| Action Date |
Action |
Description |
DEC Staff |
| 9/15/1950 |
Update or Other Action |
In Alaska twenty AAA batteries protected the military complexes in Fairbanks and Anchorage from 1950 to 1958. Generally the AAA batteries consisted of 12 Quonset huts, radars, an ordnance shop, ammunition magazines, a fuse storage shelter, and the 90mm or 120mm guns. Quonset huts were used for administration and soldier housing.2 Batteries were manned around the clock, much as Nike missile sites would operate in the future. The conditions facing AAA soldiers, however, were harsher than those encountered at the Nike batteries; life in a Quonset hut can be uncomfortable.
When the Anchorage AAA batteries were initially activated in 1950, the 96th Gun Battalion arrived to find their quarters were old, drafty Jamesway huts. The men lived in these for several months until unassembled Quonset huts were delivered for the battalion to construct. The soldiers built their own barracks through the middle of a cold winter, finishing the job in February of 1951. Meanwhile contractors installed latrines, maintenance shops, and mess halls.
The poor living conditions air defense soldiers faced were not exclusive to Alaska; AAA units across the country were largely deployed with few amenities and little preplanning, for the Korean War had contributed to a grave sense of urgency. The meagerness of AAA facilities resulted in morale and personnel retention issues that likely contributed to the construction of more comfortable Nike sites, with permanent barracks, mess halls and recreational amenities.
Even as AAA batteries were being widely deployed in the early 1950’s their effectiveness was being questioned in the face of advancing aircraft technology. As described by one soldier, “nobody had much fear of a 75 millimeter gun…when they’re in an airplane they fly one and a half mach, we finally figured out we could only get about three [rounds] off at it as it passed over. The gun was fast but it didn’t have the range, so it had limited capabilities.” The defense technology had to keep pace with progressing aircraft capabilities. |
Louis Howard |
| 1/31/1992 |
Update or Other Action |
Records from 1949 indicate five small buildings (log structures) were located at the site that was then called Search Light Area No. 4. Base plans from 1951 revealed 24 buildings existing at this site designated as “Alaska Scouts Combat Intelligence” and labeled as “Battery D 96th Anti-Aircraft Artillery (AAA)”. The AAA battery was under the command of the U.S. Army, which was responsible for ground and anti-aircraft defense in Alaska (USARAL 1972). Other activities may also have occurred at the site. The SS83 site was decommissioned in the 1960s. |
Louis Howard |
| 3/26/1993 |
Update or Other Action |
DOD & ADEC joint Technical Memorandum of understanding signed concerning the Base wide Groundwater (GW) signed by: ADEC Jennifer Roberts RPM & USAF Joseph Williamson Chief Environmental Programs & Restoration. Due to the base wide GW study & the FY92 field work that occurred at Operable Units (OUs) 1, 2, & 5 it appears a large portion of the GW flows into OU5 (attach. 1-contour map). Based on this fact, Elmendorf (EAFB) will move all upgradient GW into the OU5 Feasibility Study, Proposed Plan & Record of Decision (ROD). This means addressing all GW from upgradient sources (CERCLA (ST20, OUs 3 and 4) & OUs 1 & portions of OU2) & SERA) at OU5 instead of at each individual source area (see attach. 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...).
Also included in the file is the AF 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 & 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. The Board approved this policy. Minutes approved by Thomas R. Case Brigadier General USAF Commander. The IRP has RODs for OUs 3 & 6 which require, the aquifer remain unused. 2) Personnel in the review process within CES must be aware of these policies & review them on a recurring basis. It is imperative this restriction be recognized & observed during engineer reviews & operations. |
Jennifer Roberts |
| 12/12/1996 |
Update or Other Action |
Beginning in 1996, the SS83 site was incorporated into the Area Under Evaluation (AUE) discovery process undertaken by EAFB as part of restoration activities conducted under the Air Force's Installation Restoration Program (IRP). The AUE program was designed to identify and evaluate areas of potential environmental concern that had not been previously identified and/or addressed under other environmental source discovery efforts at EAFB.
A preliminary site visit was conducted at SS83 in 1996 to observe the current site conditions and to note any indications that contamination might exist. During the site visit, building foundations and what appeared to be several standpipes near the buildings-possibly associated with underground storage tank (USTs) were observed. There was some evidence of stressed vegetation adjacent to the building foundations. The field team recommended further investigation to confirm or deny the presence of USTs and to evaluate the area around the building structures for contamination. SS83 was originally designated POL1, but it subsequently was redesignated AUE1. After a historical record review, preliminary site visit, and development of a conceptual site model, it was determined that the site should be considered a candidate AOC and further investigated. |
Louis Howard |
| 1/1/1997 |
Update or Other Action |
Area Under Evaluation Informal Technical Information Report received.
Area Under Evaluation 1-POI 1 is located in the northern portion of the base, between Six Mile Lake and Knik Arm. It is the current location of an antenna site and the previous location of several buildings and possible fuel tanks or bladders. As-built record data from 1949 show an assemblage of five small buildings at what was then known as Search Light Area No. 4. The site was later converted to the antenna area it is now. There are no current source areas in the vicinity of POI 1, and it is not associated with any other
environmental investigation.
During the site visit, concrete foundations of pre-existing structures were observed near the antenna site. Possible locations of buried USTs and stressed vegetation were
observed near these concrete foundations. Two fill pipes or vent pipes observed during the site visit may indicate the existence of at least two USTs. The UST locations appeared to be directly related to the furnace room in at least one of the structures and may have provided heating fuel. Based on these observations, the site was retained for further evaluation as an AUE.
The conceptual site model for AUE I (Figure 4-2) address only the most likely potential contaminant migration pathways and exposure routes. Potential waste sources at AUE 1 are two possible USTs located next to the old building foundations and possible surface or shallow soil contamination around the concrete foundations.
As stated above, the UST locations appear to be directly related to the furnace room in at least one of the structures. It is possible that these USTs stored fuel used to heat adjacent buildings. Stressed vegetation around the building foundations suggests the possibility of surface or shallow soil contamination.
If contamination does exist in the area, it may be associated with heating oil potentially stored in the USTs. However, no environmental sampling has been performed in this area to document or characterize potential contamination.
Assuming heating oil is a potential source of contamination, contaminants of potential concern may include volatile organic compounds, such as benzene, toluene, ethylbenzene, and xylenes; semivolatile organic compounds; polyaromatic
hydrocarbons; and diesel-range organic compounds. |
Louis Howard |
| 11/11/1997 |
Update or Other Action |
A limited field investigation (LFI) was conducted in 1997. The LFI identified and investigated several areas of possible contamination. The individual
areas include: the large foundation, motor pool, bermed bunker, small foundation, underground
bunker, docking area, and ravine area. Hand borings and small test pits were excavated in
these areas. During excavation, headspace samples were collected at intervals of 1 foot and
soils were observed for evidence of staining. A polychlorinated biphenyl (PCB) field-test kit
(EnviroGard PCB Test Kit) was used at the site to evaluate if PCB contamination was present.
This immunoassay test enabled semi-quantitative screening for Aroclor 1016, 1242, 1248, 1254,
and 1260. Results were used to assist in determining if PCBs were present.
The LFI report recommended that the site be designated an AOC because the site has several
distinct areas where evidence of contamination exists. |
Louis Howard |
| 12/22/1998 |
Update or Other Action |
The site was further investigated in 1998. The investigation included additional review of historical records, as-built drawings and aerial photographs, as well as interviews conducted with EAFB personnel and a military historian. A preliminary investigation/site investigation report documented the results of the limited field investigation. |
Louis Howard |
| 2/17/2000 |
Site Added to Database |
Soil contaminated with diesel |
Louis Howard |
| 2/18/2000 |
Update or Other Action |
Quarterly progress report from October 1, 1999 -Dec. 31, 1999. Preliminary assessment/site investigation from 1999 showed soil to be contaminated with POL (petroleum, oil and lubricants) and lead. The area was mentioned on maps as the Battalion D 96th AAA (anti-aircraft artillery). Lead is at 74,000 mg/kg, DRO at 10,000 mg/kg and RRO at 38,000 mg/kg. Engineering evaluation/cost analysis will be conducted in FY 00 (September 99-October 2000). Straddle bid awarded in December 1999. |
Louis Howard |
| 2/18/2000 |
Site Ranked Using the AHRM |
Site ranked by project manager. Multiple class of contaminants: Lead and diesel fuels/gasoline. Likely source of lead contamination from improper disposal of batteries, source areas: former motor pool, former generator buildings, former radar site, former transportation shops. |
Louis Howard |
| 4/5/2000 |
Site Characterization Workplan Approved |
Staff commented on a Draft Engineering Evaluation/Cost Analysis Work Plan for SS83. Main comments centered on cleanup levels for PCBs under residential and commercial land use. Additionally, comments clarified the practical quantification limits for soil analyses of PCBs and benzene. |
Louis Howard |
| 9/13/2000 |
Update or Other Action |
USAF proposed to transport the SS83 IDW soil from SS83 to Alaska Soil Recycling for thermal treatment. The contaminated IDW soil is from the investigation phase of the Engineering Evaluation/Cost Analysis site SS83. After reviewing the lab analyses results, ADEC concurred with the proposal. |
Louis Howard |
| 10/2/2000 |
Update or Other Action |
Quarterly progress report received for the 3rd quarter 1, July 2000-30 September 2000. Completed filed investigation for the engineered evaluation/cost analysis including initial clearing and geophysical investigation, excavation of test pits, and installation of groundwater monitoring wells. Soil and groundwater were sampled in September 2000. |
Louis Howard |
| 10/6/2000 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the draft Engineering Evaluation/Cost Analysis for the removal action of petroleum contaminated soils at the site. Comment requested changing the signature block to project manager level since this is an approval memorandum for a work plan and not a decision document. |
Louis Howard |
| 1/12/2001 |
Update or Other Action |
Quarterly progress report received for October 2000 to December 2000. Evaluation of data collected underway in preparation of a report. Next deliverable scheduled for July 30, 2001 (EE/CA Report) and develop programming documents for Phase II, investigation of the newly discovered landfill (March 2001). |
Louis Howard |
| 7/24/2001 |
Site Characterization Report Approved |
Staff reviewed and commented on the draft final Engineering Evaluation/Cost Analysis for the site. ADEC requests the Air Force include applicable cleanup levels for soil and groundwater within the tables summarizing analytical results. Additionally, background concentrations for inorganics will need to be included in each table when background concentrations are compared to source area concentrations.
Alternatively, the Air Force may wish to identify the specific cleanup levels applicable at each site within Section 6.0 Recommendations and conclusions. This would be in lieu of merely stating that the concentrations exceed Table C cleanup levels and background levels (e.g. Sec. 3.2 Scope of Removal page 3-1) or migration to groundwater soil cleanup levels (e.g. Sec. 6.1.1 Drum Bunker Area page 6-1).
6.1.1 Drum Bunker Area: ADEC concurs with the recommended removal and disposal action to remove 5 cubic yards of contaminated soil within the center of the bunker.
6.1.2 Large Foundation Area: ADEC concurs with the recommended removal and treatment to remove 25 cubic yards (which may increase, pending soil sampling results) of contaminated soils. If groundwater is encountered while the Air Force is conducting soil sampling, then the provisions of 18 AAC 78.090 must be followed concerning sampling of the groundwater interface.
6.1.3 Motor Pool Area: ADEC concurs with the recommended removal and disposal action to remove less than 10 cubic yards of contaminated soil.
6.1.4 Suspected Landfill Area: ADEC concurs with the recommendation that further investigation and specific information is needed regarding the suspected landfill’s properties-such as fill thickness, lateral and vertical extent and age. While there is no substitute for test pits and monitoring wells within a source area to identify or characterize contamination, ADEC concurs with the approach to characterize the landfill area using high-resolution electromagnetic and magnetic surveys, including ground-penetrating radar.
6.1.5 Small Foundation Area: ADEC concurs with the recommended removal and disposal action of 20 cubic yards of contaminated soil. Additionally, ADEC questions necessity of further characterization of the metals in soils and groundwater during excavation to clarify whether elevated metals in groundwater are naturally occurring or related to historical activities since a background study has been done on soils and groundwater across the Base (USAF January 1993). Please elaborate on the rationale for not using the existing background data that is available for metals in soil and groundwater.
6.1.6 Bermed Bunker Area: ADEC concurs with the recommended removal and disposal action to remove 20 cubic yards of contaminated soil.
6.1.10 Lookout Pad Area: ADEC concurs with the recommended removal and disposal action to remove 20 cubic yards of contaminated soil. |
Louis Howard |
| 2/28/2002 |
Update or Other Action |
EE/CA reports the following source areas with contamination:
Drum Bunker Area (DBA) located east of the Rosette Antenna: One surface sample (DBATP01SO1.0) was collected and analyzed for GRO, DRO, RRO, BTEX, and PAH. DRO was detected at a concentration of 6,480 ppm and RRO was detected at 4,970 ppm.
Large Foundation Area (LFA) located east of 42nd Street:DRO was detected in seven samples ranging in concentration from 27.3 mg/kg to 3,000 mg/kg.
Motor Pool Area (MPA) located on the west side of 42nd Street:Analytes and concentrations detected in the debris sample include GRO (103 mg/kg), DRO
(6,480 mg/kg). Analytical results indicate that DRO/RRO contamination decreased significantly with depth. DRO and RRO were detected at 1,070 mg/kg and 11,800 mg/kg in the deepest MPATP01 sample collected at 6.0 feet bgs, while DRO and RRO were not detected in any of three samples collected at depths from approximately 16.6 to 23.5 feet bgs at MPAWL01. GRO, DRO, benzene, ethylbenzene, and total xylenes were not detected in any of the soil boring soil samples. Toluene was detected in one subsurface sample (MPAWL01S022.0) at 66.0 mg/kg.
Two samples were collected from the test pit dug within the mechanics pit (MPATP01). The shallow sample MPATP01SO4.5 collected at 4.5 feet bgs had higher concentrations of chemicals of concern than the deeper sample MPATP01SO6.5. Analyte concentrations in the two samples collected from MPATP01 ranged from not detected to 18.1 mg/kg for GRO; 1,070 mg/kg DRO; 11,800 to 94,000 mg/kg RRO; total BTEX from nondetect to 2,397 mg/kg; 21,130 to 33,780 mg/kg TOC; and PAHs from nondetect to 2,330 mg/kg benzo(a)anthracene.
Bermed Bunker Area (BBA): DRO (5,230 mg/kg) and GRO (6.86 mg/kg) were the only
analytes detected in BBATP06SO7.0. DRO was detected in all BBAWL01 samples ranging in concentration from 75.7 mg/kg (BBAWL01SO20.0) to 3,730 mg/kg (BBAWL01SO15.0). Groundwater samples were collected from the two BBA monitoring wells (BBAWL01 and BBAWL02). A very slight sheen was observed on the surface of purge water and a moderate petroleum odor was noted at BBAWL01, but no free product was measured in the well itself.
Groundwater samples were analyzed for GRO, BTEX, VOC, DRO, RRO, metals, PAH, and nitrate-nitrite. Arsenic, barium, cadmium, chromium, lead, and mercury were the only analytes detected in BBAWL02; no organic analytes were detected. BBAWL02 nitrate/nitrite was detected at 2.02 mg/L. GRO, RRO, BTEX, and nitrate/nitrite were below detection limits in BBAWL01. DRO was detected in BBAWL01 at 1,450 µg/L (2,410 µg/L in the field duplicate). Naphthalene was detected at 0.0528 µg/L (0.0744 µg/L in the field duplicate); no other PAH analytes were detected in BBAWL01. It is likely that the source of the petroleum product observed in BBATP06 and BBAWL01 is the 0.5-inch fuel line that was excavated at the surface near these locations. It is probable that the fuel line was associated with the presumed tank source on the SFA pad.
Lookout Pad (LOP-The LOP is a 17-foot by 18-foot concrete pad that was situated 5 feet east of the edge of the bluff at the commencement of the SS83 EE/CA field
investigation in May 2000. A site visit conducted in January 2001 revealed that a 6-foot by 4-foot section of bluff had catastrophically eroded from the bluff face immediately adjacent to the center of the LOP. As of January 2001, the LOP was situated 1.5 feet east of the top edge of the bluff. One galvanized guy wire tie-down was located in the pad. It is unknown what the tie down was securing. DRO was detected in four samples ranging from 18.0 mg/kg (LOPWL02SO20.0) to 20,400 mg/kg (LOPWL01SO1.0). |
Louis Howard |
| 7/3/2002 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the draft work plan for the landfill at the site. Document was approved as submitted.
The Department’s review and concurrence on the work plan is to ensure the proposed work is in accordance with State of Alaska environmental conservation laws and regulations. While the Department may comment on other state and federal laws and regulations, our concurrence on the work plan does not relieve the United States Air Force (USAF) or its consultants, contractors, or civilian personnel from the need to comply with other applicable laws and regulations. Should the Air Force significantly change the work plan as approved, the Department will require an additional review and comment period for the changed document. |
Louis Howard |
| 10/21/2002 |
Update or Other Action |
J. Roberts sent a letter 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 |
| 5/21/2003 |
Document, Report, or Work plan Review - other |
Staff reviewed and had no comments regarding the engineering evaluation/cost analysis (EE/CA) for the SS83 site. Document was approved as submitted. |
Louis Howard |
| 5/31/2003 |
Update or Other Action |
A Decision Document signed by the USAF and ADEC in 2003 requires the removal and
transportation of POL-contaminated soil from six areas within SS83 (Drum Bunker Area, Large Foundation Area, Motor Pool Area, Small Foundation Area, Bermed Bunker Area, and the
Lookout Pad) to an off-base facility for thermal desorption treatment, as well as confirmatory
sampling to ensure removal. In addition, the Decision Document requires that the two USTs
located at the Large Foundation Area be removed. |
Louis Howard |
| 3/3/2004 |
Update or Other Action |
Staff reviewed, commented on the Draft February 2004 SS83 Landfill SIte Investigation Report. 4.0 Nature and Extent of Contamination Page 4-2 Last Sentence-The text states: “…and based on the likely age of the landfill (World War II era), any wood present is unlikely to have been treated with arsenic.” This statement is not necessarily correct. In 1933 , Dr. Kamesam (S. Kamesam 1933, British Patent 404855) developed the first CCA formulation in which copper sulphate and arsenic pentoxide are fixed by dichromate (CCA). CCA has been manufactured in three formulations known as CCA-A, CCA-B and CCA-C respectively. All three formulas contain the same basic ingredients: arsenic in the form of arsenic pentoxide, chromium, in the form of both hexavalent chromium and trivalent chromium, and copper in the form of copper oxide.
5.2 Recommendations-The Department concurs that the inorganics detected in the soil at site SS83 (contaminated sites database name “Elmendorf SERA SS83 Anti-Aircraft” reckey# 199921X900401) are likely background concentrations and need not require further action. The Department reserves its rights, under 18 AAC 75 Oil and Other Hazardous Substances Pollution Control regulations and AS 46.03 to require additional investigation, cleanup, or containment if subsequent information indicates that: 1) additional contamination remains at the site which was previously undiscovered and presents an unacceptable risk to human health, safety, or welfare, or the environment. |
Louis Howard |
| 6/22/2004 |
Update or Other Action |
Staff reviewed and approved the Draft June 16 2004 SS83 Removal Action to remoe and sample two heating fuel underground storage tanks. General Comments- The document states the two underground storage tanks (USTs) containing diesel heating fuel as not being regulated by the Department. This is not entirely true. If the USTs had a release from overfills, spills, or leaks, they would be regulated by 18 AAC 75 Contaminated Sites regulations for investigation and cleanup.
Additionally, 18 AAC 75 adopts the UST Procedure Manual by reference in regulation. For example: 18 AAC 75.355(d) Analysis for petroleum contamination must follow the applicable Alaska methods for petroleum hydrocarbons referred to in Table 1 of Chapter 2 of the UST Procedures Manual, dated November 7, 2002. Table 1 of Chapter 2 and Appendices D and E of the UST Procedures Manual, dated November 7, 2002 are adopted by reference. Therefore the UST Procedure Manual is not “guidance” as stated in the document, but it is in fact, regulation that must be followed by the Air Force.
Please provide clarification where the USTs are stated as not being “regulated” by the Department simply because they contained heating fuel. With these corrections and EPA’s comments being incorporated, the plan is approved. |
Louis Howard |
| 5/17/2005 |
Update or Other Action |
Staff reviewed a draft amendment to a decision document for six areas within the former anti-aircraft artillery battery site. The document states because the site falls under the CERCLA petroleum exclusion, five year reviews are not required. ADEC requests that concurrent with CERCLA five year reviews, the Air Force include all contaminated sites (excluded from CERCLA) that have land use controls placed on them or a remedy which includes natural attenuation with monitoring, be reviewed at the same time to ensure the selected remedy and associated land use controls remain protective of human health, safety, or welfare or the environment. |
Louis Howard |
| 6/20/2006 |
Update or Other Action |
Staff reviewed and commented on the Draft Work Plan for Delineation of Soil Contamination and Groundwater Monitoring at SS83, Elmendorf AFB, AK Dated June 12, 2006. Plan was approved as submitted. While ADEC may comment on other state and federal laws and regulations, ADEC’s concurrence on the request does not relieve the Air Force or its contractors, sub-contractors, civilian personnel from the need to comply with other applicable state and federal laws and regulations. |
Louis Howard |
| 8/9/2006 |
Update or Other Action |
Staff reviewed and commented on the Draft Appendix E Work Plan Addendum for Delineation of Soil Contamination and Groundwater Monitoring at SS83, Elmendorf AFB, AK Dated July 28, 2006. Document approved as submitted. While ADEC may comment on other state and federal laws and regulations, ADEC’s concurrence on the document does not relieve the Air Force or its contractors, sub-contractors, civilian personnel from the need to comply with other applicable state and federal laws and regulations. |
Louis Howard |
| 1/11/2007 |
Update or Other Action |
Staff reviewed and commented on the Draft SS83 Field Investigation Report, Elmendorf AFB, AK Dated December 2006.
Table 3-8 Groundwater Analytical Data (Diesel Range Organics and Natural Attenuation Parameters) Page 3-11
Drinking water regulations (amended as of November 9, 2006) at 18 AAC 80.300(b)(1) list maximum contaminant levels for: nitrate at 10 mg/L (as nitrogen), nitrite at 1 mg/L (as nitrogen) and Total nitrate and nitrite at 10 mg/L (as nitrogen). ADEC requests the table be changed to reflect these levels for nitrate and nitrite.
Appendix G Data Quality Assessment The text states that evaluation of data quality indicators involved the review of the following laboratory QA data criteria established for the following parameters: REPRESENTATIVENESS - Sample chain-of-custody and - Holding times and preservation
Absent from the appendices were copies of: 1) sample receipt forms documenting the condition of the samples and the ambient temperature of the shipping container adjacent to the sample containers (or temperature blank) WHEN RECEIVED by the laboratory (SGS Environmental Services, Inc. Anchorage); and
2) a copy of the Chain of Custody(ies) (COC) for each sample or group of samples, including the COC for samples transferred to alternate locations. ADEC requests copies of the sample receipt forms and chain-of-custody forms be submitted for its review relating to the SS83 Bermed Bunker Area field investigation.
These forms (as well as other information included in tech memo 06-002 dated October 9, 2006) are required as part of all quality assurance submittals for both laboratory data packages and quality assurance summaries that must be included in all reports containing analytical data submitted to ADEC under 18 AAC 75 and 18 AAC 78 regulations. |
Louis Howard |
| 2/19/2008 |
Exposure Tracking Model Ranking |
Initial ranking with ETM completed. |
Louis Howard |
| 9/30/2008 |
Update or Other Action |
Final Work Plan received. This Work Plan and its appendices describe the removal action to be conducted at Site SS83 and the Zone 2 treatment system (SD15 and ST32 Tank 2) removal at Elmendorf Air Force Base (AFB), Alaska. The scope of work for this project includes environmental sampling and removal of contaminated soil in pursuit of site closure. This Work Plan was prepared in accordance with the requirements of the Alaska Administrative Code (AAC),
Title 18, Section 75.360 (Alaska Department of Environmental Conservation [ADEC] 1999).
1.1 PROJECT GOALS AND OBJECTIVES
The goal for the work at Site SS83 is to excavate petroleum, oil, and lubricants (POL)-
contaminated soil to achieve cleanup goals. Project activities include soil sampling,
excavation of contaminated soil, and waste management. These activities are designed to
remove contaminated soil with diesel-range organics (DRO) in concentrations greater than the
ADEC Method Two cleanup level of 250 milligrams per kilogram (mg/kg). The goal for the
work at the Zone 2 Treatment System (SD15 and ST32 Tank 2) removal will be to
decommission the treatment systems as part of the effort to achieve closure for these sites.
The scope of work for this project includes the excavation of POL-contaminated soil at Site
SS83 Bermed Bunker Area (BBA) to meet soil cleanup levels. An estimated 1,350 tons(900 cubic yards [cy]) of soil will be removed. The scope also includes decommissioning of the high-vacuum extraction (HVE) system at Site SD15 and the bioventing system at ST32, Tank 2. Decommissioning activities will include demolition of the HVE process building at SD15, removal of the blower unit at ST32, removal of piping at both sites, and decommissioning of any well not needed for future groundwater monitoring.
Confirmation sample collection activities will be conducted in accordance with 18 AAC 75
protocol. The excavation will be sampled at a frequency of one confirmation soil sample per 250 square feet, with two soil samples from the first 250 square feet of excavated area. At least one sample will be collected from the floor of the excavation. Confirmation soil samples will be collected at the location of the highest field screening results, at the frequency specified above. Samples will be collected and submitted to an approved laboratory for analysis. DRO is the only anticipated analyte of concern. Samples will be analyzed using method AK102 and in accordance with the FSP.
Soil sampling from the clean soil stockpile will be performed in accordance with 18 AAC 75
and as described in the FSP. Field-screening samples will be collected from the stockpile at a minimum frequency of one per 25 cy. Analytical confirmation soil samples will be collected from random locations within the stockpile; they will be taken with a frequency of one sample per 50 cy of stockpile, with two samples from the first 50 cy. |
Louis Howard |
| 10/15/2008 |
Update or Other Action |
5 YR REVIEW: Two other areas, SS83 and SA99, were also mentioned in the 2003 five-year review, but these sites were subsequently removed from CERCLA and addressed under state programs due to the nature of contaminants. Therefore, SS83 and SA99 are not required to be evaluated under this
five-year review.
Operable Unit Status
SS83 is a World War II-vintage antiaircraft artillery site (Battery D, 96th Antiaircraft Artillery) located near Six-Mile Creek on the northwest side of the base, adjacent to Knik
Arm. This area is uninhabited, vegetated, and restricted.
Since the 2003 five-year review, this site was transferred from CERCLA to a state program due to the nature of the contaminants. This site will not be included in subsequent five-year
reviews because it is no longer part of the CERCLA program. |
Louis Howard |
| 3/17/2009 |
CERCLA ROD Periodic Review |
Cover letter to the EPA's Five-Year Review signature sheet sent to Richard J. Walberg, Colonel, US Air Force Vice-Commander from EPA Region 10 Office of Environmental Cleanup Daniel D. Opalski, Director. The Environmental Protection Agency (EPA) has completed their review of the third Five-Year Review report for the United States Air Force (USAF) Elmendorf Superfund site, in Anchorage Alaska.
EPA reviewed this report for technical adequacy, accuracy, and consistency with EPA guidance. In general, EPA agrees with the protectiveness determinations in this report. However, I understand that all parties to the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) Section 120 Federal Facility Agreement (FFA) are aware of a potential new source that has not been fully characterized, namely SS-022. It is also my understanding that while the Five-Year Review identifies this potential new source, the USAF has not adequately discussed the interim measures it has already taken to ensure protectiveness as site characterization proceeds, such as Institutional Controls (ICs) at SS-022 and the ongoing Remedial Investigation.
Therefore, we recommend that within ninety (90) days (by June 15, 2009), USAF supplement the Site File and Administrative Record with a Memorandum to document the ICs (e.g., installation of a fence, signage, and notation on the Environmental Restoration Program Atlas) that have been implemented for the protection of human health and the environment at SS-022. The Memorandum should also mention the Installation-wide ICs (including restriction of ground water use) already in place.
In addition, EPA agrees with USAF's recommendation for further action at the OU-l landfill area for the trichloroethylene (TCE) groundwater contamination, and requests that the Program Managers meet to discuss the timeline for completion of the groundwater contamination characterization and establish deadlines and, as appropriate, target dates for subtasks, as required under the FFA.
|
Louis Howard |
| 4/30/2009 |
Update or Other Action |
SS83 Final Soil Cleanup Report received. This report describes the soil cleanup at SS83 at Elmendorf Air Force Base (AFB). This report was prepared for the U.S. Air Force (USAF), 3rd Civil Engineer Squadron/Asset Management Flight, Natural Resources Element, Cleanup Section, by Jacobs Engineering Group Inc. under Air Force Center for Engineering and the Environment contract F41624-03-D-8673.
Historically, SS83 is the site of a former anti-aircraft artillery (AAA) site (USAF 2003).
Several structures (including concrete foundations, underground storage tanks, soil berms,
underground bunkers, drum walls, and demolished structures) are associated with former uses
of the site. SS83 was divided into 10 areas for investigation purposes: Landfill Area, BBA,
Underground Bunker Area, SFA, Large Foundation Area, Motor Pool Area, Ravine Area, Lookout Pad, Docking Area, and Drum Bunker Area.
Currently, the SFA consists of a concrete pad, approximately 400 square feet in area, located
on the east side of the Overlook Area access road. The BBA is a concrete pad originally
surrounded on three sides by stacked, soil-filled drums located directly next to and southeast
of the SFA. A soil berm formed the outside of the drum wall. Drums were used as a splinter-proof retaining wall.
This report describes the cleanup of petroleum-contaminated soil at SS83 during late September and early October 2008. Field activities included the removal of concrete pads from the Bermed Bunker Area (BBA) and the Small Foundation Area (SFA); the excavation of petroleum, oil, and lubricants (POL)-contaminated soil at the SS83 BBA to meet soil cleanup levels; and confirmation sampling. Approximately 875 tons (580 cubic yards [cy]) of soil was removed from the BBA and transported offsite for thermal treatment.
The 2008 soil cleanup at SS83 sought to excavate all remaining petroleum-contaminated soil
with DRO concentrations in excess of the agreed-upon cleanup level of 250 mg/kg.
A total of 875 tons (580 cy) of DRO-contaminated soil was excavated from SS83, near the
SFA and BBA. Confirmation samples were collected from the walls and the floor of the excavation
between 4 and 21 feet bgs. DRO results for all confirmation samples were below ADEC Method Two migration-to-groundwater criteria, with the exception of two samples from the floor of the excavation below the groundwater interface. Thus, all DRO sample results indicate contamination above the groundwater interface has been removed. |
Louis Howard |
| 12/1/2009 |
Update or Other Action |
Semi-annual progress report received. Summary of Work Performed during last six months. Planned Activities for next six months. Award FY10 Zone 1 Remedial Action-Operations project (Jan 10),
Receive final work plan for summer 2010 field activities (May 10) and Conduct groundwater sampling at 3 monitoring wells (Jul 10). |
Louis Howard |
| 4/28/2010 |
Update or Other Action |
Memorandum for ADEC. SUBJECT: Response to ADEC Comment on Draft 2009 Zone 1 Field Activities Report (Ref: ADEC Memo, 12.Mar 10)
1. This memorandum is in response to ADEC's concern as to why diesel-range organics (DRO) and gasoline-range organics (GRO) at select groundwater plumes were not sampled in 2009 as previously agreed in a January 14, 2003 meeting. Specifically, ADEC's comment (Attachment 1) is in reference to Section 3.7.1 Implications of Contaminant and Geochemical Monitoring, Page 3-17 of the draft 2009 Zone 1 Field Activities Report, which stated: "The text states: When these parameters were monitored from 1999 to 2007, GRO concentrations in this monitoring well exceeded cleanup levels while DRO concentrations hovered near the cleanup level. ADEC requests the Air Force provide an explanation or a memorandum to the site file as an appendix to the document on why DRO and GRO were eliminated from the monitoring program as previously agreed to in a January 14, 2003 meeting with ADEC, USAF and EPA."
2. The analytes in question were not included in the Zone 1 groundwater monitoring program for FY09 due to an administrative oversight. The agreement to monitor for DRO and GRO was captured in meeting minutes (Attachment 2), not in a more formal mechanism such as a decision document or memorandum to the site file. In preparation for programming of project requirements, we reviewed the governing documents for the Zone 1 sites. None of the governing documents for Zone 1 sites identified GRO/DRO as a contaminant of concern (COC); therefore, GRO/DRO sampling was not programmed or conducted in 2009.
3. The U.S Air Force agrees with ADEC's request to continue sampling for diesel-range organics (DRO) and gasoline-range organics (GRO) for CERCLA sites with fuel-related plumes. Minutes of a 14 Jan 03 meeting with EPA, ADEC and DRS, provided with the above referenced ADEC memo, documents that the Air Force agreed to add DRO/GRO into the sampling program under the following conditions:
a. The decision will be documented in the 5-Year Review. The addition of DRO/GRO to the program should be introduced in the 5-Year Review under• mention of new issues affecting protectiveness.
b. The Air Force will NOT add DRO/GRO as a CERCLA ARAR, but will compare DRO/GRO results to ADEC cleanup levels in the annual reports and will discuss in subsequent 5-Year Reviews. The benefit of this is that if CERCLA COCs meet ARARs, the Air Force can achieve a partial delisting.
c. The Air Force will add DRO and GRO to the suite of analyses at monitoring wells associated with fuel plumes starting in 2004.
d. The Air Force will not pursue a decision document with ADEC on DRO/GRO until more data is gathered on the extent of the problem.
e. Until a decision document is signed with ADEC, GRO and DRO concentrations will be compared to ADEC regulations in 18 AAC 75 (Table C, Groundwater Cleanup Levels; 1,500 ug/L for DRO, 1,300 ug/L GRO).
f. Sampling frequency for DRO/GRO will follow the latest Decision Guide for Sampling Frequency (see 2002 Basewide Annual Report). "Immediately up gradient" means within a 2-year warning line, similar to that generated for OU5.
g. ADEC GRO/DRO criteria apply to groundwater, not to seeps which daylight as surface water. Criteria in 18 AAC 70 (TAR, TAqH) apply to surface water.
4. The fact that these analytes were not included in the Zone 1 groundwater monitoring program for FY09 is attributed to an oversight. The USAF will add DRO/GRO into the suite of analyses at monitoring wells associated with fuel-related plumes for Zone 1 (LF04 South and WP14) and will prepare a memo to the site file to prevent this type of oversight from occurring in the future.
The USAF strategy will be to compare DRO/GRO and total aromatic hydrocarbon (TAH)/total aqueous hydrocarbon (TAqH) sample results as contaminants of interest with current ADEC regulations in 18 AAC 75 - Table C - Groundwater Cleanup Levels and 18 AAC 70 for surface water. Should you have any questions, please feel free to contact me at (907) 552-2875.
Signed Gary Fink YF-02 Chief, Environmental Restoration.
|
Louis Howard |
| 2/10/2011 |
Update or Other Action |
Zone 1 Draft Field Activities Report received. MNA parameters in both BBAWL-04 and BBAWL-05 showed moderate DO levels (6.38 to 7.93 mg/L) and moderate conductivity (138 to 315 µS/cm) and oxidizing conditions (120 to 174.1 mV) (Table 9-2). Ferrous iron was not detected in either well.
In 2006, three monitoring wells were installed and sampled for DRO using Method AK102.
The upgradient well (BBAWL-04) was below the cleanup level while the source area and inplume wells (BBAWL-03 and BBAWL-05, respectively) were above the cleanup level. Contaminated soil and the source-area well were removed in 2008. Following the removal action, the first round of post-remedial groundwater monitoring data was collected in 2010. The upgradient well (BBAWL-04) continues to be clean and the in-plume well (BBAWL-05) continues to be contaminated.
Several additional years of monitoring results will be needed to determine the rate of natural attenuation and predict a cleanup data. DRO in the source area in 2006 was at a level consistent with the presence of only immobile, slowly dissolving product, suggesting that a downward trend should soon develop, but the sluggish groundwater system may result in a protracted period (a decade or more) of natural attenuation.
MNA parameters in the two monitored wells (BBAWL-04 and BBAWL-04) indicate moderately oxidizing groundwater. Due to the age of the spill, it was expected that degradation over time would create reducing conditions. These oxidizing conditions may be the result of disturbing the contaminated smear zone during the 2008 soil removal activities and, therefore, do not rule out the possibility of degradation taking place.
Conditions and trends in the SS83 plume are as follows:
Upgradient. Results in the upgradient monitoring well BBAWL-04 continue to be below
cleanup criteria. BBAWL-04 was monitored in 2006 and again in 2010.
In-plume. Results from 2006 and 2010 define a groundwater DRO plume extending from the source area to an unknown distance past BBAWL-05.
Downgradient. The extent of the plume is unknown because no downgradient monitoring points have been established.
The 2010 recommendations for future monitoring at SS83 are as follows:
Continue annual monitoring of the COC and of MNA parameters.
Install crossgradient and downgradient wells to better define the SS83 plume. A crossgradient well would provide triangulation to determine an accurate groundwater flow direction, and a downgradient well would provide a sentry point to test the hypothesis that the plume is stationary.
Investigate the bluff below SS83 for the seep that is the most likely discharge point for
groundwater from the SS83 plume. The seep should be added to the SS83 monitoring program if a downgradient well is not installed (or if the downgradient well turns out to be contaminated).
Evaluate SS83 for in situ chemical oxidation to expedite reduction of DRO in the smear zone and groundwater. |
Louis Howard |
| 2/24/2011 |
Document, Report, or Work plan Review - other |
Staff reviewed and approved the recommendations in the draft field activities report for this site. |
Louis Howard |
| 7/15/2011 |
Update or Other Action |
Draft Work Plan Environmental Remedial Action-Operations & LTM & Maintenance received.
The purpose of this project is to perform RA-O & LTM activities for several JBER Programs. These programs include sites distributed across both JBER-Elmendorf & JBER-Richardson. This Work Plan addresses remedial activities in JBER-Elmendorf Zone 1, Zone 2, & Zone 3 Management Areas, JBER-Elmendorf Compliance Restoration Program (CRP) sites, the JBER Elmendorf Operable Unit (OU) 1 Landfill, JBER-Richardson Multiple Installation Restoration Program (IRP) Sites, & JBER-Richardson Poleline Road & OUE Armored Vehicle Maintenance Area (AVMA).
Environmental Restoration Program Zone 1 Management Area covers the comparatively sparsely developed portions of JBER-Elmendorf to the west, north, & east of the airfield & administrative core of the base. Eleven sites are now managed under Zone 1: LF02, LF03, LF04, WP14, ST36/66, ST41, ST61, ST69, SS83, & DP98. LF02 & LF03 are located in the southeastern portion of the base, near the Boniface gate, whereas the remaining nine sites are distributed throughout the northwestern portion of the base, between the airfield & Knik Arm. GW contamination is tracked in nine plumes at these sites, & exposed landfill debris is of concern at LF04.
Six sites (LF02, LF03, LF04, WP14, ST41, & DP98) are administered under the Comprehensive Environmental Response, Compensation, & Liability Act (CERCLA), with USEPA oversight, & are governed by ROD. The five remaining sites (ST36/66, ST61, ST69, & SS83) are regulated according to State of Alaska requirements. GW COCs for most of the sites (WP14, ST36/66, ST41, ST61, & SS83) are fuel constituents (one or more of benzene, toluene, ethylbenzene, xylenes, or diesel-range organics [DRO]). These sites were contaminated by pipeline & storage tank leaks & past practices. The primary sources have been removed, leaving secondary sources comprised of residual fuel distributed in contaminated smear zones at the water table. Two sites have chlorinated-solvent GW COCs: LF04 (1,2-dichloroethane & methylene chloride, as well as fuel constituents), & DP98 (chlorinated solvents). The chlorinated solvents occur in shallow GW as dissolved contaminants at LF04 & in conjunction with a DRO contaminated smear zone at DP98.
SS83 is a 20-acre site located along the bluff above Knik Arm, south of Six Mile Lake (Figure 2.9). SS83 was used as a former World War II anti-aircraft artillery site that was abandoned in the late 1950s and is currently used as the Rosette Antenna Site. Two areas within SS83, the Small Foundation Area (SFA) and Bermed Bunker Area (BBA), were previously identified as contaminated. Petroleum hydrocarbon contamination is associated with a surface release from a presumed former storage tank on the SFA and associated piping leading to the BBA. The BBA consisted of a concrete pad originally surrounded on three sides by stacked, soil-filled drums.
The Zone 1 Management Area sites are located throughout the western, northern, & eastern portions of JBER-Elmendorf. Nine sites on JBER are managed under Zone 1: LF02, LF04, WP14, ST36/66, ST41, ST69, SS83, & DP98. COC are tracked in all nine GW plumes at these sites, & are listed below. LF04 also contains an inactive landfill where debris is monitored & fallen debris removed.
• Site LF02 - 1,1,2,2-tetrachloroethane (PCA)
• Site LF04 - Benzene, ethylbenzene, toluene, methylene chloride, 1,2-dichloroethane
(DCA)
• Site WP14 - Benzene, ethylbenzene, toluene
• Site ST36/66 - diesel range organics (DRO)
• Site ST41 - benzene, toluene, ethylbenzene, & xylenes (BTEX)
• Site ST69 - Benzene
• Site SS83 - DRO
• Site DP98 - tetrachloroethene (PCE), Trichloroethene (TCE), 1,1-dichloroethene, cis-1,2-
dichloroethene, vinyl chloride (VC)
Data quality objectives directly linked to Zone 1 project objectives are defined in the FSP & UFP-QAPP, within the SAP (Appendix A). Additional Zone 1 Management Area project objectives in 2011 include:
Evaluate & maintain the integrity of monitoring wells;
Evaluate GW flow characteristics while continuing to study trends in GW level with the monitoring wells; &
Evaluate erosion rates & characteristics of the LF04 bluff.
The activities to be performed under this TO include:
Collect & analyze GW & surface water samples;
Conduct GW level survey;
Perform maintenance of existing wells, as needed;
Install a maximum of 2 new/replacement GW wells;
Decommission a maximum of 5 damaged/redundant wells; &
Conduct LF04 erosion survey & debris removal.
|
Louis Howard |
| 4/10/2012 |
Update or Other Action |
Draft Annual report received for Zones 1, 2, and 3.
SS83 was added to the annual groundwater monitoring program in 2010 per 18 AAC 75. The present remedial action consists only of groundwater monitoring. Table 2.36 lists groundwater COCs and cleanup levels.
Contaminated soil and the source-area well were removed in 2008. Following the removal action, groundwater monitoring data was collected in 2010 and 2011. The upgradient well (BBAWL-2741 04) continues to be clean. DRO results for the in-plume well (BBAWL-05) exceeded the cleanup level in 2006 and 2010 but dropped below the cleanup level in 2011. Several additional years of monitoring results will be needed to determine the rate of natural attenuation and predict a cleanup date.
DRO in the source area in 2006 was at a level consistent with the presence of only immobile,
slowly dissolving product, suggesting that a downward trend should soon develop, but the
sluggish groundwater system may result in a protracted period (a decade or more) of natural
attenuation.
Summary and Recommendations for SS83
Conditions and trends in the SS83 plume are as follows:
· Upgradient. In 2006 and 2010, DRO results in well BBAWL-04 were below the cleanup level. DRO was not detected in this well in 2011.
· In-plume. Results from 2006 and 2010 defined a groundwater DRO plume extending from the source area to an unknown distance past BBAWL-05. The concentration of DRO in well BBAWL-05 decreased in 2011 and was below the cleanup level.
· Downgradient. The extent of the plume is unknown because no downgradient monitoring points have been established.
The 2011 recommendations for future monitoring at SS83 are as follows:
· No changes to the sampling program as outlined in Table 2.37.
· Install cross-gradient and downgradient wells to better define the SS83 plume. A cross2766
gradient well would provide triangulation to determine an accurate groundwater flow direction, and a downgradient well would provide a sentry point to test the hypothesis that the plume is stationary.
· Investigate the bluff below SS83 for the seep that is the most likely discharge point for
groundwater from the SS83 plume. The seep should be added to the SS83 monitoring program if a downgradient well is not installed (or if the downgradient well turns out to be contaminated). |
Louis Howard |
| 6/6/2012 |
Update or Other Action |
Draft project management plan received for review and comment.
Performance Objective
Site Closure
Performance Indicators
· Prepare an approved Site Characterization Workplan by December 2012
· Coordinate, mobilize, and execute Site Characterization by August 2013
· Prepare an approved Site Characterization Report and Site Closure Report by March 2014
· Conduct final site closure requirements and well abandonment to achieve SC by May 2014
Potential Risk
HRC indicates soil contamination is present exceeding risk levels
HRC indicates groundwater contamination is present exceeding risk levels.
Risk Mitigation
Excavation or treatment (biovent) will be completed for vadose zone soils exceeding risk
levels to eliminate risk, and evaluation of groundwater impacts will be completed and
appropriate treatment (enhanced bioremediation) will be implemented to remediate groundwater.
Date of Achieving Performance Objective
3rd Quarter FY 2014
Planned Approach
Prepare an approved Site Characterization Workplan including an updated CSM.
Coordinate, mobilize, and execute Characterization by installing and sampling five soil borings and convert on boring to monitoring well.
Use HRC to evaluate SC based on risk to future residential receptors for all pathways.
Prepare an approved Site Characterization Report with an updated CSM, documented HRC risk
evaluation, and include the Site Closure Report requesting Cleanup Complete without ICs.
Receive concurrence from ADEC that site has achieved Cleanup Complete without ICs and provide
documentation to AFCEE |
Louis Howard |
| 6/22/2012 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft Project Mgt. Plan.
Table 6-3 JBER-Elmendorf
General comments
Risk mitigation: In general, vadose zone soils shall not exceed maximum allowable levels for petroleum contamination for soil from 0 – 15’ bgs (i.e. direct contact for BTEX, PAHs & ingestion for DRO, GRO, RRO) regardless of HRC calculated 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 & ICs will be required. Once GW is below Table C for for a period of time (per the latest approved “Basewide Monitoring Program Well Sampling Frequency Decision Guide”), the maximum allowable levels may become the cleanup levels as determined by ADEC on a case by case basis.
7.1.2
Independent QA Oversight on Performance Based Contracts
The site cleanup rules require that “collection, interpretation, & reporting of data, & the required sampling & analysis is conducted or supervised by a qualified, impartial third party”. Depending upon the specific terms in a performance based contract, a contractor may no longer be considered an impartial third party with respect to collecting, interpreting & reporting data.
This should be taken into consideration when preparing scopes of work. ADEC strongly recommends the Air Force provide an on-site Quality Assurance Representative or a third party QA oversight contractor to monitor fieldwork for consistency with approved plans & contract requirements.
7.2.1 UFP-QAPP Requirements (Planning)
Any existing approved UFP-QAPPs will be updated to reflect current regulations and guidance that have been updated since they were approved.
Page 7-6
The text states: “Our Technical Site Managers and Project Chemists will ensure that, prior to sampling activities, full service analytical laboratories to be used are, at a minimum, DoD ELAP accredited and in good standing based on standard business information sources (e.g., Dunn & Bradstreet). In addition to DoD ELAP, the Project Chemist will also ensure that the supporting laboratories are approved for work in the State of Alaska, when required. Analytical methods used will be
Alaska and EPA standard methods, unless technically impractical.”
ADEC disagrees. The full service analytical laboratories have to be both DoD-ELAP accredited AND Alaska approved. Any non-EPA and/or Alaska methods must be approved by the department prior to sample collection.
SS83 WWII Anti-Aircraft Artillery (IRP) Page 11-16
GW is already impacted at this site with DRO at 3.6 mg/L so the Table B1 migration to GW cleanup level for soil is applicable. Sites with GW contamination above Table C cleanup levels will not receive a “cleanup complete” designation without ICs.
|
Louis Howard |
| 4/18/2013 |
Update or Other Action |
Draft UFP-QAPP site characterization work plan received for review and comment.
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 from the ADEC. To meet these objectives, soil and groundwater samples will be collected to characterize risk to human health and the environment within the framework of the ADEC site cleanup process (18 AAC 75 Sections 325 to 390 and 18 AAC 78 Section 600).
If 18 AAC 75 Method Two cleanup criteria are exceeded, the Hydrocarbon Risk Calculator (HRC) approach under Method Three will be used to assess whether site conditions meet ADEC risk criteria (in which case a determination of cleanup complete without ICs will be made for SS083, which is equivalent to site closure) 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.
Approximately 10 LIF probes will be used to help identify the horizontal and vertical extent of petroleum hydrocarbon contamination at the small foundation area and bermed bunker area. The LIF probes will be driven in a loose grid pattern west and northwest of the source area. All probes will extend through the zone of seasonal water table fluctuation to a depth of about 25 ft.
• The first probe will be placed near the location of the excavation confirmation sample 07005 and this probe is expected to encounter contaminated soil in the zone of seasonal water table fluctuation.
In addition, to confirm that the 2004 excavation removed the near surface contaminated soil at the SFAWL03 location, a probe will be installed at the location of the former well. If the probe at the SFAWL03 location does encounter contaminated soil, then additional probes will be installed as needed to define the extent of contamination near the former monitoring well. If the probe does not encounter contaminated soil, then no additional probes will be installed at this location.
If water samples from monitoring well BBAWL05 exceed 18 AAC 75 Table C criteria, then a downgradient monitoring well will be installed and sampled, or groundwater samples from the seeps on the Knik Arm bluff will be collected. These data will be used to assess the extent of the dissolved-phase plume and if there is an exceedance of the surface water quality criteria.
One new monitoring well will be installed in each of the NAPL-contaminated source areas at both the bermed bunker area and the large foundation area. The new monitoring wells and existing well BBAWL05 will be sampled for GRO, DRO, RRO, BTEX, PAHs, EPH, and VPH analysis. If monitoring well BBAWL05 or the new in-source monitoring well at the large foundation area exceed 18 AAC 75 Table C criteria, then an additional downgradient monitoring well may installed to document the downgradient extent of the dissolved-phase plume associated with each source area. If a downgradient well is installed, it will be sampled for GRO, DRO, RRO, and BTEX. |
Louis Howard |
| 4/30/2013 |
Update or Other Action |
Draft Annual report for monitoring received for review and comment.
SS083 was used as a former World War II anti-aircraft artillery site that was abandoned in the late 1950s and is currently used as the Rosette Antenna Site. Two areas within SS83, the Small Foundation Area (SFA) and Bermed Bunker Area (BBA) (Figure 17-1), were previously identified as contaminated (USAF, 2003b). Petroleum hydrocarbon contamination is associated with a surface release from a presumed former storage tank on the SFA and associated piping leading to the BBA. The BBA consisted of a concrete pad originally surrounded on three sides by stacked, soil-filled drums.
Historic sampling results for SS083 have indicated fuel constituents present in groundwater above cleanup criteria in 18 AAC 75 Table C and fuel constituents in soil above 18 AAC 75 Tables B1 and B2. Soil cleanup efforts in 2008 excavated and removed approximately 875 tons of DRO contaminated soil near the SFA and BBA. Confirmation sampling for DRO indicated that vadose zone contamination above the groundwater interface has been removed (USAF, 2009e). Current monitoring requirements at Site SS083 include annual groundwater sampling for DRO at groundwater monitoring wells BBAWL-04 and BBAWL-05. Well BBAWL-04 was found to be destroyed during 2012, likely by a snow plow, and is no longer usable.
Additional investigation to characterize the current presence/absence of soil contamination is being proposed for SS083 in 2013 under the new PBR contract (Pre-draft SS083 Site Characterization Work Plan USAF, 2013f). The proposed site investigation will help identify the horizontal and vertical extent of petroleum hydrocarbon contamination at the site. No changes to the annual monitoring are being proposed for this site. |
Louis Howard |
| 5/6/2013 |
Document, Report, or Work plan Review - other |
Staff commented on the draft HRC UFP-QAPP for SS083.
Executive Summary
1st paragraph
The text states: “After extensive excavation and thermal treatment of hydrocarbon-contaminated soils in 2004, seven of the SS083 subareas appear to meet Title 18 Alaska Administrative Code (AAC) 75 Method 2 cleanup levels and therefore, are ready for a “cleanup complete without 54 institutional controls” determination by the Alaska Department of Environmental Conservation (ADEC).”
Sub-areas of the 20 acre site known as SS083 will not be granted separate cleanup complete determinations by ADEC. The site is not divided up into subareas under the SOO or PMP nor is it an operable unit with separate source areas, but instead SS083 is a single site on JBER-Elmendorf. Partial closures of subareas will not change the status of SS083 as an “active” site in the Contaminated Sites database.
Page iii
Small Foundation Area
The text states: “…before excavation, there were two separate non-aqueous phase liquid (NAPL)-contaminated soil sources that may have been from an aboveground storage tank and fuel pipelines (no USTs were discovered at the bermed bunker area or small foundation area).”
Please provide clarifying text regarding the fuel used in the AST and fuel pipelines (e.g. mogas or arctic diesel).
Page iv
Large Foundation Area
The text states: “…The large foundation area samples indicate that before excavation, there was NAPL-contaminated soil associated with the 500-gallon UST on the west side of the foundation and the 1,000-gallon UST on the south side of the foundation.”
Please provide additional information in the text regarding the fuel type stored in the 500-gallon UST and the 1,000 gallon UST.
Sampling Design and Rationale
Page 40
The text states: “If the site conditions meet the ADEC risk standard, then a determination will be made that TU091 meets ADEC’s “cleanup complete without ICs. If the site poses an unacceptable risk, then remedial options that address the compounds and exposure routes that contribute most significantly to the cumulative risk will be evaluated and remediation and/or, ICs and engineering controls may be used to manage the risk.”
Please note that vadose zone soils shall not exceed MAC 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 groundwater contamination exceeding Table C criteria.
See comment #1 above regarding ADEC’s position on when ICs would be applied at JBER sites.
1st Bullet
The text states: “Define the horizontal and vertical extent of soil hydrocarbon contamination both above and below the water table. This typically requires drilling and soil sampling both inside and outside contaminated soil source area and above and below the water table [but can be augmented by using tools such as laser-induced fluorescence (LIF)].”
ADEC will require that the horizontal and vertical extent of any remaining residual contamination be characterized by definitive laboratory data not field screening tools such as the LIF, PID, FID, etc. Samples analyzed with field screening devices may not be substituted for required laboratory samples.
|
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.
Historic sampling results for SS083 have indicated fuel constituents present in groundwater
above cleanup criteria in 18 AAC 75 Table C and fuel constituents in soil above 18 AAC 75 Tables B1 and B2. Soil cleanup efforts in 2008 excavated and removed approximately 875 tons of DRO contaminated soil near the SFA and BBA. Confirmation sampling for DRO indicated that vadose zone contamination above the groundwater interface has been removed (USAF, 2009). Current monitoring requirements at SS083 include annual groundwater sampling for DRO at groundwater monitoring wells BBAWL-04 and BBAWL-05. Well BBAWL-04 was found to be destroyed during 2012, likely by a snow plow, and is no longer usable.
During 2013, a groundwater sample was collected from monitoring well BBAWL-05. Analytical laboratory sample results were below 18 AAC 75 Table C cleanup criteria.
The ADEC site status for SS083 is “Open.” DRO concentrations in groundwater samples collected from the site well BBAWL-05 have been below the 18 AAC 75 Table C cleanup criteria for three consecutive years.
Additional investigation to characterize the current nature and extent of soil and groundwater
contamination at SS083 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 |
| 3/26/2014 |
Document, Report, or Work plan Review - other |
2013 Draft Annual Report comments
SS083 Site Summary
ADEC has no comments on the annual report and will comment or have commented on the site characterization report for the site.
|
Louis Howard |
| 7/24/2014 |
Update or Other Action |
Draft SC report received for review and comment.
Small Foundation Area and Bermed Bunker Area (SFA/BBA)
The data set for the SFA/BBA on Site SS083 supports the following conclusions:
• Following previous historical excavation activities there is no longer vadose zone contamination. The NAPL-contaminated soil has smeared through the zone of seasonal water table fluctuation over an area of approximately 60 feet long and 35 feet wide.
• The average and 95% UCL DRO concentrations within the NAPL source area are 1,786 and 2,696 milligrams per kilogram (mg/kg), respectively.
• Groundwater samples collected from monitoring wells located in the NAPL contaminated soil source area and screened across the water table are below 18 AAC 75 Table C criteria.
• Additionally, the groundwater data from the current wells meet 18 AAC 70 TaqH and TAH criteria, which subsequently indicate that the site groundwater cannot cause exceedances of the surface water quality criteria.
• 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 Ecoscoping Form completed for the site does not indicate that more in-depth assessment is necessary. 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 completed for the SFA/BBA does not indicate that more in-depth assessment is necessary
Large Foundation Area (LFA)
The data set for the LFA on Site SS083 supports the following conclusions:
• Following previous historical excavation activities there is no longer vadose zone contamination. The NAPL-contaminated soil has smeared through the zone of seasonal water table fluctuation over an area of approximately 45 feet long and 50 feet wide.
• Groundwater samples collected from the monitoring well located in the NAPL contaminated soil source area and screened across the water table are below 18 AAC 75 Table C criteria.
• Additionally, the groundwater data from the current wells meet 18 AAC 70 TAqH and TAH criteria, which subsequently indicates that the site groundwater cannot cause exceedances of the surface water quality criteria.
• 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 Ecoscoping Form completed for the site does not indicate that more in-depth assessment is necessary. 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 ADEC Ecoscoping Form completed for the LFA does not indicate that more in-depth assessment is necessary.
Based on the HRC calculations and compliance with environmental criteria, it is recommended that the ADEC grant Site SS083 at JBER a “Cleanup Complete” determination. Institutional Controls do not appear to be applicable at this site. Following ADEC concurrence with this conclusion, groundwater monitoring of the site should be terminated and the existing monitoring wells at the site should be decommissioned.
|
Louis Howard |
| 8/12/2014 |
Cleanup Complete Determination Issued |
Cleanup complete determination issued.
Contaminants of Concern
Diesel Range Organics (DRO)
Cleanup Levels
The cleanup level for soils at SS083 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).
SFA/BBA
All analytical groundwater data collected after 2010 have met 18 AAC 75 Table C criteria and risk criteria. The data for downgradient monitoring well BBAWL05 show that the last DRO exceedance of 18 AAC 75 Table C criteria was in 2010 and the annual groundwater sample concentrations results have decreased every year since. The analytic groundwater results from the site wells also show that the groundwater meets 18 AAC 70 total aromatic hydrocarbon (TAH) and total aqueous hydrocarbon (TAqH) criteria. This indicates that the site groundwater cannot cause exceedances of the surface water quality criteria. The groundwater flow direction at the site is toward the Knik Arm to the northwest.
The average and 95% UCL DRO concentrations within the NAPL source area are 1,786 and 2,696 milligrams per kilogram (mg/kg), respectively. Groundwater occurs at 19 – 22 feet bgs.
LFA
The analytical groundwater results from the site wells also show that the groundwater meets
18 AAC 70 TAH and TAqH criteria. This indicates that the site groundwater cannot cause
exceedances of the surface water quality criteria. The data show that there are no exceedances of 18 AAC 75 Table C criteria. The groundwater flow direction at the site is toward the Knik Arm to the northwest.
No UCL was calculated for DRO at LFA, instead the maximum detected value was used: 7,200 mg/kg at 17-17.5’ bgs. Groundwater occurs at 16 – 19 feet bgs.
Based on the analytical data for soil and groundwater samples, modeling using the Hydrocarbon Risk Calculator (HRC), residual DRO in soil at the site does not pose a migration to groundwater concern.
Cumulative Risk Evaluation
The HRC was used to evaluate risk from petroleum contamination at SS083. 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 SS083 for the current industrial and hypothetical residential exposure scenarios, across all exposure pathways, (SFA/BBA: 1 x 10-7 and 3 x 10-7 and at LFA 5 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 SS083 for the current industrial and hypothetical residential exposure scenarios, across all exposure pathways for both SFA/BBA and LFA, (0.0 and 0.0 respectively) are below the regulatory risk standard of 1. SS083 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 SS083 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 SS083 site conditions are protective of the environment.
Based on a review of the environmental records, ADEC has determined that SS083 has been adequately characterized and has achieved the applicable requirements under the site cleanup rules. ADEC is issuing this written determination that cleanup is complete, subject to a future department determination that the cleanup is not protective of human health, safety, welfare, or of the environment [18 AAC 75.380(d)]. A “cleanup complete” designation will be entered for SS083 in the Contaminated Sites Database. |
Louis Howard |
