Air Force list where this is documented in the report.
Conclusions
2nd Bullet
ADEC disagrees that the units were in fact reported incorrectly since JBER has not produced any laboratory data to the contrary since the report was generated.
Text from the 1993 Site Investigation Project Report for Fire Training Pits at Fort Richardson & Fort Greely, Alaska, states as Section 6.4.1 Fort Richardson RFI’P-2 “Though VOCs were detected frequently in subsurface soils, the concentrations were generally well below the RBCs.
Tables 6-1 & 6-2 summarize the organic chemicals & metals, respectively, detected in soil at RFTP-2. Though VOCs were detected frequently in subsurface soils, the concentrations were generally well below the RBCs. Trichloroethene was found in sample 92RFTP38OSL at 73 mg/kg, which slightly exceeds the RBC; however, this sample was collected from a depth of 22 to 24 feet BGS, where exposure cannot occur.”
The Region 10 RBC of 10-6 risk for TCE was 50 mg/kg based on soil ingestion, residential & 73 mg/kg would "slightly" exceed this risk number.
Please provide written documentation that shows that TCE was misreported at 73 ug/kg instead of 73 mg/kg. Otherwise, the 73 mg/kg TCE result from 1993 stands as reported & the text should reflect it in the current report addendum.
Data Quality Evaluation
Please explain which samples were qualified due to field duplicate sample result relative percent difference exceedances. Please define in this section which associated samples where qualified.
Please discuss in this section the fact that a subset of soil samples were not analyzed for low level SW8260C due to instrument contamination concerns as documented in ASL SDG# N2064. Please also discuss how this issue affects the usability of the analytical results for decision making purposes.
Conclusions
Please discuss the mechanism of aerobic pathway of TCE in the vadose zone & why this is may be occurring.
Recommendations
ADEC concurs with the Air Force that further action under CERCLA is necessary for AT029 Ruff Road
Fire Training Area.
General Comment Regarding Field Notes
Please document the level of helium detected under the shroud & in the sample port in the field notes during subsequent site investigations where soil gas is sampled.
Please explain in more detail why the field duplicate for SB1603 was moved due to contamination. Ideally, field duplicates should be collected from the most contaminated areas.
The notes for AT029-SV01 suggest helium leak check failed multiple times; however, soil gas samples were collected at this location. Please discuss this discrepancy in the Data Quality Evaluation Section.
Please identify the length of time samples were analyzed for VPH & EPH past holding time.
Please also justify qualifying & not rejecting the VPH & EPH data associated with these samples.
SDG’s for soil gas results associated with samples AT029-SV02, AT029-SV03, AT029-SV04, AT029-SV05 were not provided. Please include these laboratory reports in Appendix B-2.
|
Louis Howard |
| 3/3/2015 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft SS041 Roosevelt Road Transmitter Site Site Characterization report.
ADEC concurs with the conclusions and recommendations of the report as long as the current land use does not change and occupied buildings are not constructed within 100 feet of the TCE soil contamination on SS041 Roosevelt Road Transmitter Site. Please add the former transmitter annex’s foundation pad as part of the LUC inspections and reporting (the coating on the pad was observed on October 14, 1994 to be disintegrating & no longer is encapsulating the pad).
Originally, the top of it was encapsulated using an epoxy resin (Scotchkote™ by the 3M™ Company).The foundation pad and cable routing trenches were encapsulated due to three out of four wipe sample results exceeding 100 micrograms per 100 square centimeters as specified in 40 CFR Part 761 . If the pad’s encapsulating coating has failed and the pad is exposed (if not completely covered by several feet of fill), then it would pose a current risk to human health and the environment. |
Louis Howard |
| 4/28/2015 |
CERCLA PA |
Final Preliminary Assessment received. Under authority of CERCLA and the Superfund Amendments and Reauthorization Act of 1986, CH2M HILL conducted a PA visit at Joint Base Elmendorf-Richardson (JBER) during the week of December 15, 2014, with a follow-up visit on January 12 and 13, 2015, to secure additional information.
Based on background research and visits to JBER, a total of four FTAs, seven fire stations, seven hangars, five crash locations, four areas where AFFF spray testing has occurred, and three
additional “miscellaneous” locations have been identified as being active during the timeframe
when AFFF has been used by the USAF for fire suppression.
RRFTA was active from the 1940s to 1980s. Records and interviews did not confirm that AFFF was used during fire training at RRFTA; however, not enough information was available to confirm that AFFF was never applied. It is likely that impacted media could occur at RRFTA.
Recommendation: initiate a site inspection as an investigation to collect and analyze waste and environmental samples to support an evaluation.
Since the draft was not provided to EPA or ADEC prior to the FINAL version being submitted, it was decided that no comments or approval letter would be granted on the preliminary assessment for PFCs on JBER. |
Louis Howard |
| 10/29/2015 |
Update or Other Action |
Memo for incorporation of AT029 - Ruff Road Fire Training Area into the JBER-Richardson (JBER-R) Federal Facility Agreement (FFA) signed by AFCEC, EPA & ADEC remedial project managers.
Site characterization was conducted in 2013 to evaluate action required to eliminate ICs & obtain closure of the site. During the 2013 investigation TCE, a CERCLA-regulated volatile organic compound (VOC), was detected above soil screening levels. Follow-up shallow soil gas samples collected in 2014 detected CERCLA regulated VOCs (TCE, PCE, vinyl chloride) & petroleum-related VOCs (benzene, ethylbenzene, xylenes, 1,3,5-trimethlybenzene) above ADEC residential shallow soil gas target levels. Based on these results, EPA & ADEC indicated at a meeting on 13 August 2014 that further actions for AT029 should be addressed under CERCLA & that these actions should begin with an evaluation of data gaps to determine whether a supplemental RI is necessary to provide additional data to perform a revised risk assessment.
In accordance with Section 24.3 of the 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. The FFA requires unanimous written agreement between the Project Managers concerning disposition of individual source areas. Based on site-specific information indicating CERCLA contaminants are present in the soil, the Project Managers agree that AT029 - Ruff Road Fire Training Area will be incorporated into the JBER-R FFA as a new site subject to the stipulations listed in the FFA, including Attachment 1. Upon approval, this document will be attached to the current FFA (effective 5 Dec 1994).
See site file for additional information. |
Louis Howard |
| 3/25/2016 |
Institutional Control Update |
CY2015 Annual Land Use Control (LUC) and Institutional Control (IC) Monitoring at Joint Base Elmendorf-Richardson (JBER) received for review.
1. This letter serves as the annual monitoring report on the status of LU Cs/ICs in place on
JBER-Elmendorf(JBER-E) and JBER-Richardson (JBER-R). The Air Force ensures compliance with LU Cs by conducting periodic monitoring and site inspections. Formal LUC/IC inspections occur annually on JBER during late spring through early fall and are typically conducted by contract. Random inspections are also conducted throughout the year by JBER Restoration staff.
2. The sites on JBER-E that were inspected in 2015 include: CG509, CG526/S0525, CG527, CG529, CG530, CG536, CG539, CG543, CG551/S0550, CG702, DP098, FT023, LF002, LF003, LF004, LF059, PL081, SD015, 80024, SD025, SD029, 80507, S0510, 80513, S0552, SS418, SS522, ST032, ST036, ST037, ST041, ST048, ST068, ST600, TU091, TU107, and TS003. The discrepancies identified at these sites are summarized in Attachment 1.
The sites on JBER-R that were inspected in 2015 include: AT029, AT032, AT035, CG039, DA089, DP009, SS013, SS041, 8S044, SS090, TU037, TU043, TU053, TU058, TU064, TU068, TU074, TU07S, TU08S, TU1Ol, TU102, TU103, XE023, and XU022. The discrepancies identified at these sites are summarized in Attachment 2.
Please note that the completed LUC inspection forms are included in the 2015 Field Activities
Report or in the Land Use Control Inspection Report, which included 10 State sites. Unless a
discrepancy was corrected on the spot, it will be included in the 2016 RA-0 & Monitoring Letter.
Work Plan and addressed in the 2016 field season.
3. In addition to formal inspections, JBER also employs a LUC educational program and relies
on information from contractors and base personnel on potential discrepancies. As an example,
the breach of the JBER-R SS090 LUC came to light when a base contractor informed us of the
situation while coordinating on a dig permit for a different construction project.
4. Separate controls are in place and enforced to prevent inappropriate soil and groundwater
exposure at restoration sites. JBER requires all projects that result in soil disturbance to follow 673rd Wing Instruction 32-1007, Safeguarding Utilities from Damage, dated 03 Jul 2013 and
673d Wing Instruction 32-7003, Land Use control Management, dated 19 May 2011. Both
instructions require the proponent to obtain an approved Base Civil Engineer Work Clearance
Request (673 WG Form 3) prior to conducting any work on the Base. This form is also referred
to as a dig permit. It is required for ANY project in which mechanized equipment penetrates or
disturbs the ground (including vacuum excavation), or hand digging activities that penetrate deeper than 4 inches into the ground.
5. A total of393 dig permits were reviewed by this office in CY2015 (213 on JBER-E and 180 on JBER-R). Of those, 48 were for activities that occurred on active restoration sites, or had LUCs/ICs, potential to impact groundwater monitoring wells, or had other environmental requirements (42 on JBER-E and 6 on JBER-R). Eight projects required approved Storm Water Pollution Prevention Plans that were reviewed by the JBER Environmental Quality section. There was one activity that required the potential use of dewatering. Unless it was specifically noted no soil was removed from the sites. The dig permits with the above mentioned environmental requirements are presented as Attachment 3.
6. JBER requires certificates of compliance for every dig permit. These certificates are presented to the proponent during review of the dig permit and provide site-specific information
on LU Cs and other applicable environmental requirements. The proponent is required to return
the signed certificate within 30 days of completing the project signifying that they have compiled
with the requirements. As of the date of this letter we have received 216 signed certificates or a
55% return rate which is up from 43% in 2015 and 31% in 2012. |
Louis Howard |
| 4/11/2016 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft PFC Site Inspections work plan for JBER-E and JBER-R.
Main comments were regarding obtaining prior approval from ADEC and EPA project managers before making changes to the approved QAPP and that the EPA RSSLs are less stringent than the human health soil cleanup levels and migration to ground cleanup levels ADEC will be promulgating this winter (2016). It was noted that WS# 10 is especially vague: "Based on the above, the best available screening criteria for PFOA and PFOS releases are the EPA PHAs for groundwater and RSSLs for soil. Because ADEC has proposed lower concentration limits that are in the public
comment process, the ADEC levels should also be considered."
It states that ADEC levels should also be considered, however in WS # 11, it states the concentrations of PFOA and PFOS in soil and groundwater will be compared to project screening levels based on the most conservative risk based EPA or ADEC values.
For determining presence or absence of PFOS and PFOA using solely risk based screening levels is not acceptable to ADEC. If the migration to groundwater cleanup level is adopted by ADEC and it exceeds for PFOS or PFOA, a release is confirmed and it is deemed to be contaminated by ADEC. 18 AAC 75.990 Definitions.
(23} "contaminated soil" means soil containing a concentration of a hazardous substance that exceeds the applicable cleanup level determined under the site cleanup rules. If AFCEC chooses to proceed with risk based values (as it is apparent upon review of Table 10-2 Steps 2, 4, & 5), then ADEC reserves the right to require further investigation/cleanup under 18 AAC 75 for all areas of concern/source areas where AFC EC determined no addition action was necessary at an area of concern/ source area, but the PFC levels detected exceed migration to groundwater cleanup levels for PFCs.
See site file for additional information. |
Louis Howard |
| 9/16/2016 |
Update or Other Action |
Supplemental work plan received for review to address the groundwater sampling, institutional controls (IC) inspection, and landfill cap inspection activities associated with the 2016 Long Term Monitoring (LTM) at the Joint Base Elmendorf-Richardson (JBER), Sites PL081, CG551, ST408, CG530, SO510, SS522, SO507, SS418, TS003, CG543, CG529, TU107, ST048, CG509, SO508, SO549, AT035, AT029, SS019, and DP009.
As a requirement of the 2016 Environmental Long Term Monitoring contract, the following work shall be performed at JBER Site AT029:
? Perform IC inspection |
Louis Howard |
| 3/22/2017 |
Update or Other Action |
2016 Draft Report for Remedial Action Operation and Land Use/Institutional Control at JBER received for review and comment.
The USAF AT029 Site Characterization Report (2014b) states the migration to groundwater criteria are attained in surface and subsurface soils as per 18 AAC 75.340, supporting a Cleanup Complete determination at AT029. However, this site has been added to the Joint Base Elmendorf-Richardson former Fort Richardson area (JBER-R) Federal Facilities Agreement (FFA) for further delineation of the TCE.
The inspection of Site AT029 revealed a well-vegetated field that appeared to have been tilled in
the recent past. The vegetation in this area appears to be mowed by site personnel. Frozen
standing water was observed in the furrows. No other evidence of ground disturbance was
observed at this site other than the mowing maintenance activities. Re-vegetation appeared to
be occurring and the monitoring wells located at the site were observed to be in good condition.
No warning signs relevant to the area of concern were observed. Photographs 1 through 7 in
Photograph Log A14 present the general condition of Site AT029.
See site file for additional information. |
Louis Howard |
| 4/3/2017 |
Document, Report, or Work plan Review - other |
ADEC letter to AFCEC approving the draft 2016 Environmental LTM ast several sites on JBER. |
Louis Howard |
| 6/1/2017 |
Update or Other Action |
Site inspection (SI) at aqueous film forming foam (AFFF) areas on JBER-E and JBER-R waa received for review and comment. The purpose of the SI was to determine the presence or absence of perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS) in the environment. These compounds are a class of synthetic fluorinated chemicals used in industrial and consumer products, including defense-related applications. This class of compounds is also referred to as per- and polyfluorinated alkyl substances (PFAS).
One soil sample from ground surface to 15 feet bgs was collected. PFBS was not detected in soil.
PFOA was detected in soil at concentrations below the EPA RBSL and ADEC cleanup levels. PFOS was
detected in soil at concentrations below the EPA RBSL and the ADEC human health cleanup level but above the ADEC MTGW cleanup level.
One groundwater sample was collected from 150 to 160 feet bgs in new monitoring well AT029-1. PFBS and PFOS were not detected in groundwater. PFOA was detected in groundwater at concentrations above the EPA HA but below the ADEC cleanup level.
See site file for additional information. |
Louis Howard |
| 6/13/2017 |
Document, Report, or Work plan Review - other |
Staff reviewed the Draft SI Report for AFFF Areas on JBER-E and JBER-R sites.
AT029-1 Sheet 2 of 7 (Page 347): 40’ below ground surface (bgs)- PID 0.0 Logging Notes-Weak to moderate hydrocarbon odor observed from 40-45 ft. bgs.
AT029-1 Sheet 3 of 7 (Page 348): 55’ bgs- PID 0.0 Logging Notes: Moderate hydrocarbon odor observed 55 to 57’ bgs.
It appears analysis for BTEX, GRO, DRO, RRO, PAHs (8270-SIM), VOCs (8260 w/methanol and low-level) are warranted from this monitoring well associated with Boring AT029-1 either under CERCLA or as part of a further site characterization effort as required by 18 AAC 75.335.
See site file for additional information. |
Louis Howard |
| 6/19/2017 |
Update or Other Action |
EPA email requests clarification on whether AFCEC has a coordinated review on the data (especially lab packages) before it goes to the regulatory partners [EPA & ADEC] for review. For example, does Cornell Long (AFCEC) or someone else with PFAS expertise review and comment on the data from the AF sites. |
Louis Howard |
| 7/17/2017 |
Document, Report, or Work plan Review - other |
EPA received the Draft Site Inspection Report for Aqueous Film Forming Foam Areas, Joint Base Elmendorf-Richardson, Alaska, May 2017 for review the week of June 2, however Appendix B2 (App B2) laboratory data was not included. EPA received App B2 for review the week of June 20. EPA preliminary comments were sent to the Air Force on July 17, 2017.
EPA Office of Research and Development staff, as well as EPA Region 5 Laboratory chemists, reviewed App B2. EPA has asked the Air Force for clarification regarding what level of report and data review was done by the government prior to submittal of the report to EPA and have not received a clear response. EPA’s initial review has identified a number of data quality issues and that the government data review should be completed and submitted to EPA before we are asked to finalize our comments. The comments submitted reflect only those requiring clarification on the narrative or figures and are not inclusive of review of the laboratory data, and therefore cannot substantiate any conclusions drawn on the presence/absence of PFAS at the 26 AOCs.
EPA review of the laboratory data packages has raised a number of concerns with deviations from workplan approved standard operating procedures, laboratory methods, and data validation.
EPA requests the Air Force clarify the level of governmental data review conducted on the JBER Site Inspection laboratory packages, and provide a copy of the Air Force data review to EPA.
Additional EPA comments on the laboratory data are pending receipt of the Air Force data review.
See site file for additional information. |
Louis Howard |
| 8/15/2017 |
Update or Other Action |
AFCEC will have the U.S. Army Corps of Engineers conduct a level IV data review for the JBER PFAS data. Guestimates are it will be at least 4-6 weeks. The review may also include Eielson and Clear AFB since they were on the same contract/ same labs.
Level IV data validation
These data undergo full review and evaluation of a complete Data Validation Package (DVP) according to DQO/QAPP specific criteria, and National Functional Guidelines. This level of review includes all summaries, and raw data associated with the data package, and ensures the highest level of defensibility. |
Louis Howard |
| 8/24/2017 |
Document, Report, or Work plan Review - other |
Staff commented on the Draft Supplemental Work Plan for JBER-E and JBER-R sites [PL081 N. Jet Pipeline, CG551 Bldg. 4314, ST408 Bldg. 9569, CG530 ST526, SO510 Bldg. 9480, SS522 Hardstand #39, SO507, Bldg. 9669, SS418, ST532, TS003 Skeet Range, CG543 Bldg. 18877, CG529 ST529, ST048 Bldg. 11-490, CG509 Bldg. 4347, SO508 ST508, SO549 Bldg. 4913, AT035 MEB Complex, AT029 Ruff Road FTA, SS019 Bldg. 755, DP009 Bldg. 986 POL Lab, LF002, LF002 OU6 Disposal Site, CG536 ST510, CG539 Bldg. 15380, CG702 Bldg. 31562, SO544 Bldg. 10334, SO547 Bldg. 4913, CG704 Southern Plume, CG527 ST538, SO501 ST427, TU064 Bldg. 740, SS013 MP Barracks, SS014, SS041 Roosevelt Road Transmitter Site, TU107, ST048] which include this one.
ADEC concurs with the scope of work for the current work outlined in this section. Note: this site has PFOS detected in soil at concentrations above the ADEC (2017) migration to groundwater level and PFOA above EPA Health Advisory level in groundwater. |
Louis Howard |
| 11/7/2017 |
Update or Other Action |
Letter report received for CY2016 [January 1, 2016 - December 31, 2016] Annual Land Use Control (LUC) and Institutional Control (IC) Monitoring at Joint Base Elmendorf-Richardson (JBER). This letter serves as the annual monitoring report on the status of LUCs/ICs in place on JBER-Elmendorf (JBER-E) and JBER-Richardson (JBER-R). The Air Force ensures compliance with LU Cs by conducting periodic monitoring and site inspections. Formal LUC/IC inspections occur annually on JBER during late spring through early fall and are typically conducted by contract. A total of 55 sites were formally inspected. Random site inspections are also conducted throughout the year by JBER Restoration staff.
Discrepancies: Field appears to have been tilled in the recent past. Some frozen pools of water
observed Vegetation is short, appears to be re-growing after disturbance.
See site file for additional information. |
Louis Howard |
| 11/21/2017 |
Update or Other Action |
Per AFCEC email: A memo from the USACE summarizing issues found in their review should be in hand on the 4th of December. |
Louis Howard |
| 12/29/2017 |
Update or Other Action |
Draft Uniform Federal Policy—Quality Assurance Project Plan (UFP-QAPP) presents the proposed
objectives, methods, and procedures for limited field investigations of Sites AT029, DP009, SS019, and SS120 received for review and comment. Based on review of previous investigations and historical analytical data, the following data gaps have been identified at AT029: • The lateral extent of VOC (1,2,4-TMB and naphthalene), DRO, and GRO contamination in soil remains undefined to the south/southwest. • Laboratory limit issues for historical VOC analyses present uncertainty in defining the extent of contamination. • Potential site risks need to be reevaluated incorporating recently collected data.
AT029 – RUFF ROAD FIRE TRAINING AREA, SUPPLEMENTAL REMEDIAL INVESTIGATION WORK PLAN
Eight soil borings will be drilled at AT029 as part of this supplemental RI. The total depth of the borings will be 70 feet bgs, and two discrete soil samples will be collected from each boring. Two soil borings, AT029-SB10 and AT029-SB11, will be drilled within the SVE area to collect data for risk assessment.
See site file for additional information. |
Louis Howard |
| 2/14/2018 |
Document, Report, or Work plan Review - other |
Staff reviewed and commended on the draft UFP-QAPP LFI and had the following comments: ADEC believes some acknowledgement should be given to the 2017 Site Inspection of aqueous film-forming foam (AFFF) Sites on JBER which included source area AT029. AT029 was sampled for Perfluorooctane Sulfonate (PFOS) and perfluorooctanaoic acid (PFOA) contamination in soil and groundwater. PFOS was detected in soil above the promulgated 18 AAC 75.341 Table B1 Method Two – Soil Cleanup Levels Table. Migration to Groundwater of 0.0030 mg/kg (November 7, 2017). Staff requested the most current EPA Regional Screening Levels from November 2017 be used and referenced. Finally staff requested modification for PFOS/PFOA analysis which could be of significant assistance in evaluating effects on human health or the environment, in evaluating the selection of cleanup options, or in protecting human health or the environment from PFC contamination (e.g. PFOS/PFOA) at AT029. If sampling for PFCs in soil and groundwater are not conducted as part of this limited field investigation, it remains an unresolved data gap.
See site file for additional information.
|
Louis Howard |
| 2/26/2018 |
CERCLA ROD Periodic Review |
There is uncertainty regarding potential exposures to PFAS contamination at SS044 and the Ruff Road Fire Training Area AT029 (formerly a source area for OU A) which needs to be addressed prior to the next Five-Year Review (2023). |
Louis Howard |
| 6/14/2018 |
Offsite Soil or Groundwater Disposal Approved |
Staff granted approval for contaminated soil to be transported to Columbia Ridge Landfill in Arlington OR. |
Louis Howard |
| 9/17/2018 |
Document, Report, or Work plan Review - other |
A letter was sent regarding the 2018 ADEC tech memo which establishes drinking water action levels for six PFAS when detected in groundwater or surface water used for drinking at JBER. The tech memo establishes drinking water action levels for six PFAS when detected in groundwater or surface water used for drinking. These compounds, selected in accordance with the U.S. Environmental Protection Agency’s third Unregulated Contaminant Monitoring Rule (UCMR3) under the Safe Drinking Water Act, include: perfluorooctane sulfonate, also known as perfluorooctane sulfonic acid (PFOS), perfluorooctanoic acid, also known as perfluorooctanoate (PFOA), perfluorononanoic acid (PFNA), Perfluorohexanesulfonic acid (PFHxS), Perfluoroheptanoic acid (PFHpA), and perfluorobutane sulfonate (PFBS). Based on review of available information, DEC considers these six UCMR3 compounds to be hazardous substances under state law.
See site file for additional information. |
Louis Howard |
| 9/17/2018 |
Document, Report, or Work plan Review - other |
Staff sent a letter notifying Air Force of Action Levels for PFAS in Water and Guidance on Sampling Groundwater and Drinking Water Technical Memorandum dated August 20, 2018. Action levels for UCMR3 PFAS compounds in groundwater and surface water used as drinking water are as follows: Where one or more of the PFAS compounds, PFOS, PFOA, PFNA, PFHxS, or PFHpA are detected in a water sample analytical result, the sum of the concentrations for all detected compounds will be compared to an action level of 0.07 µg/L. Where PFBS is present in a water sample analytical result, the detected concentration will be compared to an action level of 2.0 µg/L. Please note that all future sampling results for PFAS-impacted groundwater, surface water, and pore water must include results for all six UCMR3 PFAS compounds.
See site file for additional information.
|
Louis Howard |
| 1/18/2019 |
Update or Other Action |
Supplemental Remedial Investigation Report received. The RI is complete, and the site should move to an FS under the CERCLA process. PFAS have not been fully characterized at the site and are recommended for future investigation.
See site file for additional information. |
Louis Howard |
| 2/6/2019 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft supplemental remedial investigation. Main comments were to point out that by not sampling for polyfluoroalkyl substances (PFAS) at AT029, AFCEC is creating a data gap that will result in an interim Record of Decision (ROD) for non-PFAS contamination. The final selected remedy for ATO29 may not be the same as the selected remedy for the interim ROD for non-PFAS contaminants.
See site file for additional information. |
Louis Howard |
| 2/14/2019 |
Update or Other Action |
The Alaska Department of Environmental Conservation (ADEC) has reviewed & approved the final JBER Site Inspection (SI) Report dated May 20181 for Aqueous Film Forming Areas. In the SI are several new source areas that exceed cleanup levels in soil &/or groundwater/ surface water for Perfluorooctane Sulfonate (PFOS) & Perfluorooctanoic Acid (PFOA) as listed in 18 AAC 75 Tables B1 & C (as amended through October 2018). ADEC has had promulgated PFOA/PFOS cleanup levels since July 1, 2017.
AFCEC has stated numerous times that any further action for PFOA & PFOS cannot be initiated until 2020. As it is now February 2019, ADEC believes the timeline for action by AFCEC will be more likely to be in 2021 or later since no JBER PFOA/ PFOS sites have been validated by AFCEC. ADEC asserts these new PFOA/ PFOS source areas require additional investigation (e.g. remedial investigation) &/or remediation to comply with the Federal Facility Agreements (FFAs) for JBER-E 1991-Elmendorf Air Force Base) & JBER-R f 1994-Fort Richardson). ADEC believes AFCEC is out of compliance with the terms of the FF As for not scheduling & investigating PFOA & PFOS source areas in a timelier manner in accordance with CERCLA.
|
Louis Howard |
| 3/30/2020 |
Update or Other Action |
JBER sent list of sites that have been validated for future funding to investigate PFAS contamination at both JBER-E and JBER-R. They may be included in an end-of-year centrally-funded investigation. Right now, the scope is for a “PFAS General RI,” with an option of adding any installation-specific requirements later. Additionally, there may be end-of-year Expanded Site Investigations, and some of the other [JBER PFAS] sites that haven’t yet been validated may be included there.
JBER-E
SS135P C17 Debris Yard [AFFF Area #06]
SS136P Current AFFF Test Area [AFFF Area #07]
SS137P Corrosion Control [AFFF Area #08]
SS138P Current Fire Training Facility [AFFF Area #09]
SS139P Former AFFF Test Area [AFFF Area #12]
SS144P Hangar 5 Test Area [AFFF Area #18]
SS145P Hangar 6 [AFFF Area #19]
SS146P Hangar 10 [AFFF Area 21]
SS147P Hangar 16 [AFFF Area #22]
SS148P Hangar 17 [AFFF Area #23]
SS150P Cesna Crash Site [AFFF Area #26]
SS155P Hangar 18 [AFFF Area #24]
SS156P Hangar 8 [AFFF Area #20]
JBER-R
SS044P FTRS-044 [AFFF Area #05]
SS149P Ruff Road [AFFF Area #01] |
Louis Howard |
| 4/12/2021 |
Document, Report, or Work plan Review - other |
DEC submitted comments on Draft JBER Basewide UFP-QAPP dated February 2021. |
William Schmaltz |
| 5/19/2021 |
Document, Report, or Work plan Review - other |
DEC Reviewed and approved of Basewide Uniform Federal Policy - Quality Assurance Project Plan. QAPP summarizes general activities for a 5 year period on JBER. |
William Schmaltz |
| 5/28/2021 |
Document, Report, or Work plan Review - other |
DEC Approved of Final LTM and LUC Inspection Work Plan for select CERCLA sites dated May 2021. |
William Schmaltz |
| 7/2/2021 |
Document, Report, or Work plan Review - other |
Reviewed and provided comments on the Draft Phase I Remedial Investigation Management Plan/UFP-QAPP, dated May 2021. The document provides the Work Plan, Field Sampling Plan, and the Quality Assurance Project Plan for the Phase I Remedial Investigation (RI) for PFAS at JBER. |
William Schmaltz |
| 8/9/2021 |
Document, Report, or Work plan Review - other |
DEC staff reviewed and provided comments on Draft 2020 Land Use Control report for Select CERCLA sites dated June 2021. Report summarized LUC inspections performed in December 2020. Most sites were covered in snow and a full inspection could not be performed until spring 2021. DEC requested that the spring 2021 inspections are included in the 2020 report or as a separate cover because they are a continuation of the 2020 inspections and separate of the 2021 inspections. |
William Schmaltz |
| 4/20/2023 |
Document, Report, or Work plan Review - other |
DEC reviewed and provided comments for the 2021 Annual Remedial Action-Operations and Long-Term Management Report for Select CERCLA Sites, Draft, dated December 2023. The report describes the site inspections, maintenance activities, and groundwater monitoring, at multiple sites located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. Site inspections and sampling were recommended to continue for all applicable sites to ensure that conditions remain protective of human health and the environment. |
Ginna Quesada |
