| Action Date |
Action |
Description |
DEC Staff |
| 5/7/1981 |
Site Added to Database |
Date the "umbrella" site, Tatalina "umbrella" site, Tatalina LRRS Base Facilities, Reckey 198125X91270, was originally added to the database. |
Former Staff |
| 7/22/1988 |
Update or Other Action |
Final Technical Support Document for Record of Decision (dated February 29, 1988) received. Sites 1 (SS001), 2, 3, and 9 are spill/leak sites, sites 5, 7, 8, and 10 are previously used dumpsites or waste accumulation areas, site 6 is an area of Lower Camp road oiling, and sites 4 and 11 are the active landfill and waste accumulation area, respectively.
Site 11 is the active waste accumulation area. Waste liquids as well as unused products are stored at this site. Unused, drummed liquids have been stored in this area since the 1950s; the area has been used for accumulation of wastes only since 1977. Evidence of minor spills was observed by the survey team, consisting of dark stains from one to several feet in diameter. The spills appear to consist of oil. In the currently active section of site 11, dozens of barrels are stacked and await shipment off base. Some of the barrels are leaking and others have rolled into the adjacent woods. No evidence of vegetative stress was observed in the area during the 1987 site visit.
Note attached to this document from ADEC project manager, Ray Burger, remarks that:USAF (David Paulsen Colonel March 7, 1988), USEPA (Jacques Gusmano February 21, 1988) and ADEC signed the ROD in 1988 (Bill Lamoreux July 22, 1988) , but the ROD was based on almost no sampling of some sites, therefore was deemed inadequate and a RI/FS was necessary. |
Bill Lamoreaux |
| 10/29/1991 |
Update or Other Action |
Request for Submission of Preliminary Assessments for the Enclosed List of sites sent to the Air Force from EPA (Reply to ATTN: HW-113) (Information Request Letter, Urgent Legal Matter -- Prompt Reply Necessary).
The U.S. Environmental Protection Agency (EPA) is issuing this request for information concerning several sites (Ten sites including Tatalina AFS EPA ID# AK4572728711) under the authority of Section 104(e) of the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), 42 U.S.C. § 9604(e). EPA is now REQUIRING this information because your agency has not submitted Complete preliminary assessments which EPA requires to complete the evaluation of the sites.
The preliminary assessments also may indicate the need to complete a site inspection, which includes sampling. Your agency's performance of the preliminary assessments, and perhaps a site inspections, is necessary in order for EPA to evaluate whether to include the facilities on the National Priorities List (NPL).
This formal request for submittal of information is being made to assure that a preliminary assessment is conducted for each facility that was listed on the original Federal Facilities
Hazardous Waste Compliance Docket, pursuant to the statutory requirement set forth in Sec. 120(d) of CERCLA, 42 U.S.C. 9620(d). In a judicial Order dated January 15, 1991, in the case
entitled Conservation Law Foundation of New England v. EPA, C.A. No. 89-2325-Y. D. Mass., EPA was ordered to conduct e preliminary assessment of certain facilities by July 15, 1992, and to
complete evaluations of each facility for the National Priorities List by July 15, 1993.
EPA has an obligation to use its utmost diligence to meet the Court order by assuring that a preliminary assessment is conducted for each facility on the docket. The cooperation of your asency and timely assessment of each site is essential if EPA is to meet these Court-ordered deadlines.
You also should be aware that Sec. 116(a) of CERCLA, 42 U.S.C. 9616(a), REQUIRES your agency to complete preliminary assessments and site investigations within specified times. The
President delegated to the heads of Executive departments and agencies the authority to conduct such assessments with respect to facilities under the jurisdiction, custody or control of those
departments and agencies, in Sec. 3(a) of Executive Order 12580 of January 23, 1987.
Therefore, pursuant to the authority of Section 104(e) of CERCLA, 42 U.S.C. 9604(e), you are hereby requested to respond to the information request titled "Preliminary Assessment (PA)/
site Inspection (SI) Data Requirements for Federal Facility Docket Sites," set forth in Enclosure A to this letter. You only need to respond to the hiqhlighted items for each site. Your responses to this request for information MUST be submitted (postmarked or hard delivered) to EPA within 60 calendar days of receipt of this letter. To comply with this request, you must
provide a response to each question.
If information relevant to a question already has been provided to EPA, your answer may precisely cite the previous submittal by title, date, page and paragraph number rather then resubmit the information. To assist in your efforts a copy of EPA's draft "Guidance for Performing Preliminary Assessment Under CERCLA"[Publlcatlon 9345.O-01A, September 1991] was provided at the October 8th meeting in Anchorage.
Please be aware that compliance with this information request is MANDATORY. Failure to respond within 60 days of receipt or to adequately justify failure to respond can result in enforcement action by EPA pursuant to Section 104(e).
LIST OF SITES REQUIRING PRELIMINARY ASSESSMENTS
EPA ID # Site Name
AK0572728632 CAPE NEWENHAN AFS
AK9572728633 CAPE ROMANZOF AFS
AK9570028655 GALENA AFS
AK3572728662 INDIAN MOUNTAIN AFS
AK1570028679 MURPHY DOME AFS
AK0210890091 PORT MOLLER
AK957a028705 SHEMYA AFB
AK4572728711 TATALINA AFS
AK3572728712 TIN CITY AFS
AK1572728631 CAPE LISBURNE AFS |
Jennifer Roberts |
| 4/9/1992 |
Update or Other Action |
EPA Memorandum April 9, 1992 Reply to the ATTN of ES-098. Subject Toxicity of Fuels. From Carol Sweeney, Toxicologist Health and Environmental Assessment Section. To Wayne Pierre Federal Facilities Superfuend Branch (HW-124). A response has been provided to the frequently-asked question of whether a reference dose or other toxicity information can be provided for fuel mixtures so that these mixtures can be addressed quantitatively in Superfund risk assessments. The memo from ECAO Cincinnati is attached (last attachment). They have developed reference doses for gasoline, JP-5/kerosene, and JP-4, and a cancer potency factor for gasoline. The memo emphasizes that these are provisional numbers and that considerable uncertainty is involved in this quantitative assessment, because of data limitations, and because inhalation studies were used to calculate oral reference doses.
I typed up a summary table showing the numbers (first attachment) and calculated some risk-based concentrations (second attachment). On the risk-based concentration table, I also
included ordnance compounds, because I hadn't made a table of those before that I can remember. The risk-based concentrations were calculated the same way as table II-1 and II-2 of the Region
10 Supplemental guidance; for soil, the same limitations apply, that the numbers presented do not consider pathways other than soil ingestion.
Toxicity Reference Vaules for Fuel Mixtures EPA Region 10 4/9/1992 Non-cancer effects-Gasoline (unleaded) RfD (mg/kg-day) Oral: 2.0E-1, Uncertainty Factor-Oral:1000, Level of Confidence-Oral: Low. Toxicity Data Source-Oral RfD: Memo 3/92. Carcinogenicity-Cancer Potency/(mg/kg/day): Oral 1.7E-3, Unit Risk (/ug/m3) 4.8E-7, Cancer Weight Of Evidence-C, Toxicity Data Source-Oral SF and Inhal. SF: Memo 3/1992.
Kerosene/JP-5 RfD2.0E-2, UF Oral: 10,000, LOC Oral: low, TDS Oral RfD: Memo 3/92
JP-4 RfD 8.0E-2, UF Oral: 10,000, LOC Oral: low, TDS Oral RfD: memo 3/92.
Screening Values for Water RBCs based on Ingestion, Residential
Gasoline-Risk = 10-6 (ug/L) 50, 10-4=5000 HI=1 (ug/L) 7000
JP-5 Kerosene Risk 10-6 10-4=NA HI = 1 (ug/L) 700
JP-4 Risk 10-6 10-4 = NA, HI = 1 (ug/L) = 3,000
Screening Values for Soils- RBCs Based on Soil Ingestion Residential
Gasoline-Risk = 10-6 (mg/kg) 400, 10-4 (mg/kg) 40,000, HQ = 1 (mg/kg) 50,000
JP-5 Kerosene Risk 10-6 10-4 NA, HQ =1 5,000
JP-4 Risk 10-6 10-4 NA, HQ = 20,000
USEPA Office of Research and Development, Environmental Criteria and Assessment Office Cincinnati, OH Subj: Oral Reference Doses and Oral Slope Factors for JP-4, JP-5; similar to Kerosene (CAS no. 8008-20-6), Diesel Fuel (CAS No. 68334-30-5), and Gasoline (CAS No. 8006-61-9) (AVGAS) [McChord AFB (Wash Rack/Treatment)/Tacoma, WA]. From Joan S. Dollarhide Associate Director, Superfund Health Risk Techncial Support Center, Chemical Mixtures Assessment Branch TO Carol Sweeney USEPA Region X.
This memorandum is in response to your request for oral systemic and carcinogenic toxicity values for JP-4, JP-5, diesel fuel, and gasoline (AVGAS) found to contaminate soil and
groundwater at McChord AFB (Wash Rack/Treatment), Tacoma, WA. We have attempted to derive RfDs and slope factors for the above fuel mixtures. We have derived provisional RfDs for
gasoline, JP-4, JP-5 and diesel fuel; provisional cancer weight-of-evidence classifications of C for gasoline and D for JP-4, JP- 5 and diesel fuel; and a provisional slope factor (adapted from an interim Agency value) for gasoline
Based on the available evidence, unleaded gasoline can be assigned to U.S. EPA (1986) weight-of-evidence Group C: possible human carcinogen. An earlier U.S. EPA document assigned unleaded
gasoline to Group B2 as a probable human carcinogen (u.s. EPA, 1987a), but that document predates the U.S. EPA (1991d) conclusion that the male rat kidney tumors produced by gasoline
are not predictive for humans, and therefore should not contribute to the weight-of-evidence or dose-response assessment of carcinogenicity. IARC concluded that marine diesel fuel is possibly carcinogenic to humans (Group 2B), but light diesel fuels and jet fuels are not classifiable as to their carcinogenicity in humans (Group 3). |
Jennifer Roberts |
| 5/18/1992 |
CERCLA PA |
EPA Letter to Patrick Coullahan USAF.
This letter is to inform you that EPA, Region 10 has reviewed the Preliminary Assessment submitted for the Tatalina Air Force Station Long Range site in Yukon-Koyukuk.
The documents have been evaluated in accordance with 40 CFR, Part 300, Appendix A, which is EPA's Hazard Ranking System (HRS) used to evaluate federal facilities for inclusion on the National Priorities List (NPL).
The reviewed documents indicate that the site could score high enough to be included on the NPL. Therefore, EPA requests that additional information be submitted in order to complete our evaluation. Specifically, all sources identified in the PA should be sampled and measured, and all targets potentially impacted by on site sources should be sampled. Background samples
should be collected to characterize natural soil conditions at the site and to determine natural conditions for surface water.
Section 120 of the Superfund Amendments and reauthorization Act requires EPA to assure that a PA/SI is conducted for all facilities listed on the Federal Agency Hazardous Waste Compliance Docket. Executive Order 12580 (1/23/87) establishes individual federal facilities as the responsible party to provide sufficient information for EPA to conduct an MRS evaluation. As
such, EPA requests that you provide us with the above information within 90 days of receipt of this letter.
If your facility anticipates an inordinate amount of delay in compiling this information, please send us within 30 days of receipt of this letter, a schedule of when we may expect to receive the required information. I would like to be involved in the development of the work plan for the AF sites and would be happy to meet with your representatives to discuss the additional sampling at the earliest convenience. If you have additional questions or wish to discuss this matter, contact either Marcia Combes or me (Mark Ader-Federal Facilities Site Assessment Manager). |
Jennifer Roberts |
| 4/19/1993 |
CERCLA SI |
EPA letter to Patrick M. Coullahan (LTC), Commander U.S. Air Force, 11th CEOS. This letter is to inform you that EPA Region 10 has completed the review of the Site Inspection (SI) report for the US Air Force Tatalina Long Range Radar Site, Alaska. The SI has been evaluated in accordance with 40 CFR Part 300 Appendix A, which is EPA's Hazard Ranking System (HRS) used to evaluate federal facilities for inclusion on the National Prioritles List (NPL).
From our evaluation, EPA has determined that the site does not score high enough to be proposed for inclusion on the NPL. Therefore, a recommendation of no further remedial action planned (NFRAP) on the EPA'S part will be included in our Federal Agency Hazardous Waste Compliance Docket tracking system. If new or additional information becomes available that suggests the facility may score high enough to be proposed for the NPL, EPA must reevaluate your facility accordingly.
EPA's NFRAP designation will NOT relieve your facility from complying with appropriate Alaska state regulations (i.e. A.S. 46.03, 18 AAC 75, 18 AAC 78, 18 AAC 60, 18 AAC 70, 18 AAC 80, 18 AAC 62). The Superfund Amendments and Reauthorization Act (SARA)* of 1986, Section 120(a) (4) requires federal facilities to comply with state cleanup requirements and standards when not listed on the NPL. All sources of contamination should be remediated to Alaska State clean-up standards.
An alternative water supply should be provided IMMEDIATELY to on site personnel, and the water gallery well should be resampled. Analytical results should be provided to both the EPA and the state of Alaska.
This facility will not be removed from the Federal Agency Hazardous Waste Compliance Docket, but as noted earlier, will be listed for no further action by EPA. If you have any questions regarding EPA's evaluatlon of the site, please contact me, at (206)553-1808.
NOTE to File: CHAPTER 103--COMPREHENSIVE ENVIRONMENTAL RESPONSE, COMPENSATION, AND LIABILITY
SUBCHAPTER I--HAZARDOUS SUBSTANCES RELEASES, LIABILITY, COMPENSATION
Sec. 9620. Federal facilities
(a) Application of chapter to Federal Government
(1) In general
Each department, agency, and instrumentality of the United States (including the executive, legislative, and judicial branches of government) shall be subject to, and comply with, this chapter in the same manner and to the same extent, both procedurally and substantively, as any nongovernmental entity, including liability under section 9607 of this title. Nothing in this section shall be construed to affect the liability of any person or entity under sections 9606 and 9607 of this title.
(2) Application of requirements to Federal facilities
All guidelines, rules, regulations, and criteria which are applicable to preliminary assessments carried out under this chapter for facilities at which hazardous substances are located, applicable to evaluations of such facilities under the National Contingency Plan, applicable to inclusion on the National Priorities List, or applicable to remedial actions at such facilities shall also be applicable to facilities which are owned or operated by a department, agency, or instrumentality of the United States in the same manner and to the extent as such guidelines, rules, regulations, and criteria are applicable to other facilities. No department, agency, or instrumentality of the United States may adopt or utilize any such guidelines, rules, regulations, or criteria which are inconsistent with the guidelines, rules, regulations, and criteria established by the Administrator under this chapter.
(3) Exceptions
This subsection shall not apply to the extent otherwise provided in this section with respect to applicable time periods. This subsection shall also not apply to any requirements relating to bonding, insurance, or financial responsibility. Nothing in this chapter shall be construed to require a State to comply with section 9604(c)(3) of this title in the case of a facility which is owned or operated by any department, agency, or instrumentality of the United States.
(4) State laws
State laws concerning removal and remedial action, including State laws regarding enforcement, shall apply to removal and remedial action at facilities owned or operated by a department, agency, or instrumentality of the United States or facilities that are the subject of a deferral under subsection (h)(3)(C) of this section when such facilities are not included on the National Priorities List. The preceding sentence shall not apply to the extent a State law would apply any standard or requirement to such facilities which is more stringent than the standards and requirements applicable to facilities which are not owned or operated by any such department, agency, or instrumentality. |
Jennifer Roberts |
| 7/15/1993 |
CERCLA PA |
Final Site Investigation Report (dated July 1993).
While not listed on the NPL, Tatalina LRRS must follow CERCLA process per E.O. 12580 [e.g. CERCLA Sections 104(a), (b), and (c)(4), 113(k), 117(a), and (c), 119, and 121) with respect to releases or threatened releases where either the release is on or the sole source of the release is from any facility or vessel under the jurisdiction, custody, or control of their departments. These functions must be exercised consistent with CERCLA Section 120 Federal Facilities.
State laws. -- State laws concerning removal and remedial action, including State laws regarding enforcement, shall apply to removal and remedial action at facilities owned or operated by a department, agency, or instrumentality of the United States when such facilities are not included on the National Priorities List. The preceding sentence shall not apply to the extent a State law would apply any standard or requirement to such facilities which is more stringent than the standards and requirements applicable to facilities which are not owned or operated by any such department, agency, or instrumentality.].
|
Ray Burger |
| 3/28/1995 |
Update or Other Action |
Management Action Plan (draft dated Febraruy 1995, received March 28, 1995, no final received). |
Ray Burger |
| 2/10/1997 |
Update or Other Action |
Human Health Risk Assessment conclusions:
No contaminants in any samples at Upper Camp and the Airstrip pose a significant risk to human health for the exposure scenario (the resident/worker scenario) evaluated. Therefore, remedial action at sites within these areas is not warranted to reduce human health risks. Future use of the Tataline LRRS is not expected to be significantly different from the current situation. Risks to the subsistence food gatherer were not evaluated because most subsistence exposure pathways are considered incomplete. If a subsistence exposure pathway is complete, exposure frequencty and duration are considered less for the substence food gatherer than for the site resident or worker.
Contaminated groundwater at Lower Camp and Sterling Landing is not currently used. Therefore, all estimated risks from contaminants in groundwater are for future potential groundwater use. Cancer risk and noncancer risk estimates for benzene in groundwater at Lower Camp (SS-003) exceed the ADEC standards. Three of the seven wells detected benzene above the 5 ug/L: 51 ug/L, 110 ug/L and 335 ug/L.
Ecological Risk Assessment: COECs: Benzo(a)pyrene, benzo(g,h,i) perylene, dibenz(a,h)anthracene, and diesel (at surface samples only). Rationale: The organics retained as COECs all indicated potentially high risks to one or more representative species, other chemicals had high contribution from background, conservative CTVs, small site area relative to foraging range (fox) or low habitat quality. Recommendations: additional work such as bioassays or soil remediation in vicinity of drum disposal area. |
Gretchen Pikul |
| 2/13/1997 |
Update or Other Action |
Site added by Shannon and Wilson, Inc. this date. Site split off from the Tatalina "umbrella" site, Tatalina LRRS Base Facilities, Reckey 198125X912701. All relevant information from the "umbrella" site moved into subordinate sites 10/31/01 by Pikul and Petrik. |
S&W-Miner |
| 2/13/1997 |
Update or Other Action |
(Old R:Base Action Code = SI - Site Investigation). SI action added on 02/13/1997 by Shannon and Wilson, Inc. Based on Air Force Relative Risk Evaluation Worksheet dated 8/28/95, Site Investigation is the current phase. |
S&W-Miner |
| 3/7/1997 |
Update or Other Action |
Addendum for Interim Remedial Action (drum removal workplan) dated November 1996; comment resolution meeting on March 7, 1997; excavation and removal of buried drums and associated soil contamination from site LF10 and SS11. |
Gretchen Pikul |
| 3/7/1997 |
Site Characterization Workplan Approved |
Remedial Investigation Workplan and associated plans (draft dated August 1996; final dated June 1997 and received on January 13, 1997; ADEC comment letter dated February 4, 1997; comment resolution meeting on March 7, 1997; no final received following ADEC comment letter and comment resolution meeting. |
Gretchen Pikul |
| 1/12/1998 |
Update or Other Action |
Final Management Action Plan (dated and received in January 1998). |
Gretchen Pikul |
| 2/10/1998 |
Update or Other Action |
1997 RI and Removal Action received. During 1997, the Air Force conducted a removal action along
with a RI at SS011. As part of the removal action, most of the waste drums located at WAA No.
1 were removed. Confirmation sampling was performed at the drum storage locations and
indicated that neither PCBs nor total petroleum hydrocarbons were present above ADEC soil
cleanup levels.
As part of the 1997 RI, soil samples collected from two test pits located downgradient of the
Hardfill No. 1 and WAA No. 1 to determine contaminant migration indicated the presence of
VOC and pesticide contaminant residues in soils at trace levels.
During the RI field work, approximately five to 10 additional drums were found partially buried
on a steep slope immediately west and below the two test pits, downslope from the WAA No. 1
drum removal area. Soil samples, one surface and one subsurface, were collected directly under
one of the partially-buried drums to determine if the drums could have potentially released any
contaminants. Sampling results indicated a higher contaminant concentration in the shallow
subsurface sample than the surface sample.
The 1997 RI report indicated that, due to the limited sampling conducted during the RI for the
drum disposal area downgradient of SS011, the nature and extent of contamination was not well
understood (USAF, 1998b). Additional monitoring of the area, including collecting additional
shallow subsurface soil samples, along with seep samples collected at a downgradient location,
was recommended. |
Gretchen Pikul |
| 3/31/1998 |
Document, Report, or Work plan Review - other |
The Department of Environmental Conservation (DEC), DoD Oversight group, received the Draft Remedial Investigation Report (dated February 1998) on February 10, 1997. The Draft Remedial Investigation Report includes a Baseline Risk Assessment, a Human Health Risk Assessment, and Ecological Risk Assessment. We appreciate the extended review deadline of March 31, 1998. We have completed our review of Draft Remedial Investigation Report and provided comments below. Please note, the Draft Risk Assessment sections are currently under review. A separate comment letter will be forwarded shortly.
The Department files include the draft Sampling and Analysis Plan (SAP; (dated August 1996), the draft Quality Program Plan (QPP) - Addendum tbr Interim Remedial Actions (dated November 1996), and the final Remedial Investigation / Feasibility Study (RI/FS)
Workplan (dated June 1997). During a site meeting on January I3, 1998, DEC received a final copy of the workplan.
Requests were made by the DEC on January [3 and February 13, 1998 to obtain final copies of the SAP and the QPP documents; no final copies have been forwarded. Therefore, any DEC comments regarding the SAP are based on the draft SAP, and may not be indicative of final decisions incorporated into the final SAP. With that clarified, any deviations from the SAP need to be clearly stated with the rationale tor the changes recorded m Section 8.0 (RI Results and Recommendations) and other
appropriate sections.
It is stated that in July 1997, site WAA No.1 field activities included excavation, and removal of drums and contaminated soil. These field activities were part of the scope of work for the RI investigation, and need to be incorporated in this report, or referenced to a separate report, appendix, or attachment. |
Gretchen Pikul |
| 4/6/1998 |
Document, Report, or Work plan Review - other |
The Department of Environmental Conservation (DEC), DoD Oversight group, received the Draft Remedial Investigation (RI) Report (dated February 1998) on February 10, 1997. The RI Report includes a Baseline Risk Assessment, a Human Health Risk Assessment, and Ecological Risk Assessment. We have completed our review and provided comments below.
General Comments -
1. In general, the human health and ecological risk assessment is well written and organized, and the conclusions appear to be sound. Based on our review of the risk evaluation report, we provisionally accept the risk assessment subject to resolution or incorporation of comments provided below. Our major concern is that a flawed COPC/COPEC selection process may have resulted in the exclusion of too many chemicals from the risk assessment. In particular, elimination of chemicals on the basis of a narrowly-defined relevancy to the site; screening against background concentrations in cases where only one background sample is available; and an inadequate detection limit evaluation are of concern.
2. Appendix B, Section 1.0, Pages B-1 and B-2: The fourth paragraph indicates that aggregate data sets for each area and sample type were used to evaluate human health risks. The first paragraph on page B-2 states that ıif estimated risks for an area and sample type were acceptable, risks for individual sites within the area were deemed acceptable.ġ The logic of this approach is unclear. Given the presence of several source areas with such varying potential contaminants (e.g., at Lower Camp there is a POL Tank Farm, numerous landfills, a former paint shop, a truck fill stand, and a sanitary sewer system), aggregating the data from these sites would underestimate the risk from the individual sites. We recommend that the chemical of potential concern (COPC) screening be performed on a site-by-site basis, rather than area-wide. Most sites will be eliminated from further consideration in the risk assessment at this point, because no COPCs will be identified for them. The remaining sites could be carried through the risk assessment with greater confidence that human health risks have not been underestimated.
This paragraph also states that use of the 95 percent confidence limit on the mean of the data supports use of this aggregate approach; we disagree. Using the maximum detected concentration would support this approach; that way no dilution of hot spots would occur.
The data quality evaluation for the ecological risk assessment (ERA) is incomplete. At a minimum, a comparison of sample quantitation limits (SQLs) to ecological screening criteria should be performed. This type of comparison ensures that SQLs were not higher than values significant to protection of ecological health, and should be performed for all media.
4. At most sites one or more chemicals were eliminated as COPECs because they did not exceed background concentrations. While background comparisons are generally reserved for naturally occurring inorganics, the text and Table C2-7 indicate that several organics were eliminated from further consideration based on comparison to background. Elimination of organics based on comparison to background may only be valid for truly ubiquitous chemicals, such as some PCBs or dioxins, and not for site related chemicals. For example, RRO, diesel, and 4,4' DDT were eliminated at Waste Accumulation Area 2 because they did not exceed background. It is not convincing that these and other chemicals are not site-related.
In addition, Table C2-5 indicates that Sterling Landing soils and Lower Camp sediments and water background values were based on one sample. It is suggested that the organic chemicals currently eliminated from further COPEC consideration on the basis of comparison to background be carried through the comparison of maximum detects to critical toxicity values (CTVs).
5. The use of home range is frequently used as a basis for eliminating COPECs from further evaluation as a COEC. While this is a valid approach the report would benefit greatly from a summary table of sites, chemicals eliminated, and size of sites evaluated as compared to size of home range. For example, on page C-36 the statement "the large home range for the fox indicate that the realistic potential for exposure to the fox is low" needs to be substantiated with a numerical comparison of site area to receptor home range. |
Gretchen Pikul |
| 6/2/1998 |
Site Visit |
ADEC participated in a facility-wide site visit. |
Gretchen Pikul |
| 6/4/1998 |
Update or Other Action |
Interim Remedial Action Report Draft received for work conducted during June & July 1997 at two sites: SS011 & LF010. Interim remedial actions were conducted during 1997 at Tatalina LRRS, Alaska to investigate & remove buried drums of waste & associated contaminated soil at sites SS011 & LF010. The target cleanup levels were:
• 1 milligrams per kilogram (mg/kg) polychlorinated biphenyls (PCBs) from 0 to 1 feet below ground surface (bgs).
• 10 mg/kg PCBs for depths greater than 1 foot bgs.
• 1,000 mg/kg total petroleum hydrocarbon (TPH) (based on a diesel range organic [DRO]/residual range organic [RRO] analysis) from 0 to 1 feet bgs.
• 3,000 mg/kg TPH (based on DROIRRO analysis) for depths greater than 1 foot bgs.
At SS011, approximately 7,000 cy of soil were excavated at site SS011 in search of buried drums. The excavation went as deep as 16’ in some areas & averaged 8’ to 12’ deep. It covered a surface area of approximately 20,000 sq ft. The excavation was guided by the geophysical survey, PID readings, & visual evidence of contamination. Excavation activities were conducted from June 13 until June 17, 1997, at which point it was determined that the site was sufficiently explored for buried drums. No drums of oil or potentially hazardous waste were located. Site restoration was completed upon the end of excavation activities.
Approximately 150 drums were encountered at the site along with buried concrete. The drums were rusted & crushed & contained no hazardous material or product. The soil at the site was free of staining & odor & appeared clean. Headspace PID readings did not indicate a significant volatile organic presence. The highest PID reading was 1.2 ppm.
A total of four soil samples were collected & field screened using the EnSys immunoassay kits. All PCB field screen results were less than 1 mg/kg for PCBs; therefore, no soil was removed due to PCB contamination. Sample 97TATSSOl1003SS was collected & submitted for analysis for PCBs to verify the accuracy of the PCB field screen. The sample was non detect for all PCBs.
Two confirmation samples (97TATSSOII00ISS & 97TATSSOII002SS) were collected & submitted for laboratory analysis prior to backfilling to ensure that cleanup objectives have been met for PCBs & TPH. In addition, these samples were analyzed for GRO, VOCs, SVOCs, pesticides, & metals to provide a thorough characterization of final site conditions. A third sample was also collected & submitted for PCB/pesticide analysis only.
Confirmation sampling indicated that TPH & PCB contamination were well below cleanup objectives. As a result of these findings, no further action is recommended for this site.
Sample 03A 97ATATSS011003SS Collected 6/17/1997 had DDT at 3.2 mg/kg “D” D = analyte was diluted to bring within instrument calibration range or to remove matrix interferences. |
Louis Howard |
| 7/6/1998 |
Document, Report, or Work plan Review - other |
Interim Remedial Action report (draft dated March 1998,received on June 4, 1998, no final received). The Department of Environmental Conservation (DEC), DoD Oversight group, received the Draft Interim Remedial Action Report (dated March 1998) on June 4, 1998. 7,000 cubic yards of material were excavated at site SS011 with a surface area of 20,000 square feet. Only two confirmation soil samples were taken to delineate the excavation. State regulations require 2 samples for the first 250 sq. ft. and 1 sample for every 250 square feet thereafter (See 18 AAC 78.090 (d)(2)(B)(i-vii)) which would mean eighty-one confirmation samples were required not the two that were taken.
Specific Comments- Pg. ES-1 Objectives: The target cleanup levels are listed in this section. As stated in the Department comment letter (dated March 6, 1997) on the IRA workplan, the target cleanup levels listed in this section are acceptable, however, if groundwater is impacted, remedial actions may be warranted. Include how the potential impact to groundwater been addressed in this study. Also include the depth to groundwater in these areas.
Pg. ES-2 Site SS011 Remedial Activities: It is stated that the excavation went as deep as 16 feet in some areas, and averaged 8 to 12 feet deep. Include whether native, undisturbed soil was encountered, and incorporate within appropriate sections throughout the report. Also, the IRA workplan (page 15) states that the drums are estimated to be buried up to 18 feet bgs. Explain how this area has been fully characterized. In addition, pertinent information collected during the RI/FS in 1997 should be incorporated into this report. Specifically, sample SL144 within the site area that had a detection of 50,000 mg/kg DRO, and the recommendations within this sample area.
Pg. 3-2 3.1 Geophysical Survey of Site LF010 and SS011: Appendix A legends/descriptions should include an explanation of the color-coding. SS011 appears to have an anomaly within the area of 0-0 and 50N-50E. Explain how this area has been characterized.
Pg. 3-4 3.3.2 Soil Analyses: It is stated that soil samples were collected at least 6 inches bgs for volatile analytes, and between 0 to 6 inches bgs for other analytes. Explain how these soil samples depths were chosen, and how the depths relate to buried drums.
Pg. 3-10 3.5.2 Drum Removal and Product Handling: Include the Drum Characterization Logs in the appendices. Also, include within the text whether any labeling was observed on the drums, and what the labels indicated.
Pg. 4-2 4.1.2 Field Screening and Analytical Results: Include the reasoning for 49 samples at LF010 and 3 samples at SS011.
Pg. 4-5 4.2.2 Field Screening and Analytical Results: It is stated that a total of 180 crushed and rusted drums were discovered. Include the location on the appropriate figure. Also include whether confirmation soil samples were collected within this area.
4.2.2 Field Screening and Analytical Results: It is stated that 2 confirmation samples were collected. These locations are situated in an area that no anomalies were encountered. Explain how the confirmation sample locations were chosen for the SS011 area.
4.2.3 Status of Site: It is stated that no contamination was present above the project cleanup objectives in the confirmation samples. Since the project cleanup objectives only include levels for PCB, DRO and RRO, any detects should be mentioned, and whether these concentrations are above or below the draft regulations (18 AAC 75, dated May 4, 1998).
Pg. 4-6 4.2.4 Recommendations/Conclusions: According to the draft RI/FS and discussions with the 611th Project Manager, an isolated area of contaminated soil (sample SL144 at 50,000 mg/kg DRO) was encountered on the hillside downgradient from the SS011 excavation area. This contaminated soil is planned for removal, potential further investigative efforts, and confirmation soil sample analysis. And as previously stated, a 3 to 5 year monitoring program should be implemented to develop a trend. In addition, a 5-year review should also be conducted to reevaluate the monitoring program. (NOTE: ADEC does not agree no further action is recommended for this site as stated in the draft IRA Report for site SS011 based on two samples which cannot be construed as "representative" of the 20,000 square foot excavation).
Pg. 4-7 Table 4-1: The “location” column is difficult to correlate to the locations on the figures. Also, there is one location that is labeled “stockpile”; page 3-9 states that the soil was not stockpiled. Please explain this label. In addition, explain what numbers are presented in the “reading” column. The table title indicates that field screening results are shown on the table. If this data represents analytical data, then the table title, notes, and references should reflect this.
|
Gretchen Pikul |
| 8/3/1998 |
Document, Report, or Work plan Review - other |
We (ADEC) have completed our review of the comment responses received on July 8, 1998. We accept these responses, except as noted below. Please call me at 269-3077 if there are any questions or concerns regarding this memorandum. Otherwise, we look forward to receiving the revised risk assessment document.
In some comment responses pertaining to providing units, references, rationale, etc., it was not clear whether it is your intent to add the information to the revised risk assessment text (rather than simply provided in the comment response); ADEC assumes that the risk assessment text will be revised.
Regarding Response #2 - Establishing meaningful exposure areas, rather than basing them solely on source areas, is an
acceptable practice if the exposure areas are carefully defined based on appropriate criteria. The criteria identified in the comment response are appropriate, but two additional criteria should be
added:
• Qualitatively demonstrating that sampling frequency per unit area (e.g., per acre) is not dramatically different between the source areas/sites that are to be combined into a single exposure area (if it is, the 95% UCL will not be representative); and
• Stating whether future (e.g. in addition to current) exposure is likely to remain nonpreferential.
Although the comment response does not provide sufficient information to allow independent judgement as to whether the criteria were appropriately applied, ADEC approves of the exposure areas based on prior information that we have received on site conditions and on the Remedial Investigation data. However, the reference to our Risk Assessment Review Term Contractor's approach to defining exposure areas at another unrelated site is irrelevant and inappropriate; therefore, it should be removed from the comment responses.
Regarding Response #4- During the comment resolution teleconference it was agreed that background screening for
organic chemicals would not be retained. The comment responses reflect this for the human health risk assessment, but not for the ecological risk assessment. The ecological risk assessment
should also be revised so that background screening is no longer applied for organic chemicals.
Although it is true that there would be no numerical impact on the risk assessment as long as the background levels are below ecological screening values (as stated in the response), ADEC does not wish to approve a risk assessment that contains inappropriate background screening for organic chemicals.
Regarding Response #5 and 50 -The responses to these comments did not adequately address our specific concern. The overall qualitative evaluation and associated recommendations remain a concern. This evaluation seems somewhat arbitrary, 'writing-off' with weak or no rationale many chenucals with hazard quotients (HQs) above 1 (in fact all chemicals with HQs below I0 and some with HQs above 10). Chemicals with an HQ between 1 and 10 are considered to pose a possible risk and should not simply be dismissed. It is certainty appropriate to consider qualitative factors, especially within this range. However, no information to directly support the limited rationale was given.
For example, poor habitat and large home range are cited. However, habitat quality was considered sufficient to perform a risk assessment, and ADEC does not consider the habitat to be
poor with the exception of the very top portion of upper camp.
Regarding Response #7-An average exposure duration of seven years, rather than a reasonable maximum, was used.
Reasonable maximum values should be used in risk assessments. Use of an average value results in an under-estimation of risk for some individuals. Exposure duration values of 10 to 12 years
have commonly been used at similar installations based on surveys at specific installations as well as surveys across several similar installations. Further, the Tatalina facility is among the more popular of such facilities. The site-specific survey reported in the risk assessment indicates some worker residents have been present at Tatalina for considerably longer time periods. The exposure duration should be justified or increased to a justifiable duration.
Regarding Response #13-Acceptability of this response depends on the discussion that is added. Also, site history indicates that Mogas and diesel were present. This would suggest the likely presence of VOCs (e.g., BTEX) and SVOCs (e.g., PAils and alkylbenzenes). Therefore, documenting the site history does not allay, but rather increases, our concern that VOCs and SVOCs were not analyzed.
|
Gretchen Pikul |
| 10/13/1998 |
CERCLA RI Report Approved |
Remedial Investigation Report (draft dated February 1998, final dated and received in October 1998) includes a risk assessment; ADEC comment letter dated March 31, 1998; comment resolution meeting on May 15, 1998. Twelve IRP sites were investigated. Upper Camp: Minimally Attended Radar (MAR) Site (SS-001), WACS Site (OT-012), Hardfill No. 2, Northwest Landfill, Morrison Knudsen (MK) Debris Site (DP-005)
Lower Camp and Airstrip: Hardfill No. I and Waste Accumulation Area (WAA) No. 1 (SS-011), POL Tank Farm (SS-003), WAA No. 3 (SS-007), Truck Fill Stand (SS-009), WAA No. 4, Old Sanitary Sewer System, Former Sewage Lagoon, and Former Paint Shop (SS-008), WAA No. 2 and Upper Landfill No. 1 (LF-010), Lower Landfill No. 2 (LF-004), Airstrip (OT-006)
Sterling Landing: Truck Fill Stand (SS-002)
The objectives of the RI were to determine if past disposal of construction and demolition activities at Hardfill No. 1 and past drum disposal activities at WAA No. I created source areas for contamination, determine potential downgradient migration of contaminants in seeps and sediments, confirm the absence or presence of groundwater in the area, and if present, define the nature of groundwater contamination and flow characteristics. RI sampling at WAA No. 1 focused on the area downgradient of and at depths below the drum removal excavation in that area. RI sampling was not conducted within WAA No. 1; therefore, the 1992 SI results were not used in a direct comparison to RI data.
GRO ranged from below the reporting limit in the surface soil sample to 18 mg/kg at a 1-foot depth. DRO ranged from 557 in the surface sample to 50,000 mg/kg at a 1-foot depth. RRO ranged from 625 in the surface sample to 1380 mg/kg in the 1-foot depth sample. Benzene and BTEX were not detected in these samples.
The total extent of contamination in the drum disposal area downslope from SS-011 cannot be determined on the basis of the limited sampling completed during the RI. The sample collected at the 1-foot depth beneath the drums contained higher levels of contaminants than the sample collected at the surface. It is possible that the area of contamination under the drums is limited, but it is also possible that it extends beyond the one location where the surface and shallow subsurface soil samples were collected during the RI. Because of the steep terrain in the area and the difficulty of mobilizing equipment to conduct additional
subsurface soil investigations, determining the full extent of existing contamination may not be feasible.
To verify that there are no future negative impacts to receptors, monitoring of shallow subsurface soil in the drum disposal area downslope of SS-011 should be conducted annually for 3 years. In addition, if seeps are observed immediately downgradient of SS-011, surface water and sediment samples should also be collected. Laboratory analyses should be completed for the same list of analytes as those performed for the 1997 RI. |
Gretchen Pikul |
| 10/13/1998 |
Risk Assessment Report Approved |
Risk Assessment, a part of the Remedial Investigation Report (draft dated February 1998, final dated October 1998); ADEC comment letter dated April 6,1998; comment resolution meetings on May 11, 1998; ADEC Memorandum on Response to Comments dated August 3, 1998. Analytical results included four chemicals: (benzo(a)pyrene, benzo(g,h,i)perylene, dibenz(a,h)anthracene, and DRO reported at levels that exceeded ecological risk-based levels and identified as COECs in the ecological risk assessment. The reported levels for the COECs and for an additional chemical, benz(a)anthracene, also exceeded proposed ADEC soil cleanup standards. |
Gretchen Pikul |
| 10/14/1999 |
Site Ranked Using the AHRM |
Initial ranking. |
Gretchen Pikul |
| 8/10/2000 |
Meeting or Teleconference Held |
Public meeting in Takotna, and site visit to Sterling Landing. |
Gretchen Pikul |
| 6/20/2001 |
Update or Other Action |
ADEC received CD copy of Tatalina LRRS Administrative Record (dated April 2001) Disk 1. |
Gretchen Pikul |
| 6/20/2001 |
Meeting or Teleconference Held |
Public meeting in Takotna, site visits to all sites with new 611th project manager, and site-specific inspection for anticipated 2001 fieldwork. |
Gretchen Pikul |
| 10/10/2001 |
Update or Other Action |
Year 2000 Clean Sweep Environmental Survey Report (final dated September 5, 2001, received on October 10, 2001). |
Gretchen Pikul |
| 10/10/2001 |
Update or Other Action |
Air Force field visit and work (including land surveys for institutional controls required by Decision Documents) delayed until mid-September due to in-house crew work conflicts (August 9, 2001); delayed to October due to September 11th terrorist attacks (September 17, 2001); was cancelled for this field season due to bad weather and impassable road conditions (October 10, 2001); field work is scheduled for FY02. ADEC received final Clean Sweep Environmental Survey Report (dated September 2001). |
Gretchen Pikul |
| 10/19/2001 |
Meeting or Teleconference Held |
ADEC particpated in a community meeting in Takotna with Air Force. |
Gretchen Pikul |
| 1/29/2002 |
Meeting or Teleconference Held |
ADEC CS DoD Oversight and Air Force Environmental Restoration and Compliance meeting on 2002 field work. |
Gretchen Pikul |
| 3/4/2002 |
Update or Other Action |
Final Environmental Assessment for Property Disposal (dated August 1997, received on March 4, 2002). |
Gretchen Pikul |
| 3/11/2002 |
Update or Other Action |
The Alaska Department of Environmental Conservation (ADEC), DoD Oversight group, received your letter (dated February 20, 2002) requesting a waiver of 18 AAC 75.355(b) in order to use qualified Air Force personnel for the 2002 fieldwork at Tatalina LRRS. The site project objectives include USAFC ES/CEVO employees obtaining soil and groundwater samples at Installation Restoration Program sites SS-002, SS-003, SS-008, and SS-011, as specified in the project’s forthcoming work plan that will be reviewed and approved, prior to field work, by this Department; the field work is currently scheduled from July through September,
2002.
Per your letter, the proposed qualified samplers are Mr. Joseph Millhouse, Mr. Carl Homlg, and Mr. James Linne of the USAF 611th CES/CEVO. These individuals are currently listed on the ADEC qualified persons website as qualified samplers, and were previously granted a waiver of the 18 AAC7 5.355(b) Impartial Third Party Requirements within ADEC letters dated August 29, 2001 and October 8, 2001.
A waiver of the Impartial Third Party requirement is granted and the 2002 fieldwork sampling by Mr.Millhouse, Mr. Homig, and Mr. Linne is approved. This waiver only applies to this specific project at Tatalina LRRS and does not extend to other projects or samplers. Signed Jennifer L. Roberts Section Manager. |
Jennifer Roberts |
| 6/7/2002 |
Meeting or Teleconference Held |
Site visit, inspections, and meetings at facility with Air Force. Public meeting with Takotna community on June 3, 2002. |
Gretchen Pikul |
| 6/11/2002 |
Document, Report, or Work plan Review - other |
ADEC and Air Force meeting on 2002 field work and work plan; draft work plan dated April 2002 and received on April 19, 2002; comment resolution meeting on April 30, 2002; 2nd draft work plan received May 9 and 10, 2002; 3rd draft received May 28, 2002; 4th draft received on and comment resolution meeting on June 4, 2002; ADEC approval letter dated June 11, 2002. |
Gretchen Pikul |
| 10/21/2002 |
Update or Other Action |
2002 Follow-on RI received. In 2002, three collocated sediment and surface water samples were
collected downgradient of the slope at SS011. The 2002 Follow-on RI recommended additional
monitoring at this location |
Gretchen Pikul |
| 12/9/2002 |
Update or Other Action |
Draft Annual Report received.
The Tatalina LRRS consists of three distinct areas: Upper Camp on Takotna Mountain, Lower Camp & the Airstrip, & Sterling Landing. Because they are so close, the Lower Camp & Airstrip areas are discussed as one overall area.
Lower Camp Hardfill No. 1 (SS 011) and WAA No. 1
Lower camp hardfill No.1 (SS 011) and WAA No.1 are adjacent to each other (Figure 9). Drum storage and disposal reportedly occurred at these sites. In 1997, the USAF completed excavation and removal of buried drums at WAA No. 1. An additional location for drum burial directly downslope from WAA No. 1 was discovered during the 1997 Remedial Investigation. Between five and ten partially buried drums were found, and a soil sample collected from underneath one of these showed the presence of polycyclic aromatic compounds in amounts that exceed levels that have been determined to pose ecological risks.
611 CES/CEVO and ADEC personnel agreed that due to the steep, heavily forested slope that surface sampling of sediment and down gradient stream water would be sufficient for monitoring any possible contamination migration from these sites. The soil and water samples were analyzed for GRO, DRO, RRO, volatile organics (8260B), SVOC (8270 SIM), total RCRA metals, and pesticides and PCBs (EPA methods 8081 A and 8082). All three water samples had barium concentrations above ADEC clean up levels and one had chromium levels above ADEC clean up levels. All three sediment samples had trace amounts of pesticides but no contaminant concentrations were above ADEC clean up levels. Table 2.1 details contaminants above detection at SS-011.
Three sediment and water samples were collected down gradient from SS-011 and WAA No. 1 in FY 2002 in lieu of drilling on prohibitively steep slopes. All three water samples had barium concentrations above ADEC clean up levels and one had chromium levels above ADEC clean up levels. All three sediment samples had trace amounts of pesticides but no contaminant concentrations were above ADEC clean up levels.
No further work is recommended. |
Louis Howard |
| 2/5/2003 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (ADEC), DoD Oversight group, received the Draft Annual Report - Remedial Action and Monitoring Program (dated November 2002) on December 9, 2002. We appreciate the extended review period, have completed our review, and provided comments below.
8.7 Lower Camp Hardfill No.1 (SS-011) and WAA No.1: It is stated that the USAF completed excavation and removal of buried drums; the drum removal was only a partial removal, and should be clarified in this statement. It is stated that an additional location for drum burial directly downslope from WAA No.1 was discovered during the 1997 RI. Please clarify that these drums are not an additional location, but simply the edge of the disposal area where some drums do not have cover material or that have resurfaced from the cover material.
The fifth sentence should be clarified to include the timeframe and rationale for the 611 CES/CEVO and ADEC decision; possibly, “During the June 2002 site inspections, 611 CES/CEVO and ADEC personnel agreed that due to the steep, heavily forested slope that monitoring well installation would be unfeasible, and that sampling of sediment and surface water from the downgradient stream would be sufficient for monitoring any possible contaminant migration from these sites.”
As stated above, the surface water and sediment results need to be compared to 18 AAC 70 and appropriate TBCs (NOAA, ORNL, Ecotox, etc.), and to the site-specific human health and ecological risk assessment levels and background levels; there are no ADEC cleanup levels listed for surface water and sediments in 18 AAC 75. Please make these revisions within the text and associated tables, and on Figure 9.
Analytical Data Sheets:
- As noted in the general comments above, the data validation discussion is not include in this draft report; please provide this information and incorporate any qualifying notes within the text.
- There is data on a soil trip blank which needs to be discussed within the appropriate table and text.
Chain of Custody Records/Sample Receipt Forms:
- The deviations from the approved work plan and FSP should be noted in the appropriate section(s), such as:
- 1023292 with the Chain of Custody Seal absent.
- 1023563 with the Chain of Custody Seal absent, and the temperature blank and cooler temperature above 4±2ºC (7.6ºC and 6.2ºC, respectively).
- 1023564 with the Chain of Custody Seal absent, and the temperature blank and cooler temperature in cooler #1 above 4±2ºC (7.6ºC and 6.2ºC, respectively).
- 1023613 with the Chain of Custody Seal absent, and the cooler temperature above 4±2ºC (7.9ºC).
- 1024464 with the temperature blank and the cooler temperature above 4±2ºC (-0.3ºC and -0.6ºC, respectively).
- 1024660 with >1 cm bubbles in VOA vials.
- 1024812 with bubbles in VOA vials, and temperature blanks in coolers 2 and 5 above 4±2ºC (7.3ºC and 6.3ºC, respectively).
- 1024838 with bubbles in VOA vials, and temperature blanks in coolers 2, 3, and 4 above 4±2ºC (6.5 ºC, 7.2 ºC, and 7.4ºC, respectively).
- 1024939 with Chain of Custody Seal absent. |
Gretchen Pikul |
| 5/27/2003 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (ADEC), DoD Oversight group, received the Draft Follow-on Remedial Investigation at SS03, SS08, and SSll Work Plan (dated April 2003) on April 9, 2003, and the Air Force response to comments on May 27, 2003; the ADEC comment tetter was sent on May1 , 2003. Based on our review of the draft document and the Air Force response to comments, ADEC concurs with the work plan, and therefore approves this document based on the incorporation of these responses, as stated, within the final document.
The Air Force is responsible for the actions of contractors, agents, or other persons who perform work to accomplish the approved work plan. For any activity that significantly deviates from the approved plan, the Air Force shall notify the ADEC and obtain written approval in the form of a work plan amendment before beginning the activity. Any action taken by the Air Force, or an agent of the Air Force, that increases the project’s overall scope or that negates, alters, or minimizes the intent or effectiveness of any stipulation contained in this plan will be deemed a significant deviation from the approved plan. The final determination as to the significance of any deviation and the need for a permit amendment is the responsibility of the ADEC. Therefore, it is recommended that the ADEC be consulted immediately when a deviation from the approved plan is being considered.
Please note ADEC review and concurrence on this document is to ensure that the work is done in accordance with State of Alaska environmental conservation laws and regulations. While ADEC
may comment on other state and federal laws and regulations, our concurrence on this document does not relieve responsible persons from the need to comply with other applicable laws and
regulations. |
Gretchen Pikul |
| 5/29/2003 |
Update or Other Action |
Follow-on Remedial Investigation at SS03, SS08, and SS11 Work Plan; draft dated April 2003 and received on April 9, 2003; ADEC comment letter dated May 2, 2003; Air Force Comment Response received on May 27 and ADEC approval letter dated May 27, 2003; final received May 29, 2003. |
Gretchen Pikul |
| 5/31/2003 |
Meeting or Teleconference Held |
ADEC participated in a public meeting at Takotna and site visits for 2003 field work and general inspections. |
Gretchen Pikul |
| 10/29/2003 |
Update or Other Action |
Follow-on Remedial Investigation at SS03, SS08, and SS11 (draft dated October 2003 and received on October 21; ADEC comment letter dated October 29, 2003). |
Gretchen Pikul |
| 11/4/2003 |
Document, Report, or Work plan Review - other |
2002 Annual Report, Remedial Action and Monitoring Program; draft dated November 2002 and received December 9, 2002; ADEC comment letter dated February 5, 2003; Air Force response to comments received on February 19 and ADEC response sent on February 21; comment resolution meeting on March 17, 2003; draft final received on April 3, 2003; ADEC commented via e-mail on April 16, 2003; final dated April 2003 and received May 2, 2003; ADEC conditional approval letter dated September 25, 2003; final report received October 27, 2003 and CD on November 4, 2003. |
Gretchen Pikul |
| 7/1/2004 |
Update or Other Action |
2003 Follow-on RI received. During the 2003 RI work at SS011, three additional sediment and surface water samples were collected from the drainage water seeps downgradient of the slope. During the 2003 RI, there was no evidence of PHC contamination in surface water or sediment
downgradient from the buried waste drums (USAF, 2004). During the sampling efforts, 10 to 20
partially-buried drums were observed in this area. Following the 2003 RI, no additional monitoring was recommended; however, it was recommended that all the waste drums be removed to prevent potential future contamination. |
Gretchen Pikul |
| 8/9/2004 |
Update or Other Action |
Follow-on Remedial Investigation at SS03, SS08, and SS11 work plan - draft dated June 2004; ADEC received on June 14; ADEC comment letter dated June 16; Air Force Comment Response received on July 6, comment resolution teleconference and ADEC approval letter sent same day. On August 9, 2004, ADEC received 2 calls for field decisions by Air Force contractor. |
Gretchen Pikul |
| 3/25/2005 |
Update or Other Action |
2004 Follow-on RI received. In 2004, RI work at SS011 consisted of soil sampling, waste drum removal, and exploration for further locations of buried waste drums. Six partially-buried waste drums were removed from the slope. Five of the drums were empty; however, one waste drum
contained less than 5 gallons of a material suspected to be diesel fuel. A magnetic tool was used to locate a 30-foot by 100-foot area of the slope where additional waste drums were potentially buried.
Five surface soil samples were collected from the area directly downgradient of the slope where
waste drums were exposed and removed. One sample at SS011 (Sample SS003) had concentrations of PAHs detected at higher concentrations than the other samples. Detected concentrations in Sample SS003 represented a local hotspot, because surrounding locations were orders of magnitude lower. The 2004 Follow-on RI determined that locating the remaining drums, quantifying the area extent of buried materials, and mapping them would be necessary to
properly characterize SS011. |
Erik Norberg |
| 7/18/2005 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (ADEC), Federal Facilities Oversight group, received the Draft Report - Follow-on Remedial Investigation at SS-003, SS-008, and SS-011 (dated March 2005) on March 25, 2005 and the Air Force Comment Response on July 18, 2005; the ADEC comment letter is dated May 20, 2005. Based on the inclusion of the Air Force Comment Responses within the final report, ADEC concurs with the contents of the document.
Please note that the ADEC review and concurrence on this document is to ensure that the work is done in accordance with State of Alaska environmental conservation laws and regulations. While the ADEC may comment on other state and federal laws and regulations, our concurrence on this document does not relieve responsible persons from the need to comply with other applicable laws and regulations. |
Jeff Norberg |
| 8/29/2005 |
Meeting or Teleconference Held |
ADEC and Air Force project managers conducted a site visit to Tatalina LRRS from August 23 to August 26, 2005. The purpose of this visit was to provide an opportunity to view and to discuss the status of ongoing contaminated sites work being performed by the Air Force. |
Jeff Norberg |
| 8/31/2005 |
Document, Report, or Work plan Review - other |
Follow-on Remedial Investigation at SS03, SS08, and SS11; draft report dated March 2005 received on March 25; ADEC comment letter dated May 20; Air Force Comment Response and ADEC approval letter dated July 18; final dated August 2005 received August 31. DRO was detected in each of the five soil samples (Table 3-7 and Figure 3-4 at concentrations ranging from 420 mg/Kg to 11,000 mg/Kg, above the ADEC Method Two cleanup level of 250 mg/Kg.
RRO was detected above the Method Two cleanup level of 10,000 mg/Kg in two samples at 20,000 mg/Kg and 32,000 mg/Kg. In addition, Sample SS03 contained concentrations of seven PAHs that exceeded ADEC Method Two cleanup levels. These analytes were detected at concentrations several orders of magnitude above the concentrations of the same analytes in nearby samples and included:
• Benzo(a)anthracene at 71 mg/Kg, cleanup level of 6 mg/Kg
• Benzo(a)pyrene at 47 mg/Kg, cleanup level of 1 mg/Kg
• Benzo(b)fluoranthene at 44 mg/Kg, cleanup level of 11 mg/Kg
• Dibenzo(a,h)anthracene at 6 mg/Kg, cleanup level of 1 mg/Kg
• Dibenzofuran at 42 mg/Kg, cleanup level of 15.6 mg/Kg
• Indeno(1,2,3-c,d)pyrene at 22 mg/Kg, cleanup level of 11 mg/Kg.
• Naphthalene at 130 mg/Kg, cleanup level of 21 mg/Kg
Sample SS03 also contained higher concentrations of other PAHs than nearby samples, but at concentrations below ADEC Method Two cleanup levels (Appendix C). Arsenic and chromium were detected above Method Two cleanup levels in nearly all of the
samples.
Conclusions: The results of soil samples indicate the presence of POL and PAHs above ADEC Method Two cleanup levels in the soil immediately adjacent to and topographically downgradient of
the buried drums. Metals detected in soil are considered representative of background conditions at the site and are not attributable to Air Force activities. |
Jeff Norberg |
| 2/1/2006 |
Update or Other Action |
File number issued 2655.38.016. |
Aggie Blandford |
| 2/27/2006 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (ADEC), Federal Facilities Restoration Program, reviewed the Draft Report - Follow-on Remedial Investigation at SS-003, SS-008, and SS-011 dated March 2005 and submitted our comment letter on May 20th. According to this document, six 55-gallon drums were removed from the hillside west of SS-011 in August 2004. The drums recovered during this field event were reported as empty and mostly buried, with the exception of one drum, which contained less than five gallons of diesel fuel. Based on findings of the Follow-on RI/FS, evidence suggested that additional drums remain buried at the site and further investigation of the soil downgradient of the buried drums was recommended for Site SS-011.
During a joint site visit conducted on 26 August 2005, the Air Force and ADEC observed a 55-gallon drum located on the steep hillside west of Site SS-011 stenciled with Air Force markings. This drum appeared to be intact and contained a substantial volume of unknown liquid.
Given that our August site visit confirmed the findings of the Follow-on RI/FS, ADEC recommends that a thorough site reconnaissance be performed to locate additional drums on the hillside adjacent to Site SS-011; characterize contents and impacted media; and dispose in accordance with applicable Alaska State laws and regulations. |
Jeff Norberg |
| 7/30/2007 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (department), Contaminated Sites Federal Facilities Restoration Program, received the Draft Work Plan Addendum for the Follow-on Remedial Investigation at Sites SS003, SS008, and SS011 at Tatalina LRRS, Alaska (dated June 2007) on 28 June. We have completed our review, and have provided comments below.
General Comments: 1) Text within Section 1.2 indicates that, “The project objectives will be accomplished by locating and mapping abandoned drums along the hillside and collecting surface soil samples from beneath the drums that show evidence of leaking to evaluate their potential as a source of contamination.” Based on findings of the 2004 Follow-on RI/FS, evidence suggested that additional drums remain buried at the site and further investigation of the soil downgradient of the buried drums was recommended for Site SS-011.
On 27 February 2006, our department issued a letter requesting that the Air Force conduct additional drum removal and characterization at Site SS-011. This letter also referenced a site visit conducted by the Air Force and ADEC on 26 August 2005, when we observed a 55-gallon drum located on the steep hillside west of Site SS-011 stenciled with Air Force markings. This drum appeared to be intact and contained a substantial volume of unknown liquid.
Based on these findings, ADEC recommended that a thorough site reconnaissance be performed to locate additional drums on the hillside adjacent to Site SS-011; characterize contents and impacted media; and dispose in accordance with applicable Alaska State laws and regulations.
Therefore, in addition to the objectives stated in the 2007 Follow-on RI Work Plan Addendum, the Air Force should include the following: a) If drums are found containing residual liquid or other waste, the Air Force should characterize the contents, and dispose in accordance with applicable Alaska State laws and regulations. b) If buried drum cache(s) are encountered during the 2007 investigation, field staff should conduct a magnetic survey to delineate areal extent and survey boundary coordinates with GPS so that it may be relocated in the future.
1.2 Project Objectives:
a) Please see General Comment No. 1 and make necessary revisions.
b) The coverage area defined as “along the hillside” for this investigation appears vague. Given that the hillside down-slope from the Hardfill No. 1 and Waste Accumulation Are No 1 (Site SS011) covers considerable area, please attempt to better define areal extent of investigation.
(pg. 11) 3.2 Field Activities: a) Given that there are an unknown number of partially-buried drums along the steep hillside at SS011 and a limited sampling budget to analyze up to ten surface soil samples, please incorporate appropriate field screening technique(s) to help field staff identify samples for laboratory submittal.
b) As discussed in General Comment No. 1, findings of the 2004 Follow-on RI/FS, suggested that additional drums remain buried at the site. One area suspected of containing buried drums measured 30 by 100 feet. Please conduct a simple geophysical survey using a magnetic locator to help determine the existence and areal extent of subsurface debris at Site SS011 and survey the boundary coordinates using GPS. This information should also be depicted on site figure(s) within the 2007 Follow-on RI/FS report.
c) If contaminated soil is identified during this investigation the field staff should attempt to ascertain the horizontal and vertical extent using hand tools. This information should be depicted on site figure(s) within the 2007 Follow-on RI/FS report.
d) When drums are encountered, the field crew should attempt to record its general condition (e.g., buried, exposed, or partially exposed on the ground surface; original bung caps in place; breached/ empty; intact/ empty; intact/ containing residual liquid or other waste; legible drum labels which identify the original contents and whether military issue; etc.).
It is a critical to this investigation to identify conditions that could result in ongoing site contamination, including the potential for leaching of in-situ contamination and the presence of leaking barrels, drums, tanks, or other containers (18 AAC 75.335). If drums are found containing residual liquid or other waste, the Air Force will need to characterize the contents, and dispose in accordance with applicable Alaska State laws and regulations. |
Jeff Norberg |
| 2/8/2008 |
Update or Other Action |
Follow-On RI at SS11 Technical Memorandum received for review and comment.
The 2007 Follow-on RI at SSI1 involved mapping the area of buried drums using a magnetometer coupled with a high accuracy global positioning system (UPS). The area of buried debris at SS11 is located approximately 50 feet west and downslope of the ridgeline at SS11 (Figure 2). The entire area is heavily forested with alder, birch, and spruce, while the area of buried debris at SS511 is overgrown with low vegetation and alder. There is an apparent two wheeled tracked trail leading from the ridgeline downslope towards the west to the area of buried debris. This trail is also overgrown with alder and low vegetation.
Depending on the distribution and orientation of the buried debris (i.e., vertical, horizontal, or stacked drums), and presuming the 2,500 square foot area is entirely drums, the area may contain tip to 400 to 500 drums if tightly packed. However, this estimate represents the maximum, wherein the actual number of buried drums at SS II is most likely significantly less.
All 10 samples had detections of DRO, ranging from a minimum of 100 mg/Kg to a maximum of
200,000 mg/kg (Table 1). Nine of the samples were above the ADEC Method II Soil Migrationto-
Groundwater cleanup level of 250 mg/Kg, while five of the samples were above the ADEC
Method II Ingestion cleanup level of 10,250 mg/Kg.
All 10 samples had detections of RRO, ranging from 700 mg/Kg to a maximum of 160,000
mg/Kg (Table 1). Five of the samples were above the ADEC Method 11 Soil Migration-to-
Groundwater cleanup level of 1 1,000 mg/Kg and Ingestion cleanup level of 10,000 mg/Kg.
Pesticides were detected in all 10 samples (Table 4). Detections were not consistently distributed amongst the 10 samples, suggesting that a variety of pesticides were present in the buried drums.
The results of the primary Sample 004 versus the duplicate Sample 204 were inconsistent,
suggesting that homogenization of the sample was incomplete and/or errors in dilution necessary
due to the high amount of DRO and RRO present in the samples.
All of the pesticides in the SO8 IS suite, with the exception of aldrin and dieldrin, were detected. Of the 21 analytes in the pesticide suite, 14 have corresponding ADEC Method II Groundwater cleanup levels. Of these 14, three analytes (alpha-benzene hexachloride, gamma- benzene hexachloride lindane, and endrin) had detections in excess of the ADEC Method H Groundwater cleanup levels.
With the exception of the detection of naphthaiene in Samples 004 (140 mg/Kg) and 204 (5,200 mg/Kg) and acetone in Sample 204 (32 mg/Kg), all VOCs were detected at trace levels, and all but seven were qualified with the "J" qualifier as estimates.
The detections from Samples 004 and 204 (duplicate of 004) were 140 vs. 5,600 mg/Kg and 5,200 vs. 13,000 mg/Kg for SW8260B and SW8270C, respectively. The lab was contacted about this discrepancy and the data revalidated to ensure there were no errors.
The discrepancy between primary and duplicate and across the two methods is attributed to
inconsistent homogenization and the necessity for dilution due to the high constituent levels,
notably DRO at 1 10,000 and 200,000 mg/Kg and RRO at 38,000 and 57,000 mg/Kg for SW8260B and SW8270C, respectively. However, both the DRO and RRO detections were flagged with "D" (dilution) and "Z" (indicating that the chromatographic fingerprints did not resemble a petroleum product) qualifiers. |
Louis Howard |
| 2/19/2008 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed. |
Louis Howard |
| 3/17/2008 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft Follow-On Remedial Investigation at SS03, SS08 and SS11 Technical Memorandum February 2008 Contract F41624-03-D-8603 Task Order 214.
ADEC requests clarification on why the nature and extent of groundwater contamination from the release of hazardous substances at this site has not been attempted with the installation of temporary well points, grab samples from hydro-punch/geoprobe like devices or other means appropriate for site conditions at SS11. This would appear to be a data gap in any risk assessment or remedy selection with the level of soil contamination present in the soil at the site are at free product concentrations (e.g. Section 3.1 Petroleum Hydrocarbons 200,000 mg/kg diesel range organics (DRO) and 160,000 mg/kg residual range organics (RRO)).
Table of Contents 3.4 Pesticides and Herbicides Page i
Herbicides were not analyzed for and ADEC requests reference to herbicides needs to be deleted from this section.
List of Tables
Table 4 2007 Analytical Results – Pesticides/Herbicides (SW8082)
Herbicides were not analyzed for and ADEC requests reference to herbicides needs to be deleted from this section.
The text states out of ten (10) drums, nine had evidence of stained soils beneath them where their contents had previously leaked. A release has occurred and an unpermitted discharge of contaminants into the environment continues to occur at this site.
ADEC regulations, 18 AAC 75.325(f) states: “A responsible person shall (1) to the maximum extent practicable, (A) use permanent remedies;
(B) recover free product in a manner that
(i) minimizes the spread of contamination into an uncontaminated area by using containment, recovery, and disposal techniques appropriate to site conditions;
(ii) avoids additional discharge; and
(iii) disposes of the recovered free product in compliance with applicable local, state, and federal requirements;
(C) complete cleanup in a period of time that the department determines to be protective of human health, safety, and welfare, and of the environment; (D) prevent, eliminate, or minimize potential adverse impacts to human health, safety, and welfare, and to the environment, onsite and offsite, from any hazardous substance remaining at the site; and (E) evaluate and perform cleanup of surface soil staining attributable to a hazardous substance;” Appendix A site photographs show obvious staining of the soil which need to be properly addressed by the Air Force.
The incorrect laboratory methods are cited for several analytes. The correct laboratory methods are as follows: Method 8081S for Pesticides, Method 8082 for PCBs, Method 6020 and 7471A for metals. Herbicides were not analyzed for and ADEC requests reference to herbicides needs to be deleted from this section.
The text states: “A complete analytical data package including case narrative, data sheets, and completed chain-of-custodies are provided in Appendix C per the Alaska Department of Environmental Conservation (ADEC) Technical Memorandum: 06-002, dated 9 October 2006.”
Please note the tech memo also requires: “All reports submitted to the Department containing analytical laboratory sample results shall contain a completed Laboratory Data Review Checklist and a Quality Assurance (QA) Summary. No quality assurance summary was included in the submitted report.
3.1 Petroleum Hydrocarbons Page 3 and throughout the document
The text states diesel range organics (DRO) had nine samples above the ADEC Method II soil migration to groundwater cleanup level of 230 mg/kg and five samples for residual range organics (RRO) were above the ADEC Method II groundwater cleanup level of 9,700 mg/kg and ingestion cleanup level of 8,300 mg/kg. ADEC was unaware that Tatalina Long Range Radar Site (LRRS) was in the over 40-inch Zone for precipitation. The correct statement for RRO cleanup level would be the “migration to groundwater” cleanup level not groundwater cleanup level.
An error has been made by the contractor on which zone for cleanup levels at Tatalina LRRS is applicable. The August 2005 Follow-On Remedial Investigation at SS03, SS08 and SS11 Report states under 2.1.1 Climate at page 2-1 : “The average annual total precipitation is 15 inches, with 84 inches of snowfall.” It appears the correct determination for source areas at Tatalina LRRS would meet the definition of “under 40 inch zone” i.e. a site that receives mean annual precipitation of less than 40 inches each year.
|
Louis Howard |
| 5/5/2008 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft February 2008 Human Health & Ecological Risk Assessment work plan for SS03, SS08, SS11. A risk assessment is a process by which potential risks to human and/or environmental health from exposures to hazardous or toxic substances is evaluated. Primary to that analysis is the understanding of what the hazardous or toxic substance is and what the potential for exposure to such is. In that regard, a thorough understanding of site conditions (i.e. adequate site characterization) is necessary to formulate any meaningful risk statement.
It is in the opinion of ADEC that the SS11 site has not been adequately characterized as to the nature (identification of potentially toxic substances contained within or in association with drums) nor the extent of contamination. Without adequate sampling data defining the horizontal and vertical extent of contamination at SS11, a meaningful risk assessment cannot be conducted. Therefore, this site will not be considered for risk assessment purposes at this time.
ADEC requests the Air Force elaborate on how the 1992 site inspection (SI) sample locations were evaluated in 1997. Request clarification on whether the 1992 data was excluded from the 1998 Final RI Report. Also, ADEC will require the Air Force to utilize the 1992 sampling results for risk screening purposes, unless the Air Force can demonstrate otherwise that the data is invalid for risk screening purposes (i.e. QA/QC issues with 1992 laboratory analyses).
ADEC will require the more conservative (higher) concentration between the primary and duplicate sample results should always be presented. ADEC requests the Air Force provide the 1997 baseline ecological risk assessment justifying the elimination of chemicals of potential environmental concern (COPECs).
ADEC requests the Air Force clarify who recommended more monitoring at the SS11 site and who made the determination that it was not technically feasible, but that future sampling events would attempt to study downgradient conditions. ADEC requests the Air Force identify what the product from the last drum removed during the 2004 field effort and what made it acceptable for an oil burner and whether all of it shipped to Elmendorf Air Force Base.
ADEC requests the Air Force clarify what is meant when comparing polynuclear aromatic hydrocarbons (PAHs), diesel range organics (DRO), residual range organics (RRO), and metals concentrations to background. Metals are typically the only contaminants that ADEC considers for background* evaluation.
*Background refers to substances or locations that are not influenced by the releases from a site, and are usually described as naturally occurring or anthropogenic:
1) Naturally occurring - substances present in the environment in forms that have not been influenced by human activity; and,
2) Anthropogenic - natural and human-made substances present in the environment as a result of human activities (not specifically related to the site in question).
Some chemicals may be present in background as a result of both natural and man-made conditions (such as naturally occurring arsenic and arsenic from pesticide applications or smelting operations).
Site activity (such as waste disposal practices) may cause naturally occurring substances to be released into other environmental media or chemically transformed. The concentrations of the released naturally occurring substance may not be considered as representative of natural background according to CERCLA 104(a)(3)(A).
The text states that out of ten (10) drums all had evidence of stained soils beneath them where their contents had previously leaked. An Air Force Technical Memorandum (Feb. 2008) identifies oil and other hazardous substances are present in the surface soils. An unpermitted discharge of contaminants has occurred at SS11. This release, the threat of a continuing source of contamination from the buried drums at SS11, and lack of containment is a violation of Alaska Statutes and Pollution Control Regulations.
Alaska Statute 46.03.822 Strict liability for the release of hazardous substances.
Records available to the Alaska Department of Environmental Contamination (ADEC) indicate that the Air Force meets one or more of the following criteria as being strictly liable, jointly and severally, for damages, for the costs of response, containment, removal, or remedial action incurred by the state:
|
Louis Howard |
| 7/29/2008 |
Update or Other Action |
Response to ADEC 5/5/2008 comments: SS011 has been investigated and to a large extent remediated, that is, a significant removal action was performed (NOTE: only 2 samples of the required 81 confirmation samples were taken for the 20,000 sq. ft. excavation). Just recently while researching the historical work for this site, a project, which was relegated to hardly a footnote in more recent documents, was discovered.
The project report was not in the Admin Record and only one copy was found in our records vault. The report was found because of the ADEC letter dated July 6, 1998 in the Admin Record. The report is being scanned and will be available for distribution soon. The ADEC files should have this report as well. Once all parties have this report site SS011 can be discussed
more completely.
Regarding the adequacy of the soil background data set, ADEC comment 17 on the 1997 Draft RI Report states, “We agree that 5 or 6 soil samples, as collected at the Upper and Lower Camp areas, is probably adequate (although minimally so) for establishing background concentrations.” In addition, ADEC comment 18 on the 1997 Draft RI Report states that,
“…Either the text or the table should explain that surface soil background samples were also used for comparison to subsurface soil samples.” However, ADEC’s comments did not say that this comparison was inappropriate or unacceptable. (NOTE: letter did not state is was "acceptable" or "appropriate" either-ADEC is now stating that it is unacceptable and inappropriate). This comment applies to the Air Force’s use of six surface, one subsurface, one sediment, one water from the infiltration gallery, and one surface water sample to represent background.
ADEC considers the number of samples to be inadequate for representing background. The comment appplies to the Air Force's use of surface soil background being used for both surface and subsurface soil as surface water background may not be used for both surface and ground water. Comparisons may only be made between soil background samples of similar depth and soil type for site soils. Likewise, water background shall only be compared to like site water. Surface soil background will not be used to compare to subsurface site soils.
ADEC will not consider one background sediment sample as being sufficient for the Air Force to determine background sediment conditions. ADEC will not consider one background surface water sample as being sufficient to determine background surface water condition. |
Louis Howard |
| 8/18/2009 |
Document, Report, or Work plan Review - other |
Staff reviewed & commented on the Draft Focused Feasibility Study at SS003, SS008, & SS011, Draft Contract F41624-03-D-8608, Task Order 0214 Tatalina LRRS July 2009. Typically, following completion of the remedial investigation/feasibility study (RI/FS), the results of the detailed analyses, when combined with the risk management judgments made by the decision-maker, become the rationale for selecting a preferred alternative & preparing the Proposed Plan. Therefore, the results of the detailed analysis, or more specifically the comparative analysis, should serve to highlight the relative advantages & disadvantages of each alternative so that the key tradeoffs can be identified.
It will be these key tradeoffs coupled with risk management decisions that will serve as the basis for the rationale & provide a transition between the RI/FS report (or in this case the Focused Feasibility Study-FFS) & the development of a Proposed Plan (see EPA/540/G-89/004 OSWER Directive 9355.3-01 October 1988 Guidance for Conducting Remedial Investigations & Feasibility Studies Under CERCLA).
ADEC requests the Air Force remove of all text from the FFS regarding the preferred alternative selection for each site until the Proposed Plan stage where the preferred alternative is selected & presented (see EPA 540-R-98-031 OSWER 9200.1-23P PB98-963241 A Guide to Preparing Superfund Proposed Plans, Records of Decision, & other Remedy Selection Decision Documents July 1999).
ADEC interprets the phrase “subsurface water” to have the same meaning as groundwater. Specifically, 18 AAC 990(46) “groundwater” means: (A) water in the saturated zone, for purposes of evaluating whether the groundwater is a drinking water source under 18 AAC 75.350; or (B) water beneath the surface of the soil, for purposes of evaluating whether the water will act as a transport medium for hazardous substance migration. ADEC requests the Air Force change the text in the document to refer to groundwater instead of subsurface water.
Additionally, the seeps mentioned throughout the FFS are considered to be surface water by ADEC. As the groundwater emerges as surface water, the surface water quality standards apply. The document should point out this distinction & these seeps are regulated by 18 AAC 70 Water Quality Standards (as amended as of July 1, 2008) & the companion document Alaska Water Quality Criteria Manual for Toxic & Other Deleterious Organic & Inorganic Substances (as amended as of May 15, 2003). The word “seep” should be footnoted & defined as “surface water” at least once in the document & then footnotes are to be used for all of the tables where concentration ranges are listed for seeps.
ADEC has a global comment on arsenic risk through the document. Arsenic should not be discounted as a risk driver for a site on the basis that it is within background concentrations. ADEC requests the Air Force rework the text when discussing risk from arsenic to state that although arsenic risk exceeds acceptable risk levels, it is within background concentrations & therefore not considered a contaminant for remedial consideration.
ERP Site SS011 Results Page ES-4: The text refers to the HHERA results being used to establish RAOs for SS011. ADEC requests the Air Force change the text as follows-
• Prevent current and future human exposure to contaminated surface soil on the slope immediately west of WAA No. (please add the number “1” to this site reference)
• Prevent exposure of mammalian and avian species to contaminated surface soil.
2.2.3 ERP Site SS011 Page 2-6: ADEC requests the Air Force change the bullets to the following-
• Prevent current and future human exposure to petroleum and pesticide contaminated surface soil on the slope immediately west of Waste Accumulation Area No. 1 (Figure 2-3).
• Prevent exposure of mammalian and avian species to petroleum and pesticide contaminated surface soil at SS011 (Figure 2-3).
2.3.3 ERP Site SS011 Page 2-16: The text states: “A series of site-specific cleanup levels have been calculated using the results of the updated HHERA (USAF, 2009) and are provided in Appendix A. Those RBCLs have been adopted as the quantitative PRGs for SS011 and are summarized in Table 2-4 for human and ecological receptors.” ADEC requests the Air Force provide clarification in the text of the report on what exposure group their RBCLs are protective of. It is not spelled out in the text of the report and only found in the Appendix RBCL tables. |
Louis Howard |
| 8/20/2009 |
Risk Assessment Report Approved |
Final Risk Assessment for SS03, SS08, & SS11 received. Potential sources at SS11 include WAA No. 1, a region with buried drums, & Hardfill No. 1, a disposal area that received construction & demolition debris. The majority of the drums at WAA No. 1 were removed in 1997. Most drums were rusted & contained no hazardous materials or products. The 1997 Final RI report indicated DRO & RRO were detected at a test pit, & VOCs, SVOCs & pesticides were detected in soil samples collected beneath partially-buried drums. Soil samples collected in a test pit downgradient from SS11 had low contaminant concentrations; the total extent of contamination, however, could not be determined due to limited sampling.
During the 2002 & 2003 Follow-on RIs, sediment & surface water samples were collected downgradient of SS11 to determine if there was contaminant migration. None of the samples had detections above the cleanup criteria that were not considered representative of background conditions, indicating the 2 disposal areas are not significant sources of contamination. During the 2004 Follow-on RI, the remaining exposed drums were removed & more soil samples were collected. DRO concentrations exceeded cleanup criteria in all soil samples & PAH concentrations exceeded cleanup criteria in 1 soil sample.
No COPCs were identified for surface water at SS11. Arsenic & chromium were identified as COPCs for sediment at SS11. Groundwater was not observed beneath SS11 during site investigations. Potential direct exposure pathways (i.e., oral, dermal, or inhalation routes of exposure) between surface water COPCs & site workers, site workers/recreational hunters, trench workers or site visitors are incomplete. Furthermore, the surface water at SS03, SS08, & SS11 is present only intermittently so any potential incidental contact with this water would be potentially minimal. Potential exposure to surface water at SS03, SS08, & SS11 is deemed complete, but insignificant. No COPCs were identified for SS11 subsurface water. Therefore, exposure pathways & risk estimates are the same between current & future human receptors at SS11.
Cumulative carcinogenic risk & noncarcinogenic HI estimates for a current / future site worker across all exposure media were 2 x 10-3 & 14, respectively, for non-PHC COPCs. Primary contributors to a carcinogenic risk estimate in excess of ADEC’s acceptable risk criterion of 1 x 10-5 were arsenic (EPC = 10 mg/kg) & various PAHs in surface soil; & arsenic (EPC = 59 mg/kg) in subsurface soil. Primary contributors to a noncarcinogenic HI in excess of ADEC’s acceptable HI criterion of 1 were 2-methylnaphthalene (EPC = 3,697 mg/kg) & naphthalene (EPC = 3,555 mg/kg) in surface soil. The cumulative noncarcinogenic HI estimate for a current / future site worker exposed to PHC-related COPCs was 1, which is equal to ADEC’s acceptable HI criterion of 1.
Cumulative carcinogenic risk & noncarcinogenic HI estimates for a current / future trench worker across all exposure media were 1 x 10-4 & 14, respectively, for non-PHC COPCs. Primary contributors to a carcinogenic risk estimate in excess of ADEC’s acceptable risk criterion of 1 x 10-5 were various PAHs in surface soil. Primary contributors to a noncarcinogenic HI in excess of ADEC’s acceptable HI criterion of 1 were 2-methylnaphthalene (EPC = 3,697 mg/kg) & naphthalene (EPC = 3,555 mg/kg) in surface soil. The cumulative noncarcinogenic HI estimate for a current / future trench worker exposed to PHC-related COPCs was 2, which exceeds ADEC’s acceptable HI criterion of 1. Primary contributors to a noncarcinogenic HI in excess of ADEC’s acceptable HI criterion of 1 were DRO (EPC = 80,000 mg/kg) & RRO (EPC = 60,000) in surface soil.
Cumulative carcinogenic risk & noncarcinogenic HI estimates for a current / future site visitor across all exposure media were 1 x 10-4 & 0.8, respectively, for non-PHC COPCs. Primary contributors to a carcinogenic risk estimate in excess of ADEC’s acceptable risk criterion of 1 x 10-5 were various PAHs in surface soil. The cumulative noncarcinogenic HI is below ADEC’s acceptable HI criterion of 1. The cumulative noncarcinogenic HI for a current/ future site visitor exposed to PHC-related COPCs was 0.06, which is below ADEC’s acceptable HI criterion of 1.
COPECs identified for SS11 surface water includes barium, chromium, carbon disulfide & chloromethane. COPECs identified for SS11 sediment include inorganics, DDT, & RRO. Ecological HQ & HI estimates were calculated for the following receptors exposed to COPECs in soil: tundra vole (herbivore), masked shrew (invertivore), & least weasel (carnivore). Ecological HQ estimates in excess of 1.0 were calculated for the tundra vole, masked shrew, & least weasel exposed to soil. The highest HQ estimate (57) was calculated for the masked shrew & was attributable to DRO in soil (EPC = 79,575 mg/kg). No ecological HQ estimates in excess of 1.0 were calculated for the mink exposed to sediment. |
Louis Howard |
| 5/10/2010 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the October 15, 2009 Meeting Minutes SS003, SS008, and SS011, Tatalina LRRS. ADEC concurs with the conceptual preferred remedies which will be incorporated in a future Proposed Plan and Record of Decision for these three source areas (SS003, SS008, SS011).
Site SS003:
* Institutional Controls with Long Term Monitoring as a remedial alternative for groundwater at site SS003.
* Vegetative cap consisting of grasses and/or plants native to Alaska will be used to address stained [petroleum constituents only] surface soil in the areas were analytical results indicate the presence of remnant petroleum hydrocarbons (predominantly within the bermed areas where the former storage tanks were located).
Site SS008:
* Actively remediate the area with PCB concentrations exceeding cleanup levels.
* Actively treat sediment near the culvert(s) that contain pesticides.
* Evaluate potential for active remedial action regarding groundwater based on summary of results for the monitoring well with at least one concentration exceeding Method 2 levels
Site SS011:
* Remove any existing visible drums within the area investigated in 2008
* Vegetative cap consisting of grasses and/or plants native to Alaska will be used to address stained [petroleum constituents only] soil associated with the visible drum
While ADEC may comment on other state and federal laws and regulations, our comments do not relieve responsible persons from the need to comply with other applicable laws and regulations.
|
Louis Howard |
| 10/15/2010 |
Meeting or Teleconference Held |
Meeting minutes from October 15, 2009 meeting. Project: Tatalina Feasibility Study,
Sites SS03, SS008, and SS011, Job Number 1851216. Participants: Louis Howard, ADEC, Marty Brewer, ADEC, Earl Crapps, ADEC, Robert Johnston, 611th CES/CEAR, Michael McCrum, MWH and Aseem Telang, MWH.
Robert indicated that he called the meeting to discuss the next phase of work at Sites SS003,
SS008 and SS011 at Tatalina LRRS. Robert wanted to get ADEC input on appropriate remedial
action at each of these three sites so he can program next year’s work.
The first several minutes of the meeting focused on bringing the ADEC representatives up to
speed on previous characterization efforts, with emphasis on the nature and extent of chemicals
of potential concern (COPCs) at each site. This portion of the discussion led to the
understanding that the primary COPCs at all three sites were petroleum hydrocarbons (and
related organic compounds). There is one location where sampling results indicated a PCB
concentration of approximately 17 mg/kg in surface soils at SS008. ADEC indicated that there
may be some flexibility in remedial action if the concentration is between 1 and 10 mg/kg, but
concentrations above 10 mg/kg require active remedial action.
Site SS011:
The ADEC was more familiar with the issues associated with this site than at SS003 and SS008
as characterization efforts at SS011 were performed in 2008. All parties agreed that access to the area where drums have been observed is difficult and lack of ready access could impact. MWH
initiated the discussion by confirming that there are no surface water bodies in the immediate
vicinity of the area investigated in 2008. The rest of the discussion focused on the drum and
associated stained soil. Following a brief summary of results from the 2008 effort, the group
discussed possible remedial action. As a result of that discussion ADEC indicated that they
would prefer the Air Force:
- Remove any existing visible drums within the area investigated in 2008
- Remove all stained soil associated with the visible drum
The ADEC did not indicate that they would ask the Air Force to extend removal activities to
include drums or other debris that is not currently visible at the surface. The acknowledged that the magnetometer results could be skewed by the presence of benign ferrous metal objects (ie. rebar, scrap metal, etc.) |
Louis Howard |
| 8/31/2011 |
Update or Other Action |
Draft Proposed Plan received for SS003, SS008, SS011 & LF004. SS003. CERCLA Section 101 (14) excludes certain substances from the definition of hazardous substance, thus exempting them from CERCLA. These substances include petroleum, meaning "crude oil or any fraction thereof." The EPA interprets this to include hazardous substances that are normally mixed with or added to crude oil or crude oil fractions during the refining process. Contamination resulting from spills of heating oil, diesel fuel, jet fuel, & gasoline are exempt from CERCLA. However, contamination caused by petroleum spills are regulated under Alaska Administrative Code, Title 18, Chapter 75 (18 AAC 75), Oil & Other Hazardous Substances Pollution Control.
The primary area of SS011 consists of WAA Number 1 and area is located at Lower Camp. Between 1997 and 2007, five Rls were conducted at 88011. There were multiple removal actions to remove the stored waste drums. The 1997 report indicated neither PCBs nor petroleum hydrocarbons were present above ADEC Method Two cleanup levels. The 2003 report indicated there was no evidence of petroleum product contamination in surface water or sediment downgradient from the buried waste drums. In 2004, surface samples downgradient of the slope where waste drums were exposed and removed had RRO results ranging from 2,300 to 32,000 mg/Kg; and DRO results ranged from 420 to 11,000 mg/Kg. One sample had polynuclear aromatic hydrocarbons (PAHs) detected at higher concentrations than the other samples, representing a hotspot.
Ten partially-exposed drums were documented in 2007 and remain on site, and a magnetometer coupled with a high accuracy global positioning system was used to determine the potential extent of possible buried drums. The extent of potentially-buried debris registering a magnetic signal was approximately 2,500 square feet. 8urface soils collected from the stained area beneath the ten drums results for DRO ranged from 240 to 200,000 mg/Kg, while residual range organics (RRO) results ranged from 700 to 160,000 mg/Kg.
The risk assessment found that exposure pathways were complete for both current and future site workers, trench workers, and recreational hunters for surface soil (SS003, SS008, and SS011). Results of the ADEC-approved human health risk assessment indicate there is a risk to site workers from naphthalene (SS003 and SS011), DRO (SS011), RRO (SS011), and various PAHs (SS011).
For SS011, the preferred soil remedial alternatives are Excavation with Off-site Landfilling for exposed debris and areas of stained soil, and ICs for the remainder of the site. Excavation with Off-site Landfilling is protective of overall human health and the environment by eliminating COPC concentrations in designated areas, while ICs would serve to reduce human and ecological exposure to the remaining soil.
There are no Location-Specific or Action-Specific ARARs applicable to the remedial alternatives evaluated for SS011. Excavation with Off-site Landfilling removes COPCs from the site. ICs do not address chemical specific ARARs as well as other alternatives. ICswould prevent exposure to subsurface soil in the attainment area, but may not be effective in preventing ecological receptor exposure.
In addition to the above ICs, the following proposed activities would be conducted:
A land survey would be conducted at ERP Sites SS003, 8S008, SS011, and LF004 to identify site boundaries. This information would be used to update land records and the Tatalina LRRS comprehensive map and Base Master Plan. Any activity that is inconsistent with IC requirements, objectives, or controls, or any action that might interfere with protectiveness of the ICs, would be addressed by the Air Force as soon as practicable after discovery. In no instance would ADEC be notified later than 10 days after the Air Force becomes aware of a deficiency.
The ICs at a site would extend indefinitely, to ensure that human and ecological receptors are protected from potential exposures. Periodic reports of IC monitoring would be prepared at a frequency of at least once every 5 years and provided to ADEC on an informational basis only with copies filed in the Administrative Record.
|
Louis Howard |
| 12/22/2011 |
Document, Report, or Work plan Review - other |
Air Force responses to ADEC comments received.
General Comments:The number of acronyms will be reduced. Acronyms that are not used multiple times will be eliminated. A glossary will be added to the end of the document.
Page 2 and 3: Disagree. The PRGs, which based on risk –based cleanup levels (RBCLs) calculated according to ADEC methods, were not part of the baseline risk assessment, but were presented in the FS (RBCLs calculated in Appendix A of the final FS). The PRGs are considered preliminary until they are finalized as cleanup standards in the Record of Decision.
Page 8: A. The following sentence will be inserted to describe the depth to groundwater: “Depth to groundwater at this site ranged from 12.85 ft bgs to 7.70 ft bgs in 2003” The text will be modified to indicate the subsurface soil pathway is incomplete and will not be considered further.
Figure 3: A note will be placed in the legend that all results exceed PRGs and the PRG table will be referenced.
The following text will be added: “The source of this DRO contamination is unknown, but was evident by the petroleum odor and staining found in 1997. No further delineation or surface water samples were collected.”
Figure 4: A. Investigations into PCE and PCB contamination indicated that these contaminants were not found throughout the site. These individual locations were not well delineated and will need to be field screened and/or laboratory tested during remedial action.
With respect to PCE, the sediment sampling location was at the outlet of a drain pipe. The following text will be added: “Surrounding boreholes to the sediment sample did not encounter groundwater, but there was no PCE present in the soil samples.”
BH-21: The following text will be added: “Eleven boreholes were completed in 1997 and 1999. Only one had PCB contamination. This is likely an isolated occurrence due to the borehole’s isolated location in a small clearing.”
Page 12 LF004: The text will be corrected to say: “No contaminants of concern were detected above ADEC method two cleanup levels for surface soil, subsurface soil, groundwater, or downgradient surface water and sediment samples.”
Page 13: E. The RAOs section will be modified to more accurately summarize the RAOs that were included in the final FS.
Table 2: The tables will be modified to reflect use of TSCA-permitted facilities for PCBs in soil and non-TSCA permitted facilities for petroleum-impacted soil.
Page 15: Details of soil treatment methods will be specified in Remedial Action Work Plans, to be developed after the alternatives are selected and the Record of Decision is finalized.
Page 16: The cited sentence will be modified to read: “This would result in a reduction of COPC concentrations through volatilization and enhanced microbial metabolization of hydrocarbons adsorbed to soil.”
Page 17: C. The cited sentences will be modified to read: “…community acceptance will be evaluated after the comment period, and public comments will be addressed in the ROD. The preferred alternatives may change in response to public comment or new information.”
Table 3: A. Tables for comparative analysis of groundwater will be added for sites SS003 and SS008.
Table 3 Natural Attenuation: Natural attenuation is a passive remedy that utilizes naturally-occurring treatment mechanisms to degrade contaminants and decrease concentrations. Although it is not an active treatment method, it does include treatment as well as monitoring. The scoring for natural attenuation will not be modified, consistent with the Final FS, although a footnote will be added to the scoring for “Reduction of Toxicity…” noting that passive treatment mechanisms are utilized.
Table 4: A. The basis of PRGs is listed in the key “PRG – preliminary remediation goal, based on the risk-based cleanup level.” There is no reference to Table C because the PRGs for groundwater are based on the risk based cleanup levels.
See response to comment 2, part D. PRGs will be finalized as cleanup levels to be specified in the ROD. The values in the Proposed Plan are “Preliminary” because they have not been finalized, and because this is the opportunity for state and public comment on these values.
Table 7: B. PCE was not carried through as a COPC/COPEC during the HHERA because the screening benchmarks were not exceeded. PCE results will be removed from Figure 4. Lead will be added to Table 7 with ADEC Method 2, Table C cleanup goal of 0.015 mg/L.
Page 22 LF004: Text will be modified to say “The landfill is not lined; therefore, ICs alone do not meet the long-term effectiveness criteria as a potential leachate problem would go undetected.” |
Louis Howard |
| 6/13/2012 |
Update or Other Action |
Pre-Draft ROD for SS003, SS008, SS011, LF004 received via electronic mail. Sites SS003, SS008, SS011, and LF004 at Tatalina LRRS cannot support unlimited use and unrestricted exposure due to hazardous substances and contaminants remaining in place after implementation of the selected remedy. Land use restrictions are required as part of this response action and will be achieved through imposition of LUCs that limit the use and/or exposure to those areas of the propery, including water resources, that are contaminated.
At ERP Site SS011, exposed debris and excavated stained soils and sediments will be disposed at
an off-site landfill.
To restrict current and future access or exposure to soil and groundwater at all four ERP Sites,
the following proposed ICs would be implemented:
- The Tatalina LRRS comprehensive map and Base Master Plan would be updated to show the boundaries of each site to restrict excavation of soil and disturbance of soil covers, as
well as to prevent access to groundwater. The Base master Plan would contain a map indicating site location, with restrictions on any invasive activities that could potentially expose contaminants. Dig permits issued by the Base Operating Contractor are required for any excavation at Tatalina LRRS. Excavation, disturbance, or relocation of contaminated soil and groundwater; and excavation or drilling in areas of groundwater contamination, will be restricted by the ICs. Relocation of petroleum-contaminated soil will require prior ADEC approval. Use or removal of petroleum-contaminated groundwater will require characterization and be managed by the applicable regulations.
Prior to approving a permit, the Tatalina LRRS comprehensive map and Base Master Plan would be reviewed to ensure that invasive activities are not taking place within the boundary of the sites where land use has been restricted. A Notice of Environmental Contamination will be placed on State (Alaska Department of Natural Resources) land records.
- The ICs will be documented in the Air Force Real Property Records, Tatalina LRRS
General Plan, and 611th IRP Records. This will include: information about current land
uses and allowed uses (prohibiting future residential land use), geographic boundaries of
the ICs, an inspection of the site and submittal of a performance report on ICs to ADEC
at least once every 5 years after the date of the signed decision document, submittal of a
long-term monitoring sampling plan and subsequent sampling reports to ADEC for
approval prior to removal of ICs.
- Long-term monitoring and IC management of soil and groundwater conditions will be
discontinued once the cleanup levels for petroleum have been met for two consecutive
sampling events. ICs will remain in effect until it is demonstrated the sites are suitable for
unrestricted use/unlimited exposure per ADEC concurrence.
- The Air Force would notify ADEC prior to making any major changes to the Base Master
Plan that could affect the ICs.
- The Air Force would obtain prior concurrence from ADEC to terminate the ICs, modify
current land use, or allow anticipated actions that might disrupt the protectiveness of the
ICs. In the unlikely event that the property is to be transferred, the Air Force would notify
ADEC prior to any transfer taking place and would ensure any ICs are incorporated into
the land transfer documents.
- 5-year reviews would be conducted to evaluate the effectiveness of the remedies.
In addition to the above ICs, the following proposed activities would be conducted:
- A land survey would be conducted at ERP Sites SS003, SS008, SS011, and LF004 to identify site boundaries. This information would be used to update land records and the Tatalina LRRS comprehensive map and Base Master Plan. Any activity that is inconsistent with IC requirements, objectives, or controls, or any action that might interfere with protectiveness of the ICs, would be addressed by the Air Force as soon as practicable after discovery. In no instance would ADEC be notified later than 10 days after the Air Force becomes aware of a deficiency.
- The ICs at each site would extend indefinitely, to ensure that human and ecological receptors are protected from potential exposures. Periodic reports of IC monitoring would be prepared at a frequency of at least once every 5 years and provided to ADEC, with copies filed in the Administrative Record.
Because the selected remedy for SS011 will result in hazardous substances, pollutants, or contaminants remaining on-site in SS011 soil above levels that allow for unlimited use and unrestricted exposure, a statutory review will be conducted within five years after initiation of remedial action to ensure that the remedy is, or will be, protective of human health and the environment. |
Louis Howard |
| 1/31/2013 |
CERCLA ROD Approved |
Record of Decision for SS011 signed by John Halverson. Off-site Disposal through Landfilling and
ICs at SS011 as the selected remedy. At SS011, exposed debris and excavated stained soils and sediments will be disposed of at an off-site landfill. Because the selected remedy for SS011 will result in hazardous substances, pollutants, or contaminants remaining on-site in SS011 soil above levels that allow for unlimited use and unrestricted exposure, a statutory review will be conducted within 5 years after initiation of remedial action to ensure that the remedy is, or will be, protective of human health and the environment.
The RAOs for SS011 are:
Prevent current and future site workers, trench workers, and recreational visitors exposure through the dermal contact and VOC inhalation pathways to naphthalene that exceeds 81 mg/Kg.
Prevent current and future site workers, trench workers, and recreational visitors exposure through the dermal contact pathway to 2-methylnaphthalene that exceeds 2,492 mg/Kg.
Prevent current and future site workers, trench workers, and recreational visitors exposure through the ingestion pathway to DRO and RRO that exceed 12,500 mg/Kg and 22,000 mg/Kg, respectively.
Prevent mammalian and avian species exposure through the ingestion pathway to surface soil contaminated with fluorine, naphthalene, endrin aldehyde, endrin ketone, DRO and RRO that exceed 1.549 mg/Kg, 3.356 mg/Kg, 0.119 mg/Kg, 0.119 mg/Kg, 12,500 mg/Kg, and 22,000 mg/Kg, respectively.
Prevent mammalian and avian species exposure through the ingestion pathway to sediment contaminated with RRO that exceeds 36 mg/Kg. |
John Halverson |
| 1/31/2013 |
Cleanup Plan Approved |
Record of Decision for SS011 signed by John Halverson. Off-site Disposal through Landfilling and ICs at SS011 as the selected remedy. At SS011, exposed debris and excavated stained soils and sediments will be disposed of at an off-site landfill.
Excavation with off-site disposal of CERCLA hazardous material (to the extent practicable) from
the surface soil at SS011 will reduce the risks to human and ecological receptors. Due to the
steep terrain, shallow bedrock, and soil type consisting of large cobbles, it may not be feasible to remove all areas of contamination from this site. The excavated material would be placed into drums or supersacks for transport off-site.
Removal of the contaminated soil would be confirmed by post-excavation sampling of the bottom and sidewalls of the excavation. The exposed debris will also be removed for off-site disposal. Solid waste will be disposed in a permitted landfill at Tatalina LRRS, while contaminated waste will be disposed off-site from Tatalina LRRS. |
John Halverson |
| 3/18/2015 |
Update or Other Action |
One of several sites with Land Use Controls in effect (LUC Mgt Plan 2015 Pacific Air Forces Regional Support Center Installations, JBER, AK) March 13, 2015.
In addition to ICs established as part of LUCs of the ERP for landfill sites with LUCs in effect, both ERP landfill & non-ERP landfill sites in Alaska under the management of PRSC must also comply with regulations set forth by the ADEC solid waste regulations in 18 AAC 60. Furthermore, landfill sites under the management of PRSC but not categorized as an ERP site must also comply with ADEC 18 AAC 60. Table 1-3 describes PRSC non-ERP landfill sites.
Landfills are defined in 18 AAC 60 as “an area of land, or an excavation in which solid wastes are placed for permanent disposal, & that is not an application site, injection well, reserve pit, or waste pile.” This definition applies to most PRSC ERP & non-ERP sites in Alaska designated as landfills, dumps, or caches. Small PRSC ERP & non-ERP landfill sites at remote installations, such as the long-range radar stations, are regulated as Class III landfills as defined by ADEC.
General requirements to manage landfills in place are established by ADEC & included in Table 2-2. However, alternative criteria can & often are adopted through negotiation with ADEC (see 18 AAC 60.900, Waivers). Post-closure notification requirements for Class III landfills, including notifications to ADEC & to potential future landowners, are summarized in Table 2-3. Tables 2-2 & 2-3 both generally assume the subject landfill is closed, has been reasonably well characterized, & a monitoring program for media of concern has been established & approved by ADEC.
Tatalina LRRS Hardfill No. 2, Morrison-Knudsen Debris Area, Northeast Landfill DP005
Tatalina LRRS Landfill No. 2 LF004
Tatalina LRRS WAA No. 2 & Upper Landfill No. 1 LF010
Tatalina LRRS Former WACS Facility OT012
Tatalina LRRS Minimally Attended Radar Site SS001
Tatalina LRRS Barge Landing & Fuel Storage Area SS002
Tatalina LRRS Spill/Leak No. 1, 2 ,3, 4, Lower Camp Former T/F SS003
Tatalina LRRS WAA No. 3 SS007
Tatalina LRRS WAA No. 4 SS008
Tatalina LRRS Former Truck Fill Station SS009
Tatalina LRRS WAA No. 1 SS011
LUC_RESTRICTION a) The site well permitting system will prevent any use of groundwater for drinking water.
b) The site construction review process will prevent damage to existing monitoring wells.
c) All ROD use limitations and exposure restrictions will be entered in the Base Master Plan and the Geographical Information System.
d) The site construction review process will be used to avoid ground-disturbing construction activities and to ensure safe soil management procedures in areas with residual contamination.
e) The site digging permit system will be used to avoid activities that could breach the landfill cover.
f) The site Environmental Impact Analysis Process will be used to assess the potential environmental impact of any action proposed at the site. |
Louis Howard |
| 1/5/2016 |
Update or Other Action |
Report for Environmental Long Term Monitoring at Tatalina LRRS Sites received for review and comment.
SS011
The IC inspection at Site SS011 noted that the area is rarely accessed. No restriction signs were found on-site. No evidence of unauthorized access or activities was observed to indicate possible contaminant exposure. |
Louis Howard |
| 2/4/2016 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft report for environmental long-term monitoring at several sites which includes this one. After reviewing the information presented, it appears the institutional controls at LF004, SS002, SS003, SS008, and SS011 are working as designed. See site file for additional information. |
Louis Howard |
| 4/8/2016 |
Update or Other Action |
Draft UFP-QAPP WP for implementing remedial actions at SS003, SS008, SS011, SR001.
ROD selected remedy text: "The remedial action for SS011 includes Excavation with Off-site Disposal and ICs for surface soil. These remedial actions were selected based upon their ability to protect human health and the environment and compliance with applicable requirements and
ARARs. These remedies provide the best balance among the balancing criteria and appear consistent with comments received from the public and ADEC. The remedies are easily implemented, are cost effective, and are both a short and long-term solution for contamination at the site."
WP: Ten partially-exposed drums documented at this site in 2007 will be removed. Drums that are
RCRA-empty will be crushed and transported offsite for recycling. Drums that are not RCRA empty
will be placed in overpack drums and transported offsite for appropriate disposal.
Approximately 150 cubic yards of POL-contaminated soil and sediment associated with the drum locations will be excavated, placed in drums or Super Sacks®, and transported off-site for
disposal at a permitted thermal treatment facility. Excavation will continue until analytical
results from confirmation soil samples collected from the floor and sidewalls of each excavation
indicate remaining concentrations of the COCs are below their respective site-specific cleanup
levels (see Worksheet #15) or the proposed soil volume of 150 cubic yards is removed (whichever is completed first). The excavations will then be backfilled with locally-available clean soil and re-contoured and re-vegetated to match surrounding natural conditions.
Confirmation soil samples will be submitted for the following analyses: DRO, RRO, pesticides, total lead, and PAH. Drums or Super Sacks® containing POL-contaminated soil will be transported to Sterling Landing and staged in a lined containment area prior to being loaded onto barges for transportation to the treatment facility.
See site file for additional information. |
Louis Howard |
| 6/26/2017 |
Update or Other Action |
RA Construction report received for review & comment. The 2016 Work Plan specified 150 cubic yards of POL-contaminated soil & 10 drums will be removed. After removing the initial 10 drums, and commencing with the removal of the proposed POL-contaminated soil, additional
drums were encountered. Through conversations with the contract manager, it was determined that quantities and types of drums removed would have an equivalent value to an excavated cubic yard of contaminated soil. 136 cubic yards of soil and 93 drums were removed, which was the equivalent of 154.8 cubic yards of material.
On 12 June 2016, approximately 2/3 of a cubic yard of PCB-contaminated soil was released from a Super Sack® while being transported from SS008 to Sterling Landing. Personnel in the transport chase vehicle observed the spill and marked the spill locations along the road. The material was removed from the road with shovels and placed in a new Super Sack®. Soil samples were collected at the spill locations, and one sample was collected from a background location. All analytical results were ND for Aroclor 1260, and the sample locations were surveyed with a RTK GPS.
Concentrations of COCs continue to be above their respective site-specific and ADEC Table B1 Method 2 Soil Cleanup Levels in both excavations (BH-8 and BH-21) in SS008, as well as in the excavation in SS011. Further action is therefore required at locations SS008 and SS011.
See site file for additional information.
|
Louis Howard |
| 7/13/2017 |
Document, Report, or Work plan Review - other |
Staff reviewed the draft RA-C report and provided comments.
Main comments were regarding exceedances of human health levels and changes in chemical properties (i.e. now a mutagen and not a carcinogen) for benzo(a)pyrene, dibenzo(a,h)anthracene, alpha-BHC and Benzo(b)fluoranthene. An explanation of significant differences or ROD amendment may be necessary to address the more protective cleanup levels in 18 AAC 75 (March 23, 2017).
See site file for additional information. |
Louis Howard |
| 8/8/2017 |
Document, Report, or Work plan Review - other |
Draft Five Year Review commented on by staff. The ERBCLs and RBCLs calculated for soil exceed the July 1, 2017 18 AAC 75 Human Health cleanup levels for the following: benzo(a)anthracene, benzo(a)pyrene, benzo(b)fluoranthene, dibenz(a,h)anthracene, indeno(1,2,3-c,d)pyrene and alpha-BHC. Staff requested text be added describing when the USAF will finish implementation of the remedy to address POL impacted soil and drums left, especially when the 2007 Follow-On RI stated that 400-500 drums could be buried there. Various contaminants from the 2007 Follow-On RI exceeded the July 1, 2017 18 AAC 75 Human Health cleanup levels and need to be addressed or evaluated in a risk discussion or analyzed for in any additional implementation of the remedy at this site.
See site file for additional information. |
Louis Howard |
| 8/14/2017 |
Update or Other Action |
Draft 2017 Supplemental Work Plan W911KB-14-D-0007-0008 Remedial Action Operations, Land Use/Institutional Control received for review and comment. Conduct and document a visual inspection of ICs as specified LF004 in Section 1.2.1
See site file for additional information. |
Louis Howard |
| 2/3/2021 |
Update or Other Action |
Bulk action entry - all Tatalina LRRS sites x-referenced with the general file, 2655.38.001, on this date. |
Cascade Galasso-Irish |
| 4/9/2021 |
Document, Report, or Work plan Review - other |
Staff reviewed "Draft Project Activities Management Plan For Remedial Action - Construction at SS008 and SS011, March 2021." The draft was returned to USAF with comments for review and correction. The plan for SS008 detailed the plan for two PCB excavations and confirmation sampling/backfilling of site after removal below the 1 mg/kg cleanup level. The plan for SS011 detailed a removal of DRO contaminated soil and landfarming based treatment. |
Axl LeVan |
| 5/3/2021 |
Document, Report, or Work plan Review - other |
Staff provided comments on the Draft 2021 Remedial Action-Operation and Long-Term Management Work Plan, Tatalina Long Range Radar Station, Sites LF004, SS002, SS003, SS008, and SS011, March 2021. The Work Plan described the approach and procedures for site-specific long-term management and remedial action-operation activities at Tatalina long-range radar site, including annual groundwater sampling for sites SS002 and SS008. The Work Plan covers work being performed over a 5-year period and will be reviewed on an annual basis between field seasons. |
Axl LeVan |
| 5/11/2021 |
Document, Report, or Work plan Review - other |
Staff backchecked the "Draft-Final Project Activities Management Plan For Remedial Action - Construction at SS008 and SS011, April 2021." The majority of the U.S. Airforce responses to comments were accepted. The revised document was returned to USAF with additional comments for review and correction. The plan for SS008 detailed the plan for two PCB excavations and confirmation sampling/backfilling of site after removal below the 1 mg/kg cleanup level. The plan for SS011 detailed a removal of DRO contaminated soil and landfarming based treatment. |
Axl LeVan |
| 5/19/2021 |
Meeting or Teleconference Held |
Staff attended a comment resolution meeting with USAF regarding the DEC Backcheck of the 2021 Draft-Final Project Activities Management Plan, Remedial Action - Construction, Tatalina Long Range Radar Station, Sites SS008, and SS011, March 2021. The meeting primarily focused on adding appropriate Chemical of Concern including PAHs and DRO to final confirmation sampling at the site. DEC and USAF came to an agreement about the comments and a final version of the document will be sent for review. |
Axl LeVan |
| 5/26/2021 |
CERCLA Removal Action Plan |
Staff reviewed and sent approval letter for the "Final Project Activities Management Plan For Remedial Action - Construction at SS008 and SS011, May 2021." All DEC comments were addressed by the Final document. The plan for SS008 detailed the plan for two PCB excavations and confirmation sampling/backfilling of site after removal below the 1 mg/kg cleanup level. The plan for SS011 detailed a removal of DRO contaminated soil and landfarming based treatment. |
Axl LeVan |
| 6/22/2021 |
Document, Report, or Work plan Review - other |
DEC provided comments for the Draft 2020 Remedial Action-Operation, Institutional Control/Land Use Control Report, Tatalina Long Range Radar Station, Alaska, Sites LF004, SS002, SS003, SS008, and SS011, March 2011. The Alaska Department of Environmental Conservation Contaminated Sites Program received a copy of the above referenced document on May 24, 2021. The report presents the results and recommendations of the 2020 Environmental Long-Term Management (LTM) program at the Tatalina Long Range Radar Station (LRRS). The 2020 LTM activities included annual visual inspection of site intuitional controls/land use controls at Sites SS002, SS003, LF004, SS008, and SS011. Annual groundwater sampling also took place at Site SS002 and Site SS008. All efforts took place in August of 2020. |
Axl LeVan |
| 8/6/2021 |
Update or Other Action |
DEC reviewed and signed a field change form (FCF) for the "Final Project Activities Management Plan For Remedial Action - Construction at SS008 and SS011, May 2021" regarding stockpiling of soil from SS011. In the original plan all removed soil would be placed for landfarming. Due to the reduced amount of soil found at the site the FCF outlined a stockpiling method for removed soil contaminated with DRO until it can be disposed of offsite. Landfarming will still occur if over 50 cubic yards of contaminated soil is found. |
Axl LeVan |
| 8/20/2021 |
Update or Other Action |
DEC reviewed and approved "Contaminated Media Transport and Treatment or Disposal Approval Forms" for SS008 and SS011 soil waste and SS011 liquid. Soil will be disposed of at the Chemical Waste Management of the Northwest. |
Axl LeVan |
| 8/23/2021 |
Update or Other Action |
DEC reviewed and approved a field change form for the "Final Remedial Action-Construction Project Activities Management Plan, Sites SS008 and SS011, Tatalina Long Range Radar Station, Alaska, May 2021". The Field Change Form outlined a plan for additional sampling at 10, 25, and 50 foot intervals from sidewalls of the SS008 excavation still containing PCB contamination. DEC noted that the samples depth (0-0.5 feet below ground surface) will not capture the true vertical delineation and that the samples would not be considered a full characterization of the remaining contamination regardless of the results. However, DEC recognizes that the additional information may inform USAF regarding future estimates for additional removals and approved of the sampling for this purpose. |
Axl LeVan |
| 9/8/2021 |
Document, Report, or Work plan Review - other |
DEC approved the Final 2020 Remedial Action-Operation, Institutional Control/Land Use Control Report, Tatalina Long Range Radar Station, Alaska, Sites LF004, SS002, SS003, SS008, and SS011, September 2021. The Alaska Department of Environmental Conservation Contaminated Sites Program received a copy of the above referenced document on September 7, 2021. The report presents the results and recommendations of the 2020 Environmental Long-Term Management (LTM) program at the Tatalina Long Range Radar Station (LRRS). The 2020 LTM activities included annual visual inspection of site intuitional controls/land use controls at Sites SS002, SS003, LF004, SS008, and SS011. Annual groundwater sampling also took place at Site SS002 and Site SS008. All efforts took place in August of 2020. |
Axl LeVan |
| 5/12/2022 |
CERCLA Remedial Action Completion Report |
DEC received the "Draft Remedial Action – Construction Report Sites SS008 and SS011, Tatalina Long Range Radar Station, April 2022" on April 4, 2022. DEC reviewed the documented and provided comments to USAF on May 12, 2022. The report summarized remedial action (RA) activities conducted at Sites SS008 and SS011 located at the Tatalina Long Range Radar Station (LRRS), Alaska. RA activities included the removal of PCB contaminated soil at two SS008 locations. At SS011, RA activities were focused on removal of waste containing buried drums and petroleum contaminated soil. |
Axl LeVan |
| 7/26/2022 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (DEC) Contaminated Sites Program received a copy of Draft-Final 2021 Remedial Action-Operation and Long-Term Management Report, Tatalina LRRS Sites LF004, SS002, SS003, SS008, and SS011, Alaska, June 2022 on June 30, 2022. This report presents the long-term management and remedial action-operation (RA-O) activities performed at sites LF004, SS002, SS003, SS008, and SS011 at Tatalina long range radar site (LRRS) between 13 September and 15 September 2021.
|
Axl LeVan |
| 8/24/2022 |
Document, Report, or Work plan Review - other |
The Alaska Department of Environmental Conservation (DEC) Contaminated Sites Program received and approved a copy of Final 2021 Remedial Action-Operation and Long-Term Management Report, Tatalina LRRS Sites LF004, SS002, SS003, SS008, and SS011, Alaska, August 2022 on August 23, 2022. This report presents the long-term management and remedial action-operation (RA-O) activities performed at sites LF004, SS002, SS003, SS008, and SS011 at Tatalina long range radar site (LRRS) between 13 September and 15 September 2021. All DEC comments were addressed and appropriate changes were integrated into the document. In the approval letter DEC noted that landfill ponding, an unidentified well at SS003, and riverside erosion near SS002 should be closely monitored moving forward. |
Axl LeVan |
| 10/6/2022 |
Document, Report, or Work plan Review - other |
DEC approved the "Final Remedial Action – Construction Report Sites SS008 and SS011, Tatalina Long Range Radar Station, September 2022" received on October 3, 2022. The report summarized remedial action (RA) activities conducted at Sites SS008 and SS011 located at the Tatalina Long Range Radar Station (LRRS), Alaska. RA activities included the removal of PCB contaminated soil at two SS008 locations. At SS011, RA activities were focused on removal of waste containing buried drums and petroleum contaminated soil |
Axl LeVan |
| 10/12/2022 |
Exposure Tracking Model Ranking |
A new updated ranking with ETM has been completed for source area 73829 Former drum dump. |
Axl LeVan |
| 12/23/2022 |
Exposure Tracking Model Ranking |
A new updated ranking with ETM has been completed for source area 73829 Former drum dump. |
Axl LeVan |
| 8/17/2023 |
Document, Report, or Work plan Review - other |
DEC approved the Final 2022 Five-Year Review for Sites LF004, SS002, SS003, SS008, and SS011 at Tatalina Long Range Radar Station, Alaska, June 2023. The Five-Year review describes the progress since the last Five-Year Review and documents issues and recommendations for the five sites. |
Axl LeVan |
| 8/22/2023 |
Document, Report, or Work plan Review - other |
DEC provided comments on the "Draft-Final 2022 Remedial Action-Operation and Long-Term Management Report, Tatalina LRRS". The report presents the long-term management and remedial action-operation (RA-O) activities performed at sites LF004, SS002, SS003, SS008, and SS011 between 11 August and 13 August 2022. |
Axl LeVan |
| 9/7/2023 |
Cleanup Complete Determination Issued |
The Alaska Department of Environmental Conservation, Contaminated Sites Program (DEC) has completed a review of the environmental records associated with the Tatalina LRRS SS011 WAA#1 located at Tatalina LRRS near McGrath, Alaska. Based on the information provided to date, it has been determined that the contaminant concentrations remaining on site do not pose an unacceptable risk to human health or the environment and no further remedial action will be required unless information becomes available that indicates residual contaminants may pose an unacceptable risk. |
Axl LeVan |
| 1/18/2024 |
Document, Report, or Work plan Review - other |
DEC reviewed and approved the "Final 2022 Remedial Action-Operation and Long-Term Management Report, Tatalina LRRS Sites LF004, SS002, SS003, SS008, and SS011, Alaska, January 2024". The report presents the long-term management and remedial action operation (RA-O) activities performed at sites LF004, SS002, SS003, SS008, and SS011 at Tatalina Long Range Radar Site (LRRS) between 11 August and 13 August 2022. |
Axl LeVan |
