| Action Date |
Action |
Description |
DEC Staff |
| 7/2/1998 |
Update or Other Action |
UST Decommissioning and Site Assessment-STMP 476 heating oil tank at Building 26282 (Formerly building 52-651). Five soil samples were collected from the excavation when the UST and
associated piping were removed in 1997. Diesel range organics (DRO) levels in the soil was found at the bottom center of the excavation at 6.0 feet bgs to be 6,450 mg/kg and from the fill end of the UST at 6.5 feet bgs to be 9,150 mg/kg and at the south wall west at 5.0 feet bgs to be 3,730 mg/kg. Based on the assessment results additional assessment and remediation are required to attain ADEC level "B" cleanup goals.
These results exceeded the ADEC 18 AAC 75, Method Two cleanup levels of 250 mg/kg for DRO and 0.02 mg/kg for benzene. The sample from the stockpiled soil contained 6,730 mg/kg DRO and 0.0863 mg/kg benzene. Contaminated soil was transported offsite for thermal treatment. The excavation was backfilled with clean excavated soil and additional clean fill. |
Louis Howard |
| 2/28/1999 |
Update or Other Action |
STMP 476 SERA Phase VII ST703 Release Investigation Draft received. Seven soil borings were drilled from 6 to 12 feet bgs during the SERA Phase VII investigation in 1998. Two of the borings were completed as downgradient monitoring wells (703WL-01 and 703WL-02). A clay and silt layer encountered between 2 and 6 feet bgs may serve as a confining layer. One to three soil samples were collected from each boring and analyzed for GRO, DRO, and BTEX compounds. Select samples were analyzed for PAHs. DRO results ranged from 285 to 11,100 mg/Kg in four samples from 4 and 6 feet bgs, and tended to decrease with depth, suggesting the clay/silt layer may be restricting vertical migration.
Benzene results ranged from 0.0401 to 0.258 mg/Kg in three samples with the highest result
from approximately 10.5 feet bgs. Elevated GRO and DRO were not detected at this depth.
Naphthalene (21.6 J mg/Kg) was detected exceeding the cleanup level in the sample containing
the highest DRO result. The lower reporting limit for benzo(a)pyrene and dibenzo(a,h)anthracene (1.8 mg/Kg) exceeded the cleanup level (1 mg/Kg) in one sample. All other results were below cleanup levels. Groundwater samples were collected from the two new monitoring wells and analyzed for DRO, BTEX compounds, GRO, and PAHs. All results were below groundwater cleanup levels. |
Louis Howard |
| 11/8/1999 |
Update or Other Action |
Institutional controls in place to prohibit access to groundwater until MCLs are met. All invasive work at the site and installation of monitoring wells are run through the Environmental Restoration office prior to any work being done to ensure consistency with institutional controls and that work will not damage monitoring wells in place at the site.
No current receptors exist for the groundwater at the Base due to the institutional controls (ICs). As a requirement of previously signed RODs for Operable Units (OUs) at the Base, ICs have been established to restrict the use of the shallow aquifer in the outwash plain on Base for both SERA and CERCLA sites. These restrictions are enforced through the Base Comprehensive Plan (BCP).
Projects and other activities are reviewed during the planning stage to ensure compliance with the BCP. In addition, construction projects and other activities also undergo an environmental review. This review helps ensures compliance with groundwater use restrictions. |
Louis Howard |
| 2/12/2001 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft Basewide Annual Groundwater Report Draft, Elmendorf Air Force Base, AK, dated January 2001.
Figure 3-1 Groundwater Monitoring and Analysis Decision Guide Page 3-4
The assumptions to the figure state in item #3 that there are no regulatory requirements to sample a particular well or utilize a specific analytical method for a mandated period of time. ADEC disagrees. With regards to sampling frequency, 18 AAC 75.345(h) Groundwater and Surface Water Cleanup Levels states:
The department will require long-term monitoring if the department determines that monitoring is necessary to ensure protection of human health, safety, or welfare, or of the environment and if groundwater, surface water, soil, or sediment contains residual concentrations of a hazardous substance that exceed the applicable cleanup levels. If long-term monitoring is required under this subsection, a responsible person shall submit a plan and schedule for monitoring as part of the requirements for cleanup operations under 18 AAC 75.360. Unless otherwise approved by the department, a responsible person shall conduct monitoring quarterly for at least one year to establish the concentration trend. The department will evaluate the monitoring program yearly.
With regards to a specific analytical method being required, 18 AAC 75.355(d) Sampling and Analysis states: Among the analytical methods set out in EPA’s Test Methods for Evaluating Solid Waste, Physical/Chemical Methods (SW-846), as adopted by reference in (c) of this section, if there is more than one analytical method for a hazardous substance, a responsible person may select any of those methods with a practical quantitation limit less than the applicable cleanup level. If only one analytical method has a practical quantita¬tion limit less than the applicable cleanup level, that method must be used. Analysis for petroleum contamination must follow the Alaska methods for petroleum hydrocarbons referred to in Table 1 of the Underground Storage Tanks Procedures Manual, dated December 1, 1999, and adopted by reference.
ADEC requests the Air Force and US EPA discuss redoing the decision matrix for eliminating wells from the sampling program at the next joint meeting later on in the month of February. ADEC questions the validity of using only two sampling events to drop wells from the program if they are below MCLs during that time. See the three examples obtained from the report which casts doubt upon whether two events are long enough to ensure for no rebound of contaminant levels.
- At monitoring well OU6MW-67 the benzene levels were below the MCL during: 1997-1, 1997-2, 1998-1, and 1998-2 sampling events, which would have lead to this well being dropped. However, in 1999-1 and 1999-2 the levels of benzene rose to and remained at 12 ug/L in 1999-1 and 1999-2 time frame.
- At monitoring well OU6MW-49 the levels of trichloroethene (TCE) remained below the MCL of 5 ug/L during the following events: 1994-2, 11995-1, 1995-2, 1996-1, 1996-2, 1997-1, and 1997-2. However, in 1998-1 and 1998-2 TCE was detected at 5.81 ug/L and 6.1 ug/L respectively.
- Finally, at monitoring well ST20-03 benzene was detected below the MCL of 5 ug/L during the following events: 1997-1, 1997-2, 1998-1, 1998-2. However, benzene rose to 17.8 ug/L in 1999-2 was above the MCL at 13.3 ug/L.
ADEC suggests the total number of events be extended to a minimum of 6 (3 consecutive years) below MCL before considering a well eligible for removal from the groundwater monitoring program.
5.1.3 2000 MTBE Evaluation Pages 5-3 and 5-4
ADEC recommends the Air Force continue to monitor for methyl tert-butyl ether (MTBE) in the SERA Miscellaneous Sampling Program at monitoring well 703-WL-02 and drop monitoring for MTBE at all other wells.
Table 6-1 Conclusions and Recommendations by Program Area OU 6 Page 6-4
ADEC generally concurs with the conclusions discussed in this section. However, with regards to eliminating OU6MW-01 from the OU6 Program Area, ADEC cannot find the necessary information, which would support this conclusion. Table 4-18 states the well “no longer providing useful data for the OU 6 Program Area.” No description of what type of data is not being provided by this well is provided in the text.
Table 4-20 does not even list well OU6MW-01, but Figure 4-12 lists the well as being ND (Not Detected) for benzene and TCE in rounds 1 and 2. Finally, in Figure 4-13 Benzene trends and Figure 4-14 TCE trends, there is no listing of well OU6MW-01 ADEC requests additional information be provided describing what the detection levels are during the monitoring events to further justify removing the well from the monitoring program. |
Louis Howard |
| 7/11/2001 |
Cleanup Plan Approved |
Staff approved a cleanup plan to remove and transport soil from the site to Alaska Soil Recycling for thermal treatment and disposal or return to Elmendorf AFB for disposal. |
Louis Howard |
| 1/31/2002 |
Update or Other Action |
ST703 Removal Action Report received. A total of 249 tons of soil were excavated and transported to ASR for thermal treatment. Petroleum impacted wood debris was encountered in the excavation. This material was transported to the Anchorage Regional landfill for disposal. Contaminated soil excavation was limited to 6 to 12 inches into the clay layer to protect the integrity of the clay layer. This precaution was taken due to the proximity of Green Lake and the bottom of the excavation was at or below the water elevation of Green Lake. Contaminated soil remains at the site (6' 4,850 mg/kg DRO). |
Louis Howard |
| 7/28/2002 |
Enforcement Agreement or Order |
ADEC (CS Program S. Bainbridge, Leslie Pearson PER Program) and Air Force (Daniel Barnett) signed the Operational Agreement (OA) concerning presumptive remedies for cleanup of certain petroleum oil and lubricant releases on the outwash plain portion of Elmendorf AFB, Alaska. This OA establishes and describes pre-approved presumptive remedies but does not establish an exclusive set of cleanup options and nothing in the memorandum prohibits EAFB from seeking or obtaining ADEC approval to implement alternative release response and remedial action plans.
For new POL spills in the outwash plain that occur in areas with no operational restrictions or interference from surrounding structures, ADEC approves immediate remediation of contaminated media after free product has been recovered in a manner that minimizes the spread of contamination into an uncontaminated area by using containment, recovery, disposal techniques appropriate to site conditions. The presumptive remedy for new POL spills on the outwash plain consist of excavation, treatment, and disposal of all impacted soil.
On a case-by-case basis, ADEC will evaluated the need for recovery of free product from the water table. Finally groundwater monitoring and ICs placed on the shallow aquifer restricting its use as a drinking water source will be required until such a time that the appropriate groundwater remedial goals are met. If additional institutional controls are required, these controls will be developed by EAFB in consultation with ADEC.
The OA does not apply to spills impacting surface waters. Nothing in the OA relieves, extends or changes the applicable requirements of 18 AAC 75 and 78 for the proper treatment, storage or disposal of contaminated media that result from the implementation of this OA. |
Steve Bainbridge |
| 6/29/2004 |
Site Added to Database |
DRO. |
Sarah Cunningham |
| 6/30/2004 |
Update or Other Action |
Remaining contaminant concentrations in the soil exceed the ADEC 18 AAC 75 (January 2003) cleanup levels at this site. Monitored natural attenuation was selected because DRO contamination is present in a clay layer approximately 5 to 6.5 feet bgs and benzene contamination was detected in the "smear zone" (The smear zone is defined as the range of depths within which the groundwater will fluctuate under normal seasonal conditions, and therefore, in which free product would move and “smear” the soil in response to these seasonal changes in the water level elevation. The smear zone soils may therefore be saturated or unsaturated with groundwater at any given time.). The impermeability of this clay layer retards the mobility of the contaminants. Additional excavation is not recommended because removal of the clay layer could allow contaminants to migrate to a more permeable layer below the clay. The groundwater monitoring well 703WL02 will be utilized to monitor for potential groundwater impacts during implementation of the remedy. This well is located down-gradient of the contaminated soil and will be sampled annually for DRO and benzene to determine if contamination is migrating towards Green Lake. |
Louis Howard |
| 6/30/2004 |
Update or Other Action |
ADEC has reviewed the documents associated with ST703 and concurs the site will not require any further remediation or site investigation; however, groundwater monitoring will have to be conducted at the site. In the event the remaining contaminated soil becomes accessible by construction, or other information becomes available which indicates that the site may pose an unacceptable risk to human health, safety, welfare or the environment, the Air Force will be required under 18 AAC 75.300 to notify ADEC. Also, any transport or disposal of contaminated soil excavated from the site requires approval from ADEC in accordance with 18 AAC 75.325(i). The Base Master Plan needs to be updated to document the locations of residual contamination and the need to properly manage contaminated soil at ST703.
ADEC is basing its decision on the most current and complete data provided by the Air Force. ADEC reserves its rights, under: 18 AAC 75 Oil and Other Hazardous Substances, Pollution Control regulations and AS 46.03 to require additional investigation, cleanup, or containment if subsequent information indicates: 1) additional contamination remains at the site which was previously undiscovered and presents an unacceptable risk to human health, safety, or welfare, or the environment; or 2) the information provided was invalid, incomplete, or fraudulent. |
Louis Howard |
| 7/23/2004 |
Site Ranked Using the AHRM |
site ranked by project manager since it was not ranked before. |
Louis Howard |
| 7/26/2004 |
Update or Other Action |
The groundwater monitoring well 703WL02 will be utilized to monitor for potential groundwater impacts during implementation of the remedy. This well is located down-gradient of the contaminated soil and will be sampled annually for DRO and benzene to determine if contamination is migrating towards Green Lake.
The Elmendorf AFB Basewide Groundwater Monitoring Program will no longer exist after this year. Please confirm that your contractor will be monitoring the wells specified in the closure document submitted for this site and that the zone project manager is aware that the monitoring requirements for the compliance wells may be different than what is being required for under the CERCLA program.
For the site known as ST703, the Department will require sampling for DRO and BTEX in the well identified above.
|
Louis Howard |
| 2/18/2005 |
Update or Other Action |
February 18, 2005 list of sites sent which includes ST703. Well ID 703WL-02 will be sampled on an annual basis for BTEX and DRO. Each well presented in the table submitted will be sampled in 2005 to establish baseline COC concentrations. Proposed sampling frequencies would thus take effect in 2006. An annual sampling frequency has been assigned to sites near the OU5 Bluff whereas all other sites received a biannual frequency. |
Louis Howard |
| 7/6/2006 |
Update or Other Action |
2005 Annual Report Monitored Natural Attenuation of Basewide Compliance Program Wells received. Currently, the 3 CES/CEVQ is required by ADEC to monitor the degree to which certain regulated contaminants are naturally attenuating on 27 sites throughout the Base. The natural attenuation of each of these sites is being monitored by sampling and analyzing the groundwater under the contaminated areas and/or downgradient of the contaminated source.
In 2001, soil at ST703 contained DRO contamination above Method Two cleanup levels. In 2005, groundwater at monitoring well 703WL-02 did not have detectable concentrations of DRO
or BTEX. Well 703WL-02 is located downgradient of the ST703 site towards Green Lake. |
Louis Howard |
| 6/20/2007 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the 2006 Annual Report Monitoring of Compliance Program Sites, Elmendorf Air Force Base (EAFB) dated May 2007. ADEC concurs with the recommendations to sample 703MW-IN for diesel range organics (DRO). |
Louis Howard |
| 7/5/2007 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft Work Plan and Field Sampling Plan Compliance Program Sites, Elmendorf Air Force Base (EAFB) dated June 27, 2007. For ST703 the following wells will be monitored: 703MW-IN and 703WL-02 for BTEX, DRO, and PAHs.
ADEC has developed a technical memorandum and a Laboratory Data Review Checklist (checklist) summarizing the minimum requirements for both laboratory data packages and quality assurance (QA) summaries (data reduction, verification, evaluation, etc.). All reports submitted by the Air Force which contain analytical laboratory sample results shall contain a completed checklist and a QA summary. The latest checklist is available online at http://www.dec.state.ak.us/spar/guidance.htm#csp and must be completed, signed and dated by the firm submitting the report to ADEC. It is not to be completed by the analytical laboratory that performed the sample analysis. The summary must be included as a specific text section of the report. All laboratory results, including laboratory quality control (QC) sample results, must be reviewed and evaluated for quality, validity and usability. The text must include any effects on data validity and/or usability due to field sampling/laboratory quality control discrepancies.
Upon incorporation of comments regarding the checklist, ADEC will approve the work plans. |
Louis Howard |
| 5/20/2009 |
Update or Other Action |
Groundwater monitoring well 703MW-IN was sampled and analyzed by an analytical laboratory for DRO and BTEX compounds. No constituents were detected above method detection limits (MDLs) in the sample. In accordance with the Air Force and ADEC-approved FSP (USAF, 2008d), a total of three soil samples were collected from each soil boring. Samples were collected at 6 feet bgs, 7.5 feet bgs, and 9 feet bgs from each boring. The samples were submitted for laboratory analysis for GRO, DRO and BTEX compounds. Two of the samples were also submitted for laboratory analysis of PAHs.
The DRO concentration in the sample collected at 6 feet bgs from the first borehole (703-08SB-
01) exceeded the cleanup level. The reported concentration of 364 mg/Kg exceeded the ADEC
Method 2 cleanup level of 250 mg/Kg. No GRO, BTEX constituents, or PAHs were reported with concentrations above cleanup levels.
Because DRO concentrations in soil are not below cleanup levels, annual sampling for DRO
should continue at the in-source well 703MW-IN. It is recommended that soil samples be
collected at this site again in 5 years to determine if contaminant concentrations have been
remediated to below cleanup levels. |
Louis Howard |
| 4/15/2010 |
Update or Other Action |
2009 Annual Report for monitoring of compliance program sites received. Elmendorf AFB site ST703 is located in the northern portion of the Base adjacent to former Building 26282, the Green Lake Cabin. ST703 is the former location of an unregulated 1,000- gallon steel UST used to store heating oil. The UST and associated piping were removed in July 1997.
Groundwater monitoring well 703MW-IN was sampled using the approved procedures provided
in the 2008 Final Work Plan (USAF, 2008b). A field duplicate sample was also collected. The
samples were supposed to be collected for DRO analysis; however, an error was made by the
contractor and the samples were collected and submitted for BTEX compounds instead. No
BTEX compound concentrations were detected above laboratory MDLs in the samples.
Soil samples collected in 2008 confirmed that vadose zone soil at ST703 continues to have DRO
concentrations above cleanup levels (EL-A201201 4,850 mg/kg DRO). In 2006 through 2008, groundwater from the in-source monitoring well 703MW-IN did not have concentrations of DRO above cleanup levels.
The 2008 Annual Report (USAF, 2009c) and 2008 Closure Sampling Summary Report (USAF,
2009b) recommended that soil sampling be collected again in 2013 to determine if contaminant
concentrations have been remediated to below cleanup levels. ADEC subsequently concurred
with the recommendation (ADEC, 2009a). This is still recommended. Annual sampling of DRO
from well 703MW-IN should also continue. Once all groundwater and soil contaminant
concentrations are below cleanup levels, this site should be considered for “Cleanup Complete”
status. |
Louis Howard |
| 3/16/2011 |
Update or Other Action |
Draft Annual Report Monitoring of Compliance Restoration Program Sites received. Groundwater monitoring well 703MW-IN was sampled. The sample was analyzed by an analytical laboratory for DRO. DRO concentrations were not detected above laboratory MDLs in the sample.
Conclusions
Soil samples collected in 2008 confirmed that vadose zone soil at ST703 continues to have DRO '
concentrations above cleanup levels (EL-A201201 4,850 mg/kg DRO). In 2006 through 2008 and 2010, groundwater from the insource monitoring well 703MW -IN did not have concentrations of DRO above cleanup levels.
Closure soil samples are programmed to be collected in 2011 to determine if contaminant
concentrations have been remediated to below cleanup levels. If soil sample results are below
cleanup levels, this site should be considered for "Cleanup Complete". status. If soil sample
results are not below cleanup levels, annual sampling of DRO from well 703MW -IN should
continue. |
Louis Howard |
| 4/26/2012 |
Update or Other Action |
2011 Annual Report for Compliance Restoration Program Sites received.
Groundwater monitoring well 703MW-IN was sampled using the approved procedures provided
in the 2011 Work Plan (USAF, 2011f). The sample was analyzed by an analytical laboratory for
DRO. The concentration of DRO in the sample did not exceed the cleanup level.
Soil samples collected in 2008 confirmed that vadose zone soil at ST703 continues to have DRO
concentrations above cleanup levels. In 2006 through 2008 and 2010, groundwater from the insource monitoring well 703MW-IN did not have concentrations of DRO above the cleanup level.
During annual monitoring in 2011, the concentration of DRO in the sample collected from well
703MW-IN was again below the cleanup level. No changes are being recommended to compliance monitoring at this site due to the 2012 PBC. |
Louis Howard |
| 1/9/2013 |
Update or Other Action |
Draft SC work plan for CG523-ST703 received.
Laser-induced fluorescence LIF technology will be used to help identify the horizontal & vertical extent of petroleum hydrocarbon contamination at the site. In practice, fiber optic cables are used to transmit the laser light from a laser at the ground surface to a window in the tip of direct push drill rods.
The LIF:
• responds only to aromatics present in non-aqueous phase liquid (NAPL) in the site soil & groundwater;
• uses four different wave lengths to help discern the character of the hydrocarbon (gasoline, jet/ diesel, residual range) encountered in the soil;
• provides continuous, real-time data on petroleum contamination at rate of about one reading per inch of downward push; &
• can be used to probe several hundred lineal feet per day.
These features make the LIF tool well suited to identifying the extent of contaminated soil source areas.
After the NAPL contaminated soil source area is delineated, focused confirmation soil sampling will be conducted. Sampling conducted inside the source area will focus on contaminated soils at high percent reference emitter (%RE) areas. Samples collected for PAH, EPH & VPH analysis will be at these areas only.
Samples collected outside the source area will focus on assessing the down gradient extent of the smear zone. These samples will be collected for DRO & BTEX only. Downgradient confirmation samples will be collected from the zone of seasonal water table fluctuation, at one location outside the down gradient limit of the source.
Approximately three to five soil borings will be advanced depending on the LIF results & two to three soil samples will be collected from each boring. Each of the soil borings will be drilled to the depth between 10-13 ft bgs & soil will screened using a PID for the presence of hydrocarbons at 2-ft intervals. Soil borings will be advanced using a direct-push, hollow-stem auger, or rotosonic drill rig in accordance with SOP-15.
The exact soil sample intervals will be adjusted based on the type of sampling device used & on field conditions. Soil cores will be examined for evidence of hydrocarbons (e.g., staining or odor) & will be screened for organic vapors using a PID.
Lithologic descriptions, observations of staining or odor, & the results of field screening with the PID will be recorded on borehole log forms in accordance with the procedures in SOP-18. Discrete soil samples will be collected using the methods described in SOP-16. Split-spoon sampling will be conducted, & field screening for petroleum hydrocarbons, using headspace organic monitoring, will be performed in accordance with SOP-16.
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 & vac truck may be used to clear the upper 6 ft of the proposed drilling location prior to drilling or conducting other invasive activities.
Once clearance activities have been completed in the upper 6 ft 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.
Specific lab methods, bottle requirements, field preservation requirements, & sample volumes for these analyses are provided in WS #19. QA/QC samples will be collected as specified in WS #20. Sample handling will follow procedures listed in SOP-02 & SOP-07.
GROUNDWATER SAMPLING
If the LIF investigation confirms that the existing monitoring well are in & downgradient of the source, then the existing GW data will be used for the HRC calculation. The GW from monitoring wells 703MW-IN, 703WL-01 & 703WL-02 will then be sampled, & analyzed for BTEX, GRO, DRO, RRO, PAH’s, EPH & VPH to complete the HRC data set.
If existing well (703MW-IN) is not within the source area & the new source is discovered, then one monitoring well will be installed within the new source area. Additionally, if the two downgradient wells (703WL-01 & 703WL-02) are not located downgradient, then at least one monitoring well will be installed downgradient of the source.
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 WS #19 in Draft JBER Basewide UFP-QAPP. QA/QC samples will be collected as specified in WS #20. Sample handling will follow procedures listed in SOP-02 & SOP-07 |
Louis Howard |
| 1/30/2013 |
Document, Report, or Work plan Review - other |
Staff reviewed & commented on the draft UFP-QAPP for ST703
Potential Receptors & Exposure Pathways
Page 14
1st Paragraph
The text states: “In addition, the site must meet the 18 AAC 75 “migration to GW” criteria, which indicates that the dissolution (leaching) of chemicals from soil will not cause GW to exceed 18 AAC 75 Table C ingestion risk based levels.”
ADEC requests JBER also state that the vadose zone soils shall not exceed MAC for petroleum contamination for soil from 0 – 15’ bgs (i.e. direct contact for BTEX, PAHs & 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 above Table C cleanup levels. This comment applies to all future UFP-QAPPs submitted by JBER for review by ADEC.
3rd Paragraph
The text states: “There are no drinking water wells in the shallow GW at this time.”
ADEC requests JBER provide information (e.g. location & well construction) on the nearest (within ½ mile of ST703) 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.
Table 10-1 Historic Soil Data
ADEC requests JBER include the 1997 & all of the 1998 soil data in the table.
UST Decommissioning & Site Assessment-STMP 476, Building 52-651 (February 1998) exceedances:
97ELMGL002SS (Fill End): Benzene 0.127 mg/kg, diesel-range organics (DRO) 9,150 mg/kg.
97ELMGL001SS (Bottom Center): Benzene <0.065 mg/kg, DRO 6,450 mg/kg
97ELMGL005SS(South Wall West-confirmation): Benzene 0.159 mg/kg, DRO 3,730 mg/kg
97ELMGL006SS(Bottom East-confirmation): Benzene <0.053 mg/kg, DRO 511 mg/kg
STMP 476 SERA Phase VII ST703 Release Investigation Report Final Draft (February 1999) exceedances:
703BH01: 5’ bgs Benzene (0.284 mg/kg) U, DRO 285 mg/kg
10’ bgs: benzene (0.0346 mg/kg) U
703BH02: 4.5’ bgs Benzene 0.0401 mg/kg, DRO 5,680 mg/kg
703BH04: 5’ bgs Benzene 0.16 mg/kg, DRO 11,100 mg/kg,
6’ bgs Benzene (0.0518 mg/kg) U, DRO 3,350 mg/kg,
10.5’ bgs Benzene 0.258 mg/kg
703BH05 6’ bgs Benzene (0.0426 mg/kg) U
Table 10-2 Historical PAH Soil Data
703-08SB-02
1-Methylnaphthalene at 7.22 mg/kg is above the Table B1 Method 2 migration to GW cleanup level of 6.2 mg/kg. 2-Methylnapthalene is above the Table B1 Method 2 migration to GW cleanup level of 6.1 mg/kg. Both of these values shall be BOLDED to show they exceed the applicable cleanup levels.
WS #15 Project Action Limits & Lab-Specific DLs/QLs
Lab Specific DLs/QLs for the contaminants proposed for analysis were not included with ST703. The example & referenced reporting limits included in the Draft Basewide UFP-QAPP are insufficient if Test America (Sacremento, Seattle & Anchorge), Applied Sciences Laboratory (ASL) are not chosen for this project.
Please be aware that the ADEC approval expires for TA Seattle, WA (UST-011) on March 14, 2013, TA Anchorage (UST-067) approval expires on June 16, 2013 & CH2M Hill Applied Sciences Lab Corvalis, OR (UST-079) approval expires on August 29, 2013. JBER is responsible for ensuring that any analyses conducted for this project will be performed by a lab with current ADEC approval.
ADEC requests JBER submit the information (also include ADEC’s approval letter for the methods, matrices, & dates for which the lab has approval) with the next revision of this site-specific UFP-QAPP, if it has selected a specific laboratory for this project. If ASL is chosen, then please state here & elsewhere in the work plan that ASL is the CH2M Hill-Corvalis Laboratory (UST-079). This comment applies to all UFP-QAPPs submitted for agency review.
WS #17 Sampling Design & Rationale
2nd Paragraph
The text states: “If the site conditions meet the ADEC risk standard, then a “cleanup complete without ICs” determination will be requested. If the site poses an unacceptable risk, then remedial options that address the compounds & exposure routes that contribute most significantly to the cumulative risk will be evaluated & remediation &/or, ICs & engineering controls may be used to manage the risk.”
See comment above on Potential Receptors and Exposure Pathways 1st paragraph.
ADEC requests JBER change the text to state: “If the site conditions meet the ADEC risk standard, then a “cleanup complete without ICs” determination will be requested. If the site poses an unacceptable risk, or exceeds Table C for GW contamination or soil contamination is above maximum allowable concentrations, then remedial options that address the compounds & exposure routes that contribute most significantly to the cumulative risk will be evaluated & remediation &/or, ICs & engineering controls may be used to manage the risk.” |
Louis Howard |
| 4/30/2013 |
Update or Other Action |
Draft Annual Report for Monitoring of State Regulated Sites received.
CG523 is the former location of an unregulated 1,000-gallon steel UST used to store heating oil.
Most recently, soil samples collected from borings advanced within the source area in 2008 indicate that DRO concentrations continue to exceed cleanup levels in the soil at CG523. GRO, BTEX compounds, and polycyclic aromatic hydrocarbons (PAH) were not detected above cleanup levels in the samples. Current monitoring requirements at Site CG521 include annual groundwater sampling for DRO at groundwater monitoring well 805WL-01.
Additional investigation to characterize the current presence/absence of soil contamination is being proposed for CG523 in 2013 under the new PBR contract (Draft CG526 – ST703 Site Characterization Work Plan USAF, 2013c). No changes to the annual monitoring are being proposed for this site. |
Louis Howard |
| 5/20/2013 |
Document, Report, or Work plan Review - other |
ADEC has received the final version of the UFP-QAPP SC Work Plan for CG523 ST703 Bldg. 26282 (ADEC CS DB Hazard ID 2786) on JBER-Elmendorf on May 17, 2013. ADEC has reviewed the document and has no further comments on it. The document is approved. |
Louis Howard |
| 3/13/2014 |
Update or Other Action |
Draft 2013 Annual report received for review and comment.
The overall project objectives included collecting sufficient data to:
• Monitor concentrations of contaminants of concern (COCs) at each site with sufficient
precision and accuracy to evaluate their concentrations with respect to cleanup goals.
• Identify potentially toxic and/or mobile transformation products.
• Verify individual plume characteristics, such as downgradient, lateral, or vertical expansion or retraction.
• Evaluate groundwater flow directions and hydraulic gradients to monitor plume migration and assess contaminant sources.
• Evaluate the effectiveness of land use controls/ institutional controls (LUCs/ICs) to
protect human health and the environment.
• Identify and repair damaged monitoring wells to protect groundwater.
• Identify monitoring wells that are no longer needed or are damaged beyond repair.
DRO 703MW-IN 29 ug/L (Table C 1,500 ug/L).
The ADEC site status for CG523 is “Cleanup Complete with ICs.” Site monitoring well
703MW-IN has met the 18 AAC 75 Table C cleanup criteria for more than three consecutive
annual rounds of groundwater sampling.
Additional investigation to characterize the current nature and extent of soil and groundwater
contamination at CG523 was also performed during 2013 under the JBER PBR contract. A site
characterization report has been prepared under separate cover. Recommendations for the site,
including any changes to the sampling program are provided in the site characterization report. |
Louis Howard |
| 5/28/2014 |
Update or Other Action |
Draft SC Report received for review and comment.
The data set for CG523 supports the following conclusions:
• The existing data show that NAPL has infiltrated to approximately 6.5 feet bgs. Contaminated soils within the vadose zone have largely been removed by excavation. Saturated zone soils are interpreted in the source area to contain NAPL.
• The existing data show that diesel fuel releases have resulted in smear zone contamination source over an area approximately 80 feet long and 50 feet wide. NAPL source extends through the zone of seasonal water table fluctuation.
• The fuel is interpreted to have infiltrated to the water table within the source area. The NAPL is interpreted to have spread laterally on the water table to a width of 50 feet and migrated the length of approximately 80 feet, not extending downgradient to Green Lake. The NAPL has been smeared through the zone of seasonal water table fluctuation over this footprint area.
• The average and 95% UCL DRO concentrations within the NAPL source area are approximately 3,180 mg/kg and 6,164 mg/kg, respectively.
• Groundwater samples collected from monitoring wells located in the NAPL contaminated soil source area and screened across the water table are below 18 AAC 75 Table C cleanup levels.
• No visible staining of surface soils, odors, or stunted vegetation was noted at the site during the site characterization field investigation. There is no significant surface water runoff or sediment transport from the site to surface water bodies.
• The carcinogenic cumulative risk and noncarcinogenic cumulative risk posed by the individual indicator compounds meet the ADEC risk standard, assuming a residential land use scenario.
• The risk posed by the GRO, DRO, and RRO aromatic and aliphatic surrogate fractions meets the risk standard for each exposure pathway, assuming a residential land use scenario.
• Existing site conditions meet risk-based migration to groundwater criteria.
• The site meets ADEC qualitative ecological/environmental risk criteria in that there were no observed environmental impacts from soil staining, impacted vegetation, surface water or sediment runoff. Additionally, groundwater from the site meets the total aromatic hydrocarbon (TAH) and total aqueous hydrocarbon (TAqH) ambient water quality criteria. The Ecoscoping Form indicates that a more in-depth risk evaluation is not needed and that the CG523 site conditions are protective of the environment.
Recommendations
Based on the HRC calculations and compliance with environmental criteria, it is recommended that the ADEC grant Site CG523 at JBER a “Cleanup Complete” determination. Institutional Controls do not appear to be applicable at this site. Following ADEC concurrence with this conclusion, groundwater monitoring of the site should be terminated and the existing monitoring wells at the site should be decommissioned. |
Louis Howard |
| 6/25/2014 |
Cleanup Complete Determination Issued |
Cleanup complete determination given.
The site consists of the former location of an unregulated 1,000-gallon steel UST used to store heating oil. The UST and associated piping were removed in July of 1997. The UST decommissioning assessment and subsequent site investigations show that fuel hydrocarbons remain in the soil and groundwater at CG523. Petroleum hydrocarbon contamination, primarily DRO, is likely the result of spills and leaks from the tank and associated piping.
Contaminants of Concern
Diesel Range Organics (DRO)
Gasoline Range Organics (GRO)
Cleanup Levels
The cleanup level for soils at CG523 containing DRO contamination is 10,250 mg/kg in the Under 40-inch Zone based on the ingestion pathway within the 0 to 15’ interval below ground surface (bgs). The cleanup level for soils at CG523 containing GRO contamination is 1,400 mg/kg in the Under 40-inch Zone based on the ingestion, inhalation and maximum allowable concentration in the 0 – 15’ interval bgs.
Based on the analytical data for soil samples collected, groundwater samples collected, modeling using the Hydrocarbon Risk Calculator (HRC), residual GRO and DRO in soil at the site does not pose a migration to groundwater concern.
The estimated rounded cumulative cancer risk at CG523 for the current industrial and hypothetical residential exposure scenarios, across all exposure pathways, (1 x 10-6 and 2 x 10-6 respectively) is below the regulatory risk standard of 1 x 10-5 for petroleum hydrocarbons.
The estimated cumulative noncancer HI at CG523 for the current industrial and hypothetical residential exposure scenarios, across all exposure pathways, (0.0 and 0.0 respectively) is below the regulatory risk standard of 1. CG523 meets the ADEC risk criteria [18 AAC 75.325(g)] for petroleum hydrocarbons. The risk posed by the GRO and DRO aromatic and aliphatic surrogate fractions meets the risk standard for each exposure pathway, assuming a residential land use scenario.
An ecoscoping form was completed for CG523 and no observed surface soil staining, no impacted vegetation, no surface water or sediment runoff from the site. The ecoscoping form indicates that a more in-depth risk evaluation is not needed and that the CG523 site conditions are protective of the environment.
Based on a review of the environmental records, ADEC has determined that CG523 has been adequately characterized and has achieved the applicable requirements under the site cleanup rules. ADEC is issuing this written determination that cleanup is complete, subject to a future department determination that the cleanup is not protective of human health, safety, welfare, or of the environment [18 AAC 75.380(d)]. A “cleanup complete” designation will be entered for CG523 in the Contaminated Sites Database. |
Louis Howard |
| 6/26/2014 |
Institutional Control Record Removed |
Institutional Controls have been removed. |
Louis Howard |
