| Action Date |
Action |
Description |
DEC Staff |
| 11/4/1988 |
Update or Other Action |
A Resource Conservation and Recovery Act (RCRA) Part B permit application was submitted on November 4, 1988 for container storage and for the open burning/open detonation (OB/OD) of reactive wastes. The EPA and the State of Alaska issued a Notice of Deficiency (NOD) to the facility on May 26, 1989 for inadequacies in the facility's Part B permit application. The OB/OD Supbart X permit application was formally withdrawn on March 1, 1991. An OB/OD Closure/Post Closure Plan was submitted on March 19, 1991. As of June 12, 1991, the submitted plan has not been technically reviewed. |
Jennifer Roberts |
| 3/13/1991 |
Update or Other Action |
Closure Plan, Post Closure Plan & Financial Requirements
This section is submitted in accordance with the requirements of 40 CFR 270.14(b) (13). 270.14(b) (15-18), 264.110-264.115 & 264.178.
1. Closure plan (40 CFR 270.14(b) (13)
This plan identifies all steps that will be necessary to completely close the Fort Richardson [the Fort] open burn/open detonation (OB/OD) site. The Fort's Environmental Office will maintain a copy of the approved closure plan, & of all revisions to the plan. Revisions will be submitted for approval to the EPA Regional Administrator & the ADEC whenever any modifications are made to the existing equipment, structure, instruments or procedures related to the management of the facility or when required by regulatory changes.
a. Closure Performance Standard (40 CFR 264.111)
This closure plan is designed to ensure that the facility will not require further maintenance & controls after closure. It will minimize threats to human health & the environment upon completion of closure. All surface explosive material will be removed from the site at closure & the site will then be capped. Escape of hazardous waste or hazardous waste constituents will be monitored through use of monitoring wells. Leachate will be dealt with if it occurs.
b. Partial Closure & final closure Activities (40 CFR 264.115)
(1) There is no partial closure for this site.
(2) Certification that final closure of the hazardous waste treatment facility has been accomplished in accordance with the approved closure plan will be made by the owner & operator of the facility, as well as by an independent-registered professional engineer. The engineer will also be on hand during closure to ensure that this closure plan is followed. Certification of closure will be submitted to the Regional Administrator of the EPA & the ADEC. Submittal of certification will be made within 60 days of final closure.
c. Maximum Waste Inventory (40 CFR 264.112(b) (3))
At a maximum, 6000 lbs of hazardous waste were treated at this facility in one day. The facility was used 2-18 times per year. Burn & detonation residue were left at the facility after each use. The facility was cleared of visible surface contamination annually.
d. Closure Time
(1) Schedule for Closure (40 CFR 254.112(b)(6))
The Fort anticipates closure of this site upon approval of this plan. The c1osure will have to be coordinated with the Eagle River Flats study, due to the close proximity of the OB/OD area to the Flats.
Notification of intent to close will be sent 60 days before beginning final closure of the site to the Regional Administrator of the EPA & the ADEC. Final c1osure will be supervised & certified by an independent registered professional engineer. Table 1 presents an estimated closure schedule which gives an estimate of the total time required to close the facility & the time required-for intervening closure activities.
(2.) Extensions for Closure Time (40 CFR 264.113 (a) & (b))
A. No extension for closure time is anticipated. If, however, an extension would be necessary to properly close the OB/OD site, or, if it becomes inappropriate to complete closure in that time frame, then a petition would be sent at least 30 days prior to the effective closure period (s). The petition will be sent to the Regional Administrator of the EPA & to the ADEC Central Office. The petition would by definition demonstrate the need for more than 180 days to complete removal of all residual contamination.
B. The petition would also demonstrate that all steps to prevent threats to human health & the environment, including compliance with all applicable permit requirements, have & will be taken.
e. Any requests for a change in operating plans, facility design or the approved closure plan will be submitted in writing to the EPA Regional Administrator & the ADEC Central Office, & shall be in compliance with state & Federal Regulations.
TABLE 1
ESTIMATED CLOSURE SCHEDULE FOR OB/OD SITE ACTIVITY
1. Closure plan implemented 0 days
2. Conduct range clearance 1-7 days
3. Cap as a landfill 7-90 days
4. Dig monitoring wells 90-180 days.
5. Completion of Closure &, certification submittal 180 Days
f. Closure Procedures.
1. No additional ordnance will be accepted for treatment. The site will have all surface debris removed using EOD range clearance protocols. All unexploded ordnance will be blown in place.
2. Sampling of the wells will be conducted by trained personnel. The services of those personnel will be obtained at the time of closure notification through DOD contractual procedures.
3. The contractor who does the sampling & analytical testing will be required to:
a. Have an estab1ished QA/QC program that is consistent with the requirements of the EPA Test Methods for Evaluation Solid Waste, Physical/Chemical Methods. (EPA Office of Solid Waste, EPA Publication #SW-846), and;
See site file for additional information. |
Louis Howard |
| 6/12/1991 |
Update or Other Action |
June 12, 1991 RCRA HW Mgt. Compliance Evaluation Inspection Report.
It was peculiar to note that up until the April 29, 1990 inspection, Fort Richardson had never manifested any hazardous waste off-site that has been identified as exhibiting a toxicity
characteristic (TCLP) with any RCRA Waste Codes ranging from 0018 to 0043.
Ms. Scott stated that the open burning or open detonation of RCRA regulated waste is not done on Fort Richardson; that it ceased in 1988 and that all OB/OD is only done at Elmendorf Air Force Base. Thus no OB/OD units were physically inspected during the inspection. Although the facility has submitted a closure plan as required in Paragraph 22.E. of the FFCA, this OB/OD closure plan has not yet been technically reviewed for adequacy. |
Louis Howard |
| 5/29/1992 |
Update or Other Action |
Waterfowl Mortality in Eagle River Flats, Alaska The Role of Munitions Residues
Charles H. Racine, Marianne E. Walsh, Charles M. Collins, Darryl J. Calkins, Bill D. Roebuck & Leonard Reitsma May 1992 received.
Table 6. Certified Reporting Limits (CRLs) for water & soil analyses for explosive compounds.
CRL for soil ug/g & CRL for water ug/L
Analyte
HMX 2.15 ND*
RDX 1.03 0.36
TNB 0.24 051
DNB 0.12 0.17
Tetryl 0.65 ND
NB 0.11 0.12
TNT 0.24 0.15
2-Am-4,6-DNT 0.11 0.27
4-Am-2,6 DNT ND 0.34
2,4-DNT 0.07 0.16
2,6-DNT 0.16 0.22
O-NT 0.24 ND
P-NT 0.22 0.93
m-NT 0.25 ND
* ND =not determined
Spring analyses of sediments & water
Neither RDX nor TNT was detected in any of the 93 sediment & water samples with the field screening procedures. However, when the samples were analyzed in the laboratory by liquid chromatography, three sediment samples from the area next to the EOD were found to contain 2,4-DNT.
This contamination would not have been detected using the field screening procedure since it is optimized for RDX & TNT. Two samples contained only trace amounts (0.4-0.5 ug/g or mg/kg), while the levels in the third bulk sample varied with each subsample(0.61, 3.42, 4.82, 18.0 & 27.4 ug/g dry wt).
In addition this sample contained other compounds, including 2,6-DNT (0.03-0.89 ug/g), 2,4,6-TNT (0.15- 0.50 ug/g) & the TNT reduction products 2-amino-4,6 dinitrotoluene (0.05 ug/g - 0.47 ug/g) & 4-amino-2,6- dinitrotoluene (0.16 - 0.52 ug/g or mg/kg).
To reconfirm the presence of 2,4-DNT at the site, three additional samples were collected from the same location & shipped to CRREL in late June. Only trace amounts (O.O2 - O.4 ug/g) of 2,4-DNT were again found in these samples. (NOTE TO FILE: cleanup level for 2,4-DNT Migration to GW is 0.0093 mg/kg).
Fall analyses of sediments
Out of the 172 samples collected from the salt marsh, 62 were contaminated with 2,4-DNT. All of these samples were collected from along the base of, or in the salt marsh adjacent to, the EOD area.
In most samples with concentrations of 2,4-DNT greater than 1 ug/g, 2,6-DNT & TNT were also confirmed but at much lower concentrations. Also present in some samples were trace amounts of the TNT biotransformation products 2-amino-4,6-dinitrotoluene & 4-amino-2,6-dinitrotoluene.
In the fall, propellant grains were found scattered on the EOD pad & in one deep sediment sample “hole” in the adjacent salt marsh. The acetonitrile extracts of these propellant grains & the sediment samples containing the highest concentrations of 2.4-DNT were analyzed by GCMS.
Two munition compounds were found in ERF sediments:
2,4-DNT (a nitroaromatic compound) and white phosphorus (P4). We concluded from the extensive sampling that high explosives are not found in the water nor in surface sediments at ERR. The salt marsh immediately adjacent to the EOD area is contaminated, however, with propellants, as shown by the distribution of samples containing 2,4-DNT.
The source of this contamination was probably the demolition of propellants in the EOD area. The whole grains of propellant found on the EOD pad and in the adjacent salt marsh also suggest that incomplete demolition of these propellants contaminated both the EOD pad and the adjacent salt marsh. When these grains were extracted and analyzed by GCMS, the compounds found in the grain extract were identical with those found in the soil sediment extract.
This spatial variability in the concentration of 2.4-DNT within a frozen bulk sediment sample also indicates that the contamination is particulate in nature as opposed to a plume coming from a point source.
Although 2,4-DNT was found locally in the salt marsh up to 50 m from the edge of the EOD, several lines of evidence suggest that 2,4-DNT is not the cause of waterfowl mortality in ERF:
- The behavior of ducks dosed with 2,4-DNT in the laboratory was not consistent with that of sick wild ducks in ERF.
- 2.4-DNT has a relatively high acute dosage (1000 mg/kg of body weight). The highest concentration of 2,4-DNT found in ERF sediment was about 60 ug/g (cleanup level for MGW is 0.0093 mg/kg, 8.8 mg/kg direct contact). For a duck to consume a lethal dose, 17 kg of sediment would have to be processed.
- Methemoglobin, as indicated by blood color, was not visually obvious in any of the ducks autopsied in the field
- The area where 2,6-DNT was found is mostly tall sedge marsh with few ponds suitable for waterfowl habitat.
CONCLUSIONS
- Two sources of contamination, potentially toxic to waterfowl, were found in the ERF salt marsh and include 2,4-DNT (used as a propellant) and white phosphorus (used to produce smoke).
- 2,4-DNT is localized in its distribution in ERF and is found in the sediments of a tall sedge marsh adjacent to an explosive ordnance demolition site. Incomplete demolition of propellant grains on this EOD site is the probable source of this contamination. |
Louis Howard |
| 4/15/1993 |
Document, Report, or Work plan Review - other |
EPA letter to Army. Comments on Demolition area #1 (OB/OD Area). 1. Fort Richardson (through the AEHA) designed and implemented an inadequate scope of soil sampling which concentrated only on surface sampling and did not include detailed depth soil sampling (Section 3.12). OB/OD activities at this site were performed in craters as deep as 12-feet, with ground water surface being intersected at an average depth of eight-feet. The current scope of site characterization is inadequate to establish attainment of clean-closure standards.
2. The current scope of site specific soil (particularly subsurface soils) and ground water characterization is very limited and inadequate to support an objective decision making process. This is further compounded by having only analyzed for the presence of the five “most frequently detected” ordnance compounds instead of analyzing for a full suite of constituents of concern (COC), defined from the suite of ordnance compounds known to have been handled at this site.
3. No site speciftc studies of the subsurface geology or hydrology of the DEMO-l area currently known and the scope of fhe proposed site characterization activities are inadequate for filling the current data gap. The proposed activities do not support the installation and monitoring of a comprehensive ground water monitoring network that is capable of demonstrating attainment of clean closure standards. This represents anotber major deficiency of the current closure plan. |
Jennifer Roberts |
| 12/15/1993 |
Update or Other Action |
Demolition Area Number One Closure Guidelines prepared for USACE by EMCON Alaska Inc. Project 5117-072.00 The U. S. Army entered into a Federal Facility Compliance Agreement (FFCA) with the U. S. Environniental Protection Agency (EPA), Region 10, in 1991 to resolve hazardous waste management issues at a number of sites at Fort Richardson. Among other actions, Fort Richardson agreed to submit a closure
plan for its Demolition Area Number One (DEMO 1) site that had been used for
Open Burning/Open Detonation (OB/OD) of explosives. These guidelines serve
to satisfy that agreement.
The objective of these guidelines is to help bring the DEMO 1 solid waste
management unit into compliance with Fort Richardson’s FFCA and the regulations governing hazardous waste management promulgated under the Resource Conservation and Recovery Act (RCRA). The FFCA calls for
submittal of a closure plan for the OB/OD site. as stipulated in 40 CFR 265 Subpart G. For such closure plans, RCRA provides other guidelines, including 40 CFR 264.110-l 16, Subpart G, 40 CFR 264.600-603 Subpart X. 40 CFR 265.110-115 Subpart G. 40 CFR 270.14(b)(13), and 40 CFR 270.14(b)(15-18).
These guidelines fulfill the requirements of these and orher RCRA regulations that
are appropriate for closure of DEMO 1. In addition, these guidelines offer initial
recommendations for post-closure care, although the Army may develop a separate. more-detailed post-closure plan (40 CFR 264.118).
The purposes of the closure actions are to reduce the threat that hazardous wastes
at DEMO 1 may pose or. alternatively, to demonstrate the absence of a significant threat. A variety of explosive devices were destroyed on the gravel pad adjacent to Eagle River Flats for more rhan 30 years until operations were halted in 1988. Explosives Ordnance Disposal (EOD) staff had burned and
detonated materials from both military and civilian sources. Now, discarded metal parts and traces of explosives chemicals are still found in the surface soils of the pad. These guidelines describe the actions to prevent releases from the site that may have adverse effects on human health or the environment.
The current regulatory status of DEMO 1 is governed by Fort Richardson’s FFCA with the EPA, signed April 2, 1991. Items V.20.Q and.V.22.E in the FFCA (EPA ID Number AK1210022157) required five actions by Fort
Richardson regarding OB/OD activities. These required compliance actions now constitute the regulatory foundation for OB/OD activities at the site.
All OB/OD activities were to cease until Fort Richardson received permits for them. Fort Richardson was to formally withdraw the RCIU permit application or submit a revised application that incorporated the Notice of Deficiency (NOD) comments. Closure and post-closure plans were to be submitted in accordance with 40 CFR Part 265, Subpart G within 15 days of the FFCA’s effective date.
Those plans were to be implemented once they were approved by the EPA. Studies were to continue to determine whether hazardous constituents have been released into the environment. and the relevant findings were to be incorporated in the OB/OD closure plan.
At this time, Fort Richardson has partially fulfilled the requirements of the FFCA
regarding DEMO 1. First. OB/OD activities were halted in 1988. Second, the RCRA Part B permit application was withdrawn in 1991. Soil sampling has continued to determine whether hazardous waste constituents may have been
released from the site. These guidelines, incorporating relevant results of those studies, may be submitted in accordance with 40 CFR 264, Subpart G. Because DEMO l’s interim status was withdrawn, 40 CFR 264 should govern the closure, rather than 40 CFR 265.
Currently, Fort Richardson is without a RCRA permit for OB/OD activities. The EPA stated in its Notice of Non-Compliance (NON), issued to the U. S. Army on June 19, 1990, that OB/OD activities had not been covered in Fort Richardson’s Part A application. In the following year. Fort Richardson followed
that condition of the FFCA and withdrew the Part B application for an OB/OD permit. |
Jennifer Roberts |
| 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.
Proposed listing on NPL was 06/23/1993 and Final listing on NPL was on 05/31/1994.
There are certain source areas (RCRA "units”) at the Fort identified in the March 29, 1991 [Federal Facility Compliance Agreement] FFCA [RCRA Docket No. 1090-01-27-6001] between EPA & the Army (hereinafter "1991 FFCA”) that are subject to RCRA requirements including, but not limited to, interim status closure requirements found at 40 CFR Part 265.
The Army, EPA & ADEC agree that corrective action at the following units which were identified in the 1991 FFCA as subject to RCRA closure requirements will be addressed through CERCLA response actions at OUs under the terms & schedules specified in the FFA: under
1) OU-A: Building 986 [POL Laboratory];
2) OU-C; OB/OD [open burning/open detonation area];
3) OU-D: Buildings 700 [PCB Storage Site], 704 [Drum Storage Area], 35-752, 955 [DEH Sludge Bin], & Circle Road [aka Circle Drive Drum Storage Site].
RCRA requirements at these units shall be addressed through the CERCLA ARARs process specified in the FFA. RCRA public notice & public participation requirements for closure at these units shall be addressed during the CERCLA public notice process specified in the FFA & this Attachment at the time of issuance of the Proposed Plan for that particular OU.
In addition, if a "no-action” decision is made under the FFA & CERCLA for an OU which includes units subject to RCRA closure requirements, such units shall remain subject to RCRA closure & post-closure care requirements. The Region 10 RCRA program shall make a final determination whether further closure work under RCRA is necessary with respect to such units.
Remedial Investigation/Feasibility Study (RI/FS)
Roosevelt Road PCB site
Ruff Road Fire Training Area
Bldg. 986-POL lab.
Eagle River Flats Impact Area
OB/OD Area, Eagle River Flats
Parallel Track Activity
Certain potential source areas at Fort Richardson, identified in Table 1, will be addressed pursuant to a companion agreement entered into by the Army and the State of Alaska. Generally,
these areas are underground storage tanks and other source areas where there are suspected or known releases of petroleum, oil, and/or lubricants (POL).
By a date established by the Project Managers, and at least ninety (90) days prior to submittal of the last OU RI/FS Management Plan, the Army shall provide a report summarizing the
status of all source areas listed in Table 1 which have not previously been addressed in a ROD as well as any other source areas discovered during the investigation. Included within this
group of source areas will be those areas addressed in the companion agreement (which have not been addressed in earlier RODS).
The Project Managers shall review the report, determine what actions remain to be completed, (e. g. no further action, incorporate into a RI/FS, or continue with the two party action), and decide how best to implement those actions. The Army shall incorporate the Project Managers' decision into the last OU draft RI/FS Management Plan which as a primary document will be subject to dispute resolution (per Part XXI of the Agreement).
Site#: W025, Operable Unit: OUC Building/Location: Vicinity of Eagle River Flats, Site/Function: Open Burning/Open Demolition Area, Unit/Activity: Multiple Units/Activities, Potential Contaminants: Power bags, fuzes, TNT, Grenades, Rocket Motors, Projectiles, Ash, Status: RCRA Closure, 1990 RFA SWMU: 99, Notes & References: USATHAMA 1991 Property. |
Louis Howard |
| 2/17/1997 |
Site Added to Database |
Ordnance disposal. Site added by Shannon and Wilson, Inc. |
S&W-Miner |
| 5/15/1997 |
Site Characterization Report Approved |
Final Remedial Investigation Report approved. The findings documented in this report are based primarily on data collected before implementing the CERCLA process at OUC. The following are major findings for OB/OD Pad: 1. The groundwater is at a depth of 6 to 11 m below the surface, and the gradient is shallow, with groundwater moving toward
the southwest, toward ERF. Groundwater movement patterns are likely influenced by the tides and the river. 2. The site investigation detected only a limited number of organic
chemicals and metals in the soil and groundwater. In many cases, observed soil concentrations were similar to reference area values. 3. The OB/OD Pad will meet clean closure requirements. The detected chemicals were all considerably below their clean closure
action levels. 4. The ecological and human health risk assessments found very low risks associated with exposures to these chemicals at the measured concentrations.
At OB/OD Pad, the USARAK should proceed with clean closure in accordance with the requirements in the closure guidance from
Title 40 of the Code of Federal Regulation, Part 264. The USARAK may consider the use of the ERF dredge spoils as cap material. |
Jennifer Roberts |
| 4/21/1998 |
Site Ranked Using the AHRM |
Ranking action added now because it was not added when the site was originally ranked. Suspected S&W oversight. |
Bill Petrik |
| 9/30/1998 |
Update or Other Action |
Record of Decision (ROD) was signed memorializing no further action under CERCLA decision. Institutional controls are in place to provide monitoring and control access to the site for addressing concerns about potential human exposure to unexploded ordnance. HOWEVER, RCRA (EPA-Region 10) is requiring closure plans be submitted if and when the ERF firing range is closed out by the Army. So the site is still considered open by the RCRA program.
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 |
| 12/14/1998 |
Update or Other Action |
Technical Memorandum outlining the OB/OD Interim Closure Plan Approach Document. Additional subsurface soil sampling will be required during closure activities at the OB/OD pad to determine if hazardous wastes remain onsite to support a potential clean closure. Soil concentrations found in 1996 Remedial Investigation showed no action levels were exceeded for residential exposure scenarios for contaminants of concern at the site (includes metals, explosive compounds). The calculated risks for adults and child receptors were about 1 x 10-7 at all sampling locations with Arsenic being the major contributor to risk. It is likely the greatest risk in any exposure scenarios come from potential explosions from unexploded ordnance. |
Louis Howard |
| 1/19/1999 |
Document, Report, or Work plan Review - other |
EPA commented on interim closure plan for EOD pad. RCRA requested additional documentation/sampling of groundwater and soils to show that no action levels for hazardous waste constituents are exceeded.
Army has subsequently withdrawn its closure plan for the site and will submit a final closure plan for the site when ERF range closes sometime in the distant future. |
Louis Howard |
| 2/22/2001 |
Document, Report, or Work plan Review - other |
EPA comment letter for RCRA Closure under the 1991 Fort Richardson FFCA. Fort Richardson submitted a draft interim closure plan in March 1999. EPA commented on the draft interim closure plan in letters dated April 28, 1998 and August 12, 1999. To date, USARAK has not adequately responded to EPA comment letters nor submitted a revised closure plan.
In order to be in compliance with the FFCA and the OU C ROD, USARAK must resubmit a revised interim closure plan for the OB/OD Pad which adequately addresses EPA's comments.
In summary, CERCLA actions conducted to date appear to be consistent with RCRA requirements. However, for five of the units, USARAK must supply additional documentation and/or conduct additional cleanup actions before these units can be considered closed in accordance with requirements of RCRA and the FFCA. In addition, USARAK must be responsive to EPA's previous comments and submit a revised interim closure plan for the OB/OD Pad at Eagle River Flats. |
Louis Howard |
| 12/12/2001 |
Institutional Control Record Established |
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 |
| 2/14/2003 |
Update or Other Action |
EPA sent letter regarding RCRA emergency permit EPA ID No. AK6 21002 2426 for the emergency detonation of fifty-three M79 trip flares currently in storage at the Ft. Richardson Ammunition Supply Point. The flares were noted to have deteriorated inner packaging and loose powder and primers and have been deemed "NOT SAFE" for shipment. The permit is valid for a two-week period and the emergency detonation is to be accomplished within a one-day timeframe. Treatment location: 40-90 Range, grid UC557995 (military map) expiration date 2/28/2003. |
Rich Sundet |
| 2/20/2003 |
CERCLA ROD Periodic Review |
Jennifer Roberts signed the five-year review document for ADEC. 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.
The RI conducted at the OB\OD Pad indicated that no concentrations of contaminants of concern above regulatory levels specified in the Operable Unit C RI/FS Management Plan have been discovered. In addition, the ecological and human health risk assessments completed during the RI indicate that the risks are very low. Therefore, no further action under CERCLA was selected.
The OUC ROD selected the remedial action under CERCLA, as well as the EPA decision under RCRA regarding closure of the OB\OD pad. The OB\OD pad is designated as a RCRA regulated unit and subject to closure under 40 CFR 265, Subpart G and P. The RPMs and EPA RCRA mutually agreed to delay final RCRA closure of the OB\OD pad until final clearance of the operating range.
The ROD stipulates that no less often than during the CERCLA 5-year reviews, the Army will evaluate the OB/OD area. Because the range has not been closed and Fort Richardson remains an active installation, the Army has determined that delayed closure will not affect the OB/OD area. The Army's evaluation concluded that ICs for the OB/OD area remain protective. No new RCRA or munitions rules/regulations specific to post-closure procedures for former OB/OD areas have been promulgated. Therefore the selected remedy remains protective.
The Record of Decision for Operable Unit C, p. 9-16, requires US Army Alaska (USARAK) to evaluate no less often than during the CERCLA Five-Year Review whether delay of closure of the OB/OD Pad is still viable. The ROD stipulates three conditions under which delay of closure is no longer viable: The Eagle River Flats impact area (ERF) is no longer operating; The post (Ft. Richardson, Alaska) is being closed; Any other reason.
As of the time of the current Five-Year Review (February, 2003), Ft. Richardson is an operational installation quartering a number of active military units including the 501st PIR, the 4/11th Field Artillery, among others. These active military units continue to use ERF as an impact area for artillery, mortar, and aircraft (fixed-wing and rotary) training. Institutional controls regarding the type of munitions used at the site, and regarding the time of year the range may be used are still in force.
USARAK has no other information or reason to suggest that delayed closure of the OB/OD Pad is not protective or viable. Next Five Year Review is in 2008. |
Jennifer Roberts |
| 2/20/2003 |
Conditional Closure Approved |
The RI conducted at the OB\OD Pad indicated that no concentrations of contaminants of concern above regulatory levels specified in the Operable Unit C RI/FS Management Plan have been discovered. In addition, the ecological and human health risk assessments completed during the RI indicate that the risks are very low. Therefore, no further action under CERCLA was selected.
The OB\OD pad is designated as a RCRA regulated unit and subject to closure under 40 CFR 265, Subpart G and P. The RPMs and EPA RCRA mutually agreed to delay final RCRA closure of the OB\OD pad until final clearance of the operating range. The ROD stipulates that no less often than during the CERCLA 5-year reviews, the Army will evaluate the OB/OD area. Because the range has not been closed and Fort Richardson remains an active installation, the Army has determined that delayed closure will not affect the OB/OD area. The Army's evaluation concluded that ICs for the OB/OD area remain protective. No new RCRA or munitions rules/regulations specific to post-closure procedures for former OB/OD areas have been promulgated. Therefore the selected remedy remains protective to require no further remedial action at this time. |
Louis Howard |
| 8/22/2003 |
Site Number Identifier Changed |
Changed Workplan from X1 to X2 to reflect presence of UXO as primary site concern. |
Louis Howard |
| 9/30/2005 |
Update or Other Action |
Perchlorate: Overview of Issues, Status, and Remedial Options Prepared by The Interstate Technology & Regulatory Council Perchlorate Team September 2005.
Highly soluble and mobile in water, perchlorate is also very stable. Most of the attention focused
on perchlorate contamination concerns groundwater and surface water contamination. However,
perchlorate can also contaminate soil and vegetation. The potential for perchlorate contamination
in drinking water and food supplies is a human health concern because it can interfere with
iodide uptake by the thyroid gland and, through this mode of action, result in decreased thyroid
hormone production.
NOTE 18 AAC 75 (January 2016) lists perchlorate cleanup level for under 40 Inch Zone Direct Contact 71 mg/kg and Migration to GW value of 0.067 mg/kg. Table C Groundwater cleanup level is 0.026 mg/L. EPA RSL THQ=1 lists ammonium/lithium/potassium/sodium perchlorate RSLs of 55 mg/kg residential 820 mg/kg commercial tapwater 14 ug/L.
All of the services within DoD have current and/or past weapon systems that contain perchlorate
in varying amounts. A 2001 DoD survey of weapons systems containing perchlorate listed 259
different munitions and related items such as fuzes, flares, illumination rounds, simulators,
grenades, etc., as well as 41 missile systems in the DoD Munitions Items Disposition Action
System (MIDAS) database. For example, current families of munitions containing perchlorate in
use by the Army include training simulators, insensitive munitions, smokes or obscurants,
pyrotechnics, grenades, signals and flares, and fuzes. Some types of simulators contain relatively
high perchlorate concentrations, as do most of those with solid rocket motors.
Prior to 1970, unused munitions were buried on ranges. Over long periods of time, corrosion
degrades the munitions casing, resulting in the potential release of incorporated perchlorate into
the environment. However, the potential for perchlorate release to the environment can vary greatly, depending on the length of use and the types and amounts of munitions disposed. For example, not all of the munitions contained any appreciable amount of perchlorate. In addition, the larger munitions that contained ammonium perchlorate would have been subject to OB/OD.
As more ranges are tested for perchlorate contamination, it seems likely that more contamination will be discovered over time. In addition to impact areas, burial areas, OB/OD areas, launching points for rockets and missiles, and missile test stands could also be areas of contamination potential.
Cold Regions Research Engineering Laboratory (CRREL) has conducted numerous studies led by Dr. Thomas Jenkins regarding the distribution of secondary explosives on active ranges. Secondary explosives are often dispersed as variously sized and shaped particles that slowly dissolve in precipitation because they are sparingly soluble and are wetted on only a periodic basis. They also possess low vapor pressures and hence do not volatilize to any extent.
Their distribution is typically very heterogeneous, and they are transported through soil only after they are dissolved in water. The primary difference between secondary explosives and perchlorate is the solubility. Given perchlorate’s greater solubility, it should be expected to migrate through the soil more readily even if it is initially distributed in particles. Until more data have been gathered, it would be prudent to conduct perchlorate sampling in soil based on the type of anticipated source. If the anticipated source is a detonation, composite sampling is recommended (Walsh et al. 1993; Crockett et al. 1996; Jenkins et al. 1996, 1997a, 1997b, 1997c, 2004; Thiboutot et al. 1997; Thiboutot, Ampleman, and Hewitt 2002.)
To detect perchlorate in the environment, analytical chemists use several techniques. As of the writing of this document, the only method that has been approved for compliance monitoring (UCMR 1) is USEPA Method 314.0. Method 314.0 is a presumptive method, and when perchlorate is detected for the first time in an environmental medium and this method is used, the presence of perchlorate should be confirmed using a determinative method. To confirm the presence of perchlorate in an environmental sample, it is preferable to use the analytical technique MS, which confirms the chemical composition of unknown ions by their molecular weight (mass-to-charge ratio).
As noted previously, some supplies of the laboratory detergents contain detectable levels of
perchlorate. Considering the potential bias from these detergents, laboratories using these products either directly or indirectly during perchlorate analysis should consider analyzing a diluted sample of the detergent to eliminate the potential for this bias. Use of disposable equipment for any sample manipulation is recommended to limit the potential for cross-contamination. |
Louis Howard |
| 8/31/2007 |
GIS Position Updated |
61.3186 N latitude -149.6989 W longitude |
Louis Howard |
| 2/22/2008 |
CERCLA ROD Periodic Review |
Second Five year review signed by Jennifer Roberts (ADEC). 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.
RCRA regarding closure of the OB\OD pad. The OB\OD pad is designated as a RCRA regulated unit and subject to closure under 40 CFR 265, Subpart G and P. The RPMs mutually agreed to delay final RCRA closure of the OB\OD pad until final clearance of the operating range. The ROD stipulates that no less often than during the CERCLA 5-year reviews, the Army will evaluate the OB/OD area. Because the range has not been closed and Fort Richardson remains an active installation, the Army has determined that delayed closure will not affect the OB/OD area. The Army's evaluation concluded that ICs for the OB/OD area remain protective. No new RCRA or munitions rules/regulations specific to post-closure procedures for former OB/OD areas have been promulgated. Therefore the selected remedy remains protective.
The Record of Decision for Operable Unit C, p. 9-16, requires US Army Alaska (USARAK)
to evaluate no less often than during the CERCLA Five-Year Review whether delay of
closure of the OB/OD Pad is still viable. The ROD stipulates three conditions under which
delay of closure is no longer viable: The Eagle River Flats impact area (ERF) is no longer operating; The post (Ft. Richardson, Alaska) is being closed; Any other reason.
As of the time of the current Five-Year Review (February, 2008), Ft. Richardson is an
operational installation quartering a number of active military units including the 501st
PIR, the 4/11th Field Artillery, among others. These active military units continue to use
ERF as an impact area for artillery, mortar, and aircraft (fixed-wing and rotary) training.
Institutional controls regarding the type of munitions used at the site, and regarding the
time of year the range may be used are still in force.
USARAK has no other information or reason to suggest that delayed closure of the OB/OD Pad is not protective or viable. |
Jennifer Roberts |
| 5/19/2011 |
Update or Other Action |
Wing Instruction 32-7003 dated May 19, 2011 Land Use Control Management. OPR: 673 CES/CEANR Certified by: 673 CEG/CC (Col Russell R. Hula). This instruction implements AFPD 32-70, Environmental Quality, & is used in conjunction with AFIs 32-7020, The ERP, 32-7066, Environmental Baseline Surveys in Real Estate Transactions, & 673ABWI 32-1007, Safeguarding Utilities From Damage.
It prescribes the processes & responsibilities for the management of & compliance with land use controls on Joint Base Elmendorf-Richardson (JBER) & applies to all military & civilian organizations that occupy facilities, or conduct business, on the installation. This publication does not apply to the USAF Reserve or Air NG units & members. The current land use control areas can be found on the Environmental Restoration map located on the GeoBase webpage.
General:
1.1. Land use controls (LUC), such as limitations on access, water use, excavations, & property transfers, will supplement engineering controls as appropriate for short-term & long-term mgt to prevent or limit human & environmental exposure to hazardous substances, pollutants, or contaminants.
Examples include limitations on the depth & location of excavations, prohibition of or restrictions on well drilling & use of GW, mgt. of excavated soils, & prohibition of certain land uses. LUCs, often used interchangeably with (ICs), are administrative, procedural, engineering, & regulatory measures to control human access to & use of property.
1.2. LUCs were established at JBER to prevent exposure to contaminated soil & water, based on agreements between the military services & the EPA & the ADEC. LUCs are used to reduce the potential for exposure to hazardous substances or to enhance the protectiveness of a soil &/or water cleanup remedy. They include restrictions on the use of portions of the shallow aquifer south of the Elmendorf Moraine, limitations on the types of buildings allowed in certain areas – primarily occupancy limitations, & land use designations for certain areas as recreational use only.
The LUCs have been implemented at several sites & operable units (OU) as part of the ERP. LUCs were established for DP98 & OUs 1, 2, 4, 5, & 6 on former Elmendorf AFB property in their respective records of decision (ROD), as a component of the selected cleanup remedy. LUCs were also established for restoration & compliance sites formerly part of Fort Richardson in their respective RODs or Decision Documents. LUCs must be in place as long as a property is not available for UU or UE & may include temporary or permanent restrictions or requirements. When all cleanup goals have been achieved for a given site, temporary controls, such as GW use restrictions, may be removed.
2. Responsibilities:
2.1. JBER personnel, tenants, or contractors whose projects or activities require excavation in areas where site-specific LUCs are in effect will comply with all LUCs, 673ABWI 32-1007, & applicable AF instructions. Base contractors & tenant organizations will have LUC compliance requirements incorporated into their contracts & interagency agreements, as will be necessary. Failure to comply with LUCs will be grounds for penalty, in accordance with provisions specified in applicable contract documents. At project completion, the JBER organization or contractor will sign a certification of LUC compliance & return the compliance statement to 673 CES/CEANR.
2.2. The 673d Civil Engineer Squadron (673 CES):
2.2.1. Asset Management Flight (673 CES/CEA):
2.2.1.1. Natural Resources Management (673 CES/CEAN):
2.2.1.1.1. Environmental Restoration (673 CES/CEANR):
2.2.1.1.1.1. Will provide GW & site-specific LUC requirements throughout the installation & identify any known soil contaminated sites & monitoring wells for the area of the proposed project.
2.2.1.1.1.2. Will conduct annual site visits to ensure compliance with LUCs during project implementation.
2.2.1.1.1.3. Will conduct 5-year reviews, at 5-year intervals, or as required by any subsequent RODs.
2.2.1.1.1.4. Will prepare annual LUC compliance reports & submit reports to ADEC & USEPA by 1 February each year.
2.2.1.1.1.5. Will disseminate LUC information to personnel involved in LUC mgt, including real property & 673 CES/CEPT for inclusion into GeoBase.
2.2.1.1.1.6. Will operate an active educational program that includes disseminating updated fact sheets & LUC information, providing notices through the installation intranet & the Arctic Warrior newspaper, & by briefing LUC mgt at project kick-off meetings; Environmental, Safety & Occupational Health Council meetings, & CEB meetings.
2.2.1.1.1.7. Will coordinate any changes in the base general plan (BGP), or real estate transactions, with USEPA & ADEC.
2.2.1.1.1.8. Will maintain copies of signed certificates of compliance, indicating requestor’s adherence to LUCs during project execution.
See site file for additional information.
|
Louis Howard |
| 6/6/2012 |
Update or Other Action |
Draft Project Management Plan received for review and comment.
Performance Objective
Optimized Exit Strategy for Site Closure.
Performance Indicators
· Complete an approved OES Plan by May 2013
· Complete an approved OES Implementation Completion Plan by October 2013
· Complete an approved OES Confirmation Report by January 2019
Potential Risk
EPA requires installation of monitoring wells. EPA may require additional data because the
original data were based on an incomplete analyte, the detection limits were too high for
assessing risks under a residential scenario, or we find unanticipated concentrations of COCs
that require further characterization.
Risk Mitigation
Install and sample wells.
Date of Achieving Performance Objective
2nd Quarter 2013.
Planned Approach
Prepare an approved OES Plan outlining anticipated requirements for achieving RCRA Closure.
Prepare RCRA Closure Plan. Prepare an approved Clean Closure Report if contaminant concentrations are below screening levels.
Prepare an approved Corrective Action Plan if remediation is still required to achieve SC.
|
Louis Howard |
| 6/11/2013 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 73766 name: OB/OD Pad |
Louis Howard |
| 8/10/2015 |
Document, Report, or Work plan Review - other |
Staff provided comments on the Annual CERCLA Report. Main comments were to remind JBER of the purpose and results from the groundwater wells installed at the site in 1996, |
Louis Howard |
| 1/13/2017 |
Update or Other Action |
ADEC received a GW monitoring report for several JBER sites which summarizes the 2015 annual long-term management (LTM) activities, including remedial action-operation (RA-O) & ROD requirements conducted at JBER CERCLA sites.
Site XE023 is identified as a Green priority. No further remedial action is necessary and
continuation of LUC inspections is recommended for this site.
See site file for additional information. |
Louis Howard |
| 1/18/2018 |
Document, Report, or Work plan Review - other |
Draft Fourth Five-Year Review report received for review and comment.
Main comments were on placing a notice of environmental contamination with Alaska Dept. of Natural Resources land records for the site. Other comments were on notifying AFCEC of the change in cleanup levels for various compounds in 18 AAC 75 since 1992 Hazardous Waste Consult document and the 1997 remedial investigation for Operable Unit C.
See site file for additional information. |
Louis Howard |
| 2/13/2018 |
Document, Report, or Work plan Review - other |
Staff commented on the draft RA-O & M Report for select CERCLA Sites. Main comments were on lower cleanup levels in November 7, 2017 18 AAC 75 than were analyzed during the 1997 Remedial Investigation which should have been addressed as part of the 2018 Five Year Review regarding cumulative risk and any impacts to remedy protectiveness.
See site file for additional information. |
Louis Howard |
| 2/10/2020 |
Enforcement Action |
EPA issues a Notice of Deficiency Letter to JBER. According to the Closure Plan, JBER intends to clean close the OB/OD pad, and Section 4.2 states that clean closure will be demonstrated following "sampling and analysis activities or following contaminant removal or site remediation." The Closure Plan includes infonnation on the closure sampling process and potential action levels for environmental media. However, details regarding how the data will be processed and what decisions will be made based on those data should be included in the Closure Plan. Furthermore, clean closure is not always possible, even despite the most careful unit and waste management.
As such, the Closure Plan should provide specific detail on contingency actions to be implemented if the OB/OD pad cannot be clean closed. The Closure Plan should generally clarify whether the pad will be closed in place and subject to a comprehensive Post-Closure Plan or addressed via RCRA corrective action. Specific details should be provided as to how JBER and OB/OD pad persom1el will proceed if contamination is detected above action levels. In revising the Closure Plan, JBER should provide enough detail and specificity that a third party could accurately bid on and implement pad closure; this will ensure that the installation has considered the full scope of closure requirements for the OB/OD pad.
62. Section 2.4.2 concludes that no contamination above action levels was found in soil, sediment, or groundwater samples during historical investigations of the OB/OD pad area. However, in some cases, action levels in effect at the time of those investigations are higher than the EPA Regional Screening Levels (RSLs) from May 2019. For example, the current RSL for 2,4-dinitrotoluene (DNT) in residential soil is 1.7 milligrams per kilogram (mg/kg), but the historical action level used for comparison was 100 mg/kg. According to Table 3 of the Closure Plan (page 19), the maximum concentrations of2,4-DNT detected in OB/OD pad soil and sediment samples were 65 and 84 mg/kg, respectively- both of which exceed the current RSL. Update the Closure Plan to include a discussion of historical sampling results as compared to current RSLs. This information is necessary to evaluate adequacy of the proposed clean closure sampling plan.
See site file for additional information. |
Louis Howard |
| 4/12/2021 |
Document, Report, or Work plan Review - other |
DEC submitted comments on Draft JBER Basewide UFP-QAPP dated February 2021. |
William Schmaltz |
| 5/19/2021 |
Document, Report, or Work plan Review - other |
DEC Reviewed and approved of Basewide Uniform Federal Policy - Quality Assurance Project Plan. QAPP summarizes general activities for a 5 year period on JBER. |
William Schmaltz |
| 4/20/2023 |
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 |
