| Action Date |
Action |
Description |
DEC Staff |
| 10/2/1992 |
Enforcement Agreement or Order |
State Elmendorf Environmental Restoration Agreement signed. The agreement is designed to remedy environmental contamination due to past practices at the Base and avoid the expense of formal enforcement proceedings. The Air Force will perform any necessary assessment, monitoring, remediation, and closure of the sites. The agreement addresses the following program areas: solid waste, underground storage tanks (USTs), and petroleum oil and lubricants (POL) spills. |
Jennifer Roberts |
| 3/26/1993 |
Update or Other Action |
DOD and ADEC joint Technical Memorandum of understanding signed concerning the Base-wide Groundwater (GW) signed by: ADEC Jennifer Roberts RPM and USAF Joseph Williamson Chief Environmental Programs & Restoration. Due to the base-wide GW study and the FY92 field work that occurred at Operable Units (OUs) 1, 2, and 5 it appears a large portion of the GW flows into OU5 (Attachment 1 - Contour Map). Based on this fact, Elmendorf (EAFB) will move all upgradient GW into the OU5 Feasibility Study, Proposed Plan and Record of Decision (ROD). This means addressing all GW from upgradient sources (CERCLA (ST20, OUs 3 and 4) and OUs 1 and portions of OU2) and SERA-Two Party petroleum sites) at OU5 instead of at each individual source area (see Attachment 2 - Area Map). Sites with free phased product would be looked at to see if there is an available technology to clean them up in a cost effective way. Soil contamination would be addressed at the source areas. NOTE: addressed at the source areas is interpreted by ADEC as removal through excavation or active treatment systems (e.g. high vacuum extraction, bioventing, etc.). |
Jennifer Roberts |
| 4/21/1995 |
Update or Other Action |
Air Force Memorandum to John Halverson re: UST meeting. Elmendorf AFB will accomplish the following actions regarding UST projects. These actions are based upon conversation between, John Mahaffey, Larry Opperman and yourself.
1) EAFB will make every effort to accomplish clean closure of a UST removal if possible.
2) UST removal locations requiring cleanup action will be transferred into the State Elmendorf Environmental Restoration Agreement (SERA). A list of sites requiring cleanup will be coordinated with your office.
3) The presumptive remedy for contaminated UST sites in the outwash plain only will be bioventing technology.
4) Contaminated soils exceeding cleanup levels may be placed back into the excavation only if the site assessment (SA) indicates a need for further action.
5) Contaminated UST sites not in the outwash plain will require further investigation to determine appropriate cleanup options.
6) We (Elmendorf) will make every attempt possible to assure new USTs or new aboveground tanks are not installed in any way that would hamper future access for cleanup.
7) The project will first accomplish removal of all the USTs. SA information will be used to prioritize sites for cleanup using existing project funds. Additional funding will be requested to complete cleanup if available. Sites not addressed for cleanup due to exhausted funding will be placed in SERA Phase IV.
John Halverson signed memorandum on April 21, 1995. Memorandum submitted by Douglas G. Tarbett, Maj. USAF, Chief Environmental Compliance (CCs 3 WG/JA and 3 SPTG/CE). |
John Halverson |
| 8/11/1995 |
Enforcement Agreement or Order |
ADEC (J. Halverson) sent letter to Air Force (L. Opperman) RE: Disposition of petroleum contaminated soil generated during underground storage tank (UST) Closures at Elmendorf AFB. I met with you and Mr. John Mahaffey on April 18, 1995, to discuss UST closures planned at Elmendorf this summer and the issue of how contaminated soil would be handled. We agreed that if "clean closure" could be reached through excavation, all contaminated soil should be removed and taken to an off-site treatment facility.
We also agreed that petroleum contaminated soil could be placed back in the ground, on the condition bioventing systems would be installed starting this year, if clean closure was not feasible. However, it has become apparent the Air Force has not been able to implement corrective action at leaking underground storage tank sites in a timely manner.
Therefore, our April 21, 1995 agreement on soil management must be revoked. Starting
immediately, the department requests that all contaminated soil removed from the ground during
closure or upgrade of USTs be completely contained in accordance with our petroleum contaminated
soil stockpiling guidelines referenced in the UST regulations. Please notify your project managers, the Army Corps of Engineers project manager and all of your UST contractors of this change. The rationale behind the need to contain all excavated petroleum contaminated soil is provided below.
Failure to implement Corrective Action-Tank #805, at building 24-805, failed a tightness test in 1994 and was removed from the ground. Tanks #96-104 were also removed from the ground in 1994. Petroleum contaminated soil was excavated during removal of the tanks. The Air Force requested approval to place contaminated soil back in the ground at both sites. Department approval was granted on the condition corrective action be started at each site no later than June 30, 1995.
The Air Force had committed to doing this work under Phase IV of the SERA. However, we have been informed that contracts for SERA Phase IV have not yet been awarded, work plans have not been developed, and it does not appear the field work will be started this year. This is a violation of the corrective action requirements outlined in the UST regulations and our prior agreements.
Management Action Plan (MAP) for transfer of LUST sites into the SERA-On several occasions the department has requested a formalized process for transfer of leaking UST sites from the UST agreement into the SERA. The January 3 1, 1995 annual UST report states that a MAP was being prepared to formalize such a process and that a copy would be forwarded to us as soon as it was completed.
We have not received a copy of the MAP. Numerous LUST sites have been identified during the past two years and transfer of sites between the UST and SERA compliance agreements has not been working. It appears the UST agreement needs to be amended to address release investigation and corrective action requirements. Based on the above and the fact that funding for DoD environmental cleanups is being reduced, we are no longer in a position to allow contaminated soil to be placed back in the ground with the hope it will be remediated in a timely manner. |
John Halverson |
| 10/17/1996 |
Institutional Control Record Established |
Air Force memo: Restricted Use of the Shallow Aquifer on EAFB signed by William R. Hanson P.E. GM-14 Chief Environmental Flight dated October 17, 1996 Memorandum for 3 SPTG/CEC/CEO from 3 SPTG/CEV.
1) Due to the contamination and commitments to EPA/DEC the use of the shallow aquifer for any purpose on is not allowed. Attached Facilities Board minutes-03/29/1994 0930 Item 9 has Mr. William Hanson, briefing the Board on the policy to not use the shallow aquifer due to contamination (Basewide Institutional Control on the shallow aquifer). The Board approved this policy. Minutes approved by Thomas R. Case Brigadier General USAF Commander. The IRP has RODs for OUs 3 and 6 which require, the aquifer remain unused.
2) Personnel in the review process within CES must be aware of these policies and review them on a recurring basis. It is imperative this restriction be recognized and observed during engineer reviews and operations. |
Jennifer Roberts |
| 4/30/1999 |
Update or Other Action |
UST Decommissioning and site assessment STMP 685 and 686 Former Battery Shops. The Air Force Storage Tank Management Program (STMP) number for the USTs are STMP 685/686, and the Alaska Department of Environmental Conservation (ADEC) facility identification number for Elmendorf AFB is 1525.
The purposes ofthis project were to:
• Remove and decommission USTs STMP 685/686 and associated piping.
• Perform site assessments for closure in accordance with Alaska's Underground Storage Tank Regulations (18 AAC 78).
• Document removal and decommissioning actions in a site summary and closure report.
It appears the two tanks were actually two water heaters that were welded together with angle iron and piped in parallel. Each had a 100 gallon capacity and were installed prior to 1970. The USTs served as heating oil tanks for battery shops that were formerly at this site off of Acacia Drive and Taxiway Q (unused).
Excavation measured 29 ft. wide by 23 ft. long, and 8 ft. deep. The existing stockpile was field screened with a PID. One PID reading was taken for each 10 cy of stockpiled soil. PID samples were taken from soil deeper than 18 inches from the surface of the stockpile. Table 2 provides the stockpile field screening results. Field screening of the stockpiled soil at the STMP 685/686 excavation showed PID deflections within background (three readings of 2.2 ppm and less). Based on the field screening results of the overburden, the Air Force directed the
contractor to place the excavated soil back in the excavation.
The excavated soil was placed back in the excavation even though the DRO results were as high as 4,000 mg/kg from sample ID 685/6860003SS at 7.42 feet bgs. Soil sample 685/68600 I SS was collected under the union of the tanks. Soil sample 685/686002SS was collected at the bottom of the excavation. Sample 685/686003SS was collected at the bottom of the excavation, approximately 14 inches below the tank.
Sample handling and analysis were within the specified parameters with the following exceptions. The satellite refrigerator where volatile soils are stored shut off overnight due to a tripped breaker. The temperature of all samples submitted for method SW8020 analysis was measured at 14.6 degrees C. The incident occurred prior to analysis, and the laboratory was instructed to proceed with analysis. [NOTE TO FILE: VOCs, BTEX would be biased LOW due to elevated temperatures, no closure decision would be granted on this soil data.]
Based on the results of the field screening and lab analyses of the soil samples collected in the vicinity of the excavated USTs it is recommended that a UST release investigation be conducted. Closest active water well, Base Well 16, is within 1000 ft. of the site. Cleanup level is calculated to be level "A". |
Louis Howard |
| 10/25/1999 |
Document, Report, or Work plan Review - other |
Letter sent by Tim Stevens to the Air Force notifying them of a Notice of Release Facility ID 1525 Tank # STMP 685 & 686. June 10, 1999 the Department received the final site assessment report for 685 & 686. It summarizes the field data and results of the confirmation samples collected during the June 23, 1998 closure of two 100-gallon unregulated underground storage tanks (USTs), located at the former "Battery Shop" building on Elmendorf AFB.
Information presented in the report indicates a petroleum release to the environment has occurred at the site that warrants further investigation. It is the Department's understanding that the Base is scheduling a release investigation of the two USTs under SERA VIII. On October 15, 1999, the Department received the draft work plans for SERA VIII. The Department will make a sincere attempt to review and comment on the work plans before November 1, 1999. |
Tim Stevens |
| 5/31/2000 |
Update or Other Action |
SERA Phase VIII Release Investigation Report ST805/ST806, Former Battery Shop UST STMPs 685 and 686. Highest soil contamination from 13 feet bgs at 805WL01 was 12,000 mg/kg DRO and in boring 805BH02 at 14 feet bgs was 1,400 mg/kg DRO. Groundwater was found to be impacted with DRO at 30,000 ug/L in monitoring well 805WL01.
Depth to groundwater was measured to be at 12 feet bgs. The report states petroleum impacted soil in the "smear zone" (The smear zone is defined as the range of depths within which the groundwater will fluctuate under normal seasonal conditions, and therefore, in which free product would move and “smear” the soil in response to these seasonal changes in the water level elevation.
The smear zone soils may therefore be saturated or unsaturated with groundwater at any given time.) extends 30 feet south and west from the site of the former USTs. A sheen was observed on the water surface, but no measurable amount of free product was detected.
According to a directive provided by the EAFB, smear zone and dissolved phase groundwater contaminants will not be investigated for sites in the outwash plain/OU5 model area unless free product is found on the water table. Free product was not detected at this site.
Continued monitoring of well 805WL01 as part of EAFB's groundwater monitoring program could provide sufficient information regarding the natural attenuation of the impacted groundwater and confirmation that groundwater contaminant levels are decreasing over time. Since no significant amounts of contaminants were detected in the soil column above the smear zone, monitored natural attenuation may be a viable cleanup option. |
Louis Howard |
| 7/28/2002 |
Update or Other Action |
ADEC (CS Program S. Bainbridge, Leslie Pearson PER Program) and Air Force (Daniel Barnett) signed the Operational Agreement (OA) concerning presumptive remedies for cleanup of certain petroleum oil and lubricant releases on the outwash plain portion of Elmendorf AFB, Alaska. This OA establishes and describes pre-approved presumptive remedies but does not establish an exclusive set of cleanup options and nothing in the memorandum prohibits EAFB from seeking or obtaining ADEC approval to implement alternative release response and remedial action plans.
For new POL spills in the outwash plain that occur in areas with no operational restrictions or interference from surrounding structures, ADEC approves immediate remediation of contaminated media after free product has been recovered in a manner that minimizes the spread of contamination into an uncontaminated area by using containment, recovery, disposal techniques appropriate to site conditions. The presumptive remedy for new POL spills on the outwash plain consist of excavation, treatment, and disposal of all impacted soil.
On a case-by-case basis, ADEC will evaluated the need for recovery of free product from the water table. Finally groundwater monitoring and ICs placed on the shallow aquifer restricting its use as a drinking water source will be required until such a time that the appropriate groundwater remedial goals are met. If additional institutional controls are required, these controls will be developed by EAFB in consultation with ADEC.
The OA does not apply to spills impacting surface waters. Nothing in the OA relieves, extends or changes the applicable requirements of 18 AAC 75 and 78 for the proper treatment, storage or disposal of contaminated media that result from the implementation of this OA. |
Steve Bainbridge |
| 10/21/2002 |
Update or Other Action |
Letter sent to Joe Williamson dissolving the State Elmendorf Environmental Restoration Agreement. The Alaska Department of Environmental Conservation (DEC) has reviewed the issue of abolishing the State Elmendorf Environmental Restoration Agreement (SERA) per your recommendation. Elmendorf Air Force Base and DEC entered into the SERA in 1992. The agreement was developed as a tool to bring the Base into compliance with Alaska's regulations addressing underground storage tanks, oil and other hazardous substance releases and solid waste.
Since that time, Elmendorf has made significant progress in investigating and cleaning up historic contamination problems. Many of the sites covered by the SERA have been successfully cleaned up and closed. Cleanup is underway at the remaining sites.
Additionally, Alaska has amended the regulations addressing fuel storage tanks, oil and other hazardous substance spills and solid waste. We concur with you that the SERA is no longer a necessary or beneficial. This letter serves as notice that DEC will end oversight on environmental work at Elmendorf by using the SERA. Instead, it is understood that the sites and programs formerly addressed by SERA: solid waste, underground storage tanks (UST), and oil and other hazardous substance discharges will be addressed in accordance with 18 AAC 60, 18 AAC 78 and 18 AAC 75. |
Jennifer Roberts |
| 12/31/2002 |
Site Added to Database |
DRO. Site is not in LUST database. |
Debra Caillouet |
| 1/13/2003 |
Site Ranked Using the AHRM |
Site not previously ranked and has now been ranked by program staff. |
Louis Howard |
| 7/21/2004 |
Long Term Monitoring Established |
The source has been removed and historically released petroleum hydrocarbons have likely completed the migration to groundwater and therefore the potential for continued groundwater impact is limited. The maximum contaminant concentrations were detected in the "smear zone" (The smear zone is defined as the range of depths within which the groundwater will fluctuate under normal seasonal conditions, and therefore, in which free product would move and “smear” the soil in response to these seasonal changes in the water level elevation. The smear zone soils may therefore be saturated or unsaturated with groundwater at any given time.) and would be expected to degrade over time through natural attenuation.
This site is located within the OU5 modeling area as identified in the Operational Agreement (OA) between ADEC and Elmendorf AFB signed 28 July 2002. In the OA, both parties agree that the portion of the unconfined shallow aquifer in the outwash plain has demonstrated, through modeling and sampling, the ability to naturally attenuate residual hydrocarbon contamination from most POL spills in a reasonable period of time.
The Elmendorf AFB Base-wide Groundwater Monitoring Program will be utilized to monitor groundwater during implementation of the remedy. The nearest downgradient monitoring wells currently in the Base-wide Groundwater Monitoring Program are OU5MW-11 and OU5MW-35, located approximately 3,000 to 3,200 feet downgradient. |
Louis Howard |
| 7/21/2004 |
Conditional Closure Approved |
After reviewing the data and reports submitted for ST805/806 Former Battery Shops, the Department agrees that additional remediation or investigation is not required for ST805/806. Additional groundwater monitoring will be required until applicable cleanup levels in Table C of 18 AAC 75.345 are met.
The Base Master Plan needs to be updated to document the location of residual contamination at ST805/806 and the need to manage contaminated soil properly during any future construction or excavation work. The Department reserves its rights, under: 18 AAC 75 Contaminated Site regulations, 18 AAC 78 Underground Storage Tank regulations, and AS 46.03 to require additional investigation, cleanup, containment, and/or other necessary actions, if subsequent information indicates: additional contamination remains at the site which was previously undiscovered and presents an unacceptable risk to human health, safety, or welfare, or the environment. |
Louis Howard |
| 7/6/2006 |
Update or Other Action |
2005 Annual Report Monitored Natural Attenuation of Basewide Compliance Program Wells received. Currently, the 3 CES/CEVQ is required by ADEC to monitor the degree to which certain regulated contaminants are naturally attenuating on 27 sites throughout the Base. The natural attenuation of each of these sites is being monitored by sampling and analyzing the groundwater under the contaminated areas and/or downgradient of the contaminated source.
Groundwater monitoring well OU5MW-35, which was formerly located approximately 3,200-feet downgradient of ST805/806, had been abandoned the previous summer by the Basewide Groundwater Monitoring Program. Monitoring well OU5MW-03, located approximately 225 feet west of former well OU5MW-35, and an equal distance downgradient of ST805/806, was sampled in its place.
Groundwater wells OU5MW-11 and OU5MW-03 were sampled using the approved procedures provided in the 2005 Final Work Plan (USAF, 2005). Samples from each well were submitted to
an analytical laboratory for the following analyses: GRO by Method AK101, and BTEX by Method SW8021B. GRO was detected in the sample collected from well OU5MW-03 only. The sample was reported with a GRO concentration of 69.3 ug/L, which is below the cleanup level of 1,300 ug/L. No other compounds were detected above MDLs from either well.
Recommendations include continuation of sampling for all sites. At some sites, the well network used to monitor the site should be reviewed. The groundwater monitoring wells used to monitor each site were chosen because they were the closest wells that were already being sampled under the Elmendorf Restoration Basewide Groundwater Monitoring Program at the time the decision documents were prepared (USAF, 2004a-z). Sites ST402, ST523, ST532, ST538, ST805/806, and ST904 are examples of sites where the well network needs re-evaluation and may need to be changed or enhanced.
The primary recommendation for all of the sites is to perform a review of each site's conceptual site model (CSM) in 2006. The well network for each should be evaluated as part of this review. It should be noted that the Compliance Monitoring Program is being transitioned into the Elmendorf Restoration Program in 2007. As such, the CSM review should be followed by performing a remedial process optimization (RPO) effort for all of the compliance sites so that the manner in which all of the groundwater sites on Elmendorf are monitored and evaluated will be consistent which the two programs are merged together. |
Louis Howard |
| 7/10/2006 |
Document, Report, or Work plan Review - other |
ADEC reviewed the draft annual report for monitored natural attenuation of basewide compliance wells. ADEC concurs with the recommendations to continue monitoring of the sites and evaluate the well network for sites such as: ST402, ST523, ST532, ST538, ST805/806, and ST904. Waiting until 2007 to conduct a conceptual site model review and well network evaluation after the Compliance Monitoring Program merges with the Restoration Program is acceptable to ADEC. |
Louis Howard |
| 6/20/2007 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the 2006 Annual Report Monitoring of Compliance Program Sites, Elmendorf Air Force Base (EAFB) dated May 2007. ADEC concurs with the recommendations to sample 805WL-01 for gasoline range organics (GRO), diesel range organics (DRO) and benzene, toluene, ethylbenzene, and total xylenes (BTEX). |
Louis Howard |
| 7/5/2007 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft Work Plan and Field Sampling Plan Compliance Program Sites, Elmendorf Air Force Base (EAFB) dated June 27, 2007. For ST805/806 the following well will be monitored: 805WL-01 for GRO, BTEX, and DRO.
ADEC has developed a technical memorandum and a Laboratory Data Review Checklist (checklist) summarizing the minimum requirements for both laboratory data packages and quality assurance (QA) summaries (data reduction, verification, evaluation, etc.). All reports submitted by the Air Force which contain analytical laboratory sample results shall contain a completed checklist and a QA summary. The latest checklist is available online at http://www.dec.state.ak.us/spar/guidance.htm#csp and must be completed, signed and dated by the firm submitting the report to ADEC. It is not to be completed by the analytical laboratory that performed the sample analysis. The summary must be included as a specific text section of the report. All laboratory results, including laboratory quality control (QC) sample results, must be reviewed and evaluated for quality, validity and usability. The text must include any effects on data validity and/or usability due to field sampling/laboratory quality control discrepancies.
Upon incorporation of comments regarding the checklist, ADEC will approve the work plans. |
Louis Howard |
| 9/10/2007 |
GIS Position Updated |
61.2431 N latitude -149.8289 W longitude I38/J38 of 2004 Environmental Atlas and USAF 3rd CES UST Decommissioning and Site Assessment - STMP 685 & 686, Former Battery Shops Final- Dated April 1999. Figure 2 STMP 685 & 686 location Demo'd Battery Shops dated July 1998 (contract no. F41624-94-D-8070-0014). |
Louis Howard |
| 5/20/2009 |
Update or Other Action |
Draft groundwater monitoring report received. Groundwater well 805WL-01 was sampled and analyzed by an analytical laboratory for GRO, DRO, and BTEX compounds. DRO was reported with a concentration of 1,740 µg/L in the sample, which exceeds the cleanup level of 1,500 µg/L. Field activities at ST805/806 also consisted of closure soil sampling. Direct-push technology was used to advance two soil borings placed near the locations with the highest contaminant concentrations during the 1999 SERA VIII Investigation.
Samples were collected at 8 feet bgs, 13 feet bgs, and 18 feet bgs from each boring. In addition, a sample was collected at 15 feet bgs from the second soil boring (805/806-08SB-02). The PID reading at this location was 622 ppm, indicating that significant contamination may exist. The samples were submitted for laboratory analysis for GRO, DRO and BTEX compounds. The DRO concentration in the samples collected at 13 and 15 feet bgs from the second borehole
(805/806-08SB-02) exceeded the cleanup level. The reported concentrations of 478 and 7,450
mg/Kg exceeded the ADEC Method 2 cleanup level of 250 mg/Kg. No GRO or BTEX constituents were reported with concentrations above cleanup levels.
Because DRO concentrations in soil continue to exceed cleanup levels, annual groundwater
sampling for DRO should continue at the in-source well 805WL-01. It is recommended that soil
samples be collected at this site again in 5 years to determine if contaminant concentrations have been remediated to below cleanup levels. |
Louis Howard |
| 4/15/2010 |
Update or Other Action |
2009 Annual report for monitoring of compliance program sites received. ST805/ST806 is located east of the former Battery Shops, Building 32-129, which was previously demolished. This site is located southwest of the intersection of Fighter Drive and Johnson Avenue, in the central portion of the Base. Two unregulated 100-gallon, single-wall USTs were located at this site. These tanks reportedly stored heating oil for the former Battery Shops.
Groundwater well 805WL-01 was sampled using the approved procedures provided in the 2008
Final Work Plan (USAF, 2008b). Samples from the well were submitted to an analytical
laboratory for DRO. DRO was reported with a concentration below the cleanup level.
In 2008, DRO concentrations in soil exceeded cleanup levels. Groundwater samples were
collected from the in-source monitoring well 805WL-01 during annual Compliance Monitoring
from 2006 through 2009. Only the sample collected in 2008 had a DRO concentration above
cleanup levels in the well. The DRO concentration of 1,740 ug/L, exceeding the cleanup level of
1,500 ug/L.
The 2008 Annual Report (USAF, 2009c) and 2008 Closure Sampling Summary Report (USAF,
2009b) recommended that soil samples be collected again in 2013 to determine if contaminant
concentrations have been remediated to below cleanup levels. ADEC subsequently concurred
with the recommendations (ADEC, 2009a). This is still recommended. Annual groundwater
sampling for DRO should continue at the in-source well 805WL-01.
|
Louis Howard |
| 3/16/2011 |
Update or Other Action |
Draft Annual Report Monitoring of Compliance Restoration Program Sites received. Groundwater well 805WL-Ol was sampled. The field sample and a field duplicate sample from the well
were submitted to an analytical laboratory for DRO. DRO was reported with a concentration
below the cleanup level in both samples.
Conclusions
In 2008, DRO concentrations in soil exceeded cleanup levels at ST805/806. Results from a
sample collected from the in-source monitoring well 805WL-Ol, during the 1999 SERA VIII
investigation, was reported to have a DRO concentration of 30,000 Jlg/L. Groundwater samples
were collected from the in-source monitoring well during annual Compliance Monitoring from
2006 through 2010. During that period, only the sample collected in 2008 had a DRO
concentration above cleanup levels in the well. The DRO concentration of 1,740 ug/L,
exceeding the cleanup level of 1,500 ug/L.
The 2009 Annual Report (USAF, 2009b) and 2008 Closure Sampling Summary Report (USAF,
2009a) recommended that soil samples be collected again in 2013 (if funding is available) to
determine if contaminant concentrations have been remediated to below cleanup levels. ADEC
subsequently concurred with the recommendations (ADEC, 2009a and 2010). This is still
recommended. Until soil samples are collected, annual groundwater sampling for DRO should
continue at the in-source well 805WL-Ol. |
Louis Howard |
| 4/26/2012 |
Update or Other Action |
2011 Annual Report for Compliance Restoration Program Sites received.
Groundwater well 805WL-01 was sampled using the approved procedures provided in the 2011
Work Plan (USAF, 2011f). The sample was submitted to an analytical laboratory for DRO.
DRO was reported with a concentration below the cleanup level.
In 2008, DRO concentrations in soil exceeded cleanup levels at ST805/806. Results from a
sample collected from the in-source monitoring well 805WL-01, during the 1999 SERA VIII
investigation, was reported to have a DRO concentration of 30,000 µg/L. Groundwater samples
were collected from the in-source monitoring well during Annual Compliance Monitoring from
2006 through 2011. During that period, only the sample collected from well 805WL-01 in 2008
had a DRO concentration exceeding the cleanup level of 1,500 µg/L at 1,740 µg/L. No changes are being recommended to compliance monitoring at this site due to the 2012 PBC. |
Louis Howard |
| 1/30/2013 |
Update or Other Action |
CG521 ST805_806 UFP-QAAP work plan received for 2 USTs.
The USTs contained heating fuel for Building 32-129. The USTs and associated piping were decommissioned in 1998; however, fuel hydrocarbons remain in the soil and groundwater at CG521. This work plan describes site characterization activities that are proposed to support site closure in accordance with the Alaska Department of Environmental Conservation (ADEC) cleanup process for petroleum hydrocarbon-contaminated sites. This site-specific work plan follows the Uniform Federal Policy – Quality Assurance Project Plan (UFP-QAPP) format and the work will be performed under the Joint Base Elmendorf-Richardson (JBER) Basewide UFP-QAPP
The Site CG521 field investigation will include following:
• Approximately 10 laser induced fluorescence (LIF) probes will be used to confirm the source area extent. The initial probes will be placed east, southeast, and southwest and west of the known source area and/or UST excavation area. If the initial probes indicate uncontaminated soils, additional probes will be installed closer to the known source area until contaminants are detected.
If the initial probes encounter contaminated soils, additional probes will be installed further downgradient from the known source until the extent of the contamination is determined. One LIF probe may be installed downgradient of boring 805-BH01 to confirm the southward extent of the source.
• After the non-aqueous phase liquid (NAPL) contaminated soil source area is delineated, focused soil sampling will be conducted. Depending on the results of the LIF probes, three to five borings will be drilled in the NAPL-contaminated soil source area.
• Approximately 10 source area soil samples will be collected and analyzed for BTEX, GRO, DRO, and RRO. Sampling conducted inside the source area will focus on contaminated soils and be representative of high, medium and low percent reference emitter (%RE) areas. If the LIF probes show a very limited footprint, fewer samples may be collected.
• Approximately three source area soil samples will also be analyzed for PAHs, EPH and VPH. Samples collected for PAH, EPH, and VPH analysis will tend to be focused on high %RE areas and/or on the samples showing staining, odor or high photoionization detector (PID) readings.
• Two soil borings will be drilled outside the source area indicated by the LIF probes and soil sample results to help document the extent of the source area in the direction of groundwater flow. One boring will likely be to the southeast and one boring will be to the southwest of the source area. At least one soil sample from the smear zone of each of the borings will be analyzed for BTEX, GRO, DRO, and RRO. If the source area MW is interpreted to exceed groundwater cleanup criteria, then a MW will be constructed in the hydrologically downgradient borehole (the MW will be constructed following SOP-14).
• Since CG521 has a relatively long term and complete water quality record from in-source MW 805WL-01 and because the recent samples from the well have met ADEC Table C criteria, no new MWs are proposed. A new groundwater sample will be collected from well 805WL-01 and analyzed for BTEX, GRO, DRO, RRO, PAH, EPH, and VPH. The new data and recent existing data from MW 805WL-01 will be used in the HRC calculations. Standard groundwater sampling procedures will be followed. Observations of odor, turbidity, and color will be recorded on the groundwater sample collection log.
|
Louis Howard |
| 2/12/2013 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the draft UFP-QAP WP.
Executive Summary
2nd Paragraph
The text states: If 18 AAC 75 Method 2 cleanup criteria are exceeded, the Hydrocarbon Risk Calculator (HRC) approach under Method 3 will be used to assess whether site conditions meet ADEC risk criteria (in which case, a "cleanup complete without ICs" determination will be requested) or whether the site poses unacceptable risk (in which case remediation, ICs, or both may be required)."
It is ADEC's position that ICs would be applied at JBER sites when:
· The GW under or downgradient of a site was contaminated with POL constituents at concentrations exceeding risk criteria or MCLs; or
· POL contaminants in the soil were above the MAC given in Table B2 of 18 AAC 75 or at concentrations exceeding risk criteria.
· ICs also needed if direct contact or inhalation risks exceed residential land use risk-based levels. Sites should be suitable for UU /UE for cleanup complete without ICs.
If soil that was above the maximum allowable contaminant concentration were excavated, the excavation confirmation sample concentrations could be used to replace the higher concentration in the removed soil and the statistics for the site could be rerun. The ProUCL checks for outliers and the Q-Q plot should be submitted with the 95% UCL calculations. Vadose zone soils shall not exceed MACs for petroleum contamination for soil from 0 -15' bgs (i.e. direct contact for BTEX, PAHs and ingestion for DRO, GRO, RRO) regardless of HRC calculated risk levels. Treatment or excavations deeper than 15' bgs may be warranted on a site-specific basis to prevent the soil from acting as a continuing source of GW contamination.
In addition, sites with existing GW contamination above Table C cleanup levels will require that migration to GW cleanup levels be used for soil and ICs will be required. Once GW is below Table C for a period of time (per the latest approved "Basewide Monitoring Program Well Sampling Frequency Decision Guide (Attachment 1 Memo to the Site File for OUs 4, 5, and 6 September 2003)" two rounds annual groundwater monitoring), the maximum allowable levels may become the cleanup levels as determined by ADEC on a case by case basis.
Site-Specific CG521 Proposed Work
The text states: "ApproximatelY 10 source area soil samples will be collected and analyzed for BTEX, GRO, DRO, and RRO. Sampling conducted inside the source area will focus on contaminated soils and be representative of high, medium and low percent reference emitter (%RE) areas. If the LIF probes show a very limited footprint,fewer samples may be collected."
Be aware that EPA's ProUCL Version 4.1.00 Technical Guide, Chapter 1 "Use of Statistical Methods as Incorporated in ProUCL 4.0 & Associated Minimum Sample Size Requirements" states: "Decisions based upon statistics obtained using data sets of small sizes (e.g., 4 to 6 detected observations) cannot be considered reliable enough to make a remediation decision that affects human health and the environment."
Also see 1.7.4 Minimum Sample Sizes for Hypothesis Testing.
Nature and Extent of Contamination
PAH concentrations exceeded ADEC GW cleanup levels in 1999. See Table 3-2 ST805/ST806 1999 GW Sample Analytical Results for dibenzo(a,h)anthracene and 2-Methylnaphthalene which exceed 18 AAC 75 Table C GW Cleanup levels (April 2012). The PAH data shall be reported and reflected in the table for historic GW data and not discounted by JBER since the DRO GW data at 30 mg/L or 30,000 ug/L is obviously above the solubility limit for diesel fuel, but reported in the table.
Source and Release Mechanisms
While the spills at ST805/ ST806 are several years to decades old and free product has not been observed in the one and only well onsite (805WL-01), this does not mean that free product does not exist at the site as defined by 18 AAC 75.990(43).
If free product is encountered, use of the HRC does not address the requirement to recover free product to the extent practicable (see 18 AAC.75.325 (f) (1) (B) and 18 AAC 78.240(b» . When using the HRC, the extent and recoverability of free product must be thoroughly evaluated as part of the site characterization process. Methods for conducting this evaluation shall be articulated in the site characterization report, and, as appropriate, other documents submitted for ADEC approval. |
Louis Howard |
| 2/13/2013 |
Document, Report, or Work plan Review - other |
ADEC provided review comments on the draft UFP-QAPP
Executive Summary
2nd Paragraph
The text states: If 18 AAC 75 Method 2 cleanup criteria are exceeded, the Hydrocarbon Risk Calculator (HRC) approach under Method 3 will be used to assess whether site conditions meet ADEC risk criteria (in which case, a “cleanup complete without ICs” determination will be requested) or whether the site poses unacceptable risk (in which case remediation, ICs, or both may be required).”
It is ADEC’s position that ICs would be applied at JBER sites when:
• The GW under or downgradient of a site was contaminated with POL constituents at levels exceeding risk criteria or MCLs; or
• POL contaminants in the soil were above the MAC given in Table B2 of 18 AAC 75 or at levels exceeding risk criteria.
• ICs also needed if direct contact or inhalation risks exceed residential land use risk-based levels. Sites should be suitable for UU/UL for cleanup complete without ICs.
If soil that was above the MAC were excavated, the excavation confirmation sample concentrations could be used to replace the higher concentration in the removed soil and the statistics for the site could be rerun. The ProUCL checks for outliers and the Q-Q plot should be submitted with the 95% UCL calculations.
Site-Specific CG521 Proposed Work
The text states: “Approximately 10 source area soil samples will be collected and analyzed for BTEX, GRO, DRO, and RRO. Sampling conducted inside the source area will focus on contaminated soils and be representative of high, medium and low percent reference emitter (%RE) areas. If the LIF probes show a very limited footprint, fewer samples may be collected.”
Be aware that EPA's ProUCL Version 4.1.00 Technical Guide, Chapter 1 "Use of Statistical Methods as Incorporated in ProUCL 4.0 & Associated Minimum Sample Size Requirements" states: "Decisions based upon statistics obtained using data sets of small sizes (e.g., 4 to 6 detected observations) cannot be considered reliable enough to make a remediation decision that affects human health and the environment."
Also see 1.7.4 Minimum Sample Sizes for Hypothesis Testing.
Nature and Extent of Contamination
PAH concentrations exceeded ADEC groundwater cleanup levels in 1999. See Table 3-2 ST805/ST806 1999 GW Sample Analytical Results for dibenzo(a,h)anthracene and 2-Methylnaphthalene which exceed 18 AAC 75 Table C Groundwater Cleanup levels (April 2012).
The PAH data shall be reported and reflected in the table for historic GW data and not discounted by JBER since the DRO groundwater data at 30 mg/L or 30,000 ug/L is obviously above the solubility limit for diesel fuel, but reported in the table.
ADEC requests JBER footnote all the 1998 BTEX data as being biased low due to high sample temperatures. JBER shall not include the volatile soil sample results in any future HRC risk calculations due to the data being biased low since the samples were not held at proper temperatures prior to analysis (e.g. 4o ± 2oC.). Any further use of the 1998 BTEX data is not approved by ADEC.
Per the UST Decommissioning And Site Assessment – STMP 685 & 686 Former Battery Shops, Final. April 1999, Section 3.2.2 Laboratory Quality Assurance which states:
“The laboratory data received a quality assurance review. Sample handling and analysis were within the specified parameters with the following exceptions. The satellite refrigerator where volatile soils are stored shut off overnight due to a tripped breaker. The temperature of all samples submitted for method SW8020 analysis was measured at 14.6 degrees C. The incident occurred prior to analysis, and the laboratory was instructed to proceed with analysis.”
805WL01 from 13’ bgs (1999 SERA Phase III ST805/ST806 RI Report Table 3-1) detected GRO at 480 mg/kg which is above the 300 mg/kg migration to GW Table B2 Method Two Petroleum Hydrocarbon Soil Cleanup Levels. This result shall be bolded. |
Louis Howard |
| 4/29/2013 |
Update or Other Action |
ADEC has received the final version of the UFP-QAPP for ST805/806 on April 12, 2013. Upon review of the document it appears the document satisfactorily incorporated ADEC’s comments and ADEC approves the final document. |
Louis Howard |
| 4/30/2013 |
Update or Other Action |
Draft 2012 Annual Monitoring report received for review and comment.
Two unregulated 100-gallon, single-wall USTs were located at this site. These tanks reportedly stored heating oil for the former Battery Shops. Most recently, soil samples collected from borings advanced within the source area in 2008 indicate that DRO concentrations continue to exceed cleanup levels in the soil at CG509. Current monitoring requirements at Site CG521 include annual groundwater sampling for DRO at groundwater monitoring well 805WL-01.
Additional investigation to characterize the current presence/absence of soil contamination is being proposed for CG521 in 2013 under the new PBR contract (Draft CG521 – ST805/806 Site Characterization Work Plan USAF, 2013b). No changes to the annual monitoring are being proposed for this site. |
Louis Howard |
| 6/10/2013 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed for source area id: 73990 name: auto-generated pm edit Elmendorf ST805/806 Bldg 9336 |
Louis Howard |
| 3/13/2014 |
Update or Other Action |
Draft 2013 Annual report received for review and comment.
The overall project objectives included collecting sufficient data to:
• Monitor concentrations of contaminants of concern (COCs) at each site with sufficient
precision and accuracy to evaluate their concentrations with respect to cleanup goals.
• Identify potentially toxic and/or mobile transformation products.
• Verify individual plume characteristics, such as downgradient, lateral, or vertical expansion or retraction.
• Evaluate groundwater flow directions and hydraulic gradients to monitor plume migration and assess contaminant sources.
• Evaluate the effectiveness of land use controls/ institutional controls (LUCs/ICs) to
protect human health and the environment.
• Identify and repair damaged monitoring wells to protect groundwater.
• Identify monitoring wells that are no longer needed or are damaged beyond repair.
DRO 805WL-01: 380 ug/L (Table C 1,500 ug/L)
The ADEC site status for CG521 is “Cleanup Complete with ICs.” Site monitoring well 805WL-01 has met the 18 AAC 75 Table C cleanup criteria for five consecutive annual rounds of groundwater sampling.
Additional investigation to characterize the current nature and extent of soil and groundwater
contamination at CG521 was also performed during 2013 under the JBER PBR contract. A site
characterization report has been prepared under separate cover. Recommendations for the site,
including any changes to the sampling program are provided in the site characterization report. |
Louis Howard |
| 6/30/2014 |
Update or Other Action |
Draft SC report received for review and comment.
Conclusions
The data set for CG521 supports the following conclusions:
Historic data at CG521 show that diesel fuel releases have resulted in vadose zone contamination over an area approximately 25 feet long and 30 feet wide.
Fuel has infiltrated the vadose zone source area to the water table, and the NAPL is interpreted to have spread laterally on the water table to a width of approximately 50 feet and migrated approximately 95 feet downgradient. The NAPL has been smeared through the zone of seasonal water table fluctuation over this footprint area.
The average and 95% UCL DRO concentrations within the NAPL source area are approximately 2,974 and 5,597 mg/kg, respectively.
Groundwater samples collected from monitoring well located in the NAPL-contaminated soil source area and screened across the water table are below 18 AAC 75 Table C criteria.
No visible staining of surface soils, odors, or stunted vegetation were noted at the site during the site characterization field investigation. There is no significant surface water runoff or sediment transport from the site to surface water bodies.
The carcinogenic cumulative risk and non-carcinogenic cumulative risk posed by the individual indicator compounds meet the ADEC risk standard, assuming a residential land use scenario.
The risk posed by the GRO, DRO, and RRO aromatic and aliphatic surrogate fractions meets the risk standard for each exposure pathway assuming a residential land use scenario.
Existing site conditions meet risk-based migration to groundwater criteria.
The site meets ADEC qualitative ecological/environmental risk criteria in that there were no observed environmental impacts from soil staining, impacted vegetation, surface water or sediment runoff. In addition, groundwater from the site meets the TAH and TAqH ambient water quality criteria.
At least two additional NAPL-contaminated area unrelated to the former CG521 USTs were discovered. One of these is mainly GRO and the other is mainly DRO. These plumes will be investigated as site CG111, Johnson Avenue Plume. The investigation is scheduled for FY2015.
The site meets ADEC qualitative ecological/environmental risk criteria in that there were no observed environmental impacts from soil staining, impacted vegetation, surface water or sediment runoff. In addition, groundwater from the site meets TAH and TAqH ambient water quality criteria. The Ecoscoping Form indicates that a more in-depth risk evaluation is not needed and that the CG521 site conditions are protective of the environment.
Recommendations
Based on the HRC calculations and compliance with environmental criteria, it is recommended that the ADEC grant Site CG521 at JBER a “Cleanup Complete” determination. ICs do not appear to be necessary at this site. Following ADEC concurrence with this conclusion, groundwater monitoring of the site should be terminated and the existing monitoring wells at the site should be decommissioned. |
Louis Howard |
| 7/14/2014 |
Cleanup Complete Determination Issued |
Cleanup complete determination granted.
Contaminants of Concern
Diesel Range Organics (DRO)
Cleanup Levels
The cleanup level for soils at CG521 containing DRO contamination is 10,250 mg/kg in the Under 40-inch Zone based on the ingestion pathway within the 0 to 15’ interval below ground surface (bgs).
Modeling using the Hydrocarbon Risk Calculator, in accordance with Method 3 under 18 AAC 75.340, demonstrated that residual petroleum contaminants in soil do not pose a migration to groundwater risk/concern.
Cumulative Risk Evaluation
The HRC was used to evaluate risk from petroleum contamination at CG521. The HRC is designed for sites with petroleum contamination—specifically the petroleum fractions, BTEX, PAHs, and other compounds dissolved in petroleum—with the intention and purpose of assessing human health risk from this type of contamination.
The estimated rounded cumulative cancer risk at CG521 for the current industrial and hypothetical residential exposure scenarios, across all exposure pathways, (4 x 10-7 and 1 x 10-6 respectively) is below the regulatory risk standard of 1 x 10-5 for petroleum hydrocarbons.
The estimated cumulative noncancer HI at CG521 for the current industrial and hypothetical residential exposure scenarios, across all exposure pathways, (0.0 and 0.0 respectively) is below the regulatory risk standard of 1. CG521 meets the ADEC risk criteria [18 AAC 75.325(g)] for petroleum hydrocarbons. The risk posed by the DRO aromatic and aliphatic surrogate fractions meets the risk standard for each exposure pathway, assuming a residential land use scenario.
An ecoscoping form was completed for CG521 and no observed surface soil staining, no impacted vegetation, no surface water or sediment runoff from the site. The ecoscoping form indicates that a more in-depth risk evaluation is not needed and that the CG521 site conditions are protective of the environment.
Based on a review of the environmental records, ADEC has determined that CG521 has been adequately characterized and has achieved the applicable requirements under the site cleanup rules associated with the two former USTs. ADEC agrees that there are at least two additional NAPL-contaminated areas unrelated to the former CG521 diesel fuel USTs. One of these is mainly GRO and the other is mainly DRO.
These plumes will need to be investigated as site CG511, Johnson Avenue Plume. The investigation is scheduled for FY2015. ADEC is issuing this written determination that cleanup is complete at CG521, subject to a future department determination that the cleanup is not protective of human health, safety, welfare, or of the environment [18 AAC 75.380(d)]. A “cleanup complete” designation will be entered for CG521 in the Contaminated Sites Database. |
Louis Howard |
| 7/14/2014 |
Institutional Control Record Removed |
Institutional Controls have been removed. |
Louis Howard |
