| Action Date |
Action |
Description |
DEC Staff |
| 9/1/1983 |
Update or Other Action |
Area "D" (Site S-7) of the Defense Property Disposal Office (DPDO) of Elmendorf AFB has been used to store partially empty 55-gallon drums. As many as 1,500 50-gallon drums have been stored per year. No known spills exist. Based on a visual inspection of the site, the area presents no potential for contamination. S-7 is right next to Site D-5 (now LF05) Landfill which was used as a disposal area for general refuse and other base generated wastes from 1951 to 1973. Trenches were excavated at this 17 acre site to a depth of 14-to-16 feet in most areas. However, on the east side of the landfill one 50-feet wide and 30-feet deep trench was excavated. Solid wastes were then disposed of in the trenches and covered daily with local soil.
In addition to scrap metal, general refuse and construction rubble, drums of spent chemicals, partially full cans of herbicides and paint cans were disposed of at this location. The majority of the site is closed with several feet of local cover, vegetation and small trees. However, one small pit is still open just west of the DPDO storage yard which contains miscellaneous rubbish, including mattresses. The majority of the site has been closed and covered with brush, small trees, and grass. However, a small area of the site to the east of the DPDO storage yard is open. |
Louis Howard |
| 11/2/1983 |
Update or Other Action |
USAF William R. Hanson, P.E. Director, Engrg. & Envmtl. Planning to DEEV (Mr. Hostman) 21 CSG/DEEV RE: Memorandum of Understanding (MOU) between DOD and EPA.
1. The attached guidance has been received from HQ USAF/LEE (atch 1). It is subject to change as time progresses. It is important to note that all actions affected by this agreement will be implemented within the overall guidance of the Installation Restoration Program.
2. All queries or requests for action received from Federal or State agencies concerning releases from former Air Force installations (MOU para 3.2) or other releases for which the Air Force is a responsible party(MOU para 3.3) will be referred to HQ AAC/DEEV for forwarding to HQ USAF/LEEV. HQ USAF will task appropriate commands and/or staff agencies for response action. Any requests received from the State of Alaska or other Federal agencies will be reported by phone to this office, autovon 552-4151. All pertinent information will be provided to assist HQ AAC/DEEV in determining the exact nature of the information requested and required for the reply. The information requested will include any information on pending legislation or other enforcement actions that may have an effect on the situation.
Letter from Gary Alkire Brigadier General USAF Deputy Director, Directorate of Engineering & Services to ALMAJCOM/DE/SG/JA.
1. The attached MOU regarding implementation of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 is provided for your information. It deals, in general, with DoD and EPA responsibilities and procedures to be followed in identifying, evaluating, and controlling releases of hazardous pollutants from currently active and former DoD facilities and third party facilities at which DoD is a responsible party.
2. This letter provides interim implementation guidance concerning the MOU.
3. All Air Force actions in response to this MOU will be conducted within the framework of the existing Installation Restoration Program.
4. Affected major commands will continue to be responsible for releases from currently active Air Force installations (MOU para 3.1).
5. All queries or requests for action received from Federal or State agencies concerning releases from former Air Force installations (MOU para 3.2) or other releases for which the Air Force is a responsible party (MOU para 3.3) will be referred to HQ USAF/LEEV. HQ USAF will task appropriate commands and/or staff agencies for response action. See site file for additional information. |
Louis Howard |
| 3/17/1986 |
Update or Other Action |
Installation Restoration Program Phase II - Confirmation/Quantification Stage 1 Final Report by Dames and Moore March 17, 1986: HISTORIC GROUND WATER PROBLEMS 1. Shallow Aquifer-Utilization of the shallow aquifer as a source of drinking water has been limited because of contamination problems. The primary threat to this coarse grained, shallow aquifer is from septic systems serving single-family dwellings, but other incidents of contamination have been reported. An infiltration gallery located at Ship Creek within the Anchorage city limits was abandoned when it became contaminated with kerosene, and leachate contamination has been reported at the Merrill Field municipal landfill south of Elmendorf AFB (Engineering-Science, 1983).
The only study to date that has found ground water contamination under Elmendorf AFB that probably originated from on-base activities is an as-yet incomplete study of the deicing drum storage area for a proposed hazardous waste storage facility. The priority pollutant 1,1-dichloroethane has contaminated ground water at that site (Donohue, 1984). A study of the abandoned base landfill near Ship Creek failed to detect contamination at that site (Engineering-Science, 1983). |
Louis Howard |
| 1/2/1988 |
Update or Other Action |
Stage 3 RI/FS - Appendix D, Raw Field Data, Pump Test Data (August - November 1988). NS-2: Conduct. (ft./day) 300, gradient: (ft./mile) 20, Distance to Receptor (feet): 5,200, Velocity (ft./day) 56.82, Travel Time (Days): 9 |
Louis Howard |
| 1/25/1988 |
Update or Other Action |
USEPA Assistant Administrator J. Winston Porter (OSWER) Memorandum for the record to Regional Administrators I-X Subj: Enforcement Actions under RCRA and CERCLA at Federal Facilities. Statutory language makes it clear that Federal facilities must comply both procedurally and substantively with RCRA and CERCLA in the same manner as any non-Federal entity. The purpose of this memo is to lay out the statutory authorities under RCRA and CERCLA that EPA may use at Federal facilities to achieve compliance and expeditious cleanup.
EPA (The Agency) is viewing the Section 120 Interagency agreement as a comprehensive document to address hazardous substance response activities at a Federal facility from the remedial investigation/ feasibility study (RI/FS) through the implementation of the remedial action. All such interagency agreements must comply with the public participation requirements of Section 117. The timetables and deadlines associated with the RI/FS and all terms and conditions associated with the remedial actions (including operable units or interim actions) are enforceable by citizens and the States through the citizen suit provisions of Section 310 of CERCLA. In addition, Section 122(1) of CERCLA authorizes the imposition of civil penalties against Federal agencies for failure to comply with interagency agreements under Section 120. Procedures for imposing these penalties are provided for in Section 109 of CERCLA.
Executive Order 12580 clarifies that EPA is authorized to issue Section 104 and Section 106 administrative orders to other Federal agencies, with the concurrence of the Department of Justice. Section 4(e) of the Executive Order provides that: Notwithstanding any other provision of this Order, the authority under Section 104(e)(5)(A) and Section 106(a) of the Act to seek information, entry, inspection, samples or response action from Executive Departments and agencies may be exercised only with the concurrence of the Attorney General.
States also have a variety of enforcement authorities under CERCLA, so the exercise of EPA's enforcement authorities should be closely coordinated with the States.
First, Section 121(e) (2) of CERCLA authorizes States to enforce ANY Federal or state standard, requirement, criteria or limitation to which the remedial action must conform under CERCLA.
Second, Section 310 authorizes citizen suits to require Federal agencies to comply with the standards, regulations, conditions, requirements, or orders which have become effective pursuant to CERCLA including IAGs under Section 120 of the Act.
Third, Section 120(a)(4) clarifies that State laws concerning removal and remedial action, including State laws regarding enforcement, are applicable at Federal facilities not included on the NP. In addition, Section 120(i) states that nothing in CERCLA Section 120 shall affect or impair the obligation of the Federal agency to comply with the requirements of RCRA, including corrective action requirements (see section IV.C., "Importance of the States as a Party to the IAG"). EPA enforcement actions against Federal agencies should therefore be carefully coordinated with States to avoid potentially duplicative or conflicting exercises of authority.
All RCRA Subtitle C permits issued after November 8, 1984, will contain provisions for implementing the corrective action requirements of 40 CFR Part 264 Subpart F (or authorized state requirements), and Section 3004(u) and (v) of RCRA. For facilities that have or are seeking a RCRA permit, the requirements for a "CERCLA" remedial investigation and cleanup could be met by implementing these requirements through RCRA corrective action. It is important to keep in mind, however, that the extent of coverage of the RCRA permit is generally limited to hazardous wastes/constituents (e.g., some CERCLA hazardous substances such as radionuclides are not RCRA hazardous constituents and, therefore, the permit may not be able to address all of the releases at a facility).
The corrective action authority under Section 3008(h) of RCRA can be used at RCRA interim status facilities to address releases from RCRA regulated units and other solid waste management units. At a Federal facility that has interim status, a RCRA corrective action order could address the investigation and clean-up of releases in. lieu of a "CERCLA" response action or as an interim measure. Again, the extent of coverage in the RCRA corrective action order is limited to RCRA hazardous wastes/constituents.)
CERCLA Section 106 can be used to address releases from RCRA units or CERCLA sites when an "imminent and substantial endangerment" is shown. A Section 120 IAG could be drafted to incorporate all RCRA corrective action requirements and CERCLA statutory requirements. Where some or all of a Federal installation has been listed on the NPL, the CERCLA Section 120 IAG is required for remedial action by statute. |
Louis Howard |
| 3/1/1988 |
Update or Other Action |
IRP RI/FS Stage 3 Work Plan (HLA March 1988) Site NS-2, DRMO Scrap Pile Site NS-2 was not investigated in the IRP Phase I and II. A reconnaissance of the site was conducted by HLA on 15 September 1987 as part of the Integrated RI/FS site visit. Bruce Erickson of ADEC indicated 5 that drums of various kinds are stored in this area, and some surface - staining of the soil has resulted. The extent of possible contamination and the pathways affected if contamination has occurred are unknown at this time. Sites NS-2 and D-13 (aka LF13) are in close proximity; the wells complement each other and also the data from D-7 (LF07?) and D-5 (LF05).
Site D-13 Disposal Site Site D-13 (Plate 5-3), located east of Davis Highway and south of Marketing and Redistribution Storage (aka DRMO), is an old gravel pit used as a disposal site to dispose of empty drums, metal piping, drums full of asphalt, and small quantities of quicklime from base renovation operations (Engineering-Science, 1983). This site was not investigated in IRP Phase II. HLA's objective in IRP Integrated RI/FS is to establish: (1) the true location of site D-13 and (2) whether or not soils and/or groundwater contamination are present as a result of past landfilling activities. The recommended field tasks for Integrated RI/FS field investigation are listed below. These field tasks have been coordinated with those recommended for Site NS-2 (DRMO Scrap Pile) since the two sites are adjacent. Data collected at this site will also aid in interpreting the potential impacts from Sites D-5 and D-7.
Site NS-2, DRMO Scrap Pile Site NS-2 (Plate 5-3) was not investigated in Phases I or II of the Elmendorf IRP. During our brief field reconnaissance, we observed that drums of various kinds have been disposed of in the scrap pile. Some surface staining of the soil around the margins of the scrap pile has resulted. HLA's objective in IRP Integrated RI/FS is to determine whether past disposal practices have resulted in contamination of the soils and/or groundwater at the site. The field tasks recommended for Integrated RI/FS are identified below. Borings/Monitoring Well Installations Two soil borings will be drilled and sampled at Site NS-2 at the locations shown on Plate 5-3. These locations were selected based on the results of Stage 1 and 2 work at Sites D-5 and D-7 (Plate 5-2) and will augment data obtained from the monitoring wells to be installed at Site D-13 (Plate 5-4). The borings will be drilled and sampled to a depth of about 60 feet.
Samples will be taken at the surface and at five-foot intervals thereafter. Two monitoring wells will be installed in the borings. These wells are necessary to establish the chemical characteristics at both the up and downgradient locations at the site and will aid in the calculation of groundwater flow direction at this site and at Site D-13. Field Permeability Test One field permeability test will be conducted to provide a site-specific estimate of transmissivity of the the shallow aquifer. Groundwater Sampling/Chemical Analysis Each of the monitoring wells will be sampled to determine the chemical characteristics of the groundwater at the site.
Analytical parameters for these samples are: alkalinity-carbonate, specific conductance, pH, total dissolved solids, temperature, common anions, petroleum hydrocarbon, metals screen, arsenic, lead, mercury, selenium, purgeable halocarbon, nonhalogenated volatile organics, purgeable aromatics, and extractable priority pollutants. Chemical Analysis of Soils Four of the soil samples collected during the soil boring investigation will be analyzed for: petroleum hydrocarbon, metals screen, mercury, organochlorine pesticides and PCBs, volatile organic compounds, semivolatile organic compounds, cyanide, and soil moisture content. |
Louis Howard |
| 8/1/1988 |
Update or Other Action |
Resource Conservation and Recovery Act (RCRA) Facility Assessment Report: Preliminary Review and Visual Site Inspection conducted by ADEC during July 19 and 20, 1988. Interviews with Base representativs. Mr. Sam Swearingen, Environmental Protection Specialist was interviewed for Defense Reutilzation and Marketing Office (DRMO) formerly Defense Property Disposal Office (DPDO). Site NS-2, DPDO Scrap Pile: Location: This site is located east of Davis Highway (now called Vandenberg Avenue). Operation: Reports indicated that drums of various kinds are stored in this area, and some surface staining of the soil has resulted. Contamination Potential: A low potential exists for environmental contamination from this site, further study is not warranted at this time. Recommended Action: Further action is not required due to nature of materials stored at this site.
Also see: D-ll, Small Arms Ammo Disposal Site a. Location: This site, less than one acre in size, is located in a remote area, on the explosive materials disposal range. Also located on this site is a device which EAFB terms a "burn kettle". See photographs #18, #19, #20, #21 of Attachment 2.
b. Operation: The materials either detonated or disposed of in the burn kettle include the following: bulk explosives, signal devices/pyrotechnics, bombs, grenades, dynamite and small ammunition arms, which EAFB stated that was either expired shelf life components, unstable or materials which were in some way defective and required disposal for safety reasons. EAFB stated that their net explosive range was 250 pounds of waste explosives or propellants per each detonation. The metals left over are turned over as salvage. Various areas of the site are used as detonation pits. It was stated by EAFB that most of the materials are destroyed because of the danger of the materials and only a small amount of the total material destroyed is used for training of specific employees. The burn kettle is an enclosed device which destructs small arms, approximately 400 rounds of ammunition per kettle.
Diesel fuel oil is used as the burn inhibitor, which is added to the actual burn kettle through a pipe. The material is allowed to burn, then cooled for 24 hours. The materials are shoveled out, stored in metal containers, and later sent on to the Defense Property Disposal Office (DPDO) as scrap metal for disposal. c. Contamination Potential: Since this area is restricted, and it is believed that ordnance remaining on the ground would be immobile and inert, no potential should exist for contamination. |
Louis Howard |
| 8/2/1988 |
Update or Other Action |
Operable Units' source areas that correspond to RCRA SWMUs from the RCRA RFA. SS22 S-7 DRMO Storage Area - South of Davis Highway. Also known as Area "D", is the future storage site. |
Louis Howard |
| 9/25/1989 |
Update or Other Action |
ADEC Ron Klein, Supervisor, Contaminated Site Investigations, sent letter to Captain Brad Gerken, Dept. of Air Force, 5099th Civil Engineering Operations Squadron (AAC) Subject: Response to September 27, 1989 Letter; Requirements for Temporary Storage of Petroleum Contaminated Soil. Enclosed is a copy of the Southcentral Region Office's interim policy for storage and disposal of waste oil contaminated soil.
The guidance also applies to storage of soils contaminated with clean fuels if they are to be stored off the site where they were generated or stored on-site longer than thirty (30) days. The guidance document will be revised shortly to make that explicit. Petroleum contaminated soils generated on-site and stockpiled onsite for less than thirty (30) days must be placed on a bermed liner and covered. The liner and cover must be at least 6 mil reinforced polyethylene. Alaska Department of Environmetal Conservation Southcentral Region Office - Interim Policy For Storage and Disposal of Waste Oil Contaminated Soil The Southcentral Regional Office solid waste program has been working on an interim policy for storage and disposal of waste oil contaminated soil. Currently the Region has approved the removal of waste oil contaminated soil to a facility permitted to properly handle the contamination. With the exception of the Municipality of Anchorage (MOA) Landfill and Alaska Pollution Control Palmer Facility (pre-treatment for landfill disposal) all of these facilities are located in the contiguous United States. Currently, if the waste oil contaminated soil does not meet MOA Landfill criteria the only disposal option is to send the contaminated soil out of Alaska. Soil disposal under this method is costly due to handling, shipping, and facility fees. In discussions with Responsible Parties (RP) there appears to be a strong move to develop other local disposal methods that would meet with agency approval. Therefore the Regional solid waste program has developed interim storage guidelines for waste oil contaminated soils.
These guidelines include the following: 1. An approved design for a low-maintenance or maintenance free storage liner and cover that will be able to withstand winter conditions and is petroleum resistant. This will include a schedule to monitor the storage facility to verify that the integrity of the liner and cover is maintained through out the storage period.
2. Obtain a solid waste storage plan approval for onsite storage of waste oil contaminated soil from ADEC prior to storage construction. 3. The Responsible Party may propose to remove the waste oil contaminated soil to an off-site storage location if long term on-site storage is not practical. This location must be approved of by the Department prior to any transfer of the soils. The storage site must meet, ADEC design criteria and the RP must obtain an off-site; solid waste storage plan approval prior to transfer of the soil. All transfer of soil off-site must be done under a Bill of Lading and copies provided to ADEC. 4. The maximum allowable storage time is one (1) year. |
Louis Howard |
| 11/2/1989 |
Update or Other Action |
ADEC letter to USAF Subj: EAFB Petroleum Contaminated Soil. Thank you for your 17 October, 1989 response to my September 1989 letter. The following are answers to the questions detailed in your letter:
1. What State of Alaska regulations cover the treatment of soil contaminated with petroleum product? The State has no detailed regulations on petroleum contaminated soil treatment. According to the oil pollution regulations (18 AAC 75.140, Cleanup), Immediately upon becoming aware of a discharge of a hazardous substance to the water or land of the state, persons responsible for that discharge shall clean up and dispose of the material collected using methods for which prior approval, oral or written, has been given by the regional supervisor or his designee. Under this section the Department reviews soil treatment plans to insure that the treatment method proposed is effective and will not result in the contamination of other sites. Petroleum contaminated soil is also classified a solid waste under State solid waste management regulations. See 18 AAC 60.910 (53) for the definition of solid waste. According to the solid waste regulations a permit is required for solid waste facilities. The solid waste regulations also provide guidance in 18 AAC 60.075 for landspreading operations. Depending upon the petroleum contaminated soil treatment method selected other regulations may apply such as our Air Quality Control (18 AAC 50) and Wastewater Disposal (18 AAC 72) regulations.
2. What are the State of Alaska cleanup standards for soil contaminated with petroleum products? According to 18 AAC 75.130 (Disposal of Hazardous Substances) prior approval by the Department is required for the ultimate disposal of a hazardous substance, and soil, cleanup materials, or other substances contaminated with a hazardous substance. Chapter 75 classifies oil as a hazardous substance (see 18 AAC 75.900 (05)). Ultimate cleanup levels depend upon what the proposed disposal alternative is. At a minimum soil needs to be cleaned up to a level which will not pose a risk to the lands and waters of the disposal site. The beneficial use of petroleum contaminated soils is encouraged. For example, processing petroleum contaminated soil through a hot mix asphalt plant for use as non-spec asphalt base. |
Ron Klein |
| 12/29/1989 |
Document, Report, or Work plan Review - other |
RI/FS Stage 4 2nd draft WP October 1989 comments provided by ADEC. For several sites the disposal method for soil contaminated with high levels of TPH is quoted as "the sanitary landfill". The only area landfill that is permitted to receive petroleum contaminated soil is the MOA Landfill. The MOA will accept soils only if the TPH level is below 1000 mg/kg. In many cases the WP was referring to soils with TPH in excess of 1000 mg/kg. The issue of proper contaminated soil disposal has been brought up by ADEC several times (reference letters: Klein to Gerken, October 20, 1989 & Klein to Mabry, November 2, 1989).
ADEC requests clarification on the disposal method of soils contaminated with TPH levels over 1000 mg/kg & verification the proposed sanitary landfill is the MOA Landfill. In addition, ADEC requests written notification regarding disposal of all contaminated soils. The notification should include: date of disposal, quantity of soil, location that soil originated, & final disposal method.
ADEC requests that an expanded seasonal sampling schedule be established for selected MWs. In several sites (for example, W-18 on site IS-1) there may be floating product. ADEC is concerned that accurate data is not being collected based on a once a year sampling schedule. Seasonal water table fluctuations can easily dilute or mask the true level of the contaminant. Determinations on site status & remedial actions are being based on incomplete information. In all the proposed borings/MW the WP calls for 2 soil samples per boring to be taken to determine the extent of vertical contamination. The exact depth of the sample is to be based on field screening results. Field screening techniques to determine the presences of TPH contamination is not reliable & it is not uncommon to miss contaminated zones using field screening in lieu of analytical lab analysis.
Also much of the contamination is from old fuel spills which may now be low in benzene & again would be very difficult to read on any field meter calibrated to benzene. ADEC requests that additional soil samples be taken in soil borings/MW & recommends that sampling be done on 5’ or 10’ intervals depending on the total depth of the boring.
Paragraph 2.2.1.2 & many other sections reference HNu readings of less than 1 ppm. Key data such as span setting, ambient HNu reading, & calibration gas used, need to be stated to interpret HNu data. Ambient levels of greater than 1 ppm at span 9.8 calibrated to benzene are common. Relying solely on HNu field screening may allow contaminated zones to be missed. ADEC requests that additional soil samples be taken in soil borings/monitoring wells.
In many sites 2 deep borings/monitoring wells are proposed. The decision to drill the 2nd boring would be based on the results of the 1st deep boring. ADEC is concerned that using only 2 soil samples per boring to determine if contamination is present will allow layers of contamination to be missed. ADEC requests that additional soil samples be taken to determine the vertical location of contamination & that this additional sampling be used to determine the depth of the second deep boring & the other shallow borings.
See site file for additional information.
|
Ron Klein |
| 1/18/1990 |
Update or Other Action |
Management of Radioactive Waste Burial Sites Under the Installation Restoration Program from HQ USAF/SG/DE letter is provided to 11 TCW/LGM 21 CSG/DEEV, 343 CSG/DEEV & 5099 CEOS/DEEP. This letter provides interim guidance on handling low-level burial sites. 1. The USAF Radioisotope Committee has identified potential problems with current Installation Restoration Program (IRP) guidance for radioactive material burial sites. Additional management considerations & coordination requirements for these sites are imposed by:
a. The lack of Environmental Protection Agency (EPA) standards for residual radioactivity in soils.
b. The probable presence of Nuclear Regulatory Commission (NRC) regulated materials & devices in many sites.
c. Current & projected costs, requirements, & limitations associated with disposal of radioactive wastes at commercial low-level burial sites.
2. In cooperation with the Environmental Division (HQ USAF/LEEV) we have agreed on a plan for additional information for Air Force IRP Management Guidance (White Book). The current target date for completion is 31 December 1989.
3. Use the attached guidance until the White Book is distributed. In general, our intent is to support site characterizations & removals to a licensed radioactive waste burial facility, when conducted according to regulatory agency requirements.
Interim Guidance for Radioactive Waste Burial Site Characterization or Exhumation 1. Maintain identified burial sites in accordance with HQ AFOMS/SGPR ALMAJCOM/SG/DE letter, Maintenance Requirements for Radioactive Burial Sites on Air Force Installations, dated 9 Aug 88. 2. Prior to any decision to proceed to any invasive method of site characterization or site exhumation, research all locatable records possibly having information concerning past base activities involving radioactive materials & use of the burial site. 3. Ensure site characterizations using intrusive methods or site exhumations are undertaken, except only by a qualified (NRC or Agreement state licensed) organization, which is equipped to properly respond to a release of material & is operating under an NRC approved characterization & exhumation plan.
Based on our information on known burial sites & past burial practices, invasive characterization should be undertaken only if there is an intent to exhume the site. Site penetration for characterization has a high probability of breaching containment & generating radioactive wastes that will require control & disposal. It may also result in damage to containment & release of materials requiring prompt total exhumation. Since the NRC views exhumations of NRC-regulated materials as a licensable activity, invasive characterizations or exhumations of sites containing (or which may contain) NRC-regulated materials, must be made only by a licensed contractor operating under an NRC approved exhumation plan.
See site file for additional information. |
Louis Howard |
| 4/16/1990 |
Meeting or Teleconference Held |
USEPA Memorandum Subject: Elmendorf AFB Deliverables and Operable Units (OU) from Doug Johnson Environmental Scientist, AOO/A to George Hofer Chief Federal Facility Branch HW-074. The following is a synopsis of two meetings that were held with staff members of ADEC and EPA. The first meeting was held on April 6, 1990 and the second was held on April 12, 1990. Attendees for the meetings from ADEC were Ron Klein, Max Schwenne, Colleen Burgh, Jennifer Roberts with Mary Siroki and Geoff Kany attending the first meeting. The following reflects the input from ADEC regarding the document deliverables, determination of operable units, and schedules for inclusion to the Elmendorf AFB Interagency Agreement. This information was discussed with Bob Loiselle during your absence.
Document Deliverables: It was determined by mutual agreement that the same document deliverables now proposed for the Eielson IAG be incorporated into the Elmendorf IAG without change. ADEC agrees that for consistency and simplicity reasons the document deliverables for all Alaska IAG's remain the same. Operable Units: Operable unit determination was based upon a hierarchy which was derived by either geographic or site characteristic similarities.
The listed order was determined by severity of contamination (worst first) based upon common knowledge of the meeting participants. Operable Unit #1 (Million Gallon Hill Area)-Sites SP-5/5A, OT-1, D-15, D-16, D-17, NS-2. Operable Unit #2 (Air Force High Priority Sites-Sites S-5, D-4, D-10, FT-1 Operable Unit #3 (Landfills)-Sites D-5, D-6, D-7, D-8, D-9, D-11, D-12, D-13, NS-2 Operable Unit #4 (Hangar Floor Drains)-Sites IS-1, IS-2, IS-3, IS-4, IS-5, IS-6, IS-7, IS-8 Operable Unit #5 (Fuel Spill Sites)-Sites SP-1 thru SP-16, NS-3 Operable Unit #6 (UST/LUST Sites)-Approx. 35 known UST/LUST sites scattered around facility. Operable Unit #7 (Misc. Sites)-Sites D-1, D-2, D-3, RD-1, S-l, S-3, S-4, S-6, S-7 [NOTE TO FILE: new IRP# for S-7 is SS22 DRMO Storage Area - South of Davis Highway also known as Area "D", is the future storage site]
Please note that of these operable units, the first three are probable definites for inclusion to the IAG. The last four have been included at this stage for discussion purposes and for understanding the perceived universe of sites at Elmendorf AFB. Further refinement of this list and determination of schedules to be discussed on May 2, 1990 with ADEC. I will continue to discuss this subject with Bob as it develops, and would welcome any input you might have. |
Louis Howard |
| 5/1/1990 |
Update or Other Action |
Stage 3 RI/FS D-5 Landfill combined with Sites D-7, D-13, and NS-2 and assigned high priority for further investigation. NS-2 DRMO Scrap Pile: Contaminants Detected: Vinyl chloride, and trans-1,2-dichloroethene were detected. Vinyl chloride exceeded cleanup levels. Metals did not exceed background concentrations. Recommended Action & Rationale: See Site D-5 Site NS-2 DRMO Scrap Pile The Defense Reutilization and Marketing Office (DRMO) scrap pile is designated as Site NS-2.
Various drums are stored in the vicinity of NS-2. Prioritization of Sites for Remedial Alternatives Contamination in groundwater samples from Site D-5 were above groundwater cleanup levels as discussed in Section 4.1. In addition, Site D-5 is close to several other sites (Sites D-13, D-7, and NS-2) where contamination was detected in the groundwater. It is recommended that Sites D-5, D-7, D-13, and NS-2 be combined due to their proximity and the similarity of the contaminants found at these sites. This new site would be assigned a high-priority for remedial alternatives due to contaminant levels exceeding State of Alaska water quality regulations and the evidence of offsite migration. Results for Site NS-2, DRMO Scrap Pile, in Section 4.2.21.4.
Site D-7 is assigned a high-priority site for remedial alternatives due to the exceeding of State of Alaska water quality regulations, and the evidence of offsite migration. It is recommended that sites D-5, D-7, D-13 and NS-2 be combined due to their proximity and the similarity of the contaminants found at these sites. Site D-13 is assigned a high priority for futher investigation due to the evidence of offsite migration and the sites probable relationship with Sites D-5, D-7 and NS-2. It is recommended that Sites D-5, D-7, D-13 and NS-2 be combined due to their proximity and the similarity of the contaminants found at these sites. Drums containing various kinds of materials are stored in the vicinity of Site NS-2 (Figure 4.2.21.1) and some surface staining of the soil has resulted. Site NS-2 is underlain by sands and gravels with a water table depth of approximately 38 feet. The direction of groundwater flow is based on a comparison of regional trends and waterlevel measurements at 13 wells in the area (Figure 4.2.21.3).
The direction of groundwater flow is west-northwest with a gradient of approximately 20 feet per mile. These sites are located less than 0.5 mile downgradient from Ship Creek, which loses water to the groundwater system in this area. Hydraulic conductivity values have not been established for this site. HNu readings of 5 ppm was recorded on a soil samples of 15 and 20 feet, respectively from NS2-02. Chlorinated hydrocarbon compounds were detected at Site NS-2. However, the concentrations were generally low and isolated to 2 compounds. For example, vinyl chloride (2.2 ug/L) and trans-1,2- dichloroethene (4.7 ug/L) were detected in water samples from well NS2-01. Analytical results for water samples from Site NS-2 indicated contamination by various organic compounds. The source of the organic contamination in the groundwater is most likely shop wastes, buried drums containing unknown wastes, and steel and metal alloy debris buried in the landfills at Site D-13 and Site D-5.
Basic receptors are humans, wildlife, and plants. Pathways of exposure to the receptors include ingestion of groundwater by humans and wildlife. Due to the depth of groundwater at the site (about 40 feet), uptake of contamination by plants is probably only important to species recolonizing the disturbed areas. The data density at the site allows for some generalization of the zones of contamination. Well W-1 at Site D-5, sampled as part of the investigation for Site D-5 (Section 4.2.2.3) is the most upgradient well in the area of Site NS-2. The next well along the gradient, well NS2-01, was contaminated above the State of Alaska Primary Standard for vinyl chloride (2 ug/L). Due to the lack of clear definition of site boundaries, it is not readily apparent if wells NS2-01 and NS2-02 are outside of or within the landfills at Site D-13 and Site D-5.
The potential for offsite and off-Base migration at Site NS-2 is unknown. Historical records suggest that well NS2-02 may be outside and downgradient of the landfill boundary. However, surface trash and rubble was observed to the immediate west of well NS2-02, suggesting that the well is located on the fringes of the landfill. Well NS2-01 is most likely within the landfill boundaries and was contaminated with vinyl chloride above its MCL.
See site file for additional information. |
Louis Howard |
| 8/30/1990 |
Update or Other Action |
NPL Listing History: Proposed Date: 7/14/1989 Final Date: 8/30/1990 EPA ID: AK8570028649 SEC. 120 [42 U.S.C. 9620] Federal Facilities [§120 added by PL 99-499] (e) Required Action by Department. --
(1) RI/FS. -- Not later than 6 months after the inclusion of any facility on the National Priorities List, the department, agency, or instrumentality which owns or operates such facility shall, in consultation with the Administrator and appropriate State authorities, commence a remedial investigation and feasibility study for such facility. In the case of any facility which is listed on such list before the date of the enactment of this section, the department, agency, or instrumentality which owns or operates such facility shall, in consultation with the Administrator and appropriate State authorities, commence such an investigation and study for such facility within one year after such date of enactment. The Administrator and appropriate State authorities shall publish a timetable and deadlines for expeditious completion of such investigation and study.
(2) Commencement of Remedial Action; Interagency Agreement. -- The Administrator shall review the results of each investigation and study conducted as provided in paragraph
(1). Within 180 days thereafter, the head of the department, agency, or instrumentality concerned shall enter into an interagency agreement with the Administrator for the expeditious completion by such department, agency, or instrumentality of all necessary remedial action at such facility. Substantial continuous physical onsite remedial action shall be commenced at each facility not later than 15 months after completion of the investigation and study. All such interagency agreements, including review of alternative remedial action plans and selection of remedial action, shall comply with the public participation requirements of section 117.
(3) Completion of Remedial Actions. --Remedial actions at facilities subject to interagency agreements under this section shall be completed as expeditiously as practicable. Each agency shall include in its annual budget submissions to the Congress a review of alternative agency funding which could be used to provide for the costs of remedial action. The budget submission shall also include a statement of the hazard posed by the facility to human health, welfare, and the environment and identify the specific consequences of failure to begin and complete remedial action. |
Louis Howard |
| 10/31/1990 |
Update or Other Action |
Richard L. Howard DERA Program Manager - Memo for the record: SUBJECT: Closeout of 13 IRP sites. 1. During discussions with the DEC and EPA on 30 October 1990, regarding the Elmendorf AFB IRP program, the determination was made that 13 of our previously reported areas are eligible to be closed out at this time. A listing of the sites and a rationale for their closing are as follows. 2. Sites SS-22 (S-7 is the DRMO Storage Area - South of Davis Highway - also known as Area "D", is the future storage site) and SS-33 (S-4 also known as bldg. 64-580 - now bldg. 33855) will be regulated by provisions of our EPA Part "B" permit.
Upon completion of initial base studies, Sites: LF-011, LF-02 (D-2), LF-06, LF-08 (D-8), LF-09 (D-9), OT-11 (D-11) , LF-12 (D-12), RW-17 (RD-1), SS-18 (S-1), and SS-19 (S-3) were determined to pose no threat to the environment or human health. This determination was also made by ADEC during its Federal Facilities RCRA Inspection. Also, site SS-59 (6 Mile Archery Club Spill- closure under 18 AAC 75) has been remediated by completion of a removal action. 3. The necessary documentation will be coordinated with EPA and DEC prior to final closeout of any of these sites. |
Louis Howard |
| 6/18/1991 |
Update or Other Action |
Source LF05, unfortunately none of them seem to be downgradient & outside of the source (inspection of B&V maps, May 1990). W-1 shows some signs of indicator parameter contamination: higher than background conductivity & alkalinity. As the first GW samples were unfiltered, the reported total recoverable metals levels of aluminum (0.13 to 199 mg/l), iron (8.3 to 400 mg/l), & manganese (0.85 to 112 mg/l) may be artificial. There is some concern expressed in the B&V report (May 1990) that there may have been cross contamination of samples in the field or laboratory. Use of PVC well screens & casing (riser pipe) might explain the presence of the bis(2-ethylhexyl) phthalate in the GW samples. Other volatile organic compounds tend to be low in concentration.
Source LF07 GW flow to the northwest. There are 4 monitoring wells (GW-2C, GW-2B, W-6 & GW-1B) directly downgradient, & one well somewhat downgradient (GW-1C). Monitoring well W-5 appears to be an upgradient well. GW-1B, GW-2B, & GW-2C show signs of indicator parameter contamination: higher than background conductivity & alkalinity. This is often taken as an indication of presence within or near a landfill contamination plume. What has been said above for Source LF05 with regard to metals, including lead, in GW also applies to Source LF07.There are still questions regarding the filtering procedure expressed in the discussion of Source LF05, above. The resampled iron (26 & 4.2 mg/I) & manganese (8.7 & 7.6), if truly representative for monitoring wells GW-2B & GW-2C, respectively, may represent a chemical front formed by dissolution of metals in the landfilled material.
The VOCs detected in downgradient monitoring wells GW-1B & GW-2B would seem to be representative of GW derived from a landfill containing shop waste (solvents) & residue remaining in buried drums. Definition of the extent of this plume in a downgradient direction has not been completed. SOURCE LF13 GW flow to the northwest. There are three monitoring wells (D13-03, D13-02, & NS2-02) directly down gradient. D13-01 appears to be an upgradient well. D13-02 & D13-03 do not show signs of indicator parameter contamination: higher than background conductivity & alkalinity. This is opposite to what is observed at Sources LF05 & LF07. The reported values result from the dissolution of particulate soil or rock material by the nitric acid used in sample preservation. Filtered sample results were much lower, although there are still questions regarding the filtering procedure expressed in the discussion of Source LF05, above. The resampled iron (2.6 & 0.33 mg/l) & manganese (1.3 & 0.0527 mg/) for monitoring wells G13-01 & G13-03, respectively, may be representative of natural levels of these metals. The resampled iron (4.5 mg/) & manganese (7.4 mg/l) for G13-02 may represent a chemical front formed by dissolution of metals in the landfilled material.
SOURCE OT56 GW flow is to the northwest. There are two monitoring wells at the source, NS2-01 & NS2-02, neither of which is truly downgradient or upgradient, but off to the side. Well NS2-01 seems to be monitoring Source LF05, & Well NS2-02 seems to be monitoring Source LF13. The conductivity & alkalinity values reported for wells NS2-01 & NS2-02 are not as high as observed for Sources LF07 & LF13, but may still be indicative of a contaminant plume. However, this plume may not be from Source OT56 but from the other two sources mentioned previously. Again, the reported metals values for the soils are of a level to be expected, considering the source rocks from which they were derived. The unfiltered metals samples in GW produced artificial dissolved metals concentrations, which need not be addressed. The high filtered values for iron (8.2 & 13 mg/l) & manganese (5.7 & 2.3 mg/l) in GW from wells NS2-01 & NS2-02, respectively, may represent a chemical front moving from sources LF05 & LF13. The low levels of VOCs are probably & extension of the plumes from sources LF05 & LF13. |
Louis Howard |
| 7/24/1991 |
Document, Report, or Work plan Review - other |
This technical memorandum is based on the preliminary review of previous reports prepared for Elmendorf Air Force Base (EAFB). The accuracy of the data presented in these reports was not validated. CH2M HILL has reviewed the available information and has complied a brief description of the source history followed by a list of deficiencies, inconsistencies, data gaps, and recommendations. The above described information for Source OT56 is as follows: SOURCE HISTORY This source has drums containing various types of materials stored at the source, and some surface staining of the soil has resulted. The source is north of Source LF13 (D-13), east of Source LF05 (D-5), and north of Source LF07 (D-7). This source was not addressed until Phase III, Stage 3. Two borings drilled at Source OT56 were completed as monitoring wells (NS2-01 and NS2-02).
Groundwater samples were analyzed for sulfate, VOCs, VOHs, ICP metals, other metals, TPH, and extractable priority pollutants. Soil samples were analyzed for TPH, ICP metals, mercury, VOCs, semi-volatile organic compounds, and soil moisture. Analytical results indicated chlorinated hydrocarbons. During Phase III, Stage 4, it was recommended to combine Source OT56 with Sources LF05, LF07, and LF13. This new source would be assigned a high priority for remedial alternatives.
DATA GAPS/DEFICIENCIES - No hydraulic conductivity data are available. - Sanitary fill (abandoned), shown on Plate 5-3 HLA, is assumed to be Source D-7. - Due to the lack of a clear definition of source boundaries, it is not apparent if wells NS2-01 and NS2-02 are outside or within Sources D-13 and D-5 landfills. - A pattern of contaminant migration in the groundwater is not clearly evident. - The scope of previous studies did not estimate the volume and quantities of materials at the source. -The volumes of source material is important in determining the appropriate remedial action needed. - Water table elevation is based on two wells and not four or five other wells installed in immediate vicinity. - The potential for off-source and off-site contaminant migration is unknown. Noncontaminated upgradient and downgradient wells do not exist. * Temporal and seasonal changes in groundwater direction have not been delineated which may be crucial to the rate and direction of contaminant movement. * Groundwater flow data is incomplete. The potential effects of tides and recharge from Ship Creek need to be investigated. * Vertical and horizontal extent of the plume, flow rate and direction have not been determined. Without this information, the cost effective selection of alternatives and proper methods of remediation cannot be effectively evaluated. * Geophysical investigations to define the boundaries and explore for buried metallic wastes/containers have not provided adequate results.
RECOMMENDATIONS Additional source investigations are necessary in order to properly characterize the extent of the contamination. Characterization of the source is needed so that the most cost effective remediation alternative is selected and that sufficient data are available during the remedial design stage. Additional tasks would be to: - Include investigation of base supply well 42 (BW-1 and BW-52). - Suspend operations at gravel pit less than 500 feet north. - Define the horizontal and vertical extent of the plume by monitoring well installation and sampling. Cluster wells with 2 to 3 screened intervals will be required at some locations. At least 2 to 3 downgradient and 1 upgradient location will be required to define the plume and groundwater flow. - Combine further investigation with Sources D-5, D-7, D-13. - Investigate boundary of landfill(s) with tentative use of geophysical equipment. - Source conditions could limit results. Coordinate with Sources D-7 and D-13. - Additional investigation at this source indicate the potential for groundwater extraction and/or source control. - Conduct slug test, specific capacity tests and/or pumping tests to evaluate hydraulic properties of the aquifer and landfill. - Analyze soils to confirm that soils will not be a contaminant source. - Coordinate analytical parameters with other sources combined. Halogenated organics, aromatics, metals and inorganics are the most common and frequently detected constituents of landfills. Additional analysis may be considered if additional information requires inclusion. - Downgradient monitoring of the sources will be required on a long-term basis. Results of further investigation will indicate if source removal, source control/isolation, and/or groundwater extraction will be applicable. |
Louis Howard |
| 7/24/1991 |
Update or Other Action |
Technical Memorandum for EAFB By CH2MHILL (M. Micheau). SUBJECT: Source SS22 (S-7), DRMO (DPDO) Storage Area PROJECT: ANC31026.D6.10 This technical memorandum is based on the preliminary review of previous reports prepared for Elmendorf Air Force Base (EAFB). The accuracy of the data presented in this TM was not validated. CH2M HILL has reviewed the available information and has compiled a brief description of the source history followed by a list of deficiencies, inconsistencies, data gaps, and appropriate recommendations. The following information applies to Source SD30 Building 21-900 floor drains.
SOURCE HISTORY This source has been used to store empty 55-gallon used oil drums. In addition, scrap metal has been stored at the source prior to resale/recycling. In 1988, a storage building was constructed at this location. No spills or releases have been reported from this source. No soil or water samples have been collected from this source. Previous investigations included: Phase l/1, Records Search and Statement of Work by Engineering Science, 1983; Phase II, Stages 1 and 2, Dames & Moore, 1986/1987; Phase II, RI, JMM/Harza Environmental, Sept. 1988; Phase II, Stage 3, Harding Lawson Associates, Jan. 1988; Phase III, Stages 3 and 4, Black & Veatch, May 1990.
DATA GAPS/DEFICIENCIES * Insufficient information available to evaluate the potential for contamination at this source. * Classification of material stored at the source area unclear, i.e., whether any of the drums stored at this source contained hazardous wastes (i.e., spent solvents or solvent/oil mixtures). * No groundwater or soil samples have been collected or analyzed at this source. * There has been no indication that the source has been inspected to assess if releases or spills have occurred.
RECOMMENDATIONS * Further investigations should be conducted at this source to verify the materials stored at the source. * Preliminary soil gas survey and groundwater surveys should be conducted to identify contamination sources (if present). * Pending the results of the preliminary investigation, recommendations for further action or no further action will be provided. |
Louis Howard |
| 8/6/1991 |
Enforcement Agreement or Order |
USEPA Federal Facility Compliance Agreement RCRA Docket No. 1090-01-27-6001. The Air Force recognizes its obligations to comply with RCRA, as set forth in Section 6001 of RCRA. For purposes of this Agreement, the Air Force: consents to the issuance of this Agreement; admits EPA's jurisdiction; agrees not to contest EPA's authority to enter into this Agreement; agrees to comply with all requirements of this Agreement; and agrees that the terms of the Agreement shall be binding upon the Air Force, and its employees, tenants, assigns, successors and upon contractors, consultants and agents. On or before August 15, 1991, Elmendorf shall comply with the following:
Elmendorf AFB shall submit a revised and complete Part B permit application for the Facility including the Explosive Ordnance Disposal Area, the burn kettle, Building 22-009, and the DRMO-Anchorage Storage Building. The revised Part B permit application shall address all deficiencies described in the July 13, 1990 Notice of Deficiency issued jointly by Alaska DEC and EPA. Elmendorf AFB shall submit each portion of the revised Part B permit application in Draft during development of the complete Part B permit application. |
Louis Howard |
| 10/1/1991 |
Update or Other Action |
IRP Site Summary SOURCE SUMMARY SOURCE OT56 (NS-2), DRMO STORAGE AREA HARM SCORE: NOT RATED
SOURCE HISTORY Drums containing various types of materials are stored at Source OT56, and some surface staining of the soil has resulted. The source is north of Source LF13 (D-13), east of Source LF05 (D-5), and north of Source LF07 (D-7). -Located at elevation 210 feet on flat terrain. -Underlain by coarse sands and gravels with some silt. -Silty and clayey units of the Bootlegger Cove formation at a depth exceeding 60 feet. -Moderately dense cover of cottonwood trees to height of 25 feet. Ground surface has an appearance of regrading. -Water table depth approximately 30 to 40 feet below land surface. -Groundwater data based on 13 wells in the area; flow direction reported to be west-northwest at approximately 0.004 ft/ft. -Wells W-2, D13-02, D13-03, GW-1C, and GW-1B have been destroyed. SOURCE INVESTIGATIONS Phase I. Record Search (Engineering Science [ESi. Sept. 1983) Source NS-2 was not included in this phase. Phase II. Statement of Work (ES, Sept. 1983) Source NS-2 was not included in this phase. Phase II. Stage I. Confirmation/Quantification (Dames and Moore [D&MI. March 1986) Source OT56 was not addressed during this phase. Phase II, Stage 2, Confirmation/Quantification (D&M. March 1988) Source OT56 was not addressed during this phase.
RCRA Facilities Assessment Report (Alaska Department of Environmental Conservation [ADEC.] Aug. 1988) Source OT56 had a low potential for environmental contamination. Further study was not warranted at the time, and further action is not required due to the nature of materials stored. Phase II, RI, Field Investigation/Data Analysis (JMM/Harza Environmental. Sept. 1988) Source OT56 was not addressed during this phase. IRP. IR/FS (Harding Lawson Associates IHLAI. Jan. 1988) The extent of possible contamination and potential pathways was unknown. IRP. Phase III. Staae 3. RI/FS, (Black and Veatch [B&V1. May 1990) Two borings drilled at Source OT56 were completed as monitoring wells (NS2-01 and NS2-02). The groundwater samples were analyzed for sulfate, VOCs, VOHs, ICP metals, other metals, TPH, and extractable priority pollutants. Soil samples were analyzed for TPH, ICP metals, mercury, VOCs, semi-volatile organic compounds, and soil moisture. Analytical results are attached. Phase III Stage 4. RI/FS. Work Plan (B&V. May 1990) It was recommended to combine Source OT56 with Sources LF05, LF07, and LF13. This new source would be assigned a high priority for remedial alternatives. Final Technical Review Comments (U.S. Environmental Protection Aaencv fEPAl. July 1990) Source OT56 was not included in the review.
FIELD INVESTIGATIONS - EM and GPR surveys were conducted to determine boundary of landfill and areas of buried metal. - Four soil samples were collected from two borings, both of which were completed as monitoring wells that provided water samples. - Metals were resampled and filtered. - Monitoring wells installed to depths less than 56 feet.
SAMPLING RESULTS -HNu readings of 5 ppm recorded in soils at 15 and 20 feet at NS2-02. -Vinyl chloride and trans-1,2-DCE were detected at low levels in NC2-02. Vinyl chloride was just above the standard. -Rubble and trash west of well NS2-02 suggest well may be on landfill material. NS2-01 is also probably within the landfill. -Black and Veatch stated that the density of data allows for generalization of the zones of contamination. -Metals were below drinking water standards in base supply well 42, sampled in 1987. |
Louis Howard |
| 11/12/1991 |
Enforcement Agreement or Order |
Federal Facility Agreement (FFA) under Comprehensive Environmental Response, Compensation, and Liability (CERCLA) signed for docket # 1089-07-19-120. The agreement ensures that the environmental impacts associated with past and present activities at the Base are thoroughly investigated and appropriate removal and/or remedial action(s) taken as necessary to protect human health and the environment.
Proposed listing on the National Priorities List (NPL) was 07/14/1989 and Final listing on NPL was on 08/30/1990. NOTE:Section 105(a)(8)(B) of CERCLA (CERCLA Overview) as amended, requires that the statutory criteria provided by the Hazard Ranking System (HRS) be used to prepare a list of national priorities among the known releases or threatened releases of hazardous substances, pollutants, or contaminants throughout the United States.
This list, which is Appendix B of the National Contingency Plan, is the NPL. The identification of a site for the NPL is intended primarily to guide EPA in: determining which sites warrant further investigation to assess the nature and extent of the human health and environmental risks associated with a site; identifying what CERCLA-financed remedial actions may be appropriate; notifying the public of sites EPA believes warrant further investigation; and serving notice to potentially responsible parties that EPA may initiate CERCLA-financed remedial action. Inclusion of a site on the NPL does not in itself reflect a judgment of the activities of its owner or operator, it does not require those persons to undertake any action, nor does it assign liability to any person. The NPL serves primarily informational purposes, identifying for the States and the public those sites or other releases that appear to warrant remedial actions.
CERCLA Source Area SS22-Source area SS22, formerly called S-7, is the current Defense Reutilization and Marketing Office (DRMO) storage facility and is operated under the Base's RCRA Part B operating permit. The site is located approximately 1 mile east of the east end of the east/west runway. Source area SS22 has been used to store used empty 55-gallon oil drums. The storage building is being constructed at this location. Contamination potential for this source area appears to be nonexistent. Elmendorf AFB reported that no known spills exist based on visual evidence. There is no recommended action at this time. Source area SS22 was closed and became an official NFA site when the FFA was signed in November 1991. (NOTE: in 2007 Radium 226 and metallic anomalies detected during limited field investigation which reopened the site and changed it from conditionally closed to "active").
Decision documents NFRA (no further response actions) Site ID Source name, date written, Date signed SS18 Building 22-021 1 April 1993 7 May 1993 SD26 Hangar 14/Building 43-550 1 April 1993 7 May 1993 SD27 Building 42-300/Hangar 8 1 April 1993 7 May 1993 SD30 Building 21-900 1 April 1993 7 May 1993 ST38 JP-4 Fuel Line Leak, Bldg. 22-010 24 June 1994 4 August 1994 SD40 Railroad Maintenance Area Oil Spill 24 June 1994 4 August 1994 SS42 Diesel Fuel Spill, Bldg. 22-013 24 June 1994 4 August 1994 ST46 JP-4 Fuel Line Leak 24 June 1994 4 August 1994 SD52 Cherry Hill Ditch 20 August 1993 20 August 1993 SS53 Golf Course Seep 24 June 1994 4 August 1994 SS63 Classic Owl, Bldg. 52-140 8 September 1994 27 September 1994 SS22 DRMO Storage Facility 25 September 1991 November 1991 (FFA) (REOPENED) RW17 Radioactive Waste Site 25 September 1991 November 1991 (FFA) |
Louis Howard |
| 12/7/1991 |
Update or Other Action |
Mgt. Action Plan Appendix G Summary of No Further Action Documents. CERCLA Source Area SS22 Source area SS22, formerly called S-7, is the current Defense Reutilization and Marketing Office (DRMO) storage facility and is operated under the Base's RCRA Part B operating permit. The site is located approximately 1 mile east of the east end of the east/west runway. Source area SS22 has been used to store used empty 55-gallon oil drums.
The storage building is being constructed at this location. Contamination potential for this source area appears to be nonexistent. Elmendorf AFB reported that no known spills exist based on visual evidence. There is no recommended action at this time. Source area SS22 was closed and became an official NFA site when the FFA was signed in November 1991. |
Louis Howard |
| 2/25/1992 |
Update or Other Action |
Basewide Investigation Work Plan (Envir. Mgt. Operations Operated for the US Dept. Of Energy for Battelle Memorial Institute). During FFA negotiations, two additional source areas, SS22 and RW17, were determined to require no further remedial action under CERCLA. The Elmendorf AFB OUs and the rationale for the source groupings are summarized below. OU 1 - Sanitary landfills LF05, LF07, LF13, and LF59, and OT56 (Defense Reutilization and Marketing Office [DRMO] scrap pile) are grouped into OU 1. These five areas overlap boundaries in some locations, and the contaminants detected in each are similar. Aka NS-2 DRMO (DPDO) Scrap Pile. Source OT56-DRMO Scrap Pile Source OT56 is north of Source LF13, east of Source LF05, and north of Source LF07 (Figure 4.1). Drums containing various types of materials are stored at this source area, and some staining of the soil has resulted.
During RI/FS field activities conducted by Black & Veatch (1990a), two soil borings were completed at OT56, and monitoring wells were developed. Groundwater and soil samples were collected and analyzed. Analytical results indicated the presence of chlorinated hydrocarbons.
Information from previous investigations at source OT56 can be found in the following: * Installation Restoration Program, Stage 3, Remedial Investigation/Feasibility Study, Elmendorf AFB, Alaska (Black & Veatch, 1990a) * Installation Restoration Program, Stage 4, Remedial Investigation/Feasibility Study Report for the Elmendorf AFB, Alaska (Black & Veatch, 1990b) * RCRA Facility Assessment Report: Preliminary Review and Visual Site Inspection (ADEC, 1988) |
Louis Howard |
| 5/1/1992 |
Update or Other Action |
OU1 Management Plan Operable Unit 1 consists of five contaminant source areas located in the southeastern part of the Base, near the intersection of the Davis Highway & Second Street.LF05, LF07, LF13, & OT56 are located contiguous to each other northeast of the intersection of the Davis Highway & Second Street. Three of these contaminant source areas (LF05, LF07, & LF13) have been locations of subsurface landfilling operations.
Surface debris remains apparent at some of these source areas. The adjacent contaminant source area OT56 has been the site of surface drum storage, with some staining of surface soils apparent. Furthermore, as noted below, similar contaminants have been detected at various sampling points associated with contaminant source areas LF05, LF07, LF13, & OT56. For these reasons, these four contaminant source area will be treated as a single contaminant zone, consistent with the May 1991 version of the Air Force Handbook (USAF, 1991).
Contaminant source area LF59 is a recently-identified potential landfill or disposal zone located southwest of the zone consisting of LF05, LF07, LF13, & OT56, & northwest of the Davis Highway bridge at Ship Creek. This contaminant source area was identified after joggers on a trail in the area noticed what appeared to be tars or asphaltic liquids at the surface adjacent to the trail. This area has been termed the "Tar Seep", although visual observations do not clearly indicate that the area is a seep rather than a possible area of surface disposal. No previous investigations have been conducted at this contaminant source area. The general direction of GW flow beneath these contaminant source areas is not completely clear. The shallow GW aquifer in the area is in apparent hydraulic connection with Ship Creek, which is believed to change from a losing stream (recharging the aquifer) to a gaining stream (discharging from the aquifer) in the immediate vicinity of OU1. Thus, GW flow may be locally away from or towards Ship Creek, & may also vary seasonally with variations in the stage of Ship Creek.
Contaminant source OT56 (site NS-2) is a Defense Reutilization & Marketing Office scrap pile located immediately north of LF13. Various drums containing unknown materials (CH2M Hill, 1991) are located in the vicinity of the site, & some surface staining of soils has been observed (Black & Veatch, 1990). The contaminant source has an area of approximately 2.5 acres. In summary, the zone consisting of contaminant sources LF05, LF07, LF13 & OT56 encompasses an area of about 50-60 acres in the southeastern part of the Base. The zone has been used for past & present landfilling operations, waste disposal into old gravel pits, current gravel production operations, & drum storage. Most of the zone has been closed, covered, & revegetated, although miscellaneous debris, primarily construction rubble, is present at the surface in some areas. Various portions of the zone have been used for waste disposal operations between 1951 & the present.
DQOs Define areal & vertical extent of contamination in soils, & GW - Assess presence of contamination in surface water - Characterize contaminant sources at landfill cells, & volume & composition of the landfill waste - Determine the extent of waste deposition in shallow GW - Investigate potential soil & GW contamination at self-service gas station - Establish GW levels & flow directions in shallow aquifer, & seasonal variations, for transport analyses - Assess hydraulic connection between Ship Creek & shallow aquifer for transport analyses - Quantify potential for hydraulic connection between water table & artesian aquifers to estimate contaminant transport to artesian aquifer & for feasibility studies - Determine depth to & surface configuration of Bootlegger Cove Formation as as preferential contaminant pathways, especially for DNAPL - Characterize local stratigraphy of glacial outwash & alluvial deposits for pathway analyses & feasibility studies - Characterize physical & geochemical properties of soils for pathway analyses & feasibility studies - Characterize baseline water & sediment quality for Ship Creek, & ascertain potential contamination of those media - Estimate aquifer properties for transport analyses - Determine use & location of Base & local GW withdrawal. - Determine the use of Ship Creek as sport & subsistence fishery.
See site file for additional information. |
Louis Howard |
| 10/28/1993 |
Update or Other Action |
EOD Report indicated that an ordnance item was uncovered in a scrap pile in the DRMO while loading metal into a tractor trailer in 1993. 5.56 mm Blank, 5.56 mm Ball, 7.62 mm Ball. 1120 Received a call from DRMO asking our assistance on some ordnance they had uncovered while loading scrap metal into a tractor trailer. 1128 Team arrives at site and talks with Mr. McCory. He informs us that while loading the trailer, they noticed some small arms ammunition that appeared to be live. This scrap pile was a combination of one year of dumping what was previously certified inert items by Navy, Marines, Army and Air Force personnel.
1135 Wing Safety arrives. After discussion between Safety, Mr. McCorry, and EOD, it was agreed that all items loaded in the trailer would be unloaded and searched along the remainder of the pile. Unloading the trailer became a problem because of snow and ice buildup in the trailer. We then realized the only way were were leaving before spring was to help the driver shovel out the remaining items in the truck. MSgt Anderson brought the shovels and additional EOD personnel to assist. 1300 Team got truck unloaded after much shoveling and cursing. 1320 Team returns to shop. DRMO will research their paperwork to try and determine who is responsible for the small arms ammo and have them tasked to help us search through the scrap pile.
DRMO is marking off the area until they get further guidance from their Headquarters. It was suggested that they cover the pile to try and keep as much snow and ice off as possible. Signed Team Chief, SSGT Patrick J. Gildea, SMSGT Michael A. David and MAJCOM Staff Mgr. David C. Becker. CMSgt USAF MAJCOM EOD Mgr. |
Louis Howard |
| 12/7/1994 |
Update or Other Action |
Mgt. Action Plan Appendix G No Further Action Documents Source area SS22, formerly called S-7, is the current Defense Reutilization and Marketing Office (DRMO) storage facility and is operated under the Base's RCRA Part B operating permit. The site is located approximately 1 mile east of the east end of the east/west runway. Source area SS22 has been used to store used empty 55-gallon oil drums. The storage building is being constructed at this location. Contamination potential for this source area appears to be nonexistent. Elmendorf AFB reported that no known spills exist based on visual evidence.
There is no recommended action at this time. Source area SS22 was closed and became an official NFA site when the FFA was signed in November 1991.
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Source area RW17, formerly called RD-1, is located approximately 1.5 miles north of the north end of the north/south runway. This low-level radioactive waste disposal site was suspected of containing small quantities of cyanide and radium, which were buried in the ground. Radioactive analysis using a Geiger counter found that no radioactivity above background levels was detected. Materials were exhumed and disposed of by offsite contract disposal; thus risks associated with this source area do not exist. Following completion of initial Base studies, this site was determined to pose no threat to the environment or human health. This determination was also made by ADEC during its Federal facilities Resource Conservation and Recovery Act (RCRA) inspection. Source Area RW17 was closed and became an official NFA site when the Federal Facilities Agreement (FFA) was signed in November 1991. |
Louis Howard |
| 9/30/1996 |
Update or Other Action |
ST531 is the location of a former 3,000-gallon underground heating oil tank (HOT). The
tank was observed in good condition when the UST and associated piping were removed in 1996; however, petroleum-contaminated soil was observed near the fill pipe and throughout most of the excavation. UST removal activities resulted in an excavation measuring approximately 11 feet wide, 21 feet long, and 9 feet deep. Two confirmation soil samples were collected from the excavation floor (STMP240-9WFL) and north sidewall (STMP240-6NW) and analyzed for diesel range organics (DRO) (Attachment B).
The DRO concentrations detected (1,400 milligrams per kilogram [mg/kg] and 2,400 mg/kg) exceeded the least stringent ADEC 18 AAC 75.341 Method One, Category D cleanup standard of 2,000 mg/kg. Since no holes were observed in the UST upon removal, it was determined DRO contamination likely resulted from overfills and/or spillage during filling. No laboratory soil samples were collected from the excavated soil stockpile, which was used to backfill the excavation. Groundwater was not encountered during the UST removal. |
Louis Howard |
| 7/10/1997 |
Document, Report, or Work plan Review - other |
Site evaluation and biostudies WP comments.
General: GW monitoring wells will be required at all sites where contamination has reached the GW. ADEC is requiring monitoring wells be installed within the known hot spot of the former UST or POL excavation & within 100 yards down gradient of the site. If existing monitoring wells exist within 100 yards & down gradient of the site they may be used in lieu of installing a new down gradient well. Sampling of the contaminated ground water is needed to help the department evaluate the levels & the extent of GW contamination as result of releases from the former UST & POL sites.
Periodic GW sampling will be required to help the department determine the effectiveness of the corrective action method being implemented. Ground water samples should be tested for BTEX, GRO & DRO using analytical methods listed in, Table 1, Part B, of the UST Procedure manual. At sites involving releases from waste oil tanks, GW samples shall test for the presence of total chlorinated solvents & PCBs in addition to the standard Alaska methods if these compounds were detected in the soil samples.
General: The Air Force is proposing to test for the levels of BTEX in soil using the EPA 8020 analytical method. The Departments UST Procedure Manual, dated September 22, 1995, recommends the Alaska 101 method with methanol field preservation. Using this method may result in a cost savings for the Air Force because AK 101 analytical method can be used to detect both BTEX & gasoline constituents.
General: On sites where the boiventing is not selected as the presumptive correction action the Air Force will be required to develop another corrective action plan & submit a work plan for the department’s review.
General: It appears contractors performing UST closures for the Air Force have returned excavated soils containing high levels of contamination back into the excavation. In the past the Department has allowed the Air Force to backfill the excavation with contaminated soils if the soils slightly exceeded the Alaska Cleanup Matrix (ACM) level for the site. On many sites soils exceeding this threshold where return to the excavation, eg., ST 509 (AFID 105), ST 516 (AFID 154), ST 522 (STMP 431), ST 523 (AFID 16), ST 524 (AFID 149), ST 525(AFID 330), ST 528 (AFID 857), ST 530 (AFID 893), ST 531 (STMP 240), ST 532 (STMP 243), ST 533 (STMP 246), ST 534 (STMP 300) and ST 535 (STMP 428). At some sites laboratory samples were not collected and analyzed from the stock pile. Soils were returned to the excavation has positive PID readings, eg., ST 515 (AFID 580). These two practices are in violation of our agreement and shall be discontinued.
See site file for additional information. |
Tim Stevens |
| 8/18/1997 |
Update or Other Action |
Incident in 1997 when a grader ran over a 2.75-inch practice rocket while working on the Davis Highway, near the DRMO. EOD report 2.75 Practice Rocket MK1 Mod 3 Warhead with M178 Dummy Fuze. EOD was notified by the LE desk that a grader had run over a 2.75 rocket while working in an area on the Davis Highway, near DRMO. A team responded to the site and identified the rocket as a practice round. It now has a home in our museum. Signed Team Chief, James A. Assenmacher SSgt, Derek V. Singleton MSgt and Timothy W. Berry TSgt, Deputy EOD Command Manager. |
Louis Howard |
| 6/1/1998 |
Update or Other Action |
Stage 3 RI/FS Site NS-2 was not investigated in the IRP Phase I and II. A reconnaissance of the site was conducted by HLA on 15 September 1987 as part of the Integrated RI/FS site visit. Bruce Erickson of ADEC indicated that drums of various kinds are stored in this area, and some surface staining of the soil has resulted. The extent of possible contamination and the pathways affected if contamination has occurred are unknown at this time.
QAPP Appendix A Detailed Site specific requirements. Site NS-2, DRMO Scrap Pile Site NS-2 (Plate 5-3) was not investigated in Phases I or II of I the Elmendorf IRP. During our brief field reconnaissance, we observed that drums of various kinds have been disposed of in the scrap pile. Some surface staining of the soil around the margins of the scrap pile has resulted. HLA's objective in IRP Integrated RI/FS is to determine whether past disposal practices have resulted in contamination of the soils and/or groundwater at the site.
Two soil borings will be drilled and sampled at Site NS-2 at the locations shown on Plate 5-3. These locations were selected based on the results of Stage 1 and 2 work at Sites D-5 and D-7 (Plate 5-2) and will augment data obtained from the monitoring wells to be installed at Site D-13 (Plate 5-4). The borings will be drilled and sampled to a depth of about 60 feet. Samples will be taken at the surface and at five-foot intervals thereafter. Two monitoring wells will be installed in the borings. These wells are necessary to establish the chemical characteristics at both the up and downgradient locations at the site and will aid in the calculation of groundwater flow direction at this site and at Site D-13. One field permeability test will be conducted to provide a site-specific 3 estimate of transmissivity of the the shallow aquifer. Each of the monitoring wells will be sampled to determine the chemical characteristics of the groundwater at the site. Analytical parameters for these samples are: alkalinity-carbonate, specific conductance, pH, total dissolved solids, temperature, common anions, petroleum hydrocarbon, metals screen, arsenic, lead, mercury, selenium, purgeable halocarbon, nonhalogenated volatile organics, purgeable aromatics, and extractable priority pollutants. Four of the soil samples collected during the soil boring investigation will be analyzed for: petroleum hydrocarbon, metals screen, mercury, organochlorine pesticides and PCBs, volatile organic compounds, 3 semivolatile organic compounds, cyanide, and soil moisture content. |
Louis Howard |
| 3/31/1999 |
Update or Other Action |
In 1997, three soil borings (SB-531-01, SB-531-02, and SB-531-03) were advanced to the water
table during the State-Elmendorf Environmental Restoration Agreement (SERA) Phase V investigation. Soil samples were collected approximately every 5 feet from each boring for lithologic logging and field screening.
Up to three soil samples were collected from each boring and analyzed for gasoline range organics (GRO), DRO, residual range organics (RRO), and benzene, toluene, ethylbenzene, and xylenes (BTEX). The maximum concentration of DRO (192 mg/kg) did not exceed the ADEC 18 AAC 75.341 Method Two, Table B2 Under 40-Inch Zone, Migration to Groundwater cleanup level of 250 mg/kg. GRO, RRO, and BTEX were not detected. |
Louis Howard |
| 3/29/2002 |
Update or Other Action |
In 2001, two soil borings (531BH01 and 531BH02) were advanced to 35 feet below ground surface (bgs) near the locations where DRO contamination was noted in the 1996 tank removal/soil excavation (Attachment B). Soil samples were collected approximately every 5 feet from each boring for lithologic logging and field screening. Groundwater is present at approximately 47 feet bgs and was not investigated because the site is within the OU5 modeling area, which is managed under the Environmental Restoration Program (ERP).
Three soil samples were collected from each boring and analyzed for GRO, DRO, RRO, and BTEX. The maximum concentration of DRO (450 mg/kg) detected at 9 feet bgs exceeded the ADEC 18 AAC 75.341 Method Two, Table B2 Under 40-Inch Zone, Migration to Groundwater cleanup level of 250 mg/kg. GRO, RRO, and BTEX were not detected. Field screening and analytical results indicated the vertical extent of DRO contamination did not extend beyond 17 feet bgs at the site. |
Louis Howard |
| 8/30/2002 |
Update or Other Action |
In August 2002, a limited site investigation was conducted by the Air Force near a rail spur line in the central portion of the property (Tar Seep Area 1) as part of a larger project that was investigating the nature of two tar seeps identified within and just outside of the current DRMO Yard. Tar Seep Area 2 is located approximately 1,000 ft west of SS22 near Vandenburg Avenue is not relevant to the SS-22 site. Surface scraping and excavation activities identified two key areas within- Tar Seep Area 1: • A stained surface layer (from approximately 1 to 1.5 ft bgs), was observed extending in all directions beneath a thick layer of surface tar; and • Two buried drums were identified less than 6 inches below the surface, one of which was observed to be approximately 75 percent full of tar.
Several samples of the tar material were collected for identification and waste profiling. As expected, elevated levels of total petroleum hydrocarbons (TPH) were detected from each sample; at maximum concentrations of 347,000 milligrams per kilogram (mg/kg) and 170,000 mg/kg for TPH as diesel range organics (DRO) and residual range organics (RRO), respectively. In addition, elevated levels of lead by Toxicity Characteristics Leaching Procedure (TCLP) analysis (maximum concentration of 25.2 milligrams per liter) indicate that the material, should it be removed from the ground, would be classified as a RCRA hazardous waste. NOTE TO FILE: 18 AAC 75.990 (127) “surface soil” means soil that extends no more than two feet below the surface. |
Louis Howard |
| 10/4/2002 |
Update or Other Action |
Geophysical Survey and Subsequent Trenching, October 2-4, 2002 i. Geophysical investigation ii. Fifteen anomalous areas identified; test trenches used to confirm buried debris iii. Debris included automotive parts and miscellaneous metallic debris iv. Anomaly 4 included a cell of buried drums containing tar-like substances v. No metallic debris found in Anomaly 7 vi. Anomaly 13 believed to be a former burn pit location |
Louis Howard |
| 10/31/2002 |
Update or Other Action |
ADEC received the Final Technical Memorandum "Geophysical Survey and Subsequent Field Investigation at the DRMO Yard" under contract no. DACA-45-98-D-0004 Task Order No. 0052 October 2002. Between the dates of October 2 and October 4, 2002, the United States Air Force (USAF) performed a geophysical investigation at the Defense Reutilization and Marketing Office (DRMO) site on Elmendorf Air Force Base, Anchorage, Alaska for the 3rd Civil Enginering Squadron/Civil Environmental Restoration Group. The geophysical survey was conducted on an area encompassing approximately 20 acres, utilizing electromagnetic (EM) terrain conductivity surveying methods to collect geophysical data needed to characterize the subsurface conditions.
Previous activities at the DRMO, conducted by the Environmental Compliance Program revealed buried drums of a tar substance in the shallow subsurface. Tar was present in the soil surrounding the drums. A subsequent geophysical investigation was conducted to determine the extent and location of the buried contaminated drums and other potentially .buried debris located through. out the DRMO yard. Following the geophysical investigation, test pits were excavated at select locations with a backhoe to correlate the geophysical results with actual types and quantities of buried debris and subsurface features. Test pits were excavated at the 15 locations identified during the geophysical survey as areas with anomalous readings. The 15 locations are depicted on both Figures 1 and 2. Test pits were, excavated to correlate the geophysical results with physical evidence of the types and quantities of buried debris and to validate the geophysical results. A 420 rubber-tired backhoe was used to excavate the test pits. Care was exercised throughout the excavations due to the historical presence of unexploded ordnance (UXO) at the site. All test pits encountered buried metallic debris to various extents except for test pits excavated at Anomaly 13.
As discussed above in Section 4.1, EM31 readings at Anomaly 13 suggested that there was minimal buried metal but likely a soil condition different from the rest of the surveyed area. The test pits excavated in the Anomaly 13 area confirmed the survey conclusion. Metallic debris was found within the center of Anomaly 13, but the overall anomaly was the result of black silty soil uncharacteristic to the site encountered in a circular pattern identical to the pattern detected during the EM31 survey. The shape of the anomaly of soil characteristics of the area suggest that the area may have been used as a burn pit/fire training area. The other anomaly of interest was Anomaly 4. Four test pits excavated within the defined limits of
Anomaly 4 confirmed that a cell of buried drums approximately 125feet by 40 feet is present within the DRMO yard. No obvious contamination other than that previously encountered in some of the unearthed drums (a tar-like substance) was observed. However, some of the drums uncovered during the site investigation appeared to be intact or partially intact. No drums were removed to the surface for further investigation and the vertical extent of the drums was not ascertained. It appeared that the drums in certain areas were placed up to at least 10 feet bgs.
All other anomalies (based on test pits) contained buried automotive parts and miscellaneous metallic debris in various amounts. With the exception of limited observations of corroded automotive parts (possibly indicative of battery acid), obvious signs of soil contamination within each of these remaining anomalies were generally not observed during trenching activities. Soil sampling for chemical analysis was not conducted as a part of that investigation. |
Louis Howard |
| 3/20/2003 |
Meeting or Teleconference Held |
Kevin Oates EPA AK Ops Office Region 10 spoke with Howard Orlean who is the EPA RCRA permit person for the DRMO. Howard is okay with proceeding with work at SS-22 under CERCLA. He does ask that we keep him in the loop as investigation and cleanup moves ahead. He will also want to look at any final cleanup plans and closeout documents to ensure they are consistent with RCRA closure requirements. |
Louis Howard |
| 5/7/2007 |
Meeting or Teleconference Held |
MEMORANDUM FOR FILE DATE: 21 June 2007 FROM: 3 CES/CEVR SUBJECT: Minutes of Remedial Project Manager Meeting, 30 May 2007 1. A meeting of the remedial project managers (RPMs) convened at 0900 on 30 May 2007 in the Environmental Flight (3 CES/CEV) Conference Room, Building 5312, at Elmendorf Air Force Base (EAFB), Alaska. Attendees included: Mr. Jacques Gusmano (Environmental Protection Agency [EPA]), Mr. Louis Howard (Alaska Department of Environmental Conservation [ADEC]), Ms. Donna Baumler (CEVR), Ms. Melissa Markell (CEVR), Mr. Claude Mayer (CEVR), Mr. Glen Verplancke (CEVR), and Mr. Joe Williamson (CEVR).
Zone 1 Update (Mr. Verplancke). SS22 RI/FS. The contract for this work has been let, and the contractors have begun work. Current efforts are focused on establishing milestones and producing an attachment for the Federal Facilities Agreement (FFA). Mr. Williamson noted that the agencies must commit to the review times in the FFA attachment in order for the work to proceed, especially since the work is expected to occur in the current field season. Mr. Verplancke would like to schedule a meeting on or around 18 June 2007 with ADEC and EPA to discuss the TRIAD investigation approach. The site is expected to have petroleum contamination only, but has the potential to be a CERCLA site due to the presence of lead. |
Louis Howard |
| 7/12/2007 |
Update or Other Action |
Email from Air Force G. Verplancke to EPA and ADEC RPMs: I would like to schedule a meeting to kick off the SS-22 Triad RI/FS project on Tuesday, 17 July 07 at 1:00 pm in our conference room. I anticipate that the meeting will last approximately 2 hours. Meeting attendees: me and my contractor, Earth Tech Environmental. Representing Earth Tech will be Bill Burke (Anchorage office), Andy Boudreau (Denver Office). |
Louis Howard |
| 7/13/2007 |
Document, Report, or Work plan Review - other |
Staff provided comments on the S-22 Remedial Investigation - Feasibility Study Work Plan, Elmendorf AFB July 3, 2007.
Exposure Point Concentrations and Fate and Transport Modeling Page 3-3: ADEC is not accepting multi-increment sampling data for risk assessment purposes at this time. ADEC will require the use of the 95% UCL of the mean or maximum detected concentrations when addressing exposure point concentrations.
Management Team Meeting Page 3-6: If MI sampling is proposed, a separate or revised sampling analysis plan (SAP) must be submitted to ADEC for approval. The SAP would need to include sufficient details and figures to verify MI sampling will be performed according to the DEC MI guidance “Draft Guidance on Multi-Increment Soil Sampling” (as amended through March 2007).
Collection of Definitive Data Page 3-6: The text states that Washington State volatile petroleum hydrocarbon (VPH) and extractable petroleum hydrocarbon (EPH) data will be used as input to phase partitioning calculations, fate and transport calculations, human health and ecological risk calculations, and remediation calculations.
ADEC requests specific information on these calculations and whether or not: • the phase partitioning, fate and transport or remediation calculations are in the public domain or proprietary; and • the risk assessment calculations will follow current EPA risk assessment guidance for superfund or ADEC guidance: e.g. draft risk assessment procedures manual (updated and recommended for use through November 2005) and ecoscoping guidance (as amended through March 2007) and not be based upon any multi-increment (MI) sampling data.
Human Health Conceptual Site Model: ADEC requests the receptors include a completed (C) designation for site visitors, trespassers, or recreational users. The justification for including/evaluating site visitors/recreational users is found at 2.2.1 Contaminant Sources and Contamination on page 2-1. It states that currently, a portion of the SS-22 site is used for recreational vehicle storage for base residents. Also see 2.2.5 Demographics on page 2-6 where it states potential current receptors are interpreted to be site workers and site visitors (including people doing business and people storing RVs at the DRMO), while potential future receptors could also include site construction/trench workers.
Test Pit Excavation (Anomaly 4) Page 6-8: The first screening sample above 25 ppm (not 100 ppm), as agreed on for other projects on Base, will be the threshold for taking environmental management action (i.e. collecting soil samples). Please note that field screening may not take the place of laboratory samples. Use of field screening analyses with PID and Flame Ionization Detectors (FIDs) must follow the relevant procedures outlined in both Section 4-Sampling Procedures of the UST Procedures Manual and Section 7-Calibration and Maintenance of Field Equipment of the UST Procedures Manual (as amended, through November 2, 2002). If other instruments are used, a written description of that use must be provided to ADEC by the assessment firm.
Soil Samples Page 5-3: ADEC is not accepting multi-increment sampling data for risk assessment purposes at this time. ADEC will require the use of traditional sampling methods (discrete) for any data needed for remedial alternatives based on risk analysis.
See site file for additional information. |
Louis Howard |
| 7/13/2007 |
Document, Report, or Work plan Review - other |
SS-22 Remedial Investigation - Feasibility Study Work Plan, Elmendorf AFB July 3, 2007 review comments by staff.
3.2 Risk Assessment
5. Exposure Point Concentrations and Fate and Transport Modeling Page 3-3
The text states that exposure point concentrations for the SS-22 exposure areas may be based on either the 95% upper confidence limit (UCL) of the mean or the maximum detected concentration; or potentially on the results of multi-increment sampling techniques. ADEC disagrees. ADEC is not accepting multi-increment sampling data for risk assessment purposes at this time. ADEC will require the use of the 95% UCL of the mean or maximum detected concentrations when addressing exposure point concentrations.
3.2.1 Key Guidance Pages 3-3 and 3-4
Please be aware that EPA Region 10 is now recommending use of the Region 6 EPA Human Health Medium-Specific Screening Levels (as amended through May 4, 2007) rather than the Region 9 PRGs. The Region 6 internet version of the document can be found at http://www.epa.gov/earth1r6/6pd/rcra_c/pd-n/screen.htm. The USEPA Region 6 Human Health Medium-Specific Screening Levels address common human health exposure pathways. They do not consider all potential human health exposure pathways nor address ecological concerns. The comparison of preliminary investigation data against risk-based media concentrations provides for an initial evaluation for the relative environmental concern for a site or set of environmental data.
3.4.4 Collection of Definitive Data Page 3-6
The text states that Washington State volatile petroleum hydrocarbon (VPH) and extractable petroleum hydrocarbon (EPH) data will be used as input to phase partitioning calculations, fate and transport calculations, human health and ecological risk calculations, and remediation calculations. ADEC requests specific information on these calculations and whether or not:
• the phase partitioning, fate and transport or remediation calculations are in the public domain or proprietary; and
• the risk assessment calculations will follow current EPA risk assessment guidance for superfund or ADEC guidance: e.g. draft risk assessment procedures manual (updated and recommended for use through November 2005) and ecoscoping guidance (as amended through March 2007) and not be based upon any multi-increment (MI) sampling data.
Although ADEC does not maintain an approved list of fate and transport models, ADEC recommends that models with the following characteristics be selected for use:
1. The model should provide conservative predictions. With the uncertainty in model parameters and unknowns in subsurface (for example, a few fractures are always present in a porous medium) conservative prediction is critical.
2. The model should be technically sound and legally defensible.
3. The model is within the public domain
4. Model information and reviews are published in reputable technical journals
5. The model has received adequate peer review.
5.1.2 Definitive Data
The text states that the project chemist will prepare a Quality Control Summary Report (QCSR) for inclusion as an appendix to the RI/FS report. In order to ensure consistency in data quality across the Contaminated Sites Program, ADEC has developed a technical memorandum and a Laboratory Data Review Checklist that summarizes the minimum requirements for both laboratory data packages and QA Summaries (data reduction, verification, evaluation, etc,).
This information must be included in all reports containing analytical data related to soil and water samples submitted to the Contaminated Sites Program under the 18 AAC 75 and 18 AAC 78 regulations. The technical memorandum can be found on the DEC Internet site at http://www.dec.state.ak.us/spar/csp/guidance/tm_lab_qa.pdf and the Laboratory Data Review Checklist can be found at http://www.dec.state.ak.us/spar/csp/guidance/lab_checklist.pdf.
|
Louis Howard |
| 7/17/2007 |
Meeting or Teleconference Held |
Staff attended a Remedial Investigation/Feasibility Study SS-22 (Former DRMO Storage Yard) Area-1 – Elmendorf Air Force Base, Alaska Triad Meeting. Agenda items: Site History & Overview, Draft Work Plan (Dynamic Planning Document), Remedial Investigation Project Tasks, CSM, Field Investigation, Site Reconnaissance, Land Survey, Radiation Survey, Screening Data Collection, Management Team Meeting (Triad #2), Definitive Data Collection, IDW, Risk Assessment, Feasibility Study, Remedial Action Objectives, Alternative Evaluation, Data Assessment, Plan Comments/Revisions – Action Items, NTP - WP Approval, & Field Schedule. Handling of potential radioactive sources during operations at the former DRMO yard was discussed & the radiation survey proposed in the work plan (WP) was agreed to by the project team.
Prior to radiation survey, Earth Tech & EAFB Environmental will verify that calibration check sources used for radiation detection instrumentation can be brought on to Elmendorf AFB. If not allowed, instrument calibration will be conducted off base prior to the survey. The draft WP incorrectly identified ADEC clean-up levels as risk screening criteria. EPA & ADEC reiterated the correct risk screening criteria for the site data. 1/10th the ADEC clean up as amended & referenced on ADEC’s website will be used for risk screening criteria. If a specific analyte is not referenced on ADEC’s website, then U.S. EPA Region 6 PRGs will be used as the risk screening criteria.
Volatile organic compound analysis & sample preservation methods were discussed. ADEC requires methanol (MeOH) preservation for all VOC analysis. Deviations from this methodology are only approved on a site specific basis. The project team discussed the fact that reporting limits for some analytes using the methanol preservation method for VOC analysis would be higher than the project screening criteria rendering the data less useful in the risk assessment. A low level VOC analysis method would need to be selected & approved by ADEC for these analytes & multiple VOC samples may be required from the same soil horizon to complete both the high-level & low-level analysis. The project team discussed use of the hydrocarbon calculator to complete risk calculations for the risk assessment.
ADEC indicated that the model is not currently approved & has been revised periodically. The project team discussed that the calculations used in the base model were reviewed & were correct but that they have not reviewed subsequent revisions to the calculator since the original model was reviewed. The project team reached a consensus that risk calculations for site COPCs in the RI risk assessment would follow both the U.S. EPA Risk Assessment Guidance document & ADEC approved risk assessment guidance. Additionally, it was agreed that a complete pathway for site visitors would be included within the site conceptual model for the risk assessment.
The project team discussed the screening approach & ultimate closure requirements for Anomaly 4 based on the fact that there are unknown quantities & contents of crushed & partially intact drums within this anomaly. Closure of this portion of the site would likely require full characterization of each drum & likely removal of these drums as part of the site remedy. A screening approach involving excavating test pits near the edge of the anomaly & collecting soil samples immediately below the drums & at depth via angled direct push sampling was discussed. These data would be limited, only providing information to determine if the drums have leaked any contents over time but would not be as useful to fully characterize the anomaly.
Since there is a possibility that other drums containing different constituents could be encountered within the anomaly it was decided the best information to obtain early on in the investigative work was an assessment of any potential migration of contamination to underlying GW.
References within the geophysical survey report to Anomaly 13 as a potential burn pit was discussed. Since this area has a potential to contain other specific contaminants, field screening for PCBs, dioxin/furans within the burn pit needs to be done during the phase 1 field effort to assess the presence of these constituents & help guide definitive sampling plans during phase 2. Soil samples will be collected from visually stained layers within the anomaly & sent for analysis at a fixed based ADEC approved laboratory.
Additionally, a determination of any potential migration of contamination to underlying GW assessing any immanent threat resulting from potential releases also needs to be evaluated at this anomaly. Installation of one upgradient & three downgradient GW monitoring wells within 100’ to 300 feet of this anomaly was agreed to by the project team.
See site file for additional information. |
Louis Howard |
| 8/3/2007 |
Update or Other Action |
Technical Memorandum Phase 1: Collection of Screening Data Remedial Investigation SS-22, Area 1 4P-AE Contract No. F41624-03-D-8597 Task Order No. 0215 CDRLs A007, A004, A005, A001B This Technical Memorandum has been prepared for the United States Air Force (USAF) 3rd Civil Engineering Squadron (CES)/Civil Engineering Environmental Flight (CEV) Elmendorf Air Force Base (AFB) and the Air Force Center for Engineering and the Environment (AFCEE) by Earth Tech Inc., under Contract F41624-03-D-8597, Task Order 215.
This document describes the activities required to complete collection of screening data for Phase 1 of the Remedial Investigation through Feasibility Study (RI/FS) of Site SS-22 (Former Defense Reutilization and Marketing Office [DRMO] storage yard) at Elmendorf AFB, Alaska. The RI/FS has been divided into two phases. During Phase 1, screening data will be collected from the 15 areas of suspected contamination identified in the Final Technical Memo Geophysical Survey and Subsequent Field Investigation at the DRMO Yard (USAF 2002), and other areas identified from the site reconnaissance to determine the presence and extent of contamination.
The collection of screening data will guide collection of definitive data during the second phase and preparation of the Draft Final SS-22 RI/FS Work Plan. Definitive data will be used in the baseline risk assessment and for evaluation of remediation alternatives on the areas with the greatest likelihood of having been impacted. With the exception of Anomaly 4, each area of suspected contamination will be screened starting at the center of the anomaly or where other visual indications of contamination exist, and then radiate outward (both laterally and vertically) to determine the presence of contamination and to establish the extent of identified contamination.
Anomaly 4 is known to contain intact and partially intact buried drums. To avoid puncturing a drum that may contain hazardous materials or petroleum products within Anomaly 4, the field screening will be limited to the surface soils and to underlying subsurface soils accessed by angle drilling techniques from a location outside the boundaries of the anomaly foot print as defined be the geophysical survey work done in 2005. The soil surface at each anomaly will be screened for the presence of lead (400 milligrams per kilogram [mg/kg] clean up standard) with an X-ray fluorescence (XRF) instrument. Following the screening of the soil surface, the subsurface soil will be screened for contamination using a soil gas survey. The soil gas survey will screen for the presence of volatile TPH and volatile organic compounds (VOCs) at concentrations of 25 parts per billion (ppb) or greater using a Toxic Vapor Analyzer (TVA) equipped with a dual photoionization detector/flame ionization detector (PID/FID).
Following the soil gas survey a laser-induced fluorescence (LIF) probe or a ultra violet fluorescence (UVA) – 3100 instrument will be used to determine the presence of hydrocarbon non-aqueous phase liquid (NAPL) (which are commonly present as diesel range organics [DRO] and gasoline range organics [GRO]) at concentrations greater than approximately 50 mg/kg. The LIF or UVA survey will be followed by the collection of soil samples from the surface and subsurface zones.
One Groundwater monitoring well will be installed up gradient and three groundwater monitoring wells will be installed down gradient of anomalies 4 and 13. During excavation trenching at Anomaly 4 and during the drilling operations at anomalies 4 and 13, soil and groundwater samples will be collected for determination of GRO, DRO, RRO VOCs, SVOCs, PAHs, PCBs, organochlorine pesticides, and metals by the definitive methods listed in Table 3. In addition, one soil and one groundwater sample will be collected from anomaly 13 for determination of dioxins and furans. Anomalies and screening data collection activities will be extensively photographed and a photograph log indicating the location and number of each photograph will be prepared. |
Louis Howard |
| 8/16/2007 |
Update or Other Action |
Staff received from the Air Force: Radiation Source areas at SS-22 technical memorandum internal request to their USAF Radioisotope Committee (RIC). Request approval to proceed with planned environmental investigation of Site SS-22, Elmendorf AFB Alaska, considering recent discovery of limited areas of elevated radioactivity on the site. Request decision by close of business 17 Aug 2007.
Geophysical anomalies 2 & 3 located north of the railroad spur were consistently used as a scrap material staging area from 1962 through 2003. Two locations in Anomaly 2 and one location on the boundary of anomalies 2 & 3 were found to contain elevated readings ranging from 102K cpm to 282K cpm with a 3” x 3” NaI detector during the limited radiological scoping survey. Anomaly 11 lies on the southern site boundary fence line. A closed landfill lies to the south beyond the site boundary (Figure 2). A single detection at 42K cpm was identified along the southern fence line in this area. Both the 1982 and 1993 aerial photos show a pile of scrap material that is located to the south, outside the site boundary.
Upon discovery of areas of elevated radioactivity, planned field activities ceased and the base RPM and Elmendorf RSO were notified. The RSO in turn notified the USAF Radioisotope Committee (RIC) Secretariat and performed additional site measurements using a Berkley Nucleonics SAM 935 Gamma Spectrometer. The in-field results of the SAM 935 were indeterminate and the spectral files were sent to the Air Force Institute of Occupational Health (AFIOH).
Additional analysis of the spectral files by AFIOH tentatively identified the isotope of concern as Radium-226. Additionally, the RSO collected soil samples that have been submitted to the AFIOH for laboratory analysis. Gamma spectroscopic analysis of the soil sample was completed by AFIOH on 15 Aug 07 and confirmed Ra-226 as the radioisotope of concern.
Radiological investigation to date has demonstrated very small areas of elevated radioactivity that are consistent with historical storage of demilitarization debris piles. The likely source of elevated activity is incidental contamination by radium containing commodity items that passed through the DRMO facility. Considering the above analysis, the Air Force would like to proceed with the investigation of the non-impacted areas of SS-22 (areas outside of anomalies 2, 3, and 11).
However, erring on the side of caution, all intrusive activities will be conducted with appropriate health physics monitoring to include surface gamma measurements at all areas to be intrusively investigated and contamination monitoring of all equipment in contact with surface and subsurface soils. The project health and safety manual will be expanded to include health physics procedures and requirements. If elevated radioactivity is found as a result of this monitoring, activities will cease and the Elmendorf RSO will be notified immediately. |
Louis Howard |
| 8/21/2007 |
Update or Other Action |
Email from Air Force G. Verplancke: We have received clearance through Air Force Industrial and Occupational Health (AFIOH0) and the Radioactive isotope Committee (RIC) to proceed with field screening in areas that did not show elevated radioactivity as proposed in our Technical Memorandum for collection of screening data. The health and safety plan for the site is currently being re-worked to included provisions for insure that works are not exposed to radioactive substances and that no cross contamination occurs. As soon as the Health and Safety Plan is complete I will forward a copy to each of you. Also, I have attached a copy of the request that was sent to the RIC requesting approval to proceed with the screening effort. It gives a pretty good synopsis of activities conducted thus far. |
Louis Howard |
| 8/22/2007 |
Spill Transferred from Prevention Preparedness and Response Program |
Spill no. 07239923302. Source may likely be from elevated activity of incidental contamination by radium containing commodity items that passed through the DRMO Facility. Substance Radium 226.
Transferred to Louis Howard in CSRP due to active CS site with his management. |
Louis Howard |
| 8/23/2007 |
Update or Other Action |
Ra-226 was used until the late 1960s/early 1970s in self-luminous paints for watches, aircraft switches, clocks, and instrument dials. Because of its gamma emission properties, Ra-226 was also used in various industrial applications such as radiation monitoring instrument calibration facilities, industrial radiography cameras, oil well logging instrumentation, and many others. The time required for the intensity to decrease by one-half is referred to as the “half-life”. The half-life of Ra-226 is 1600 years.
Certain low-level radioactive wastes are authorized to be disposed of in hazardous waste disposal sites pursuant to Subtitle C of the Resource Conservation and Recovery Act (RCRA). Generally, disposal of radium sources in RCRA hazardous waste sites is very limited. The EPAct very specifically states that the disposal of these sources does not fall under the Low-Level Waste Policy Act.
Discrete sources of radium retain their identity as discrete sources even when co-mingled with soil and building rubble. Any discrete source created for a commercial use retains that identity throughout the source lifetime. “Discrete” radium need not be encapsulated; for example, the contaminated soil associated with the radioactive rubble is also defined as discrete. |
Louis Howard |
| 9/24/2007 |
Update or Other Action |
A Phase 1 field investigation that included site reconnaissance, radiological scoping survey, soil-screening activities, test pit trenching, GW monitoring well installation, & definitive soil & GW sample collection was performed in 2007. The investigation was conducted to determine whether subsurface geophysical anomalies identified in previous investigations (USAF 2002) & visually observed physically distressed areas or other potentially contaminated areas have contributed to soil or GW contamination.
The geophysical survey identified 2 areas of particular interest: Anomalies 4 & 13. In order to determine if past operations at these anomalies posed an imminent threat to GW, soil & GW samples were collected for lab analysis. Soil sampling locations were based on screening data results. Exceedances for the collection of definitive data were based on EPA Region 6 residential soil PRGs & ADEC method 2 screening levels found in 18 AAC 75 Tables B-1 & B-2 (ADEC 2006), & screening levels for GW were derived from EPA Region 6 tap water PRGs & 18 AAC 75 Table C (ADEC 2006). These values helped identify nature & extent & delineate possible contaminant sources.
8 wells were installed during the investigation at SS22. All of these wells were completed in the water table aquifer above the Bootlegger Cove Formation in glacial outwash deposits. These deposits have a relatively high hydraulic conductivity as confirmed by recoveries monitored during well development. Wells SS22MW01 through SS22MW04 were installed in association with Anomaly 13 in the southern part of the study area. The water table was found to be approximately 40 to 42 feet bgs. Based on preliminary water level measurements, the GW flow appears to be slightly north of due west, with an approximate gradient of 12.5 feet per mile.
Wells SS22MW05 through SS22MW07 were installed up- & downgradient in association with Anomaly 4. Well SS22MW08 was installed farther downgradient of Anomaly 4 due to its close proximity to Anomalies 2 & 3. This well could not be placed directly downgradient of Anomaly 4 because the area of Anomaly 3 is restricted until the radiological concerns have been addressed. Wells were installed across the top of the water table in this highly permeable glacial outwash alluvium. One perched water zone was located at SS22MW05 at 18.0 feet bgs associated with a silt zone of approximately 0.25 foot in thickness. The water table aquifer in these wells was encountered at approximately 48 to 50 feet bgs. Based on water level measurements at these four wells, GW flow direction in this northern part of SS22 trends northwest with a gradient of approximately 11.3 feet per mile.
Based on a review of the 2007 screening data results, the following anomalies were identified as possible areas of contamination related to petroleum, oil, & lubricants (POL), VOCs or RCRA metals: Anomalies 4, 6, 7, 10, 12, 13 & the distressed area. Radium-226 (Ra-226) was identified as a radioisotope of concern in soil at Anomalies 2, 3, & 11 & is considered a COPC in these areas. Four test pits were excavated at Anomaly 4 using a backhoe, one each on the north, south, east, & west sides of the anomaly boundary. Starting outside the boundary each test pit was excavated to a depth of 12 to 15 feet bgs & then proceeded inward toward the center of the anomaly until metallic debris or crushed drums were encountered. Near surface (0.5 to 3 feet bgs) crushed drums & other metallic debris were observed in the north, south & west trenches, & at a maximum depth of 10 feet bgs in the test pit excavated along the eastern edge of Anomaly 4.
Detections of “significance” for field screening include levels greater than project screening levels for metals using XRF, & readings greater than 25 PPM for VOCs using the PID. For LIF, “significance” is determined by interpreting the characteristics of the detected waveform & the magnitude of the detection. EPA regional screening levels (RSLs) for residential soil were used (& ambient base-wide metal concentrations in soil at JBER-Elmendorf) & when a RSL value was not available, the screening deferred to State levels.
See site file for additional information. |
Louis Howard |
| 10/11/2007 |
Update or Other Action |
Quality Assurance Report ElmendorfSS-22 Remedial Investigation Sampling, August/September 2007 Test America SDG D7I100140. Sample -002 (SS22MW03S03841) was incorrectly identified on the chain of custody (COC) as SS22MW03S002N2. The sample was collected at SS22MW03 but from a depth of 38-41 feet below ground surface (bgs), and not from 0-2 feet bgs as indicated in the field sample ID. The discrepancy was not identified until after the data had been reported. The depth information was corrected during validation. Gasoline range organic (GRO) analysis by method AKI 0 1 was cancelled for samples -002, -004 and -005 because of methanol loss during shipment.
Samples -004 and -005 were re-collected for AK10l and reported in SDG D71250283. Sample -002 was mistakenly identified as a surface soil sample but was collected from a depth of 38-41 feet and could not be re-collected. Because the sample was collected outside of the associated anomaly (anomaly 13); only low concentrations of GRO were detected site-wide; and the associated water sample results for GRO was less than the reporting limit; this data gap should not affect the project objectives. The reporting limits are less than ADEC soil screening levels for the undiluted sample (-002). Because sample extracts for samples -001, -004 and -005 were oily, dark colored and viscous the laboratory was unable to analyze the samples undiluted.
The laboratory used a 4X dilution for the affected samples. All elevated reporting limits were still less than the soil screening levels except for benzo(a)pyrene and dibenz(a,h) anthracene. However, the elevated MDLs for benzo(a)pyrene (0.00066 mglkg) and dibenz(a,h) anthracene (0.011 mglkg) were both less than the soil screening level (0.015 mglkg for both). Data usability is not affected. Some screening criterion were not analytically possible. This was noted in the work plan and QAPP prior to sample collection. Data quality or usability affected? This will be evaluated during risk assessment. |
Louis Howard |
| 10/11/2007 |
Update or Other Action |
Quality Assurance Report ElmendorfSS-22 Remedial Investigation Sampling, August/September 2007 Test America SDG D7I100140. Sample -002 (SS22MW03S03841) was incorrectly identified on the chain of custody (COC) as SS22MW03S002N2. The sample was collected at SS22MW03 but from a depth of 38-41 feet below ground surface (bgs), and not from 0-2 feet bgs as indicated in the field sample ID. The discrepancy was not identified until after the data had been reported. The depth information was corrected during validation.
Gasoline range organic (GRO) analysis by method AKI 0 1 was cancelled for samples -002, -004 and -005 because of methanol loss during shipment. Samples -004 and -005 were re-collected for AK10l and reported in SDG D71250283. Sample -002 was mistakenly identified as a surface soil sample but was collected from a depth of 38-41 feet and could not be re-collected. Because the sample was collected outside of the associated anomaly (anomaly 13); only low concentrations of GRO were detected site-wide; and the associated water sample results for GRO was less than the reporting limit; this data gap should not affect the project objectives. The reporting limits are less than ADEC soil screening levels for the undiluted sample (-002). Because sample extracts for samples -001, -004 and -005 were oily, dark colored and viscous the laboratory was unable to analyze the samples undiluted. The laboratory used a 4X dilution for the affected samples.
All elevated reporting limits were still less than the soil screening levels except for benzo(a)pyrene and dibenz(a,h) anthracene. However, the elevated MDLs for benzo(a)pyrene (0.00066 mglkg) and dibenz(a,h) anthracene (0.011 mglkg) were both less than the soil screening level (0.015 mglkg for both). Data usability is not affected. Some screening criterion were not analytically possible. This was noted in the work plan and QAPP prior to sample collection. Data quality or usability affected? This will be evaluated during risk assessment. |
Louis Howard |
| 10/12/2007 |
Update or Other Action |
Quality Assurance Report Elmendorf SS-22 Remedial Investigation Sampling, August/September 2007 Test America SDG D7I080115 dated October 12, 2007. The following subsections present an evaluation of the data for each data quality indicator associated with the soils for the RV storage parking lot expansion (soils from sites SS22MWOI, SS22MW02, SS22MW03, & SS22MW04) reported in SDGs D7I080115, D7Il00138, D7IlOOI40, D7IlOOI50, & D71250283. Sample -003 (SS22MWOIS02530) was listed on the COC twice for Method 8082 & was also reported as sample -004 (for all methods). Sample -003 Method 8082 results were the same as sample -004 results & the sample -003 Method 8082 results are not preferred & will be reported from sample -004 for consistency.
The soil samples were preserved using methanol preservation (QC Batch 7256046) per State of Alaska requirements. However, because the reporting limits for the methanol preserved samples was greater than the screening levels for many of the target analytes, samples were also collected using sodium bisulfate preservative (QC Batch 7256377) to achieve lower reporting limits. The methanol preserved samples were collected in pre-tarred vials with 5 grams of methanol instead of 5 mL of methanol (6.6 mL). The laboratory corrected for the actual volume of methanol used & resulted in an effective dilution of 1.32 raising the reporting limits by a factor of 1.32.
Data usability was only minimally affected because only the reporting limit for chloroform (0.25 mglkg) increased from a value below the screening level to a value greater than the screening level (0.25 mglkg to 0.33 mglkg). All other methanol preserved reporting limits were either already greater than the screening level or did not increase to a value higher than the screening level. The analytical data packages were complete. Because of sample matrix & chromatographic limitations benzo(b)fluoranthene & benzo(k)fluoranthene could not be resolved in samples -002, & -005. The benzo(b )fluoranthene reported should be considered a combination of the two. Benzo(b )Fluoranthene results are qualified for MS/MSD recovery & results for benzo(k)fluoranthene were UM qualified in addition because of the matrix effect causing the lack of resolution between benzo(b )fluoranthene & benzo(k)Fluoranthene.
A MS/MSD was not requested on any samples in this SDG. Sample -004 (SS22MW04S002) was collected for MS/MSD in SOG 0711 00 140. Percent recoveries (%Rs) & relative percent differences (RPOs) were within the QAPP limits except as summarized in the following table. Because the recoveries for benzo(b)fluoranthene & cbrysene were less than the lower control limits those results were M/UM qualified in all the associated samples (soils from sites SS22MW01, SS22MW02, SS22MW03, & SS22MW04). Because DDT & methoxychlor in all investigative samples were reported from analysis of a 10X dilution & the MS/MSD was analyzed un-diluted results for DDT & methoxychlor in all associated samples were M/UM qualified because of the MS/MSD outliers & the different dilution used between the reported samples & the MS/MSD. Because the recoveries for beta-BHC DDD, & DDE were less than the lower control limits, beta-BHC, DDD & DDE results were qualified M/UM in all the associated samples (soils from sites SS22MWOl, SS22MW02, SS22MW03, & SS22MW04).
Fifty five of 63 RPDs between the MS & MSD results for method 8260B sodium bisulfate preserved soils & one of 63 RPDs in the methanol preserved soils were greater than SS 22 QAPP specified limits, indicating imprecision in the Method 8260B sodium bisulfate results. Acetone was the only target analyte detected in methanol preserved soils by method 8260B & therefore, the only result affected by the imprecision. RPDs between the field duplicate & parent sample for field duplicate pairs were within SS 22 QAPP specified limits, with the exception of arsenic, barium, & manganese (Method SW6020); & benzo(a)antracene (Method SW8270C w/SlM) RPDs. There may be some imprecision in the qualified results for these analytes. MS/MSD recoveries for Method SW8260B methanol preserved soils were less than SS22 QAPP limits for methylene bromide & trichloroethene. The UM/M qualified results for methylene bromide & trichloroethene in all methanol preserved samples may have an associated low bias.
Conclusion Samples collected during this sampling event were successfully analyzed and are acceptable for project use except for antimony. The remaining results qualified during data validation are usable, however, some inaccuracy and/or imprecision may be associated with the qualified results. |
Louis Howard |
| 1/16/2008 |
Meeting or Teleconference Held |
A meeting of the remedial project managers (RPMs) convened at 0830 on 1 6 January 2008 in the Environmental Flight (3 CESICEV) Conference Room, Building 53 12, at Elmdorf Air Force Base (EAFB), Alaska. Attendees included: Mr , Jacques Gusmano (Environmental Protection Agency [EPA]), Mr. Louis Howard (Alaska Department of Environmental Conservation [ADEC), Mr. Joe Williamson (CEVR), Mr. Claude Mayer (CEVR), Mr. Gary Fink (CEVQ), Mr. Glen Verplancke (CEVR), Ms. Melissa Markell (CEVR), and Ms. Donna Baumler (CEVR). Air Force Center for Engineering and the Environment Restoration-Program Management Office (AFCEE R-PMO) Program Review (Mr. Williamson).
The AFCEE R-PMO program review was held on 12-13 December 2007 and it was a good review of our program. This review supports the transition underway with AFCEE taking over the management of the Air Force Environmental Restoration Program (ERP). The change-over will be a bumpy road because no special funding was set aside to accomplish this new way of doing business. Beginning with FY09 projects, AFCEE will be responsible for project validation, funding, and execution. Funds will flow directly from Air Staff to AFCEE. MCEE plans to validate up to 5 years of site requirements for reoccurring remedial actionoperation (RA-0) projects. PACAF will continue to validate and fund the manpower and management projects. The schedule for FY09 will be project validation between May and July 2008. Currently, we have not received funding for our FY08 projects. We expect authority to advertise by the end of Jan 2008.
The Civil Engineer Squadron is also amidst a transformation. The Environmental Flight will be reorganized and Restoration personnel will either be a part of the Asset Management or Programs Flight. We anticipate this change to occur in the next 6 to 8 months. Additionally, Joint Base Elmendorf-Richardson (JBER) has been delayed to 201 0. The property bomdaries of the joint base have not yet been determined. b. Zone 1 Update (Mr. Verplmke). (2) 5522 Remedial Investigation and Fmibility Study (RVES) Status. A technical memorandum is in draft status to dlow us to sit down with tbe contractor and discuss the radiation issue.
Radiation Screening (field and subsurface) took place over the 20-acre site with no additional weas of radioactive contamination being detected. Bioenviromental is working with the Radioactive Isotope Committee WC) to get applicable base permits and to detedne next step to assess the extent of the radiatio~lc ontamination. The tech memo and work plan are king reviewed by MCEE prior to their submittal to the agencies. |
Louis Howard |
| 1/30/2008 |
Update or Other Action |
Quality Assurance Report ElmendorfSS-22 Remedial Investigation Sampling, August/September 2007 Test America SDG D7I100138. The samples were received at the laboratory at 12°C, outside the 4 ± 2 °C temperature criteria, and analyzed within the 14-day holding time for VOCs. Because the cooler was delayed in transit and samples could not be re-collected, results not otherwise qualified were qualified J/UJ because of the temperature exceedance. The samples were received at the laboratory at 12°C, outside the 4 ± 2 °C temperature criteria, extracted within 14-days and analyzed within the 40-day holding time for SVOCs. Because the cooler was delayed in transit and samples could not be re-collected, results not otherwise qualified were qualified J/UJ because of the temperature exceedance.
The samples were received at the laboratory at 12°C, outside the 4 ± 2 °C temperature criteria, extracted within 14-days and analyzed within the 40-day holding time for DROIRRO for the original extraction in QC Batch 7255586. However, the LCS %R for DRO in Batch 7255586 (69%) and LCSD (63%) were less than the lower control limit of75% for DRO. Samples were re-extracted in QC Batch 7260409 with acceptable LCS/LCSD recoveries. The re-extraction of samples -001 and -002 was performed 3 days after the holding time expired (17 days after collection). Both sets of data were reported. To be most protective of human health and the environment the higher result was chosen as preferred. Results in samples -00 I and -002 are preferred in QC batch 7255586 and J qualified for the low LCS/LCSD.
Results for the re-extracted samples in QC Batch 7260409 are not preferred and flagged NP. Because the cooler was delayed in transit and samples could not be re-collected, results not otherwise qualified were qualified J/UJ because of the temperature exceedance. The samples were received at the laboratory at 12°C, outside the 4 ± 2 °C temperature criteria, extracted within 14-days and analyzed within the 40-day holding time for pesticides. Because the cooler was delayed in transit and samples could not be re-collected, results not otherwise qualified were qualified J/UJ because of the temperature exceedance. |
Louis Howard |
| 3/13/2008 |
Meeting or Teleconference Held |
MEETING MINUTES Triad Planning Meeting for Remedial Investigation at SS22, Elmendorf AFB 13 March 2008. AF RPM: Completed introductions, explained meeting format, outlined meeting agenda, & identified the Anomaly Summary Document as the primary tool to outline the Phase 2 definitive sampling approach to be discussed at the Triad meeting. Contractor : Introduced the site & provided an overview of the screening technologies used during Phase 1 & the radiological survey. Provided overview of the radiation survey completed during Phase 1, which included a gamma walk-over using a sodium iodide (NaI) detector.
Discrete “point sources” were identified within Anomalies 2, 3, & 11. Surface soil samples collected by Elmendorf Bioenvironmental staff were sent to the AFIOH laboratory in San Antonio, TX; the laboratory confirmed the presence of radium-226 (Ra-226). Ra-226 is typically found in luminescent paint used on aircraft & watch dials in the 1940s & 1950s & is the most common source of Ra-226 at DRMO sites. Further investigation will be conducted following MARSSIM guidance to define the nature & extent of radiological contamination & provide sufficient information to conduct a risk assessment.
611th JA: Raised the question of whether public access needs to be restricted. AF RIC: A small fence barricading the area & signage indicating radiation contamination would be sufficient. Formal notification should be filed by the Air Force. AF RPM: Elmendorf has a Dig Permit process in place that needs to be completed prior to any intrusive work on base.
This permit process should help prevent unauthorized digging within SS22.
ACTION ITEMS For the Air Force: • Internal memo to be placed on file documenting need for restricted access at SS22. • Signage posted near access points indicating site has radioactive contamination; closing off public access. • Risk communication fact sheet to be prepared to brief the DRMO facility personnel. For Earth Tech: • Anomalies 2, 3, & 11 will require a walk-over MARSSIM survey, which will classify areas based on potential contamination & statistically identify sampling locations. Laboratory samples should be scanned for radiation prior to shipment. • Research historical information regarding radioactive substances at DRMO facilities & add this information to the work plan.
Contractor Anomalies 2 & 3 Provided overview of the site; no screening/definitive data collected in these anomalies during Phase 1 due to radiation issues. Recommend five discrete sampling locations for each anomaly & collection of soil samples from the surface & subsurface. Two of the sampling locations will be co-located near radiation source areas. Samples will be analyzed for Ra-226, SVOCs, pesticides, PCBs, GRO, DRO, & metals. VOCs will be added to the analytical suite for subsurface samples. Earth Tech will do the risk assessment for chemical investigation & AFIOH will do risk assessment for radiological investigation. (Earth Tech will conduct the risk assessment as well as the MARSSIM walk-over survey & sample collection, not AFIOH.
This was clarified & confirmed between Earth Tech & 3 CES/CEANR following the Triad meeting). Most Ra-226 sources at DRMO facilities are small & do not typically migrate more than a few feet from their source. ADEC: Discrete sampling points are not acceptable to ADEC for clean closure because there could be a release in the future. Long-term monitoring would be required. EPA: During the geophysical survey no trenching was completed in Anomaly 2. Trenching did not find the total depth of buried debris in Anomaly 3. Knowing the depth of burial & contents could help target sampling locations & analyses of COPCs. Recommend adding trenching activities within Anomalies 2 & 3 to determine debris type & burial depths, & collection of subsurface soil samples within the trenches. Trenching activities should be documented in the field log with numerous photos. Contractor: Confirmed that excavated material removed during trenching activities may be placed back within the excavation at the conclusion of trenching activities & need not be managed as investigation-derived waste.
Anomaly 11 EPA & ADEC: Recommended trenching activities within Anomaly 11. Use the same sampling strategy as used for Anomalies 2 & 3. AF RPM: Due to highly technical & specific radiation discussion, parties on the phone (AFIOH, RSO, Earth Tech) are advised to continue discussion off-line. Technical approach will be documented in work plan.
See site file for additional information. |
Louis Howard |
| 3/21/2008 |
Enforcement Agreement or Order |
Memorandum for Federal Facility Agreement Schedule addition for Site SS22.
Attached for your review and acceptance is the proposed document schedule for Site SS22 on EAFB. If approved, the schedule will be attached to the current FFA (September 25, 1991).
For the purposes of the FFA attachement, the proposed schedule lists quarters of the calendar year for document review due dates. Precise due dates for each document review period will be developed as the project progresses. |
Louis Howard |
| 5/20/2008 |
Document, Report, or Work plan Review - other |
Staff reviewed & commented on the SS-22 Remedial Investigation - Feasibility Study (RI/FS) Draft Final Work Plan. The Work Plan is actually part of a CERCLA RI/FS Management Plan , which includes a work plan, as required by the September 19, 1991 Federal Facility Agreement (FFA) for Elmendorf Air Force Base. ADEC requests the Air Force add a new section 1.3.1 called “Scoping Documents” & use the text below.
The RI/FS will be carried out in accordance with project scoping documents. The purpose of the project scoping documents is to clearly define project activities before beginning the field work. The Air Force, US EPA, & ADEC review & approval of these documents ensures that project goals & other applicable requirements will be met. Format guidance for the management plan, the sampling & analysis plan & health & safety plan is provided in EPA’s “Guidance for Conducting Remedial Investigations & Feasibility Studies under CERCLA, Interim Final" (October 1988) EPA/540/G-89/004, OSWER Directive 9355.3-01.
Baseline risk assessment consisting of human health & ecological risk assessments. The TRIAD approach presented in this document of analyzing the data in conjunction with the site investigation planning is inconsistent with the EPA CERCLA approach for human health & ecological baseline risk assessments. ADEC questions the validity of conducting a baseline human health & ecological risk assessment during the field season rather than after the data has been analyzed & has undergone rigorous quality assurance review.
The text provided in this section is inadequate as a risk assessment work plan. Please refer to: EPA’s guidance documents: Risk Assessment Guidance for Superfund, Volume I- Part A 1989); Part B (1991); Part C (1991); Part D (1998); • Part E (2000); Supplement to Part A: Community Involvement in Superfund Risk Assessments (1999); Ecological Risk Assessment Guidance for Superfund: Process for Designing & Conducting Ecological Risk Assessments - Interim Final (1997); “Issuance of Final Guidance: Ecological Risk Assessment & Risk Management Principles for Superfund Sites” OSWER Directive 9285.7-28 P (October 1999); & ADEC’s Draft 2005 Risk Assessment Procedures Manual (November 2005) for guidance on the required documents & information to be provided in the risk assessment work plan.
Risk characterization & risk assessment shall be separated in this section since they are two different things. Risk assessment is based on a series of questions that the assessor asks about scientific information that is relevant to human &/or environmental risk. Each question calls for analysis & interpretation of the available studies, selection of the concepts & data that are most scientifically reliable & most relevant to the problem at hand, & scientific conclusions regarding the question presented. The text states: “Some media concentrations, such as indoor & outdoor air, will not be measured directly; rather, the media concentrations will be modeled using phase partitioning & fate & transport models.
Exposure point concentrations will be determined by medium for each exposure area. The exposure areas will be identified through the site investigation work.” Use of any phase partitioning models will require prior review & subsequent approval by ADEC & EPA before being used. Please identify any modeling programs being considered for SS22 & how they will be used as well as assumptions for each of the models.
The text states that only public-domain programs or peer-reviewed, widely distributed, & generally accepted "modified" public-domain programs will be used for phase partitioning, fate, & transport remediation calculations. EPA & ADEC will be provided with specific program information & calculation details as part of the Triad meetings & in the RI/FS report. Prior review, comment & subsequent approval (or no approval) of all programs being considered for modeling purposes at SS22 will be required by ADEC & EPA. ADEC wishes to clarify the reference to "modified" portion of the statement. When a public domain program has been modified it can no longer be considered a public domain program. A modified public domain model can still be proposed for use if it is peer reviewed, widely distributed, & generally accepted. Compared to public domain modeling programs, proprietary modeling programs, without proper review & general acceptance, provide a lower level of confidence in making site cleanup decisions.
The text states: “During site reconnaissance, crushed barrels, lead acid batteries, miscellaneous vehicle parts, machine parts, welding gas cylinders, scrap metal, electrical transformers, & fire brick were identified.” It appears the debris pile (stockpile) does not comply with state & federal laws/regulations regarding proper disposal of broken lead acid batteries, transformers & other solid waste. |
Louis Howard |
| 5/29/2008 |
Document, Report, or Work plan Review - other |
EPA Comments on Work Plan for SS22 (Former DRMO Storage Yard) Area. The Draft Final Work Plan Remedial Investigation through Feasibility Study (RI/FS), SS22 (Former DRMO Storage Yard), Area 1 – Elmendorf Air Force Base, Alaska, (hereafter referred to as the SS22 RI/FS WP) is disorganized & fragmented. Based on the current presentation of information, it is difficult to understand the site history & ascertain the proposed field work. The SS22 RI/FS WP should provide sufficient detail for the field team to readily understand the existing information for each unit being investigated & the objectives of each proposed sample. In addition, descriptions must be clear, concise, & comprehensive so stakeholders obtain a general idea of the site history & proposed work, with references to additional information in Appendices being acceptable.
Please include additional detail on site history, previous, & proposed work in the SS22 RI/FS WP so it can function as a stand-alone document. For example, a figure with proposed sample locations, & a table presenting previous contaminant exceedances, proposed analyte lists, & the previous and proposed sampling information provided in Appendix B, should be included in the main text of the SS22 RI/FS WP. Given the lack of information presented in & the disorganization of the SS22 RI/FS WP & the Field Sampling Plan (FSP), presented as Attachment 1 to Appendix A, it is unclear if the proposed sampling strategy is adequate to meet the objectives of the RI/FS.
Please revise the SS22 RI/FS WP to address these issues. There are numerous instances within the SS22 RI/FS WP where the term “anomaly” is referenced. In some cases, a numerical identifier is used in conjunction with “anomaly” to reference a specific location (e.g., Anomaly 4 & Anomaly 13). No further written description enabling the reader to comprehend the geography of these specific locations is provided. Although figures have been provided illustrating the anomaly locations, please consider providing additional descriptive information in the text. A clearer understanding of the Anomaly locations should be conveyed to the reader by referencing its spatial/geophysical location.
The SS22 RI/FS WP & FSP are disorganized & constitute a fragmented presentation of the proposed field tasks. Therefore, it is difficult to understand the full scope of the project & the timeline by which the different phases of the project will occur. Section 6 of the FSP begins to clarify these issues; however, a clear & concise summary of the proposed work is required in main text of the SS22 RI/FS WP for a clearer understanding of the proposed sampling approach & to ensure the sampling program is properly implemented by the field team. Please revise both the SS22 RI/FS WP & FSP to include a comprehensive summary of proposed field tasks, including the timeframe in which tasks will occur.
Please revise the FSP to clearly explain the decision logic behind the evaluation of screening data & selection of additional sampling locations & depths. Consider adding one or more decision logic flowcharts for clarification & to facilitate decision-making in the field. It is unclear how screening data will be used in the context of delineating the extent of vertical & horizontal contamination at the site. Section 6, Screening Analytical Methods, provides an overview of field & laboratory analyses that are identified as the source of screening data. However, no description is provided as to how the data will be used in making project decisions and in meeting project/data quality objectives.
Please describe the purpose of the screening data, how it will be evaluated & what decisions it will be initiating. A flow chart illustrating decision steps would prove most practical. Please revise Section 6 to address these issues. According to the meeting minutes presented in Appendix B, it appears a consensus has been reached by regulators regarding the proposed sampling locations, number of samples, & analyses for each anomaly. This detailed information needs to be included in both the main text of the SS22 RI/FS WP & the FSP so the SS22 RI/FS WP & FSP can function as stand-alone documents. Furthermore, this will furnish the field team with all the information necessary to properly implement the sampling program. A figure illustrating all proposed sampling locations should also be included in both the SS22 RI/FS WP & FSP.
Additionally, there are apparent discrepancies between regulator statements recorded in the meeting minutes & the proposed sampling presented in the Anomaly Summaries. For example, regulatory comments indicate field screening is not a substitute for definitive data & cannot be used to confirm that no release has occurred. However there are a number of cases where sampling for GRO, DRO, RRO are omitted based on field screening results. Please clarify these apparent discrepancies. |
Louis Howard |
| 6/5/2008 |
Update or Other Action |
3 AMDS/SGPB Air Force sent 3 CES/CEANR a memorandum RE: SS22 RI through FS review. Bioenvironmental Engineering (BE) evaluated the work plan for the remedial investigation/feasibility study ofSS22 (former DRMO storage yard), Area 1, Elmendorf AFB, AK. BE acts as the installation Radiation Safety Officer (RSO) in accordance with API 40-201, Managing Radioactive Materials in the US Air Force, and is responsible for managing the base radiation safety program. BE is working in coordination with the USAF School of Aerospace Medicine Health Physics Consulting (USAFSAM/OEHRH) for technical assistance, and the USAF Radioisotope Committee (RIC).
In August 2007, BE validated contractor findings of radiation above background levels in four locations on site. Soil analysis by USAFSAM/OEHRH confirmed that Radium-226 is present. Radium waste on Air Force installations is commonly a result of disposed radium-painted dials and gauges from aircraft and vehicles, which exhibit low levels of radioactivity. At that time the RIC approved continuation of remedial investigation in the unaffected areas. All radiation levels detected are well below applicable limits. Further investigation is needed in order to characterize the radiation source. Radiation exposures to personnel on and near the SS22 site are not expected to exceed the public dose limit of 100 mrem per year. Additionally, the contractor's work plan implements all necessary controls to mitigate risk of personnel exposure and spread of contamination.
Controls include restricted access to the work site, on-site monitoring by a health physicist, decontamination of personnel and equipment, and oversight by the RSO. If at any point the radiation levels exceed 0.5 mR per hour, workers will exit the area and notify the appropriate agencIes. Upon review of the work plan and after consulting with USAFSAM/OEHRH, BE approves the initiation of field work at SS22 to further characterize the source of radioactive contamination, among other remediation investigation activities. BE's health risk assessment concluded that there is no current hazard to personnel and all precautionary controls will be in place. Questions regarding this information may be directed to me at 552-3893 or MSgt Kim at 552-3885. Signed Patrick J. Ryan Capt, USAF, BSC, Bioenvironmental Engineer. |
Louis Howard |
| 6/23/2008 |
Update or Other Action |
Air Force sent over spreadsheet and proposal for sampling at SS22 to EPA and ADEC RPMs. SS22 RI/FS Management Plan document edits are underway. The project chemists and risk assessors have proposed approaches for a few items where problems were identified in the previous document. Please see below, and let me know if you concur or if we need to discuss. If discussions are necessary, I'll make sure that the appropriate project team members can participate to address the technical details.
1. VOC Soil Analyses: We propose collecting two 5 g of sample into 5 mL of water and preserving in the field by freezing to -10 degrees C per method 5035. These VOC samples will be packed with an ice/salt slurry into 5-day X-treme coolers to ensure samples remain frozen during transport to TestAmerica Denver. The hold time from sampling to analyses is 14-days using the freezing preservation.
Sodium bisulfate will not be added as a preservative because foaming was occasionally observed during the 2007 field season when sodium bisulfate was used as a preservative for VOCs. SW 846 Method 5035, as well as the AFCEE QAPP 4.0.02, allows for the freezing of low level VOC samples as preservation method, particularly when foaming occurs with the sodium bisulfate preservative.
This low-level preservation method is necessary to achieve VOC reporting limits less than the EPA Regional human health screening levels for chemicals at Superfund sites. Methanol preservation is not proposed because it raises the reporting limits for five VOCs, including vinyl chloride, to greater than the human health screening values. However, one 5 g aliquot of the sample will be collected into 5 mL of methanol in case a dilution is required. If no dilution is required, the methanol preserved aliquot will not be analyzed. In addition, soil will be collected for percent moisture determination.
Please note that samples for GRO analyses will be collected into methanol (25 g soil to 25 mL methanol) per method AK101.
2. Risk assessors will compare MDLs to human health screening values for target analytes that are 100% not-detected. Per AFCEE, non-detect results are reported to the MDL with a U flag.
3. For groundwater, the laboratory's MDLs for several target analytes are greater than the human health screening levels. These are aldrin, dieldrin, heptachlor epoxide, toxaphene, the PCBs, 1,1,2,2-tetrachloroethane, 1.2-dibromo-3-chloropropane, ethylene dibromide, tetrachloroethene, vinyl chloride, 3,3'-dichlorobenzidene, Bis(2-chloroethyl) ether, Hexachloroethane, N-Nitrosodi-n-propylamine, benzo (a) pyrene, dibenz (a,h) anthracene, arsenic, 2,3,7,8 TCDD, 1,2,3,7,8-PeCDD, and pentachlorophenol. The screening level table is attached for reference. For most of these analytes, lower MDLs are not available. These analytes will be discussed in the uncertainty section of the risk assessment. |
Louis Howard |
| 6/24/2008 |
Document, Report, or Work plan Review - other |
Staff provided comments on the SS22 Items for consideration:
1) The 2007 VOC samples which "foamed" are invalid. ADEC requests the Air Force verify that these samples (from 2007) will be re-sampled this field season. If the proposed salt/ice slurry is inadequate to maintain < -7 degrees C, the VOC samples must be analyzed or frozen at the laboratory within 48 hours from the time of sampling.
2) The screening levels presented in the table for review are not adjusted to an HQ of 0.1. The Regional Screening Levels Tables provide SLs corresponding to a 10-6 risk level for carcinogens and an HQ of 1 for noncarcinogens. ADEC requires screening for cumulative risks from non-carcinogens at the HQ of 0.1. 3) EDB and DBCP should be analyzed by EPA Method 504.1 or SW846 Method 8011 to achieve lower detection limits. |
Louis Howard |
| 6/25/2008 |
Document, Report, or Work plan Review - other |
EPA sent over comments on the Air Force's SS22 Items for your consideration. EPA agrees with the comments made by ADEC.
Region 6 PRGs for residential exposure for carcinogens are used for screening for human health risk without modification. The Region 6 PRG values for non-carcinogens are based on a hazard index of 1, so screening levels for these chemicals are divided by 10.
When no Region 6 PRGs exist, ADEC cleanup levels are employed. ADEC cleanup levels are divided by 10 for risk screening purposes. If contaminants were not detected, detection limits should be evaluated in the screening process by comparing 1/2 the MDL value to screening levels. (ADEC,2005a) If 1/2 the MDL is less than the screening level then the non-detected contaminant may be eliminated from further evaluation. If 1/2 the MDL is greater than the screening levels then the contaminant is addressed in an uncertainty analysis in the Risk Assessment. |
Louis Howard |
| 6/30/2008 |
Document, Report, or Work plan Review - other |
EPA (J. Gusmano) sent email to Air Force and ADEC RPMs. Also, attached is a recent explanation of how Regions 3,6 and 9 PRGs and HHMSSLs have been combined and updated.
It will address the use of a Hazard Screening factor of 0.1 for non carcinogens. The use of 0.1 has also been a Region 10 Policy since 1991( EPA Region 10 Supplemental Risk Assessment Guidence for Superfund, August 16, 1991). All Regions now use the PRGs and Screening levels on the Oak Ridge National Laboratory Web Page, or go to Region 6 or Region 9 web pages.
These Screening Criteria are to identify Potential Contaminants of Concern, not necessarily for Remediation Goals. The non carcinogen factor is low to address the potential of cumulative effects and to prevent the premature exclusion of contaminants for consideration in the Risk Assessment. The analytical methods that are unable to reach these screening levels because of method or high cost will be considered in the uncertainty analysis, as I described in my last e-mail.
Since the Work Plan, in my opinion, has very limited sample numbers at each anomaly and, since site history as to disposal practices is very minimal, at best, I feel we must collect surface samples at each sampling location as well as subsurface. We also must sample for VOAs, Semi-VOAs, PCBs/Pesticides, RCRA metals, and ADECs petroleum constituent methods.
The combination of limited sample numbers, unknown disposal practices, radiation sources, suspicious surface stress vegetation, limited preliminary screening techniques,and TCE and Carbon Tet. verified in ground water, all add to the need for conservative analytical sampling, before we can move to an FS. Since ICs and/or Removal Actions are the likely Alternatives we would consider, we must know the extent and sources of the contamination and determine if there is plume stability.
I understand we have had several meetings and the condition of the Draft Work Plan made the issues more confusing, so I hope this e-mail clears up EPA positions on at least a few of these issues. |
Louis Howard |
| 7/7/2008 |
Update or Other Action |
Air Force responds to EPA comments. Regarding the Screening Levels: Thank you for providing the reference for the 1/10th rule. Earth Tech is working on a memo and table showing the screening levels they will be using. The table will show analytes, carcinogen/non-carcinogen status, and screening levels, with non-carcinogen screening levels clearly shown at 1/10th the ORNL table levels.
Where analytes do not have a value in the ORNL table, the appropriate cleanup value (ADEC, MCL, etc.) will be shown, with non-carcinogens at 1/10th the cleanup value. In reference to "ICsand/or Removal Actions are the likely Alternatives" in the third paragraph below: we do not intend to perform any Removal Actions.
Alternatives that we will consider may include excavation and disposal of soil/buried material, but this would be performed as part of the Remedial Action after signing the ROD, not as a Removal Action. |
Louis Howard |
| 7/10/2008 |
Update or Other Action |
Email to M. Markell USAF from ADEC L. Howard: We would like to see the 2007 data packages and any associated tech memos/reports at some point for our files. |
Louis Howard |
| 7/10/2008 |
Update or Other Action |
Air Force response to 2007 data package request. Air Force requested that Earth Tech provide all their lab data, validation reports, field forms and logbooks, and other data backup materials since the Tech Memo issued in February 2008 was incomplete WRT the data backup. They are working on the revised Management Plan and preparing for field work, so they intend to include the requested documentation as an appendix in the draft RI/FS report due in autumn 2008. |
Louis Howard |
| 7/23/2008 |
Document, Report, or Work plan Review - other |
It appears the contractor acting on the Air Force's behalf is still unclear on the VOC collection, so we will need to see the revised document to review. The methanol is required for all VOCs, not just GRO/BTEX, so the proposal to do Encore for VOCs and methanol for GRO/BTEX will NOT be acceptableto ADEC.
Additionally, if they drop the low level NaHSO4 preservative and go strictly with Encore samplers, the holding time is reduced to 48 hours and/or there is a freezing requirement to -7 C. They would need to document how they were going to meet these requirements, although neither seems realistic with an out-of-state lab (Colorado). |
Louis Howard |
| 7/28/2008 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the draft final Work Plan for SS-22. Human Health Conceptual Site Model- The electronic version is blank and the hard copy version following Page 3-4 has completed pathways and exposures listed. ADEC requests the Air Force correct the electronic version to match the hard copy version of the CSM. ADEC requests the Air Force add a “Future (F)” receptor for both Incidental Soil Ingestion and Dermal Absorption of Contaminants from Soil under the Construction Workers.
Development of Risk Assessment Data Set Page 6-17 - The text states where both regular sample and duplicate samples are detections, sample results will be averaged. ADEC does not agree. ADEC requests the Air Force make the following change to the text regarding handling of duplicate same results which were previously provided on May 20, 2008 letter to the Air Force: “Where both the regular sample and duplicate samples are detections, the more conservative (greater) sample result will be used.”
The text also states “Where one of the sample-duplicate pair is a detection and the other a non-detection, the following procedure will be employed:...” ADEC disagrees on the procedure mentioned in text. ADEC requests the Air Force simply use the following when this situation occurs: “Where one of the sample-duplicate pair is a detection and the other a non-detection, the detected result will be used.”
The following comments for this section are based on EPA’s “Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA”. The first bullet states (RAOs) are medium-specific goals for protecting human health and the environment and are expressed in terms of a combination of contaminant levels and exposure routes. ADEC requests the text be reworded as follows: • Develop and refine remedial action objectives (RAOs) specifying the contaminants and media of interest, exposure pathways, and preliminary remediation goals that permit a range of treatment and containment alternatives to be developed. The preliminary remediation goals are developed on the basis of chemical-specific ARARs, when available, other available information (e.g., Rfds), and site-specific risk-related factors.
The second bullet states “Develop and refine general response actions. These are general categories of remedial technologies which, either together or in combination, can satisfy the RAOs.” ADEC requests it be reworded as follows: • Develop and refine general response actions for each medium of interest defining containment, treatment, excavation, pumping, or other actions, singly or in combination, that may be taken to satisfy the remedial action objectives for the site. The third bullet states “Identify and apply volumes or areas of contaminated media to which the general response actions would be applicable.”
ADEC requests it be reworded as follows: • Identify and apply volumes or areas of media to which general response actions might be applied, taking into account the requirements for protectiveness as identified in the remedial action objectives and the chemical and physical characterization of the site.
Preliminary RAOs Page 6-22-The first bullet states the preliminary RAOs for SS22 is • Protect human receptors by preventing exposure to soil and groundwater with contaminant concentrations having total excess cancer risk greater than 10-4 to 10-6; ADEC disagrees. ADEC requests the Air Force separate out media types in this section for soil and groundwater and change the text to read:
For groundwater contamination, the preliminary RAOs for SS22 have been identified as: • Prevent ingestion of groundwater having a total excess cancer risk for all contaminants greater than l0-4 to 10-6 or in excess of MCLs • Maintain concentrations of noncarcinogenic compounds to below a hazard index of 1.0; and • Restore the groundwater aquifer to contaminant concentrations less than chemical-specific ARARs, if ARARs exist.
For soil contamination, the preliminary RAOs for SS22 have been identified as: • Prevent ingestion/direct contact with soil having an excess cancer risk greater than 10-4 to 10-6 • Ingestion/direct contact should be prevented with soil having a noncarcinogenic hazard index of 1.0; and • Restore the soil to contaminant concentrations which are less than chemical-specific ARARs, if ARARs exist. |
Louis Howard |
| 8/4/2008 |
Document, Report, or Work plan Review - other |
EPA review comments on the management plan. App A FSP Section 2, Detailed Field Investigation Approach, Pages 2-1 and 2-2: It is unclear what sampling criteria will be used. The last bullet on page 2-1, leading to page 2-2, states that the Group 3 Areas will be evaluated by collecting samples directly from the trenches, as well as by direct push methods. The text further states that the criteria for sampling will follow those for Group 2 (Figure 2-2). However, in Section 2.1.3, it’s not completely clear what criteria will be used. It appears that Figure 2-2 will only be followed if “evidence of contamination” is observed.
Please revise the last bullet on page 2-1 and Section 2.1.3 to clarify the decision criteria for determining additional sampling and for determining when sampling is “done.” Figure 2-1, Sampling Decision Protocol for Group 1 Areas: Anomalies 1, 5, 8, 9, 14 and 15, Page 2-3: The decision logic does not appear to address all contaminants. The decision logic in Figure 2-1, starts with the top diamond “Contamination present in initial downgradient boring,” where “contamination” in the Legend is indicated by visible debris or contamination and Photo Ionization Detector (PID) reading greater than 25 parts per million per volume.
It appears that the initial decision about whether contamination is present is based on visual observations or screening (top diamond). If no “contamination” is observed, then two samples are to be collected and then it's "done." However, it is not clear from the decision protocol what will occur if metals, polycyclic aromatic hydrocarbons or polychlorinated biphenyls, which typically cannot be identified by the aforementioned screening instrumentation, are found to be present in the samples. Please revise Figure 2-1 to address the situation if contamination is found to be present in the two soil samples.
Figure 2-1 indicates that if contamination is found in the initial sample, a set of three samples would be collected and a new borehole would be advanced. It appears that “contamination” in the anomaly drives the "contamination indicated" decision (again, based on visual observations or screening methods). It is unclear from the decision protocol what will occur if contamination that may not be identified by the screening tools was found to be present in the laboratory analyses of the three samples.
Please revise Figure 2-1 to provide guidance if contamination is found to be present in any of the three soil samples. Section 2.1.3, Group 3 Areas: Anomalies 2, 3, and 11, Page 2-17: The bulleted section following the third paragraph of Section 2.1.3 states that two surface and two subsurface samples will be collected within the trench footprint of Anomaly 2, 3, and 11; however, the rationale behind the selection of two surface and subsurface samples per trench is not provided.
Please revise Section 2.1.3 to include the rationale behind the selection of two surface and subsurface samples per trench. Section 2.2, Trenching at Anomalies 2, 3, and 11, Page 2-19: Table 2-1, Trenching Lengths and Directions, provides the proposed trench lengths for Anomaly 2, 3, and 11 as 100 feet, 180 feet, and 80 feet, respectively; however, the rationale behind the selection of the length and direction of each trench is not provided.
Please revise the section to include the rationale behind the selection of the length and direction of each trench. Section 3.3.4, Collection Soil Sample Aliquots, Page 3-8: The second paragraph describes the collection of three 5-gram aliquots of soil using the TerraCore coring device; however, successful collection of the aliquot is based on the assumption that the soil is suitably fine-grained to fit into the TerraCore device. If coarse grained soils are encountered during drilling, there may be difficulties in using the TerraCore device to collect the three 5-gram aliquots of soil.
Please revise the section to include an alternate soil sample collection method if it is possible that coarse grained soils may be encountered. Section 3.4.2, Well Termination Depth and Screen Interval, Pages 3-11 and 3-12: The first two paragraphs provide the anticipated monitoring well screened interval depths and the well construction material including the use of 10–foot pre-packed screens. However, an explanation is not provided for the selection of the 0.010-inch factory slotted screens nor the size of the sand pack material.
Please revise Section 3.4.2 to include information that supports the selection of the screen slot and sand pack size and material to ensure that the monitoring wells will not become clogged with silt and will provide representative data. |
Louis Howard |
| 8/13/2008 |
Document, Report, or Work plan Review - other |
EPA comments to Air Force "SS22 Field Work" Previous EPA comments on the Field Work to be conducted at SS-22 deal mainly with more explanation on sampling rationale. We understand that the current field season is quickly coming to a close. In order to expedite the collection of critical data that will determine the true contaminant conditions at this site, EPA suggests that corrections and further explanation in the Field Investigation Work Plan be conducted as an addendum to the Work Plan or dealt with in the RI Report itself.
EPA approves the Field Investigation Work Plan with the caveat that our comments will be addressed in the near future in one of the aforementioned methods, so that the Field Work for this year can proceed. We intend to have comments on the entire Management Plan in a few days, but suggest that these comments not hold up progress with the Field Investigation.
Technical issues on data needs can be discussed this Fall or Winter, after we have more site investigation information to assist our decisions. Please proceed with the Field Investigation, if possible, keeping our comments in mind. |
Louis Howard |
| 8/26/2008 |
Document, Report, or Work plan Review - other |
EPA comments on the SS-22 RI/FS Schedule Update Through Final Remediation Action Construction Report. EPA has reviewed the subject document and feels it is far too premature to conclude there is no need for RD/RA Primary and Secondary Documents. The RI process has just begun with only preliminary data available. The FFA outlines these documents in the schedule and EPA Regions use these deliverable dates as metrics for progress when reporting to Congress.
Should the RI/FS Reports demonstrate that engineering design is not required, the RPMs can adjust the schedule accordingly. In any event, it is likely design documents will be replaced by Monitoring Plans and/or IC Modifications, so the RD/RA placeholder would still be valid. |
Louis Howard |
| 8/28/2008 |
Document, Report, or Work plan Review - other |
EPA comments on the draft final mgt. plan RI/FS SS22 (Former DRMO Storage Yard).
1. Section 3, The Conceptual Site Model (CSM) has not been well defined. First, Figure 3-1 has not been completed. Second, the discussions in Section 3.2 are overly general & do not point out specific constituents of concern (COC), pathways or receptors based on existing information for SS22 (Former DRMO Storage Yard).
Please provide a completed Figure 3-1 & revise the discussion presented in Section 3.2 to include specific COC, pathways, & receptors applicable to SS22. In addition, ecological receptors are briefly discussed in Section 3.2.2.2. However, the CSM has not been prepared to address potential contaminant pathways & ecological receptors. Please revise the Draft Final Mgt. Plan RI/ FS SS22 (Former DRMO Storage Yard) (herein referred to as the SS22 Draft Final Mgt. Plan) to include a CSM that addresses ecological receptors or incorporate this information into Figure 3-1.
Section 3.2, GW, states that GW discharge to surface water is not expected to occur, but that the “exposure route will be investigated using downgradient monitoring wells.” However, the text does not clarify what metric will be used to identify whether there is a local GW to surface water connection.
Please revise the discussion in Section 3.2 to describe how the potential for a GW to surface water connection will be evaluated. The criteria for collection of additional step out samples have not been well defined. Step 5: The Analytic Approach states that step out borings may be collected until the constituents of potential concern (COPCs) are below screening criteria. However, guidance describing whether or not additional samples will be collected has not been provided. Please revise Step 5 to discuss the decision criteria that will be used to determine whether additional step out samples will be collected.
Table 4-1: Soil Sampling & Analysis – Summary & Rational for SS22: The following specific concerns have been identified with the information presented in Table 4-1.
a. Anomaly/Area of Concern (AOC) 1: i. The rationale indicates that the sample is intended to confirm screening results; however, the sample is not located near samples with results exceeding criteria. The sample should be moved to be adjacent to 01-LF-01. According to Figure 2-4 in Appendix A, the sample designated to be collected from AOC 1 is located adjacent to 01-LF-05. Please resolve the discrepancy. ii. Rationale for excluding radiological sampling has not been provided. Please provide a rationale for elimination of radiological COCs or add radiological COCs to Table 4-1.
b. AOC 2: i. Rationale for excluding pesticides from all but one location has not been provided. Please provide a rationale for the elimination of pesticides or add pesticides to Table 4-1.
c. AOC 5: i. The rationale indicates that the sample is intended to confirm screening results; however, the sample is not located near samples with results exceeding criteria. The sample should be moved to be adjacent to 05-LF-05. According to Figure 2-4 in Appendix A, the sample is near 05-LF-06. Please resolve the discrepancy.
d. AOC 6: i. Rationale for excluding radiological sampling has not been provided. Please provide a rationale for elimination of radiological COCs or add radiological COCs to Table 4-1. ii. Rationale for including pesticides in only one location has not been provided. Please provide a rationale for the elimination of pesticides or add pesticides to Table 4-1.
e. AOC 7: i. Rationale for including pesticides in only one location has not been provided. Please provide a rationale for the elimination of pesticides or add pesticides to Table 4-1.
f. AOC 8:i. Sampling in the eastern portion of the AOC has not been completed based on Figure 2-4 in Appendix A. Please provide rationale for not sampling in the eastern portion or provide an additional sampling location in the eastern portion of AOC 8.
g. AOC 9: i. The rationale indicates that the sample is intended to confirm screening results; however, the sample is not located near samples with results exceeding criteria. The sample should be moved to be adjacent to 09-LF-01. According to Figure 2-4 in Appendix A, the sample is near 09-LF-03. Please resolve the discrepancy.
h. AOC 10: i. Rationale for including pesticides in only one location has not been provided. Please provide a rationale for the elimination of pesticides or add pesticides to Table 4-1.
i. AOC 14: i. According to Figure 2-4 in Appendix A, it appears that no samples have been collected from within the boundary of AOC 14. It is recommended that at least one sample be collected from within the boundary of this AOC or additional rationale be provided for not collecting a sample within the boundary of AOC 14.
|
Louis Howard |
| 9/16/2008 |
Update or Other Action |
Exploratory trenching was discontinued at Anomaly 20 upon encountering discarded military munitions in the form of bazooka rockets, some of which appeared intact and possibly live. Identification by explosive ordnance disposal (EOD) personnel classified them as “Fuse, Rocket, & Dummy” M-405 rounds manufactured in the early 1950s.
All discarded munitions were disposed of by EOD and backfilling of this anomaly resumed only after procurement, and under the direct supervision, of a certified unexploded ordnance technician.
Following discovery of the discarded military munitions, records of historical EOD reports were uncovered.
One record indicated that an ordnance item was uncovered in a scrap pile in the DRMO while loading metal into a tractor trailer in 1993. There was another incident in 1997 when a grader ran over a 2.75-inch practice rocket while working on the Davis Highway, near the DRMO. |
Louis Howard |
| 9/17/2008 |
Update or Other Action |
EPA email to Air Force. Due to the incident involving the EOD at SS-22 yesterday, I will refrain from signing the revised schedule, since issues with munition debris may effect the schedule. I anticipate an incident report soon on the kind and condition of the item found at the site. I would also remind you that the ADEC has requested notification of such discoveries, as a release.
For your convenience I have attached the latest DOD Standards for investigations involving the potential for explosives and/or ammunition. Please let me know if you would like a conference call or meeting to discuss this new development and it's effect on the scheduled activities. |
Louis Howard |
| 9/17/2008 |
Update or Other Action |
M. Markell, Air Force response to email regarding EOD activity at SS-22. I talked to EOD and asked for a copy of their report. The materials found were mortar casings, machine gun parts, and empty magazines. They said that while the materials found were related to munitions, no hazardous or explosive materials were present so they were not going to write a report.
Basically, what was found is scrap metal that happens to be gun-related. They said that the contractor can continue drilling, trenching, and sampling according to the current work plan - no UXO/EOD monitoring necessary. The field work is still on schedule and no schedule delays are anticipated due to munitions-related issues. There will be no incident report as there has been no release. |
Louis Howard |
| 9/18/2008 |
Update or Other Action |
Air Force email regarding memo on additional soil borings. Earth Tech is proposing a change to the subsurface soil sampling for the radiological survey. See below. The purpose of the subsurface soil sampling as specified in the radiological investigation work plan was to identify if radiological contamination existed in the subsurface debris fields identified by the geophysical survey.
Field observations of buried radioactive sources during this week's trenching operations have provided us with this information, obviating the need to do the planned borings. Due the highly localized nature of the radioactive materials (small distributed sources), a limited number of random bore samples has a low probability of finding additional sources.
Negative results do not allow conclusions to be drawn as to absence of buried sources in close proximity to the borehole. A positive result would merely confirm what we already know. No changes are proposed to the surface soil sampling plan. Earth Tech recommends not collecting the subsurface soil borings as outlined in section 2.7.2 of the radiological work plan. No value is added for the reasons indicated above. |
Louis Howard |
| 9/18/2008 |
Meeting or Teleconference Held |
EPA response to conference call on memo on additional soil borings. Thanks for the opportunity to discuss this issue on the conference call. I agree that soil borings will not reveal any better information than you have already obtained from trenching. I agree that we can suspend the radiological soil borings for the time being and de-mob for this season. |
Louis Howard |
| 10/8/2008 |
Meeting or Teleconference Held |
Minutes of Remedial Project Manager Meeting, 8 October 2008 1. A meeting of the remedial project managers (RPMs) convened at 1305 on 8 October 2008 in the SABER Conference Room, Building 5312, at Elmendorf Air Force Base (EAFB), Alaska. Attendees included: Mr. Jacques Gusmano (Environmental Protection Agency [EPA]), Mr. Louis Howard (Alaska Department of Environmental Conservation [ADEC]), Mr. Don Aide (CEANR), Ms. Donna Baumler (CEANR), Mr. Gary Fink (CEAN), Ms. Melissa Markell (CEANR), Mr. Bruce Steely (CEANR), and Ms. Renee Wright (PA). (4) SS22 Update.
Final RI/FS Management Plans (MPs) and FFA schedule update letters were distributed to the agencies. An addendum to the MP is expected in spring 2009 to address vapor intrusion risk assessment. 2008 field work was completed and included all surface soil sampling, debris pile characterization, MARSSIM survey and sampling, and trenching and sampling at Anomalies 2, 3, and 11. A few instrument dials and compasses were found in the trenches, confirming the suspected sources of Radium-226 and indicating that other sources may be buried at the site. Efforts are underway to install the fence before mid-November 2008. In 2009, field work will include well installation and sampling, and subsurface soil sampling. |
Louis Howard |
| 11/17/2008 |
Update or Other Action |
Treatability study to characterize the distribution of chlorinated ethenes in GW & surface at the Slammer Avenue Plume, Operable Unit 5 received.
A drainage ditch runs in an east to west orientation at the base of the bluff, with access by a gravel service road on the south side of the drainage ditch. Shallow GW discharges to a drainage ditch & a Beaver Pond wetland area at the base of the bluff overlooking the Ship Creek flood plain, while deeper GW continues to migrate underneath the Ship Creek flood plain. [NOTE: This discharge to the ditch is actually from SS22 1.6 mile chlorinated solvent plume originating from anomaly 10.]
TCE in GW in the eastern plume was traced as far northeast as location DPS-14, located adjacent to Slammer Avenue, where TCE was present at a maximum concentration of 21 µg/L at a depth of 58 feet bgs. Concentrations further to the north were less than 3.0 µg/L at location DPS-30. These data suggest a potential source area in an upgradient direction to the northeast of DPS-14, on the eastern side of Slammer Avenue.
Sample location BPSW-04 is at the outfall of the drainage ditch into the Beaver Pond. Concentrations of TCE in surface water at location BPW-04 are variable, with no apparent trend.
The variation in concentrations of TCE at this location may be due to the effects of dilution & mixing that occurs between surface water in the ditch & GW that is discharging further up stream in the ditch. Based on concentrations of TCE in surface water along the ditch relative to the concentration of TCE in GW at GW-4A, it appears the drainage ditch exerts some hydraulic control on the eastern Slammer Avenue Plume.
The eastern plume discharging to a drainage ditch that flows into the eastern margin of the Beaver Pond wetland area, & the western plume discharging directly to the northern margin of the wetland. The highest concentrations of TCE appear to discharge from the eastern plume to the drainage ditch. Attenuation may occur in the ditch due to dilution & volatilization, although concentrations of TCE above 5 µg/L are consistently detected at surface water sampling location BPSW-04, located at the point of discharge from the drainage ditch to the wetland.
While sampling at well ST37SMW-08 indicates that TCE does not migrate in GW underneath the Ship Creek flood plain, there is less certainty whether TCE continues to migrates in GW underneath the drainage ditch to the east of well location GW-4.
The first four samples were collected on 07 September 2007 from the drainage ditch that flows into the Beaver Pond. The final three samples were collected on 11 September 2007 from three of the previously sampled locations along the drainage ditch. These samples were collected to provide confirmation of elevated concentrations of TCE detected in samples collected on 07 September 2007.
Shallow GW discharges to the drainage ditch & the wetlands at the base of the bluff overlooking the Ship Creek flood plain, while deeper GW continues to migrate underneath the Ship Creek flood plain.
Locations BP115/104, BP116/105, BP116/106, & BP118 are located along the drainage ditch that cuts across the base of the bluff & discharges to the Beaver Pond at sample location BPSW-04. Locations BPSW-05 is located further west in the Beaver Pond, & location BPSW-01 is located at the western margin of the overall Beaver Pond area where surface water discharges towards Ship Creek. Concentrations of TCE measured along the northern margin of the Beaver Pond in September 2007 were below detection, with the exception of a detection of 7 µg/L at BP-111.
Along with inconsistent detections of TCE above 5.0 µg/L at BPSW-03, discharge of the western plume appears to have a limited impact on surface water quality. Continued monitoring of BPSW-03 is suitable for monitoring discharge of the western plume. Concentrations of TCE along the drainage ditch where the eastern plume discharges to surface water were relatively higher, with concentrations of TCE as high as 31 µg/L at BP116 & 36 µg/L at BP117. Because these sample results were higher than TCE measured in GW, they were re-sampled on 11 September 2007.
The concentration of TCE in BP105 (re-sample of BP116) was 7.0 µg/L by portable GC & 8.17 µg/L by laboratory method SW8260B. Similarly, the concentration of TCE in BP106 (re-sample of BP117) was 14 µg/L by portable GC & 9.66 µg/L by laboratory method SW8260B. These concentrations are lower than initially measured by the portable GC, but it should be noted that it rained immediately prior to the re-sample event; concentrations for samples from the drainage ditch may have been lower due to dilution from precipitation.
|
Louis Howard |
| 12/22/2008 |
Document, Report, or Work plan Review - other |
EPA comments on the preliminary data received Chemical Data Summary 1. A screening table is not provided for compounds that were not detected in any sample. In order to determine if method detection limits (MDLs) were sufficient to meet screening criteria, it is recommended that screening be conducted for all non-detected compounds. Following this screening process, if there are MDLs not adequately sensitive to meet screening criteria for any compound, qualitative evaluation is necessary to evaluate whether these compounds may be present at the site based on site history and current site use.
2. Various compounds were not detected in every sample. When determining exposure point concentrations (EPCs) for the quantitative risk assessment, ensure that ProUCL 4.0 is used and the accompanying guidelines are followed.
3. The endnotes for the screening tables (see Soil Notes tab of the workbook) should clarify how carcinogenic and noncarcinogenic compounds are being screened. It appears that the column entitled “Human Health Screening Criteria” is appropriate for carcinogenic compounds, while the column entitled “1/10 Human Health Screen” provides criteria based on a hazard quotient of 0.1 for screening noncarcinogenic compounds. It is assumed that the screening criteria for noncarcinogens were adjusted to account for additive effects; however, this was not specified in the table. This should be clarified in the report and in the screening table endnotes. Also, please clarify whether each compound is being evaluated as a carcinogen or noncarcinogen.
4. Inorganic compounds (i.e. metals) were screened against both human health risk-based screening criteria and background levels. Please ensure that inorganic compounds exceeding human health risk-based screening criteria are retained as chemicals of potential concern (COPCs) in the quantitative risk assessment regardless of background levels. Consistent with EPA’s Guidance for Comparing Background and Chemical Concentrations in Soil for CERCLA Sites (2002), all chemicals detected above the most relevant health-based screening are to be retained as COPCs and assessed under total risk baseline conditions. Following a total estimate of risk and hazard, a further refinement of the total expression of risk can be conducted and discussed as part of the uncertainty analysis; three components of risk can be provided such as total risk, background risk and residual (or site-related) risk. This refinement of the quantitative expressions of risk is helpful in ultimately supporting site risk management decisions. This comment pertains to both human health and ecological risk assessments.
5. Discrepancies were identified during the review of the data screening tables. For example, screening criteria are provided for compounds not listed in the Regional Screening Levels for Chemical Contaminants at Superfund Sites Screening Table dated September 2008 (SL Table). If other screening levels are being used, the type and source of those screening levels should be indicated. Also, the data screening tables do not indicate all exceedances. Furthermore, the screening criteria are incorrect for various compounds. Specific examples are provided below.
This list in not exhaustive or inclusive of all discrepancies, but rather serves to provide examples only. • The source of the screening criteria for the following compounds is unknown as criteria for these compounds are not published in the SL Table: PHC as gasoline, PHC as diesel fuel, PHC as heavy/residual range organic compounds, acenaphthylene, benzo(g,h,i)perylene, phenanthrene, alpha-chlordane, gamma-chlordane, dibenzofuran, etc. Please indicate the source of the criterion selected for each compound not listed in the SL Table. While the endnotes, or “Soil Notes” tab of the workbook, list additional sources, the endnotes should specifically clarify the source of the criterion selected for each compound not listed in the SL Table. Please revise the endnotes accordingly. • Please double check that all exceedances are indicated. Several exceedances were noted that were not indicated by shading.
For example, chromium (a noncarcinogen) exceeded the 1/10 Human Health Screening Criterion and its background level in various subsurface soil samples. Also, “PHC as gasoline” was detected in SS22AN03-03SB02_1_(1) (4-5 feet below ground surface [bgs]) at 730 J milligrams per kilogram (mg/kg), which is above the screening criteria of 140 mg/kg. Please review the data tables closely and revise the tables to indicate all exceedances. • The screening criterion for several compounds is incorrect. While these changes will not generally affect the number of exceedances, changes should be made for accuracy.
See site file for additional information. |
Louis Howard |
| 2/5/2009 |
Update or Other Action |
MEMORANDUM FOR DRMO FROM: 3 AMDS/SGPB SUBJECT: DRMO Storage Yard Ra-226 Health Risk Assessment 1. The purpose of this memorandum is to inform DRMO personnel of remedial investigation activity occurring in the vicinity of Building 12755. The environmental restoration project is managed by 3 CES/CEANR and Bioenvironmental Engineering (BE) acts as the installation Radiation Safety Officer (RSO) in accordance with AFI 40-201, Managing Radioactive Materials in the US Air Force, and is responsible for managing the base radiation safety program.
2. Prior to today's stringent environmental regulations, waste was often buried as a form of disposal. Aerial photos on file indicate the Elmendorf AFB DRMO storage yard was used for various vehicle and material storage operations dating back to the 1950's. Further investigation confirmed the presence of buried waste in this area, which runs North-South, several hundred feet to the East of Bldg 12755. As part of an effort to remediate this site, a contractor was hired to conduct an initial assessment of the area. In August 2007, contractor personnel detected low level radiation in several parts of the yard. BE validated contractor findings and collected soil samples.
Analysis by USAFSAM/OEHRH confirmed the presence of Radium-226; a radioactive element. Radium waste on Air Force installations is not uncommon as a result of disposed radium-painted dials and gauges from aircraft and vehicles. The paint in these dials exhibit low levels of radioactivity. A detailed survey was conducted over the entire surface area and all radiation levels detected are well below exposure limits. Contractor personnel, under the supervision of an Air Force health physicist from USAFSAM/Det 3, initiated trenching activity in September 2008 to better identify the source of Radium. Several samples of contaminated soil and two dials were recovered from the site. Further investigation will resume in the summer of 2009 to further characterize the contamination. 3. Radium waste in the DRMO storage Yard is not a health risk to personell working in Bldg 12755. Personnel shall not enter or disturb the area without contacting BE or CEANR. Questions or concerns regarding this information may be directed to TSgt Becker at 552-3929 or Capt Ryan, Base RSO, at 552-3893. Yolanda S. Becker TSgt USAF, NCOIC, Radiation & Training |
Louis Howard |
| 3/17/2009 |
CERCLA ROD Periodic Review |
Daniel D. Opalski, Director, Office of Environmental Cleanup for Region 10 EPA sent US Air FOrce Vice Commander, Colonel US Air Force Richard Wahlberg a cover letter to the signature sheet for the Five-Year Review report. 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 |
| 3/31/2009 |
Meeting or Teleconference Held |
Minutes, Remedial Project Manager Meeting, 3 1 Mar 09 1. A meeting of the remedial project managers (RPMs) convened at 0900 on 3 1 Mar 09 in the 3rd Civil Engineer Squadron Asset Management-Natural Resources (3 CESICEANR) Conference Room, Building 53 12. Attendees included: Mr. Jacques Gusmano - Environmental Protection Agency (EPA), Mr. Louis Howard - Alaska Department of Environmental Conservation (ADEC), Mr. Rafael Vazquez - Air Force Center for Engineering and Environment (AFCEE)-Restoration Program Management Office (R-PMO), Ms. Renee Wright - 3rd Wing Public Affairs (3 WGIPA) and CEANR personnel - Mr. Gary Fink, Ms. Melissa Markell, Mr. Don Aide, and Ms. Donna Baumler.
A busy field season is expected with the continuation of fieldwork at SS22 to complete the remedial investigation (RI), decommissioning of approximately 26,000 linear feet of pipeline (OT92) in multiple segments that run throughout the base, reviews of potential stimulus projects such as demolishing extraneous buildings, and integrating the environmental compliance contaminated sites program into the environmental restoration program (ERP), as well as Fort Richardson into Elmendorf. SS22 Update - Ms. Markell explained that this field season consists of subsurface soil sampling, well installation and soil vapor sampling, which will require a contract modification. The draft MARSSIM report has been received and reviewed internally. This report was written by PhDs for PhDs - there are lots of results with no answers to questions and there are no concrete recommendations. This report may not be out for review by the Agencies until the draft remedial investigation (RI) is available. This will allow the Air Force to provide a thorough technical review prior to presenting the results of this report to the public. Some of the results include elevated gamma ray readings thought to be from buried self-luminescent dials.
The dials are not expected to be excavated. Since these may need to be left in place, the RIIFS must take this condition into consideration. Ms. Markell also mentioned that all documents for the SS22 administrative record (AIR) are being collected and the A/R file will be developed as a part of the proposed plan (PP) and record of decision (ROD) contract. All documents that have been prepared for this site are available in hard copy at the information repository at the Alaska Resources Library and Information Services (ARLIS) located in the University of Alaska Anchorage campus.
Bioenvironmental Engineering (BEE) Relationship - Ms. Markell added that we have been engaging the BEE shop more and more with radiation concerns at SS22. The BEE is responsible for vapor intrusion measurements inside of existing buildings and their funding source is different than environmental funds. |
Louis Howard |
| 9/1/2009 |
Update or Other Action |
Email from Air Force regarding meetings to discuss RI/FS documents. The intent of these meetings is to meet the requirements of Section E, paragraph 20.9 of the FFA (pg 37): "Prior to preparing any draft [primary or secondary] report,... the Project Managers shall meet to discuss the report results in an effort to reach a common understanding, to the maximum extent practicable, with respect to the results to be presented in the draft report."
So, we will have these pre-report meetings to agree on the direction the reports will take. Then you'll get the RI/BRA/ARARs draft reports for review. You'll get a second chance to review these revised reports and RTCs together in the draft RI/FS. You'll get a final review opportunity for the whole package when the draft final RI/FS is published. There are no changes proposed to draft document deliverable schedule as appended to the FFA: Draft RI Report for agency review 11/3/09 - 12/2/09 Draft BRA for agency review 11/17/09 - 12/16/09 Draft ARARs evaluation for agency review 12/2/09 - 12/31/09 Draft RI/FS Report (which will address comments and provide RTCs for the draft RI/draft BRA/draft ARARs) for agency review 2/4/10 - 3/5/10 Draft Final RI/FS Report (which will address comments and provide RTCs for the draft RI/FS report) for agency review 4/9/10 -4/23/10 Having these pre-report meetings does not preclude having other meetings during the RI/FS development process.
As shown in the SS22 document schedule amended to the FFA, we have planned all along to finalize the RI and FS documents concurrently, and have done so with EPA and ADEC concurrence. Through pre-report meetings and other coordination, it is my hope that we can agree that we have no data gaps substantial enough to prevent the FS from proceeding on schedule.
If you feel strongly that the FS schedule cannot be achieved, please let me know asap so we can review and revise the schedule as necessary. |
Louis Howard |
| 9/1/2009 |
Document, Report, or Work plan Review - other |
EPA comments to Air Force on the meetings to discuss the RI/FS documents. The Sept. 23 or 24 dates look fine for me for a discussion of the Data. The dates in Oct., so far, look fine for ARARS and Risk Assessment discussions. This, however, would mean a Draft RI Report and Risk Assessment will be delivered sometime after our meetings, probably Nov./Dec. 2009.
It is safe to assume there may be data gaps or, at best, one more re-write of these documents before approval.
We should agree on a defensible RI Report before moving to the FS. This makes discussion of an FS highly unlikely before Spring of 2010 even if there are no data gaps in the RI. |
Louis Howard |
| 9/2/2009 |
Update or Other Action |
M. Markell, Air Force response on meetings to discuss RI/FS documents. I have instructed the contractor to provide the 2007 data deliverable, validation, and related information as part of the data deliverable you'll be getting on 18 September. This material will also be provided as an appendix in the RI report, along with field notes and other relevant information from that effort that may be applicable to the RI. The radiation report is still under review at the Pentagon level.
The radiation data will be included in the 18 Sept data package, and radiation findings, interpretations, and recommendations will be included in our discussion during the pre-draft-RI meeting. Radiation report revisions are expected to be finished concurrently with the draft RI report. The revised rad report will be included as an appendix in the draft RI report, so it will be available for review during the draft RI report review period. Just so you know, no sources detected other than Ra-226, plus there is a significant possibility of more buried radiological commodities at the site, so unless we excavate the whole site we'll have land use controls (at a minimum) for quite a spell (half life of Ra-226 is 1600 years). The risk assessment will have to address, among other things, radon in a future use scenario with buildings onsite.
I'll set up a meeting for the 24th. Not sure on the meeting length just yet, but I'll leave open the possibility that it could go for at least half the day. The field team lead will be there, as well as the technical lead from the contractor's side, so you can ask them any questions. If, after the initial presentation and Q&A, you need more time to digest the info before discussing the general RI approach, we can plan a second meeting. |
Louis Howard |
| 9/24/2009 |
Meeting or Teleconference Held |
Representatives of the United States Air Force (USAF) 3rd Civil Engineer Squadron (3 CES)/Asset Management Flight, Natural Resources Element, Restoration Section (CEANR), the US Environmental Protection Agency (EPA), the Alaska Department of Environmental Conservation (ADEC), and AECOM met for a meeting to discuss results of the SS22 Phase 2 remedial investigation (RI) Task Order (TO) 034 conducted under Contract No. FA8903-08-D-8770. The purpose of the meeting was to present the results from sampling activities to date and to discuss with the regulatory agencies an appropriate and agreeable path forward to complete the RI characterization activities.
The Air Force presentation proposed that the extent and nature of contamination have been adequately characterized at most locations. This means that geophysical investigations and soil trenching and boring have provided adequate delineation of contaminant extent, and that because soil sampling was targeted in the most contaminated areas, additional soil sampling is unlikely to reveal previously unknown contaminants. Consequently, for most areas of SS22, site characterization data are adequate to proceed with the risk assessment and feasibility study. However, three of the anomalies (5, 9 and 10), the stressed vegetation area, and groundwater appear to warrant further investigation. Q: There appears to be a discord between soil gas results and results from the soil samples; specifically TCE is present in soil gas in both anomalies 2 and 3 but not present in soil. Was the source area missed, or is the soil gas possibly coming from groundwater? Also, one of the functions of a DRMO is to strip precious metals from material brought in so contamination due to use of solvents could be expected. A:
While it is true that small sources can likely be missed with discrete sampling, we (the Air Force) believe that the biased sampling strategy (approved in the workplan) provided a best probability to locate large sources that would pose a risk across the areas investigated. Also, based on the depth to groundwater and relatively low concentrations detected in water, it is unlikely (in the Air Force's opinion) that groundwater is the source for the soil gas hits. Q: Delineation of TPH at Anomaly 2 should probably be addressed. A: The radiological point sources identified are likely to drive the remedial strategy. Further delineation of TPH detected below the upper range of ADEC cleanup levels does not appear warranted. Q: Carbon tetrachloride appears in soil gas across the site, but not in soil.
Where is the source? May need to consider additional wells in these areas (example presented with Anomaly 4). This may help in the long run when deciding what to do with individual anomalies if a groundwater plume is showing that area as a source or if the source is elsewhere. A: Carbon tetrachloride is not an issue in groundwater sampled in wells downgradient from Anomaly 4. A review of monitoring wells associated with the landfill will be performed to identify whether or not that could likely be a source (in southern portion of the site) and has been added as an action item.
Q: What are the exceedances in the tables and figures based on?
If using eco screening levels, which ones are being used? A: Direct contact for human health was used to determine the exceedances as provided in the Management Plan. Eco screening levels will be used in the risk assessment. |
Louis Howard |
| 9/28/2009 |
Document, Report, or Work plan Review - other |
Staff sent the Air Force a comment letter regarding the SS22 Pre-report Remedial Investigation September 2009. The Alaska Department of Environmental Conservation (ADEC) appreciates the opportunity to discuss the RI Findings of anomalies and investigation areas at Spill Site (SS22). ADEC has the following general comments followed by specific comments on the meeting. The screening levels in the field sampling plan were set at 1/10th of the Table B2 Method Two Petroleum Hydrocarbon Soil Cleanup Levels: gasoline range organics (GRO) 1,400 mg/kg inhalation/ingestion, diesel range organics (DRO) 10,250 mg/kg ingestion and residual range organics (RRO) 10,000 mg/kg ingestion.
The ingestion and inhalation levels are appropriate for human health screening purposes, but are not meant to evaluate contaminant migration to groundwater. The groundwater at SS22 has been demonstrated to be contaminated by chlorinated solvents and DRO. Since groundwater is contaminated, the Table B1 Method Two – Soil Cleanup Levels Migration to Groundwater cleanup levels are applicable at SS22. ADEC believes that the extent of vertical and horizontal soil contamination has not been adequately delineated for some areas at SS22 to provide sufficient information to determine the necessity for remedial action or to support the evaluation of remedial alternatives.
A baseline risk assessment cannot be conducted if the extent of contamination has not been determined during the RI. The baseline risk assessment shall evaluate risk to current and future human/environmental receptors based on current conditions without regard to either current/future remediation or current/future institutional controls. “Analyses that are important to the subsequent risk assessment and subsequent development of remedial alternatives include the horizontal and vertical extent of contamination in soil, ground water, surface water, sediment, air, biota, and facilities (Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA EPA/540/G-89/004 EPA October 1988)”.
ADEC realizes the intent of the remedial investigation (RI) is not to fully characterize SS22 to eliminate all uncertainties because uncertainty is inherent in all hazardous and radioactive waste management. The intent is instead to bound the uncertainties sufficiently (1) to allow meaningful description of the most probable site conditions and possible variations in those conditions, and (2) to develop and compare alternative remediation technologies in the feasibility study (FS) to address the hazards to human and environmental receptors posed by the SS22.
Anomaly 2 The following soil borings detected contamination above cleanup levels: 2SB06-DRO 3,100 mg/kg and field duplicate 4,200 mg/kg at 3-4 feet (ft.) below ground surface (bgs), 2SB07-DRO 3,500 mg/kg at 3-5 ft. bgs, and 2SB03-DRO 4,200 mg/kg at 4-5 ft. bgs The assumption made is that the soil contamination is related to the metal debris/waste detected in the anomaly and is delineated by soil borings 2SB01, 2SB02, 2SB04. ADEC disagrees with the discussion that the horizontal and vertical extent of DRO contamination has been delineated. Borings 2SB01, 2SB02 and 2SB04 are located approximately 60 to 90 feet away and do not have any DRO detections. The DRO contamination is not necessarily bound by or associated with Anomaly 2’s boundary.
The DRO contamination could be related to historical surface spills/leaking drums which were covered up during the site’s previous use and reworking of the soil during burial and/or salvage activities. The vertical and horizontal extent of petroleum contamination has not been characterized for Anomaly 2.
Anomaly 3 Soil boring 3SB02 had DRO at 3,100 mg/kg and GRO at 730 mg/kg from 4-5 ft. bgs The assumption made is that the petroleum contamination is related to the metal debris/waste detected in the anomaly and is delineated by soil borings 3SB01, 3SB03, 3SB04 and 3SB05. ADEC disagrees that the horizontal and vertical extent of DRO contamination has been delineated. These four borings are located approximately 75 to 120 feet away from 3SB02 and do not have any DRO or GRO detections. The contamination is 3SB02 is not necessarily bound by or associated with Anomaly 3’s boundary.
The DRO/GRO contamination could be related to historical surface spills which were covered up during the site’s previous use and reworking of the soil during burial and/or salvage activities. The horizontal and vertical extent of DRO and GRO contamination detected in 3SB02 has not been sufficiently delineated for Anomaly 3.
See site file for additional information. |
Louis Howard |
| 10/12/2009 |
Document, Report, or Work plan Review - other |
Email from ADEC to USAF re: SS22 investigation of FID Readings. 2010 field work: Since the latest round of data disproved the Air Force's hypothesis* of [methane] gases coming from the landfill (most results for soil gas-Methane were at or very near the reporting limit via ASTM D-1946, see QARs 9/18/09), are we going to go back and investigate/confirm the high flame ionization detector (FID) hits noted in the earlier field screening samples?
Or are we, as remedial project managers for our respective agencies, going to accept the 2009 field work activities as "sufficient" characterization of the nature and extent of contamination to support an informed risk management decision? Sure wish we had overlays or figures of the earlier FID readings, definitive soil sample locations/depths, sample results and follow-up soil gas readings to compare apples to apples. Looks like one of many topics for discussion in RPM and SS22 specific meetings in the near future. "A flame ionization detector (FID) measures the change of signal as analytes are ionized by a hydrogen-air flame. A FID can be used alone to give a total reading of ionized contaminants in parts per million (ppm).
When used in this setting, the FID is a screening tool for soil contamination. It can give a general idea whether soil is slightly or grossly impacted based on the total ppm reading. However, note that there is not a direct relationship between the contaminant levels identified with a FID and those obtained during laboratory analysis of the soil. In addition, when a FID is used alone the contaminant is unknown because it cannot identify the individual contaminants causing the ionization. Because a FID can detect phenols, phthalates, PAHs, VOCs, and petroleum hydrocarbons, the ppm reading could be any one of these individual contaminants or a combination of them." |
Louis Howard |
| 10/13/2009 |
Update or Other Action |
EPA approval of the meeting minutes. The meeting minutes do adequately capture the discussion topics at the meeting. I notice that a meeting is planned to discuss the upcoming RI Work Plan for next year. At this meeting we can discuss issues remaining such as "migration to groundwater" for soil cleanup criteria and the potential for more delineation at some anomalies.
For that meeting it would be helpful if all screening, trenching and analytical sampling could be presented by anomaly to summarize all information known at that site, for all media. I know our last meeting attempted to do that but a more complete figure or table would be helpful in understanding the complete picture at each anomaly. |
Louis Howard |
| 10/13/2009 |
Update or Other Action |
USAF Response to ADEC concerns regarding SS22 investigation usage of FID. You may want to refer to the Management Plan Addendum - Soil Gas Investigations (Final, May 2009). The soil gas investigation in 2009 targeted not only where we had high hits in soil during 2009, but also where we had high soil gas screening results in 2008.
You may recall that many of the soil gas screening results from 2008 were considered suspect for a number of reasons (very high moisture due to the rainy conditions, problems with the soil gas probe); therefore, the fact that some high hits from 2008 were not confirmed by the more rigorous methodology used in 2009 is not surprising.
USAF considers the 2009 soil gas investigation sufficient to characterize soil gas in the eastern portion of the expanded SS22 site. We are working on the presentation for the 2010 RI Triad meeting. While it may not be possible to present every piece of data on a single figure for each anomaly, we are doing our best to ensure that all stakeholders will be able to understand everything we know about SS22. |
Louis Howard |
| 10/15/2009 |
Meeting or Teleconference Held |
A meeting of the remedial project managers (RPMs) convened at 0900 on 15 October 2009 in the CEAN Conference Room, Building 5312, at Elmendorf Air Force Base (EAFB), Alaska. Attendees included: Mr. Jacques Gusmano (Environmental Protection Agency [EPA]), Mr. Louis Howard (Alaska Department of Environmental Conservation [ADEC]), Mr. Don Aide (CEANR), Ms. Donna Baumler (CEANR), Mr. Gary Fink (CEAN), Ms. Melissa Markell (CEANR), and Ms. Renee Wright (3 WG/PA).
Zones 2 and 3, SS22 Updates (Ms. Markell)
(1) Parsons is changing project managers for the Zones 2 and 3 contracts from Bill Plaehn to Steve Brauner. (2) CEANR has changed the RPM for Zone 2 from Melissa Markell to Don Aide. The boundary for Zone 2 has been changed to encompass ST48 and ST68 as these are flightline support area sites with fuel contamination similar to other Zone 2 sites. (3) A map with sample results and proposed sampling areas for ST32 was distributed (Attachment 6). The map represents what was happening in the middle of the 2009 field season, where more extensive contamination than anticipated was found at ST32 and the plan to install permanent monitoring wells was replaced with a plan to collect groundwater grab samples. This map was distributed to provide a preview of what will be discussed in the annual report regarding the field efforts for 2009. More investigation, an updated conceptual site model, and new sampling program recommendations are anticipated for ST32 in the next few years. (4) A summary of the biovent decommissioning at FT23 was distributed (Attachment 7).
Mr. Fink thanked EPA and ADEC for the quick response and concurrence that allowed this decommissioning to occur. Ms. Markell explained that while the soil remediation had concluded at FT23, groundwater was still being monitored and the soil vapor investigation conducted in summer 2009 could lead to more soil vapor work, including installation of more soil vapor monitoring points.
Preliminary soil vapor and groundwater monitoring results were not available for this meeting. (5) A proposal to continue the Wetland Remediation System Optimization Study was distributed (Attachment 8). Analytical results to date were attached, showing that all sample results have been below cleanup levels. Ms. Markell read through the proposal, emphasizing that if the study continued and a need to reactivate pumping was realized during the winter, a temporary pump and conveyance line would be used since the existing system would be unusable until spring 2010. If the study results indicate that cleanup levels are being met using the passive collection and drainage system, use of passive treatment would be proposed for the duration of the remedy. Mr. Gusmano stated that this proposal was acceptable only because a back-up system would be in place; without the ability to reinstate pumping, it would be hard to concur. Mr. Howard agreed. (6) Updates to the SS22 schedule for the FFA are under review. These proposed new dates will be sent to the agencies for review and concurrence within the next couple of weeks.
A Triad meeting to plan the investigation work for 2010 will be scheduled in the 2-23 November timeframe. EPA and ADEC will provide their available dates to assist in scheduling. (7) The draft memorandum on interim LUCs at SS22 is in internal review. This memo is expected to be sent for agency review within a few weeks. The memo does not fully cover all interim LUCs at SS22 because the possession-only permit is still pending from the Radioactive Isotope Committee (RIC) Secretariat. The current version of the memo includes descriptions of the dig permit process, health physics monitoring, and fencing. Once the permit is received, details on signage requirements and other LUCs will be specified; another memo will be issued to describe these interim LUCs. |
Louis Howard |
| 10/29/2009 |
Update or Other Action |
MEMORANDUM FOR DEFENSE REUTILIZATION AND MARKETING SERVICE (Attention: Mr. David Miner) FROM: 3 AMDS/SGPB, 10449 Luke Avenue, Elmendorf AFB, AK 99506 SUBJECT: DRMO SS-22 East Site Radiological Exposure Survey 29 October 2009
1. On 27 October 2009, MSgt Kim, TSgt Becker, AlC Colbert and Amn Tyson from Bioenvironmental Engineering conducted a radiological exposure survey on the exterior fence line surrounding the DRMO SS-22 East Site. The purpose of this survey was to monitor the radiological exposure rates outside of the fence and compare these readings to the general population exposure standard.
2. The general population exposure standard can be found in Title 10 Code of Federal
Regulations 20.l301, Dose Limits for Individual Members of the Public, which states that the total effective dose equivalent to individual members of the public shall not exceed 100 millirem (mRem) in a year and the dose in any unrestricted area shall not exceed 2 mRem in any one hour.
3. Per conversation with Mr. David Miner, Defense Reutilization and Marketing Service (DRMS) Operations Monitor, DRMS employees do not routinely work in the SS-22 East Site fenced in area, except for daily perimeter checks to validate the integrity of the fence. During this perimeter check, one individual walks the interior side of the fence, which takes roughly 10-15 minutes. Based on this information and using the highest exposure rate detected (20 uR/hr), the results of the radiological exposure survey are well within the general public standard of 100 mRem in a year and 2 mRem in anyone hour unrestricted area standard.
4. The radiological contamination within the fenced in area is an environmental clean-up issue and does not pose a health risk to DRMS employees or to the general public. At this time, there are no requirements for radiation warning signage; however, there should be signs posted around the perimeter to inform the public to keep out ofthis area. The attached diagram (attachment 1) depicts the location of all signs on the SS-22 East Site. Unfortunately, some have been damaged and need to be replaced. These are demonstrated on the drawing as well.
5. We have included attachment 2 to provide DRMS employees with background information on the DRMO SS-22 radiological contamination issue.
6. If there are any questions regarding this letter, please contact me or MSgt Kim at 552-3985 Gregory A. Frick Lt Col USAF, BSC, Flight Commander. GeneralPopulation Exposure (50 uR/hr)(50 hrs/yr) = 1.00 mRem/yr <<< 100 m/Rem/Yr All measurements were taken at the exterior fenceline with an Inovision 451P (S/N: 00000006237). Calibrated: 4 May 09 (ca1 due 4 Nov 09). Background: <20 uR/hr Estimated exposure time:, 50hrs per year (based on 1 hr. a week x 50 weeks a year) Below 2 mRem in any one hour unrestricted area standard Survey conducted on 27 October 2009 by MSgt Kim TSgt Becker, A1C Colbert & Amn Tyson |
Louis Howard |
| 11/4/2009 |
Update or Other Action |
MEMORANDUM FOR DISTRIBUTION FROM: 3 CES/CEANR 6326 Arctic Warrior Drive Elmendorf AFB AK 99506-3240 SUBJECT: Federal Facilities Agreement (FF A) Document Schedule Amendment for SS22 1. An updated schedule for primary* and secondary** SS22 documents is enclosed. This schedule is an amendment to the Elmendorf AFB FFA. Document Type Secondary Draft Remedial Investigation Report 1 Apr 2011 Secondary Draft Baseline Risk Assessment 31 May 2011 Secondary Draft ARARs Evaluation 28 Ju12011 Primary Draft RIIFS Report 14 Oct 2011 Secondary Draft Proposed Plan 22 May 2012 Primary Draft Record of Decision 19 Mar 2013
NOTE to FILE: FFA 14.1 All Parties shall expeditiously transmit primary and secondary documents, and all notices required herein. Time limitations shall commence upon receipt. Primary documents include those documents that are major, discrete portions of RI/FS or RD/RA activities. Primary documents are initially issued by USAF in draft subject to review and comment by U.S. EPA and ADEC. *20.3 Primary documents include those documents that are major, discrete portions of RI/FS or RD/RA activities. Primary documents are initially issued by USAF in draft subject to review and comment by U.S. EPA and ADEC. Pending receipt of comments on a particular draft primary document, USAF will respond to the comments received and issue a draft final primary document subject to dispute resolution. The draft final primary document shall become the final primary document either thirty ~ (30) days after submittal of a draft final document if dispute resolution is not invoked, unless otherwise agreed as provided in Paragraph 20.18, or as modified by decision of the dispute resolution process. U.S. EPA and ADEC shall, within the first fifteen (15) days of this thirty (30) day period for finalization of primary documents, identify to USAF any issues or comments in order to provide sufficient time for review, discussion, and modification of draft final documents as necessary to resolve potential disputes.
20.5 USAF shall complete and transmit draft documents for the following primary documents to U.S. EPA and ADEC for review and comment in accordance with the provisions of this Part: (a) Base-wide Investigation Work Plan (b) RI/FS Management Plan, including Work Plan, Field Sampling Plan ("FSP”), Quality Assurance Project Plan ("QAPP”), and Treatability Study Work Plan, (c) Community Relations Plan (“CRP”) [Base-wide], (d) RI/FS Report (including RI, Baseline Risk Assessment, FS), (e) ROD(s), (f) Remedial Design/Remedial Action ("RD/RA”) Scope of Work, including: Critical path schedule for RD/RA and start of RA work element, Funding needs and availability for RD/RA, Description of each remedial work element, CRP Amendment, (g) Remedial Design and (h) Remedial Action Work Plan **20.4 Secondary documents include those documents that are discrete portions of the primary documents and are typically input or feeder documents. Secondary documents are issued by USAF in draft subject to review and comment by U.S. EPA and ADEC. Although USAF will respond to comments received, the draft secondary documents may be finalized in the context of the corresponding primary documents.
20.7 USAF shall complete and transmit draft documents for the following secondary documents to U.S. EPA and ADEC for review and comment in accordance with the provisions of this P a r t : (a) LFI Work Plan (b) LFI Report (c) Conceptual Site Model/Data Quality Objectives (d) ARARs Evaluation (e) Health and Safety Plan ("HSP”) (f) Base-Wide Background Sampling Plan (g) Base-Wide Ecological Survey (h) RI Report (i) Baseline Risk Assessment (j) Proposed Plan (k) 5% Remedial Design (1) 60% Remedial Design |
Louis Howard |
| 11/10/2009 |
Meeting or Teleconference Held |
Meeting Minutes for Phase 2 RI Summary & Proposed Scope for Additional Field Investigation Spill Site 22 (TO-034)Elmendorf Air Force Base, Anchorage, AlaskaContract No. FA8903-08-D-8770 Date: 10 November 2009 Time: 0800 Alaska Daylight Time Location: Conference Room Building 5312 Elmendorf AFB, Alaska 1. ATTENDEES Representatives of the United States Air Force (USAF) 3rd Civil Engineer Squadron (3 CES)/Asset Management Flight, Natural Resources Element, Restoration Section (CEANR), the US Environmental Protection Agency (EPA), the Alaska Department of Environmental Conservation (ADEC), & AECOM met for a meeting to discuss the remedial investigation (RI) for Task Order (TO) 034 being conducted under Contract No. FA8903-08-D-8770.
The purpose of the meeting was to discuss with the regulatory agencies an appropriate & agreeable path forward to address identified data gaps to complete the RI characterization activities. SS22 RI RESULTS TO DATE, CONCLUSIONS & RECOMMENDATIONS The meeting began with a discussion of those anomalies at SS22 that ADEC commented on in their September 28, 2009, letter to Melissa Markell. Since the data were previously presented during the September 24, 2009, meeting, it was decided that the discussion would be reserved only for those areas requiring further investigation or those areas on which ADEC commented in their letter dated September 28, 2009. During this discussion, several comments/concerns were raised by representatives from both the EPA & ADEC. In an effort to streamline the meeting minutes, comments that surfaced during these discussions are summarized within a Q & A forum following the presentation of SS22 RI Results to Date, Conclusions, & Recommendations.
Anomaly 02 & 03. Although each of the individual COPCs may not be tightly delineated (i.e. TPH) with quantitative sampling results, the qualitative data strongly suggest that the nature & extent of source area contamination in Anomalies 02 & 03 have been sufficiently delineated to proceed with a FS. For Anomaly 2, the TPH exceedances are clustered together in one location & since the anomaly boundary is well defined & groundwater has not been impacted, as indicated by MW08, there is minimal value in refining the delineation. For Anomaly 3, the single TPH exceedance has been delineated in all directions except to the west. Any dissolved phase TPH plume would have long since reached dynamic equilibrium such that impact to an offsite receptor is highly unlikely. PCB contamination is low level, widely dispersed & no source has been identified at the site. Ra-226 exceedances were found in the subsurface soil, radioactive items were found buried in Anomaly 3, & the nature of the radiological contamination (small, discrete sources) precludes delineation of these materials within any anomaly. Based on the above, it was recommended that further investigation of these two areas is not necessary. Following the presentation of the data at these two sites, there was a discussion regarding the need for additional delineation of TPH at anomaly 2. After a discussion of the data gaps, it was generally agreed that one additional soil sample from a depth of 3 to 5 feet bgs on the west side of Anomaly 2 would be sufficient to close the perceived data gap for delineation of the TPH-DRO.
Anomaly 5. One surface soil & one subsurface soil sample were collected for laboratory analysis at Anomaly 5 during the Phase 2 RI. A co-located surface soil sample had several PAHs present well above ADEC cleanup levels, while the primary sample had concentrations that were more than two orders of magnitude lower. Additional sampling is required to determine whether PAHs could potentially impact receptors at the anomaly. The scope of work proposed for this anomaly is to collect surface soil samples from three additional locations approximately 20 feet south/southwest, north/northeast, & east/southeast of 05SB01. These data will confirm whether PAHs are an issue in surface soil at the site & require a remedial measure to prevent exposure. Surface soil data from Anomaly 4 & the Debris Pile confirm no PAHs at the surface in those directions.
Anomaly 9. Sampling results at this anomaly show minor exceedances of chromium & PCBs, though both are below ADEC cleanup levels. However, the area is downgradient of a suspected solvent plume source (based on 10SB17 data) that is not delineated to the west. For this reason, two soil samples are being proposed for collection from a boring just west of 10SB17 to confirm that the apparent source area found in 10SB17 is delineated in a westerly direction.
See site file for additional information. |
Louis Howard |
| 12/1/2009 |
Update or Other Action |
Semi-annual progress report received. SUMMARY OF WORK PERFORMED DURING LAST SIX MONTHS- Completed Phase 2 field work (Aug 09) and Presented preliminary interpretations of data with a plan for Phase 3 investigation (Sep 09). PLANNED ACTIVITIES FOR NEXT SIX MONTHS-Distribute draft Radiological Characterization Report for agency review (Dec 09) and Submit a draft Work Plan addendum for the Phase 3 RI fieldwork (Jan 10). |
Louis Howard |
| 12/7/2009 |
Update or Other Action |
MEMORANDUM FOR DRMS/OWDA (DRMO Anchorage) FROM: 3 AMDS/SGPB SUBJECT: VOC Sample Results, DRMO (Site SS22) December 7, 2009.
1. On 2 Nov 2009, Bioenvironmental Engineering (BE) conducted air monitoring for VOCs at the Anchorage DRMO (workplace identifier 0687-DPHS-581A). MSgt Nicole Bradley, SrA Timothy Heath, SrA Emanuel-Madrigal Zamora & A1C Marceea Colbert sampled with the help of Ms. Margie Steward of DRMO. The driver for this survey was a letter BE received from 3 CES, dated 8 Oct 2009 (see Atch 1), listing particular concerns of carbon tetrachloride detected in soil gas & an undelineated TCE GW plume. Although these chemicals are underground, approximately 100 yards from occupied DRMO facilities, sampling was performed to determine if there was any vapor intrusion.
2. BE performed passive air sampling using two 6-liter Summa canisters as recommended by the AF Center for Environmental Excellence (AFCEE), with equipment contracted from Air Toxics Ltd. of Folsom, CA. Canisters had an initial vacuum of > 30 inches Hg & were fitted with devices pre-calibrated by the company to control airflow at 7.6 ML/min to collect a total of 5 Liters over 12 hours. Two areas were sampled after being identified by shop personnel as the most occupied. Sampling was done after-hours to ensure the area was unoccupied, thus minimizing movement & ensuring a "worst case" sample. One canister (#34194) was placed on the Customer Service desk in the administrative area, Bldg 12745, & started sampling at 1806. The other canister (#34190) was placed on a work station in the receiving warehouse, Bldg 12755, & started sampling at 1813. MSgt Bradley returned 12hours later, on 3 Nov 2009 at 0600 & verified the final vacuum of each canister was good (7 inches Hg), indicating successful sampling. Canisters were shipped back to Air Toxics Ltd. for VOC analysis.
3. The chemicals of concern (carbon tetrachloride & TCE) were not detected. Laboratory reporting limits were kept very low, in the parts per billion (ppb), to ensure that any low levels of the target chemicals were captured. Because of the low reporting range, ethanol exceeded lab detection limits in one sample but is estimated to be less than 1 part per million (ppm). Other VOCs detected were low level ppb. Based on results, carbon tetrachloride & TCE found during soil & groundwater studies have not infiltrated DRMO facilities. No further sampling is necessary at this time. Full lab results are provided as Atch 2. Nicole A. Bradley MSgt, USAF, NCOIC, Bioenvironmental Engineering. Analytical Data from Site SS22 & Community Environmental Board Meeting
1. Enclosed for your use are three compact disks (CDs) containing analytical data collected from Site SS22 during 2007, 2008, & 2009. These data are summarized in tables & in figures included on the CDs. The investigation results indicate previously unanticipated contamination in soil, GW, & soil gas, in addition to the radiological contamination of which you are already aware. Of particular note are the relatively high concentrations of carbon tetrachloride found in soil gas throughout the site, & the undelineated TCE plume in GW that appears to travel directly toward the DRMO facility. The extents of the soil gas issues & the GW contamination are unknown at this time.
2. Because of the current data gaps, CEANR (with concurrence from USEPA & ADEC) is expanding the investigation area for the SS22 Remedial Investigation to include an additional 24 acres as shown on the attached map. A field investigation to address the data gaps is scheduled for 2010.
3. The current conceptual site model & plans for additional investigation will be presented at the Community Environmental Board CEB) meeting (Wednesday, 4 Nov 09, at 1900, location: Howard Johnson's Plaza Hotel, 239 West 4t Avenue, downtown Anchorage). CEANR anticipates that the EPA & ADEC regulators present, in addition to members of the public at the meeting, will have questions regarding worker health & safety at the DRMO facility. CEANR recommends that BEE provide a representative to attend the CEB meeting & address these issues. BEE representatives may also want to participate in CEB meeting pre-briefs with Mr. Danny Barnett on 2 Nov 09, 0930, main CE conference room, & Col. Mark Camerer on 2 Nov 09, 1400, in his office.
4. CEANR recommends proactive communication with DRMO staff regarding any concerns they may have about this situation. Our Public Affairs representative for environmental restoration (Ms. Renee Wright, 552-5756) & I are available to assist with this effort should you wish. Please contact me at 552-7111 if you have any questions.
NOTE: Modified EPA Method TO-15 GC/MS Full Scan reporting limit for TCE at 4.6 and 2.7 ug/m3 are above the residential December 2012 EPA residential level of 2.0 ug/m3. Industrial/Commercial level is 8.4 ug/m3. |
Louis Howard |
| 1/11/2010 |
Document, Report, or Work plan Review - other |
EPA provides comments to the Air Force regarding the Draft SS22 Radiological Characterization Survey dated November 2009. It contains conflicting conclusions about the results of the statistical comparisons used to evaluate sample Radium 226 (Ra-226) concentrations against the mean background concentration of 0.96 average picocuries per gram (pCi/g). For example, Section 4.3.2 (Anomaly Area #3) states that the results for all samples except sample numbers SS22AN03-SS-001 at 1.5 pCi/g, SS22AN03-SS-007 at 1.3 pCi/g, and SS22AN03-SS-009 at 1.6 pCi/g were not statistically distinguishable from the Ra-226 background value; however, it does not include samples number SS22AN03-SS-003 at 1.3 pCi/g or SS22AN03-SS-013 at 1.3 pCi/g, even though sample 007 was also detected at 1.3 pCi/g.
Additionally, Section 4.3.1 (Anomaly Area #2) states that the results for all samples, except sample number SS22AN02-SS-007 at 1.9 pCi/g and SS22AN02-SS-015 at 19.2 pCi/g, were not statistically distinguishable from the Ra-226 background value; however, it does not include sample SS22AN02-SS-017 reported at 1.7 pCi/g, which is a concentration that is within the range of sample concentrations at Anomaly Area #3 determined to be statistically different from background.
Section 4.5.4 (Subsurface Soil Boring Summary) states “[N]o subsurface soil boring sample contained a Ra-226 concentration statistically distinguishable from the background Ra-226 concentration of (0.96 + 0.07 pCi/g). However, Table 4-9 lists sample AN02-SS-025B07-N-01-0002 as having a concentration of 2.5 + 1.7 pCi/g. Since surface soil results with Ra-226 concentrations lower than 2.5 pCi/g (e.g., 1.9 pCi/g at Anomaly Area #2) were listed as statistically significantly different from background, it is unclear why a subsurface result at 2.5 pCi/g would not be considered statistically different from background. The text in the referenced sections do not state what statistical methods were used to evaluate the data, and if the results were determined not to be statistically significant based on the large uncertainty associated with the results (e.g., 2.5 + 1.7 pCi/g where 1.7 is large compared to the reported result).
The lack of information regarding how these statistical evaluations were conducted and how the decision rules were applied, would be remedied if the Data Quality Objectives (DQOs) which describe how the data were to be evaluated were presented in the report. A response and text revisions about how the characterization results were evaluated, what statistical methods were employed, and what decision rules apply (i.e., the statistical test criteria for acceptance or rejection of the hypothesis) is required to understand the objective and outcomes of the characterization effort.
Sections 4.3.1 (Anomaly Area #2), Section 4.3.2 (Anomaly Area #3), and Section 4.3.2 (Anomaly Area #11) provide a listing of sample results in Tables 4-3, 4-4, and 4-5 respectively, which do not include the maximum count rates that are recorded in Table 4-1: Walkover Survey Summary Statistics for the same anomaly areas. [Note that Section 4.3.2 is a duplicative section number for anomaly areas #3 and #11 and should be corrected.] For instance, the maximum count rate listed in Table 4-1 for Anomaly Area #2 is 132,451 counts per minute (cpm), yet the Table 4-3 sample results listing for Anomaly Area #2 has the maximum count rate listed as 75,556 cpm. The same is true for all three anomaly areas. Please provide a response or text revisions to explain the differences between sample ranges (in cpm) listed in Table 4-1, and those provided in Tables 4-3, 4-4, and 4-5.
The DQOs discussed in Section 4.10 should be expanded to demonstrate that all seven steps of the DQOs were developed and implemented for this characterization effort in accordance with those specified in the Radiation Characterization Survey Work Plan (referenced on page 1-1 of the report), and as required by EPA guidance document EPA QA/G-4, Guidance on Systematic Planning Using the DQO Process [EPA/240/B-06/001, February 2006] (EPA DQO guidance). For example, the DQO section (Section 4.10) provides a listing of the number of grid samples collected per anomaly, the scan minimum detectable concentration (MDC), and the laboratory MDC for Ra-226; however, it does not provide a consolidated summary of how all of the DQOs for the project were met.
It is recognized that much of this information is dispersed throughout the report in Sections 2 and 3; however, it appears that based on the statements provided in Section 4.10 of the report, that the number of samples and MDCs are the only defined DQOs for the project. Furthermore, the Radiation Characterization Survey Work Plan referenced on page 1-1 is stated to be included in Appendix E; however, Appendix E contains the MDC calculations, not the referenced Work Plan.
See site file for additional information. |
Louis Howard |
| 5/11/2010 |
Update or Other Action |
Management Plan Addedendum for Phase 3 Remedial Investigation received. The objectives of the Phase 3 RI are two-fold: (1) to fill remaining data gaps within SS22 East following the Phase 2 RI; and (2) incorporate the adjacent property (SS22 West) into the phased RI/FS process as outlined in the original MP. The goal of the Phase 3 RI is to further evaluate past hazardous waste disposal practices and spill sources as identified by previous investigations. Specifically, to fill data gaps (i.e., eliminate uncertainties) in the CSM that are preventing a complete understanding of the source, extent, and chemical fate and transport of COPCs across the site (both SS22 East and SS22 West).
Because of the nature of the Ra-226 contamination and the fact that radioactive commodities were located within a trench from an anomaly that did not detect elevated counts during the previous gamma walkover survey, health physics monitoring is being proposed for all remaining intrusive activities. The Phase 3 RI is designed to collect the appropriate type, quantity, and quality of data to characterize the nature and extent of contamination at SS22 West, and quantify the risks that contamination may cause to human health and the environment. In addition to incorporating SS22 West into the project, remaining data gaps from the first two phases of the RI at Anomalies 2, 5, 9, and 10 within SS22 East need to be filled.
A sixth secondary study question was subsequently added as part of the 2009 MP Addendum for Soil Gas Investigations and has been included in the following table for completeness; which will also account for any sub-slab soil gas should its collection beneath site structures become necessary.
Phase 3 of the investigation at SS22 East will include the collection of soil and discrete-depth groundwater samples for definitive analysis from soil borings and groundwater samples from existing and proposed groundwater monitoring wells. • Collection of soil samples to complete delineation of identified contamination at each of the previously identified anomalies. • Collection of discrete-depth groundwater samples for vertical delineation of chlorinated solvents found in groundwater suspected to be sourced by waste identified at Anomaly 10. • Installation, development, and sampling of permanent monitoring wells to delineate the nature and extent of elevated TCE concentrations identified in MW14. • Sampling of all previously existing monitoring wells for those analytes previously detected above 75% of their screening criteria within each respective monitoring well. • Collection of soil gas samples from areas outside of the known anomaly boundaries and away from suspected groundwater plumes.
See site file for additional information.
|
Louis Howard |
| 5/25/2010 |
Document, Report, or Work plan Review - other |
Staff reviewed & commented on the Management Plan Addendum for the Phase 3 Remedial Investigation/Feasibility Study, SS22 (DRMO Storage Yard). For releases associated with leaded gasoline or aviation gasoline (AVGAS), analysis for ethylene dibromide (EDB) & 1,2-Dichloroethane (1,2-DCA) is required by ADEC. EPA 8260 is required for the analysis of 1,2-DCA. EDB is used exclusively in aviation gasoline because chlorine is corrosive to aluminum parts. EPA Method 8011 or EPA Method 504.1 should be used when evaluating EDB. EDB soil samples should be field preserved in hexane.
EPA 8260 will quantify EDB in ground water; however, the detection limits do not meet the Table C cleanup level of 0.00005 mg/L. ADEC requests the Air Force include EDB & 1,2-DCA as part of the full analytical suite for soil & groundwater investigation at SS22 West mobilizations & for all groundwater samples at SS22 East. If the groundwater samples at SS22 East & SS22 West are below cleanup levels for EDB & 1,2 DCA then they may be eliminated as contaminants of concern. This same statement applies for soil samples at SS22 West.
2. Project Background 2.1 RI Approach Page 2-1: The text seems to suggest that the Air Force will consider the entire area as an exposure area over which to calculate risks. If so the Air Force may be pooling all data regardless of source area & may potentially dilute risk estimates. ADEC requests the Air Force provide clarification on this matter.
2.1.2 Phase 2 Page 2-7: The text suggests areas within the site will be assessed. ADEC requests the Air Force provide clarification on this matter. It appears that the primary radionuclide of potential concern (ROPC) is Ra-226 at Anomalies 2, 3, & 11. All other radionuclides detected at the site were either below background or the screening value. (Radiological Risk Assessment Process Addendum 1.1 Hazard Identification Page D-1). ADEC requests the Air Force consider conducting interim remedial actions for the other Anomalies/areas at SS22 which do not have Ra-226 above the human health screening level of 2 picocuries per gram (pCi/g), but do have exceedances of a federal or state promulgated cleanup levels of other contaminants of concern in soil (e.g. Anomaly 12 4,4-DDT 420 mg/kg 10-12 feet (ft.) below ground surface (bgs) Sample ID 12SB01).
2.2.1.4 Anomaly 4 Page 2-10: ADEC requests the Air Force provide a statistical test of significant difference between site arsenic & background to substantiate the statement made. It appears that diesel range organics (DRO) is above promulgated cleanup level (250 mg/kg) at Sample ID 4SB-08 which had DRO results of 1,700 mg/kg at 3-5 ft. bgs. This anomaly appears to be a candidate for the Air Force to conduct an interim remedial action to address the DRO contamination. Ra-226 is not above the human health screening level of 2 picocuries per gram (pCi/g) at this anomaly.
2.2.1.5 Anomaly 5 Page 2-11: ADEC requests the Air Force to please refer to ADEC’s Guidelines for Data Reporting, Data Reduction, & Treatment of Non-detect Values - Technical Memorandum 08-001 August 12, 2008 for guidance on the handling of duplicate data. The guidance states that the more conservative (higher concentration) should be used to represent the sampling location. Additional sampling will not negate the use of the prior data exceeding screening levels. ADEC agrees that all data be carried forward into the risk assessment as stated. After additional sampling results are available & before any risk assessment is conducted, an interim remedial action could be performed at Anomaly 5. This anomaly appears to be a candidate for an interim remedial action to address the polynuclear aromatic hydrocarbon (PAH) contamination above promulgated cleanup levels currently present at 1-2 ft. bgs. There is no Ra-226 above the human health screening level of 2 pCi/g at this anomaly.
2.2.16 Anomaly 6 Page 2-12: This anomaly appears to be a good candidate for an interim remedial action. Contamination is limited to 0-1 ft. bgs for benzo(a)pyrene & other COCs detected at 1-2 ft. bgs for: GRO 2,100 mg/kg (300 mg/kg), DRO 5,800 mg/kg (250 mg/kg), 1,3,6-Trimethylbenzene 31 mg/kg (23 mg/kg), Benzene 0.19 mg/kg (0.025 mg/kg), & Ethylbenzene 11 mg/kg (6.9 mg/kg). There is no Ra-226 above the human health screening level of 2 pCi/g at this anomaly 2.2.1.7 Anomaly 7 Page 2-12: ADEC requests the Air Force provide information on whether the extent of polychlorinated biphenyl (PCB) contamination greater than one (1) mg/kg has been defined.
2.2.1.11 Anomaly 11 Page 2-14: ADEC requests the Air Force provide a statistical test of significant difference between site arsenic and background to substantiate the statement made. The EPA RSL for lead is 400 mg/kg is ADEC’s Method 2 cleanup level. The relative percent exceedance of 400 mg/kg is irrelevant.
See site file for additional information. |
Louis Howard |
| 6/8/2010 |
Document, Report, or Work plan Review - other |
EPA (J. Gusmano) commented on the Phase 3 RI/FS, SS22 (DRMO Storage Yard. 1. Section 2.2, “those samples that have concentrations that are above human health screening levels [SLs] but below either background levels, EPA residential Regional Screening Levels [RSLs], or ADEC cleanup levels, will be considered minor exceedances…these minor exceedances will not require further delineation.”
However, it is unclear if concentrations need to be below both the EPA RSLs & ADEC clean up levels to be considered a minor exceedance. For example, if the EPA RSL is 5 milligram per kilogram (mg/kg), the ADEC cleanup levels is 50 mg/kg, & concentration detected is 20 mg/kg, it is unclear if this would be considered a minor exceedance or a significant exceedance.
Further, it is unclear how the SLs differ from the RSLs, & the tables provided in Appendix A of the Draft MP Addendum do not provide this information. As such, the tables in the Draft MP Addendum should be revised to show the SLs, RSLs, ADEC cleanup levels, & background levels (where appropriate) so that exceedances can be verified.
Please revise the Draft MP Addendum to clarify what will be considered a minor exceedance versus a significant exceedance, & to provide screening criteria in the data tables presented in Appendix A.
2. The DQOs for the RI include the goal to determine the nature & extent (N&E) of contamination by filling remaining data gaps within SS22 East, & to incorporate the adjacent property (SS22 West). However, the Draft MP Addendum lacks sufficient information to demonstrate that the N&E DQO will be satisfied. Particularly, there are many cases where additional sampling has not been proposed & it appears that there are several exceedances that have not been bounded in all directions.
For example: • The text often indicates that metals concentrations narrowly exceeded background levels & no further investigation is proposed. • The text often indicates that Radium 226 (Ra-226) is present as point sources which cannot be located definitively with any reasonable effort & no further investigation is proposed. • Section 2.2.1.3 indicates that no source for PCBs was identified & therefore no additional delineation is planned.
These statements do not provide sufficient information to demonstrate that the extent of contamination is or will be adequately characterized, & do not provide sufficient justification to support the decision to limit further investigation. Please revise the Draft MP Addendum to provide further rationale/justification for the proposed Phase 3 sampling strategy & ensure that the text supports the achievement of the N&E DQO.
3. Background concentrations for metals are discussed in the Draft MP Addendum; however, the source of the background values is unclear. Also, the background values should be provided in the appropriate metals analytical results tables. Please revise the Draft MP Addendum to provide this information.
4. The summary of RI sample results presented in Section 2.2 often states no further investigation is warranted because there is sufficient information to complete the risk assessment & the fate & transport section of the RI report, even though there are exceedances that have not been bounded. Since the RI should demonstrate that the extent of contamination has been bounded, it is unclear why no further investigation has been proposed. Please revise the Draft MP Addendum to provide justification for the current approach.
5. The Draft MP Addendum proposes to collect three or four additional soil gas samples at locations outside of anomalies & not near a suspected GW plume. Further, Section 4.2.1.3 states, “As a result of the biased soil gas data already collected, it is believed that the worst case for soil gas impacts has already been evaluated…it is proposed that additional soil gas samples be collected at locations that are both outside of the anomalies & not in the vicinity of a suspected GW plume.” It is unclear, however, how this data will be useful in delineating the extent of the contamination.
Further, it is unclear how it can be assumed that the worst soil gas impacts have already been evaluated given that the extent of soil gas contamination is not yet defined. Please revise the Draft MP Addendum to clarify the rationale for collecting these proposed soil gas samples.
6. Several data gaps do not appear to have been adequately discussed in the Phase 2 summary provided in Section 2.2. However, according to Section 3, one of the objectives for the Phase 3 RI is to fill remaining data gaps within SS22 East. Please revise the Draft MP Addendum to provide additional discussion regarding the nature & extent of contamination at SS22 East so that it can be verified that all data gaps have been identified.
See site file for additional information.
|
Louis Howard |
| 7/1/2010 |
Update or Other Action |
The process for conducting a human health risk assessment (HHRA) from exposure to radionuclides at Spill Site 22 (SS22), Elmendorf Air Force Base will follow the same basic format as presented in Appendix C (Human Health & Ecological Risk Assessment Process Details) to the initial Remedial Investigation (RI)/Feasibility Study (FS) Management Plan (MP) (USAF 2008).
The five required steps include:
1. Hazard Identification
2. Exposure Assessment
3. Toxicity Assessment
4. Risk Characterization
5. Uncertainty Analysis
Results of the Draft SS22 Radiological Characterization Survey (USAF 2009) indicate that Radium 226 (Ra-226) is the primary radionuclide of potential concern (ROPC). The 2008 gamma walkover surveys were conducted in Anomalies 2, 3, & 11, where a previous investigation had detected radioactivity. Trenching & subsequent subsurface soil sampling for laboratory analysis were performed in these areas. Analytical results were reported for many different radionuclides, most of which are naturally occurring.
The Draft SS22 Radiological Characterization Survey (USAF 2009) compared activities from the various detected radionuclides with screening levels & background activities from soil samples collected from a background reference area in the northeastern corner of SS22. It was concluded that Ra-226 & its progeny are present in the form of intact items containing radioluminescent paint & contaminated soil. All other radionuclides detected at the site were either below background or the screening value. In addition, the survey states that groundwater samples from monitoring wells installed around the site are consistent with background Ra-226 concentrations.
There is no indication that migration of Ra-226 from buried radioactive sources or surface hot spots is impacting groundwater conditions in detectable concentrations. ROPCs for the radiological HHRA will be selected through a screening process. After the instrument background is subtracted from the analytical results for each detected radionuclide, the maximum activity will be compared to screening levels, such as the radiological PRGs established by the EPA.
Although radiological activities are generally compared to background activities in the initial stages of a radiological survey investigation, in HHRAs, background comparisons are made after the risks including background are estimated. Thus, radionuclides with maximum activities that exceed screening levels will be considered as ROPCs for inclusion in the HHRA. To complete the risk assessment & plan for future actions at the site, the AF is conservatively assuming that as-yet-undiscovered Ra-226 point sources are located within the waste of all anomalies at SS22 East.
With few exceptions, the preliminary conceptual site model (CSM) for the radiological HHRA will be the same as that provided in the Appendix C.1 (Human Health & Ecological Risk Assessment Process Details) to the initial RI/FS MP (USAF 2008). However, some revisions may occur following full evaluation of the data. Any revisions to the CSM will be discussed in the HHRA. Dermal contact with surface soil will not be addressed in this HHRA, as this exposure route is a very minor pathway for the radionuclides present at the site. As provided in EPA guidance (EPA 1989), dermal absorption of airborne radionuclides is not an important route of uptake, except for tritiated water vapor, which is efficiently taken into the body through dermal absorption. Tritium was not detected in the anomaly areas investigated.
Toxicity values for SS22 ROPCs will be obtained using EPA guidance for sites with radioactive substances. Dependent upon the type of radiation, exposure, & irradiated tissue, potential health effects include an increase in the probability of cancer induction, mutagenisis, & teratogenesis. Consistent with EPA guidance, cancer risk is used to evaluate health effects from ROPC exposure at SS22 (EPA 1989). Potential health effects for low levels of ionizing radiation are considered to have no threshold dose with no dose level providing zero risk & with the probability of cancer incidence increasing with the absorbed dose.
In general, the risk characterization will focus on the excess risk posed by chemicals released to the environment through operations conducted at SS22 (& not on risk caused by background concentrations); however, risk estimates with & without background contribution will be presented. The radiological carcinogenic risks for potential exposures at SS22 will be expressed in terms of the increased probability that an individual would develop cancer over a lifetime. The EPA has defined an incremental target for carcinogenic risks associated with contaminants at a site, which is an excess upper bound lifetime cancer risk to an individual of between one in ten thousand (1 × 10–4) & one in a million (1 × 10–6) (40 CFR 300). |
Louis Howard |
| 7/6/2010 |
Meeting or Teleconference Held |
Phase 3 RI Approach Meeting Minutes Spill Site 22 (TO-034) Elmendorf Air Force Base, Anchorage, Alaska Contract No. FA8903-08-D-8770 Date: 06 July 201 0 Time: 1300 Alaska Daylight Savings Time Location: Conference Room Building 5312 Elmendorf AFB, Alaska Representatives of the United States Air Force (USAF) 3rd Civil Engineer Squadron (3 CES)/Asset Management Flight, Natural Resources Element, Restoration Section (CEANR), the US Environmental Protection Agency (EPA), the Alaska Department of Environmental Conservation (ADEC), & AECOM met for a meeting regarding the remedial investigation (RI) at Spill Site (SS) 22, Task Order GO) 034 conducted under Contract No. FA8903-08- D-8770.
The purpose of the meeting was to discuss the RI approach for continuation through Phase 3 & applicable updates to chemical & radiological processes regarding how the collected data will be used in the risk assessment. This meeting was also conducted to seek regulatory approval for field activities as proposed in the Draft Management Plan Addendum. Background Information - Risk Assessment Process Addendum Following the welcome & introductions, Mr. Boyd delivered a brief background regarding the chemical risk assessment addendum, the radiological risk assessment addendum, & the RI approach. This information was previously submitted along with RTCs pertaining to regulatory review of the Draft Management Plan Addendum for the Phase 3 Remedial InvestigatiodFeasibiIity Study, SS22 (DRMO Storage Yard) to supplement & support the Air Force's approach to completion of the RIRS for SS22.
Several concerns were raised regarding the assessment of contaminants of potential concern (COPCs) in various media across the proposed exposure units; specifically regarding the assumptions & uncertainties on how each unit is defined. Ms. Walter explained that the use of exposure units was proposed & is consistent with EPA's Risk Assessment Guidance for Superfund (RAGS) & was certainly appropriate for the SS22 site. Ms. Brewer indicated that she preferred to not use data across an entire exposure unit, but rather just a single anomaly. The discussion continued on preferences for how to use the data in the risk assessment. It was ultimately agreed that the exposure unit for purposes of the risk assessment will be equal to the anomaly or area of concern. The exposure units for SS22 East will be 13 anomaly areas (Anomalies 2 & 3, & Anomalies 9 & 10 will be combined & identified as Anomaly 213 & Anomaly 9/10, respectively), the stressed vegetation area (SVA), & the debris pile.
Any anomalies identified at SS22West during the Phase 3 investigation will be incorporated into the risk assessment in a similar fashion. A summary of how this data will be used in the risk assessment will be presented in the Draft Final Management Plan Addendum for the Phase 3 Remedial Investigation/Feasibility Study, SS22 (DRMO Storage Yard). The approach for how soil gas data will be used in the risk assessment was also briefly discussed & it was agreed that the same exposure unit approach discussed for soil would also be used for soil gas. As a point of clarification, all data collected outside the boundary of an anomaly will be included in the risk assessment for that anomaly for which it was collected as determined by the sample ID. This applies to both soil & soil gas data.
Furthermore, the exposure unit approach for each anomaly agreed to in soil will be extrapolated to groundwater except that the exposure unit will be equal to the extent of the dissolved phase plume rather than an anomaly. If the area of an anomaly & a groundwater plume intersect, then the risk will be added together in those areas of intersection. There were no concerns with the radiological risk assessment approach, however, EPA will check with their senior radiological risk reviewer to confirm that the responses to comments address their concerns. In addition, concerns resurfaced regarding what appeared to be limited characterization at some anomalies based on defmitive data sets & how the risk assessment would be performed to address this.
There was a brief discussion regarding the sufficiency of the characterization at some of the anomalies. It was explained however that a large amount of screening data (geophysical survey, gamma walk-over survey, trenching, laser induced fluorescence, FID/PID, & XRF) was generated at each of the anomalies & used to identify the location of quantitative samples.
See site file for additional information. |
Louis Howard |
| 8/20/2010 |
Update or Other Action |
Air Force sent a spill report on August 20, 2010 to Mark Sielaff (PERP)-UXO Report. Date it was discovered was August 16, 2010 at 8:00 a.m. 12 - M29Al Bazooka Rockets (with live motors) uncovered during site investigation at SS22 (approximately 650 ft. SE of 11735 Vandenburg Avenue). Rockets were recovered (moved from site) by the Explosivie Ordnance Detail (EOD). EOD detonated the rockets at the EOD range using 16 blocks of C-4 (1.25 lbs. per block). Each rocket contained 5.6 oz. of M-7 propellant.
Work stoppage was ordered by the Air Force to the contractor on site to deal with the bazooka rounds uncovered during trenching activities. The rounds were found in anomaly 20.
NOTE TO FILE: The timeliness of notification of work stoppage at SS22 is not in accordance with the Federal Facility Agreement requirements.
XVIII. Creation of Danger/Emergency Action Pages 31-32 18.2 In the event USAF determines that activities undertaken in furtherance of this Agreement or any other circumstances or activities at the Site are creating an imminent and substantial endangerment to the health or welfare of the people on the Site or in the surrounding area or to the environment, USAF may stop implementation of this Agreement for such periods of time necessary for U.S. EPA and ADEC, to evaluate the situation and determine whether USAF should proceed with implementation of the Agreement or whether the work stoppage should be continued until the danger is abated. USAF shall notify the other Parties as soon as is possible, but not later than twenty-four (24) hours after such stoppage of work, and provide U.S. EPA and ADEC with documentation of its analysis in reaching this determination. If, after consultation with ADEC, U.S. EPA disagrees with the USAF determination, it may require USAF to resume implementation of this Agreement.
18.3 If U.S. EPA concurs in the work stoppage by USAF, or if U.S. EPA or ADEC require or order a work stoppage, USAF’s obligations shall be suspended and the time periods for performance of that work, as well as the time period for any other work dependent upon the work that was stopped, shall be extended, pursuant to Part XXV of this Agreement. |
Louis Howard |
| 8/23/2010 |
Document, Report, or Work plan Review - other |
Staff sent the Air Force (D. Aide) review comments regarding the Draft Final Management Plan Addendum for the Phase 3 Remedial Investigation/Feasibility Study, SS22 Elmendorf AFB, AK Draft May 2010.
General Comments Pursuant to the 1991 Elmendorf Federal Facility Agreement, Section XX, & as a Party to the Agreement, ADEC seeks to have the Air Force modify the above document to include information regarding munitions & explosives of concern (MEC). This modification is due to significant new information (bazooka rounds filled with propellant being uncovered during trenching activities at SS22) previously unavailable after the document was produced as a draft-final version.
XX. Consultation with U.S. EPA & ADEC J. Subsequent Modification Pages 41-42 20.23 A Party may seek to modify a document, including Attachment 1, after finalization if it determines, based on new information (i.e., information that became available, or conditions that became known, after the document was finalized) that the requested modification is necessary. A Party may seek such a modification by submitting a concise written request to the Project Managers of the other Parties. The request shall specify the nature of the requested modification & how the request is based on new information. 20.24 In the event that a consensus among the Parties is reached, the modification shall be incorporated by reference & become fully enforceable under the Agreement. In the event that a consensus is not reached by the Project Managers on the need for a modification, any Party may invoke dispute resolution as provided in Part XXI to determine if such modification shall be conducted.
Modification of a document shall be required only upon a showing that: (1) the requested modification is based on significant new information, & (2) the requested modification could be of significant assistance in evaluating effects on human health or the environment, in evaluating the selection of remedial alternatives, or in protecting human health & the environment. Additionally, in accordance with the Federal Facility Agreement, Part XVIII, the Air Force should have notified (within 24 hours after stoppage of work) both ADEC & EPA project managers when a work stoppage occurred at SS22 due to the bazooka rounds causing an “imminent & substantial endangerment to the health or welfare of the people on the Site or in the surrounding area or to the environment.” XVIII. Creation of Danger/Emergency Action Pages 31-32
18.2 In the event USAF determines that activities undertaken in furtherance of this Agreement or any other circumstances or activities at the Site are creating an imminent & substantial endangerment to the health or welfare of the people on the Site or in the surrounding area or to the environment, USAF may stop implementation of this Agreement for such periods of time necessary for U.S. EPA & ADEC, to evaluate the situation & determine whether USAF should proceed with implementation of the Agreement or whether the work stoppage should be continued until the danger is abated. USAF shall notify the other Parties as soon as is possible, but not later than twenty-four (24) hours after such stoppage of work, & provide U.S. EPA & ADEC with documentation of its analysis in reaching this determination. If, after consultation with ADEC, U.S. EPA disagrees with the USAF determination, it may require USAF to resume implementation of this Agreement.
See site file for additional information.
|
Louis Howard |
| 8/26/2010 |
Update or Other Action |
Email from Air Force to ADEC/EPA RPMs: The contractor backfilled the trench today (26 Aug) with an UXO Technician II/III present to provide oversight. Attached is their updated Task Hazard Analysis which includes the updated UXO Awareness document. This is being incorporated into the site specific health and safety plan.
One bazooka rocket (same as before) was encountered while backfilling. Fire Dept and EOD responded and the UXO was removed. All trenching operations are now complete for Phase 3 and the contractor will demob tomorrow. We expect to have validated data toward the end of Sep or beginning of Oct and will schedule a meeting at that time in order to direct our second mobilization efforts. |
Louis Howard |
| 10/1/2010 |
Document, Report, or Work plan Review - other |
Upon review of the military specifications for Propellant M7, it is recommended that additional munitions constituents be sampled for to characterize the nature contamination associated with the rockets found during the 2010 field effort. ADEC is requesting the Air Force consider using SW8330B for soils and groundwater.
This method includes the munitions constituents of interest. During the meeting Tuesday, sampling of perchlorate in groundwater down gradient of where rockets were located was proposed. Although this analysis may evaluate potential migration from the source area, it is not adequate for characterizing the potential risk at the source area where the munition items were found. If no munition constituents are found in soil or groundwater using SW8330B, then they likely may be eliminated as a contaminant of concern for Anomaly 20.
Please keep in mind, that although the management options are already being considered for the site, risks must be assessed without such regard to future remedial actions or implementation of institutional controls. [EPA/540/1-89/002 Risk Assessment Guidance for Superfund Vol. 1 Human Health Evaluation Manual- Part A: 1.1.2 Site Characterization (RI)"Part of the human health evaluation, the baseline risk assessment (Part A of this manual) is an analysis of the potential adverse health effects (current or future) caused by hazardous substance releases from a site in the absence of any actions to control or mitigate these releases (i.e., under an assumption of no action)."] We are already making a huge compromise by not requiring the full characterization of each source area, but assuming a single worst case sample result should provide a conservative estimate of risk. This approach should also be taken in regard to attempting to characterize the potential risks posed by munitions related source materials at the source area and for all of the contaminants of potential concern associated with such source material.
It is also recommended that further data be provided for the white solid substance at Anomaly 16 (".an unidentified white solid substance that was drummed for disposal.) and the white crystalline material discovered at Anomaly 21 (".a white crystalline material were removed from the trench and set aside for disposal.") at SS22. Any waste characterization data or fixed lab analytical data should be evaluated by the remedial project managers before we concur to the determination that this material from both anomalies is benign in nature. |
Louis Howard |
| 10/4/2010 |
Update or Other Action |
USAF Response to ADEC comments: We have reviewed your request for additional sampling and analysis with respect to the discarded military munitions (DMM) discovered at Anomaly 20 and propose the following changes to the scope of our 2nd mobilization.
1. We propose sampling the downgradient monitoring wells (MW-22,MW-23, & MW-24) for both perchlorate (Method 6850) and nitroglycerin (Method 8330B).
2. We propose that no additional soil sampling occur in Anomaly 20 for safety reasons associated with the DMM. As a possible alternative, we suggest analyzing the existing soil samples for perchlorate and nitroglycerin. The samples will be outside the 14 day holding time and would be flagged/qualified by the laboratory, but the data could be used to determine if perchlorate and nitroglycerin are present in the soil at the anomaly.
3. The laboratory data requested for the white solid material from Anomaly 16 and Anomaly 21 is attached. This data was used for disposal parameters. The other tests that the lab performed were qualitative and no data deliverable was prepared. All we have is what was provided during the meeting:
a. Qualitative lab analyses showed that the material is mostly sodium and phosphorous/phosphate and may be a surfactant such as mono-di-or trisodium phosphate.
b. Nothing organic was present - the crystals did not dissolve in an organic solvent but did dissolve in water.
c. ICP/MS - lots of sodium and a small amount of phosphorus.
d. Ion Chromatography (IC) - lots of phosphate with a little chloride and sulfate (results are relative to each other) no quantitation was performed. |
Louis Howard |
| 11/17/2010 |
Meeting or Teleconference Held |
A meeting of the remedial project managers (RPMs) convened at 0900 on 17 November 10 at the Joint Base Elmendorf-Richardson (JBER)-Richardson Conference Room in Building 658. Attendees included: Mr. Bill Adams - Environmental Protection Agency (EPA); Mr. Louis Howard - Alaska Department of Environmental Conservation (ADEC); Mr. Robert Shirley - Air Force Center for Engineering and Environment (AFCEE) Western Region Environmental Office; Mr. Nick Muszynski - AFCEE Restoration - Program Management Office (R-PMO); Mr. Rafael Vazquez - AFCEE R-PMO; Mr. Jim Klasen - lith Air Force Environmental Attorney; Ms. Renee Wright - Environmental Restoration Community Relations Coordinator; and CEANR personnel - Mr. Gary Fink, Mr. Mark Prieksat, Ms. Donna Bawnler, Mr. Don Aide, Mr. Tim Plucinski, Mr. Dick Nenahlo, and Ms. Cynthia Tomlinson.
SS22 Remedial Investigation and Feasibility Study (RIfFS) - Mr. Aide explained that during this summer's field activities included a geophysical survey, which identified 13 additional anomalies in the western portion of SS22; dummy bazooka rockets were found in Anomaly 20; and a radioactive survey was conducted. Volatile organic compounds (VOCs) in groundwater exceeded the cleanup level in 11 anomalies and it appears that this contaminated groundwater plume is contributing to the Slammer Plume within the ST37 site boundaries. The Remedial Investigation (RI) report is expected in April 2011. |
Louis Howard |
| 12/14/2010 |
Meeting or Teleconference Held |
Meeting with AF, ADEC, EPA and contractor to discuss preliminary RI data from site. Data Summary & 2010 Results [Please note that the following is based on final validated data. There were a few instances where the preliminary data the Air Force provided at the last meeting has changed.]
Anomaly 1: The only COPCs detected above human health screening levels at the site were PCBs & metals & the metals were all below background levels. The investigation at this anomaly was already deemed complete in 2009 for both the RI & risk assessment.
Anomaly 2: The only data gaps identified in 2009 & being filled this year were the delineation of TPH DRO to the west with sample 02SB08 & a sample for dioxins from the black ash layer noted during trenching (sample 02SB09). The TPH-DRO is now delineated to the west. The black ash does contain dioxins above screening levels however the ash layer is contained within the boundary of the anomaly. No additional data is necessary to complete the RI or risk assessment.
Anomaly 3,4 6, 7, 8, 11, 13, 14, 15 Debris Pile, : No data gaps were identified in 2009 & no additional data is necessary to complete the RI or risk assessment. Anomaly 5: One data gap was identified in 2009 & was filled in 2010 with three samples for PAH Anomaly 9: One data gap was identified in 2009 at Anomaly 10 & was closed with the collection of three samples for VOC analysis. No additional data isnecessary to complete the RI or risk assessment. Anomaly 10: One data gap was identified in 2009, but the samples were actually collected from Anomaly 9 as described above. No additional data are necessary to complete the RI or risk assessment.
Anomaly 12: One data gap was identified in 2009 related to the soil gas hit of carbon tetrachloride. This gap was closed with the collection of three soil samples from two locations which were analyzed for VOCs. A source for the carbon tetrachloride was not found. No additional data is necessary to complete the RI or risk assessment.
Stressed Vegetation Area: One data gap was identified in 2009 to complete the vertical delineation of TPH. One sample was collected from a depth of 4-5 feet & analyzed for TPH. No additional sampling is necessary to complete the RI or the risk assessment.
Anomaly 16: Trenching at this anomaly indicated that the waste extends to a depth of approximately 6 feet bgs. Waste that was observed in the trench showed the presence of numerous drums & some scrap metal. Groundwater was sampled from a temporary monitoring well (TMW-01) & exceeded screening criteria for TCE at a concentration of 3.8 pg/L & arsenic at 0.16 pg/L. The TCE is most likely associated with the Anomaly 10 TCE plume. Arsenic is present in nearly all of the groundwater monitoring wells at the site, including upgradient wells, & is believed to be associated with background conditions. In addition, the concentrations of both I C E & arsenic are below their respective ADEC groundwater cleanup levels.
Soil samples indicate that antimony, TPH-RRO, DDT & PCBs have been detected above screening levels. The TPH-RRO is below ADEC cleanup levels & the DDT & PCBs have been delineated vertically. Antimony, which is relatively immobile & not a leaching concern, was not detected above screening levels in the temporary monitoring well installed at this anomaly. No additional sampling is necessary to complete the RI or the risk assessment. Anomaly 17: Trenching at this anomaly indicated that the waste extends to a depth of approximately 8 feet bgs.
Waste that was observed in the trench includes mostly scrap metal such as drums, pipes, sheet metal & empty compressed gas cylinders. Groundwater was sampled from TMW-02 & exceeded screening criteria for TCE, PCE, carbon tetrachloride, & 1,1,2,2-tetrachloroethane as well as arsenic & mercury. The VOCs are clearly associated with the Anomaly 10 TCE plume. Arsenic is believed to be at background levels & both arsenic & mercury are below ADEC groundwater cleanup levels.
Soil samples were collected from three locations at three depths & the data show that only one organic compound, benzo(a)pyrene, had a minor exceedance which did not exceed the ADEC cleanup level. All other exceedances at this anomaly are for the metals aluminum, arsenic, cobalt, iron, lead, & manganese which are below basewide background levels. No additional sampling is necessary to complete the RI or the risk assessment.
See site file for additional information. |
Louis Howard |
| 1/28/2011 |
Update or Other Action |
Draft Radiological Characterization Survey received. The radiological assessment applied a 2 picocurie per gram (pCi/g) Ra-226 screening criterion that was established by the Department of the Air Force. A background reference area was established in the northeast corner of SS22 East. This area was selected based on review of historical photographs showing limited use of this area & the absence of geophysical anomalies. Average background surface soil concentrations for Ra-226 at the background reference area were calculated to be 0.96 ± 0.07 pCi/g.
In Anomaly Area #2, the walkover survey identified four areas of elevated surface radioactivity where Ra-226 soil levels were likely greater than the established screening level of 2 pCi/g. A hot spot surface soil sample from Anomaly Area #2 recorded Ra-226 approximately 10 times the site screening level. The Anomaly Area #2 trench investigation also identified concentrations above the screening level in the subsurface soil.
In Anomaly Area #3, the walkover survey identified one area of elevated surface radioactivity. However, surface soil samples recorded Ra-226 less than the screening level. It was also noted that one compass dial & one gauge dial containing Ra-226 were recovered from the Anomaly Area #3 test trench.
In Anomaly Area #11, the walkover survey identified one area of elevated surface radioactivity where Ra-226 likely exceeded the screening level. The highest concentration of Ra-226 at SS22, 166 ± 6 pCi/g, was observed in a subsurface soil sample collected from the Anomaly Area #11 test trench.
With the exception of one direct push subsurface soil sample collected in close proximity to a previously identified area of elevated radioactivity, the results of these samples were consistent with background radionuclide concentrations. A scoping/characterization survey of SS22 West was conducted in July 2010 in accordance with a WP Addendum. This effort included 100% gamma walkover surveys of 13 geophysical anomalies areas identified inside the DRMO fence & inside the RV Lot.
These walkover surveys were followed up by surface soil sampling at several locations that demonstrated elevated gamma counts & also exploratory trenching. The soil/debris from the trenches was also scanned for radioactive materials & soil samples were taken when radioactive materials were identified. The results of the SS22 West characterization are summarized below. Gamma walkover surveys identified only 2 locations of surface or near surface radioactive materials, both in Anomaly Area #19. Ra-226-containing items were identified in & recovered from eight of the 13 exploratory trenches excavated in the geophysical anomalies.
Most of these eight trenches yielded more than one source. Residual Ra-226 soil contamination was identified at levels greater than the 2 pCi/g screening level in five of the eight trenches. Samples were only collected if a radioactive item was located. Results from groundwater sampling indicate that groundwater has not been impacted. Based on the nature of the contaminant, groundwater is not expected to become impacted in the future. Residual Ra-226 contamination will be addressed in the SS22 76 risk assessment & remedial investigation/feasibility study report.
The greatest imminent risk posed by the presence of radioactive materials &/or contamination in these areas would be an event in which an individual unknowingly handled a radioactive item from the site. This could result in low level contamination of the individual’s hands & small potential uptake of radioactive material. For this reason, restrictive land use controls should be implemented to prevent intrusive activities on site except when appropriate health physics monitoring is conducted.
See site file for additional information. |
Louis Howard |
| 2/10/2011 |
Update or Other Action |
Staff received the Draft Zone 3 Mgt. Area Annual Report. NOTE to file: Slammer Avenue plume is downgradient and linked to source area SS-22 DRMO contaminated site.
Staff received the Draft Zone 3 Mgt. Area Annual Report. TCE concentrations measured at well OU5MW-06 (15 and 17 ug/L [duplicate samples]) and well OU5MW-07 (17 ug/L) exceeded the groundwater cleanup level of 5 ug/L; these concentrations are similar to those measured at these wells in 2009. No other VOCs were detected at concentrations above cleanup levels.
Biogeochemical indicator parameters measured in samples from the Slammer Avenue Plumes suggest an environment that varies from oxidixing (aerobic) to reducing (anaerobic). Anaerobic (reducing) conditions were present at wells GW-4A and OU5MW-06. In contrast, aerobic (oxidizing) conditions were observed at wells OU5MW-07 and OU5MW-08 in 2010. The ranges of individual parameter values and the corresponding interpretation of the active electron acceptor processes reported for data in 2010 are generally consistent with findings from previous monitoring events, indicating that the biogeochemical conditions at this site are not changing significantly over time.
Data from plume interior well and OU5MW-07 indicate that TCE will be relatively recalcitrant in these areas, and reductive dechlorination rates will be slow. The more highly anaerobic and reducing conditions observed at GW-4A, which may be caused by natural sources of organic carbon discharging to groundwater from existing wetlands, are conducive to a faster rate of TCE degradation than at upgradient locations. The presence of oxygen-depleted, reducing conditions at the toe of the Slammer Avenue Plumes is expected to help maintain plume stability by attenuating TCE that migrates into this area.
The 2007 RPO evaluation (USAF, 2008a) identified the Slammer Avenue Plumes as a Red priority site because the TCE concentrations in the eastern portion of the plume (now the eastern Slammer Avenue Plume) were not decreasing. TCE concentrations measured in wells OU5MW-06 and OU5MW-07 in 2010 were similar to concentrations measured in these wells in 2009. TCE concentrations at well OU5MW-06 are declining over time, suggesting that natural attenuation processes will eventually cause TCE concentrations to decline below the cleanup level in the western Slammer Avenue Plume. TCE concentrations in samples from well OU5MW-07, however, are largely unchanged over time, suggesting that the eastern Slammer Avenue Plume will persist above cleanup standards beyond the anticipated 2025 cleanup date identified in the ROD. Based on the data from OU5MW-07, the Red priority designation for the Slammer Avenue Plumes remains appropriate.
As discussed in the 2007 RPO evaluation, the source area(s) for the Slammer Avenue Plumes needs to be investigated, and source removal/treatment should be initiated if appropriate. Discrete groundwater samples were collected during the 2010 field season as part of a study performed to evaluate the current horizontal and vertical extent of individual plumes within Site ST37. The results of this study will be reported in 2011. The downgradient extent of TCE contamination in the eastern Slammer Avenue Plume is uncertain. Collection of discrete groundwater samples should be considered to 1) define the nature and extent of contamination, and 2) identify if one or more new sampling locations should be established and added to the Zone 3 Management Area monitoring program. |
Louis Howard |
| 3/4/2011 |
Update or Other Action |
U.S. Air Force (Donald Aide) notifies EPA and ADEC of the SS22's project delays via electronic mail. "The current contract for SS22 has exhausted all of its ceiling. Due to the ongoing federal budget issues we are experiencing delays in obtaining additional funding. Therefore the document schedule for the SS22 project will not be met by the AF. Until the funding issues are resolved we will not be able to determine the length of extension that we will require. At that time we will submit a formal written request for extension as is required in the FFA, under Section XXV. Extensions."
NOTE to the file: the 1991 Federal Facility Agreement-Elmendorf Air Force Base states: XXV. EXTENSIONS 25.1 Either a deadline or a schedule shall be extended upon receipt of a timely request for extension and when good cause exists for the requested extension. Any request for extension by USAF shall be submitted in WRITING to the Project Managers and shall specify: a. The deadline or the schedule that is sought to be extended; b. The length of the extension sought; c. The good cause(s) for the extension; and d. Any related deadline or schedule that would be affected if the extension were granted. Good cause exists for an extension when sought in regard to: a. An event of Force Majeure; b. A delay caused by another Party's failure to meet any requirement of this Agreement; c. A delay caused by the good faith invocation of dispute resolution or the initiation of judicial action; d. A delay caused, or that is likely to be caused, by the grant of an extension in regard to another deadline or schedule; and e. Any other event or series of events mutually agreed to by the Parties as constituting good cause.”
25.2 Absent agreement of the Parties with respect to the existence of good cause, USAF may seek and obtain a determination through the dispute resolution process that good cause exists. 25.3 Within seven (7) days of receipt of a [WRITTEN] request for an extension of a deadline or a schedule, the other Parties shall attempt to advise USAF, in writing, of their respective positions on the request. Any failure by the other Parties to respond within twenty-one (21) days shall be deemed to constitute concurrence in the request for extension. If either U.S. EPA or ADEC does not concur in the requested extension, it shall include in its statement of nonconcurrence an explanation of the basis for its position.
25.4 If there is consensus among the Parties that the requested extension is warranted, USAF shall extend the affected deadline or schedule accordingly. If there is no consensus among the Parties as to whether all or part of the requested extension is warranted, the deadline or schedule shall not be extended except in accordance with a determination resulting from the dispute resolution process. |
Louis Howard |
| 10/20/2011 |
Update or Other Action |
Draft Remedial Investigation for Spill Site 22 received. This draft RI report does not include a risk assessment because that is being prepared as a separate stand-alone document at this stage. Following regulatory review of the draft baseline risk assessment & the draft RI, which includes the draft radiological characterization survey, these three documents will be merged along with a draft feasibility study (FS) into a draft RI/FS. Potential ARARs & TBC criteria are being prepared as a separate stand alone document. The ARARs will be incorporated into the draft RI/FS document.
The objectives of the RI are to present a complete understanding of site contamination & to define the nature & extent of contamination across the entire site to support risk assessment & remedial activities that might be necessary at SS22. The radiological characterization survey, baseline risk assessment, & ARARs evaluation are being prepared separately & will eventually be included in the Draft RI/FS document. It is the focus of this report to address the field efforts associated with filling specific data gaps that were preventing a complete & comprehensive CSM (i.e., the source, extent, & chemical fate & transport of COPCs across the SS22 study area).
All of the data were screened in the risk assessment that is being prepared as a separate document & will later be incorporated into the RI/FS document. The RI portion of this study was performed in accordance with the RI/FS MP (USAF 2008c) & its addenda (USAF 2010) to identify source areas & characterize the nature & extent of contamination at each of the source areas. The radiological characterization survey, baseline risk assessment, & ARARs evaluation are being prepared separately & provided under separate cover. It is the focus of this report to address the field efforts associated with filling specific data gaps that were preventing a complete & comprehensive CSM (i.e., the source, extent, & chemical fate & transport of COPCs across the SS22 study area).
All of the above three documents will ultimately be combined with the FS & incorporated into a single draft RI/FS document. The data collection portion of the RI was performed to collect the appropriate type, quantity, & quality of data to fulfill the project objectives. The RI field efforts were completed in three separate phases between 2007 & 2010 & was conducted in an iterative manner so that data gaps identified as the project progressed could be addressed in subsequent phases to allow a better understanding & comprehensive delineation of site contamination.
Phases 1 & 2 of the RI were performed to evaluate soil, GW, & soil gas contamination at SS22 East, whereas Phase 3 was largely performed to incorporate SS22 West into the study & to fill data gaps that had been identified at SS22. The SS22 site has historically been used for materials storage & handling operations including subsurface disposal of wastes in pits & trenches that are closely associated with the 28 geophysical anomalies identified. In addition to the 28 disposal areas, a debris pile & SVA have also been identified as AOCs. The field observations of debris that could act as potential sources at each of the areas are summarized in Table 4-1. In addition to geophysical surveys & trenching activities, both field screening & definitive analyses were conducted for samples collected from various media to define the nature & extent of contamination at each of the identified AOCs.
Results from the data collection efforts of the RI show soil exceedances for VOCs, PAHs, PCBs, & metals occur in the majority of the AOCs. COPC exceedance statistics for soil have been compiled & summarized in Table 6-1, & those exceedances above ADEC cleanup levels (referred to as significant exceedances) are presented in Table 6-2. GW contamination (primarily as a dissolved-phase chlorinated GW plume extending off site) & soil gas contamination have also been identified.
Soil Contamination A summary of all significant soil exceedances for each of the chemical classes discussed in Section 5 is provided below. It should be noted that all of these COPCs at the SS22 study areas have been sufficiently characterized to determine their nature & extent. This is based on definitive data as well as the fact that most of the contaminants are relatively immobile & are sourced by waste disposed of mostly in pits such that the delineation of the waste is sufficient to delineate the contamination. Minor exceedances were observed for relatively immobile COPCs such as PCBs & metals, but were not delineated in surface soil. These data were assumed to be representative of the anomaly from which they were collected & will be evaluated that way in the risk assessment.
See site file for additional information. |
Louis Howard |
| 11/18/2011 |
Document, Report, or Work plan Review - other |
EPA Jacques Gusmano Remedial Project Manager submits review comments on the Draft RI report. 1. The Draft Remedial Investigation for Spill Site (SS) 22 (the RI Report) does not include a risk assessment. Table 3-13 of the United States Environmental Protection Agency (USEPA) Guidance for Conducting Remedial Investigations & Feasibility Studies Under CERCLA, EPA/540/G-89/004, dated October 1988 (the Guidance) displays a suggested RI report format , which includes risk evaluations of both human health & the environment. Please revise the RI Report to include a risk assessment section for SS 22. If a separate document will be submitted to address risk at SS 22, then please state this within the RI Report & indicate when the risk assessment will be completed.
2. A Review of an RI without ARARs & a Risk Assessment, make the effort problematic. In addition, the use of exact screening criteria was confusing & vague in this document.
3. Many instances in this document COCs exceed apparent screening criteria but the reviewer is uncertain if this is considered a data gap or will be dealt with as a risk uncertainty. Stating that the RPMs decided the nature & extent has been investigated sufficiently does not mean that there is no risk uncertainty, & this fact must be carried forward in the FS.
4. The Vapor Intrusion issue is very troubling; COCs exceed screening criteria but no follow-up is suggested, no crawl space sampling or indoor air sampling; this risk cannot be overlooked.
5. A recent Report for ST37 indicates that the TCE plume at a location directly down gradient of the western edge of the SS-22 plume is at a much deeper depth in the groundwater than indicated in this RI Report. This surely would indicate a data gap.
6. An overall summary of the data usability has not been provided in the RI Report. A section summarizing any rejected data & how it impacts project completeness & data usability should be provided. Additionally, any overall trends or biases in the data should also be discussed. Please revise the main text of the RI Report to include a discussion on the overall data usability.
7. The terminology employed to describe the munitions related items presented in the RI Report is in need of correction & standardization. Specifically, the items described by the varying terms as “ bazooka rocket motors,” “bazooka rockets,” “ FUSE, ROCKET, DUMMY, M-405,” & “Fuse, Rocket & Dummy, M-405 rounds,” should be, based on an analysis of the accompanying discussions, referred to as, “Rocket, Practice, 3.5-inch, M29 series.” Since these items are described as “rounds,” this indicates that all of the components required to fire the associated weapon are present for each “round” located. In this instance, these are: The rocket fin assembly; the rocket motor & included igniter & propellant; the dummy fuze, rocket, M405; & the warhead assembly, which is inert.
Some issues involving the above noted descriptions found in the RI Report are as follows: - “Bazooka rockets” is a slang term used to refer to both the 2.36-inch rockets used in World War II & the early phases of the Korean War, & the 3.5-inch rockets used during the Korean & Vietnam wars. If the term “bazooka rocket” is used, it could be either of these two rocket types. In addition, this usage does not indicate whether the item is a high explosive antitank rocket, a practice rocket, or a white phosphorous rocket. - “Bazooka rocket motors” indicates that only the motor is present. It does not indicate whether the propellant & igniter are present (i.e., whether the item is unfired or fired). - “Fuse, Rocket & Dummy, M-405 rounds,” contains a contradiction. If it is a fuze, (not a “fuse” as stated) then it cannot be a round, since a round is, by definition, all of the components required to fire a weapon once. Please review the use of the terms noted above & correct them as necessary at all occurrences in the RI Report & attached appendices.
8. The RI Report does not appear to address the potential for munitions & explosives of concern (MEC) to be present in those areas where munitions related items have previously been found on the site. Experience has shown that salvage yards & other locations where supposedly inert munitions related items have been temporarily located or permanently disposed often contain one or more items that have energetic components that classify them as MEC. Please provide a statement as to when these issues will be addressed.
9. Section 4.4 (Subslab Soil Gas Sampling & Vapor Intrusion), Figure 4 33 (VOC [volatile organic compound] Exceedances for Subslab Vapor Samples – SS22 West & East), & Table 4-38 (Subslab Soil Vapor Results) do not identify the screening levels being utilized to evaluate subslab soil gas & vapor intrusion.
See site file for additional information. |
Louis Howard |
| 11/22/2011 |
Update or Other Action |
673 CES/CEANR 6326 Arctic Warrior Drive JBER, AK 99506-3240 Memo for Distribution (i.e. memo to the site file) SUBJECT: Revision of the Federal Facility Agreement Document Schedule for Spill Site 22 on JBER-Elmendorf 1. Spill Site 22 (SS22) was incorporated into the JBER-Elmendorf(JBER-E) FFA on 14 May 2008. At that time Federal and State Federal Facility Agreement (FFA) Project Managers, along with the U.S. Air Force (USAF) FFA Project Manager established a schedule for primary and secondary documents under the FF A.
This schedule has since been amended on 18 Sep 2008 and 04 Nov 2009 due to the discovery of radioactive waste and expansion of the site boundaries. However, recent contractual and funding issues have resulted in a failure to meet the schedule as delineated.
2. Schedule updates and/or modifications to the schedule require unanimous written agreement between the Project Managers. As such, the Project Managers are asked to review the attached revised document schedule for SS22. Please indicate if you concur/non-concur with this request to modify the FF A document schedule for SS22 and sign the enclosed agreement.
I. Project Managers agree to the proposed revision of the SS22 document schedule.
2. The revised document schedule will be included as an attachment to the FF A: Document Type Document and Date Due for Agency Review Secondary Draft Baseline Risk Assessment 15 Dec 2011 Secondary Draft ARARs Evaluation 23 Jan 2012 Primary Draft RIIFS Report 29 Jun 2012 Secondary Draft Proposed Plan 15 Feb 2013 Primary Draft Record of Decision 09 Aug 2013
3. This schedule may be updated or modified to include additional primary or secondary documents as necessary to meet FFA requirements. Signed by Gary Fink, FFA Project Manager U.S. Air Force, Jacques Gusmano FFA Project Manager U.S. EPA, Louis Howard FFA Project Manager ADEC. |
Louis Howard |
| 11/23/2011 |
Update or Other Action |
Draft Risk Assessment received for SS22. Uncertainties in Estimation of Site-Related Risk EPA guidance indicates that carcinogenic risks & non-cancer HQs resulting from various multiple chemicals should be considered additive. In the absence of supporting data for synergy or antagonism, the assumption of additivity could overestimate or underestimate potential cancer risk or HQs for receptors. In addition, chemicals in this HHRA were initially screened against federal soil criteria. If the maximum detected level was below the criteria, the chemical was not evaluated any further.
As a result, only the chemicals that exceeded the screening criteria were carried through the RA process & the possibility of additivity among the chemicals was not taken into account. Additionally, site risk estimates include the sum risk from pathways that all use high-end exposure assumptions. The probability of receptors’ exposure reflecting high-end values for all exposure pathways is likely low. Thus, final risk estimates are conservative in predicting actual risks expected for these sites. The degree of this potential overestimation is considered moderate.
Overall, the methods & assumptions used in this HHRA are considered conservative in the estimation of HH risks. Therefore, the risk estimates presented are necessarily protective & not accurately predictive. Actual risks posed by the anomalies are moderately overestimated as a result. Many generic &/or chemical specific assumptions are used to calculate the cancer risk & noncancer hazards. One generic assumption is that the HHRA conservatively assumes 100% bioavailability for all chemicals carried through the RA process. If arsenic is assumed to be 25% bioavailable in accordance with Copeland & Fehling (2008) & chromium is assumed to be 50% bioavailable in accordance with Witmer, Harris, & Shupack (1991), the HIs would be decreased for exposure to both surface & subsurface soil. Therefore, the inclusion of the generic assumptions in the risk & hazard calculations could overestimate the risk & hazard estimates.
Conclusions of the Tier 2 ERA The results of the RI indicated that antimony, cadmium, & selenium & one phthalate in soil may be present at levels high enough to cause adverse effects to terrestrial wildlife receptors (LOAEL-based HQs exceed 1). Anomaly areas of ecological concern were identified which require further evaluation or remediation. Migration of contaminated GW to offsite surface water does not present a potential risk of adverse effects to ecological receptors.
Conclusions [for Radiological Risk to Human Receptors] The radiological HHRA conducted characterized the dose & risk from the sole ROPC, Ra-226. Since much of the data used in this HHRA was biased characterization data, the resultant dose, & risk may represent a worst case scenario. Although dose & risk through GW exposure are less than the 25 mrem/yr & 1E–04 guidelines, respectively, dose & risk from soil exposure ranged widely across receptors & anomaly areas with the smallest dose & risk estimated for the construction worker & the greatest dose & risk estimated for the hypothetical future resident.
These doses can be compared to the 300 to 350 mrem the average US resident receives per year from natural background radiation. As a result of the peak analytical result for the site, 166 pCi/g in Anomaly 11 subsurface soil, the peak dose & risk for the future resident were estimated at 36,100 mrem over a 30-year exposure duration & 3E-02, respectively. Removal of background contributions provided negligible reduction in calculated dose & risk. Since Ra-226 contamination is only present as discrete radiologic artifacts & small areas of surrounding soil contamination & since soil shields many of these artifacts, some buried to more than 20 ft deep, the biased data used in this HHRA provides an extremely conservative estimation of the site risk.
Since the primary exposure pathway contributing to dose & risk is external gamma radiation, the results of the gamma walkover surveys are more indicative of the average dose & risk from the site. These surveys showed little or no increase in the average radiation levels measured at ground level when compared to background with only a few small areas above background (minimum detectable level of the survey was less than 2 pCi/g Ra-226+D). Therefore, a radiological risk or dose based on the external gamma radiation levels averaged over each anomaly area rather than on biased EPC results in more realistically indistinguishable from background.
Conclusions for Radiological Risk to Ecological Receptors Additional investigation (i.e., detailed dose assessment) is not warranted based on the results of the analysis herein. Biota dose evaluations indicate that there is no potential adverse impact from radiation as a stressor to populations of biota at SS22.
See site file for additional information. |
Louis Howard |
| 12/13/2011 |
Update or Other Action |
Air Force Response to EPA comments 1) : It is unfortunate that the reviewer was not provided any background or history for this site because the FFA clearly calls for a separate draft risk assessment & draft RI report. The Risk Assessment was submitted under separate cover to the AF on 11/22/11. The fact that separate risk & RI documents were prepared as agreed to was stated in the Draft RI on several occasions & as early as the first paragraph within the Executive Summary. The Draft RI report will not be revised, but the responses to comments will be incorporated into the Draft RI/FS, which will include risk assessment & ARARs sections.
2) Agreed. Because of the separation of the risk assessment & ARARs we were forced to focus the document on identification & delineation of source areas & COPCs in soil, soil gas, & GW. It is unfortunate that the FFA called for separate documents for the RI, ARARs, & risk assessment. Screening criteria incorporated into the RI were previously agreed upon by the core project team as presented in the MP & it’s addenda, as well as a detailed discussion on how they were used (with Table references to the values) to meet the RI objectives. Second full paragraph on Page 4-3 spells this out. Some of the language regarding screening criteria was a bit confusing & this will be corrected in the Draft RI/FS.
3)Response: COPC exceedances are not by themselves a data gap unless they are not delineated. All exceedances have been carried forward into the risk assessment & will be carried into the FS at the Draft RI/FS document stage. This comment appears to be related to the Nature & Extent section. It does not appear to be appropriate to discuss risk in a nature & extent section of an RI document that doesn’t have a risk assessment.
4) Response: No risk is being overlooked. It is simply addressed in the risk assessment, which will eventually be incorporated into the Draft RI/FS document. Again, we agree it is awkward to separate the risk assessment from the rest of the RI report at this stage, but that was agreed to early on.
5) Response: The referenced report was unavailable for our use during the preparation of the Draft RI. We were forced to assume that the AF completed the delineation of the TCE plume addressed in the ST37 report. Without more specifics, it is impossible to respond to this comment. Following a cursory review of the ST37 report, it appears that the delineation of the eastern ST37 plume is largely if not entirely complete. It is the AF’s opinion that the eastern ST37 plume is sufficiently complete as a result of the fact that the distance to the regional GW discharge point (i.e., Ship Creek) is no more than 200 to 500 feet from existing monitoring points.
There would be little value in collecting data in this area, since the existing wells & surface sampling points can be used as points of compliance
6)Response: The data usability section was included in the Draft Risk Assessment & will be a part of the Draft RI/FS.
7) Response: Agreed. The language will be corrected & standardized.
8) Response: While it is possible that MEC is present in certain locations at the site, to date no MEC has been found despite all the trenching that has been conducted. Furthermore, it would require excavation of the entire site to rule it out. Due to the prohibitive cost of excavating the entire site, the AF is willing to assume that MEC may be present at various locations & will treat the entire site accordingly. This is similar to the situation for radiological sources. Language to this effect will be added to the report.
9) Response: The screening levels used will be added to Section 4.4, Figure 4-33, & Table 4-38.
10) Response: This is addressed in the radiological risk assessment, which was submitted to the AF on 11/22/11.
11) Response: Agreed. While the information is contained in Appendix A, Ra-226 will be added to the Tables.
12) Response: Section 4 Tables will be cross-referenced against Table 6-2 & the text within the summary discussions in Section 6.1.1 to ensure that all significant exceedances are properly captured.
13) Response: These statements were intended as a general approach since each AOC had specific target analytes being delineated. Also, the specific depth-intervals were also greatly varied based on field observations/screening (or default depths in the absence of field/screening indicators). The above information would be too voluminous to repeat for each location at each depth interval.
Since this information is not entirely accounted for within the Tables & Figures as presented in the Draft RI report, a new Table will be created & incorporated into the Draft RI/FS Report as a cross-reference guide indicating the target analyte list for each location (& depth), similar to Table 3-3: Target Analysis for GW Samples.
See site file for additional information. |
Louis Howard |
| 12/21/2011 |
Update or Other Action |
Air Force response to ADEC comments on the RI. Executive Summary Page ii The use of the term “significant exceedance” was used to determine whether contamination had been sufficiently delineated, as described in the 2010 Management Plan Addendum for Phase 3 of the RI/FS that the core project team agreed to. The term has nothing to do with risk & is not used in the risk assessment. Because the risk assessment was stripped out of the RI, the primary purpose of the RI document was to determine whether contamination had been identified & delineated & to evaluate fate & transport characteristics of the contaminants. As such, no change is necessary.
Project screening criteria (PSC) were defined in the 2008 Management Plan & use the RSLs except when one does not exist, in which case the lower of the ADEC direct exposure cleanup levels was used.
Furthermore, if a COPC had both carcinogenic & non-carcinogenic risk values, the lower of 1/10th the non-carcinogenic risk & the carcinogenic risk was used. The term significant exceedance makes use of all of the ADEC cleanup levels & was used solely to complete the delineation of COPCs during Phase 3 of the RI. Language has been added to the first full paragraph on page ii of the ES as follows: “Results from the data collection efforts of the RI were compared against project screening levels (EPA regional screening levels [RSLs] for residential soil &, where an RSL is not available, the appropriate ADEC value) as detailed & agreed upon within the RI/FS Management Plan & its addenda. Comparison of the RI data against the project screening levels show soil exceedances for…” & clarification of which ADEC levels are being used will be added throughout the document
All data were screened against the project screening criteria, & the investigation proceeded as spelled out in the RI Approach (Appendix F of the RI). All the data were evaluated in the risk assessment.
The specific criteria & the rationale for how the investigation proceeded, as well as the use of the “significant exceedance” terminology were detailed in Appendix F of the RI. It was our intention to follow that approach as agreed to by the core project team & present the data as clearly as possible within that context. It is unclear whether the TCE plume statements here are regarding risk assessment screening levels, RI screening levels, or ARARs. The RI screening levels were determined as described above & previously agreed to by the ADEC.
Page iv The Ra-226 comment appears to be a risk assessment comment rather than an RI comment. AECOM did not have the referenced report for ST037 during preparation of the Draft RI, however that document has since been made available & a cursory review made. The figure being referenced shows the depth bgs for the groundwater data. It is impossible to say what portion of the aquifer is impacted, since the depth to GW is not shown in the figure. It appears that the data represents the top 20 to possibly the top 30' of the aquifer. Furthermore, dissolved phase chlorinated solvents do not “sink” like their non-aqueous phase liquid counterpart. In fact, in this part of the aquifer near the regional discharge point, it is expected that the vertical component of the groundwater gradient is in an upward direction, which would tend to limit the downward advection & dispersion of the contaminant plume.
Reference to the ADEC GW Cleanup Level of 5 µg/L for TCE has been incorporated on pages iv & v. It should be pointed out that the vertical extent of the dissolved phase plume was determined both in the source area & at different locations including the downgradient property line through the use of temporary wells & discrete GW grab samples. The dissolved phase plume was found to be limited to the upper 20 feet of the aquifer in nearly all instances. This is entirely consistent with a vadose zone source, which is what exists at Anomaly 10.
Page v & vi Soil gas screening levels are the levels from the 2002 EPA OSWER Subsurface Vapor Intrusion Guidance referenced in the comment, which has been added to the third sentence under the Soil Gas Contamination within the ES on page v. These levels were agreed to in the 2009 Management Plan Addendum for Soil Gas Investigations (EPA 530-D-02-004). The question of further sampling should be addressed once the risk assessment has been reviewed. If the risk assessment does not show excess risk, no additional sampling will be proposed.
As indicated in the RI Approach that was agreed to, the investigation focused primarily, but not exclusively on the mobile contaminants & those with significant exceedances. This statement simply states that the contaminants & their sources have been identified & delineated to the extent agreed to by the core project team.
See site file for additional information. |
Louis Howard |
| 12/23/2011 |
Document, Report, or Work plan Review - other |
Staff reviewed & commented on the Draft Human Health, Ecological, & Radiological Risk Assessments for Spill Site 22 Joint Base Elmendorf-Richardson, AK November 2011. Table 2-1 Anomaly 16 field observation should include mention of the “white substance”. Hazardous characterization analyses (for disposal purposes) were conducted on the substances from Anomaly 16 & 21, but other analyses (e.g. pesticides/herbicides) were not conducted on the substances nor from the area where the material was removed.
Figure 2-2 Suggest updating figure title to more clearly convey content. Please include what contamination is being referred to & the criterion used for assessment of exceedances. Table 3-2 Preliminary Screening Levels higher than the 18 AAC 75 Table C Groundwater Cleanup Levels 2,6-Dinitrotoluene at 3.7 ug/L (1/10th NonCancer EPA 2010c) is higher than the Table C Groundwater Cleanup level of 0.0013 mg/L or 1.3 ug/L. bis(2-Ethylhexyl) phthalate at 4.8 ug/L (EPA 2010c) (c) is higher than the Table C Groundwater Cleanup level of 0.0013 mg/L or 1.3 ug/L.
5.1 Hazard Identification Page 5-1 Please note, the United States Environmental Protection Agency Regions 3, 6, & 9. Regional Screening Levels for Chemical Contaminants at Superfund Sites have been updated as of November 2011. The last version before this update was June 2011. Page 5-3 Soil gas screening criteria should correspond to the cancer risk level of 10-6 & HQ of 0.1 for the consideration of cumulative risks from multiple COPCs &/or exposure pathways.
Page 5-6 Site work including excavation may exposure site/construction workers to groundwater. This exposure pathway should be considered. Table 5-3 Please include COPC screening criteria corresponding to the cancer risk level of 10-6 & HQ of 0.1 & reference their source. 5.2.4.4 Surface Water Please note that regardless of surface water risks calculated, water quality standards apply (18 AAC 70 & the Alaska Water Quality Criteria Manual adopted by reference).
5.7 Summary of Estimated Risk by EU Please present the ILCR & HI for each exposure scenario assessed (Future resident, outdoor site worker/construction worker, & indoor site worker). In addition to discussing whether risk levels exceeded acceptable criteria, please state the risk estimate calculated.
5.8.4.4 Results of Risk-Based Surface Water Screen for Recreational Visitor Please note that regardless of surface water risks calculated, water quality standards apply.
5.9 Lead Evaluation Please note ADEC has calculated an industrial/commercial lead cleanup level of 800mg/kg
See site file for additional information. |
Louis Howard |
| 1/3/2012 |
Document, Report, or Work plan Review - other |
EPA provided comments after reviewing the HHERA for SS22. Section 2.3, Previous SS22 Investigations, states that soil and groundwater investigations of SS22 have occurred since 2002. However, earlier investigations are described in the Alaska Department of Environmental Conservation (ADEC) Contaminated Sites Database. For example, an entry from June 1, 1998 describes an investigation of a scrap pile where drums of various kinds were disposed and staining was observed. Please revise the Draft Human Health, Ecological, and Radiological Risk Assessment for Spill Site 22, United States Air Force, Joint Base Elmendorf-Richardson, Alaska, dated November 2011 (Risk Assessment) to provide a more thorough description of historical investigations.
A fire occurred in storage buildings in the 1950s in close proximity to many of the anomalies shown in Figure 2-2 (i.e., near the drums containing a tar-like substance). The documentation regarding the fire may contain information correlating the locations of the drums, as well as equipment such as transformers containing PCBs which may have been stored at this location. Because the fire described above occurred in the same area as SS22, it may be useful to review this file material and include any applicable historical information in Section 2 of the Risk Assessment.
Section 3, Data Evaluation, does not provide a complete assessment of the data usability. Section 3.0 should include a discussion of how the rejected data affects the completeness goals of the project. It should also include a discussion of how precision, accuracy, representativeness, comparability, and sensitivity parameters were met. Finally, any overall trends or biases in the data should be discussed. Please revise Section 3 to include a more detailed data evaluation discussion.
To the greatest extent possible in any subsequent revision of the document, please ensure that any discussions of generic residential exposures are relevant to adult and child subpopulations. The human health risk assessment (HHRA) indicates that toxicological criteria used in the quantitative assessment were taken from the November 2010 EPA Regional Screening Level (RSL) table. The RSL table was updated in November 2011. Please review the toxicological criteria used in the HHRA and ensure that the HHRA uses the most currently available toxicological criteria in the quantitative assessment available from EPA’s Integrated Risk Information System (IRIS) (also available from the November 2011 RSL Table), or describe any uncertainties associated with not using the most currently available toxicological criteria in the uncertainty analysis of the risk characterization.
The Risk Assessment considers exposure to chemicals in surface water by offsite receptors in Sections 5.2.1.2, 5.2.2, 5.2.4.4, and 5.8.1 and the CSM. It is unclear why dermal contact and incidental ingestion of sediment has not been included. Please revise the Risk Assessment to include this pathway or provide justification for excluding it. Throughout the Ecological Risk Assessment (ERA), there are sections or sentences that conflict with procedures used to conduct the Tier 1 ERA and Tier 2 ERA. Examples are provided below:
Section 6.1.7 describes the uncertainties associated with the Tier 1 ERA, which consisted of comparing maximum concentrations in surface soil and groundwater to direct-contact soil screening benchmarks for plants and soil invertebrates. However, species-specific exposure factors relevant to the evaluation of wildlife are discussed in Sections 6.1.7.1 and wildlife-associated concepts are discussed in Sections 6.1.7.2, and 6.1.7.3. This discussion does not apply to the Tier 1 ERA because wildlife food chain modeling was not conducted. Further, Section 6.1.7.3 discusses uncertainties associated with Hazard Quotients (HQs), although the concept of HQs is not discussed until later in the ERA in Section 6.2.4 Risk Calculations – Risk Characterization. Please revise these sections to clearly present the uncertainties related to the Tier 1 ERA and discuss the applicable uncertainties in the Tier 2 ERA, Section 6.2.5.
In Section 6.2.3.1, Ecotoxicity Reference Values for Food Chain Analysis, the last sentence of the first paragraph states, “For this study, the NOAEL [No Observed Adverse Effect Level] was used to screen the site COPEC [Chemicals of Potential Ecological Concern] list for risk from food chain exposure”; however, only direct-contact soil screening benchmarks for plants and soil invertebrates were used in the Tier 1 ERA so this statement is not applicable and should be deleted. Please ensure that all the procedures used to conduct the Tier 1 and Tier 2 ERA are clearly presented in the Risk Assessment.
See site file for additional information. |
Louis Howard |
| 1/10/2012 |
Document, Report, or Work plan Review - other |
Staff reviewed & commented on the Draft Identification of Applicable or Relevant and Appropriate Requirements for Spill Site 22
1.0 Introduction Include the following text in the first paragraph: CERCLA §121 provides that for any hazardous substance, pollutant, or contaminant that will remain on site, remedial actions undertaken pursuant to §§104, 106, 120, or 122 must satisfy any applicable or relevant & appropriate Federal requirement & any applicable or relevant & appropriate promulgated State standard, requirement, criterion, or limitation under State environmental or facility siting law that is more stringent than any Federal requirement if the State requirement is identified in a "timely" manner.
It is incumbent upon the AF, who is conducting the RI/FS, to provide sufficient information about the site & remedial alternatives to permit the State to identify potential applicable or relevant & appropriate requirements (ARARs). Fifth Paragraph 2nd sentence Add text so the sentence reads: “Under specific circumstances, only the substantive requirements….” Sixth Paragraph Last sentence on this page ADEC requests the Air Force provide supporting information for the statement: “Presidential executive orders are considered TBCs.”
Strike text: CERCLA Section 121(d)(4) provides for possible waiver of ARARs under the following six circumstances: Insert text: CERCLA §121 provides that under certain circumstances an otherwise ARAR may be waived. These waivers apply only to meeting ARARs with respect to remedial actions on-site; other statutory requirements, such as that remedies be protective of human health & the environment, cannot be waived. A waiver must be invoked for each ARAR that will not be attained or exceeded. The waivers provided by CERCLA §121(d)(4), some circumstances under which each waiver might be invoked, & criteria for invoking the waivers are discussed below.
First Bullet • Interim Measures: The remedial action selected is only part of a total remedial action that will attain such level or standard of control when completed.(CERCLA §121(d)(4)(A).) This waiver may be applicable to interim measures that are expected to be followed within a reasonable time by complete measures that will attain ARARs. The interim measures waiver may apply to sites at which a final site remedy is divided into several smaller actions.
Second Bullet • Greater Risk to Health & the Environment: Compliance with such requirement at the facility will result in greater risk to human health & the environment than alternative options. (CERCLA §121(d)(4)(B).) This waiver may be invoked for an ARAR that can only be met by using remedial action that, because it meets that ARAR, poses greater risks than a similar remedial alternative that does not meet that ARAR. This waiver could be used to “salvage” a remedial action option that would cause greater environmental damage or health risks solely because that option had to meet all ARARs, especially where one ARAR causes the problem.
Third Bullet • Technical Impracticability waiver: Compliance with an ARAR technically impracticable from an engineering perspective. The term “impracticable” implies an unfavorable balance of engineering feasibility & reliability. The term “engineering perspective” used in the statute implies that cost, although a factor, is not generally the major factor in the determination of technical impracticability. A remedial alternative that is feasible might be deemed technically impracticable if it could only be accomplished at an inordinate cost.
Fourth Bullet • Equivalent Standard of Performance waiver: The remedial action selected will attain a standard of performance that is equivalent to that required under the otherwise applicable standard, requirement, criteria, or limitation, through use of another method or approach. (CERCLA §121(d)(4)(D).) This waiver may be used in situations where an ARAR stipulates use of a particular design or operating standard, but equivalent or better remedial results (e.g., contaminant levels or reliability) could be achieved using an alternative design or method of operation.
Fifth Bullet • Inconsistent Application of State Standard waiver: With respect to a State standard, requirement, criteria, or limitation, the State has not consistently applied (or demonstrated the intention to consistently apply) the standard, requirement, criteria, or limitation in similar circumstances at other remedial actions. (CERCLA §121(d)(4)(E).)d. This waiver is intended to prevent unjustified or unreasonable restrictions from being imposed on cleanups. This waiver may be used in two situations.
See site file for additional information. |
Louis Howard |
| 1/13/2012 |
Document, Report, or Work plan Review - other |
EPA responses to Air Force responses to its comments received. Evaluation of the Response to General Comment 4: The response partially addresses the comment. It is understood the risk assessment has not yet been combined with the RI Report. However, the comment asks whether any additional sampling will be proposed based on the conclusions from the risk assessment. The response does not address this portion of the comment. Please revise the response to clarify whether any additional sampling will be conducted as a result of the risk assessment.
Evaluation of the Response to General Comment 5: The response partially addresses the comment. The response addresses concerns about horizontal extent of the TCE plume, but does not address the concerns expressed about the vertical extent. Please revise the response to also address the vertical extent of the TCE plumes related to Spill Site (SS)-22 & ST-37.
Evaluation of the Response to General Comment 10: The response indicates that the concern regarding insufficient characterization of subsurface radiological contamination & how this affects the adequacy of the risk assessment, has been addressed by the radiological risk assessment submitted on November 11, 2011. The HHRA was reviewed to determine how the HHRA addressed the concern raised in General Comment 10. Upon review, it was determined that Section 7.1.5 provides some useful information but does not fully communicate the concern about the limitations of the current Radium-226 (Ra-226) characterization data. Specifically, text in Section 7.1.5.1 page 7-27 acknowledged that soil is known to shield Ra-226 from gamma measurement at depths greater than 6 to 8”.
Additional text in Section 7.1.6 states “Since Ra-226 contamination is only present at the site as discrete radiological artifacts & small areas of surrounding soil contamination & since soil shields many of these artifacts, some buried to more than 20’ deep, the biased data used in this HHRA provides an extremely conservative estimation of the site risk.” The conclusion presented in the HHRA Section 7.1.6 indicates that although Ra-226 is known to remain in soils at depths up to 20' which may not have been surveyed/characterized, the conservative nature of the risk assessment accounts for any Ra-226 exposures given the currently evaluated exposure scenarios.
The conclusion reached in the HHRA Section 7.1.6 about the conservative nature of the risk assessment for Ra-226 is fairly well substantiated. It should be understood however that while the characterization of the site may be considered sufficient for purposes of assessing risk given the current land use & exposure scenarios, it has not completely defined the nature & extent of contamination, especially for subsurface locations where gamma walk-over surveys cannot fully identify radium sources whose gamma emissions are shielded by soil, gravel, & asphalt. As such, the site should be subject to land use controls since the potential for exposure from Ra-226 contamination remains a concern if intrusive activities were to occur at the site.
In addition, should the evaluation of remedial actions warrant any kind of intrusive activities such as a removal action, the risk posed to the worker as a result of such actions may warrant additional characterization or a careful evaluation to ensure adequate protective measures are taken to prevent exposure to Ra-226.
Text provided in Section 5.2 & Section 5.3 of Appendix A of the Draft RI Report provides additional information about the limitations on the use of the Ra-226 characterization data obtained by gamma walkover surveys, particularly for the subsurface. For example, Section 5.2 states the following: “The radiological characterization survey confirmed the presence of Ra-226-items in Anomaly Areas #3, #19, #20, #23, #25, #27, & #28. Only a few of these items were detected during walkover surveys, demonstrating that radioactive sources contained in the debris buried are rarely detectable from the ground surface. Consequently, it is possible that other radioactive sources &/or subsurface soil contamination is present at SS-22.” This information about the limitations on the use of gamma walkover survey data to identify subsurface contamination does not appear to be fully & clearly communicated in the main text of the SS-22 RI Report or in the HHRA.
The RI Report should be revised to incorporate additional information about the limitations on the use of the current Ra-226 characterization data & the risk to a future worker should intrusive activities occur at the site. In addition, this information should be carried forward to the FS to ensure adequate land use controls & as applicable, worker safety controls are put in place to prevent future exposures to Ra-226 contamination for intrusive activities.
See site file for additional information. |
Louis Howard |
| 1/17/2012 |
Update or Other Action |
Air Force Response to EPA comments
2.3 Future iterations of the risk assessment report will be as an appendix to the Remedial Investigation (RI) report. The purpose of this section of the risk assessment is to provide a brief overview of the investigations that have occurred at the site & the data used in the risk assessment, & is not intended to be comprehensive discussion of all the historical investigations. The text will be revised to include reference to the location in the RI report of the descriptions of historical investigations.
Future iterations of the risk assessment report will be as an appendix to the RI report. The purpose of this section of the risk assessment is to provide a brief overview of the investigations that have occurred at the site & the data used in the risk assessment, & is not intended to be a comprehensive discussion of all the historical information. The text will be revised to include reference to the location in the RI report of historical information pertaining to the site.
3 Future iterations of the risk assessment report will be as an appendix to the RI report. A full data usability assessment will also be included as part of the RI. Reference to the location of the more detailed data evaluation discussion will be provided in future revisions.
4 Comment noted. Both adult & child subpopulations will be included in discussions of hypothetical future residential exposures.
5 The HHRA was completed prior to the release of the updated RSLs. The updated RSLs & toxicity values from IRIS will be considered during the revision to the HHRA. COPC screening using updated RSLs will be provided; however, potential changes to the list of contaminants of potential concern (COPCs) will not be evaluated quantitatively, but will be evaluated qualitatively in the uncertainty section of the HHRA.
6 The primary contaminants of potential concern (COPCs) in the pond area are volatile organic compounds (VOCs). VOCs are not expected to be present in sediments. In addition, due to the climate of Alaska dermal exposure to sediments is minimal. Based on the COPCs & site conditions, exposure to sediments is at best a minimal pathway. The conceptual site model (CSM) will be revised to show this pathway as “Insignificant” exposure. The text will also be revised to be consistent with this change to the CSM. The document will be edited to ensure that Tier 1 & Tier 2 procedures & uncertainties are discussed in their respective sections.
a. Future iterations of the risk assessment report will be as an appendix to the RI/FS report. A full data set used in the risk assessments will also be included as an appendix to the RI/FS. Reference to the location of the data will be provided in future revisions.
b. The comment is not clear. Section 6.0 does not provide a discussion of exceedances of MDLs & LODs for PALs. However, Section 5.10.1 provides discussion of the uncertainty of not including non-detected analytes in the human health risk evaluation
3.2.2 The higher of the LOD/MDL for non-detected duplicate pairs will be used should further calculations of EPCs be necessary. If EPCs are not re-calculated, the use of the lower of the LOD/MDL for non-detected duplicate pairs will be discussed in the uncertainty section.
Table 4-1 A description for how the background values were derived is provided in Section 4.1. Table 4-1 will be revised to identify the basis of the soil background concentrations for each metal.
5.1 The screening levels for vapor intrusion from both soil gas & GW will be updated to be based on RSLs for indoor air, appropriate default attenuation factors based on the Subsurface Vapor Intrusion Guidance (OSWER 2002), & cancer risk level of 1 in 1 million (1E-06) & a Hazard Quotient (HQ) equal to 0.1. However, potential changes to the list of COPCs for vapor intrusion will not be evaluated quantitatively but will be evaluated qualitatively in the uncertainty section of the HHRA. Further, the text on page 5-4 will revised to provide a corrected description of the USEPA RSL for ambient air
5.2.1.1 The following information will be added to this section: “The JBER electronic Base General Plan (eBGP) in GeoBase places environmental restrictions on any development within the site footprint.”
5.2.4.1 The discussion of the derivation of the PEF will be clarified. In addition, the affect of the PEF on the risk evaluation for the future construction worker will be discussed in the uncertainty section
Table 5-4 Clarification of the selection of exposure frequency for the current/future outdoor worker will be provided. In addition, discussion of the PEF used will be provided, along with discussion in the uncertainty section of use of the default value in the evaluation of risk to the construction worker.
See site file for additional information. |
Louis Howard |
| 1/19/2012 |
Document, Report, or Work plan Review - other |
Air Force responses to ADEC comments Table 2-1 The information on the white substance is included in the RI report & will be added to this Table
Figure 2-2 The purpose of this figure is to give the reader an overview of the site, including locations of anomalies & samples collected. A note regarding the screening criteria used to generate the figure will be added to the figure.
3 The HHRA was completed prior to release of the updated Risk Assessment Procedures Manual (RAPM). The November 2011 version of the manual will be reviewed & the reference updated in future revisions.
Table 3-1 The above soil screening levels for the indicated chemicals will be considered during the revision of the Human Health Risk Assessment (HHRA). However, potential changes to the list of COPCs will not be evaluated quantitatively, but will be evaluated qualitatively in the uncertainty section of the HHRA.
Table 3-2 The above GW screening levels for the indicated chemicals will be considered during the revision of the HHRA. However, potential changes to the list of COPCs will not be evaluated quantitatively, but will be evaluated qualitatively in the uncertainty section of the HHRA.
5.1 The updated Regional Screening Levels (RSLs) will be considered during the revision to the HHRA. In addition, the screening levels for vapor intrusion from both soil gas & GW will be updated to be based on RSLs for indoor air, appropriate default attenuation factors based on the Subsurface Vapor Intrusion Guidance (OSWER 2002), & cancer risk level of 1 in 1 million (1E-06) & a Hazard Quotient (HQ) equal to 0.1. However, potential changes to the list of COPCs will not be evaluated quantitatively, but will be evaluated qualitatively in the uncertainty section of the HHRA.
5.2.1.1 The November 2011 ADEC RAPM will be reviewed & referenced & appropriate revisions to the risk assessments will be made based on the updated manual. As noted in Section 2.1.5, the unconfined aquifer underlying the investigation areas at SS22 East & SS22 West occurs at depths ranging from 40 to 50 feet below ground surface (ft bgs). Thus, because the depth to GW at the site is greater than 12 ft bgs, exposure to contaminated GW by the construction worker is not likely & is not included in the risk evaluation for the construction worker receptor.
Table 5-3 The COPC screening criteria & their source are presented in the tables in Appendix B. A note will be added to Table 5-3 to indicate where the screening criteria are located in the document. 5.4.1 The HHRA was completed prior to release of the updated RAPM. The November 2011 version of the manual will be reviewed, & the reference updated in future revisions. The updated RSLs will be considered during the revision to the HHRA. In addition, the screening levels for vapor intrusion from both soil gas & GW will be updated to be based on RSLs for indoor air, appropriate default attenuation factors based on the Subsurface Vapor Intrusion Guidance (OSWER 2002), & cancer risk level of 1E-06 & a HQ equal to 0.1. However, potential changes to the list of COPCs will not be evaluated quantitatively but will be evaluated qualitatively in the uncertainty section of the HHRA.
See site file for additional information.
|
Louis Howard |
| 1/26/2012 |
Document, Report, or Work plan Review - other |
EPA Jacques Gusmano sent Air Force JBER (G. Fink/D. Aide) email RE: SS-22 RI/Risk Assessment Draft There is apparently some confusion on how the [remedial investigation] RI will use Screening Criteria. I have noticed, and perviously commented on, the vague Screening procedures described in the RI (EPA Comments May 2010 General Comments:
Comment#1). The exact manner in which JBER will screen for potential [contaminants of concern] COCs is described in the TRIAD meeting minutes of 17 July 2007 2.2 Field Data Screening Criteria. 1st use 1/10th the ADEC clean-up criteria from B2 and C tables, and 1/10th the revised [trichloroethylene] TCE clean-up criteria. 2nd use 1/10th the additional cleanup criteria for ADEC's technical memorandum 3rd If no ADEC clean-up criteria exist use EPA Region 6 PRGs(RSLs)
If a sample exceeds any of these screening levels it is a potential COC. It will be up to the Air Force to describe reasons that this potential COC need not be brought forward for consideration in the FS, such as being within Background soil levels. The specific objective of the RI is to be sure potential risk is not prematurely overlooked and is, at least, considered and addressed in the Risk Assessment. The use of terms like "minor" or "significant" exceedance is problematic. Either it is or isn't above Screening Criteria. The above screening process is used on every Superfund Site in Alaska; if we have given you the wrong impression, I apologize.
I understand with changes in [remedial project managers] RPMs, contracting staff and the length of time taken for this phased RI, the possibility exists for this confusion. Louis and I have discussed this issue in depth and both agree on the process for screening. I am sure you understand that my comments so far have been on Secondary Documents for the benefit of constructive support for the RI/FS Draft and need not be included in the Administrative Record. However EPA [and ADEC] comments on the Primary RI/FS Documents will be part of the Administrative Record. |
Louis Howard |
| 3/16/2012 |
Update or Other Action |
Co-Occurrence of 1,4-Dioxane with Trichloroethylene in Chlorinated Solvent GW Plumes at US Air Force Installations: Fact or Fiction (Richard H Anderson,*Janet K Anderson, & Paul A Bower)
Air Force Center for Engineering & the Environment, Technical Support Division (AFCEE/TDV), 2261 Hughes, Site 155, Lackland AFB, Texas 78236, USA. Contractor, AFCEE Environmental Restoration Branch (AFCEE/ERD), Lackland AFB, Texas, USA (Submitted 22 November 2011; Returned for Revision 23 January 2012; Accepted 16 March 2012)
ABSTRACT: Increasing regulatory attention to 1,4-dioxane has prompted the United States Air Force (USAF) to evaluate potential environmental liabilities, primarily associated with legacy contamination, at an enterprise scale. Although accurately quantifying environmental liability is operationally difficult given limited historic environmental monitoring data, 1,4-dioxane is a known constituent (i.e., stabilizer) of chlorinated solvents, in particular 1,1,1-trichloroethane (TCA). Evidence regarding the co-occurrence of 1,4-dioxane & trichloroethylene (TCE), however, has been heavily debated.
In fact, the prevailing opinion is that 1,4-dioxane was not a constituent of past TCE formulations &, therefore, these 2 contaminants would not likely co-occur in the same GW plume. Because historic handling, storage, & disposal practices of chlorinated solvents have resulted in widespread GW contamination at USAF installations, significant potential exists for unidentified 1,4-dioxane contamination.
Therefore, the objective of this investigation is to determine the extent to which 1,4-dioxane co-occurs with TCE compared to TCA, & if these chemicals are co-contaminants, whether or not there is significant correlation using available monitoring data. To accomplish these objectives, the USAF Environmental Restoration Program Information Management System (ERPIMS) was queried for all relevant records for GW monitoring wells (GMWs) with 1,4-dioxane, TCA, & TCE, on which both categorical & quantitative analyses were carried out.
Overall, ERPIMS contained 5788 GMWs from 49 installations with records for 1,4-dioxane, TCE, & TCA analytes. 1,4-Dioxane was observed in 17.4% of the GMWs with detections for TCE &/or TCA, which accounted for 93.7% of all 1,4-dioxane detections, verifying that 1,4-dioxane is seldom found independent of chlorinated solvent contamination. Surprisingly, 64.4% of all 1,4-dioxane detections were associated with TCE independently. Given the extensive data set, these results conclusively demonstrate for the first time that 1,4-dioxane is a relatively common GW co-contaminant with TCE. Trend analysis demonstrated a positive log-linear relationship where median 1,4-dioxane levels increased between approximately 6% & approximately 20% of the increase in TCE levels.
In conclusion, this data mining exercise suggests that 1,4-dioxane has a probability of co-occurrence of approximately 17% with either TCE &/or TCA. Given the challenges imposed by remediation of 1,4-dioxane & the pending promulgation of a federal regulatory standard, environmental project managers should use the information presented in this article for prioritization of future characterization efforts to respond to the emerging issue. Importantly, site investigations should consider 1,4-dioxane a potential co-contaminant of TCE in GW plumes. Integr Environ Assess Manag 2012;8:731–737. |
Louis Howard |
| 8/16/2012 |
Document, Report, or Work plan Review - other |
ADEC's comments on the draft technical memorandum - Feasibility Study for SS22.
2.1 General Comment for Soil & GW COPC Screening
Step 1
Chemicals detected at 1/10th of the direct contact/inhalation & Table C GW levels are included in cumulative risk calculations [Reference 18 AAC 75.340 (k) & 345 (k) ].
Step 1 screening: Any anomalies with soil concentrations above; a) 1/10th the direct contact/inhalation levels or, b) the MGW level are carried forward to step 2. If the cumulative risk is less than 10-5 carcinogenic & HI of 1, then the anomaly can be screened out.
Step 2 screening: Step 2 only needs to be used if ADEC does not have values for the COPC in 18 AAC 75.341 clean up tables (assuming the EPA RSL tables would be used then). The screening should be based on HQ= 0.1 (Not HQ=1) & carcinogenic risk of 1 x 10-6.
GW the same process applies – screening at 1/10th Table C, if cumulative risk acceptable then screen out. Likely not an issue with GW, since all the detectable compounds should also be associated with the chlorinated solvent plume.
2.2 GW
It should be noted that if the shallow aquifer were not contaminated, it would be usable for drinking water purposes. ADEC will consider it a potential source of drinking water that has been contaminated. The NCP states at 300.430(a)(1)(iii)(F): “EPA expects to return usable ground waters to their beneficial uses wherever practicable, within a time-frame that is reasonable given the particular circumstances of the site. When restoration of ground water to beneficial uses is not practicable, EPA expects to prevent further migration of the plume, prevent exposure to the contaminated ground water, & evaluate further risk reduction.”
Page 2-52
The text states: “. It should be noted that the contaminated shallow aquifer on base is not used for any purpose. Land use restrictions are part of the Base Comprehensive Plan. These controls would prohibit construction of GW wells for residential, industrial, or agricultural purposes in the contaminated shallow aquifer.”
Please note that EPA OSWER Directive 9238.1-33 June 26, 2009, see GW Classification & Beneficial Use Policy on page seven which states: “Land use is not identified as a consideration in making GW classifications.” & “… groundwaters should be restored to their beneficial use. While a State's designation of GW use will be considered for establishing remediation goals, EPA's classification scheme (EPA Guidelines/or Ground-Water Classification (Final Draft, December 1986)) will generally be used if a state's classification would lead to a less stringent solution.”
Step 3 & Table 2-3 If cumulative risk is 1 x 10-5 or HI equal to or less than 1 for the contaminants at an anomaly, then the anomaly can be screened out. ADEC is assuming that the calculations & assumptions for cumulative risk will be provided as an appendix to the RI/FS when it is sent to the regulatory agencies for review.
3.0 Remedial Action Objectives
Fourth Bullet
The definition of “background ”means: “Substances or locations that are not influenced by the releases from a site & are usually described as naturally occurring or anthropogenic:
(1) Naturally occurring substances present in the environment in forms that have not been influenced by human activity.
(2) Anthropogenic substances are natural & human-made substances present in the environment as a result of human activities (not specifically related to the CERCLA site in question).”
Fifth Bullet
Provide a reference to the screening criteria of 2 picocuries per gram (pCi/g) for RA-226.
Sixth Bullet
Institutional controls do nothing for off-site migration. EPA defines ICs as non-engineered instruments, such as administrative & legal controls, that help to minimize the potential for human exposure to contamination &/or protect the integrity of a response action. ICs are a subset of Land Use Controls (LUCs). LUCs include engineering & physical barriers, such as fences & security guards, as well as ICs (EPA “Institutional Controls: A Guide to Planning, Implementing, Maintaining, & Enforcing Institutional Controls at Contaminated Sites”, EPA-540-R-09-001, November 2010 Interim Final.)
ADEC requests JBER delete reference to ICs as a means of mitigating off-site migration of COPCs.
4.2.3 – 4.2.4 Monitored Natural Attenuation
Monitored natural attenuation (MNA) includes monitoring which implies long-term GW monitoring. Institutional controls are also required as part of the alternative. Recommend MNA be retained, but incorporate LTM & ICs into this alternative.
|
Louis Howard |
| 8/23/2012 |
Document, Report, or Work plan Review - other |
EPA Sandra Halstead's comments on the draft technical memorandum for SS-22. A revised version of the draft RI (dated Oct 2011) and draft HHERA (dated Nov 2011) have not been received by EPA. The screening levels used in the draft RI/RA documents did not meet risk assessment/remedial investigation guidance.
Comments on this FS tech memo are predicated on revised COPCs for both soil and groundwater at the appropriate screening levels in the revised RI/RA have been brought forward for consideration in this tech memo. Section 1.0 Introduction describes the purpose of the technical memo is to explain the approach and methods for the FS. The tech memo instead offers a ‘cliff’s note’ version of the FS and does not adequately describe the methods to be used, especially in the comparative analysis of remedy alternatives.
Please clarify in the FS how the rating of remedy alternatives will be conducted. Will a numeric scale be used to score alternatives within the nine criteria? Or a low, medium, high designation? (developing a set of numeric criteria to assist in ‘quantifying’ alternatives for the comparative analysis allows for some scored distinction between treatment remedies.)
In section 4.0 Identification and Screening of Remedial Components, as treatment options are described, many are “eliminated from further consideration in the FS”. Omission of remedies from consideration in the FS, based on this technical memo, is premature as this tech memo will not be part of the administrative record. All remedies should be identified and discussed in the FS for the benefit of the public for consideration.
At a minimum, the same narrative from the FS tech memo can be transferred to this sections of the FS narrative. During the FS, treatment options which are not viable when screened for effectiveness, implementability, and cost, can be then eliminated from the detailed analysis of alternatives.
Page 2-1 Sect 2.1: Please clarify this sentence. “COPCs identified for the AOCs in the RI were screened in three sequential steps to determine the FS sites that warrant evaluation for protection of human health. These steps are described below.” If Steps 1-3 describe is how the screening to determine if a substance is a COPCs during the RI, it is not protective and unacceptable.
If Steps 1-3 describe how COPCs were screened for FS consideration, after the RI screening to include risk uncertainty at a level far below the cleanup level (typically 1/10th or at EPA RSLs), then the method described is adequate Table 2-1: Please include Radium-226 as a COPC for each anomaly and matrix where it occurs. Please describe in footnote 1 the location of the background value. Is this from the Base-wide background study or localized to this site? For the COPCs brought forward to the FS for consideration, an additional column that identifies the screening value (1/10th the cleanup level or RSL) would help to clarify if risk uncertainties were considered during COPC screening.
Suggest a column labeled as ‘COPC screening level’ and placed between the column labeled ‘COPC’ and the column labeled ‘COPCs for soil exceeding’ could be informative.
The existing third column in Table 1 (COPCs for soil exceeding..’) appears to be the range of detected sample values by analyte which exceeded soil cleanup levels and should be titled as such. Page 2-43: Ra-226 is listed as critera to identify the FS sites ‘besides human health risk characterization’. . In the FS, please describe the target cleanup level for Ra-226. Is 2 pCi/g the screening level and the target cleanup goal? Please describe the basis for the Ra cleanup standard (ie..soil, drinking water, air emissions) and the guiding regulation (ie. EPA, NRC, ATSDR, etc..)
Page 2-54: “where metal exceedances are marginal…. will not be considered for remedial action”. The use of the term “marginal” in reference to an exceedance is problematic. It either exceeds the screening criteria, or it doesn’t. 3.0 Remedial Action Objectives: In the FS, please clarify the RAO goals: Bullet 5: is 2 pCi/g the screening or the cleanup level?
What is the basis? Bullet 8: Is the vapor instrusion cancer risk level 10-6 and a HI of 0.1. ?
6.0 Detailed Evaluation of RAOs: In the FS, please describe the rating scheme that will be used to evaluate the alternatives. Develoment of a numeric scale to help evaluate on the nine criteria with a total score to can help delinate between alternatives. Graphical can be used but is much more subjective in determining differences between alternatives, In the FS, please clarify if the munitions identified during the RI are debris or MEC. |
Louis Howard |
| 11/28/2012 |
Document, Report, or Work plan Review - other |
Staff reviewed the draft final closure report and determined the site meets the requirements of 18 AAC 75.380(d)(1). The site has been adequately characterized under 18 AAC 75.335 and has achieved the applicable requirements under the site cleanup rules. ADEC issued this written determination that the cleanup is complete, with institutional controls, subject to a future ADEC determination that the cleanup is not protective of human health, safety, or welfare, or of the environment. Please finalize.
|
Louis Howard |
| 12/3/2012 |
Update or Other Action |
Email to M. Markell USAF from ADEC L. Howard: We would like to see the 2007 data packages and any associated tech memos/reports at some point for our files. |
Louis Howard |
| 12/6/2012 |
Update or Other Action |
Draft Memorandum for the Record received.
Revision of the Federal Facility Agreement Document Schedule for Spill Site 22 on JBER-Elmendorf
1. Spill Site 22 (SS22) was incorporated into the JBER-Elmendorf (JBER-E) FFA on 14 May 2008. At that time Federal and State Federal Facility Agreement (FFA) Project Managers, along with the U.S. Air Force (USAF) FFA Project Manager established a schedule for primary and secondary documents under the FFA. This schedule has since been amended on18 Sep 2008 and 04 Nov 2009 due to the discovery of radioactive waste and expansion of the site boundaries. However, recent contractual and funding issues have resulted in a failure to meet the schedule as delineated.
2. Schedule updates and/or modifications to the schedule require unanimous written agreement between the Project Managers. As such, the Project Managers are asked to review the attached revised document schedule for SS22.
Document schedule revision as an attachment to the FFA
Primary Draft RI/FS Report January 4, 2013
Secondary Draft Proposed Plan January 15, 2014
Primary Draft Record of Decision September 15, 2014 |
Louis Howard |
| 12/7/2012 |
Update or Other Action |
Samples collected in 2001 indicated DRO contamination remained at the site, and excavation/soil movement restrictions will remain in place at the site. Analytical results indicate remaining contamination is limited to 17 feet bgs and not migrating to groundwater. Additionally, the site is located with OU5, which is monitored and addressed under the ERP. Site closure with institutional controls is appropriate and protective of human health and the environment.
In accordance with State of Alaska regulation 18 AAC 75, the USAF has completed cleanup
activities at ST531 , JBER-Elmendorf. DRO in soil remaining above the ADEC 18 AAC 75.345 Table C and 18 AAC 75.341 Method Two, Table B2 Under 40-Inch Zone, Migration to Groundwater cleanup level is limited to 17 feet bgs and not migrating to groundwater. Additionally, the site is within OU5, which is monitored and addressed under the ERP. Excavation/soil movement restrictions will remain in place at the site.
ADEC's review and concurrence on the request for Cleanup Complete with Institutional Controls status is required in accordance with State of Alaska environmental conservation laws and regulations. While ADEC may comment on other state and federal laws and regulations, ADEC's concurrence on the site closure does not relieve the USAF or its consultants, contractors, subcontractors, or USAF civilian personnel from the need to comply with other applicable state and federal laws and regulations.
The site has been adequately characterized under 18 AAC 75.335 and has achieved the applicable requirements under the site cleanup rules. Cleanup at the site is complete, subject to a future ADEC determination that the cleanup is not protective of human health, safety, or welfare, or of the environment. ADEC will, as necessary to ensure protection of human health, safety, and welfare, or of the environment, require the USAF to conduct additional actions that meet the requirements of 18 AAC 75 Contaminated Site regulations and Alaska Statute 46.03-46.09. |
Louis Howard |
| 2/19/2013 |
Update or Other Action |
EPA (Sandra Halstead) sends Air Force (Don Aide/Gary Fink) an email message requesting an extension for comments on the draft RI.
EPA has received the draft RI-FS for JBER SS22 for review. As stated in the Elmendorf FFA, Section XX.G.20.13, EPA requests a 20 day extension in addition to the 30 day review period. EPA will submit comments by April 5, 2013.
Please feel free to contact me if you need to discuss this proposed timeline.
|
Louis Howard |
| 2/20/2013 |
Update or Other Action |
Draft RI report received for SS22
VOCs. Significant exceedances of VOCs were observed at Anomalies 2/3 (including the capillary fringe from MW07), 6, 9/10, 12, & 13. Maximum levels ranged up to 300 milligrams per kilogram (mg/kg) for 1,2,4-trimethylbenzene at Anomaly 12, 30 mg/kg for 1,1,2,2 -tetrachloroethane, up to 280 mg/kg for trichloroethylene (TCE) & 4.2 mg/kg for tetrachloroethene (PCE) at Anomaly 9/10. In addition, lone significant detections of 1,1,2-trichloroethane (0.5 mg/kg) at Anomaly 10, ethylbenzene (11 mg/kg) at Anomaly 6, & sec-butylbenzene (29 mg/kg) at Anomaly 12 were detected as significant exceedances.
PAHs. Significant exceedances of PAHs were observed at Anomalies 2/3, 4, 5, 6, 8, 10 through 28, the debris pile, & the SVA. Although widespread, the majority of the exceedances were limited to surface soils. Maximum surface concentrations were all from Anomaly 5 & ranged up to 81 mg/kg for benzo(a)anthracene, 40 mg/kg for benzo(a)pyrene, 80 mg/kg for benzo(b)fluoranthene, 6.5 mg/kg for dibenz(a,h)anthracene, & 18 mg/kg for indeno(1,2,3-c,d)pyrene. All of these maximum levels originate from a single duplicate sample. The primary sample from this sample pair had results that were roughly two orders of magnitude lower, as did the step out samples, which suggests a very small source.
PCBs. Significant exceedances of PCBs were generally limited to surface soils within Anomalies 2/3, 7, 9/10, 11, 13, 21, & 22 & the debris pile. Maximum levels for Aroclor 1254 & Aroclor-1260 in surface soils ranged as high as 5.1 mg/kg within the debris pile & 6.3 mg/kg at Anomaly 22. Localized PCB contamination was observed in subsurface soil at Anomalies 2/3, 13, 16, 22, & 24 at maximum level of 1.6 mg/kg (as Aroclor-1254) from Anomaly 2/3 & 8.1 mg/kg (as Aroclor-1260) from Anomaly 16.
TPH. Significant total petroleum hydrocarbon (TPH) exceedances were observed at Anomalies 2/3, 4, 6, 10, 12 through 16, 18, 21 through 24, 26 through 28, & the SVA. TPH-diesel range organics (DRO) is by far the predominant petroleum contaminant observed across the SS22 study. The maximum surface contamination was detected at a concentration of 6,400 mg/kg within the SVA. The greatest contamination observed in subsurface soils was found to be 4,200 mg/kg at a depth of 5 feet (ft) below ground surface (bgs) at Anomaly 2. The highest concentration of RRO was observed at the SVA at a concentration of 20,000 mg/kg & is an occurrence of localized contamination confined to surface soil. The highest GRO exceedance, observed in a near-surface soil sample at a concentration of 2,100 mg/kg within Anomaly 6, was also found to be an isolated occurrence.
Pesticides. Significant pesticide exceedances were limited to Anomalies 5, 11, 12, 16, 21, 22, & the debris pile. The maximum pesticide exceedance for dichlorodiphenyltrichloroethane (4,4’-DDT) was detected at 420 mg/kg at Anomaly 12, while that for endrin was 3.7 mg/kg at Anomaly 16. Both locations are associated with the wastes in the disposal areas & both have been completely delineated.
Dioxins/Furans. Significant dioxin exceedances (as toxicity equivalents or TEQ) were only observed at Anomaly 2, at a maximum concentration of 43.2 nanograms per kilogram. This is an anomaly specific contaminant associated with the ash layer which is present at a depth of 3 to 4 ft bgs at Anomaly 2.
Ra-226. Significant exceedances of Ra-226 in soil were observed at Anomalies 2, 3, 11, 19, 20, 23, 25, 27, & 28. In addition, multiple radioactive items were recovered from trenches excavated at several of the anomalies. Residual Ra-226 contamination in soil is unlikely to migrate to any significant degree due to the low solubility of radium sulfate, the compound responsible for the contamination. This is further supported by the GW sampling results.
See site file for additional information.
|
Louis Howard |
| 2/20/2013 |
Update or Other Action |
GW contamination results from SS22 RI draft report.
Anomaly 10 has been identified as the source of a long, diffuse, low concentration chlorinated solvent plume (Figure ES-2). The plume is approximately 500 ft wide & 1.6 miles long & consists of TCE, 1,1,2,2-tetrachloroethane (1,1,2,2-PCA), PCE, & carbon tetrachloride. This plume has migrated off site to the west with TCE concentrations above the 5 micrograms per liter (µg/L) ADEC GW Cleanup Level.
TCE is the primary contaminant present in the plume with concentrations ranging from 169 µg/L at the source area to slightly above 2 µg/L at the toe of the plume. The source is located in the vadose zone soil & appears to be centered around borings 10SB02 & 10SB17. TCE & 1,1,2,2-PCA are also present in these source areas above their respective ADEC Soil Cleanup Levels of 0.020 mg/kg & 0.017 mg/kg, respectively. Identification of the source area is further supported by the soil gas data, which shows the highest TCE detection (64,000 micrograms per cubic meter [µg/m3]) near 10SB17.
In the unconfined aquifer beneath the source area, TCE is present above the 2 µg/L screening level throughout the upper portion of the aquifer but higher concentrations are primarily limited to the top 20 ft of the water table. Outside the source area, TCE is restricted to the top 20 to 40 ft of the water table with the highest TCE concentrations typically being confined to only the top 20 ft of the water table. The generally aerobic nature of the aquifer & the absence of TCE daughter products suggest that the chlorinated VOCs in GW are not being attenuated via biodegradation.
At the downgradient edge of the plume, GW discharges to Beaver Pond & the drainage ditch. Relatively low concentrations of TCE ranging between 8.17 & 9.66 µg/L were detected in surface water samples collected from the drainage ditch. The human health risks associated with the off-site portion of the plume are at acceptable levels. There are no ecological concerns for the offbase plume. Based on data from this RI & from the OU 5 investigation, the chlorinated solvent plume that originates at SS22 is completely delineated, both horizontally & vertically.
In addition to the chlorinated solvent plume, one localized GW plume was identified at SS22. TCE & TPH-DRO have been detected above ADEC GW Cleanup Levels of 5 & 1500 µg/L, respectively, in GW samples collected in the northern portion of the site, which may be associated with Anomaly 2/3 or possibly a closed underground storage tank in the immediate vicinity. Results from the 2010 sampling event indicate that TCE concentrations have decreased to below the ADEC GW Cleanup Level of 5 µg/L at this location. Based on data from this RI, this small GW plume has been delineated.
Exceedances for VOCs were observed under four of the six buildings on or near the site where subslab vapor sampling was performed. These buildings are all located within 100 ft of a soil or GW exceedance of one or more VOCs. Carbon tetrachloride, chloroform, & TCE were the only constituents shown to exceed screening levels in the subslab data. The highest exceedances of TCE were 110 µg/m3 & 180 µg/m3 in Buildings (Bldg.) 12737 & 11735, respectively.
See site file for additional information. |
Louis Howard |
| 4/5/2013 |
Document, Report, or Work plan Review - other |
Staff provided comments on the draft RI/FS for SS22.
Page ES-5
Groundwater Contamination
Please note in the text that sample results from just four days before on September 7, 2007 detected trichloroethylene (TCE) at 36 µg/L (BP117) & 31 µg/L (BP116). The lower results listed in the text were from a resampling effort on September 11, 2007. It should be noted in the text that it rained immediately prior to the re-sample event; concentrations for samples from the drainage ditch likely were lower due to dilution from precipitation.
These locations should be resampled for TCE as part of a long-term monitoring plan for SS22.
Pages ES-6 & ES-7
Soil Gas Contamination
Subslab TCE soil gas contamination is of concern to ADEC at the buildings (non-residential use) where the shallow soil gas exceeds 84 ug/m3 (incorporating an attenuation factor of 0.1 for x the 8.4 ug/m3 short term noncancer level defined in EPA’s December 2012 Memorandum OEA Recommendations Regarding Trichloroethylene Toxicity in Human Health Risk Assessments from Joyce C. Kelly Office of Environmental Assessment).
Conclusions & Data Gap Evalution
Use of the Johnson & Ettinger (J&E) vapor intrusion (VI) model to demonstrate risk from subslab soil gas TCE exceedances may not be protective of human health, welfare, safety in light of EPA’s December 2012 memorandum & EPA’s Superfund Vapor Intrusion FAQs (February 2012).
Page ES-9
Feasibility Study
ADEC requests the Air Force clarify whether the 2pCi/g Ra-226 screening level is an actual cleanup level or not & whether it corresponds to a cumulative risk within the 10-4 to 10-6 carcinogenic risk range based on reasonable maximum exposure at areas of concern (AOCs). If not, then list what the applicable or relevant & appropriate cleanup level would be for Ra-226 would be & the basis for the cleanup level. On page 3-5 it states that the Ra-226 screening criterion was established by the Department of Air Force with no reference to a promulgated cleanup level.
See site file for additional information. |
Louis Howard |
| 4/5/2013 |
Document, Report, or Work plan Review - other |
EPA (Sandra Halstead) provided comments on the draft RI/FS for SS022.
Comment: The Draft RI/FS defines a significant exceedance for soil or GW as a concentration that exceeds all of the following:
• human health screening criteria (either regional screening levels [RSLs] or ADEC human health criteria when no RSL exists);
• background concentrations (for metals); &
• ADEC cleanup levels.
However, the purpose of identifying significant exceedances is not clearly indicated. Any contaminant present at SS22 that is determined to pose a risk to human health &/or the environment should be retained as a COC & addressed in the FS. In addition, the inclusion of two exceedance categories (significant exceedances & exceedances) adds unnecessary complexity to an already complex site.
Lastly, Section 4 states that all of the exceedances were retained & used during the preparation of the risk assessment, so the importance of discussing only significant exceedances is not understood. Please revise to assess exceedances based on the risk to human health &/or the environment (as well as background in the case of metals) rather than the designated significance of the exceedance & consider removing the discussion of significant exceedances.
Draft RI/FS Comment: Section 4 describes the nature & extent of contamination, but it does not appear that the nature & extent is well defined for many of the contaminants present at SS22. For example, the nature & extent discussion for cadmium & PCBs in soil at Anomaly 2/3 states that these contaminants “are associated with the waste at this location; however, because the waste is well defined by the anomaly boundary, this is not considered a data gap for the FS.”
This assumption does not appear to be supported. It assumes that contaminants do not extend beyond the boundaries of the waste; however, leaching of waste constituents or seepage of liquid wastes may have resulted in elevated concentrations of contaminants beyond the extent of physical waste.
Another example is the discussion of TCE in GW at Anomaly 2/3, which states that “GW samples collected from downgradient monitoring well MW08 have a significant exceedance for TCE (7.6 [µg/L]). The exceedance is likely associated with previous disposal activities at Anomaly 2 &/or 3 based on elevated TCE soil gas concentrations. At these low GW concentrations, it is apparent that there is no significant soil source at the anomaly & no further GW delineation is necessary.”
TCE at MW08 exceed the MCL value, & delineation appears to be necessary. Please revise to acknowledge potential data gaps related to contaminants that may extend beyond the extent of physical wastes. Please also revise the Draft RI/FS to provide justification for why delineation of extent is not necessary in those cases where further delineation is not recommended.
The Draft RI/FS does not discuss the potential for vapor intrusion (VI) from the chlorinated solvent plume at SS22 that originates from Anomaly 10 or include RAOs for VI. Based on Figure 4-17, the chlorinated solvent plume at SS22 extends beneath several buildings (e.g., Building 11735, Building 12737, Bldg 12755, Bldg 8565, Building 8559).
Additionally, EPA Region 10 has developed new recommendations (nonchronic, 21 day average, not to exceed values) for TCE VI to be considered in human health risk assessments. It is acknowledged the risk assessment for SS22 was conducted prior to the issuance of these new toxicity recommendations, however, the evolving science & epidemiological evidence increases the urgency of re-evaluating & reducing exposure to TCE vapor intrusion, especially when women of reproductive age may be exposed.
Please revise to address the potential for VI at SS22 using the new EPA Region 10 recommendations. The document “ OEA Recommendations Regarding Trichloroethylene Toxicity in Human Health Risk Assessments”, December 13, 2012 was provided to JBER staff in December 2012.
The RAOs presented in the Draft RI/FS lack detail. Section 4.1.2.1 (Development & Screening of Alternatives) of the Guidance for Conducting RI/FSs Under CERCLA, EPA/540/G-89/004, dated October 1988 (RI/FS Guidance) states RAOs should specify the contaminants & media of interest, exposure pathways, & PRGs that permit a range of treatment & containment alternatives to be developed. The RAOs presented in Section 9.2.1 do not specify the contaminants. In addition, stipulating the use of treatment techniques whenever practicable does not meet the definition of a RAO. Please ensure that the RAOs presented in the Draft RI/FS specify the contaminants & media of interest, exposure pathways, & PRGs that permit a range of treatment & containment alternatives to be developed. |
Louis Howard |
| 7/23/2013 |
Document, Report, or Work plan Review - other |
EPA responses to JBER's RTCs on EPA's original comments for SS22 Draft RI/FS.
Comment #2 EPA response: Please see general comment #6 on inclusion of 2012 RSL’s & IRIS toxicity values in the vapor intrusion risk assessment
Comment #5 EPA response:
EPA understands the AF desire to delay incorporation of new science & policy in their risk assessment as this creates a moving target. Although ‘future regulatory updates’ are revisited during a five year review, the R10 TCE nonchronic policy is not regulation, & this site does not have a ROD yet, so the AF should be incorporating the new information at this stage while the RA/RI/FS is still draft. Secondly, the ‘calculated’ indoor air concentrations as based on subslab values are within only a few ug/m3 of EPA levels of concern & therefore present a need for confirmation indoor air sampling.
The R10 TCE non-chronic policy addresses evaluation of short-term exposures to women of reproductive age. This is not technically considered a screening level, but rather an average concentration that should not be exceeded during any 21-day period of time. A HQ of 1.0 is appropriate for this purpose. The concentration representing the maximum acceptable short-term concentration of TCE in indoor air is 2 ug/m3 for a standard residential scenario & 8.4 ug/m3 for a standard commercial/industrial exposure scenario. These should be considered not-to-be exceeded concentrations when women of reproductive age may be present, due to the risk of the occurrence of fetal heart malformations.
There are additional concerns with the vapor intrusion model results as found in the draft RA in Appendix I, Attachment C for the buildings which were evaluated for vapor intrusion. The TCE IRIS value for chronic inhalation RfC (ug/m3) used in the calculations was 0.00 & should have used 0.002 ug/m3 (IRIS value updated in 9/28/2011). No calculations for the non-cancer hazard quotient are presented in the J-E spreadsheets & the field is presented as NA (see spreadsheets SG-screen ind 11735 TCE.xlsm as one example).
The calculated incremental risk values in the J-E spreadsheets of Appendix I, Att C do not match the values in the summary tables (Table 5-9, p 5-198 of the draft RA, Appendix I; & Table 7-3 of the draft RI/FS). Additionally, the J-E model used does not include the use of site-specific building information that would be used in the advanced J-E models; & the use of sand as a homogeneous subsurface substrate amplifies uncertainties in the J-E model when the subsurface has characteristics such as coarse sand, gravels & boulders, typical of glaciated soils.
The vapor intrusion risk assessment for buildings where multiple volatile organics are present did not consider a non-cancer hazard quotient of HI=0.1. This applies to buildings 12755, 12737, & 8565 where multiple compounds were detected in subslab gas but a non-cancer hazard quotient of HI=1 was used as the target risk level.
There are multiple discrepancies between the text presented in the draft RA, Appendix I, & the summary Nature & Extent of contamination in Chap 4 & the summary RA presented in Chapter 7 of the draft RI/FS . In particular, the descriptions of building location relative to the chlorinated solvent plume is incorrect in the draft RA in Appendix I (page 5-194 & 5-200 of the draft RA, Appendix I for descriptions of buildings 12743,12745, 11735, & 12737).
It is strongly recommended the draft RA & the supporting documentation as presented in Appendix I be revised & updated as part of the draft RI/FS.
EPA is requiring additional indoor air sampling for TCE prior to finalization of the draft SS 22 RA/RI/FS.
Comment #8 EPA Response
Please include Alternative 4 Limited Excavation/Off-site Disposal/ICs and cost estimates. Cost alone cannot justify and alternative.
Comment #35 EPA Response
Please add any assumptions used in the J-E model including attenuation factors.
Comment #53 EPA Response
It is not necessary to remove gravel/stone cover as a capping option, however realistic performance of a gravel cap in reducing infiltration and subsequent leaching of contaminants should be described. |
Louis Howard |
| 11/4/2013 |
Update or Other Action |
Fourth Five-Year Review (draft) received for review & comment. SS22 is located 1 mile east of the east/west runway at the Defense Reutilization and Marketing Office storage facility. This 22-acre site was closed with no further remedial action planned in 1991, but was re-opened when two tar seeps were discovered in 2002. The tar seeps were cleaned up and subsequent geophysical investigations indicated 15 subsurface anomalies. Site reconnaissance revealed a debris pile and a stressed vegetation area.
The anomalies, debris pile, stressed vegetation area, and underlying groundwater have undergone field screening and were sampled for definitive analyses through 2009. A remedial investigation resulted in the discovery of radioactive waste and expansion of the site boundaries. The SS22 site was added to the Federal Facilities Agreement (EPA, 1991) on May 14, 2008. The schedule for delivery of primary and secondary documents was revised after discovery of radioactive waste.
Site SS22 is not included in this Five-Year Review because it is still in the investigative
stage. Investigations began in 2007 and the Draft Remedial Investigation and another
proposed schedule change are currently undergoing regulatory review. |
Louis Howard |
| 6/12/2014 |
Enforcement Agreement or Order |
Federal Facility Agreement (FF A) Document Schedule for SS022 - Spill Site 22, JBER-Elmendorf.
Attached for your review and acceptance is the proposed document schedule for SS022 - Spill Site 22 on Joint Base Elmendorf-Richardson, Elmendorf (JBER-E), Alaska. If approved, the schedule will be attached to the current JBER-E FFA (15 November 1991).
If you concur with the proposed schedule, please sign in the block provided on the
attached signature page and return the original signature page to me. Should you have questions
or comments, please feel free to contact me at (907) 384-1824.
Document type: Primary. Draft Record of Decision, date due for agency review 15 September 2016.
Upon approval, this document will be attached to the current FFA (15 November 1991). The
document schedule may be updated or modified to include additional primary or secondary
documents as necessary to meet FF A requirements. Changes will require approval of FF A
Project Managers.
Signed by G. Fink USAF, S. Halstead 2014 L. Howard ADEC. |
Louis Howard |
| 7/31/2015 |
Update or Other Action |
Staff received a letter work plan for review and comment addressing potential soil vapor intrusion associated with volatile organic compounds groundwater contamination and total petroleum hydrocarbon groundwater contamination. This work plan is intended to describe the overall project implementation plan and methodologies to be used to complete the initial screening and building survey tasks.
Field data collection activities associated with soil vapor and ambient air will be addressed in a separate Uniform Federal Policy - Quality Assurance Project Plan (UFP-QAPP) that will be developed prior to the start of field sampling. The VI Study will include the initial screening and on-site survey of 96 buildings at JBER. Field sampling of sub-slab soil vapor, near-slab soil vapor, and indoor/outdoor air will be conducted for 30 of these buildings. Field sampling results will be used to complete a VI risk assessment and VI Study Report. See site file for additional information |
Louis Howard |
| 8/17/2015 |
Document, Report, or Work plan Review - other |
Staff provided comments on the letter work plan for VI screening which includes SS022 groundwater plume.
ADEC recommends expanding discussion of the scope of work in the introduction section. The text mentions that the intention is to conduct an initial screening. ADEC requests clarification in the text on what exactly is being screened for during this project. ADEC assumes you are screening for buildings that pose a possible inhalation risk due to vapor intrusion.
Finally, staff recommended that a priority list of buildings or PBOI list, not be developed until AFTER the building surveys have been completed. The building surveys can provide useful information for determining which buildings are more susceptible to vapor intrusion. This section suggest PBOI list developed prior to building surveys; however section 3.1.3 suggests otherwise. Please clarify and correct text.
See site file for additional information. |
Louis Howard |
| 9/17/2015 |
Document, Report, or Work plan Review - other |
ADEC has reviewed JBER's responses to ADEC's comments and finds the responses acceptable. Please finalize the document. |
Louis Howard |
| 12/10/2015 |
Meeting or Teleconference Held |
Meeting at JBER to discuss results from the building surveys conducted in October, as part of the Vapor Intrusion Project with JBER, EPA, ADEC and contractor as well as the proposed buildings of interest list.
EPA's initial comments: the buildings listed below were not completely ground truthed against the LOE matrix. We want to evaluate all buildings for VI potential, and then narrow the top 30 based on the AF contract limitations but not constrain the priority list. I’m sure HGL will be providing the basis for the buildings chosen (and those not chosen)
I did a very cursory review today and have a list of buildings to address because they
1) sit over VOC plumes and aren’t evaluated (example, building 18216 for site DP98, map page 2) ;
2) are outside the VOC buffer but make the sampling list (example building 16430, helicopter maintenance, map page 6);
3) Building 12743 (map page 11) and 8549 (map page 10) are rated high priority but don’t make the sampling list.
Additional thoughts:
FT023 : Buildings 18522, 17520 not BOI
LF059: what about building to north if plume emanates from OU1 Landfill to N/NE?
SD025 building outside VOC buffer but BOI (16430)
SD029: 16673 is not a BOI and is in buffer zone; 16716 is BOI and outside buffer zone
ST037N: 7 BOI listed and approximately 20 buildings not BOI (especially the 626x series)
ST037/SS22S: 3 BOI: 8574 BOI but not in VOC buffer or plume; 7508 and 8565 are in buffer not BOI
SS22N: 11735 in plume not BOI: 12755 BOI in buffer
ST048-ST068: 11551 BOI and not in plume or buffer; 11575 on buffer line and not BOI
DA089: Buildings 732, 730, 728 all in plume and VI path potential but not BOIs |
Louis Howard |
| 12/23/2015 |
Update or Other Action |
JBER Key changes made per discussions during last week's meeting/telecom:
* Elevated the VI Pathway floor penetration priorities to include sump/OWS/floor drain (high priority) and seam/crack/conduit (medium priority)
* Elevated the VI Pathway floor level priorities to include crawlspace/skirted trailer as high priority
* Revised Site DP098 to remove Building 18216 and to show only Building 18220 as the single large primary facility
* Confirmed presence of a crawlspace beneath a portion of Building 7535 (Kenai Dining Hall) via the design drawings
* Revised the overall BOI Priorities and BOI List selections and associated rationale
* Added color highlights within subcategories to indicate the priority driver(s) for each
The overall changes to the pathway priorities significantly changed the number of potential "high" priority buildings.
I believe this will be consistent with the revisions requested by the regulators.
Also note this version is reformatted to streamline the overall table for eventual inclusion in the UFP-QAPP.
All of the "X"s are gone, many of the detail columns are combined, and footnotes are included to explain the abbreviations.
Also reviewed an email from Sandra (EPA) that Donna forwarded last week regarding her comments on the previous BOI List.
Most of Sandra's comments were related to the exclusion of numerous buildings located within groundwater plume boundaries from the BOI List.
In general, the building location relative to a groundwater plume is only a supporting criterion for BOI List selection.
This is due to the large number of buildings located within plume boundaries (especially ST037) and our need to limit the sampling program to 30 BOIs.
There is no way we can include all of the buildings located within plume boundaries in the sampling program, so other criteria drive the selection. |
Louis Howard |
| 5/4/2016 |
Document, Report, or Work plan Review - other |
Staff reviewed and commented on the VI Study WP.
JBER-E and JBER-R Buildings of Interest (BOI)
General Comment
ADEC requests for each BOI description also list the approximate square footage of each building and how many levels (floors) are being used in the building.
10.5.6 Site SS022
Page 32
The text states: “For the purposes of the VI Study, the Site SS022 area is limited to the northeast extent of the groundwater contamination plume and includes the Building 12755 DRMO warehouse.”
ADEC would like to point out that for purposes of assigning the definition of the site known as SS022, it includes the 1.6 mile plume of TCE, 1,1,2,2-tetrachloroethane (1,1,2,2-PCA), PCE, and carbon tetrachloride. contamination originating from SS022 and extending off-site where it discharges to the Beaver Pond and the drainage ditch (RI/FS Spill Site SS22 Executive Summary “Groundwater Contamination”. The most downgradient edge of the chlorinated solvent plume ends approximately 200’ upgradient of Ship Creek (RI/FS Spill Site SS22 4.3.1.3 Lateral Delineation).
The text states: “The remaining buildings located in the southwestern extent of the SS022 plume are grouped with the adjacent ST037 Slammer Avenue/TU091 site area discussed below.”
However, the RI/FS for Spill Site SS22 at Section 4.3.1 states: “Based on a review of all available data, it appears the “East Slammer Avenue Plume is sourced and contiguous with the SS22 VOC plume.”
The text states: “TCE is the only COI at the site.”
The RI/FS for SS022 4.4.3 Building 12755 stated: “Carbon tetrachloride exceeded the screening level at all sampling locations with estimated concentrations ranging from 48 µg/m³ to 150 µg/m³. The highest concentration was detected at 12755-SG01 which is located in the southwestern portion of the building. A slightly lower concentration of 130 µg/m³ was detected near the building center at 127755-SG02. Chloroform was detected at or above the 11 µg/m³ screening level at locations 12755-SG01 and 12755-SG02 at concentrations of 44 µg/m³ and 11 µg/m³, respectively.”
Indoor and Outdoor Air Sampling Method
ADEC recommends this section be expanded to discuss how the locations of indoor and outdoor air samples where determined and what factors found in the field would allow for choosing an alternate location. Indoor samples should be labeled so that they are not tampered with by building occupants and outdoor samples should be placed in areas not frequently occupied and upgradient of the prevailing wind direction.
Additionally, ADEC recommends that ancillary data be collected during sampling events. Ancillary data includes temperature, barometric pressure, indoor/outdoor pressure differential and whether an HVAC system is currently operating. The ancillary data can be used as additional lines of evidence for assessing the potential vapor intrusion risk.
See site file for additional information. |
Louis Howard |
| 3/22/2017 |
Update or Other Action |
2016 Draft Report for Remedial Action Operation and Land Use/Institutional Control at JBER received for review and comment.
The ADEC Contaminated Sites Program online database indicates the site has been adequately
characterized under 18 AAC 75.335 and has achieved the applicable requirements under the
site cleanup rules. Cleanup at the site is complete, subject to a future ADEC determination that
the cleanup is not protective of human health, safety, or welfare, or of the environment. The
USAF has completed cleanup activities at SO508, in accordance with State of Alaska regulation
18 AAC 75. DRO in soil remaining above the ADEC 18 AAC 75.345 Table C and 18 AAC 75.341 Method Two, Table B2 Under 40-Inch Zone, Migration to Groundwater cleanup level is limited to 17 feet bgs and not migrating to groundwater. Additionally, the site is within OU5, which is monitored and addressed under the ERP. Excavation/soil movement restrictions will remain in place at the site (ADEC 2017).
The inspection of Site SO508 revealed no evidence of ground disturbance at this site. Revegetation
appeared to be occurring and the monitoring wells located at the site were observed to be in good condition. Notification signage was present on site and appeared in good condition. Photographs 1 through 6 in Photograph Log A12 present the general condition of Site SO508.
See site file for additional information. |
Louis Howard |
| 8/24/2017 |
Document, Report, or Work plan Review - other |
ADEC supports the Technical Memorandum's recommendation for consolidation of the 28 discrete exposure units and 30 areas of concern into one exposure unit for SS022 (a 46 acre site) for the purposes of the risk assessment for the supplemental Remedial Investigation at SS022. |
Louis Howard |
| 11/30/2017 |
Update or Other Action |
Draft VI report received for review and comment. Building 12755 is located within the buffer zone of a VOC groundwater contamination plume with the depth to groundwater approximately 45 feet bgs. The building is relatively airtight during normal operations. Floor penetrations included concrete floor seams and cracks. No non-VI ambient air COI contaminant sources were identified.
Although TCE was detected in all soil gas samples during FSE1, it was only detected in indoor
air during FSE2. Considering the apparent bias of increased ambient air concentrations during
the winter season (see Section 10.3), the results could indicate the presence of a complete VI
pathway. There is no spatial bias apparent in the locations of COI detections in ambient air or
soil gas.
Based on the above lines of evidence, the VI pathway is considered potentially complete at
Building 12755. The consistent detections of TCE in soil gas, and detections in indoor air during the winter season, suggest VI as a potential source for these contaminants in indoor air.
Building 7535 is located between the ST037 groundwater contamination plume buffer zones of
the SS022 and ST037 Slammer Avenue plumes, with the depth to groundwater approximately
31 feet bgs. The building is airtight during normal operations. Floor penetrations include
multiple floor drains in the kitchen area and a sump in the basement mechanical room.
A neutral sub-slab air pressure gradient (i.e., no measurable pressure difference) was indicated
during soil gas sampling at the single soil gas sample location in the basement mechanical room
(see Table 7.1). The remaining soil samples were collected from near-slab locations.
All TCE detections in soil gas, indoor air, crawlspace air, and outdoor air were at relatively low estimated concentrations. Although TCE was detected in soil gas only in the basement sample,
its presence in soil gas and indoor air during FSE2 suggests the potential presence of a complete VI pathway. Based on the above lines of evidence, the VI pathway is considered potentially complete at Building 7535.
See site file for additional information. |
Louis Howard |
| 1/8/2018 |
Document, Report, or Work plan Review - other |
Draft Vapor Intrusion study received for review and comment.
Main comments were on clarification on how the building survey determination was made that there was a lack of significant ventilation.
See site file for additional information. |
Louis Howard |
| 7/3/2018 |
Update or Other Action |
Milestone Federal Facility Agreement updates: Draft Supplemental Remedial Investigation May 3, 2019, Draft Feasibility Study report October 30, 2019, Draft Proposed Plan September 28, 2020 and Draft Record of Decision February 28, 2021. Signed by EPA, Air Force and ADEC remedial project managers on July 3, 2018. |
Louis Howard |
| 7/26/2018 |
Update or Other Action |
Supplemental RI management plan received for review and comment. Multiple lines of evidence (indoor/outdoor air, plus sub-slab and/or near-slab soil gas) are planned for SS022. Buildings were selected for VI evaluation on prior results and proximity to estimated soil contamination extents and plume boundaries. Active soil gas samples will be collected twice (summer/winter), in coordination with building management and personnel. Sample collection will be consistent with the procedures explained in ADEC, EPA, and JBER SOPs for VI assessment. Near-slab
or sub-slab sample locations will be determined based on the condition of existing probes,
prior analytical results, and site conditions including preferential pathways, security
restrictions and, if present, vapor barriers installed as part of building construction.
See site file for additional information. |
Louis Howard |
| 8/13/2018 |
Document, Report, or Work plan Review - other |
Staff commented on the supplemental remedial investigation plan. Main comments were requesting clarification on whether there were residents in building 8559 since the pathway for vapor intrusion is complete for TCE. Other comments were made on summa gas canisters with a pressure reading of zero - to not have the analytical laboratory analyze those canisters.
See site file for additional information. |
Louis Howard |
| 1/11/2021 |
Document, Report, or Work plan Review - other |
DEC Provided Comments on SS022 Draft RI/RA Report |
William Schmaltz |
| 4/29/2025 |
Document, Report, or Work plan Review - other |
DEC provided comments for the Draft Risk Assessment Work Plan SS022 Remedial Investigation/Feasibility Study Joint Base Elmendorf-Richardson, Alaska, dated April 2025. The work plan describes the methods and parameters for the quantitative evaluation of human health and ecological risks at the former Defense Reutilization and Marketing Office (DRMO) Storage Yard and Current DRMO facility site SS022 located on Joint Base Elmendorf- Richardson (JBER), Anchorage, Alaska. The results of the baseline risk assessment for the site will be used to inform risk management decisions and be conducted as part of the SS022 Remedial Investigation/Feasibility Study Uniform Federal Policy for Quality Assurance Project Plans (UFP-QAPP). |
Ginna Quesada |
