| Action Date |
Action |
Description |
DEC Staff |
| 5/14/1998 |
Update or Other Action |
A 300-gallon heating oil tank (Tank E1) located at Site TU110 was removed in 1998. While previous reports identified it as a 500-gallon tank, the tank dimensions (5 feet, 1 inch long and 3 feet, 3 inches in diameter) measured during the UST removal indicate that the volume was more likely 300 gallons (Oil Spill Consultants).
During the UST removal, approximately 20 cubic yards of contaminated soil was excavated and transported offsite for thermal treatment at Alaska Soil Recycling, Inc. (ASR). Confirmation soil samples collected from the base of the UST excavation had DRO concentrations up to 4,820 milligrams per kilogram (mg/kg) (Oil Spill Consultants). DRO at 4,820 mg/kg remains in the soil. |
Tim Stevens |
| 8/31/1998 |
Document, Report, or Work plan Review - other |
On August 31, 1998, the ADEC received the site assessment report summarizing activities that took place during the closure of the heating oil tank closure. Maximum contaminant level at tank excavation: diesel range organics 4,820 mg/kg from a duplicate sample, 2,880 mg/kg from tank pit bottom center and 3,710 mg/kg from tank pit bottom end (08/31/1998).
Based on the information presented in the site assessment report, the Department is requesting the Department of the Army to conduct a release investigation of the former UST site. The purpose of the release investigation is to determine the full extent of soil contamination found during the site assessment, and to demonstrate that the groundwater has not been impacted by past releases at this site. The release investigation must be conducted by a qualified, impartial third party in accordance with the UST Procedure Manual, dated December 10, 1998. Please submit a work plan to the Department outlining the proposed work to be conducted as part of the release investigation. |
Tim Stevens |
| 3/11/1999 |
Document, Report, or Work plan Review - other |
ADEC project manager issued a Notice of Release letter to the US Army that a release investigation is required at this site to find the full extent of the contamination found during the tank closure. Notice of Release for Fort Richardson Facility ID 0-000788, Tank # 213 (Alternate ID E1) LUST Event ID 2276.
On August 31, 1998, the Alaska Department of Environmental Conservation (ADEC) received a site assessment report from the Department of the Army documenting the May 14, 1998, closure of a 500-gallon underground storage tank system (UST) located at the corner of Westbrook and Roosevelt Drive, near Building 47431, Fort Richardson, Alaska. The information presented in the report indicates a petroleum release to the environment has occurred at this site. This letter confirms the release was reported.
The following information is provided as a summary of current laws, regulations and guidelines to further assist you in responding to the release.
Please read this information, and check to ensure you have performed or will be performing the required actions in order to comply with the Alaska Underground Storage Tank Regulations 18 ACC 78.
Initial Abatement and Release Investigation
If a release is confirmed, the owner or operator must conduct an Initial Abatement and Release Investigation, in accordance with 18 AAC 78.230 and 235. The Initial Abatement and Release Investigation includes, at a minimum, the following:
1. Preventing further release of product,
2. Continuing to monitor and reduce fire and safety hazards,
3. Storing excavated contaminated materials in a manner that prevents further migration of contaminants,
4. Measuring the extent and location of soils and ground water contaminated by the release, and
5. Investigating the possible presence of the free product and, if present, initiating removal of free product.
In addition, the collection of field data and submittal of reports shall be conducted by, or supervised by, a qualified, impartial third party that has been currently approved and is one file with the Department. The Department may waive the requirement for an impartial third party under certain conditions.
The Release Investigation report shall be submitted to the Department within 45 days respectively after confirmation of the release.
Corrective Action
In addition, upon confirmation of a petroleum release, the owner or operator of the UST must undertake Corrective Action in accordance with 18 AAC 78.240. Corrective Action includes, at a minimum, the following:
1. Determining the nature and amount of the release,
2. Conducting a preliminary risk evaluation,
3. Determining the full extent and location of soils contaminated by the release,
4. Determining the presence and concentration of dissolved contamination in the ground water,
5. Removing free product (if present) from soils and ground water,
6. Treating or removing contaminated soil and ground water, and
7. Treating and/or disposing of contaminated cleanup materials, including soil and/or water removed from the area affected by the release.
Corrective actions must be documented in an Interim Corrective Action Report (18 AAC 240(c)(1)) submitted to the Department within 60 days after the confirmation of a release.
Based on available information, the Department may request submittal of additional information and/or work plans (not listed above) which are determined necessary to respond to this release.
All work plans for site assessment, release investigation, and corrective action must be submitted to and approved by ADEC prior to implementation.
You will satisfy both state and federal regulations by following the requirements outlined above.
Please include the file number and the facility name shown at the top of this letter in any correspondence.
Cost Recovery
The State considers you a responsible party (RP) and will cost recover all “oversight” costs if additional work is necessary to close out the site. The RP will be sent a letter from Department of Law along with a detailed invoice of oversight costs and associated activities.
"Oversight" costs can include Department staff salaries, travel, equipment, supplies, contracts and services, and general program management. Typical cost expenditures for staff time can include, but are not limited to: performing plan reviews; drafting approval letters; attending site meetings; offering technical assistance via phone; and doing site visits or inspections.
The State of Alaska is authorized, under Federal regulation 42 U.S.C. 699 1 b(h), to recover funds used during oversight of a petroleum cleanup from a leaking underground storage tank (LUST). The State is also authorized by the State of Alaska comes from the Alaska Statute 46.08.070 to recover money expended by the Department to contain or cleanup the release of oil or a hazardous substance, including petroleum. |
Tim Stevens |
| 3/12/1999 |
Update or Other Action |
Oil Spill Consultants sent a letter to Tim Stevens clarifying UST soil management for the site. OSC Inc. prepared site assessment reports for UST numbers E1, E2, E5, and E7 during August 1998. Section 2.4 states soil excavated for UST removal was shipped off-site for thermal treatment. It should instead read: "The soil excavated for UST removal was stockpiled near Circle Drive at Fort Richardson, Alaska pending ADEC approval for off-site shipment to a thermal treatment facility in the Anchorage area."
This statement accurately reflects the work performed as part of the UST removal process by Brown & Root Services Corporation. After received ADEC approval, Fort Richardson will arrange for another contractor to transport the soil to a thermal treatment facility (12 Mar 1999). |
Tim Stevens |
| 7/20/2005 |
Site Added to Database |
Transferred to CS database from LUST database. |
Sarah Cunningham |
| 7/21/2005 |
Update or Other Action |
Site still active-unknown whether cleanup action has been performed. |
Sarah Cunningham |
| 7/22/2005 |
Update or Other Action |
File number issued 2102.38.053 |
Aggie Blandford |
| 5/30/2007 |
Update or Other Action |
In 2007, additional site characterization was conducted at this site. Three boreholes were
drilled near the location of the heating oil feed line to the former building. Six soil samples
were collected from each borehole at 5-foot intervals beginning at 5 feet below ground
surface (bgs).
Analytical results for the soil samples confirmed that DRO concentrations at all three borehole locations were greater than the ADEC cleanup level of 250 mg/kg. The maximum DRO concentration (5,800 mg/kg) was in a sample collected from 5 feet bgs. DRO ranged from 1,500 mg/kg to 2,900 mg/kg in samples collected from the bottom of the boreholes (30 to 32 feet bgs).
All 19 soil samples, including duplicates, were also analyzed for metals. An unusual high lead value of 34,500 mg/kg was reported for one sample collected from a depth of 5 to 7 feet bgs. The next highest reported lead values were 210 mg/kg (15-17 feet bgs) and 121 mg/kg (10-12 feet bgs). Lead values reported for the other 16 samples were less than 10 mg/kg. |
Louis Howard |
| 3/4/2008 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the Draft Tank E1 Release Investigation Report, Fort Richardson, AK February 2008.
Without the completed sample chain of custody (COC) forms, ADEC cannot concur with the results of the report which state residual range organics, gasoline range organics, polynuclear aromatic hydrocarbons, benzene, toluene, ethylbenzene, total xylenes and the majority of metals were below ADEC soil cleanup levels. The report did not include any completed, signed and dated COC forms as an appendix to the document. ADEC will require submittal of all COC forms for review and its records associated with this site.
ADEC concurs with the recommendations on the need for additional characterization at Tank E1 for both diesel range organics (DRO) and lead. Soil contamination for lead at 34,500 mg/kg may be considered a hazardous waste if it fails the toxicity characteristic leaching procedure (TCLP).
Please note, ADEC review and comment on this report 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 comments does not relieve the Army or its contractors, subcontractors, from the need to comply with other applicable laws and regulations.
It is interesting to note photoionization detector (PID) results did not correlate with DRO lab results (i.e. low PID=low sample results or high PID=high sample results).
For example, at E1-1 sample 07FR01SL, taken from five to seven feet below ground surface (bgs) had the highest level of DRO at 5,800 mg/kg, but field screening with a PID was zero (0) ppm.
The second highest DRO levels were from sample 07FR03SL, taken from fifteen to seventeen feet bgs, with DRO results of 5,600 mg/kg and PID reading of 166 ppm.
Alternatively, the highest PID reading of 254 ppm for E1-2 sample 07FR13SL, taken from thirty to thirty-two feet bgs had only DRO results of 1,500 mg/kg.
|
Louis Howard |
| 3/5/2008 |
GIS Position Updated |
GPS on site by contractor during release investigation. |
Louis Howard |
| 8/29/2008 |
Update or Other Action |
In August 2008, a test pit was excavated in the area where the highest lead level had been collected. Five soil samples were collected from the surface (0-0.5 feet bgs) to 8.5 feet bgs. The maximum analytical result for lead was 10.8 mg/kg. The cleanup level for lead in soil is 400 mg/kg. Therefore, it was determined that the original lead result (34,500 mg/kg) was an anomaly of unknown origin. No additional testing for lead is planned. |
Louis Howard |
| 5/13/2011 |
Update or Other Action |
This Work Plan, in conjunction with the addenda presented herein, will guide corrective actions to be performed at the Army Reserve Center (ARC) Tank E1, ARC Tank E2, ARC Tank E5, ARC Tank E7, Building 57-428 Tank, Building 987, Biathlon Range, & Fort Richardson Landfill sites in accordance with the requirements of the U.S. Environmental Protection Agency & Alaska Department of Environmental Conservation (ADEC) guidance documents.
Although the original building served by former UST E1 has been demolished, the concrete slab & footings remain in place. The site is located on ANG Camp Carroll Reservation, north of Hangar Building 47-431. The GPS coordinates for UST E1 are Latitude 61.26695, Longitude -149.67389. A 500-gallon heating oil tank (Tank E1) was located at the site & removed in 1998. Roughly 20 cubic yards of overburden was removed & thermally treated, but residual diesel fuel contamination was not addressed during removal. The site was backfilled with clean soil, but diesel range organic (DRO) contamination remains at the site (approximately 4,820 milligrams per kilogram [mg/kg] in soil).
In 2007, additional site characterization was conducted at this site. Three boreholes were drilled near the location of the heating oil feed line to the former building. Six soil samples were collected from each borehole at 5-foot intervals beginning at 5 feet below ground surface (bgs). Analytical results for the soil samples confirmed that DRO at all three borehole locations were greater than the ADEC cleanup level of 250 mg/kg. The maximum DRO (5,800 mg/kg) was in a sample collected from 5 feet bgs. DRO ranged from 1,500 mg/kg to 2,900 mg/kg in samples collected from the bottom of the boreholes (30 to 32 feet bgs).
All 19 soil samples, including duplicates, were also analyzed for metals. An anonymously high lead value of 34,500 mg/kg was reported for one sample collected from a depth of 5 to 7 feet bgs. The next highest reported lead values were 210 mg/kg (15-17 feet bgs) & 121 mg/kg (10-12 feet bgs). Lead values reported for the other 16 samples were less than 10 mg/kg. In August 2008, a test pit was excavated in the area where the highest lead level had been collected. Five soil samples were collected from the surface (0-0.5 feet bgs) to 8.5 feet bgs. The maximum analytical result for lead was 10.8 mg/kg. The cleanup level for lead in soil is 400 mg/kg. Therefore, it was determined that the original lead result (34,500 mg/kg) was an anomaly of unknown origin. No additional testing for lead is planned.
Soil will be removed from the ARC Tank E1 site. POL contaminated soil will be excavated from an area 20 feet wide by 20 feet long by 10 feet deep. The location & boundaries of the soil excavation will be determined in the field by USACE & Bristol personnel.
photoionization detector (PID) will be used to guide soil removal in the horizontal & vertical direction. The PID calibration will be conducted at the start of each day of use, & results will be documented in field notebooks, along with any deviations or repairs completed. The PID will be used to screen soil using a conservative level of 20 parts per million (ppm) to separate “dirty” soil from “clean” soil. The “dirty” & “clean” soil will be placed into separate stockpiles. The upper five feet of the excavation is considered “clean” & is expected to be reused as backfill, unless PID field screening indicates suspected contamination is present. The total volume of stockpiled soil is expected to be 74 cubic yards.
After the excavation has been completed, soil from the sidewalls & bottom of the excavation will be field screened prior to sample collection for laboratory analysis. As per the ADEC Draft Field Sampling Guidance (ADEC, 2010), sidewall field screening samples will be collected at a rate of 1 per every 10 linear feet of excavation. For a 20 foot by 20 foot excavation (80 linear feet), a total of 8 field screening samples will be collected from the excavation side walls. Field screening of the excavation base (400 square feet) will be conducted at a rate of 10 for the first 250 square feet of excavation, plus an additional sample for each additional 100 square feet of excavation, for a total of 4 excavation base field screening samples.
In addition to soil removal, 4 soil borings will be advanced and sampled to the groundwater table (approximately 100 feet bgs). Soil boring locations will be determined in the field by USACE and Bristol personnel.
Three of the 4 borings will have a monitoring well installed to a depth of 10 feet into
groundwater (approximately 110 feet bgs). The monitoring wells will be constructed of
Schedule 40 polyvinyl chloride (PVC) casing, and will have a 15-foot section of screened
casing across the water table (5 feet above groundwater and 10 feet below groundwater). |
Louis Howard |
| 5/20/2011 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the draft work plan for UST Corrective Actions HOT TANKS Dated March 2011 contract no. W911KB-10-C-0029.
3.3.1 ARC Tank E1 Soil Excavation
The text states contaminated and noncontaminated soil will be stockpiled separately (short-term) and characterized according to the ADEC Draft Field Sampling Guidance document (ADEC, 2010). ADEC wishes to inform the Army for projects where field screening is being conducted with a PID set at 20 ppm or any other numerical level, this field screening will not substitute for definitive laboratory data required to demonstrate whether “clean” stockpiled soil is suitable for use as backfill material.
3.3.2 Soil Borings and Monitoring Well Installation At ARC Tank E1
The text states if it appears that the fuel hydrocarbons may have migrated to the water table, some of the soil samples will be collected at and below the water table to assess if the source extends into the zone of seasonal water table fluctuation. ADEC requests the Army collect soil samples from within the first six inches of the vadose zone above the zone of seasonal water table fluctuation. There is no regulatory requirement to collect soil samples from below the water table.
If there are not any indications from field screening for areas with the highest contamination, then ADEC recommends the Army take the five samples from areas based on visual observation, best professional judgment by the field sampler for analysis of GRO, DRO, RRO, BTEX and PAH. There are no ADEC regulatory cleanup levels for EPH or VPH.
The text states In addition, within the 4 site borings, a total of 5 samples from any location with no indication of contamination but representative of the soil conditions in the contaminated zones, will be collected and analyzed for total organic carbon (TOC).
ADEC requests clarification on what the purpose of collect TOC data if the excavated soil will be sent off site for thermal treatment. TOC data cannot be taken from the contaminated site (i.e. the former excavation of the UST) using the same site borings for obtaining samples from contaminated soil. ADEC has specific guidelines for TOC collection (see ADEC Technical Memorandum 08-002 dated September 30, 2008). Please refer to and comply with all the requirements of the memorandum if TOC data collection is still something the Army wishes to pursue for this project.
|
Louis Howard |
| 4/26/2012 |
Update or Other Action |
Revision no. 2 for Corrective Actions HOT Tanks received. Soil will be removed from the ARC Tank E1 site. POL-contaminated soil will be excavated from an area 20 feet wide by 20 feet long by 10 feet deep. The location & boundaries of the soil excavation will be determined in the field by USACE & Bristol personnel.
Soil from 5 feet bgs to 10 feet bgs is contaminated. This soil will be excavated & directly transported off site for thermal treatment & recycling. Treated soil provided by ASR will be used to backfill the excavation. The backfill will be compacted by track-walking with heavy equipment. Compaction testing will not be required.
Soil confirmation samples for laboratory analysis will be collected from the floor & sidewalls of each excavation, after all of the PID field-screening samples are collected & measurements recorded. A total of 4 soil confirmation samples (excluding QC samples) are expected to be collected from the 4 sidewalls (1 per every 20 linear feet of excavation). In addition, a total of 3 soil confirmation samples (excluding QC samples) will be collected from the base of excavation (2 for the first 250 square feet & 1 for each additional 250 square feet of excavation).
Soil samples will be collected & submitted for laboratory analysis & analyzed for GRO, BTEX, DRO, RRO, & PAH. Quantities of primary, QC, MS/MSD, equipment blanks, & trip blank samples to be collected for each sample matrix are listed in the SAP in Appendix B.
The excavated soils will be stockpiled in accordance with 18 AAC 78.274. Contaminated & non-contaminated soil will be stockpiled separately (short-term) & characterized according to the ADEC Draft Field Sampling Guidance document (ADEC, 2010). Contaminated soil (estimated 135 tons) will be thermally treated & recycled at ASR. The excavated area will be backfilled with clean backfill material (approximately 135 tons) & compacted.
In addition to soil removal, 4 soil borings will be advanced & sampled to the groundwater
table (approximately 100 feet bgs). The locations may be modified in the field based on the real-time field observations or issues. In general, one boring will be located in the area of highest suspected contamination. The other three borings will be placed within the zone of contamination to gain information for the HRC, but in areas that will also provide good hydrogeologic information (e.g., the borings will be placed in a square pattern instead of a linear pattern, so that potential monitoring wells can be used to collect hydrologic flow information).
Approximately three soil samples per boring (excluding QC samples) will be collected &
submitted for laboratory analysis of GRO/BTEX, DRO, & RRO (yielding a total of 12 soil
samples in addition to the excavation confirmation samples). Most of the soil samples
submitted for hydrocarbon concentration analysis will be from the non-aqueous phase liquid
(NAPL)-contaminated soil source zone—to facilitate HRC calculations the goal is to have a
total of at least 10 excavation & soil boring samples from the NAPL-contaminated soil
source zone. In addition, a total of five soil samples with the highest indication of
contamination will be analyzed for extractable petroleum hydrocarbons (EPH), volatile
petroleum hydrocarbons (VPH), & PAH (some of the EPH, VPH, & PAH samples may be
collected from the excavation floor & sidewalls to reduce the difficulty of collecting the
required amount of soil from the split spoons).
If it appears that the fuel hydrocarbons have migrated to the water table, some of the soil samples will be collected at & below the water table to assess if the source extends into the zone of seasonal water table fluctuation. Soil sampling below the water table will allow the vertical extent of the source to be identified as required by the regulations. Soil samples collected below the water table that are thought to be from the NAPL source zone will be analyzed for hydrocarbon concentrations (BTEX, GRO, DRO, RRO, & potentially PAH, VPH, & EPH).
In addition, within the 4 site borings, a total of 5 samples from any location with no indication of contamination, but representative of the soil conditions in the contaminated zones, will be collected & analyzed for total organic carbon (TOC). Some soil samples collected in the saturated zone below the NAPL source zone may be analyzed for TOC (DRO analysis may be
used to confirm that the TOC result is not due to hydrocarbons) to enable better retardation
& half-life calculations.
Lastly, up to 5 geotechnical samples will be collected at each site, including approximately 2 from the saturated zone, & analyzed to assess the particle size distribution (PSD), moisture content, & bulk density. Three of the 4 borings will have a monitoring well installed to a depth of 10 feet into groundwater (approximately 110 feet bgs). |
Louis Howard |
| 8/24/2012 |
Update or Other Action |
UFP-QAPP for PA/SIs at Sites SA034, SA033, AT035, and AT032 Site Characterization/Cleanup at Sites TA008, TU948, TU110, TU111, TU112, TU949, and SS001 Dated August 23, 2012 received. SA034 – TBD #2, Powerline Drum Site
TU949 Building 770 UST Site (CC-FTRS-05)
SS001 - Building 796 (Battery Shop) (FTRS-01)
SA033 – TBD #3, Otter Lake Road Drum Site
TA008 –Biathlon Range Fuel Release (CC-FTRS-08)
TU948 –Building 57-428 UST Site (CC-FTRS-09)
TU110 –Building 47-431 Tanks E1 & E2 (CC-FTRS-10)
TU111 – CC-FTRS-11, Tank E5
TU112 – CC-FTRS-12, Tank E7
AT035 – TBD #4 MEB Complex, COF (FTR269)
AT032 – TBD #1, Airborne Training Facility (FTR255)
Site characterization/cleanup activities proposed in this Uniform Federal Policy Quality
Assurance Project Plan (UFP-QAPP) for Site TU110 are being conducted to support site closure
in accordance with the Alaska Department of Environmental Conservation’s (ADEC) cleanup
process for petroleum-hydrocarbon contaminated sites.
The overall objectives for the site are to meet “unrestricted or residential site use” criteria and achieve a “cleanup complete without institutional controls (ICs)” determination. To meet these objectives, soil and groundwater samples will be collected to characterize risk to human health and the environment within the framework of ADEC’s site cleanup process (18 Alaska
Administrative Code [AAC] 75 Sections 325 to 390 and 18 AAC 78 Section 600).
Soil sampling analytical approach
– Soil samples will be collected at 5-foot intervals from the ground surface to 25 feet bgs, and at 10-foot intervals from 25 feet bgs to the water table (approximately 100 feet bgs) from up to eight boreholes
– If, based on photoionization detector (PID) field screening and visual/olfactory evidence, the boring reaches the maximum vertical extent of the soil contamination, two samples will be collected beyond the last evidence of contamination, and the boring will be terminated.
– Continuous logging of soil type and stratigraphy, moisture or groundwater, visual observations of staining or liquid-phase petroleum, PID readings, and other observations will be performed
– All soil samples collected (up to 52 primary samples, excluding quality control [QC]) will be analyzed for gasoline-range organics (GRO); DRO; residual-range organics (RRO); and volatile organic compounds (VOCs), excluding the chlorinated compounds.
– A subset of soil samples (as described in Worksheet #17 of this appendix) will be collected for additional analyses to facilitate HRC calculations. These analyses include polycyclic aromatic hydrocarbons (PAHs), volatile petroleum hydrocarbon (VPH), extractable petroleum hydrocarbon (EPH), fraction of organic carbon (foc), bulk density, grain size distribution, specific gravity, and moisture content.
Groundwater sampling approach
– Groundwater samples will be collected from three monitoring wells (at theTank E1 site) and up to two soil borings (at the Tank E2 site) using a HydroPunch sampler. Groundwater samples will be analyzed for GRO, DRO, RRO, VOCs (excluding chlorinated compounds), PAHs, VPH, EPH, and total organic carbon (TOC). Additional data to be collected for HRC analysis include the following:
? Soil source zone temperature (field measurement)
? Average precipitation/infiltration (estimate from available regional information)
? Aquifer hydraulic conductivity (estimate from literature values based on grain size distribution or from available aquifer testing data from a nearby site)
If Method 2 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). If unacceptable risk is indicated by the HRC, then remedial options that address the compounds and exposure routes that contribute most significantly to the cumulative risk will be evaluated. |
Louis Howard |
| 4/4/2014 |
Update or Other Action |
Draft SC report received for E1 and E2 at Bldg. 47431 for review and comment.
E1
DRO in boring TU110-SB11: 15 to 20 feet bgs at 979 mg/kg. The soil sample from 20 to 25 feet bgs at TU110-SB01 detected DRO at 12,700 mg/kg, which exceeds the maximum allowable concentration for DRO of 12,500 mg/kg.
E2
DRO in boring TU110-SB15: 10 to 15 feet bgs at 4,170 mg/kg; 15 to 20 feet bgs at 4,060 mg/kg.
Groundwater
Groundwater is present at approximately 152 feet bgs. Monitoring wells E1-A, E1-B, and E1-C were sampled for GRO, DRO, RRO, VOCs, PAHs, EPH, and VPH. Free product was not observed in the monitoring wells. Based on groundwater sample results, groundwater is not affected by petroleum hydrocarbons. Groundwater was not encountered during any investigations at Tank E2. The maximum depth of soil contamination (25 feet bgs) is approximately 125 feet above the estimated depth to
groundwater (150 feet bgs at Tank E1). |
Louis Howard |
| 4/22/2014 |
Cleanup Complete Determination Issued |
Staff provided a cleanup complete determination for TU110 (E1 and E2)
Contaminants of Concern
During the 2012 and 2013 site characterizations at TU110, the maximum concentration of diesel range organics (DRO) was detected at E1 at a concentration of 12,700 mg/kg (TU110-SB01), from 20 to 25 feet bgs. At boring TU110-SB11 the maximum concentration of DRO was 979 mg/kg from 15 to 20 feet bgs. The maximum concentration of DRO detected at E2 was 4,170 mg/kg from boring TU110-SB15 at 10 to 15 feet bgs. Groundwater sampling results did not have any exceedances for any contaminant concern. Groundwater is at approximately 150 feet bgs.
ADEC does not recognize the Tables 5-7, 5-8 and 5-9 in 2013 Site Characterization report which lists concentrations for aromatics and aliphatics in groundwater or pore water concentrations under Method Three as cleanup levels for TU110. Current regulations do not list aromatic and aliphatic cleanup levels for groundwater in Table C. However, since groundwater results did not exceed Table C cleanup levels for any contaminant of concern, it is not an issue at TU110.
Cleanup Levels
In accordance with 18 AAC 75.341(d), Table B2, the cleanup level for DRO at TU110 is based on the ingestion pathway for the under 40” Zone at 10,250 mg/kg. Soil is contaminated with higher levels of DRO at 12,700 mg/kg (20 to 25 feet bgs), but it is below 15 feet bgs, not likely to be excavated in the future as part of any military construction activities, and sampling results shows there are no impacts to groundwater at 150 feet bgs and not likely to be impacted in the future.
In accordance with 18 AAC 75.380(d)(1), after reviewing the site characterization report submitted under this section, ADEC has determined TU110 has been adequately characterized under 18 AAC 75.335 and has achieved the applicable requirements under the site cleanup rules for a “cleanup complete” designation. The designation shall be noted in the CS Database. This written determination does not preclude ADEC from requiring additional assessment, investigation, monitoring, and cleanup if future information, site conditions, or new data indicates that action is necessary to protect human health, welfare, safety, or of the environment.
In accordance with 18 AAC 75.325(i) and 18 AAC 75.370(b): the Air Force shall obtain ADEC approval before moving or disposing of soil from TU110. Movement or use of contaminated material in a manner that results in a violation of 18 AAC 70 water quality standards is prohibited. Notations of these requirements shall be made on the Environmental Restoration map/Base General Plan which will show up during a dig permit review/work clearance request process for TU110.
Any person who disagrees with this decision may request an adjudicatory hearing in accordance with 18 AAC 15.195 -18 AAC 15.340 or an informal review by the Division Director in accordance with 18 AAC 15.185. Informal review requests must be delivered to the Division Director, 410 Willoughby Avenue, Suite 303, Juneau, Alaska 99801, within 15 days after receiving ADEC’s decision reviewable under this section. Adjudicatory hearing requests must be delivered to the Commissioner of the Department of Environmental Conservation, 410 Willoughby Avenue, Suite 303, Juneau, Alaska 99801, within 30 days after the date of issuance of this letter, or within 30 days after ADEC issues a final decision under 18 AAC 15.185. If a hearing is not requested within 30 days, the right to appeal is waived. |
Louis Howard |
| 6/11/2014 |
Document, Report, or Work plan Review - other |
Staff provided comments on the well decommissioning work plan.
This letter formalizes ADEC’s concurrence to finalize the document for decommissioning wells associated with TU110 (HOT E-1 & E-2), TU111 (HOT E-5), TU112 (E-7), and TU071 Bldg. 962. ADEC has no comments on the document. These wells are no longer needed as part of the 2-Party Agreement sites nor are they needed for monitoring at any CERCLA sites on JBER-Richardson. Any significant changes to the approved work plan will need to be resolved with ADEC prior to implementing the changes.
|
Louis Howard |
